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• US Department ofTransportation Exemption Request Pursuantto Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation December 30, 2015 

### RickyWilliams 

### 169Clancy Cir. Cary, NC 27511

U.S Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulationsfrom: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14CFR 91.7(a); 14CFR91.9{b)(2); 14CFR 91.103; 14 CFR 91.109; 14 CFR 91.1i9(c); 14CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14

### CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuantto the authority contained in 49 U.S.C. 106(f), 40113, and 44701/

Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 {the "Reform Act") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS), Ricky Williams hereby applies for an exemption from the listed Federal Aviation Regulations C'FARs11) to allow commercial operation of Designated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333
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• Commercial operation of an UAS, as described hereinl which are equipped with camera(s) and sensors, would provide professional services in the following areas: 

### 1. Real Estate 2. Aerial Videography I 

### Photography 3. Weddings 4. Bridge Inspections I Flare Stack Inspections 

### 5. Law Enforcement I 

### Fire Rescue 

### 6. Utility Inspections notto limit, 

### Pipelines I Cell Tower's 

### "1. 

### Cinematography 

### I Photography 8. Public I 

### Private Events 9. Construction Sites 

### 10. Search and Rescue 

### 11.**Ne~Ns** 

### Gathering 12. Publicand Private Awareness to irnprove safetyfor currant & 

### future UAS operations within the NAS. 13. Spacial Events 14. Disasterand Catastrophe Events. On or about Sept 25, 2014the FAA granted exemptions to six UAS operators, 

### including Astraeus 

### Aerial. As set 

### forth in Top Shot's FlightOperations and Procedures Manual (the "'FOMPl') and Motion PictureTelevision Operations Manual (both submitted separately under 

### i4CFR 11. 35 (b), RickyWilliams will Adheretothe terms ofthe Astraeus Exemption. 

### RickyWilliams requested exemption would permitthe operation of small, unmanned UAS under controlled And HsterileH conditions in the "outdoor television filming" airspacethat is: 

### (i) limited, (2) predetermined, (3) subjectto controlled access, and (4) provide greater safety in connection with aircraft operations in the Outdoorfilm and television industry. As established bythe exemptions alreadygranted 

### bythe FAA1 approval of 

### Ricky

### Williams exemption would enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities

### to establish requirements for the safe operation of such aircraft systems in the national airspace. Below is an example how leading film organizations feel about using UAS's by aerial production companies; The following is a]statement from Neil Fried, Senior Vice President, Government and Regulatory Affairs forthe Motion Picture Association of America, Inc., "Unmanned aerial systems (UAS) offerthe motion picture and television industry an innovative and saferoption for filming. This newtool for storytellers will allow for creative and exciting aerial shots, and is the latest in a myriad of new

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• technologies being used by our industryto further enhance the viewer experience. We welcomethe FAA's leadership and supporttheir guidance to safely authorize the use of UASsfor the motion picture and television industry." 

### Tllis application 

### is submitted by: 

### RickyWillian1s 

### 169ClancyCir. Cary, NC 27511
Regulations from which the exemption is requested: 

### From whichtheexemption is requested: 14 CFR Part 

### 21 subpart 

### H 14 CFR 45.23 (b) 

### 14 CFR 61 .113 (a) 

### & (b) 

### 14 CFR 91.7 (a) 

### 14 CFR 91.9 (b) (2) 

### 14 CFR 

### 91.103 14CFR 91.109 14 CFR 

### 91.119 (c) 

### 14 CFR 91.121 14CFR91.151 (a) 

### 14 CFR 91.203 (a) 

### 14 CFR 91.405 (a) 

### 14 CFR 

### 91.407 (a) 

### 14 CFR 

### 91.409 (a) 

### 14 CFR 91.417 (a)


### As in Grants of Exemption Nos. 

### i 

### 1062to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112to 

### VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), and 12645to Allied Drones (see Docket No. FAA-20i4-0804), There is enhanced safetyachieved using an unmanned aircraft (UA) with the specifications described bythe petitioner and carrying no passengers orcrew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, givesthe FAA good cause to find that the UAS operation enabled bythis exemption is in the public interest.


