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# & BigShotAerialImagingLLC 3347 Mount Pleasant RoadNE ·, Dalton, GA 30721 January 10, 2016
U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New JerseyAvenue, SE. Washington, DC 20590 ..J)

Re: Exemption Requestunder Section 333 ofthe FAA Reform Act and Paw 11 ofthe Federal Aviation Regulations 

### o ·Y"<,-

. .,...t Dear SirorMadam:
We are writing pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "ReformAct") and 14 C.P.R. Part 11, Big Shot Aerial Imaging LLC seeks an exemption from Federal Aviation Regulations ("PARs") detailedbelow for the following described Unmanned Aerial System oralike called in this application the UAV System, which includes an Unmanned Aircraft (UA) and ground station-based equipment and crew: THE UNMANNED AIRCRAFT (UA):

• A lightweight (5.3 lb gross weight with all on-board equipment), battery operated 4-motorrotorcraft in the form ofa Quadcopterthat takes offand lands vertically, manufacturedbyDJI, Model Phantom 3 Professional, modified bythe applicant to carrythe following equipment in,flight;



### • An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller;



### • An on-board 4K camera capable ofcapturing imageryin the form offull color, high definition Dstill photos and video;**~-**


### • An on-boardtelemetry system that delivers flight data from the on-board flight computerto the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site;

• A 600mW, 5.8GHz on-boardradio transmitterthat transmits live video from the on-board cameraplus all the flight data from the telemetry system described above; THE GROUND STATION-BASED PART OF THE SYSTEM:

• A Pilotin Command (PIC) in operational control ofa flight operation from beginning to end and who controls the UA while in the air;• A 1OOm W, 2.4GHzradio transmitter/controller operatedbythe PIC to control the UA while in flight;

• A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto a screen for the PIC to view during flight;

• A Visual Observer (VO) is a person who provides a second pair ofeyes to visuallytrack the UA while in flight. The requested exemption would support an application for a commercial Certificate ofAuthorization to use the UAV System to support aerial photography and video primarilyofLarge Scale Construction Project, to conduct land survey, top side building progress and condition, and wide scale documentation of construction conditions and also used for agricultural surveys and real estate. The UA, powered bybatteries, is smaller, lighter and more maneuverable than larger aircraftrunning on combustible fuel, itoperates at lower altitudes with nopeople on board andwill therebyreduce current risk levels and thereby enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly I0 minutes, this offers little orno risk to national security.
Low level oblique photos and video from several angles are far more effective than ground- based imagery for displaying the characteristics oflarge, complexproperties with several buildings and large trees. The applicants in the pasthave chartered 2-seat full-sized helicopters for this purpose, which has proven more costly than manypotential clients have been able 

### to afford. Thebenefits ofreduced cost, reduced noise interference and improved quality ofpresentation from the UA will bevaluable to and benefit many construction professionals as well as community leaders, in the development ofproject site characteristics. The state constmctionbased photography occor in restricted or other areas where access to the public is strictly limited and controlled. Undervirtually all circumstances, all ofthe onlyproperty or structures near the construction sites are owned and operated bythe same entity. As a result, the operation has no substantial impact on any third persons not involved in the actual siteproject. Because Big Shot Aerial Imaging will operate in a sterile area, the UAS will be flown based on visual line-of-sight at altitudes below 400' AGL, and a NOT AM wi11 be issued prior to any flight, the requested exemption provides an equivalent level ofsafety to any requirement for a commercial pilot's certificate. Additionally, we request that we be allowed to use our system to benefit first responders nearbywho might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. The UA V System will be operated in the field withboth a PIC and a VO in accordancewith FAA PolicyN 8900.227 Section·14 "Operational Requirements for UAS" and with the following Restrictions: (a) No flight will bemade with a UA Gross weight exceeding 

### 55 pounds; (b) All operations must occur in .FAA Class G airspace at no more than 400 ft AGL, at an airspeed ofno more than 25 knots andno further than 3/4NM from the PIC; (c) All operations must utilize a visual observer (VO). TheVO and PIC must be able to communicate byvoice at all times during a flight operation; (d) Operations willberestricted to flights overprivate propertywith thepermission of the property owner; (e) The PIC musthave accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51 (b), a minimum oflOO flight cycles and 25 hours oftotal time as a UA rotorcraftpilot and at leastten hours logged as a UA pilot with a similarUA type; 

