§ 61.125 Aeronautical knowledge. § 61.105 Aeronautlcallcnowledge. 

(a) General. A person who applies for a conunercial (a) General. A person who is applying for a private pilot certificate must receive and log ground pilot certificate must receive and log ground 

training ... training ... 

(b) Aeronauticallmowledgc areas. (b) Aeronauticnllmowledge areas. 

(1) Applicable Federal Aviation Regulations ofthis (1) Applicable Federal Aviation Regulations ofthis 

chapter that relate to commercial pilot privileges, chapter that relate to private pilot privileges, 

Limitations, and flight operations; limitations, and flight operations; 

(2) Accident reporting requirements of the National (2) Accident reporting requirements of the National 

Transportation Safety Board· Transportation Safety Board; 

(3) Basic aerodynamics and the principles of flight; (1 0) Principles of aerodynamics, powerplants, and 

aircraft systems; 

( 4) Meteorology to include recognition of critical ( 6) Recognition of critical weather situations from the 

weather situations, windshear recognition and ground and in flight, windshear avoidance, and the 

avoidance, and the use of aeronautical weather procurement and use of aeronautical weather reports 

reports and forecasts; and forecasts· 

(5) Safe and efficient operation of aircraft; (7) Safe and efficient operation of aircraft, inc! uding 

collision avoidance, and recognition and avoidance of 

wake turbulence; 

(6) Weight and balance computations; (9) Weiaht and balance computations; 

(7) Use of performance charts; (8) Effects of density altitude on takeoff and climb 

performance; 

(8) Significance and effects of exceeding aircraft ~<~~<Related to other areas within the private 

p_erformance limitations; requirements but not referet\ced specifically** 

(9) Use of aeronautical charts and a magnetic (4) Use of aeronautical charts for VFR navigation 

compass for pilotage and dead reckoning; using pilotage, dead reckoning, and navigation 

systems· 

(10) Use ofnir navigation facilities; ( 4) Use of aeronautical charts for VFR navigation 

using pilotage, dead reckoning, nnd navigation 

svstems; 

{5) Radio communication procedures; 

(11) Aeronautical decision making and judgment; (I 2) Aeronautical decision making and judgment; and 

(12) Principles and functions of aircraft systems; (10)Principles of aerodynamics, powerplants, and 

aircraft systems; 

( 13) Maneuvers, procedures, and emergency (7) Safe and efficient operation of aircraft, including 

operations appropriate to the aircraft; collision avoidance, and recognition and avoidance of 

wake turbulence; 

{11) Stall awareness, spin entry, spins, and spin 

recovery techniques for the airplane and glider 

category ratin!:lS' 

(14) Night and high-altitude operations;  Although not mentioned in § 61.105, 3 hours of 

night flight training is required for the private per § 

61.107 and § 61.109. For this comparison, highaltitude operations are considered not applicable.**  

(15) Procedures for operating within the National {3) Use of the applicable portions ofthe ''Aeronautical 

Airspace System; and Information Manual" and FAA advisory circulars; 

( 13) Preflight action that includes- (i) How to obtain 

infom1ation on runway lengths at airports of intended 
( 16) Procedures for flight and ground training for **For this comparison (ASEL), these operations are 

lighter-than-air ratings."'* considered not applicable.** 

§ 61.127 Flight proficiency. § 61.107 Flight proficiency. 

(a) General. A person who applies for a commercial (a) General. A person who applies for a private pilot 

pilot certificate must receive and log ground and certificate must receive and log ground and flight 

flight training training 

(b)Areas of operation. (I) For an airplane category (b) Areas of operation. (1) For an airplane category 

rating with a single-engine class rating: rating with a single-engine class rating: 

(i) Preflight preparation; (i) Preflight preparation; 

(ii) Preflight procedures· (ii) Preflight procedures; 

(iii) Airport and seaplane base operations; (iii) Airport and seaplane base operations; 

(iv} Takeoffs, landings and go-arounds; {iv) Takeoffs, landings, and go-arounds; 

_(v) Performance maneuvers; {v) Performance maneuvers; 

(vi) Ground reference maneuvers; (vi) Ground reference maneuvers; 

(vii} Navigation· (vii) Navigation; 

(viii) Slow flight and stalls; (viii) Slow flight and stalls: 

(ix) Emergency operations· (x) Emergency operations· 

(x) High-altitude operations; and **For this comparison, high-altitude operations are 

considered not applicable.*"' 

(xi) Postflight procedures. (xii) Postflight procedures. 

