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 an d Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CF R Part 21;14 CF 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) & (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 Modern ization 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 c onditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the reques ted exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermine d 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 Tr ansportation’s (the FAA Administ rator’s) respon sibilities to “... establish requirements for the sa fe operation of such aircraft sy stems in the national airspace system.” Section 333(c) of the Reform Act.

The petitioner, John Winter is a licensed pi lot with experience flying both full sized aircraft and remote controlled UASs.

Pilot Certificate #: 3419498The name and address of the applicant is: Aerial Additions, LLC John Winter Ph: 720-240-8441 Email: john@win terlogistics.com Address: 22091 E. Alamo Pl., Centennial, Colorado, 80015

Regulations from which th e 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 fulf ill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. Th is law directs the Secr etary 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 u nder 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, spee d, 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 Secret ary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall estab lish 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 he rein do not fulfill the statutor y requirements for approval.The Federal Aviation Act expres sly grants the FAA the auth ority to issue exemptions. This statutory authority by its terms includes exempting civil airc raft, 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 s ection or any sections 4 4702-44716 of this title if the Administrator finds the exem ption 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 nor mal 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 an d will operate only within the ster ile area describe d in the Flight Safety Manual, attached as Exhi bit B (hereinafter “the Manual ”). Such opera tions will insure that the sUAS will “not create a hazard to users of the nationa l airspace system or the public.” B

Given the small size of the sU ASs involved and the restrict ed sterile environment within which they will operate, the app licant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that th e 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, approv al of the application presents no national secu rity issue. Given the clear directio n in Section 333 of the Reform Act, the authority contained in the Federal Aviation Ac t, as amended; the strong equivalent level of safety surround ing the proposed operatio ns, and the significant pub lic benefit, including enhanced safety, reduction in environmental im pacts, 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 applic ant respectfully requests that th e 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 characte ristics and that operate with the limitations listed herein. These limitations provide for at least an equ ivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancem ent to the already safe mo vie and television filming operations conducted with conventiona l aircraft.

