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October 09, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE  

Washington, DC 20590 

West Coast Sky Cam’s Petition for Exemption to Operate

Unmanned Aircraft Systems for Aerial Photography and Filming



NAME AND ADDRESS OF PETITIONER

West Coast Sky Cam

Attn: William Meyers - ATP 3141175

Patrick Keesee - COMM 2771875

10061 Riverside Drive, Suite 195

Toluca Lake, CA 91602

(818) 691-6210
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PETITION SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. 

L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), West 

Coast Sky Cam. (“Petitioner”) hereby petitions for exemptions from 14 C.F.R. Part 21, 

14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.121, 91.151(b), 91.155, 91.405(a), 

91.407(a)(1) 91.409(a)(2), 91.417(a)-(b). The proposed exemptions, if granted, would 

allow Petitioner to operate, camera-mounted unmanned aircraft systems (“UAS”) 

weighing 55 pounds or less for the purpose of aerial data collection including but not 

limited to Closed-set filming of motion pictures, music videos, web videos, corporate 

videos, television programs and commercials, and still photography. 

Based on the small size of Petitioner’s UAS, the qualifications and experience of 

Petitioner’s UAS operators, and the restricted, sterile environment within which 

Petitioner will operate, the requested exemptions fall squarely within the zone of safety

envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety 

achieved by replacing significantly larger manned aircraft carrying crew and flammable 

fuel with small UAS carrying no passengers or crew and operated under the specific 

guidelines and procedures proposed by Petitioner gives the FAA good cause to find that 

the UAS operations enabled by the instant Petition are in the public interest. Thus, the 

requested exemptions should be granted. 

II. BACKGROUND

All our pilots are FAA licensed multi-engine commercial pilots and/or Airline 

Transport Pilots with current first class medical certificates and FCC Restricted Radio 

Operators Permits. Combined flying experience for Petitioner’s is in excess of 18,000 

hours in Single Engine Land & Sea, Multi-Engine land, Large ME Turbine Aircraft and 

Helicopters.

Remote controlled aircraft experience spans over 25 years for both pilots 

including powered fixed wing and glider as well as single and multi rotorcraft.

For over 12 years, Petitioner’s production and filming professionals have 

provided advanced motion picture services and camera support for films, television 

programs, corporate and music videos. Combining the latest technology with a long 

track record of safe and successful projects. Petitioner’s technical expertise has been 
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relied upon for filming projects ranging from commercials to Grammy nominated music

videos. In order to continue to provide the highest level of service, and to promote 

safety by eliminating the need for large manned aircraft on a filming set, Petitioner 

seeks regulatory exemptions that will allow Petitioner to employ camera- mounted UAS 

technology in the filming and production process.

III. STATUTORY AUTHORITY 

A. Section 333 

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” 

provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the National Airspace System (“NAS”). Section 333(a) states that the FAA 

“shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the [comprehensive] plan and rulemaking 

required by section 332(b)(1) of this Act or the guidance required by section 334 of this 

Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a 

mechanism for “expedited operational authorization.” The FAA has committed to 

complying with this mandate by granting several petitions almost identical to the one at 

hand. See, e.g., Exemption No. 11062, Regulatory Docket No. FAA-2014-0352 

(granting regulatory exemptions to Astraeus Aerial for operation of unmanned aircraft 

systems for the purpose of filming for the motion picture and television industry).

Section 333(b) identifies several factors that the FAA should consider in 

determining whether commercial UAS operations should be approved. These include 

UAS that, “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 [NAS] or the public or pose a threat to national security.” See 

Section 333(b). 

B. Section 44701(f)

In addition to the specific authority conferred by Section 333, the FAA 

Administrator has general authority to grant exemptions from the FAA’s safety

regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See U.S.C. § 44701(f).
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IV. REQUESTED EXEMPTIONS

Petitioner requests relief from the following regulations: 

Part 91.119 Minimum safe altitudes: General.

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

the following altitudes:

(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—

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

less than the minimums prescribed in paragraph (c) of this section.

Petitioner requests that the UAV be classified the same as a powered parachute 

or weight-shift-control aircraft as it has considerably less mass, at a maximum of 55lbs, 

vs. a powered parachute or weight-shift-control aircraft, both classified as an ultralight 

vehicle under Part 103.1, with a maximum empty weigh 254lbs and a maximum of 5 

gallons of gas (30lbs avg.) and 1 occupant (140-250lbs). That’s a total of about 534 lbs. 