**Not referenced specifically'~<* (ix) Basic instrument maneuvers; 

*'*Not referenced specifically"'* (xi) Night operations, except as provided in .§61.11 0 

ofthis part; and 

The specific UAS airmanship skills required for Ast1·aeus' PIC(s): Some of the 

requirements for Astraeus' PIC(s) are provided in their proprietary documents. However, as 

with other exemptions that contain specific pilot qualifications, e.g. Exemption Nos. 7830, 

6802K, and 6540N, those pilot requirements become conditions and limitations within the 

grant of exemption. An abbreviated summary of those PIC requirements include the 

following: 

a. The PIC must possess a Private Pilot's Certificate and a valid third-class 

medical certificate; 

b. The PIC must have accumulated and logged a minimum of200 flight cycles 

and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours 

logged as a UAS pilot with a similar UAS type (single blade or multirotor). 

c. The PIC must have accumulated and logged a minimum of five hours as UAS 

pilot with the make and model of UAS to be utilized for operations under the 

exemption and three take-offs and landings in the preceding 90 days. 

d. The PIC must have successfully completed the qualification process as 

specified in the MPTOM and FOPM, to include a knowledge and skill test. 

The FAA's analysis regarding PIC requirements: The parallel foundation of aeronautical 

knowledge required for private and commercial pilots is shown in the above table. Private 
conducted for compensation or hire. However, the experience obtained beyond a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily aid 

a pilot in the operational environment proposed by the petitioner; the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the 

airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing. 

The FAA shares ALP A's concerns regarding appropriate training on the UAS being utilized. The FAA has reviewed the petitioner's knowledge and experience criteria for its PICs. The 

FAA finds that the combination of aeronautical knowledge, UAS airmanship skills, and verification through testing is a sufficient method for Astraeus to evaluate a pilot's qualifications, given that operations will be conducted within the limitations outlined in this 

exemption. 

The knowledge and airmanship test qualifications have been developed by Astraeus for the 

UAS operations proposed in their petition for exemption. There are no established practical 

test standards that support a judsdictional FAA FSDO evaluation and approval of company designated examiners. The petitioner will conduct these tests in accordance with its FOPM 

and the conditions and limitations noted below. Given the constraints of the proposed operations, the FAA believes this would not adversely affect the safety of the NAS. 

The petitioner plans to operate in a unique and limited environment. Given the 1) separation of these closed-set filming operations from other manned operations, 2) the parallel nature of private pilot aeronautical knowledge requirements to those of commercial requirements, and 3) the UAS ailmanship skills of Astraeus' PICs, the FAA finds that the additional manned 

aitmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Astraeus' specific proposed operations. Upon consideration of 

the overall safety case presented by the petitioner and the concerns of the commenters, the 

FAA finds that granting the requested relief from 14 CFR § 61.113(a) and (b), provided the conditions and limitations outlined below, would not adversely affect the safety of the NAS. 

Another consideration supporting the certificate requirement is that pilots holding a private pilot certificate are subject to security screening by the Department of Homeland Security. This requirement should ameliorate security concems over UAS operations under this exemption. 

Operating parameters of the UAS 

Astraeus has stated that it plans to comply with the waiver process as described in FAA Order 

8900.1, Volun1e 3, Chapter 8, Section 1 (V3, C8, Sl) Issue a Certificate of Waiver for Motion 

Picture and Television Filming. The FAA agrees with this philosophy; however, the current 

section of Order 8900.1 has specific processes that preclude a jurisdictional FAA FSDO from 

issuing the required Certificate ofWaiver, because the section did not originally provide for 
U

a

ned Air Vehicle authorizations.

 

Therefore, the FAA will exempt Astraeus from the applicable regulations normally waived 

during that process. The FAA will then include the required notifications and coordination 

with jurisdictional FSDOs through the conditions and limitations listed below. Motion picture 

and television filming waivers similar to Astraeus' operation are normally issued from one 

jurisdictional FSDO and can be used in locations covered by other geographically responsible 

FSDOs through notification. Those local FSDOs then have the ability to review the proposed 

plan of activities and associated operations manual(s) and levy any additional local special 

provisions. Since Astraeus' operation deals specifically with UAS, this exemption will take 

the place of the Certificate of Waiver normally issued by a jurisdictional FSDO under 8900.1 

V3, C8, S 1. Every FSDO with jurisdiction over the area that Astraeus plans to operate within 

must still be notified, 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, as stated below in the conditions and limitations section of this 

exemption. 

