Aerial Additions, LLC 

John Winter 

22091 E. Alamo Pl. 

Centennial, Colorado 80015 

john@winterlogistics.com

October 3, 2015

U. S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

 Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) 

 & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) 

 & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, Aerial Additions, LLC, developer and operator of Small Unmanned

Aircraft Systems (“sUASs”) equipped to conduct aerial photography for the commercial video

industry, hereby applies for an exemption from the listed Federal Aviation Regulations

(“FARs”) to allow commercial operation of its sUASs, so long as such operations are

conducted within and under the conditions outlined herein or as may be established by the FAA

as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of

small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that

is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety

enhancements to the already safe operations in the aerial filming and monitoring industry

presently using conventional aircraft. Approval of this exemption would thereby enhance safety

and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...

establish requirements for the safe operation of such aircraft systems in the national airspace

system.” Section 333(c) of the Reform Act. 

The petitioner, John Winter is a licensed pilot with experience flying both full sized

aircraft and remote controlled UASs. 

Pilot Certificate #: 3419498
The name and address of the applicant is: 

Aerial Additions, LLC 

John Winter 

Ph: 720-240-8441 

Email: john@winterlogistics.com 

Address: 22091 E. Alamo Pl., Centennial, Colorado, 80015 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation

to consider whether certain unmanned aircraft systems may operate safely in the national

airspace system (NAS) before completion of the rule making required under Section 332 of the

Reform Act. In making this determination, the Secretary is required to determine which types

of UASs do not create a hazard to users of the NAS or the public or pose a threat to national

security in light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated 

• Operation of the UAS within visual line of sight of the operator. \

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may

operate safely in the national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added) A

________________________________________________________________________ 

A - Applicant interprets this provision to place the duty on the Administrator to not only process applications for

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if

it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is defined

under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must

have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if

the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49

USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Aerial Additions, LLC’s sUASs are rotorcraft, weighting 55 or fewer lbs. including

payload. They operate, under normal conditions at a speed of no more than 50 knots and have

the capability to hover, and move in the vertical and horizontal plane simultaneously. They will

operate only in line of sight and will operate only within the sterile area described in the Flight

Safety Manual, attached as Exhibit B (hereinafter “the Manual”). Such operations will insure

that the sUAS will “not create a hazard to users of the national airspace system or the public.” B

Given the small size of the sUASs involved and the restricted sterile environment within

which they will operate, the applicant falls squarely within that zone of safety (an equivalent

level of safety) in which Congress envisioned that the FAA must, by exemption, allow

commercial operations of UASs to commence immediately. Also due to the size of the UASs

and the restricted areas in which the relevant sUASs will operate, approval of the application

presents no national security issue. Given the clear direction in Section 333 of the Reform Act,

the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of

safety surrounding the proposed operations, and the significant public benefit, including

enhanced safety, reduction in environmental impacts, including reduced emissions associated

with allowing UASs for movie and television operations, the grant of the requested exemptions

is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the

requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil

aircraft that have the characteristics and that operate with the limitations listed herein.

These limitations provide for at least an equivalent or even higher level of safety to

operations under the current regulatory structure because the proposed operations

represent a safety enhancement to the already safe movie and television filming

operations conducted with conventional aircraft. 

____________________________________________________________________ 

B Reform Act Section 333 (b). 
These limitations and conditions to which Aerial Additions, LLC agrees to be bound

when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200

feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and

the Camera Operator. 

6. sUAS pilot will be an FAA licensed airman with at least a sport or recreational certificate and

a valid driver’s license. The observer will also hold a valid driver’s license. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS

Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial

Coordinator), that person can also be designated as PIC. 

8. The UAS will only operate within a confined “Sterile Area” as defined in the Manual.

Section C of the Manual requires the establishment of a “Security Perimeter” for the flight

operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s

production activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing. 

10. 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. 

11. The operator will obtain the consent of all persons involved in the filming and ensure that

only consenting persons will be allowed within 100 feet of the flight operation, and this radius

may be reduced to 30 feet based upon an equivalent level of safety determination, as required

by Section F of the Manual. With the advanced permission of the relevant FSDO, operations at

closer range can be approved. (See Section B in the Manual Appendix B) 

12. The operator will submit a written Plan of Activities to the FSDO three days before the

proposed shoot as required in Section C of the Manual. 

