**In the matter of the petition of HD BROS. LC**
**Daniel Clifton 820 North Pollard Street**  **Ar lington V**  **A, 22203** 

for an exemption from part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 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); and 91.417(a) and (b) of Title 14, Code of Federal Regulations

By letter dated December 18th, 2015, HD BROS. LC, 21 Princess Street, Stafford VA 22556 petitioned the Federal Aviation Administration (FAA) for an exemption from part 21, §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 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), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow operation of unmanned aircraft systems (UAS) for the purpose of photographing real estate and land.

**The petitioner requests relief from the following regulations:** Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals.
Se ction 45.23(b) prescribes, in pertinent part, that when marks include onl y the Roman capital letter “N” and the registration number is display ed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft , the operator
AFS

- 14

- 320

- E must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Section 61.113(a) and (b) prescribes that

—(a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that per son, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or employment if: (1) The flight is only

incidental to that b usiness or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it is in an airworth y condition. Section 91.9(b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or an y combination thereof. Secti on 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight, to include

— (a) For a flight under IFR or a flight not in the vicinity of an airp ort, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and an y known traffic delays of which the pilot in command has been advised by ATC; (b) For an y flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope , aircraft gross weight, and wind and temperature. Section 91.109 prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functionin g dual controls. Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) An ywh ere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or propert y on the surface.(b) Over congested areas. Over an y congested area of a cit y, 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 an y person, vessel, v ehicle, 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 p aragraph (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 l ess than the minimums prescribed in paragraph (c) of this section. Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day , to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. [emphasis added] Section 91.203(a) prohibits, in pertinent part, an y person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it i s legible to passengers or crew. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided i n paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter.Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service b y a person authorized under § 43.7 of the same chapter. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. Section 91.417(a) and (b) prescribes, in pertinent part, that

— (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, pr eventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. T he records must include

— (i) (Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containin g the following information: (i) The total time in service of the airframe,each engine,each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last ove rhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safet y d irective involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and app liances. (b) The owner or operator shall retain the following records for the periods prescribed:(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

The Petitioner seeks relief in order to photograph residential properties for sale, and provide service for agents and buy ers. HD BROS. L C b elieves there is public interest photographing properties, and would provide benefit towards persons interested in purchasing home. High demand from realtors, home sellers and home bu yers for aerial photography.

The Petitioner exemption would not adverse ly affect safet y, because UAS operation would be held entirel y on private properties, operated within line of sight of pilot. UAS would not be directly flown over any

persons, only

over home and surrounding propert y.

**Summary**
HD BROS. L C is requesting exemption for 14 CFR 11.81 in order to operate UAS for commercial use photographing real estate.

**Unmanned Aircraft System**

The UAS proposed b y the petitioner is a proprietary design, conceived and constructed by Astraeus Aeria l, and referred to as the Astraeus Aerial Cinema Sy stem V.3CS UAS aircraft variant, serial #001 onward (hereafter referred to as V.3). This aircraft has eight rotors and eight motors in a quadcopter configuration (X8). The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted and meets th e requirements for an equivalent level ofsafet y under 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of

2012 (PL112

- 95). The petitioner further states that UAS operated without an airworthiness certificate in the restricted enviro nment and under the conditions and limitations proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 CFR part 21, Subpart H and not subject to the proposed conditions and limitations. The petitioner states that the unmanned aircraft (UA) to be operated under this request is less than 55 lbs. fully

loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor passenge r, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the MPTOM. In addition, the petitioner has integrated safety features into the design of the UAS, as described in the petitioner’s FOP M, to ensure the safet y of persons and propert y within and surrounding the limited operating area. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability

to return to a pre

- determ ined location within the Security Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted obstacles or emergencies. The petitioner states that even though its UAS will have no airworthiness certificate, an exempt ion may

be needed from 14 CFR § 45.23 as the UA will have no entrance to the cabin, cockpit, or pilot station on which the word “experimental” can be placed. Given the size of the UA, the petitioner notes that the two