### (f) All requiredpermits will be obtained from state and local government prior to operation; (g) The UA V System will not be operated over denselypopulated areas; (h) The UAV System will not beoperated at air shows; (i) TheUA V System will not beoperated over any open-air assembly ofpeople; 

### G) The UAV System will notbe operated overheavily trafficked roads; (k) The UA V System will notbe operated within 

### 5 NM ofan airport orheliport; (1) The UA V System will notbe operated overproperties without property owner representationin observance (m) Operations will be restricted to day onlyand weather conditions equivalent to VFR; (n) The PIC will briefthe VO andproperty owner aboutthe operation and riskbefore the first flight at each new location; (o) No flight maybe made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe for flight (see Appendix A). ThePIC andVO will meet the requirements outlined inFAA PolicyN 8900.227 Section 16 personnel Qualifications. Additionally, the PIC andVO will perform maintenance on the system and will complete a course ofmaintenance instruction as part oftheir initial training.We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (o) listed above, the FAA can have full confidence thatthe operation will have an equivalent or greater level ofsafetythan manned aircraft performing the same mission. The name and contact information ofthe applicant ar:e: Big Shot Aerial Imaging LLC, 3347 MountPleasant Road, Dalton, GA 3072I, (706) 980-9287. Email: dan@bigshotaerialimages.com The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendumupon which each maybe found together with ourproposed equivalent level ofsafety for each regulation:

- I4 CFR Part 2I

........................................Addendum Page I

- 14 CFR91.203

.........................................Addendum Page I

- 14 CFR 45.23, 45.29

................................Addendum Page 2

- 14 CFR 91.9

.............................................Addendum Page 2

- I4 CFR 61.113, 61.133

............................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.12l..

.............Addendum Page 3

- 14 CFR91.15 1..

.......................................Addendum Page 4

- 14 CFR Subpart E (91.401- 91.4I7)

......Addendum Page 4 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum Page 4 We are prepared to modify or amend anypart ofthis request to satisfythe need for an equivalent level ofsafety. Please contact us at anytime ifyou require additional information orclarification. We look forward to working with your office. Sincerely, Daniel M, Ursitti President, Big Shot Aerial Imaging LLCAddendum containing Exemption Requests and Equivalent Level ofSafety Appendix A- Flight Manual Appendix B Owner's Manual for UA ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 14 CPR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to workto develop airworthiness standards for UnmannedAerial Systems, werequest an experimental certificatebe issued for the CAV System under either orboth ofthe following provisions: 21.191 Experimental certificates.0 Experimental certificates are issued for the following purposes:O(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, ornew uses for aircraft.0 

### (b) Showing compliance withregulations. Conducting flight tests and otheroperations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliabilityrequirements ofthe regulations. Since the experimental certificate can beused for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate wouldpermit our commercial purpose as well. The aircraft will not carrypersons orproperty, will not carry fuel, and will onlyfly under strict operational requirements. Combined with the UA's light weight, being constructed primarily ofcarbon fiber and plastic, wepropose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CPRPart 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafetyoutlined in the previous paragraph. 14 CPR 91.203(a) & (b) Civil aircraft: Certifications required. Theregulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of5.3 pounds, the UA is too small to carry documentation, does nothave an entrance, and is not capable ofcarryingpassengers orcrew. To obtain an equivalent level ofsafety and meet the intent of91.203, wepropose that documentsdeemed appropriate for this aircraftbythe FAA will be co-located with the crew at the ground control station and available for inspection upon request. 

### In order to identifythe aircraft, wepropose that the information found on airworthiness and registration certificates bepermanentlyaffixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to

