### May 4, 2015

Exemption No. 11449 Regulatory Docket No. FAA–2014–0937

Mr. Randy Gomez Mr. Gary Taillon West Coast Aerials, LLC In conjunction with Camera Support ACS, Inc.

2827 North San Fernando Boulevard Burbank, CA 91504

Dear Messrs. Gomez and Taillon:

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

By letter dated January 8, 2015 1 

### , you petitioned the Federal Av iation Administration (FAA) on behalf of West Coast Aerials, LLC (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanne d aircraft system (UAS) to conduct aerial cinematography, primarily in use for televisi on, and research on UAS safety protocols.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

1 By letters posted to the public docket on April 13 and 15, 2015, the petitioner responded to the FAA’s request

for information.

### 2

Airworthiness Certification

The UAS proposed by the petitioner are th e Foxtech Kraken, DJI S-1000, DJI S900, DJI Flamewheel F550, and DJI Phantom 2.

In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consider ation of the size, weight, speed, and limited operating area associated with the aircraft a nd its operation, the Secret ary of Transportation

has determined that this airc raft meets the conditions of Section 333. Therefore, the FAA finds that the relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection and closed set motion picture and filming. The FAA has issued grants of exemp tion in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 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 Labs, Inc. ( see Docket No. FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned airc raft (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 find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant 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, West Coas t Aerials, LLC 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) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection andclosed set motion picture and filming. This exemption is subject to the conditions and

limitations listed below.

### 3

Conditions and Limitations

In this grant of exemption, West Coast Aerials, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions an d 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 ex emption are limited to the Foxtech Kraken, DJI S-1000, DJI S900, DJI Flamewheel F550, an d DJI Phantom 2 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a peti tion to amend this exemption.

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

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. 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 th e 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 observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C 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 pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform 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 documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

### 4

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d 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 wh ich the FAA granted this exemption, then the operator must petition for an amendmen t to its grant of exemption. The FAA’s UAS Integration Office (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 aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions 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 functi onal test flight 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 must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e 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 manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot 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 government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles 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 e xperience-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 dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity 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 ai rport management must be made available to the Administrator or any law enforcement official upon request.

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 pr ivate or controlled-access property.

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

20. The PIC is prohibited from beginning a f light 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 fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce 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 unde r the terms of the attached COA.

### 6

22. All aircraft operated in accord ance 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.

23. Documents used by the operator to ensure th e 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 wa y to all manned aviation operations and

activities at all times.

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 pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch 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 struct ures 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 es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller 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 must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

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

.

### 7

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following 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 exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the 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 UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating 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 al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

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

Sincerely,

/s/

John S. Duncan Director, Flight St andards ServiceRe:Exemption Request Pursuant To Section333 of the FAA Refonn Act d 2012
Dear Sir or Madam: ACS lnccrpcrated dba Camera Suppcr1 Burbank in conjunction with West Coast Aerials LLC. a California Limited liability Ccrnpany are writing pursuant to the FAA Modernization and Refonn Act of 2012 (the "Reform Act") and the procedures contained in

14 C.F.R. 11. to request that West Coast Aerials, an owner and operator d small unmanned aircraft. equipped to conduct aerial photography fcr the motion picture and television industry for scripted closed set filming, hereby applies for an exemption from

the listed Federal Aviation Regulations ("FARs") to allow ccrnmercial operation of its sUASS, so long as such operations are conjucted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.1.
This requested exemption would penn it the operation of small. unmanned UAS under contrdled conditions in airspace that is 1)
limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations in

the film and television industry presently using conventional aircraft. Approval d this exemption would thereby enhance safety
and fulfill the Secretary d Transpcr1ation's (the FAA Administrator's) responsibilities to "

... establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333( c) of the Reform Act.

West Coast Aerials owners Randy Gomez and Gary Taillon are professional operators and engineers in the television and film industry capturing aerial cinematography with small. unmanned aircraft and lightweight UASS. It is a company that has publicly

and privately shown its ability to carry camera systems on astable UAS platfonn. West Coast Aerials has equipped each d its

small unmanned aircraft fcr a9rial video. primarily fcr use in the television industry, though given their stability and maneuverability, they may be used fcr dher cinematography using cameras like the Arri Alexa. Red Epic and Sony F55. West Coast Aerials
UASS are the mcct advanced remote control aircraft being used fcr these purpcces and they are already highly regarded by notewcr1hy movie and television directors and experts in the field of unmanned rotorcraft. Owners Randy Gcrnez and Gary Taillon have been on the forefront of remote control and wireless technology since its inception. bringing their expertise to the television and film industry fcr the past 30 years. West Coast Aerials owner operators specialize in moving camera platforms using wireless applications. Our owner operators have provided professional technical support and equipment rental fcr the television and film industry fcr 30+ years on such

shows as: The Academy Awards, The Academy ofTelevision Arts Emmy Awards, MTV Music Awards, Winter and Summer Olympics, Triple Crown. Dancing with the stars, The Vdce, Wheel of Fortune, Jeopardy, Jimmy Kimmel Live. Master Chef. Survivor. Biggest Lccer. plus numerous situation comedies on all majcr TV netwcrks and cable channels.

These clients are very interested to utilize this UAS technology and are contident with the professional approach our company provides using our moving camera platfonns such as Technojibs, jibarms. cable cams. rail cams. steadi cams. towercams etc
West Coast Aerials technical team always ensures a safe operating environment. first concern being public safety. Our company has a pertect safety record operating its crane mounted cameras over crowds and public areas during live television broadcasts

and concerts. Based in Burbank California, West Coast Aerials would like pennission to fly its UASS ccrnmercially in the United States to capture aerial cinematography and conduct research on UAS safety protocds.
West Coast Aerials exemption request would permit its operation of lightweight. unmanned (pilded by remote control) and state
d the art UASS in tightly controlled and limited airspace. Our ccrnpany only works in spedfically pennitted areas of operation

and ccrdoned off locations provided by the production ccrnpany. West Coast Aerials always obtains all necessary pennissions and penn its prior to operation: and. West Coast Aerials has procedures in place to abort flights in the event d safety breaches or potential danger.

West Coast Aerials is asking the agency to grant an exemption from regulations that address general flight rules. pilot certificate requirements, manuals, maintenance and equipment mandates. We are also asking for relief frcrn airworthiness certification requirements as allowed under Section 333. Under that section d the law, certain airworthiness requirements can be waived to let specific UAS fly safely in narrowly- defined, controlled, low- risk situations. Granting West Coast Aerials request comports with the Secretary of Transpcr1ation's (FAA Administrator's) responsibilities to net only integrate UASS into the national airspace system. but to"

... establish requirements fcr the safe operation of such aircraft systems [UASS) in the national airspace system" under Section 333( c) of the Refcrm Act. Further. West Coast Aerials will conduct its operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated in our attached petition. West Coast Aerials respectfully requests the grant d an exemption allowing it to operate lightweight, remote controlled UAS's within the national airspace system. forthwith.

Thank you. Respectfully submitted, Randy Gomez Gary Taillon
West Coast Aerials, LLC

in conjunction with Camera Suppcr1 ACS Inc.

'<£27 N. San Fernando Blvd

Burbank. CA 91504
Members IAT SE Local 600
International Cinematographers Guild