The petitioner must also obtain a Certificate ofWaiver or Authorization (COA) from the 

FAA's Air Traffic Organization (ATO) prior to conducting any operations. This is an existing 

process that not only makes local Air Traffic Control (ATC) facilities aware ofUAS 

operations, but also provides ATO the ability to consider airspace issues that are unique to 

UAS Qperations. The COA will require the operator to request a Notice to Airman (NOT AM), 

which is the mechanism for alerting other users of the NAS to the UAS activities being 

conducted. Therefore, the FAA believes that adherence to this process is the safest and most 

expeditious way to permit Astraeus to conduct their proposed UAS operations. The conditions 

and limitations below prescribe the requirement for Astraeus to obtain an A TO-issued COA. 

Regarding the petitioner's requested relief from 14 CPR§ 91.7(a) Civil Aircraft 

Airworthiness, Astraeus' request is based on the fact that no airworthiness certificate will be 

issued for the UAS. As previously noted, the petitioner's UAS will not require an 

airworthiness cettificate in accordance with 14 CPR part 21, Subpatt 

H. Based on the fact that 

an airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary. 

In accordance with the pertinent part of 14 CFR § 91 . 7(b ), the PIC of the UAS is responsible 

for determining whether the aircraft is in condition for safe flight. The petitioner's manuals for 

maintenance and operations include safety checklists to be used prior to each flight. 

Regarding the petitioner's requested relief from 14 CPR§ 91.9(b)(2) Civil aircraft flight 

manual, marking, and placard requirements and§ 91.203(a) and (b) Civil aircraft: 

Certifications required, the original intent of these regulations was to display an aircraft's 

airworthiness, certification, and registration documents so they would be easily available to 

inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft's control station," 
there will be no approved Airplane or Rotorcraft Flight Manual as specified in paragraph 

(b )(1 ), the FAA believes that the petitioner can comply with the other applicable requirements 

in14 CFR § 91.103(b)(2). The procedures outlined in the petitioner's :MPTOM and FOPM 

address the FAA's concerns regarding compliance with§ 91.103(b). The petitioner has also 

stated its intent to comply with§ 91.103(a): "The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft performance 

data before initiation of flight." The FAA has imposed stricter requirements with regard to 

visibility and distance from clouds; this is to both keep the UA from departing VLOS and to 

preclude the UA from operating so close to a cloud as to create a hazard to other aircraft 

operating in the NAS. The FAA also notes the risks associated with sun glare; the FAA 

believes that the PIC's and VO's ability to still see other air traffic, combined with the PIC's 

ability to initiate a return-to-home sequence, are sufficient mitigations in this respect. The PIC 

will also accmmt for all relevant site-specific conditions in their preflight procedures. 

Therefore, the FAA finds that exemption from 14 CFR § 91.103 is not necessary. 

Regarding the petitioner's requested relief from 14 CFR § 91.1 09 Flight instruction; 

Simulated instrument flight and certain flight tests, the petitioner did not describe training 

scenarios in which a dual set of controls would be utilized or required, i.e. dual flight 

instruction, provided by a flight instructor or other company-designated individual, that would 

require that individual to have fully functioning dual controls. Rather, Astraeus evaluates the 

qualification of its PICs based on their experience with the UAS to be operated and verifies 

through testing, in lieu of foffi1alized training. As such, the FAA finds that the petitioner can 

conduct its operations without the requested relief from 14 CPR§ 91.109. 

Regarding the petitioner's requested relieffrom 14 CFR § 91.119 Minimum safe altitudes, the 

petitioner failed to specify the pertinent part of 14 CFR § 91.119 from which they require 

relief. Relief from 14 CFR § 9l.ll9(a), which requires operating at an altitude that allows a 

safe emergency landing if a power unit fails, is unprecedented and unwarranted. Relief from § 

14 CFR 91.119(b), operation over congested areas, is not applicable, because the petitioner 

states that operations will only be conducted within the sterile area described in the MPTOM. 

