March 24, 2015

Exemption No. 11223 Regulatory Docket No. FAA− 2014

− 0613

Mr. Mark A. Dombroff

Counsel for Wilbur

- Ellis Co mpany McKenna Long & Aldridge LLP

1676 International Drive Penthouse
McLean, VA 22102

Dear Mr. Dombroff :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated August 14, 2014 1

, you petitioned the Federal Aviation Administration (FAA)

on behalf of Wilbur

- Ellis Company ( hereinafter petitioner o r operator ) for an exemption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to

conduct precision agriculture survey and inspection operations

.

See Appendix A for the petition submitted to the FAA des cribing the pro posed operations and

the regulations that the petitioner seeks an exemption

.

.

1 By letter dated November 26, 2014, and posted to the public docket on December 1, 2014, the petitione r provided additional information.2

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on September 2, 2014, (79 FR 52105). Three comments were received. The Small UAV Coalition (Coalition) supported the petition, while the Air Line Pilots Association, International (ALPA) and the National Agricultural Aviation Association (NAAA) opposed it.

I n supp o r t of the p e tition, the C o a lition st a t e d the p e tition e r h a s p r opos e d t o a bide b y st r o n g e r

s a fe t y m e a su re s th a n hob b y a nd mod e l e r g r oups op e r a ting simil a r a i r c raf t. The C o a lition

st a t e d th a t it do e s not b e li e ve th a t h e i g ht e n e d s a f e t y m ea su r e s should be re qui re d f or the

p e tition e r simp l y b eca use o f the c omm e rc i a l n a tu r e of its op e ra tions. The C o a lition u r g e d the

F AA to a dopt a n e v a l u a tion fra m e w o r k f or U AS op era tions und e r s e c t ion 333 of P ub. L

. 112

– 95 th a t w e i g hs the r e l a tive s a f e t y issu e s a nd r isks of UAS b y c l a ss a nd op era tion al

c i rc umst a n c e s, ra th e r th a n a dopting a r ti f i c i a l distin c tions a mong unm a n n e d aer i a l v e h i c l e s

b a s e d on c omm erc i a l a nd no n c omm erc i a l op e r a tions. The p e tition er’ s UAS pose

c onsid e ra b l y l e ss s afe t y r isk th a n l ar g e r U AS. The C o a lition a ss er t e d th a t b e ca use UAS

op era tions like the p e tition er’ s pose minim a l r isk to s afe t y , th e y should be subj ec t to minim a l

a nd a pp r op r i a te r e g ul a tions.

The C o a lition not e d the F AA is to c onsid e r t h e s e v e n fac t o r s 2 in s ec tion 333 a s a minimum.

The C o a lition st a t e d the p e tit i on shows the F AA shou l d c onsid e r f a c to r s oth e r t h a n th ose

sp ec i f i e d in s ec tion 333, such as: location, the altitude of its small UAV operations, proven
experience pursuant to Certificates of Authorization in the United States and similar approvals

in Canada. The C o a lition m a int a in e d th a t the p e tition er’ s p r o pos e d op era tions s a tis f y the

s e v e n fac t o r s in s ec tion 333 a nd in c lude s e v e ra l a ddition a l miti g a ting f a c t o r s to e nsu r e the

s afe t y a n d s ec u r i t y of the p r opos e d UAS op e r a tions. The C o a lition e mph a si z e d the F AA must

e v a l u a te e a c h f a c tor within the c ont e x t of t he p e tition er’ s p r opo s e d UAS op e r a tions.

The C o a lition a lso c omm e nt e d th a t the F AA should g r a nt re li e f fr om the r e qui re m e nt to hold

a n a i r m a ns c er ti f i ca t e. The Coalition further stated that if an airman certificate is required

then, a t a minimum the, F AA should p r ovi d e a n e x ce ption fr om the t ra ini n g a nd t e sting

r e quirements in part 61 in favor of requirements p er tin e nt to the a i r c raf t a nd op era tion

p r opos e d. The C o a lition a lso a ss er t e d th a t in s ec tion 333 Congress intended for the FAA to

consider n a tion a l s ec u r i t y with respect to the operation as opposed to addressing it through
pilot certification.

2 Section 333(b) of P.L. 112

- 95 states, in part: “In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; . . . .”3

The FAA notes that

, a s dis c uss e d in the g r a nt of e x e mption to T r imble N a vig a tion L td.
(Exemption No. 1111 0 ) , n e ith e r s ec tion 333, nor th e F A A ’ s exemption auth ority 3 allows

the F AA to e x e mpt pilots from the st a tuto r y r e qui r e m e nt to hold a n a i r m a n c e r ti f i ca te a s

p re s cr ib e d in 49 U S C § 44711.

The C o a lition c omm e nt e d th a t a visual observer ( VO) should not be re qui r e d f or a ll sm a ll
UAS op era tions. The C o a lition f u r th e r a s s er t e d th a t the p re s e n c e of one o r mo r e VOs m a y

a llow the UAS to be op era t e d b e y o nd visual line of sight ( V L OS) of the pilot in command
( P I C) a nd th a t the p e tition er’ s p r o p os a l to op era te the unmanned aircraft (UA) within V L OS

of the P I C and/or VO should b e p er mitt e d.