___________________________________ _________________ ________________ B Reform Act Section 333 (b).These limitations and c onditions to which Aerial Add itions, 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 operate d within line of sight of a pilot and/or observer. 3. Maximum total flight time for each operationa l flight will be 20 mi nutes. 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 AG L or, not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operatio n will consist of the sUAS Pi lot, the Visual Observer, and the Camera Operator. 6. sUAS pilot will be an FAA lice nsed airman with at least a spor t or recreational certificate and a valid driver’s license. The observer w ill 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 pr esent on set (i.e. the Aerial Coordinator), that person can al so be designated as PIC. 8. The UAS will only operate within a confin ed “Sterile Area” as defined in the Manual. Section C of the Manual requir es the establishment of a “Sec urity Perimeter” for the flight operations area. 9. A briefing will be conducted in regard to the plan ned sUAS operations prior to each day’s production activities. It will be mandatory that all personne l who will be performing duties within the boundaries of the safety pe rimeter be present for this briefing. 10. The operator will file a FAA Form 7711-1, or its equi valent, as modified in light of the requested exemption, with the appropriate Flight St andards District Office. 11. The operator will obtain the consent of all pe rsons involved in the filming and ensure that only consenting persons will be allo wed within 100 feet of the f light operation, and this radius may be reduced to 30 feet base d upon an equivalent level of sa fety 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 Se ction 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 w ill 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 pi lot will at all times be able to communicate by voice. 15. Written and/or oral permis sion from the relevant prope rty holders will be obtained. 16. All required permissions and permits will be obtaine d from territorial, st ate, county or city jurisdictions, including local law enforcemen t, fire, or other appropriate governmental agencies. 17. If the sUAS loses communicati ons or loses its GPS signal, the UAS will have capability to return to a pre-determined location w ithin 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: Airworthine ss Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Cert ificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operatin g area associated with the aircraft to be utilized by the Applicant, an exemptio n from Part 21 Subpart H meets the requirements of an equivalent level of sa fety 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 exem pt aircraft from th e requirement for an airworthiness certificate, upon consideratio n of the size, weight, speed, operational capability, and proximity to ai rports and populated areas of the particular UAS. In all cases, an analysis of these criteria demo nstrates that the UAS operated without an airworthiness certificate, in the rest ricted environment an d 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, ca rries no explosive material s or flammable liquid fuels, and operates exclusively within a secured ar ea as set out in the Manual. Unlike other civil aircraft, operations under this exemptio n will be tightly controlled and monitored by both the operator, pur suant to the Manual’s re quirements, and under the requirements and in compliance with local public safety requir ements, to provide security for the area of opera tion 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 conne ction with motion picture and television production, provide a greater degree of safe ty to the public and property owners than conventional operations conducted with ai rworthiness certificat es issued under 14 C.F.R. Part 21, Subpart H. Lastly, applicat ion of these same criteria demonstrates that there is no credible threat to national secu rity posed by the UAS, due to its size, speed of operation, location of op eration, 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 ca pital letter "N" and the registration number is displayed on lim ited, restricted or ligh t-sport category aircraft or experimental or provisionally certificated aircraft, the op erator 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 "p rovisional," as applicable.Even though the UAS will have no airworth iness 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 safe ty will be provided by havi ng 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.” Th e FAA has issued the following exemptions to this regulation to Exem ptions Nos. 10700, 87 38, 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 privat e 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 re motely controlled with no living thing on board. The area of operation is controlled and rest ricted, and all fli ghts are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceed s that provided by a single individual holding a commercial pilot’s certificate op erating a conventional aircraft. The risks associated with the operation of the sUAS are so diminis hed from the level of risk associated with commercial operations cont emplated by Part 61 when drafted, that allowing operations of the sU AS as requested with a priv ate 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 requi res that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airw orthiness certificate issued for the aircraft, should this exemption be gr anted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft an d the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Secti ons C & D, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircra ft 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 currentapproved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size a nd 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 main tained by keeping the flight manual at the ground control point where the pilot flying th e 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, 10 167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in co mmand to take certain actions before flight to insure the safety of flight. As FAA approv ed rotorcraft flight manuals will not be provided for the aircraft an ex emption will be needed. An equ ivalent level of safety will be provided as set forth in the Manual. The PI C will take all actions including reviewing weather, flight battery requ irements, landing and take off 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 instruct ion 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 accomplis hed through the use of a control box that communicates with the ai rcraft via radio communications. The FAA has approved exemptions for flight traini ng without fully fu nctional dual controls for a number of aircraft and for flight instruction in expe rimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provi ded 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 co mputer using the drone controls. Any practice flying will take place in a safe environm ent, with no risk to human life below.

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

Section 91.119 establishes safe altitude s for operation of ci vil aircraft. Section 91.119 (d) allows helicopters to be operate d at less than the minimums prescribed, provided the person operatin g the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemptio n is for a sUAS that is a helicopter and the exemption requests author ity 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 need ed to allow such operations. As set forth herein the UAS will never operate at higher than 400 AGL. It wi ll however be operated in a restricted area with security perimeter, w here buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safe ty will be achieved give n 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 ow ner or local officials. Beca use of the advance notice to the property owner and participan ts in the filming activity, all affected individuals will be aware of the planned flight op erations as set forth in th e Manual. Compared to flight operations with aircraft or rotorcraft wei ghting far more than the maximum 55lbs. proposed herein and the lack of flammabl e fuel, any risk associated with these operations is far less than those presentl y presented with conventional aircraft operating at or below 500 AGL in the movi e industry. In additi on, the low-altitude operations of the sUAS will ensure separa tion 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 operat ing an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate al timeter setting available befo re departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be need ed. An equivalent level of safe ty will be achieved by the operator, pursuant to the Manual and Safety Checklist, confirming the altitude of the launch site shown on the GPS al titude 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 wi nd and forecast weather conditions) there is enough fuel to fly to the first point of intende d landing, and, assuming normal cruising speed – (1) During the day, to fly a fter 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 re quirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minute s in length. Given the limitations on the UAS’s proposed flight area and the locati on of its proposed operations within a predetermined area, a longer time frame for f light 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 MartinCorporation to operate without compliance wi th 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 sm all UAS. Additional ly, limiting sUAS flights to 20 minutes would greatly reduce the utility fo r which the exemption will be granted.