The UAS is 1/10 the weight or less and considerably more maneuverable than both of 

these aircraft and able to hover and land safely in a 5 foot diameter circle.

Under §103.7 Certification and registration

(a) Not withstanding any other section pertaining to certification of aircraft or their 

parts or equipment, ultralight vehicles and their component parts and equipment 

are not required to meet the airworthiness certification standards specified for 

aircraft or to have certificates of airworthiness.

(b) Not withstanding any other section pertaining to airman certification,

operators of ultralight vehicles are not required to meet any aeronautical 

knowledge, age, or experience requirements to operate those vehicles or to have 

airman or medical certificates.

(c) Not withstanding any other section pertaining to registration and marking of 

aircraft, ultralight vehicles are not required to be registered or to bear markings of 

any type.
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Petitioner’s UAS operations will be conducted within a sterile environment of 

closed-set filming. All participating personnel will be thoroughly briefed as to all flight 

operations. All our pilots are FAA Commercial licensed pilots with current first class 

medical certificates flying FAA registered UAS’s. All non-participating people will be 

kept a distance of 500 feet away from nearest operation of UAS flight path. 1 Thus, good 

cause exists for granting Petitioner’s requested relief from 14 C.F.R. § 91.119 (c) (d).

Part 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.” 

Petitioner seeks such relief because Petitioner will not have a typical barometric 

altimeter onboard the UAS. Instead, altitude information will be provided to the UAS PIC 

via a digitally encoded telemetric data feed, which downlinks from the aircraft to a

ground-based on-screen display. The altitude information will be generated by 

equipment installed onboard the UAS, using GPS triangulation, digitally encoded 

barometric altimeter, radio altimeter, or any combination thereof. Prior to each flight, a 

zero altitude initiation point will be established and confirmed for accuracy by the UAS 

PIC. Thus, good cause exists for granting the requested relief from 14 C.F.R. § 91.121. 

Part 91.151(b) No person may begin a flight in a rotorcraft 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, to fly after that 

for at least 20 minutes.

Petitioner’s UAS are do not carry fuel. Maximum flight time is limited to the size 

of the batteries installed for a flight. Maximum total flight time is about 20 minutes. 

There is no enroute flight. Takeoff and landing are in the same location and in very 

close proximity to where the aerial data collection is taking place. All flights will be 

terminated with 5 minutes or 20% remaining battery power, whichever occurs first. 

Thus, good cause exists for granting Petitioner’s requested relief from 14 C.F.R. § 

91.151(b) 

1 Pursuant to Order 8900.1 V3, C8, S1, “participating persons” includes all persons associated with the filming production. 

Participating persons will be briefed on the potential risk of the proposed flight operations and must acknowledge and accept those 

risks prior to participation. 
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Part 91.155(a) Except as provided in paragraph (b) of this section and §91.157, 

no person may operate an aircraft under VFR when the flight visibility is less, or at a 

distance from clouds that is less, than that prescribed for the corresponding altitude and 

class of airspace in the following table:

Class B 3 statute miles Clear of Clouds.

Class C 3 statute miles 500 feet below.

 1,000 feet above.

 2,000 feet horizontal.

Class D 3 statute miles 500 feet below.

 1,000 feet above.

 2,000 feet horizontal.

Class E:

Less than 10,000 feet MSL 3 statute miles 500 feet below.

 1,000 feet above.

 2,000 feet horizontal.

Class G:

1,200 feet or less above the 

surface (regardless of MSL 

altitude)

For aircraft other than 

helicopters:

Day, except as provided in 

§91.155(b)

1 statute mile Clear of clouds.

For helicopters:

Day 1/2 statute mile Clear of clouds

Petitioner Requests that standard cloud clearance limitations apply to all UAS 

operations. We primarily operate in Class G airspace. We simply ask to not be limited 

by cloud clearance requirements for B, C, D and E airspace when operating in Class G 

airspace as seems standard in Grants of Exemption, Conditions and Limitations items 

15 and 17. Operating 1⁄2 statute mile and clear of clouds DOES NOT constitute Special 

VFR as stated in §91.157 Special VFR weather minimums and AIM 4−4−6 Special VFR 

Clearances. Special VFR as stated in §91.157 Special VFR weather minimums is for

operations in and out airports. UAS’s do not operate in or out of airports. 