Although the petitioner specifically mentioned relieffrom 14 CFR § 91.119(d), the FAA finds 

that relief is only needed from 14 CFR § 91.119( c), which is consistent with the relief 

typically provided to manned operations in FAA Order 8900.1 V3, C8, Sl Issue a Certificate 

ofWaiver for Motion Picture and Television Filming. This Order allows for relieffrom § 

91. I 19( c) with respect tq those participating persons, vehicles, and structures directly involved 

in the pe1formance of the actual filming. In accordance with the petitioner's stated intention to 

adhere to Order 8900.1 V3, C8, S 1, persons other than participating persons 1 are not allowed 

1 Pe1· Order 8900.1 V3, C&, S 1, pa11icipnting persons are all persons associated with the filming production, and 

they must be briefed on the potential risk of the proposed flight operation(s) and must acknowledge and accept 

those risks. Nonparticipating persons are the public, spectators, media, etc., not associated with the filming 

production. 
y 

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, 

, 

g

, 

etc. Such barriers may protect nonparticipating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. 

The FAA notes the petitioner's additional guidelines in its MPTOM to protect its participating 

production personnel, and finds that relief from 14 CPR § 91.119( c) is warranted, provided 

adherence to the procedures outlined in the petitioner's MPTOM and FOPM, and the FAA's 

additional conditions and limitations outlined below. However, all nonparticipating personnel 

will be required to be at least 500 feet from flight operations, with possible relief to allow 

reductions to 200 feet, as specified above. 

Regarding the petitioner's t•equested relieffrom 14 CFR § 91.121 Altimeter Settings, the FAA 

believes that an altitude reading is a critical safety component of the petitioner's proposed 

operation. Although the petitioner will not have a typical barometric altimeter onboard the 

aircraft, the FAA finds the petitioner's intention to operate the UA within VLOS and at or 

below 400 feet AGL, combined with the petitioner's intention to provide altitude information 

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

aircraft to a grotmd-based on-screen display, to be a sufficient method for ensuring the UAS 

operations do not adversely affect safety. The altitude information will be generated by 

equipment installed onboard the aircraft, as specified using GPS triangulation, or digitally 

encoded barometric altimeter, or 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. The FAA has determined that good cause exists for granting the requested relief to 

14 CFR § 91.121. 

Regarding the petitioner's requested relief from 14 CFR § 91.15l(a) Fuel requirements for 

flight in VFR conditions, relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in 14 CFR § 91.151 (a), including Exemption Nos. 2689, 5745, and 

10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811, 

10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner states 

that its UAS operations will be conducted in a controlled closed-set filming environment, with 

UA under 55 pounds, at speeds below 50 Knots, and within VLOS. These factors, combined 

with Astraeus' stated intention to terminate flights after 30 minutes or with 25% remaining 

battery power (whichever occurs first), provides the FAA sufficient reason to grant the relief 

from 14 CFR § 91.15l(a) as requested in accordance with the conditions and limitations 

proposed by Astraeus. 

With respect to the petitioner's request to operate at night, the FAA finds that the petitioner 

has not provided a sufficient safety case and mitigations, per FAA Order 8900.1 V16, C5, S3 

General Operational Requirements, to avoid collision hazards at night. All previous VASspecific grants of relief from 14 CFR § 91.151(a) have restricted flights to daytime VFR 

conditions only. While the FAA acknowledges the petitioner's stated film set lighting 

techniques to mitigate the risks of nighttime operations, the petitioner has not provided 
p

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d seek an 

amendment to its exemption to permit night operations. 

Additionally, in evaluating the petitioner's proposed operating parameters with regard to 

VLOS and a safe operating perimeter, the FAA considered operations from a moving device 

or vehicle. Since the petitioner did not discuss provisions for these circumstances, the 

conditions and limitations below preclude operations from moving devices or vehicles. 

Public Interest 

The FAA fmds that a grant of exemption is in the public interest. The enhanced safety 

achieved using a 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. The FAA also finds that UAS provide an 

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

supplements the current capabilities offered by manned aircraft. 