Applicant believes that an equivalent leve l of safety can be achieved by limiting flights to 20 minutes or 25% of battery pow er whichever happens first. This restriction would be more than adequate to return the sUAS to its pl anned landing zone from anywhere in its limited operating area.

Similar exemptions have been grante d to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carryi ng 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 ai rworthiness 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 th an 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 displa y 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 ar e applicable to the sUAS. The FAA has issued numerous exemptions to this regulati on. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789 A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 40 7 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircra ft operator or owner “shall have that aircraft inspected as prescrib ed in subpart E of this pa rt and shall be tween requiredinspections, except as provid ed 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 co mpliance with Part 43.

Given that these section and Part 43 appl y only to aircraft with an airworthiness certificate, these sections will not ap ply to the applicant. Maintenance will be accomplished by the operat or 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 ar e very limited in size and will carry a small payload and operate only in restrict ed areas for limited periods of time. If mechanical issues arise the UAS can land immediately an d will be operating from no higher than 400 feet AGL. As provided in th e Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform requ ired maintenance, and keep a log of any maintenanc e performed. Moreov er, the operator is the person most familiar with the aircraft and best suited to maintain the aircra ft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the follo wing summary is prov ided for publication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemptio n 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);91.1 03(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 commer cial operations of sUASs in the film industry will enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, ope rate at extremely low altitude s 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 th e neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel (140 gallo ns for jet helicopters shown below). Such aircraft must fly to and from the film loca tion. In contrast, a sU AS 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 pass engers or crew and, therefore, will not expose them to the risks associat ed with manned aircraft flights.

The operation of small UASs, weighting less than 55 lb s., conducted in the strict conditions outlined above, will provide an equ ivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operatio ns. These lightweight aircraftoperate 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 no t 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 ope rate within 5 nautical miles of an airport reference poi nt as denoted on a current FAA-published aeronautical chart unless a letter of agreem ent with that airp orts management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operators COA. The letter of agreemen t with the airport management must be made available to the Ad ministrator upon request."

As well as in Exemption No. 11195 - Regulatory Dock et No. FAA20140884, page 12, "19. The UA may not operate within 5 nautical mi les of an airport reference point as denoted on a current FAA-publish ed 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 ai rports' 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 fact ory trained technician every 10 flight hours. All maintenance records will be maintained for in spection as set forth in Section B.

b. If any maintenance is unde rgone, the UAS must pass a flight test with both a pilot and a manufacturer traine d 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 th e 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 “steri le” environment for the operation.

1. Aerial Additions, LLC must obtain written or oral permission from all landowners in sterile environment.
2. 48 hours before filmin g, all residents or businesses within 100 yards of the filming will be notified with printed flyers. a. Flyers will contain date of f light, time of flight, and contact information. 3. Streets and sidewalks that cross into the sterile env ironment 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 pe rsons within the safety parameterc

. Identify potential obstacles

i. Before each flight, an inventory will be taken for all poten tial 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 f ound 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 ch ecked to ensure it is >75%2. Blades will be inspected to ensu re 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 in specting shows a damaged part or parts, the UAS is deemed non-usable and must be inspected by a factory trained technician. d. Post Flight Insp ections/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 huma ns are at risk, the UAS will be grounded immediat ely 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 th e production or filming usin g 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 spo tter will receive upda ted information on the UAS and its firmware. b. The controller allows for a simulator training, both the pi lot and spotter are allowed to run through the simulator training.16 Appendix C
UAS: DJI

See Appendix D for user manual
Model: Phantom 3 Professional
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