Peter T Booth 1

FAA Private Pilot

Certificate Number: 2735103

10 Hubbell Ave.

Oneonta, NY 13820

December 1, 2015

Mr. James Williams

Manager, Flight Standards Service

Unmanned Aircraft System Integration Office

Federal Aviation Administration

800 Independence Ave, SW

Washington, DC 20591

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Request for exemption from multiple regulatory provisions to allow 

the use of a small-unmanned aerial system in remote locations to assist 

private agencies in the evaluation of environmental stressors within the 

Upper Susquehanna, and Greater NYC Watersheds.

Dear Mr. Williams:

I, Peter T Booth, (Petitioner) FAA Private Pilot # 2735103, Do 

hereby, and respectfully, request an exemption from several provisions of 

Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of 

small unmanned aerial systems (sUAS) to assist in the evaluation of 

environmental stressors within the upper Susquehanna, and greater NYC 

watersheds located in Otsego, and Delaware county NY. This Request is 

motivated primarily by the desire to maximize the efficiency, and 

therefore efficacy of small scale localized environmental mapping. An 

exemption would enable me to provide local conservation and ecological 

agencies with much needed up to date environmental mapping for the 

purpose of monitoring change, land usage change, and a number of other 

environmental factors within this sensitive watershed. These same aerial 

surveys have been conducted in the past resulting in full-scale aircraft 

flying at dangerously low altitudes over a large lake lined on all sides with 

private residences. Accordingly, the grant of an exemption is consistent 

with Congress’ intent, reflecting in Section 333 of the FAA modernization 

and Reform Act of 2012 (Modernization Act) 1, that safe systems be 

permitted in the national airspace prior to the issuance of final regulations 

governing general use of these systems. 2 A summary of this request 

suitable for publication in the federal register is provided as Appendix A.
Appendix B provides the manufacturers information regarding the 2

design, aircraft performance, and fail-safe features. I have provided 

manufacturer information related to operating limitations, normal 

emergency procedures, and maintenance and inspection procedures.

Appendix C provides my best practices operations manual for flights 

that will be conducted under this Exemption Request.

Background Information:

I, Peter T Booth, am an undergraduate student at SUNY, Oneonta. I am 

majoring in Geography/GIS in a capacity as to be supportive to 

environmental research scientists. Agencies connected to the SUNY 

system frequently approach me to assist their research by creating smallscale localized environmental maps of key areas within their field of study. 

I have developed specific safe sUAS operating procedures that do not 

require altitudes in excess of 400’ AGL, or for the UAV to leave my line of 

sight at any time.

Proposed Operations Requiring Exemption:

Aerial surveying

Remote sensing

Agricultural support

Real Estate Photography

Aerial filmmaking and photography

Construction site inspections and monitoring

Wildlife and forestry monitoring

Educational and research operations

I seek this exemption in support of these operations.

Regulatory Basis for Exemption Request: (How granting will be in the 

public interest)

In addition to the waiver authority provided in §333 of the Modernization 

Act, the FAA may grant an exemption under 49 U.S.C. §44701(f) if it has 

determined that such an exemption is in the public interest. The FAA has 

imposed a separate requirement in its procedural regulations, providing 

that the petitioner shall explain why granting the exemption would not 

adversely affect safety of how the exemption would provide at least an 

equivalent level of safety as compliance with underlying regulation. In this 

case, approval of this exemption would advance the public interest by 

providing a much-needed temporal resolution increase in environmental 

monitoring of two large sensitive watersheds. The first being the Upper 

Susquehanna water shed which eventually drains into the Chesapeake 

Bay; the second is the Delaware River watershed, which provides drinking 

water to millions of NYC residents. These mapping missions have, in the 
past, been conducted using full scale aircraft which at best are 3

unnecessarily expelling 100LL aviation gasoline exhaust over sensitive 

watersheds, while contributing to problematic noise pollution in residential 

areas. At worst these flights, conducted at approximately 500’ AGL, are 

recklessly endangering human lives on the ground, and the lives of the 

airplane’s crew. By contrast the sUAS in question can perform these 

mapping missions with zero risk of damaging the ecosystems in question, 

while providing data at greater detail than can be achieved with full-scale 

aircraft. The 400’ AGL ceiling of these operations represents an altitude at 

which a full scale aircraft, were it to be flying there, would be in violation of 

FAA 14 CFR § 91.119 (a) (b) and (c) Minimum Safe Altitudes: General. 

