DC: 5843669-1

September 29, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R., Part 11, Microsoft Corporation (“Microsoft”), operator of Small Unmanned Aircraft 

Systems (“sUAS”) equipped to conduct aerial videography and photography for advertising and 

other aerial photography purposes, including use in software, requests a limited exemption 

from the below-listed regulations to allow commercial operation of its sUASs, provided that the 

proposed sUAS operations comply with the conditions outlined below or as established by the 

Federal Aviation Administration (“FAA”) under Section 333.

The name and address of the applicant is:

Microsoft Corporation

Attn: Steve Kaneko

One Microsoft Way

Redmond, WA 98052

Phone: 425-706-9147

Fax: 425-936-7329

Email: stevekan@microsoft.com

Microsoft makes this request under the “summary grant” process that the FAA 

announced in April 2015.1 This request is similar in all material respects to a number of recent 

grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial 

Cinematography, LLC (FAA Docket No. 2014-0090), Grant of Exemption No. 12721 to Limitless 

Drones, LLC (FAA Docket No. 2015-2078), and Grant of Exemption No. 12956 (FAA Docket No. 

2015-2545).2

 

1 See FAA Summary Grants Speed UAS Exemptions, available at 

https://www.faa.gov/news/updates/?newsId=82485. 

2 The use limitations and arguments in this application are nearly identical to those contained in 

Advanced Aerial Cinematography’s November 24, 2014 application and the FAA’s May 5, 2015 

approval of that application, and to the June 8, 2015 application for an exemption from 

(continued...)
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 2

Regulations from which the exemption is requested:

14 C.F.R. part 21

14 C.F.R. § 45.23 (b)

14 C.F.R. §§ 61.113 (a) & (b)

14 C.F.R. § 91.7 (a)

14 C.F.R. § 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 C.F.R. § 91.151 (a)

14 C.F.R. §§ 91.203 (a) & (b)

14 C.F.R. § 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. §§ 417 (a) & (b)

Microsoft proposes that it receive an exemption to use sUAS to conduct aerial 

videography and photography for advertising and other aerial photography purposes, including 

use in software. Microsoft would obtain the consent of all personnel in the vicinity in which the 

sUAS may operate. The sUAS proposed by the petitioner is a DJI Phantom 3.

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system (“NAS”) or to persons and property on the ground. Microsoft proposes that the 

exemption apply to civil aircraft that operate within the limitations listed below. These 

limitations were established in the FAA’s grant of Advanced Aerial Cinematography’s request for 

an exemption:

 

Wingless Aerial Solutions and Photography and the FAA’s September 22, 2015 approval of that 

application.
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 3

1. The sUAS will weigh less than 55 pounds, including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend 

this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

permitted. (A motion picture and television operations manual (MPTOM) is 

attached to this application for exemption.)

3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per 

hour). Microsoft may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the sUAS be 

operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer. 

4. The UAS will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude will be reported in feet AGL.

5. The UAS will be operated within visual line of sight (VLOS) of the Pilot in Charge 

(PIC) at all times. This requires the PIC to be able to use human vision unaided 

by any device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The UAS will be operated 

within the VLOS of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains the VLOS capability. 

The VO and PIC will be able to communicate verbally at all times; electronic 

messaging or texting will not be permitted during flight operations. The PIC will 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the sUAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant 

of exemption, are hereinafter referred to as the operating documents. The 

operating documents will be accessible during sUAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in the exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and 

will be followed. Otherwise, Microsoft will follow the procedures as outlined in 

its operating documents. Microsoft may update or revise its operating 

documents. It is Microsoft’s responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement 

official upon request. Microsoft will also present updated and revised documents 

if it petitions for extension or amendment to this grant of exemption. If 

Microsoft determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then Microsoft must petition for an 

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 4

80) may be contacted if questions arise regarding updates or revisions to the 

operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations 

under this exemption. Functional test flights may only be conducted by a PIC 

with a VO and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard 

to persons and property. 

9. Microsoft is responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine 

the sUAS is in a condition for safe flight. The pre-flight inspection will account 

for all potential discrepancies, e.g., inoperable components, items, or equipment. 

If the inspection reveals a condition that affects the safe operation of the sUAS, 

the aircraft will be prohibited form operating until the necessary maintenance 

has been performed and the sUAS is found to be in a condition for safe flight.