- inch lettering will be impossible. The petitioner asserts that an equivalent level of safety will be provided by

having the UA marked with the word “experimental” on the fuselage in compliance with 14 CFR § 45.29(f), in a location where the pilot, observer, and others working with the UA will see the identification. The petitioner states that the maintenance requirements in the pertinent sections of 14 CFR part 91 are onl y applicable to aircraft with an airworthiness certificate in accordance with part 43. The petitioner states that its V.3 UA S does not have specific maintenance instructions; therefore the petitioner has developed and documented in its MPTOM and FOPM an “on

- condition” maintenance process for the V.3 UAS affected b y this exemption. The petitioner has also stated that it intends to follow any manufacturers’ recommended instructions and procedures when those procedures exist for certain components of its V.3 UAS.

**UAS Operating Parameters** The petitioner states that all flights will be operated within visual line of sight (VLOS) of a pilot and/or observer, and that the UA flights will be limited to a maximum altitude of 400 feet AGL. The petitioner further states that an operator will ensure that only consenting production personnel will be allowed within 100 feet of the UA operation, but this radius may be reduced to30 feet based upon an equivalent level of safety determination, as stated in their MPTOM, with

the advance permission of the local Flight Standards District Office (FSDO). The petitioner asserts that an equivalent le vel of safety can be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. The petitioner states that the UAS will be operated within a safe operating perimeter, the boundaries of which will be determined b y production personnel and the UAS PI C based on the site

- specific filming activities and speed of the UAS required for the operation, and coordinated with the jurisdictional FAA FSDO and local government officials as applicable, as outlined in the MPTOM and FOPM. The petitioner states that only participating and consenting production personnel will be allowed within this perimeter; the petitioner also states their intention to comply with the guidelines outlined in Order 8900.1 V3, C8, S1 with regard to nonparticipating personnel outside the safety perimeter. The petitioner argues that, compared to flight operations with aircraft or rotorcraft weighing far more than its maximum 55 lb. UA, and the lack of flammable fuel, an y risk associated with its UAS operati ons is far less than those with conventional aircraft operating at or below 500 feet AGL in the movie industry

. With respect to preflight actions, the petitioner notes it may need an exemption from 14 CFR § 91.103, because it will not have approved rotorc raft flight manuals. The petitioner asserts that an equivalent level of safet y will be achieved b y the PI C taking all preflight actions as set forth in their MPTOM and FOPM, including reviewing weather, flight battery requirements, landing and takeoff dist ances, and aircraft performance data before initiation of flight. Additionally , the petitioner states that a briefing will be conducted prior to each day ’s filming regarding planned UAS operations, and all personnel who will be performing duties within the boundaries of the safet y perimeter will be required to attend. With respect to the fuel requirements, the petitioner notes that, in order to meet the 30 minute reserve requirements in 14 CFR § 91.151, UAS flights would have to be limited to approximately 10 minutes. The petitioner argues that, given the limitations on the UA’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. The p etitioner believes that an equivalent level of safet y can be achieved b y limiting flights to 30 minutes or 25% of battery power, whichever occurs first. The petitioner notes that it may need an exemption from 14 CFR § 91.121, as its UAS may have a GPS alt itude read out instead of a barometric altimeter. The petitioner asserts that an equivalent level of safety

will be achieved, as outlined in its MPTOM. Specifically , the altitude information will be provided to the UAS PI C via a digitally encoded telemetri c data feed. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PI C.

Public InterestThe petitioner states that, given the small size of the UA involved and the restricted sterile

environment within which it will operate, its proposed operation “falls squarel y within that zone of safet y (an equivalent level of safet y) in which Congress envisioned that the FAA must, b y exemption, allow commercial operations of UAS to commence immediately.” Also due to the size of the UA and the restricted areas in which the UAS will operate, approval of the application presents no national security issue. The petitioner states that, given the clear direction in Section 333, the strong equivalent level of safet y surr ounding the proposed operations, and the significant public benefit, including enhanced safety , reduction in environmental impacts, and including reduced emissions associated with allowing UAS for real estate photography purposes, granting the requested ex emptions is in the public interest.