Thus the sUAS does not pose any threat to the NAS provided full-scale

operators remain in compliance with this law.

As described more fully below, there is a noteworthy increase in 

public safety by employing the sUAS to conduct these types of operations, 

over continued usage of their full-scale counterparts.

Granting this exemption is in the public interest. Environmental 

monitoring is a process that is heavily reliant on analyzing trends that can 

occur within the frame of hours, days, and weeks. Though there is a wealth 

of satellite data available from online resources, and government 

databases, these images cannot by design be timely enough to capture, for 

example, the before and after mapping of an isolated local storm event. By 

monitoring changes at this scale, and with this kind of temporal resolution, 

we gain a more complete picture of how fluvial systems respond to storm 

events. The more comprehensive our understanding of these events, the 

more effective we can be in our efforts to design mitigation. Since many of 

these areas are not only watersheds for major cities, but also the homes of 

many people, it stands that these efforts minimize loss of property, and 

therefore minimize economic losses through insurance claim, and FEMA 

response. 

Granting an Exemption will not Adversely Affect Safety:

Since the operation profile of environmental mapping excludes possibility 

of equivalency determination with the standards surrounding model 

aircraft, It is difficult to argue that the sUAS being operated for the 

purpose of environmental mapping falls under the operations controlled by 

the Academy of Model Aeronautics. Similarly the operation profile of the 

sUAS for environmental mapping is not comparable to the operational 

profile of a full-scale aircraft, thus the sUAS cannot be compared to them.

As such I believe that it makes more sense to focus on why the proposed 

usage of petitioner’s sUAS would not adversely affect safety, which is in the 

spirit of §11.81(e) requirements.

Granting an Exemption will not adversely affect safety. All sUAS 

operations will be conducted over isolated wilderness areas, and privately 

held lands with the consent of the landowners. These operations will be 

solely conducted during daylight hours, at altitudes well below those, 
which will interact with general aviation. All operations will be conducted 4

at greater than 5 miles from airports or helipads, in the event that it 

becomes necessary to conduct operations within this proposed 5 mile ring, 

The local airport or helipad control tower will be contacted prior to 

operations; also under this circumstance the local airborne radio 

frequencies will be monitored for the duration of the sUAS operation.

Approval of exemptions allowing commercial operation of sUAS’s in 

the environmental mapping industry will enhance safety by reducing risk. 

Conventional operations using small single engine aircraft operating from 

the local uncontrolled field, involve an ageing Cessna 150. This aircraft has 

a gross weight of 1600 lbs. It carries 26 gallons of 100LL avgas, and at best 

glide rate it must land within approximately đ mile if it is flying t 500’agl, 

which is 100’ higher than the sUAS would be flying. Noting that the areas 

where I will be conducting mapping operations are in remote wilderness 

areas, or over a body of water with a minimum width of 1 mile, this means 

that a C-150 from the airfield located more than 10 miles from my area of 

study would not be in compliance with CFR’s and therefore conducting this 

same operation in an unsafe manner. Thus using an sUAS for this 

operation would have a discernible increase in safety over traditional 

aerial survey practice.

The operations of sUAS’s weighing less than 55lbs., conducted as 

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

grant of exemptions requested herein, including 333 Aircraft Exemption 

Status exempting the applicant from conventional aircraft requirements 

and allowing commercial operations. These lightweight aircraft operate at 

low speeds, close to the ground, and in a controlled environment. As a 

result, they are far safer than conventional operations conducted by fullscale aircraft carrying people. 