The F AA n ot e s th a t one of the d e t er min a tions f or op e ra t ions und e r s ec tion 333 is op era tion

within visu a l line of si g ht. T h e P I C must m a int a in V L OS w hile op era ti n g the UA. The F AA

finds th a t a VO c o mpl e m e nts the P I C’ s ca p a bili t y t o s e e a nd a void oth e r a i r cr a f t, in c luding

wh e n t h e P I C m a y b e mom e nt ar i l y a tt e ndi n g to oth e r f l y

i n g t a sks. The VO p r ovid e s a n

a ddition a l l e v e l of op e ra tion a l s a f e t y

.

ALPA expressed concern regarding several aspects of the petition. ALPA noted that while t he
proposed operations will avoid congested or populated areas and operate under VLOS in
Visual Metrological Conditions (VMC)

, the petitioner did not provide detailed procedures for
controlling the airspace or area of operation. Specifically, ALPA stated, “there must be means
both to ensure that the sUAS remains within the Class G airspace under 400’AGL and to
ensure that the hazard of other aircraft intruding on the operation is mitigated.”

The FAA believes the limitations under which the petitioner will operate (i.e. VLOS and at or
below 400 feet above ground level (AGL)) are sufficient mitigations to this risk so that the
operations will not adversely affect safety.

ALPA noted that the petitioner does not state how the pilot and the observer will be a ble to
communicate with each other. ALPA stated that text messaging, either by mobile phone or
other means, could have an unknown latency and extend to several minutes. NAAA stated
UAS observers must be present and able to communicate with the operator fr om the most
minimal distance possible. The conditions and limitations regarding PIC and VO

communications address those concerns.

ALPA asserted the UA’s lithium polymer batteries have numerous associated fire and
explosion hazards as outlined in DOT/FAA/A R

- 09/55, “Flammability Assessment of

3 49 USC § 44701(f)4

Lithium

- Ion and Lithium

- Ion Polymer Battery Cell Designed for Aircraft Power Usage
(January 2010),” and that the safe carriage of the batteries and the mitigations in place for

known risks should be addressed. The refer enced study was primarily conducted to determine
how certain battery cells react in a fire situation aboard manned airplanes. Given the size of
the battery and the operating conditions of the UAS, the FAA concludes that the use of a
lithium polymer battery will not pose an undue safety risk for the proposed operations.

ALPA commented that while the petitioner’s aircraft has a barometric sensor, the platform
does not have a barometric altimeter as required by 14 CFR § 91.121. ALPA stated that

processes or m itigations must be in place to ensure the UA can accurately maintain altitude
including engineering processes, software development and control, electronic hardware
development and control, configuration management, and design assurance to ensure the

aircr aft and its control system(s) operate to the same level of safety as other aircraft operated
commercially in the National Airspace System (NAS).

ALPA commented that command and control (C2) link failures are one of the most common

failures on a UAS, and t hat lost link mitigations should require safe modes to prevent fly

aways or other scenarios. The FAA has inserted conditions and limitations in this exemption
to mitigate the risk associated with such failures.

ALPA also noted that the petitioner’s propos ed operations are for “compensation or hire,” and
therefore contends the pilot must hold at least a current FAA commercial pilot certificate with
an appropriate category and class rating for the type of aircraft being flown, as well as specific
and adequat e training on the UAS make and model intended to be used. Similarly, ALPA

asserted a current second

- class airman medical certificate should be required. NAAA also
commented on pilot qualification, stating

—

Just as manned aircraft pilots are required to undergo a rigorous training curriculum
and show that they are fit to operate a commercial aircraft, so too must UAS operators.
Holding a commercial certificate holds UAS operators to similar high standards as
commercial aircraft operators and ensures they are aware of their responsibilities as
commercial operators within the NAS. Medical requirements ensure they have the
necessary visual and mental acuity to operate a commercial aircraft repeatedly over a
sustained period of time.

The FAA has reviewed th e knowledge and training requirements of sport, recreational, private

and commercial certificates and concluded that a UAS PIC holding a minimum of a sport pilot
certificate, and operating under this exemption, would not adversely affect operations in the5

NAS or present a hazard to persons or property on the ground. Additional discussion of the
FAA’s review is found in the FAA’s Analysis section of this exemption.

A L P A not ed the p e tition e r must sp ec i f y a m ea ns to m ee t s e e a nd a void re qu i re m e nts in

§ 91.113 g i v e n the a bs e n c e of a n onbo ar d pilot. The FAA notes that all flights must be
operated within VLOS of the PIC and VO.