**Unmanned Aircraft System** The UAS proposed b y the petitioner is a conceived and constructed b y DJ I systems, and referred to as the Phantom 3 Professional. The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted and meets the requirements for an equ ivalent level of safet y under 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (PL112

- 95). The petitioner further states that UAS operated without an airworthiness certificate in the restricted environment and under the condi tions and limitations proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 CFR part 21, Subpart H and not subject to the proposed conditions and limitations. The petitioner states that the unmanned aircraft (UA) to be operated under this request is less than 55 lbs. fully

loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor passenger, carries no explosive m aterials or flammable liquid fuels, and operates exclusively within a secured area as set out in the MPTOM. In addition, the petitioner has integrated safety features into the design of the UAS, as described in the petitioner’s FOPM, to ensure the safet y o f persons and propert y within and surrounding the limited operating area. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability

to return to a pre

- determined location within the Security Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted obstacles or emergencies. The petitioner states that even though its UAS will have no airworthiness certificate, an exemption may

be needed from 14 CFR § 45.23 as the UA will have no entrance to the cabin, cockpit, or pilot station on which the word “experimental” can be placed. Given the size of the UA, the petitioner notes that the two

- inch lettering will be impossible. The petitioner asserts that an equivalent level of safety will be provided by

having the UA marked with the word“experimental” on the fuselage in compliance with 14 CFR § 45.29(f), in a location where the

pilot, observer, and others working with the UA will see the identification.
T he petitioner states that the maintenance requirements in the pertinent sections of 14 CFR part 91 are onl y applicable to aircraft with an airworthiness certificate in accordance with part 43. The petitioner states that its V.3 UAS does not have specific m aintenance instructions; therefore the petitioner has developed and documented in its MPTOM and FOPM an “on

- condition” maintenance process for the V.3 UAS affected b y this exemption. The petitioner has also stated that it intends to follow any manufacture rs’ recommended instructions and procedures when those procedures exist for certain components of its V.3 UAS.

**UAS Operating Parameters** The petitioner states that all flights will be operated within visual line of sight (VLOS) of a pilot and/or observer, and that the UA flights will be limited to a maximum altitude of 400 feet AGL. The petitioner further states that an operator will ensure that only consenting production personnel will be allowed within 100 feet of the UA operation, but this radius may be reduced to 30 feet based upon an equivalent level of safety determination, as stated in their MPTOM, with the advance permission of the l ocal Flight Standards District Office (FSDO). The petitioner asserts that an equivalent level of safety can be achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. The petitioner states that the UAS will be
o perated within a safe operating perimeter, the boundaries of which will be determined b y production personnel and the UAS PI C based on the site

- specific filming activities and speed of the UAS required for the operation, and coordinated with the jurisdicti onal FAA FSDO and local government officials as applicable, as outlined in the MPTOM and FOPM. The petitioner states that only participating and consenting production personnel will be allowed within this perimeter; the petitioner also states their intenti on to comply with the guidelines outlined in Order 8900.1 V3, C8, S1 with regard to nonparticipating personnel outside the safet y perimeter. The petitioner argues that, compared to flight operations with aircraft or rotorcraft weighing far more than its maximum 55 lb. UA, and the lack of flammable fuel, an y risk associated with its UAS operations is far less than those with conventional aircraft operating at or below 500 feet AGL in the real estate industry

. With respect to preflight actions, the petitioner notes it may need an exemption from 14 CFR § 91.103, because it will not have approved rotorcraft flight manuals. The petitioner asserts that an equivalent level of safet y will be achieved b y the PI C taking all preflight actions as set forth in their MPTOM and FOPM, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before initiation of flight. Additionally , the petitioner states that a brie fing will be conducted prior to each day ’s filming regarding plannedUAS operations, and all personnel who will be performing duties within the boundaries of the

safet y perimeter will be required to attend. With respect to the fuel requirements, the petit ioner notes that, in order to meet the 30 minute reserve requirements in 14 CFR § 91.151, UAS flights would have to be limited to approximately