11. Microsoft will follow the sUAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each sUAS operated under this exemption will comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC will hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will also hold 

a current FAA airman medical certificate or a valid U.S. driver’s license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal Government. The PIC also will meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. 

14. Microsoft will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the sUAS in a manner consistent with how the sUAS will 

be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles, and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability to safely operate the sUAS in a manner consistent

with how the sUAS will be operated under this exemption are permitted under 

the terms of this exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and 
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 5

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC will operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

Microsoft will not operate flights under special visual flight rules (SVFR).

16. The UAS will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chart, unless a letter of agreement with 

that airport’s management is obtained or otherwise permitted by a COA issued to 

the exemption holder. The letter of agreement with the airport management will 

be made available to the Administrator or any law enforcement official upon 

request.

17. The UAS will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

18. If the sUAS loses communications or loses its GPS signal, the UA will return to a 

pre-determined location within the private or controlled-access property.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA to 

conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations will be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings 

will be as large as practicable.

23. Documents used by Microsoft to ensure the safe operation and flight of the sUAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to 

the PIC at the Ground Control Station of the sUAS any time the aircraft is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 6

24. The UAS will remain clear and give way to all manned aviation operations and 

activities at all times.

25. The sUAS will not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures, unless:

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an 

accident. Microsoft will ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UA, flight 

operations will cease immediately in a manner ensuring the safety of 

nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard.

The PIC, VO, operator trainees, essential persons, or individuals who have signed 

consent forms are not considered nonparticipating persons under this 

exemption.

27. All operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

Because this exemption permits operations for the purpose of closed-set television 

filming and production, the following additional conditions and limitations apply:

29. Microsoft will have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. The MPTOM is attached to this 

letter as Attachment A.

30. At least 3 days before aerial filming, Microsoft will submit a written Plan of 

Activities to the local Flight Standards District Office (FSDO) with jurisdiction 

over the area of proposed filming. The 3-day notification may be waived with the 
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 7

concurrence of the FSDO. The plan of activities must include at least the 

following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the sUAS aerial filming 

conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the sUAS;

d. Make, model, and serial or N-Number of the sUAS to be used;

e. Name and certificate number of sUAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the filming production event; the 

list of those who gave permission will be made available to the inspector 

upon request;

g. Signature of exemption holder or representative; and

h. 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 altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating 

persons consenting to be involved and necessary for the filming production, as 

specified in the exemption holder’s MPTOM. 

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 

14 CFR including, but not limited to, parts 45, 47, 61, and 91. Microsoft incorporates all 

arguments in support of the petition made in Advanced Aerial Cinematography’s November 24, 

2014 application for exemption. 

Federal Register Notice

As stated above, publication in the Federal Register is unnecessary because this 

application meets the FAA’s criteria for summary approval. To the extent that the FAA 

determines that publication is necessary, the following summary is provided:

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 (55 lbs or less) in 

videography and photography operations.
U.S. Department of Transportation, Docket Operations

September 29, 2015

Page 8

The Exemption is in the Public Interest 

As demonstrated above, the proposed sUAS operations would minimize the risk of harm 

to individual safety or damage to the NAS and property. The operations proposed by Microsoft

would provide public benefits by enabling Microsoft to acquire quality commercial videography 

and still photography in a cost-effective manner compared to traditional manned aircraft. Use 

of sUAS for this purpose also benefits the public by reducing the levels of air and noise pollution 

generated during traditional manned videography flights. Furthermore, the sUAS operations as 

described in this application will be far safer and more efficient than use of helicopters or other 

aircraft to capture the required footage.

The conditions outlined in this petition clearly satisfy Section 333’s exemption criteria

regarding “size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight,” and therefore the proposed operations would not 

“create a hazard to users of the national airspace system or the public or pose a threat to 

national security.” As discussed above, Microsoft agrees to use limitations that are substantially 

identical to those contained in the FAA’s recent grant of exemption for Advanced Aerial 

Cinematography. Accordingly, the proposed UAS operations of Microsoft should not raise 

safety or national security concerns, and should receive summary approval. 

Please do not hesitate to contact the undersigned if you need additional information. 