13. Pilot and observer will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated as required. 

14. Observer and pilot will at all times be able to communicate by voice. 

15. Written and/or oral permission from the relevant property holders will be obtained. 

16. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies. 

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to

return to a pre-determined location within the Security Perimeter and land. 

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies. 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR §91.203

(a) (1). Given the size and limited operating area associated with the aircraft to be

utilized by the Applicant, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the

Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certificate, upon consideration of the size, weight, speed, operational

capability, and proximity to airports and populated areas of the particular UAS. In all

cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the restrictions and

conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels,

and operates exclusively within a secured area as set out in the Manual. Unlike other

civil aircraft, operations under this exemption will be tightly controlled and monitored

by both the operator, pursuant to the Manual’s requirements, and under the

requirements and in compliance with local public safety requirements, to provide

security for the area of operation as is now done with conventional filming. The FAA

will have advance notice of all operations. These safety enhancements, which already

apply to civil aircraft operated in connection with motion picture and television

production, provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that

there is no credible threat to national security posed by the UAS, due to its size, speed

of operation, location of operation, lack of explosive materials or flammable liquid

fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display on

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less

than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable.
Even though the UAS will have no airworthiness certificate, an exemption may

be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on

which the word “Experimental” can be placed. Given the size of the sUAV, two-inch

lettering will be impossible. The word “Experimental” will be placed on the fuselage in

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV

will see the identification of the UAS as “Experimental.” The FAA has issued the following

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations.

Because the 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 aircraft to have a private pilot’s license rather than a commercial pilot’s

license to operate this small UAS. Unlike a conventional aircraft that carries the pilot

and passengers, the sUAS is remotely controlled with no living thing on board. The

area of operation is controlled and restricted, and all flights are planned and

coordinated in advance as set forth in the Manual. The level of safety provided by the

requirements included in the Manual exceeds that provided by a single individual

holding a commercial pilot’s certificate operating a conventional aircraft. The risks

associated with the operation of the sUAS are so diminished from the level of risk

associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the sUAS as requested with a private pilot as the PIC exceeds

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there will be no airworthiness certificate issued for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist for

determining airworthiness. Given the size of the aircraft and the requirements

contained in the Manual for maintenance and use of safety check lists prior to each

flight, as set forth in Sections C & D, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current 
approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because

there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the

ground control point where the pilot flying the sUAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be

provided for the aircraft an exemption will be needed. An equivalent level of safety will

be provided as set forth in the Manual. The PIC will take all actions including reviewing

weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a

manned free balloon) that is being used for flight instruction unless that aircraft has

fully functioning dual controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional

dual controls. Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications. The FAA has approved

exemptions for flight training without fully functional dual controls for a number of

aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K &

9862A. The equivalent level of safety provided by the fact that neither a pilot nor

passengers will be carried in the aircraft and by the size and speed of the aircraft.

Safe simulation and practice flight will be carried out in controlled environments.

All simulations will be carried out on a computer using the drone controls. Any practice

flying will take place in a safe environment, with no risk to human life below.

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section

91.119 (d) allows helicopters to be operated at less than the minimums prescribed,

provided the person operating the helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL,
or not more than 200 above an elevated platform from which filming is planned, an

exemption may be needed to allow such operations. As set forth herein the UAS will

never operate at higher than 400 AGL. It will however be operated in a restricted area

with security perimeter, where buildings and people will not be exposed to operations

without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of

the UAS as well as the location where it is operated. No flight will be taken without the

permission of the property owner or local officials. Because of the advance notice to

the property owner and participants in the filming activity, all affected individuals will be

aware of the planned flight operations as set forth in the Manual. Compared to flight

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs.

proposed herein and the lack of flammable fuel, any risk associated with these

operations is far less than those presently presented with conventional aircraft

operating at or below 500 AGL in the movie industry. In addition, the low-altitude

operations of the sUAS will ensure separation between these small-UAS operations

and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure

airport or an appropriate altimeter setting available before departure.” As the sUAS

may not have a barometric altimeter, but instead a GPS altitude read out, an

exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the Manual and Safety Checklist, 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 “a flight in an airplane

under VFR conditions unless (considering wind and forecast weather conditions) there

is enough fuel to fly to the first point of intended landing, and, assuming normal

cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At

night, to fly after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 35 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights

would be limited to approximately 20 minutes in length. Given the limitations on the

UAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight or night VFR conditions is

reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin
Corporation to operate without compliance with FAR 91.151 (a)). Operating the small

UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended

to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS

flights to 20 minutes would greatly reduce the utility for which the exemption will be

granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting

flights to 20 minutes or 25% of battery power whichever happens first. This restriction

would be more than adequate to return the sUAS to its planned landing zone from

anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including

Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and

Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

 (b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight

authorization issued under §91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an

onboard pilot. As such, there is no ability or place to carry certification and registration

documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the

ground control point where the pilot flying the sUAS will have immediate access to

them, to the extent they are applicable to the sUAS. The FAA has issued numerous

exemptions to this regulation. A representative sample of other exceptions includes

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.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 of this part and shall between required
inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or

maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. Maintenance will be

accomplished by the operator pursuant to the flight manual and operating handbook

as referenced in the Manual.(See Sections B, D and G) An equivalent level of safety

will be achieved because these small UASs are very limited in size and will carry a

small payload and operate only in restricted areas for limited periods of time. If

mechanical issues arise the UAS can land immediately and will be operating from no

higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the

UAS is in working order prior to initiating flight, perform required maintenance, and

keep a log of any maintenance performed. Moreover, the operator is the person most

familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication

in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

(b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55lbs or less) in motion picture and television 

operations. 

Approval of exemptions allowing commercial operations of sUASs in the film

industry will enhance safety by reducing risk. Conventional film operations, using jet or

piston power aircraft, operate at extremely low altitudes just feet from the subject

being filmed and in extreme proximity to people and structures; and present the risks

associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large

amounts of jet A or other fuel (140 gallons for jet helicopters shown below). Such

aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than

55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced

mass and lack of combustible fuel carried on board. The sUAS is carried to the film set

and not flown. The sUAS will carry no passengers or crew and, therefore, will not

expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict

conditions outlined above, will provide an equivalent level of safety supporting the

grant of the exemptions requested herein, including exempting the applicant from the

requirements of Part 21 and allowing commercial operations. These lightweight aircraft
operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people. 

UASs Details: See Appendix C 

Safety Features: 

• Emergency "Return-To-Home" 

o At the beginning of each flight a home point is set. This home point is 

set in accordance with the manual to allow for a safe take-off and return. 

Should the pilot's control lose signal with the UAS or manually request a 

return, the UAS will return to the starting point. 

Privacy 

All flights will occur over private or controlled access property with the property 

owner's prior consent and knowledge. Filming will be of people who have also 

consented to being filmed or otherwise have agreed to be in the area where filming will 

take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-­

size, weight, speed, operating capabilities, proximity to airports and populated areas 

and operation within visual line of sight and national security - provide more than 

adequate justification for the grant of the requested exemptions allowing commercial 

operation of applicant's UAS in the commercial video production industry pursuant to 

the Manual appended hereto. 

Sincerely 

erial Additions, LLC 

John Winter 
Appendix A: No-Fly Zones

Aerial Additions, LLC’s Pilots will not operating within 5 nautical miles of any

airport. 

As a safety precaution, Aerial Additions, LLC’s pilots will not operating within 5

nautical miles of any airport similar to the permission granted in Exemption No. 11153 -

Regulatory Docket No. FAA20140519, page 25, "20. The UA may not operate within 5

nautical miles of an airport reference point as denoted on a current FAA-published

aeronautical chart unless a letter of agreement with that airports management is

obtained, and the operation is conducted in accordance with a NOTAM as required by

the operators COA. The letter of agreement with the airport management must be

made available to the Administrator upon request." 

As well as in Exemption No. 11195 - Regulatory Docket No. FAA20140884,

page 12, "19. The UA may not operate within 5 nautical miles of an airport reference

point as denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airports management is obtained, and the operation is conducted

in accordance with a Notice to Airmen (NOTAM), as required by the operators

Certificate of Waiver or Authorization (COA). The letter of agreement with the airport

management must be made available to the Administrator upon request." 

Aerial Additions, LLC requests the same flexibility as exemptions 11153 and

11195 for acquiring agreement with the airports' management should operations fall

within 5 nautical miles of an airport. 
Appendix B: Safety Manual 

A. Maintenance 

a. The UAS must be inspected by a factory trained technician every 10 flight 

hours. All maintenance records will be maintained for inspection as set forth in 

Section B. 

b. If any maintenance is undergone, the UAS must pass a flight test with both a 

pilot and a manufacturer trained technician before flight.