ALPA also expressed concern that the petition makes no reference to compliance with, or a request for waiver from, 14 CFR 61.195, Flight instructor limitations and qualifications

, which defines the requirements for flight instructors. A certificated flight instructor is authorized to provide the instruction required for the certificates or ratings or currency listed in 14 CFR § 61.193. A person instructing on how to operate the UAS under the petitioner’s training program would not need to be a certificated flight instructor because the instruction is not being provided for a certificate or rating listed in § 61.193. We note that none of th e UAS operations proposed by the petitioner require such flight instruction because § 61.31( l ) allows for operation of the UAS by an airman who is current per 14 CFR § 61.56 without a category and class rating. Instruction provided toward obtaining the pi lot certificate required by this exemption would need to be provided by a certificated flight instructor.

ALPA opposed the petitioners request to avoid providing aircraft documentation (critical for
aircraft maintenance tracking, AD issuance, related perf ormance information) of its small

UAS. T he FAA has previously determined in Grant of Exemption 11062, Astraeus Aerial,

that relief from these sections is not necessary. Relevant materials may be kept in a location
accessible to the PIC in compliance with the regulations.

ALPA opposed the petitioner’s request for an exemption from the aircraft maintenance and
record keeping requirements. ALPA asserted that the petitioner’s small UAS “should comply
to the same level of safety as other aircraft operated com mercially in the NAS.” The FAA
finds that adherence to the petitioner’s operating documents, as required by the conditions and
limitations below, is sufficient to ensure that safety is not adversely affected.

ALPA also expressed concern that the petitione r’s request is not for a single specific operation
or location, but for all operations of the same general type. ALPA stated that this results in a
considerable increase in the FAA’s oversight tasks. The FAA notes ALPA’s concern and in
order to minimize po tential impact to the NAS, the FAA requires that each operator secure a
Certificate of Waiver or Authorization (COA) which covers specific details of the petitioner’s
operation. The FAA recognizes that UAS integration will generate new NAS access demand

an d will review and adjust accordingly.6

NAAA noted that its members operate in low

- level airspace, and therefore clear low

- level
airspace is vital to the safety of these operators. NAAA stated that seeing and avoiding other

aircraft and hazardous obstructio ns is the backbone for agricultural safety, and that
agricultural pilots depend on pilots of other aircraft to perform their see

- and

- avoid functions
to prevent collisions. NAAA believes UAS operations at low altitudes will increase the
potential for collis ion with agricultural aircraft.

The FAA recognizes these concerns and has incorporated associated conditions and
limitations into this exemption, including: (a) a Notice to Airmen (NOTAM) issued for all
operations; (b) operations conducted within VLOS of the pilot in command (PIC) and the VO;
and (c) the UAS PIC must always yield right

- of

- way to manned aircraft.

NAAA stated that FAA airworthiness certification should be a requirement for all unmanned
aircraft to operate within the NAS. NAAA recommended U AS be equipped with ADS

- B or
similar identification and positioning systems, strobe lights, high

- visibility markings and
registration numbers. NAAA also recommended UAS be operated strictly within the line

- of

sight of the ground controller, with the assist ance of a VO and clear of any low

- flying manned

aircraft.

As discussed in greater detail below, Section 333 of the FAA Modernization and Reform Act
of 2012 authorizes the Secretary of Transportation to determine, considering a number of

factors laid out in the statute, that an airworthiness certificate is not necessary for certain
operations. The Secretary has made that determination in this case and therefore the aircraft
operated by the petitioner will not need to be certificated by the FAA.

Airworthi ness Certification

The UAS proposed by the petitioner is a HoneyComb AgDrone.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory c riteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Sec tion 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is

not necessary.7

The Basis for Our Decision

You have requested to use a UAS for aerial data col lection

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab, Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to f ind that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 110 62, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foreg oing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Wilbur

- Ellis Company is granted an exemption from

14 CFR §§ 61.23 (a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Wilbur

- Ellis Company is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the HoneyComb AgDrone when weighing less than 55 pounds including paylo ad. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.8

3. The UA may not be operated at a speed exce eding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. 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.

5. 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.

6. All operations must utilize a visual observe r (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 verb ally 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 perf orm the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating do cuments. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating d ocuments, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the

operato r’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Off ice (AFS

- 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 criti cal component, must undergo9

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 fl ight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator 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 mu st 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.

11. The operator must follow the UAS manufacturer’s maintenance, ov erhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an air line 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 Colombia, Puerto Rico, a territory, a posses sion, or the Federal government. 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.

14. The operator may not permit any PIC to operate unless the PIC de monstrates 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

trainin g, 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 § 91.119.10

15. UAS operati ons may 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.

16. 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 req uest.

17. 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.

18. 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.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditi ons) 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 Waive r 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 C OA

.

22. 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 la rge as practicable.

23. 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.

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

activities at all times.11

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

26. All Flight operations must 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 p ersons 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 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

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 safet y 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.

27. All operations sh all 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 condu cted.

28. 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 b e reported to the National Transportation Safety Board (NTSB) per instructions

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

.

If this exemption closed

- set motion picture and television filming and production, the

followi ng additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

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

exe mption 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 in clude at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;12

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

- scene operation of the UAS;

d. Make, model, and serial or N

- Number of UAS to be used;

e. Name and certificate number of UAS 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 producti on event; the list of those who gave permission must 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 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.

This exemption terminates on March 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service