Respectfully submitted,

Kurt Wimmer

Stephen Kiehl
DC: 5843686-1

Attachment A
Page 2 of 11

Motion Picture and Television

Flight Operation Manual

Microsoft Corporation

Attn: Steve Kaneko 

One Microsoft Way

Redmond, WA 98052

Phone: 425-706-9147

Fax: 425-936-7329

Email: stevekan@microsoft.com

Date: September 29, 2015 Version: Original
Page 3 of 11

Table of Contents

A. Purpose............................................................................................................................... 5

B. Pilot/Operator Organization............................................................................................ 5

C. Pilots To Be Used During Filming................................................................................... 5

D. List of Aircraft by Make, Model and Serial or Registration Number ......................... 5

E. Distribution and Revision ................................................................................................ 5

F. Persons Authorized........................................................................................................... 6

G. Area of Operations............................................................................................................ 6

H. Plan of Activities ............................................................................................................... 6

I. Permission to Operate ...................................................................................................... 7

J. Security .............................................................................................................................. 8

K. Briefing of Pilots and Production Personnel .................................................................. 8

L. Certification/Airworthiness ............................................................................................. 8

M. Pilot Personnel—Minimum Requirements..................................................................... 8

N. Limitations......................................................................................................................... 8

O. Communications ............................................................................................................... 9

P. Accident Notification ........................................................................................................ 9

Q. Recall/Stop Procedures..................................................................................................... 9

R. Aerobatic Competency ..................................................................................................... 9

Appendix A

Appendix B
Page 4 of 11

Revision Control Page

Revision # Date Initials

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________
Page 5 of 11

Motion Picture and Television Flight Operation Manual

A. Purpose

This Manual has been developed by Microsoft Corporation (“Microsoft”) in conjunction with an 

application for an exemption from a limited number of regulations pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as outlined in Microsoft’s 

exemption application dated September 29, 2015, for use of sUAS to conduct aerial videography 

and photography for advertising and other aerial photography purposes, including use in 

software. Microsoft’s 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 an exemption.

B. Pilot/Operator Organization

Microsoft Corporation -- Operator

Attn: Steve Kaneko 

One Microsoft Way

Redmond, WA 98052

Email: stevekan@microsoft.com

Steve Kaneko - Partner Director of Design and applicant/responsible person - phone 425-706-

9147

C. Pilots To Be Used During Filming

Pilots to be used during filming will be included in the Plan of Activities to be filed at least three 

(3) days prior to each scheduled filming, pursuant to Section H, infra, with the local FSDO 

having jurisdiction over the area of proposed filming. The list of pilots will include each pilot’s 

pilot certificate number as well as special pilot authorizations or endorsements, if applicable.

D. List of Aircraft by Make, Model and Serial or Registration Number

A list of aircraft to be used appears in Appendix B, infra. Furthermore, any aircraft to be used in 

the proposed filming shall be listed by make, model and serial or registration number in the Plan 

of Activities to be filed at least three days prior to each scheduled filming, pursuant to Section H, 

infra, with the local FSDO having jurisdiction over the area of proposed filming.

E. Distribution and Revision

Microsoft will issue a copy of this manual, including all revisions, to all personnel involved in 

sUAS operation. All recipients are required to keep their manuals up-to-date with any furnished 

revisions. 

Amendments in FARs and normal usage will frequently indicate a need for additions, deletions, 

or corrections of selected subject matter in this manual. Revisions to the manual will be issued 

periodically to reflect these changes. In addition, manual users who observe or experience a 
Page 6 of 11

need for change are encouraged to submit their suggestions to Steve Kaneko, Partner Director of 

Design, Microsoft, for review and consideration. 

Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at 

least 15 days before the proposed effective date. Revisions will be noted on the Revision 

Control Page at the front of this Manual and will be noted in bold in this Manual. Each 

subsequent revision of the Manual will be distributed to all company personnel involved in 

sUAS operation.

F. Persons Authorized

Section 91.119(c) is waived only with respect to those participating persons, vehicles, and 

structures directly involved in the performance of the actual filming. The pilot-in-command and 

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 in the event that a suitable, equivalent level of safety can be 

achieved. An equivalent level of safety may be determined by evaluation of the filming 

production area and the degree of terrain features, buildings, etc. that will provide a safety barrier 

to observers.

Prior to any filming, the pilot-in-command and certificate holder shall be responsible for 

obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as 

outlined above) of the filming. Such consent forms shall be maintained by the operator for a 

period of at least six (6) months following the filming.

