Peak 3 LLC, Anchorage, AK - Section 333 Exemption Petition Page 1 September 9, 2015 U.S. Department of Transportation Washington DC 20590 Re: Request for Additional Information - Peak 3 LLC (Docket No. FAA-2015-2406)
Dear Sir or Madam, I, Zachary Melms, Managing Member of Peak 3 LLC, am writing to provide the additionally requested information pertaining to Peak 3 LLC’s request for a Section 333 Exemption. The additionally information requested is as follows:
1. Describe the aircraft make(s), model(s), and type(s) (i.e., fixed

- wing, rotorcraft, lighter

- than

- air) for the proposed UAS operation. The description(s) should include the maximum weight (including payload). This information can be located in the aircraft manual(s). Response: The aircraft proposed include: #1 Make: DJI Inspire 1 Model: T600 Type: Rotorcraft Maximum Weight: 2940 grams #2 Make: DJI Phantom 3 Professional Model: n/a Type: Rotorcraft Maximum Weight: 1280 grams
2. Please provide a copy of the following referenced materials: Motion Picture and Television Operations Manual (MPTOM) Response: The requested materials are included in this document on subsequent pages. They have also been uploaded to the Docket No. FAA-2015-2406

. Respectfully Submitted, Zachary Melms, Managing Member Peak 3 LLCPEAK 3 LLC - MPTOM



# Motion Picture and Television Flight Operation Manual

Peak 3 LLC 7731 Bethany Circle Anchorage, AK, 99507 (406) 599- 3557

Date: 5.15.2015 Page of 1 15 Revision: OriginalPEAK 3 LLC - MPTOM



## Table of Contents
1. Introduction A. Purpose 4 B. Pilot/Operator Organization 4 C. Persons Authorized 4 D. Area of Operations 4 E. Plan of Activities 5 F. Permission to Operate 5 G. Security 6 H. Briefing of Pilot/Production Personnel 6 I. Certification/Airworthiness 7 J. Pilot Personnel/Minimum Requirements 7 K. Communications 8 L. Accident Notification 8 M. Recall/Stop Procedures 8 N. Aerobatic Competency 8 O. Aerobatic Competency 9 

### 2. Company Organization A. Chief Pilot 9 B. Pilot in Command 10 

### Appendix A 1 List of Approved Pilots 11 2 List of Approved Aircraft 12 3 Permission Acquisition Form (sample) 13 4 Revision Letter (sample) 14

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## Revision Control Page
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## 1. Introduction
A. Purpose This manual has been developed by “PEAK 3 LLC.", hereafter referred to as “P3", in conjunction with an application for a Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) for the purposes of filming. P3 pilots and other company personnel when applicable will comply with the policies, procedures and conditions of this manual, whenever motion picture or television flight operations are performed that require a Waiver of Authorization as mentioned above. 

### B. Pilot/Operator Organization Zachary Melms - Managing Member Peak 3 LLC 7731 Bethany Circle Anchorage, Alaska 99507 

### C. Persons Authorized FAR 91.119 (c) is waived only with respect to those persons, vehicles and structures directly involved in the performance of the actual filming. The certificate holder shall ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if an equivalent level of safety can be achieved and the Administrator has approved it. For example, an equivalent level of safety may be determined by an ASI’s evaluation of the filming production area to note terrain features, obstructions, buildings, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an accident. 

### D. Area of Operations P3 approved areas of operations will be Alaska & Hawaii & the continental United States.

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### E. Plan of Activities At least three (3) days prior to any scheduled filming, P3 will submit a written plan of activities to the local FSDO having jurisdiction over that area. The plan of activities should include the following: (1) Dates and times for all flights. (2) Name and phone number of person responsible for the filming production event. (3) Name and phone number of person responsible for aircraft. (4) Make, model, and serial or N-number of aircraft to be used and type of airworthiness certificate, including category. (5) Name and certificate number of pilots involved in the filming production event, including any notation of external load endorsements or aerobatic competency, if required. (6) A statement that the waiver holder has obtained permission from property owners and/or local officials to conduct the filming production event. The list of those who gave permission must be made available to the inspector upon request from the waiver holder. (7) Signature of waiver holder or representative. (8) A description of the flight activity including maps or diagrams of any area, city, town, county, and/or State over which filming will be conducted and the minimum altitudes essential to accomplish the operations. The three (3) day notification equipments may be waived, however, the operator should contact the FSDO as soon as possible with this request and be prepared to explain in detail why the three (3) day notification is not practical. 