Addendum Page 1of4 satisfy the requirement of 14 CFR45.23, which follows immediately after the proposed placard description below: EXPERIMENTALManufacturer: DJI Innovations, lnc.950 E Baseline Ave. Ste. 210 Apache Junction AZ 85119 Model: Phantom 3 Professional, Serial Number: P76DCF17016857 Iffound please contact: (706) 980-9287. 14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, orpilot station. The UA does not have an entrance inwhich the word "EXPERIMENTAL" can be placed, andhas a registration number assigned to it bythe FAA: N-Number N715BS
We propose to achieve an equivalent level ofsafetyby including the word "EXPERIMENTAL" in the placard onthe top ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanentplacard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display atthe ground station a high contrast flag orbannerthat contains the words "UnmannedAircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should bevisible to anyone that observes the aircraft and chooses to investigate its point oforigin. 14 CFR 91.9 Civil aircraft flight manual, marking, and placardrequirements. This regulationprovides thatnoperson may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not onlytoo small to carry documentation, the documentation wouldnotbe available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that acurrent, approved UA Flight Manual (Appendix A) mustbe available to the crew at the ground station anytime the aircraft is in, orpreparing for, flight.
14 CFR 61.113 Privatepilotprivileges and limitations: Pilot in Command and 61.133 Commercial pilotprivileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilotin command ofan aircraft for compensation orhire. Subparagraph (b) allows a private pilot to act as pilot in command ofan aircraft in connection with anybusiness oremployment if: (1) The flight is only incidental to thatbusiness oremployment; and (2) The aircraft does not carrypassengers orproperty for compensation orhire. Addendum Page 2 of4
Ourproposed operations require thatthe PIC must either 1. Hold a Commercial Pilot Certificate issued bythe FAA, and have logged 25 hours of flight experience in this type ofUA, or
2. Meetthe requirements of8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAAprivate pilot ground instruction" and pass "the FAAPrivate Pilotwritten examination." Since there are currently no means available for thepilot ofa UAS to gain the experience in an equivalent category and class in orderto apply for a commercial pilot's license, we propose to generate an equivalent level ofsafetybyrequiring ourpilots to complete, at a minimum, FAAcommercial pilot ground instruction and pass the FAA Commercial Pilotwritten examination in addition to completing the private pilotrequirements. Since the aircraft cannot carrypassengers orproperty, we feel we meet the intent of61.113 Subparagraph (b) eventhough the intent ofthis application is to conduct a business.
14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is beingused for flight instruction unless that aircraft has fully functioning dual controls." The CA V System ground-based control station consists ofa small hand-held radio transmitter and while it does not offer a second set of"controls", both the student and instructor can, and will, operate the single setofcontrols simultaneously. Withboth student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level ofsafety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparselypopulated areas the aircraft cannotbe operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of400 feet AGL, we cannot complywith this requirement.

### In orderto provide an equivalent level ofsafety we will only fly overprivate property with a size ofat least two acres with the permission ofthe owner ofthe property flown over. The aircraft will notbe operated over congested areas orover any open air assembly ofpersons. The propertyowner will be briefed on the expectedroute offlight and the associated risks to persons andproperty on the ground. The aircraft will be operated at a low altitude allowing, ifa powerunit fails, an emergency landing without undue hazard to persons orpropertyonthe surface. Therefore we maintain that due to the small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes byreference to an altimeter setting available within 100 NM ofthe aircraft. The UA will always fly below400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoffpoint is transmitted via radio from the UA onboard computer to the display screen held bythe PIC, providing a constantlyupdated AGL readout. Addendum Page 3 of4
14 CFR 91.151 Fuel requirements for flight in VFRconditions. The regulation provides that no person maybegin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for at least 30 minutes.
We feel the intention ofthis paragraph is to provide an energyreserve as a safetybuffer for delays to landing. The UA is battery operated andthe maximum duration offlight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4 NM from the point ofintended landing, a full batterycharge at launch will ensure that we meet the reserve energyrequirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR Subpart E (91.401

- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Itis our intention thatthe PIC perform maintenance and inspection ofthe aircraft and ''be authorizedto approve the aircraft for return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections andupdating software and firmware for the onboard computer. All other maintenance will beperformed bythe manufacturer ortheir designated repair facility. The PIC will document workperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety. 8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) ObserverMedical. This policyprovides that both the PIC and VO must have a valid FAA second-class medical certificate issued underpart 67 in orderto perform as a pilot orobserver. The UA maximum gross weight is 5.3 pounds, it is constructed ofcarbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site oflaunching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carryingpassengers in a large aircraft is an unnecessaryburden. We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.
Addendum Page 4 of4 APPENDIX A- FLIGHT MANUAL FLIGHT RESTRICTIONS (a) No flight will be made with a UA Gross weightexceeding 55 pounds; (b) All operations must occur in FAA Class G airspace atno more than 400' AGL, at an airspeed ofno more than 25 knots and no further than 3/4 NM from the PIC; (c) All operations mustutilize a visual observer (VO). The VO and PIC mustbe able to communicate verbally at all times during a flight operation; (d) Operations will be restricted to flights overprivate property with the permission of the property owner; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; (f) All required permits will be obtained from state and local government priorto operation; (g) The CAV System will not be operated overdenselypopulated areas;' 