§ 91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open 

air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal 

radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Amdt. 91-311, 75 FR 5223, Feb. 1, 

2010]
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The Petitioner Requests Relief From the Following:

14 C.F.R. 14 C.F.R. Part 21, Subpart H

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

NOTES: How the operator will maintain an equivalent level of safety or 

have no adverse impact on safety:

Notes regarding: 14 C.F.R. Part 21, Subpart H 

In accordance with the statutory criteria provided in section 333 of 

PL 112-95 in reference to 49 USC 440704, and in consideration of the size, 

weight, speed, and limited operating area associated with the aircraft and 

its operation, I request that this aircraft exemption meets the conditions of 

Section 333. Therefore, if granted Section 333 relief of 14 C.F.R. part 21, 

and any associated noise certification and testing requirements of part 36, 

is not necessary.

Notes regarding: 14 C.F.R. 45.23 (b). Marking of the Aircraft

Given the size of the sUAV, Two-inch lettering will not be possible. 

UA will be identified by serial number, registered in accordance with 14 

C.F.R. part 47, subpart C. Markings will be as large as practicable.

Notes regarding: 14 C.F.R. 61.113(a) and (b) Private pilot privileges

and limitations, pilot in command

The regulation provides that no person that holds a Private Pilot 

certificate may act as pilot in Command of an aircraft for compensation or 

hire. Subparagraph (b) allows a private pilot to act as pilot in command of 

an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The 

aircraft does not carry passengers or property for compensation or hire. 

Our proposed operations require that the PIC must hold at least a Private 

Pilot Certificate issued by the FAA and since the aircraft cannot carry 

passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a 

business.
Notes regarding: 14 C.F.R. 91.7 (a) Civil Aircraft Airworthiness 6

Petitioner’s request is based on the fact that no airworthiness 

certificate will be issued for the UAS. Petitioner’s UAS will not require an 

airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart H. 

Based on the fact that an airworthiness certificate will not be issued, 

exemption § 91.7 (a) is not necessary.

Notes regarding: 14 C.F.R. 91.9 (b) (2) Civil aircraft flight manual, 

marking & placard Certifications required:

The original intent of these regulations are to display an aircraft’s 

airworthiness, certification, and registration documents so they would be 

easily available to inspectors and passengers. Based on the FAA 

Memorandum subject “Interpretation regarding whether certain required 

documents may be kept at an unmanned aircraft’s control station,” dated 

August 8, 2014, the requested relief from 14 C.F.R. §§91.9(b)(2) and 

91.203(a) and (b) is not necessary.

Notes regarding: 14 C.F.R. 91.109 Flight instruction; Simulated 

instrument & certain flight tests

Small UAS’s by design do not have fully functioning dual controls. Fight 

control is accomplished through the use of a control box that 

communicates with the aircraft via radio. Aircraft being considered for use 

by petitioner allow the UAS Instructor to place the aircraft into “loiter” 

mode (fixed altitude stationary hold). In the event of a student losing 

control, the UAS instructor can quickly via alternate equipment (not in the 

hands of the student) place the aircraft into a mode that then allows the 

instructor to bring the aircraft back under control and return it to the 

predefined landing zone. 

Petitioner does not describe training scenarios where a dual set of controls 

would be utilized or required, i.e. Dual flight instruction. Rather petitioner 

maintains soul PIC duties over his fleet of sUAV’s. Since petitioner has no 

intention of providing formalized training scenarios that will require dual 

control, he does not seek relief from 14 C.F.R § 91.109.

Notes regarding: 14 C.F.R. 91.119

General. The regulation states that over sparsely populated areas the 

aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the sUAS would be 

photography or survey of persons, vessels, vehicles or structures it would 

be necessary to operate closer than 500 feet to the items listed. Operations 

will only be flown over property or persons where permission has been 

obtained and careful pre-planned has been performed. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. 

Therefore we maintain that due to the small size of the UAS, the hazard to 

persons, vehicles and structures is minimal compared to manned aircraft, 

which should be considered in granting the exemption.
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Notes regarding: 14 C.F.R. 91.121

The regulation requires that aircraft shall maintain cruising altitudes by 

reference to an altimeter setting available within 100 NM of the aircraft. 

The sUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above 

Ground Level altimeter measurement above the takeoff point is 

transmitted via radio from the sUAS on-board computer to the display 

screen held by the PIC, providing a constantly updated AGL readout.

Notes regarding: 14 C.F.R. 91.151(a)

The regulation provides that no person may begin a flight in an airplane 

under day-VFR conditions unless there is enough fuel to fly to the first 

point of intended landing and to fly after that for at least 30 minutes. We 

feel the intention of this paragraph is to provide an energy reserve as a 

safety buffer for delays to landing. The sUAV is battery operated and the 

maximum duration of flight from a single battery charge is 15 minutes 

with a 20% reserve. Since the aircraft will never fly more than 1/8 NM 

from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent 

interpretation with the word

"energy".

Notes regarding: 14 C.F.R. 91.203 (a) & (b)

The regulation provides that an airworthiness certificate, with the 

registration number assigned to the aircraft and a registration certificate 

must be aboard the aircraft. Additionally, subparagraph (b) provides that 

the airworthiness certificate be "displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew." At a maximum gross weight of 

5.3 pounds, the sUAS is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be colocated with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that 

the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following 

information plus the word "EXPERIMENTAL" to satisfy the requirement of 

14 CFR 45.23.

Notes regarding: 14 C.F.R. 91.205 (b) Instrument and equipment 

requirements.

The majority of these regulations are not applicable to an electric 

sUAS. Since most of them are relevant to internal combustion engines and 

or VFR nighttime flying lighting requirements. Since the sUAS in use by 
the petitioner neither use internal combustion engines, nor will they ever 8

be used for nighttime flights, the petitioner seeks relief from this 

requirement.

Notes regarding: 14 C.F.R. 91.215 ATC transponder and altitude 

reporting equipment and use.

Since the Petitioner’s sUAV will not be used in any airspace as defined by 

14 C.F.R. § 91.215, the Petitioner seeks relief from this regulation.

Notes regarding: 14 C.F.R. (91.401 - 91.417) 

The regulation provides that the operator is primarily responsible 

for maintaining the aircraft in an airworthy condition, including 

compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized 

under 43.7" after maintenance and inspection. It is our intention that the 

PIC perform maintenance and inspection of the aircraft and "be authorized 

to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition 

conduct detailed inspections after every two hours of flight. Maintenance 

performed by the PIC is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and 

firmware for the on-board computer. The manufacturer or their designated 

repair facility will perform all other maintenance. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an 

equivalent level of safety.

Appendix A:

Summary for Federal Register Publication

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

publication in the Federal Register should the FAA determine that the 

publication is needed.

Petitioner: Peter T Booth, FAA Private Pilot certificate number# 2735103

Sections of 14 C.F.R. Affected:

Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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) 9

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Description of relief sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption 

Status, 14 C.F.R., 61.113 (a)&(b), 91.119(c), 91.121, 91.151, 91.405(a), 

91.407(a), 91.409(a), and 91.417(a)&(b) to conduct sUAS operations of 

permitted remote locations belonging to the clients of Petitioner. In 

general, sUAS operations are intended to be conducted in areas remote 

from congested areas and airports. The nature of operations anticipated by 

petitioner require that the sUAS be flown at relatively low altitudes. 

Expected in most instances not to exceed 50 meters (165 feet) AGL. In no 

instances will flights be conducted at altitudes exceeding 120 meters 

(393.701 feet) AGL. Accordingly the risk of interference with other 

aircraft is non-existent provided that civil aircraft are in compliance with 

regulation § 91.119 Minimum safe altitudes requirements.