### F. Permission to Operate Before any flight operations is conducted at less than 500 feet under the provisions of the certificate of waiver and this manual, the operator will obtain permission to conduct these operations from property owners and local officials as necessary or appropriate. Persons from whom permission may be required are listed below: (1) Property owners (2) Law enforcement officials

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(3) Fire department officials (4) Local, State and Federal government (5) Air traffic control The P3 personnel obtaining such permission will do so in writing whenever practical, however, verbal permission is acceptable otherwise. A standard permission form is provided in Appendix A and may be used when obtaining written permission. P3 personnel will assure a sufficient number of those forms are available at the job site. Written permission forms will be maintained at the job site until flight operations are completed, and then turned into the chief pilot to be kept on file for a minimum of six (6) months. These forms will be made available for inspection by the FAA or other official personnel upon request. 

### G. Security Prior to any flight operation the operator will coordinate with appropriate production personnel to devise a plan of securing the area(s) of operation from all unauthorized persons and vehicles. Provisions will be made to immediately discontinue operations should the area(s) become unsecured or for any other reason in the interest of safety. 

### H. Briefing of Pilot/Production Personnel Prior to the start of any operation under the provisions of this manual, the pilot in command will conduct a briefing of all procedures to participating personnel of the risks involved, emergency procedures, and safeguards to be followed during the filming production event. Personnel will also be briefed on additional provisions that may be issued by the FSDO that has geographic responsibility for the operational area, including the location of boundaries or time limits. The briefing shall cover:

• Authorization for motion picture and television certificate of waiver and the

attached special provisions

• Operations manual

• Plan of activities

• Aircraft parking and starting

• Taxi procedures

• Radio Communications

• Takeoff procedures

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• Aviation activities to be conducted during the filming production event

• Approach and landing procedures

• Recall procedures

• Emergency procedures

• Risks to participating personnel

• How to control nonparticipating persons 

### I. Certification/Airworthiness All P3 aircraft used in operations requiring a waiver of FAR 91 .119 (b) and (c) for the purpose of filming will be properly certified and hold airworthiness certificates. However, restricted category aircraft cannot be used as the filming "vehicle" in motion picture and television filming. Also, aircraft in the experimental category must have an airworthiness certificate issued for the purpose of exhibition in order to be used in motion picture and television filming. The aircraft will be 100hr/annual inspection program. Other required tests and inspections (transponder, E.L.T., etc.) will be performed as per Part 91 when necessary. Each aircraft will have a flight log containing upcoming scheduled maintenance and inspections and the dates or times they must be performed. A section for discrepancies is also found in the flight log. The pilot in command will assure the aircraft to be flown is in airworthy condition and all required inspections and maintenance has been completed before each flight. 

### J. Pilot Personnel/Minimum Requirements The pilot/operator shall establish and specify the minimum pilot requirements. Minimum requirements shall meet or exceed the following: (1) A current U.S. Commercial pilot certificate with ratings appropriate to the category, class and type (if applicable) of aircraft to be used under the terms of the waiver. (2) At least 500 hours logged as PIC and at least 20 hours logged as the PIC in the aircraft type. (3) A minimum of 100 hours in the category and class of aircraft to be used. (4) A minimum of 5 hours in the make and model aircraft to be used under the waiver. (5) In the event that the 1,500-foot minimum standard contained in the 14 CFR 91.303(e) is to be waived, the pilot performing aerobatic maneuvers must hold FAA Form 8710-7, Statement of Acrobatic Competency, to perform the operations.

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(6) In the event the operation to be conducted contains elements of an external-load operation, whether fixed or rotary wing operations, pilots used in the operation shall be qualified. This qualification may be obtained through a knowledge test (which may be oral and/written) and/or skill. The inspector or another company pilot approved by the geographically responsible FSDO who is qualified to carry loads externally will give the test(s) which are similar to part 133 requirements and cover the following subjects: (a) Steps to be taken before starting operations, including a survey of the Flight area. (b) Proper method of loading, rigging, or attaching the external load. (c) Aircraft performance capabilities under motion picture operating procedures and the aircraft flight manual. (d) Proper instructions for flight and ground crew personnel. (e) Aircraft flight manual, pilot operations handbook, or a rotorcraft-load combination flight manual and limitations, if appropriate. 