# .

(h) The CA V System will not be operated at air shows; (i) The CA V System will not be operated over any open-air assembly ofpeople; 

### G) The CA V System will not be operated over heavilytrafficked roads; (k) The CA V System will notbe operated within 5 NM ofan airport orheliport; (1) The CA V System will not be operated overproperties smallerthan two acres in stze; (m)Operations will be restricted to day only and weather conditions equivalent to VFR; (n) The PIC will briefthe VO andproperty owner about the operation andrisk before the first flight at eachnew location; (o) No flight maybe made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain that the UA is in a condition safe for flight. PRE-FLIGHT CHECKLIST 

### (1) Use voltmeter to determine that UA battery is fully charged in order to prevent unexpectedpremature descent; (2) Check all wiring connections are tight;(3) Check all propellers are undamaged and no cracks exist in any structural members oftheUA; (5) Tum on radio controller, check for adequate voltage, set it to connectto the UA, move all control switches to forward ordown position andthrottle control stick full backposition; (6) Connect UA main battery, check for radio contact with UA's radio receiver; (7) At a location different from previous flight, re-set GPS and compass to current location; (8) Tum on transmitter, gimbal and camera.January 10,2016
U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE., Washington, DC 20590 

## BigShotAerial ImagingLLC 3347 Mount Pleasant Road NE Dalton, GA 30721

Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(I); 91.409 (a)(1) and (2); 91.417(a) and (b). Dear Sir orMadam:
We are writingpursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "ReformAct") and 14 C.F.R. Part 11, Big Shot Aerial Imaging LLC an operator ofUnmanned Aircraft Systems ("UASs") for aerial photography in the Architectural Engineering and Construction industry as well as the motion picture and television industry, hereby applies for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation ofits UASs. On or about September 25, 2014, the FAA granted exemptions to six UAS operators, including Astraeus Aerial (the "Astraeus Exemption"). As set forth in Big Shot Aerial Imaging LLC's Flight Operations and Procedures Manual (the "FOPM") submitted under 14 CFR 11.35(b)), Big Shot Aerial Imaging LLC will adhere to the terms ofthe Astraeus Exemption. Low-level oblique photos and video from several angles are far more effective than ground- based imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants in the pasthave chartered 2-seat full-sized helicopters for this purpose, which has proven more costly than manypotential clients have been able to afford. The benefits ofreduced cost, reduced noise interference and improved quality ofpresentation from the UAS will be valuable to andbenefit many construction professionals as well as community leaders, in the development ofproject site characteristics. The site construction based photography occurs in restricted or other areas where access to the public is strictlylimited and controlled. Under virtually all circumstances, all ofthe onlyproperty or structures near the construction sites are owned and operated bythe same entity. As a result, the operation has no substantial impact on any third persons not involved in the actual site project Big Shot Aerial Imaging LLC's requested exemption would permit the operation ofsmall, unmanned UAS under controlled and "sterile" conditions in and on Construction Site Projects and in motion picture and television airspace that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safetyin connection with aircraft operations in the film and television industry and or Construction Site Projects. As established bythe exemptions already granted bythe FAA, approval of Big Shot Aerial Imaging LLC exemption would enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish



### --------------------------------------------------------------------------------------------------------------------------------··---requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: Big ShotAerial Imaging LLC Attn: Daniel M. Ursitti.; Ph: 706-980-9287 Email: dan@bigshotaerialimaging.com 3347 MountPleasant Road NE, Dalton, GA 30721 Regulations from whichthe exemption is requested: 14 CPR 61.113(a) and (b)
14 C.P.R. 91.103 14 C.P.R. 91.119 14 C.P.R. 91.12114 CPR 91.151(a) 14 CPR 91.405(a) 14 CPR407(a)(l) 14 CPR 409(a)(2) 14 CPR417(a) and (b) UASs operated byBig ShotAerial Imaging LLC weigh less than 55 pounds, including thepayload (i.e. camera, lens, and gimbal). They operate at speeds ofno more than 50 knots, can hover, and can simultaneouslymove vertically andhorizontally. Big Shot Aerial Imaging LLC will onlyoperate its UASs in line ofsight andwill operate only within the sterile area described in the POPM. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system or the public." Given the small size ofBig ShotAerial Imaging LLC's UASs and the restricted sterile environmentwithin which theywill operate, Big Shot Aerial Imaging LLC's UAS operations adhere to the Reform Act's safetyrequirements. Additionally, due to the size ofthe UASs and the limited areas in which they will operate, approval ofthis application presents no national securityissues. Based on the substantial level ofsafety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant ofthe requested exemption is in the public interest. Accordingly, Big Shot Aerial Imaging LLC's respectfully requests that the PAA grant the requested exemption without delay. 

