Exemption No. 11204

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

In the matter of the petition of

BUILD IMAGERY, LLC

for an exemption from §§ 61.113(a) and (b), 

91.103, 91.119(c), 91.121, 91.151(a), 

91.405(a), 91.407(a)(1), 91.409(a)(2), and 

91.417(a) and (b) of Title 14, Code of 

Federal Regulations

Regulatory Docket No. FAA–2014–0886

GRANT OF EXEMPTION

By letter dated October 23, 20141, Daniel Ursitti, Executive Producer, Build Imagery,

LLC (hereinafter Petitioner or Operator), 11870 Santa Monica Boulevard, West Los Angeles, 

California 90025, petitioned the Federal Aviation Administration (FAA) for an exemption

from §§ 61.113(a) and (b), 91.103, 91.119(c), 91.121, 91.151(a), 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 

exemption would allow the petitioner to operate the 3d Robotics Iris+ and the DJI Inspire 1

unmanned aircraft systems (UAS) for aerial photography for the architectural, engineering, 

and construction industry sites.

2 and in motion picture and television operations.

The petitioner supports its request with the following information:

See Appendix A for the petition submitted to the FAA describing the proposed operations, 

including the regulations that the petitioner seeks an exemption.

The petitioner has provided the following information to support its request for an exemption:

 1 By email dated February 8, 2015, the petitioner responded to the FAA’s request for information. 2 The petitioner originally proposed to operate its UAS for motion picture and television operations. By email 

dated February 26, 2015, the petitioner notified the FAA that it would focus its operations in the architectural, 

engineering, and construction industry.
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1) Build Imagery Aircraft Specification

2) Build Imagery Unmanned Aerial Systems Operations Manual

3) Build Imagery Flight Check list

4) Iris+ Operations Manual

5) Iris+ Flight Checklist

The petition and the document above are hereinafter referred to as the operating documents.

The FAA evaluated the petition and determined it was not precedent-setting. Therefore, a 

summary of the petition was not published in the Federal Register for public comment.

The FAA’s analysis is as follows:

The FAA has organized its analysis into four sections: (1) UAS, (2) the UAS pilot in 

command (PIC), (3) the UAS operating parameters, and (4) the public interest.

Unmanned Aircraft System (UAS)

In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference 

to 49 USC § 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, the Secretary of Transportation has determined 

that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the 

requested relief from 14 CFR parts 21, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The petitioner has proposed to operate two UAS; the 3d Robotics Iris+ and the DJI Inspire 1. 

However, based on the information provided by the petitioner in its operating documents, this 

grant of exemption applies only to the 3d Robotics Iris+.

Manned aircraft conducting aerial photography operations can weigh thousands of pounds or 

more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 

carry large quantities of fuel. The petitioner’s unmanned aircraft (UA) weighs approximately 

4 pounds. The pilot and crew will be remotely located from the aircraft. The limited weight 

and construction reduces the potential for harm to persons or damage to property in the event 

of an incident or accident. The risk to an onboard pilot and crew during an incident or 

accident is eliminated with the use of a UAS for the proposed operation.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

UA carries no fuel and therefore the risk of fire following an incident or accident due to fuel 

spillage is eliminated. 

The petitioner’s UAS has the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. 

The UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link 

event with a pre-coordinated, predictable, automated flight maneuver. These safety features 
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provide an equivalent level of safety compared to a manned aircraft holding a restricted 

airworthiness certificate performing a similar operation.

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405(a) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(2) Inspections, and 91.417(a) and (b) Maintenance records, the FAA has evaluated 

the petitioner’s request and determined that an exemption to these requirements is warranted. 

The FAA notes that the petitioner’s operating documents contain preflight and post flight 

checks for the UAS. The FAA has also determined that relief from § 91.409(a)(1) is also 

necessary because it is an alternate inspection requirement of § 91.409(a)(2). The FAA finds 

that adherence to the operating documents, as required by the conditions and limitations 

below, is sufficient to ensure that safety is not adversely affected.