Appendix B: Specific types, makes, models:

3D Robotics SOLO (How the operator will maintain an equivalent level of 

safety or have no adverse impact on safety):

3D Robotics X8 (manual available upon request)

3D Robotics IRIS+ (manual available upon request)

Excelsior UAV Silver Six with 3D Robotics Pixhawk flight controller

This is a unique six prop UAV designed and built by the petitioner. It 

has builder serial number EXUAV0002. This machine has a total weight of 

2.7 kilograms (approximately 6 lbs.), This sUAS uses the 3D Robotics 

Pixhawk autopilot/flight controller. (manual available upon request)

The Pixhawk has been installed following the exact guidelines set forth by 

manufacturer. The Silver six has undergone over 200 cycles of flight and 

flown more than 25 incident free hours.

Appendix C:

Best practices for safe operation of sUAS:

The UA may not be operated at a speed exceeding 30 MPH. The PIC may 

use either groundspeed or calibrated airspeed to determine compliance 

with the 30 MPH speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended 

by the aircraft manufacturer.

The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL.
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The UA must be operated within visual line of sight (VLOS) of the 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.

All operations must utilize a visual observer (VO). The UA must be 

operated within the visual line of sight (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 VLOS capability. The VO and PIC must be able to 

communicate verbally at all times; electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the VO can perform the duties required of 

the VO.

The operating documents must be accessible during UAS operations and 

made available to the Administrator upon request. 

The sUAS will be operated strictly in accordance with the manufacturer’s 

published guidelines for safe operation.

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.

The operator is responsible for maintaining and inspecting the UAS to 

ensure that it is in a condition for safe operation.

Prior to each flight, the PIC must conduct a pre-flight inspection and 

determine the UAS is in a condition for safe flight. The pre-flight inspection 

must 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 UAS, the aircraft is prohibited from operating until 

the necessary maintenance has been performed and the UAS is found to be 

in a condition for safe flight.

The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.
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Each UAS operated under this exemption must comply with all 

manufacturer safety bulletins.

Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 

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

The PIC must also 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.

The operator may not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the UAS in a manner consistent 

with how the UAS 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 must 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 UAS in a manner consistent with how the UAS 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 experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, 

and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

UAS operations will not be conducted during night, as defined in 14 CFR § 

1.1. All operations must be conducted under visual meteorological 

conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized.

The UA may not operate within 5 nautical miles of an airport reference 

point (ARP) as denoted in the current FAA Airport/Facility Directory 

(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 must be made available to the Administrator or any law 

enforcement official upon request.
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The UA may 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.

If the UAS loses communications or loses its GPS signal, the UA must 

return to a pre-determined location within the private or controlled-access 

property.

The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies.

The PIC is 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.

Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA). All operations shall 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.

All aircraft operated in accordance with this exemption must 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 must be as large as practicable.

Documents used by the operator to ensure the safe operation and flight of 

the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 

must be available to the PIC at the Ground Control Station of the UAS any 

time the aircraft is operating. These documents must be made available to 

the Administrator or any law enforcement official upon request.

The UA must remain clear and give way to all manned aviation operations 

and activities at all times.

The UAS may not be operated by the PIC from any moving device or 

vehicle.

All Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless:

Barriers or structures are present that sufficiently protect 

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

accident. The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating persons 
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leave such protection and are within 500 feet of the UA, flight operations 

must cease immediately in a manner ensuring the safety of 

nonparticipating persons; and

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 or essential persons are not considered 

nonparticipating persons under this exemption.

All operations shall 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.

Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable 

COA must be reported to the FAA's UAS Integration Office (AFS−80) within 

24 hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

At least 3 days before aerial filming, the operator of the UAS affected by 

this exemption must 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 

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

following:

Dates and times for all flights;

Name and phone number of the operator for the UAS aerial filming 

conducted under this grant of exemption;

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

operation of the UAS;

Make, model, and serial or N−Number of UAS to be used;

Name and certificate number of UAS PICs involved in the aerial filming;

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 must be made available to the inspector 

upon request;

Signature of exemption holder or representative; and

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.
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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 in this grant of exemption, the UAS, the UAS 

PIC, and the UAS operations must comply with all applicable parts of 14 

CFR including, but not limited to, parts 45, 47, 61, and 91.