G. Area of Operations

The area of operations shall cover the United States. The specific location for each operation 

shall be stated in the Plan of Activities to be filed at least three (3) days prior to each scheduled 

filming, pursuant to Section H, infra, with the local FSDO having jurisdiction over the area of 

proposed filming.

The pilot/operator shall coordinate with the FSDO having geographic responsibility over the area 

of the filming operations.

H. Plan of Activities

At least three (3) days prior to any scheduled filming, Microsoft shall submit a written plan of 

activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of 

activities shall include the following:

1) Dates and times for all flights.

2) Name and phone number of operator responsible for the filming production 

event.

3) Name and phone number of the person responsible for the on-scene operation 

of the sUAS.
Page 7 of 11

4) Make, model, and serial number or registration number of aircraft to be used 

and type of airworthiness certificate, including Category (CAT).

5) Names and certificate numbers of pilots involved in the filming production 

event.

6) A statement that permission has been obtained from property owners and/or 

local officials to conduct the filming production event; the list of those who 

gave permission will be made available to the inspector upon request.

7) Signature of exemption holder or a designated representative.

8) A general outline, description or summary of the flight activity schedule, 

including maps or diagrams of any area, city, town, country, and/or state over 

which filming will be conducted and the altitude essential to accomplish the 

operation.

At the discretion of the FSDO, the 3-day notification may be waived. Justification of the 

exception to the 3-day requirement is needed. 

Microsoft acknowledges that prior to the beginning of any filming operations, the plan of 

activities must be accepted by the FAA.

I. Permission to Operate

Before any flight operation 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

3) Fire department officials

4) Local, state and federal government

The Microsoft 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. Written permission forms will 

be maintained at the job site until flight operations are completed, and then turned over to 

Microsoft 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.
Page 8 of 11

J. 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, vehicles and 

aircraft. Provisions will be made to immediately discontinue operations should the area(s) 

become unsecured or for any other reason in the interest of safety. 

K. Briefing of Pilots and 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 following during the filming production event. Personnel will 

also be briefed on any additional provisions that may be issued by the local FSDO, including the 

location of boundaries or any other time limits.

L. Certification/Airworthiness

Prior to any flight operation, the pilot in command will conduct a pre-flight inspection in 

accordance with Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 91 and 

applicable operating limitations. The pre-flight inspection will account for all potential 

discrepancies, e.g., inoperable components, items or equipment. If the inspection reveals a 

condition that affects the safe operation of the sUAS, the aircraft will be prohibited from 

operation until the necessary maintenance has been performed and the sUAS is found to be in a 

condition for safe flight.

Microsoft will follow the sUAS manufacturer’s maintenance, overhaul, replacement, inpsection 

and life limit requirements for the aircraft and aircraft components. Each sUAS operated under 

this exemption will comply with all manufacturer safety bulletins. 

The aircraft to be used may be certificated in any CAT, including experimental, provided the 

requirements of 14 CFR part 91, §§ 91.7, 91.9, and 91.203 are met.

M. Pilot Personnel—Minimum Requirements

The pilot in command will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal Government. The PIC also will meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

N. Limitations

Aircraft operations shall conform with the limitations set forth in Microsoft’s request for a 

limited exemption, dated September 29, 2015.

The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude will be reported in feet AGL.
Page 9 of 11

The aircraft will not be operated during night, as defined in 14 CFR § 1.1.

O. 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 apprised of the current status of the operation.

P. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the operator would 

immediately notify the NTSB pursuant to 49 CFR § 830 and take steps to preserve and protect 

the accident scene.

Q. 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.

R. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, see Volume 5, Chapter 9, 

Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.
Page 10 of 11

Appendix A

Microsoft Corporation

Permission to Conduct Operations Form

In signing this form, I am giving Microsoft Corporation permission to operate its 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: ____________________________

Location: ____________________________

Date of 

Operation: ____________________________

Basis of Authority to Grant Permission:

______________________________________________________________________

Signature: ____________________________

Date: ____________________________

Microsoft Representative Receiving Permission:

________________________________________
Page 11 of 11

Appendix B

Microsoft Corporation

List of Approved Aircraft

Make and Model Type Weight

1 DJI Phantom 3 Quad-rotor 3 lbs. (inclusive of 

camera and battery)