UAS Pilot in Command (PIC)

Regarding the petitioner’s requested relief from 14 CFR § 61.113(a) and (b), Private pilot 

privileges and limitations, the petitioner requested to operate its UAS with a PIC holding at 

least a private pilot’s certificate and a current third-class medical certificate. Under current 

regulations, civil operations for compensation or hire require a PIC holding a commercial 

pilot certificate per 14 CFR part 61. Based on the private pilot limitations in accordance with 

pertinent parts of 14 CFR § 61.113(a), a pilot holding a private pilot certificate cannot act as a 

PIC of an aircraft for compensation or hire. However, in Grant of Exemption No. 11062 to 

Astraeus Aerial (Astraeus) (see Docket No. FAA-2014-0352), the FAA determined that a PIC 

with a private pilot certificate operating the Astraeus UAS would not adversely affect 

operations in the NAS or present a hazard to persons or property on the ground. 

The FAA has analyzed the petitioner’s proposed operation and has determined that it does not 

differ significantly from the situation described in Grant of Exemption No. 11062. The 

petitioner plans to operate in uncontrolled airspace and over private property with controlled 

access. Given: 1) the similar nature of the petitioner’s proposed operating environment to that 

of Astraeus, 2) the parallel nature of private pilot aeronautical knowledge requirements to 

those of commercial requirements as discussed in Exemption No. 11062, and 3) the limited 

airmanship skills necessary to operate the UAS, the FAA finds that the additional manned 

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

airmanship skills necessary for the petitioner’s specific proposed operations. 

With regard to the airmanship skills necessary to operate the UAS, the petitioner did not 

specify a training program, stating that the PIC will enroll in appropriate training for fixed 

wing aircraft. The conditions and limitations below require the petitioner to ensure the PIC 

has demonstrated the ability to safely operate the UAS in a manner consistent with how the

UAS will be operated under this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles, and structures.

In conclusion, the FAA finds that a PIC holding a private pilot certificate and a third-class 

airman medical certificate, and who has demonstrated the ability to safely operate the UAS in 
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a manner consistent with how the UAS will be operated under this exemption per the 

conditions and limitations, can conduct the proposed UAS operations without adversely 

affecting the safety of the NAS. Upon consideration of the overall safety case presented by 

the petitioner, the FAA finds that relief from 14 CFR § 61.113(a) is granted, with the 

conditions and limitations outlined below. The FAA also finds that relief from 14 CFR § 

61.113(b) is not necessary.

The petitioner indicated it will supplement its proposed operation(s) with a visual observer 

(VO). In Grant of Exemption No. 11062, the FAA agreed with the petitioner’s proposed use 

of a VO and required a VO to be used in all UAS operations. The UA must never be operated 

beyond the actual visual capabilities of the VO, and the VO and PIC must have the ability to 

maintain VLOS with the UA at all times. It is the responsibility of the PIC to be aware of the 

VO’s visual limitations and limit operations of the UA to distances within the visual 

capabilities of both the PIC and VO. Moreover, the VO will not be operating the aircraft. 

Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not consider a 

medical certificate necessary for the VO.

The FAA considers the PIC to be designated for the duration of the flight. Therefore, per the 

conditions and limitations below, the PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight.

UAS Operating Parameters

While the petitioner did not request relief from 14 CFR § 91.7(a) Civil aircraft airworthiness, 

the FAA finds that relief from § 91.7(a) is necessary. Although the petitioner’s UAS will not 

require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H, the FAA 

considers the petitioner’s compliance with its operating documents to be a sufficient means 

for determining an airworthy condition. Therefore, relief from § 91.7(a) is granted. The 

petitioner is still required to ensure that its aircraft is in an airworthy condition – based on 

compliance with the operating documents prior to every flight, and as stated in the conditions 

and limitations below.

Additionally, in accordance with 14 CFR § 91.7(b), the PIC is responsible for determining 

whether the UA is in a condition for safe flight. The FAA, as in grant of Exemption No. 

11062 to Astraeus, has determined that the operating documents include procedures to be 

used prior to each flight that can ensure compliance with § 91.7(b). The petitioner is required 

to ensure that its aircraft is in a condition for safe flight – based on compliance with the 

operating documents– prior to every flight.