B. Record Keeping 

a. A digital record will be kept for all flights, flight times, and maintenance 

records. 

C. Securing Flight Site 

a. FSDO Submissions 

i. The UAS 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. 

b. Safety Parameter 

i. Before filming occurs, a 100 yard perimeter from the planned flight path will be

identified in order to set a “sterile” environment for the operation. 

1. Aerial Additions, LLC must obtain written or oral permission from all 

landowners in sterile environment. 

2. 48 hours before filming, all residents or businesses within 100 yards of 

the filming will be notified with printed flyers. 

a. Flyers will contain date of flight, time of flight, and contact 

information. 

3. Streets and sidewalks that cross into the sterile environment will be 

marked with “Warning Low flying Aircraft - Stay Back 150ft” signs to warn 

the public. 

4. At all times Aerial Additions, LLC will carry $1mm in general liability 

insurance in case of any damage to property or persons within the safety 

parameter 
c. Identify potential obstacles

i. Before each flight, an inventory will be taken for all potential obstacles that 

must be avoided while in flight. Including: 

1. Powerlines 

2. Cell Phone Towers 

3. Trees 

4. Flocks of birds that may take flight 

5. Heavily traveled roadways 

6. Utility wires 

7. Elevated structures 

8. At least 5 nautical miles from the nearest airport or helipad. 

D. Pre-Flight Checklist

a. Take Off Location/ “Home” 

i. The UAS will mark its take off location as a safe area to return to should 

the UAS lose signal with the control or if the pilot signals the craft to return

to its “home” location. 

1. Take off location will be in an area with a 25ft radius with no 

obstructions, maintaining said radius vertically 200ft. 

2. The UAS will take off and land in the same location. 

3. GPS Altimeter will be marked as 0’ elevation 

b. Flight Canceling Events 

i. All flights will be cancelled for a minimum of 2 hours if any of the below 

occur: 

1. Police activity in the area 

2. Low flying aircraft in the area 

3. Medical/News Helicopters active in the area 

4. Wind exceeding 10 mph 

5. Any emergency requiring emergency services occurs within the 

sterile environment 

6. PIC is unable to complete flight without losing visual of the UAS 

7. Any precipitation 

8. Heavy bird presence in the area that could cause a mid-air 

collision. 

9. Any defects or damage found during preflight exam 

c. Physical Inspection 

i. Before each flight the UAS will be checked to ensure that it is safe for 

flight. 

1. Battery voltage will be checked to ensure it is >75% 
2. Blades will be inspected to ensure they are tightened and free of 

damage 

3. Camera mount and gimbal will be inspected to ensure it is fully 

attached and operating. 

4. UAS will be checked for any damage that may have taken place 

in transit. 

5. The UAS will be tested at a low altitude to ensure all controls are 

responding correctly. 

6. Battery checked for damage that could affect its charge 

ii. If any party of the inspecting shows a damaged part or parts, the UAS is

deemed non-usable and must be inspected by a factory trained 

technician.

d. Post Flight Inspections/Checklist 

i. After each flight, the the UAS will be thoroughly inspected for any 

damage that occurred in flight. 

1. Body inspected for any damage 

2. Blades visually checked for any damage at all 

3. Battery checked for damage 

E. Mid-Air Safety Protocol 

a. Max Speed 

i. Accent 

1. 10m/s 

ii. Decent 

1. 4m/s 

iii. Flight Speed 

1. The UAS is never to exceed 10m/s 

b. Altitude 

i. The UAS is never to exceed 400ft 

c. Emergency 

i. If it appears that the UAS, any property or humans are at risk, the UAS 

will be grounded immediately to a safe location. 

d. Sight 

i. The pilot must keep the UAS within eyesight at all times unassisted by 

any technology. 

F. Participation by non-pilot staff 

a. All staff involved in the production or filming using the UAS will consent to 

maintain a safe distance of at least 30 ft during the filming. 

G. Pilot/Spotter Training 

a. Before flying, both the Pilot and spotter will receive updated information on 

the UAS and its firmware. 

b. The controller allows for a simulator training, both the pilot and spotter are

allowed to run through the simulator training.
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Appendix C 

UAS: DJI 

See Appendix D for user manual

Model: Phantom 3 Professional

 S/N: 
17

Appendix D: User Manual
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