### RickyWilliamsWill operate one or more of the Following model UAS

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• DJIInspire**1~** 

### JDRSolo 8X, DYS 0800with the A2 Controller Safety requirements. Theapproval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grantofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAA grantthe requested exemption.
AIRCRAFTAND EQUIVALENT LEVEL OF SAFETEY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhancethe safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhereto when conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:
I.

### The UASwill weigh significantly less than 

### 55 lbs.


### 2. The UAS, depending on the model in operation, will have 

### a maximum operating speed of no morethan 50mph.

3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO).


### 4. Maximum flight time for each operational flight will 

### be depending on the UAS model in operationl but 

### will not exceed 30 minutes. Flights will be terminated at 

### 25°/o battery power reserve or 

### 30 minutes offlight timewhichever occursfirst.


### 5. Flights will be operated at an altitude of no more than 

### 400feet Above Ground Level (AGL) and not morethan 200 feet above an elevated platform from which filming is planned
. 6. Minimum crew for each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO).

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7. The UAS pilot will be a designated Pilot in Command (PIC)
.The PIC will have logged a minimum of 20 hours on the designated UAS. 8. A safety briefing will be performed priorto each day1

### s flights consisting ofall the daysl Production activities. 9. All flight activities will be logged. 1

## o. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. Theflights will occur in Class G airspace no closerthan a mile radius 

### ofthe geographic center/Airport Reference Point (ARP) ofa tower controlled or uncontrolled airport. 12. Flights will not 

### be closerthan 

### a 5 mile 

### radius of the geographic center/Airport.
13. The operatorwill do a pre check of aircraft priorto each flight. And log each • flight.



# • i 4. The operatorwill obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting personswill 

### be allowed within 100feet ofthe flight operationl and the radius may be reduced to 30feet based upon an equivalent level of safety determinationl as U.S. Department of Transportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.
15. The PIC and VO will have been trained in operation of UAS and receive upto date information forthe particular UAS to be operated.

16. The PIC and VO will be ableto communicate byvoice and/or radio at afl times.
17. The PICwill abide byall rules 18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a predetermined location within a designated location and land autonomously.

# • 19. The UAS 

### will have the capabilityto abort a flight in case of emergencies with an automated 11

### Return Home and Land 11 

### function. 20. The UAS will have the capabilityto abort a flight in case of unpredicted obstacles, weather, oremergencies such as low battery.
21. Any incident, accident, orflight operation thattransgressesthe lateral or vertical boundaries ofthe operational area as defined bythe applicable GOA must be reported tothe FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: The operating limitations proposed 

### RickyWilliams provide for a higher level of safety because operations further enhance safety of movie and television filming operations using conventional aircraft. As setforth in the FOPM, the limitations and conditions include: The UASs will weigh less than 55 pounds
• Flights 

### will be operated within line of sight of a pilot and observer Maximum flight time for each flight will be 30 minutes orat 25°/o of battery power reserve whichever comes first. Flights will be operated at an altitude of no more than 400 feet AGL as indicated byonboard GPS system. Minimum crewfor each operation 

### will consist ofthe UAS pilot, the observer. A UAS pilot will be Pilot in Command (PIC). A UAS pilot will be an FAA licensed airman with at least a private pilot's certificate and third class Medical The UAS will only operate within a confined "sterile area" as defined in the FOPM. The FOPM requires the establishment of a "Security Perimeterll for the flight operations area. A briefing will be conducted for Planned UAS operations priorto each day's flight. • All personnel

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• Performing duties within the boundaries ofthe safety perimeter are required to attend. The operator

### will file a FAA Form 7711-1 or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office. The operator will obtain consent of all persons involved in the filming and ensure that only Consenting persons 