Regarding the petitioner’s requested relief from 14 CFR § 91.103 Preflight Action, the 

petitioner requires each PIC to take certain actions before flight to ensure the safety of the 

flight. The petitioner states the exemption is needed because “FAA approved rotorcraft flight 

manuals will not be provided for the aircraft.” Although there will be no approved Airplane 

or Rotorcraft Flight Manual available, the FAA believes that the petitioner can comply with 

the other applicable requirements in § 91.103. The procedures outlined in the operating 
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documents address the FAA’s concerns regarding compliance with § 91.103. The PIC will 

take all actions including reviewing weather, flight battery requirements, landings, 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 the VLOS. The FAA also notes the risks associated with sun glare; the 

FAA believes the that 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 account for all relevant site-specific conditions in their preflight procedures. 

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

Regarding the petitioner’s requested relief from 14 CFR § 91.119(c) Minimum safe altitudes, 

the petitioner states that relief from § 91.119(c) is necessary because it proposes to operate 

below 500 feet above ground level. Section 91.119(c) states that no person may operate an 

aircraft below the following altitudes; 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. 

The petitioner states that it will operate pursuant to the following, self-imposed, restrictions 

related to § 91.119(c): 

• Petitioner will ensure aircraft operations remain within VLOS of the PIC and will be 

visually monitored at all times;

• All operations will avoid congested or populated areas;

• All operations will be conducted within a confined sterile area with the permission of 

the property owners or local officials;

• All operations will be conducted at or below 400 feet AGL;

• Petitioner will obtain consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation;

• A briefing will be conducted for planned UAS operations prior to each day’s flight.

Regarding stand-off distances from persons, vessels, vehicles and structures, 

14 CFR § 91.119(c) requires that aircraft operate no closer than 500 feet to these persons or 

objects. As discussed in Exemption No. 11109 (Clayco, Inc.), operations conducted closer 

than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. Therefore, 

the FAA is requiring that prior to conducting UAS operations, all persons not essential to 

flight operations (nonparticipating persons) must remain at appropriate distances. In open 

areas, this requires the UA to remain 500 feet from all persons other than essential flight 

personnel (i.e. PIC, VO, operator trainees or essential persons). 

The FAA has also considered the UA’s maximum gross weight of approximately 4 pounds. If 

barriers or structures are present that can sufficiently protect nonparticipating persons from 

the UA or debris in the event of an accident, then the UA may operate closer than 500 feet to 

persons afforded such protection. The operator must also ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 
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protection and are within 500 feet of the UA, flight operations must cease immediately. 

When considering how to immediately cease operations, the primary concern is the safety of 

those nonparticipating persons. In addition, the FAA finds that operations may be conducted 

closer than 500 feet to vessels, vehicles and structures when the owner/controller of any such 

vessels, vehicles or structures grants permission for the operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not 

present an undue hazard.

Thus, the FAA finds that relief from § 91.119(c) is warranted provided adherence to the 

procedures in the operating documents and the FAA’s additional conditions and limitations 

outlined below. 

Regarding the petitioner’s requested relief from 14 CFR § 91.121 Altimeter Settings, the 

UAS will not have a typical barometric altimeter onboard the aircraft. It uses information 

generated from GPS to transmit altitude information to the PIC. As stated in the conditions 

and limitations below, the FAA requires any altitude reported to Air Traffic Control (ATC)

to be in feet above ground level (AGL). The petitioner may choose to set the GPS altitude 

indicator to zero feet AGL rather than local barometric pressure or field altitude before 

flight. Considering the limited altitude of the proposed operations, relief from 14 CFR § 

91.121 is granted to the extent necessary to comply with the applicable conditions and 

limitations stated below.