10 minutes. The petitioner argues that, given the limitations on the UA’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. The petitioner believes that an equivalent level of safet y can be achieved b y limiting flights to 30 minutes or 25% of battery power, whichever occurs first. The petitioner notes that it may need an exemption from 14 CFR § 91.121, as its UAS may have a GPS altitude read out instead of a barometric altimeter. The petitioner asserts that an equivalent level of safety

will be achieved, as outlined in its MPTOM. Specifically , the altitude information will be provided to the UAS PI C via a digitally encoded telemetric data feed. Prior to each flight, a zero altitude initiation point will be established and confirmed for accurac y b y the PI C.

the operator proposed the following conditions and/or limitations, which were accepted by the FAA. 2 1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy source(s) and equipment. Operations authorized by this grant of exemption are limited to the following aircraft described in the operator’s manual: DJ I Phantom 3 Professional 2. The UA may

not be flown at a ground speed exceeding 50 knots. 3. Flights must be operated at an altitude of no more than 400 feet above gro und level (AGL), as indicated b y the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL 4. 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 us e human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued medical certificate. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy

the VLOS requirement as long as the PIC alway s ma intains VL OS capability . The VO and PI C must be able to communicate verbally at all times. 6. The operator’s manual is considered acceptable to the FAA, provided the additional requirements identified in these conditions and limitations are added or amended. The operator’s manual and this grant of exemption must be maintained 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 operator’s manual , the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual.7. The operator may update or revise its operator’s manual. It is the operator’s responsibil ity to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may

be contacted if questions arise regarding updates or revisions to the operator’s manual. 8. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the neces sary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraf t records. 9. 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 in accordance with the operator’s manual. The P IC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manual. 10. The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator’s manual. At a minimum, requirements for the following must be included in the operator’s manual:Actuators / Servos; 11. Transmission (single rotor); 12. Powerplant (motors); 13. Propellers; 14. Electronic speed controller; 15. Batteries; 16. Mechanica l dy

namic components (single rotor); 17. Remote command and control; 18. Ground control station (if used); and 19. Any other components as determined by the operator; 20. The Pilot In Command (PI C) must possess at least a private pilot certificate and at least a current third

- class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.21. The UA may not be operated directl y over an y person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergen cy
. 22. Regarding distance from nonparticipating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary

for the filming production. This provision may be reduced to no less than
● 200 feet if it would not adversel y affect safet y and the Administrator has approved it. For example, an equivalent level of safet y ma y be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safet y barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1.
● If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the securit y perimeter and land or be recovered in accordance with the operator’s manual.
● The UAS must abort the flight in the event of unpredicted o bstacles or emergencies in accordance with the operator’s manual.
● Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first.In addition to the conditions and limitations proposed by

the o perator, the FAA has determined that an y operations conducted under this grant of exemption must be done pursuant to the following conditions and limitations:
● The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 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 practicab le. The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be add ed to the operator’s manual. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual.The preflight in spection section in the operator’s manual must be amended to include the

following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection
s ections of the operator’s manual. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements

.

At least three day s before scheduled photography , the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local 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 filming production 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 PI Cs involved in the filming production event;
● A statement that the operator has obtained permission from propert y 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

- ho lder 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. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upo n request.
The UA must remain clear and yi eld the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).UAS operation s 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. The UAS may

not be operated b y the PIC from any moving device or vehicle. 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 PI C. The UA may

not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained , and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. Any incident, accident, or flight operation that tr ansgresses 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 Safet y Board (NT SB ) per instructions contained on the NTSB Web site: www.ntsb.gov . Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided. Unless otherwise spec ified 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.