1⁄2 Statute Mile and clear of clouds is standard basic VFR weather minimums for 

rotorcraft aircraft in class G airspace. Thus, good cause exists for granting Petitioner’s 

request to FOLLOW the limitations of 14 C.F.R. § 91.155(a) with Relief from Grants of 

Exemption, Conditions and Limitations items 15 and 17.
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Part 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall 

have the aircraft inspected as prescribed in subpart E of the same part and shall, 

between required inspections, except as provided in paragraph (c) of the same section, 

have discrepancies repaired as prescribed in Part 43 of the chapter. 

Part 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, preventative maintenance, rebuilding, or 

alteration unless it has been approved for return to service by a person authorized 

under § 43.7 of the same chapter. 

Part 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. 

Part 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, preventative 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. 

 (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 year 

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. 

Petitioner will strictly comply with safety and maintenance procedures included in 

all applicable UAS manufacturer’s instructions and operating manuals. In light of these 

mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), 

and 91.417(a) and (b) are warranted. 
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V. PETITIONER’S PROPOSED OPERATIONS SATISFY SECTION 333

A. UAS Pilot in Command

Petitioner’s UAS pilot in command (PIC) shall hold an airline transport, 

commercial, private, recreational or sport pilot certificate as well as at least a 3

rd Class 

Medical.

B. Unmanned Aircraft System 

The UAS to be operated under this request are less than 55 lbs. fully loaded, will 

be operated at a speed of no more than 100 mph (87 Knots), carry neither a pilot nor 

passenger, carry no explosive materials or flammable liquids, and operate exclusively 

within a secured area. Petitioner’s UAS use a radio frequency spectrum for operation 

and control that complies with Federal Communications Commission (“FCC”) Instruction 

Manual, Aeronavics Flight Operation and Safety Manual and Motion Picture and 

Television Flight Operation Manual,

2 and Petitioner has integrated safety features into 

the UAS, as described in Petitioner’s Flight Operations and User Manuals for: 3D 

Robotics Iris+, Yuneec Q500, Align M690L, and the Aeronavics Skyjib X4 XL. Iris+ 

Operations Manual, Typhoon Q500 User Manual, Typhoon Q500 Quick Start Guide, 

Align Multi-copter Manual (collectively, “operations manuals”).

C. Operating Parameters of Petitioner’s UAS

Petitioner’s UAS operations will be conducted within a sterile environment of 

closed-set filming. In this controlled environment, Petitioner’s operations will remain 

within VLOS of the PIC and VO, below 500 feet AGL, and at speeds below 100 Mph (87

kts)

Petitioner will not conduct UAS operations within 5 nautical miles of the 

geographic center of an airport unless a letter of agreement with that airport’s 

management is obtained and the operation is conducted in accordance with a Notice to 

Airmen (“NOTAM”).

2 The MPTFOM will be submitted separately and confidentially under 14 C.F.R. 11.35(b), as the manuals 

contain proprietary information that the applicant has not and will not share with others. The manuals 

contain operating conditions and procedures that are not available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. §§ 552, et seq.
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Further, the Petitioner requests that night operations be approved with the 

stipulation that daylight conditions exist throughout the flight arena and operations will 

be conducted solely with the boundary of the illuminated area i.e. closed set, such as in 

sports stadiums or indoor arenas with high intensity discharge (HID) lamps providing 

over 1,000 average watts per lamp (approximately), in short as long as day light 

conditions exist that exceed morning or evening civil twilight as described in 14 CFR § 

1.1 “Night”.

Petitioner’s UAS will remain clear and yield the right of way to all manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, and hangliders). Further, Petitioner will use a 

VHF transceiver when operating within 5 miles of an airport or under a high traffic area 

to monitor common traffic advisory frequency (CTAF) in Class G airspace and transmit 

intentions if operating above the surrounding treetop level. After receiving authorization

to operate in class E, D, C, or B air space, we will contact the appropriate air routing 

traffic control center frequency (ARTCC) or tower frequency as required by §91.126 (d), 

§91.127 (c), §91.129 (c)(1) through flight, §91.130 (c)(1) through flight, or §91.131 

(a)(1) and (c)(2)

Although Petitioner seeks to comply with the waiver process as described in FAA 

Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion 

Picture and Television Filming), the current section of Order 8900.1 has specific 

processes that preclude a jurisdictional FAA FSDO from issuing the required Certificate 

of Waiver, because the section did not originally provide for UAS operations. Thus, 

Petitioner seeks exemption from the applicable regulations normally waived during that 

process. Petitioner proposes that the FAA include the required notifications and 

coordination with jurisdictional FSDOs through the conditions and limitations 

accompanying the requested exemption, and that the exemption sought herein will take 

the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 

8900.1. Under this rubric, Petitioner will notify every FSDO with jurisdiction over the 

area that Petitioner plans to operate, just as with manned filming operations, and those 

FSDOs will have the ability to coordinate further conditions and limitations with the UAS 

Integration Office to address any local concerns. 
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Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of

Waiver or Authorization (“COA”) prior to conducting any operations under this grant of 

exemption. In fulfilling its requirements under the COA, Petitioner will be required to 

request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior 

to the operation. 