### will be allowed within 100feet of the flight operation. The operator

### will submit a written Plan of Activities tothe FSDO three days before the proposed shoot as required in the FOPM. The Pilot and observer must be trained in UAS operations and received current information on the particular UAS to be operated as required by3 the FOPM. The Observerand Pilotwill at all times be ableto communicate byvoice. Written and/ororal permission from the relevant property holders 

### will be obtained
. AJJ required permissions and permits

### wiJJ be obtained from 

### territorial, state! county, or cityJurisdictions, including local 

### law enforcement, fire or other managing governmental agencies. 

### Ifthe UAS loses communications or loses its 

### GPS signal, the UAS will and does have the capabilityto return to a pre-determined location within the Security Perimeter and land safely. The UAS will have the capabilityto abort a flight in case of unpredicted obstacles or emergencies. 14C.F.R. 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61. 113 (a) and (b) limit private pilots to non-commercial operations. Becausethe UAS Will not carry a pilot 

### or passengers, the proposed operations can achieve the equivalent level of Safety of current operations by requiring the PIC operating the aircraftto have a private pilot's license Rather than a commercial pilot's license to operate a small UAS. Unlike a conventional manned aircraftl A UAS 

### is remotely controlled by

### a ground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds thatprovided by a single individual holding a commercial pilot's certificate operating a conventional aircraftfor hire. The risks associated with the use ofa UAS are so diminished from the level of risk

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• associated with commercial operations contemplated by part 61 allowing UAS use by a private pilot as PIC exceeds the present level of safety sought by 

### i 4 C.F.R. 6i .113 (a) ab (b). 14 C.F.R. 91.103: Prefight Action Section 91.103 requires each Pilotto preflight an aircraft before flight to insure the safety 

### offlight. As FAA approved rotorcraft flight manualswill not be used, an exemption is requested. However, an equivalent level of safetywill be provided. The PIC will take actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before each flight 14 C.F.R. 91.119 (c): Minimum Safe Altitudes Section

### 91. 119 establishes safe altitudes for operation 

### of civil aircraft. Section 

### 91 .1 i 

### 9 provides, in Pertinent part, that: "Exceptwhen necessaryfor takeoff or landing, no person mayoperate an aircraft belowthe following altitudes:
....... (c ) Overotherthan congested areas. An aJtitude of 500 feet above the surface, except overopen water orsparsely populated areas. In those cases, the aircraft may not be operated closerthan 

### 500 feet to any person, vessel, orstructure.**'~** Because 

### RickyWUiiatns requests authorityto operate at altitudes only up to 

### 400 feet AGL, an exemption is needed to allow such operations. Exceptforthe limited conditions stated in the FOPM, the UASwill never operate higherthan 400 feet AGL. It will, however, be operated in a restricted areawithin a security perimeter, where buildings and people will not be exposed to operationswithouttheir preobtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well asthe location where it is operated. No flight will be taken without the permission of property owners or local officials. Because ofthe advance notice to the property owners and participants in the filming activity, all affected individualswill be informed ofthe planned flight operations. Compared to theflight operationsfor manned aircraft and the lackof flammable fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating ator below 500 feet AGL
. 

### In addition, 

### the low-altitude operations of 

### the UAS will ensureseparation 

### between a UAS and conventional aircraft.

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• 14C.F.R 91.121 Altimeter Settings Section 91.121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "
... to an elevation ofthe departure airport or an appropriate altimeter setting available before departure." As a UAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level ofsafetywill be achieved bythe operator, pursuantto the FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. 91.151 {a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflyto the first pointof intended landing, and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes 

### " The battery powering the 

### Ricky Williams UASs provides approximately

### 20 minutes of powered flight. To meetthe 30-minute reserve requirement in 14 CFR 91.151, UASflights will be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and its proposed flight area and proposed operationswithin a predetermined location, 

### a longertime frame for flight in daylightVFR 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, lessthan 

### 30 minutes of reserve fuel does not engenderthe type of riskthat 91.151 was intended to address. The owner/operator of 