### PIC Qualifications Daniel M. Ursitti, ATP Helicopter/RotorcraftHelicopter Commercial Privileges: SEL Ratings Type: B737, 

### GN, CE500, N265, CL604, SK76, DA50 Medical: 1st Class Restrictions: Mustwear corrective lenses Experience: Commercial pilot since May 25, 1979 with total time of 18,700 hours (17,000 is PIC) UA V Systems: 25 years mostly recreational 

### AircraftAnd Equivalent Level OfSafety The operating limitations proposedbyBig Shot Aerial Imaging LLC provide for at leastan equivalent orhigher level ofsafetybecause operations further enhance safety ofmovie and television filming using conventional aircraft.
As set forth in the FOPM, the limitations and conditions include: D 

### 1. The UASs will weigh less than 55 pounds 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% batterypowerreserve shouldthat occurpriorto the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL, and not more than 200 feet above an elevatedplatform from which filming is planned. 5. Minimum crew for each operation will consist ofthe UAS Pilot, the Visual Observer, andthe Camera Operator. 6. A UAS pilot will be an FAA licensed airman with at least a private pilot's certificate andthird class medical. 7. A 

### VAS Pilot will be Pilot in Command (PIC): Ifa pilot certificate holder other than the UAS Pilot, who possesses the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), thatperson can also be designated as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in the FOPM. The FOPM requires the establishment ofa "SecurityPerimeter" for the flight operations area. 9. A briefing will be conducted for plannedUAS operations priorto each day's flight. All personnel performing duties within the boundaries ofthe safety perimeter are required to attend. 10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light ofthe requested exemption, withthe appropriate Flight Standards District Office ("FSDO"). 11. The operatorwill obtain consent ofall persons involved in the filming and ensure that onlyconsenting persons will be allowed within 100 feet ofthe flight operation. This radius maybereduced to 30 feet basedupon an equivalent level ofsafety determination, as required under the FOPM. With the advanced permission ofthe FSDO, operations at closer range can be approved. 12. The operatorwill submit a written Plan ofActivities to the FSDO three days before the proposed shoot as required in the FOPM. 13. The Pilot and observer mustbetrained in UAS operations andhave received current information on the particularUAS to be operated as requiredbythe FOPM. 14. The Observer andpilot will at all times be able to communicatebyvoice and/or text. 15. Written and/or oral permission from the relevant propertyholders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county, or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre-determined location within the Security Perimeter andland. 18. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles or emergencies. 14 C.F.R. § 61.113(a) and (b): Private Pilot 

### Privileges and Limitations:
Pilotin Command Sections 61.113 (a) and (b) limitprivatepilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafetyofcurrent operations byrequiring the PIC operating the aircraftto have a privatepilot's license rather than a commercial pilot's license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is remotely controlledby a ground-basedoperator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds thatprovidedby a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated withthe use ofa UAS are so diminished from the level ofrisk associated with commercial operations contemplatedby Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level ofsafety soughtby 14 C.F.R. §61.113 (a) and (b). 14 C.F.R. § 91.103: Preflight Action Section 91.103 requires eachpilot to preflight an aircraft before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level ofsafetywill be provided. The PIC will take all actions, including reviewing weather, flight batteryrequirements, landing and takeoffdistances, and aircraftperformance data before commencement offlight.
14 C.F.R. §91.119(c): Minimum Safe Altitudes
Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 provides, inpertinentpart, that: "exceptwhen necessary for takeoffor landing, no person may operate an aircraftbelow the following altitudes:

..... (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparselypopulated areas. In those cases, the aircraft may notbe operated closerthan 500 feet to anyperson, vessel, vehicle, or structure."
Because Big Shot Aerial Imaging LLC requests authority to operate at altitudes onlyup to 400 AGL, and notmore than 200 above an elevated platform from which filming is planned, an exemption is neededto allow such operations. Except for the limfted conditions stated in the FOPM, the UAS will never operate higher than 400 AGL. It will, however, be operated in a restricted area within a securityperimeter, where buildings and people will not be exposed to operations without theirpre- obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofproperty owners or local officials. Because ofthe advance notice to the property owners and participants in the filming activity, all affected individuals will be informed ofthe planned flight operations. Comparedto flight operations for manned aircraft and the lack offlammable fuel, anyrisk associatedwith the proposed UASoperations is far less than conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between a UAS and conventional aircraft.
14 C.P.R. §91.121 Altimeter Settings Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As a UAS maynot have a barometric altimeter, butinstead a GPS altitude data, an exemption is needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the FOPM and Safety Check list, confirmingthe altitude ofthe launch site shown on the GPS altitude indicatorbefore flight.
14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly after that for at least 30 minutes