### K. Communications Prior to the start of any operation covered by this manual, the pilot in command will formulate a plan to provide communications capability to all participants during the actual operation and filming. Oral, visual or radio communications may be used as long as it is effective and is capable of keeping the participants continuously appraised of the current status of the operation. 

### L. Accident Notification Should an accident or incident requiring notification of the NTSB occur, the notification requirements of FAR Part 830 would comply. 

### M. Recall/Stop Procedures Radio communication, oral, visual or a combination will be utilized to keep the participants continuously apprised of the current status of operation. 

### N. Aerobatic Competency If the filming operations require the issuance of FAA Form 8710-7, Statement of Aerobatic Competency, refer to Volume 5, Chapter 9, Issue/Renew/Rescind a Statement of Aerobatic Competency.

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### O. Special Provisions The controls, procedures, and conditions set forth in the P3 motion picture and television operations manual is the primary assurance that persons on the surface will not be jeopardized. The aircraft and pilots used under this authorization and/or waiver will only be those specified in the P3 motion picture and television operations manual (“Appendix A” page 11) or associated plan of activities. Each pilot’s name and certificate number shall appear on each daily plan of activity. All civil aircraft and pilot(s) participating in the activity shall be available for FAA inspection before the scheduled event. Each pilot-in-command conducting operations authorized under this certificate understands the conditions of issuance, and that it constitutes a waiver of FAR 91.119 (b) and (c). Rotorcraft takeoff and landing areas will be protected in a manner that will prevent unauthorized persons from entering the takeoff and landing area. P3 will ensure that the participating persons involved in the operations are thoroughly briefed on special procedures, communication, emergency procedures, and on the provisions of the authorization and/or waiver before beginning the activities. No person may participate in any event unless that person has received a briefing on the provisions of the waiver. 

## 2. Company Organization A. Chief Pilot Duties and Responsibilities:

• Final word in the formulation of policy and procedures concerning this manual.

• Act as liaison between P3 and the FAA on matter concerning this manual.

• Assure that each approved pilot is issued a copy of this manual and obtain a signed statement from each that they have read and understand its contents.

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• Maintain a current copy of this manual at the main base of operations for P3.

• Responsible for assuring that all revisions to this manual are distributed and processed properly.

• Must approve or disapprove each proposed job or operation performed by P3 under the provisions of this manual.

• Assume the responsibilities of pilot in command when acting as such.

• The chief pilot may delegate functions to other personnel but retains responsibility. 

### B. Pilot in Command Duties and Responsibilities:

• Assure that aircraft to be flown is in airworthy condition and all inspections and required maintenance have been performed as per appropriate FAR's.

• Acquire permission from the chief pilot before any operation under the provisions of this manual.

• Be very knowledgeable of the contents of this manual and abide by the procedures, policies and conditions contained herein.

• Coordinate with movie and television personnel to formulate plans, routes, locations, etc. with safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and have it on site at any job or operation requiring the waiver.

• The pilot in command may delegate functions to other personnel, but retains responsibility.

Date: 5.15.2015 Page of 10 15 Revision: OriginalPEAK 3 LLC - MPTOM


## Appendix A.1 

# List of Approved Pilots

Chief Pilot Name : Certificate Number Grade : Medical Class/Date : Contact Number :



### Pilots Name : Certificate Number Grade : Medical Class/Date : Contact Number :

Name : Certificate Number Grade : Medical Class/Date : Contact Number :

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## Appendix A.2 

# List of Approved Aircraft
Make and Model Registration Number

1.
2.
3.
4.
5.
6.
7.

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## A.3 

# Peak 3 LLC Permission Acquisition Form (example) In signing this form, I am giving the pilots of Peak 3 LLC. permission to operate their aircraft at less than 500 feet from property, or in some jurisdiction in which I am responsible for or affiliated with, for the purpose of film or television production.

Name: Title: Basis of Authority to Grant Permission: Location: Date of Operation:
Signature __________________________________________________ Date __________________________
Peak 3 LLC Representative Receiving Permission

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## Appendix A.4 

# Revision Letter

Rev# Section Page Action Remarks Initials

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______________________________________________________________________ R • Remove and Replace D • Delete and Destroy N • Insert New Page

Manual Serial# ___________________ Issued To ___________________________

Revised By _________________________________

Date _______________________

This form must be returned to the Chief Pilot no later than _____________________

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Notes:

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