### Ricky

### Wmiams believesthat safety can be achieved 

### by limiting flights to end with a 

### 25°/o battery reserve as indicated on the PIC's controller mounted monitor. This restriction would be morethan adequate to return the UASto its predetermined landing area. 14 C.F.R. 91.405 (a) (1); 407 (a) (1); 409 (a) (2); 417 (a) and (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 in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter
.....," and others shall inspector maintain the aircraft in compliance with Part 43
. Given thatthese sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections. Maintenance will be accomplished bythe operator. An

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• equivalent level ofsafetywill be achieved becausethe UASs are limited in size, will carry 

### a small payload and operate only in restricted areasfor limited periods oftime. 

### If mechanical issues arise, the UAS can land immediately and will be operating from no higherthan 

### 400 feet AGL. As provided in the FOPM, the operator will ensurethatthe UAS is in working order priorto flight, perform any required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the UAS and best suited to maintain it in an airworthy condition. 

### 14 C.F.A. 91.203 (A) and {8); 91.715 Airworthiness certificates Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless 

### it haswithin it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner**or~** for operation within the United States, the second copy of the Aircraft Registration Application as provided for in§ 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate 

### ora special flight authorization issued under§ 91.715 is displayed atthe cabin orcockpit entrance so

### that it is legible to passengers or crew. A UAS has no certificate nor does it have a cockpit door, Jonathan Russell Sorii is requesting an exemption frorn 

### 91.203 {a) and {b) also 9·1.715.

Pursuantto 

### 14C.F.R. Part 

### 11l the following summary is provided for publication 

### in the Federal Register, should it bedetermined that publication is needed: 

### Ricky Wmiarns seeks an exemption from the following rules: 14 C.F.R. 

### §§ 61.113{a) and (b); 91.103; 91.119(c); 91.121; 91.

### i 51 (a); 91.405(a); 91.407{a)(1); 91.409(a){2); and 91.417(a) and {b); 91.203 {a) 

### and {b); 91.715 to operate commercially

### a small unmanned vehicle {55 pounds or less) in motion picture and television operations. As established 

### by the UAS exemptions already grantedbythe FAA, allowing commercial operations of UASs in the film industrywill enhance safety by reducing risk. Conventional film operations, using turbine aircraft, operate at low altitudes and presentthe risks associated with aircraftthat weigh around 

### 4l000 pounds, and which carry large amounts of

### Jet A fuel. Such aircraft must also fly to and from the film location. In contrast, a UASweighing fewer than 55 pounds and powered by batteries eliminatesvirtually all ofthat risk given the small size and lack of combustible fuel. The UAS is carried, and notflown, to a film set. In

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• this regard, the UAS carries no passengers orcrew andl therefore, will not 

### exposethem to the risks associated with manned flights. The operation of UASs conducted in the strict conditions outlined in the FOPM will provide an equivalent level of safety supporting the grantofthe exemption requested herein. The UASs operate atslow 

### speeds, close to the ground, and in a sterile environment. UAS's also have far less 

### impact on 

### the environment compared to normal filming practices it replaces. As a result, they are far safer than 

### conventional operations conducted with turbine helicoptersflying 

### near the ground and people. Privacy 

### All flights will occur over private or controlled access areaswith the property owner's prior consent and knowledge. Filming will be only of peoplewho have given their consent or otherwise have agreed to be in the areawhere filming will take place. Satisfaction ofthe criteria provided in Section 333 

### ofthe Reform Act of 2012 (size, weight, speed, operating capabilities, proximityto airports and populated 

### ·areas and operation within visual line ofsight and national security) 

### provide more than adequatejustification to grant 

### RickyWilliams requested exemption. If you have anyquestions or need any additional informationl 

### RickyWiUian1s 

### 169ClancyCir. Cary, NC 27511
Sincerely

### yours, 

### RickyWilliams