...." The batterypowering the Big Shot Aerial Imaging LLC UASs provides approximately 18 minutes ofpowered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAS flights will be limited to approximately 10 minutes in length. Given the limitations on the 

### VAS's proposed flight area and its proposed operations within a predetermined location, a longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the UASs in a tightly controlled area where only people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes ofreserve fuel does not engender the type ofrisk that §91.151(a) was intended to address. Big Shot Aerial Imaging LLC believes that safety canbe achieved by limiting flights to 10 minutes or 25% ofbatterypower, whichever occurs first. This restriction wouldbe more than adequate to return the UAS to its pre-determined landing zone from anywhere in its limited operating area. Big Shot Aerial Imaging LLC is not seeking an exemption for nighttime UAS operations. 14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner shall "have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter

...," and others shall inspect ormaintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to Big Shot Aerial Imaging's operations. Maintenance will be accomplished bythe operator. An equivalent level ofsafety will beachievedbecause the UASs are limited in size, will carry a small payload and operate onlyin restricted areas for limitedperiods oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the operator will ensure thatthe UAS is in working orderpriorto flight, perform any :required maintenance, and keep a log ofanymaintenanceperformed. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition. Summary for Publication
Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should itbe determined thatpublication is needed: Big Shot Aerial Imaging LLC seeks an exemption from the following rules:
14 C.F.R. §§ 61.113(a) and(b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a small unmanned vehicle 

### (55 pounds orless) in motion picture and television operations. As established bythe UAS exemptions already grantedbythe FAA, allowing commercial operations ofUASs in the film industry will enhance safetybyreducing risk. Conventional film operations, using turbine aircraft, operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, and which carry large amounts ofJet A fuel. Such aircraft must also fly to and from the film location. In contrast, a UAS weighing fewer than 

### 55 pounds and powered bybatteries eliminates virtually all ofthat risk given the small size and lack ofcombustible fuel. The UAS is carried, and not flown, to a film set. Inthis regard, the UAS carries no passengers orcrew and, therefore, will not expose them to the risks associated with manned**fligh~s.** The operation ofUASs conducted in the strict conditions outlined in the FOPM will provide an equivalent level ofsafety supporting the grant ofthe exemption requested herein. The UASs operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far saferthan conventional operations conducted with turbine helicopters carrying fuel and flying nearthe ground and people. Privacy All flights 

### \JVill occur overprivate or controlled access areas with the property owner's prior consent and knowledge. Filming will be onlyofpeople who have given their consent orotherwise have agreed to be in the area where filming will take place. Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security) provide more than adequate justification to grant Big ShotAerial Imaging LLC's requested exemption, allowing for Big ShotAerial Imaging LLC's UAS commercial operations for the construction industry, motion picture and television industrypursuant to the FOPM included herewith.Ifyou have any questions orneed ahy additional infonnation, please contactthe undersigned at 706-980-9287 or at dan@bigshotaerialimaging.com.

Sincerely yours,

Daniel M. Ursitti President, Big Shot Aerial Imaging LLC

# BIG SHOT 

# AERIAL IMAGING

Unmanned Aerial Systems Operations Manual

January 2016 Version 2.2

### Preface The following procedures are intended to promote safe, efficientand lawful operation of Big Shot Aerial Imaging's unmanned aerial system. The primary concern during any operation of Big Shot Aerial Imaging's UAS is safety. Any operations must comply with all safety and boundary limitations in order to proceed. Big Shot Aerial Imaging is dedicate to bringing safe and lawful operation of unmanned Aviation systems into the Architectural, Real Estate and Construction Agriculture Communities. With their use, Project managers are able to pre-program logistic matrixes to minimize impact on local communities, survey development location for information modeling, document progress and development in full perspective and inspect general scope and facilities for compliance. Additionally, project safety officers are able to get first hand perspectives in the event of out of reach incidents to make properresponse decisions.
While operating UAS Big Shot Aerial Imaging will abide by all FAA Regulation for flight and receive proper authorization for Flight.
UAV operators and observers will ensure and will be held accountable for ensuring that operations of the UAS do not intrude on any individuals privacy and that operation will be strictly for the purpose of the Construction project site and its boundaries We will do this by: While in flight on board camera and capture device will only focus on and within the boundaries ofthat specific work site. All video ofstill images from such flight will pass post flight inspection to ensure and contain any images that might have inadvertentlybe capture. All non-sites related images will be destroyed. All flight operation will be documented and approved by site operations director and recorded within the site register. Flight operators will stay current on new technologies to ever increase·safety and standards. 