Petitioner requests authorization to operate internationally and that this 

exemption apply outside of the United States. 

As Motion Picture Production Companies will routinely seek out locations that are 

not necessarily specific to the United States, but portray the appropriate location of the 

story, for both cost and appearance, we cannot control the filming locations; only 

operate on the set the Motion Picture Company has previously scouted and secured. 

All filming locations are on private property and or have full permission by the owner or 

controlling agency to occupy and film on said property. We must have the authority to 

operate internationally so that may be competitive in our business and operate on 

location, wherever that may be. 

We will comply with all applicable ICAO rules and regulations for UAS operations 

and obtain permission from that countries civil aviation authority in which we will be 

operating. Our pilots have many 1000’s of hours of international operating experience. 

Safety, procedure, precaution and policy will remain in the same high regard and not be 

jeopardized in any way. 
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D. The Requested Exemption Promotes the Public Interest

The UAS provides enhanced safety by replacing significantly larger manned 

aircraft carrying crew and flammable fuel with small UAS carrying no passengers, crew 

and or fuel and exponentially less mass and energy. The UAS provides safer work 

conditions because no one involved will have to go into a dangerous environment. 

There is much less risk to life and property on the ground. The UAS is more 

environmentally friendly than a helicopter or airplane as it reduces noise and air 

pollution. UAS use contributes to reduce airport congestion by eliminating the 

commercial use of planes and helicopters for its operations. 

All of our UAS pilots are ATP and Commercial Pilots and have extensive 

experience in NAS and are fully aware of NAS requirements, limitations, arrival and 

departure routings in and out airports and knowledge of the class of airspace we will be 

operating in anywhere we are. This contributes significantly to the safety to all users of 

the NAS and the general public. We are professional pilots and know full well the 

importance preparation, use of checklists, regular maintenance and knowing the 

performance and limitations of our aircraft.

As stated above, this exemption request promotes safety and is the public 

interest. Moreover, as the FAA has already recognized, “UAS provide an additional tool 

for the filmmaking industry, adding a greater degree of flexibility, which supplements the 

current capabilities offered by manned aircraft.” See Exemption No. 11062, Regulatory 

Docket No. FAA-2014-0352, at p. 22. 

VI. PETITIONER’S AIRCRAFT SPECIFICATIONS

Yuneec Typhoon Q500 Quad-copter

Weight: 1700g (3.75lbs)

Maximum Ascent Rate: 6m/s (19.69ft/s)

Maximum Decent Rate: 2m/s (6.56ft/s)

Maximum Speed: 8m/s (26.25mph)

Dimensions: 420x420x210mm (16.5x16.5x8.3in) 
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3D Robotics Iris+ Quad-copter

Weight: 1282g (2.78lbs)

Maximum Ascent Rate: 8m/s (26.25ft/s)

Maximum Decent Rate: 4m/s (13.12ft/s)

Maximum Speed: 20m/s (44mph)

Dimensions: 550x550x200mm (21.65 x 21.65 x 7.87in)

Align M690L Hex-copter

Weight: 3400g (7.93lbs)

Maximum Ascent Rate: 6m/s (19.69ft/s)

Maximum Decent Rate: 4m/s (13.12ft/s)

Maximum Speed: 15m/s (49.21ft/s)

Dimensions: 900x900x446mm (35.43 x 35.43 x 17.60in) 

Aeronavics Skyjib X4 XL Octo-copter

Max T/O Weight: 22Kg (48.4lbs)

Maximum Ascent Rate: TBD

Maximum Decent Rate: TBD

Maximum Speed: 60mph

Dimensions: 1020x1020x600mm (40.15 x 40.15 x 23.60in) 

VII. CONCLUSION 

For the foregoing reasons, the regulatory exemptions requested herein should be 

granted and Petitioner should be permitted to conduct UAS operations for the purpose 

of aerial data collection including closed-set filming. 

Respectfully submitted,

West Coast Sky Cam, 

By

William F Meyers Jr. - Petitioner 

ATP 3141175