The table below summarizes the FAA's determinations regarding the relief sought by the 

petitioner: 

Relief sought by ~etitioner {14 CFR} FAA determination (14 CFR} 

Part21 Not necessaty 

45.23(b) Not necessary 

61.113(a) and (b) Granted with conditions and limitations 

91.7(a) Not necessary 

91.9(b)(2) Not necessary 

91.103 Not necessary with conditions and limitations 

91.109 Not necessary 

91.119 Paragraph (c) granted with conditions and limitations 

91.121 Granted with conditions and limitations 

91.15l(a) 91.15l(a)(l), day, granted with conditions and limitations; 91.15l(a)(2), night, denied 

91.203(a) and (b) Not necessary 

91.405(a) Granted with conditions and limitations 

91.407(a)(l) Granted with conditions and limitations 
91.417(a)and (b) Granted with conditions and limitations 

The FAA's Decision 

In consideration of the foregoing, I find that a gmnt 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, Astraeus Aerial is granted an exemption from 

14 CFR §§ 61.113(a) and (b); 91.119(c); 91.121; 91.15l(a); 91.405(a); 91.407(a)(l); 

91.409(a)(l) and (2); and 91.417(a) and (b) to the extent necessary to allow Astraeus to 

operate unmanned aircraft systems (UAS) for the purpose of scripted, closed-set filming for the motim1 picture and television industry. This exemption is subject to the conditions and 

Limitations listed below. 

Conditions and Limitations 

Relative to this grant of exemption, Astraeus is hereafter referred to as the operator. 

The Flight Operations and Pmcedures Manual (FOPM) and Motion Picture and Television 

Operations Manual (MPTOM) are hereafter collectively referred to as the operator's manual. 

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. 

The operator proposed the following conditions and/or limitations, which were accepted by theFAA.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: Astraeus Aerial Cinema System V.3CS UAS aircraft variant, serial #001 onward (V.3). Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant. 

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 ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All altitudes 

reported to A TC must be in feet AGL. 

2 Conditions and limitations outlined by the operator may have been modified for clarity. 
5. All operations must utilize a visual observer (VO). 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. 

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. 

The operator may update or revise its operator's manual. It is the operator's responsibility 

to track such revisions and present updated and revised documents to the Administratot· 

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. 

7. 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 necessary 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 properly documented in the aircraft records. 

8. 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 PIC 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. 

9. 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: 
c. Powerplant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

1. Ground control station (if used); and 

j. Any other components as determined by the operator; 

10. The Pilot In Command (PIC) must possess at least a private pilot certificate and at least a 

ctll1'ent 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 PIC is rated on his or 

her pilot certificate. 

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CFR § 61.51(b), a minimum of200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations 

are considered nonparticipants, and the PIC must operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119. 

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CPR§ 61.5l(b), a minimum offive hours as UAS pilot operating the make and model 

ofUAS to be utilized for operations under the exemption and three take-offs and three 

landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency flights can be conducted under this grant of exemption to accomplish 
§ 

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator's manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available 

to the Administrator upon request. 

14. Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator-approved and -qualified pilot must be successfully completed and documented. This documentation must be 

available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator's manual. 

15. The UA may not be operated directly over any person, except authorized and consenting production pet·sonnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 

16. Regarding the distance from participating persons, the operator's manual has safety mitigations for authorized and consenting production personnel. At all times, those 

persons must be essential to the closed-set film operations. Because these procedures are specific to participating persons, no further FSDO or aviation safety inspector approval is 

necessary for reductions to the distances specified in the petitioner's manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, Sl Issue a Certificate of Waiver for Motion Picture and Television Filming. 

17. Regarding distance from nonpatticipating 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 adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector's evaluation of the filming production area to note terrain features, obstructions, buildings, safety 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, S I. 
19. The UAS must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the operator's manual. 

20. 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 operator, the FAA has 

determined that any operati~ns conducted under this grant of exemption must be done 

pursuant to the following conditions and limitations: 

2l. 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 (NOT AM) not 

more than 72 hours in advance, but not less than 48 hours prior to the operation. 

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 large as practicable. 

23. 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 added to the operator's manual. 

24. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

25. The operator must develop UAS teclmician qualification criteria. These criteria must be 

added to the operator's manual. 

26. The preflight inspection 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 sections of the operator's manual. 

27. 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. 
g

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS filming production conducted 

under this grant of exemption; 

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

UAS; 

d. Make, model, and serial or N-m1mber of UAS to be used; 

e. Name and certificate number ofUAS PICs involved in the filming production event; 

f. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave pe1mission 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. 

29. The 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. 

30. The UA must remain clear and yield 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.). 

31. UAS operations may not be conducted during night, as defined in 14 CPR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights unde1· special visual flight rules (SVFR) are not authorized. 

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

33. 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. 
agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 

35. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 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 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 September 30, 2016, unless sooner superseded or rescinded. 

Issued in Washington, DC, on September 25, 2014. 

Is/ 

Michael J. Zenkovich 

Deputy Director, Flight Standards Service