### Administration Operations Manual The policies and procedures contained in this manual are issued by Big Shot Aerial Imaging and are compiled from a number of sources to best define and apply standards so to best ensure safe operation. This manual is not intended to be all-inclusive, but as a supplement to federal Aviation Administration regulations UAS manufactures approved flight manual and other regulatorymaterial.This manual was intended to be as current and inclusive at of UAS operations at the time it was drafted. Material will beupdated and released as amendments or versions upon delivery. 

### Personnel and Responsibilities Operator Maintain all training, flight and maintenance records for the operations Team and airframe. Replace or repair all worn orbroken parts only withmanufacture approved and distributed parts. Suchrepairs orreplacements will be conducted and logged in the aircrafts maintenance log by a certifiedtechnician ofthat manufacture. Operator must maintain a current class II flight Physical and have demonstrated proficiency on the UAS airframe. Operators will have sufficient expertise to perform the task ofinteracting with AirTraffic Control. Operators must have and understanding of, and complyto FAA and Military regulations applicable to the airspace where the UAS will operate. Safe and effective operation ofthe UAS is the operators' primary duty and to do so in accordance with FAA and manufactures approved flight manuals. Operators will be required to take periodic UAV flight training.
Observer Observers must be able to communicate clearly and directly to the operator anyturning or avoidance instructions required to stay clear ofany obstructions. Observer's primary duty is to operate camera as well as maintain and monitor surrounding airspace and on ground occurrences. Observer will monitor flight information in regards to safe and compliant distances and altitudes andreport such information to the operator. Observerwill monitor onboard systems such as power consumption, flight time remaining and radio transmission strength. Observers will be required to take periodic flight operations training. 

### Safety Big ShotAerial Imaging will support safetytraining and awareness programs. Additionally, regular audits ofsafety policies, procedure andpractices will be conducted. Monitoring ofthe UAS communityto ensure best safetypractices are incorporated into our standard operations. Operators and observers will never operate outside ofmanufacture recommendation, FAAregulations or weather constraints. Operation ofUAS will operate within the geofence and boundaries ofsuch construction site. All groundpersonal will be alerted to flight path and operation ofthe UAS. Any and all occurrences will be reported to construction site manager immediately. All potential operational hazard orinterference will bereported to construction site manager as well as Big Shot Aerial Imaging supervisors. No flight will be conducted until hazard has been removed or rectified. Communicate all reported safety related problems and the corrective action taken. 

### Medical Factors Operators and Observers shall only deploy the UAS when rested and emotional prepared for the task at hand. Physical illness, exhaustion, emotional problems, etc., can seriously impair judgment, memory and alertness. The safest rule is not to act as an operator or observer when suffering from any ofthe above. Persons are expected to stand down and postpone flight when these problems could reasonablybe expected to affect their ability to perform flight duties. All crew shall make a self-assessment ofphysical condition during pre-flight activities. Performance can be seriously hampered byprescription and over the counter drugs. Ifit is determined bycrew or self-assessment that medication taken could hamper operation and observation that crew member will be prohibited to continue for that deployment. No crew person shall act as an operator or an observer within eight hours after consumption ofany alcoholic beverage, while under the influence of alcohol. Orwhile having a concentration of0.04 (FAR 91.7) 

### Training The keyto continued safe operations is bymaintaining a professional level ofcompetency. The first step in this process is establishing minimum qualifications and then keeping up with continued flight training and regulations. Operators will enroll in appropriate training(fixed wing) in order to obtain theirprivate pilot license/certificate. Observers will complete sufficient training to communicate to the pilot Operator and observer will have sufficient knowledge ofair traffic and radio communications, including the use ofapproved ATC/pilot 

### General Operating Procedures UAS flight will onlybe made when a request has been made and approved bythe project site manager. UAS will only operate under VFR guidelines. UAS crew will only deploy ifweather conditions that are within manufactures recommendations. Flight crew will only deploy UAS after completion ofpreflight checklist UAS will onlybe used within the boundaries ofthe given and documented project site and at a maximum altitude of400 feet perthe FAA COA. UAS operator will have in theirpossession a VFR Terminal Area Chart of the project areas to determine airspace designation and ATC**'I~** ' I ,.,. 

### interaction. Ariy requests from ATC orlocal towers will be made in advance offlight and flight plans will be filed as such. The Minimum personnel required on all flight with are an Operator and observer. The operator is directly responsible fro, and is the final authority over the actual operations ofthe UAS. Operators have the absolute authority to reject a flight based on personal safety or violation ofFAAregulation. No mater the instructions from a project manager. Operators are responsible for compliance with this manual and FAAregulations. Operator shall see and avoid any obstacle that will lessen safety during flight. Operators shall be responsible for documentation for mission training and updating offlight books. Observer shall see and avoid any obstaclethat will lessen the safetyduring flight. Observer shall operate any attachment to the UAS, allowing the operator to maintain complete focus on the operation ofthe UAS. Observers shall assist operators in the main objective ofsafe operation ofUAS. 

### Personal Equipment Operators /Observers shall wear proper eye protection at all times while UAS is in Flight. Depending on conditions Operators /Observers will wear polarized sunglasses

## BIG SHOT AERIAL IMAGING LLC Flight Checklist and Procedures
Pre-Operation Planning

o Set flight time and duration with project manager Project. o CheckDistance to nearest Airport and or controlled airspace using currentFAA Sectional Aeronautical Chart. Ifwithin 5NM required procedures need to be followed. o Pre-Contact local ATC ifrequiredto inform ofUAS operation. Adjust flight as instructed. o CheckAircraft for anyvisible damage or loose part. 

### o Gently shake to insure no internal parts are loose. o CheckProps for cracks ordamage (replace 

### if needed) o Charge Aircraft and Camera Batteries. Pre-Operation Check 1. Visually determine ifflight area is clear ofany obstruction orpublic spaces. 2. Visually determine weather conditions are ideal for flight. IF RAIN, CLOUD COVERORHIGH WIND EXSIST ABORTFLIGHT. 3. Ifrequired, use VHF aviation Transceiver to contact tower if closerthan 5NM. 4. Inform tower/CTAF ofUAS ops, location and Maxheight offlight. Pre-Flight Check 1. Place aircraft case on level surface. 2. Remove Radio Controller 3. Checkfor that all controls are free and operational. 4. Checkbattery. 5. Remove Aircraft 6. Checkfor any damage, loose parts a. Landing Skids b. Props c. Prop Nuts d. Battery door 7. CheckGimbal for free, clear and smooth operation. 8. Checkcamera is secure and functioning 9. CheckAircraft battery with voltage tester. (Do not use battery with percentages of charge lower than 90%) 10. Place UAS in clear and safe launch area. 11. Place all Radio transmitter toggles to full up position. 12. Center flight control 13. Place throttle control in full down position (No throttle in) 14. Turn Controller on 15. Place battery into Aircraft 16. Close and secure battery door 17. Aircraft will make and AUDIBLE alert ofpoweringup 18. Indicator Light will run a diagnostic pattern to determine satellite connection and compass calibration. (If light indicate re calibrate compass using manufactures compass calibrationprocedure)
19. Once aircraft cycle through diagnostics it will indicate as to flight readiness. 20. Check area for any activity and announce CLEARAREA. 21. Raise throttle to 10% powerto engage engines. 22. Checkand listen for smooth operation orno presence ofgrinding noise. 23. Checkoperation ofgimbal movement. 24. Engage throttle to 52% power 25. Lift off
After lift off Hover aircraft at 1Oft Checkoperation ofcontrol Front Back Left Right Rotation (L/R) Proceedwith FlightLanding check 1. Clear landing area 2. Return aircraft to above landing area 3. Hover at 30ft 4. Announce CLEARFOR LANDING 5. Slowly decrease power till Aircraft is descending. 6. Hold throttle stick at descending position 7. Once aircraft is down, Disconnect and remove battery from Aircraft 8. Turn ofpower to controller 9. Notify Tower ofcomplete operation
End ofOperation o Return Aircraft and controllerto case o Markbattery as used

# Phantom 2 Vision 

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### ·,_ If 

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