Regarding the petitioner’s requested relief from § 91.151(a) Fuel requirements for flight in 

VFR conditions, prior relief has been granted for manned aircraft to operate at less than 

prescribed minimums, 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, 

VFR conditions. The petitioner proposes to land the UAS after 10 minutes in flight or prior to 

25% battery power remaining. The operating documents indicate that the UAS will return to 

the launch point and land when the battery reaches 25% of capacity. These factors provide the 

FAA with sufficient reason to grant the relief from 14 CFR § 91.151(a) in accordance with the 

conditions and limitations below. The PIC would be prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is enough power to fly to the 

intended landing point at normal cruising speed and land the UA with 25% battery power 

remaining.

The FAA Air Traffic Organization (ATO) reviews all proposed UAS operations and evaluates 

the safety of these operations relative to the requested airspace through the existing Certificate 

of Waiver or Authorization (COA) process. The majority of current UAS operations 

occurring in the NAS are being coordinated through Air Traffic Control (ATC) by the 

issuance of a COA. This process not only makes local ATC facilities aware of UAS 

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

UAS operations. The COA will require the operator to request a NOTAM, which is the 

mechanism for alerting other users of the NAS to the UAS activities being conducted. The 

conditions and limitations below prescribe the requirement for the petitioner to obtain an 

ATO-issued COA.
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Public Interest

The FAA finds that this 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 following table summarizes the FAA’s determinations regarding regulatory relief:

Relief considered (14 CFR) FAA determination (14 CFR)

61.113(a) and (b)

Relief from 61.113(a) is granted with 

conditions and limitations; relief from 

61.113(b) not necessary

91.7(a) Relief granted with conditions and 

limitations

91.103 Relief not necessary 

91.119(c) Relief granted with conditions and 

limitations

91.121 Relief granted with conditions and 

limitations

91.151(a) Relief granted for paragraph (a)(1), day, 

with conditions and limitations

91.405(a) Relief granted with conditions and 

limitations

91.407(a)(1) Relief granted with conditions and 

limitations

91.409(a)(1) and (2) Relief granted with conditions and 

limitations

91.417(a) and (b) Relief granted with conditions and 

limitations

The FAA’s Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Build Imagery, LLC is granted an exemption from 

14 CFR §§ 61.113(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 

91.409(a)(1) and (2); 91.417(a) and (b) to the extent necessary to allow the petitioner to 

operate a UAS for the purpose of conducting aerial photography on construction sites. This 

exemption is subject to the conditions and limitations listed below.
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Conditions and Limitations

Relative to this grant of exemption, Build Imagery LLC is hereafter referred to as 

the operator.

The petition and the following supporting documentation are hereinafter referred to as the 

operating documents: 

1) Build Imagery Aircraft Specification

2) Build Imagery Unmanned Aerial Systems Operations Manual

3) Build Imagery Flight Check list

4) Iris+ Operations Manual

5) Iris+ Flight Checklist

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.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1) Operations authorized by this grant of exemption are limited to the following aircraft 

described in the operating documents which is an Iris+, four rotor quadcopter, 

weighing less than 4 pounds. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant.

2) UAS operations under this exemption are limited to conducting operations for the 

purpose of aerial photography on construction sites.

3) The UA may not be flown at a ground speed exceeding 30 knots.

4) The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents. All 

altitudes reported to ATC must be in feet AGL. 

5) The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate.

6) 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. Electronic messaging or 
9

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight.

7) The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

8) The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operating documents, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise 

its operating documents. It is the operator’s responsibility 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 upon 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 operating 

documents. 

9) 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 must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

10) 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 operating documents. 

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 operating documents.

11) The preflight inspection section in the operating documents 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 operating documents.

12) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular 

attention to flight critical components that may not be addressed in the 

manufacturer’s manuals.
10

13) The operator must carry out their maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

and alterations must be noted in the aircraft logbook, including total flight hours, 

description of work accomplished, and the signature of the authorized UAS 

technician returning the UAS to service.

14) Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.

15) The authorized person must make a record entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections.

16) The PIC must possess at least a private pilot certificate and a third-class airman 

medical certificate for all of petitioner’s flight operations. 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.

17) The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency must be logged in a manner consistent with 14 CFR § 61.51(b). The PIC 

must ensure that the VO is trained appropriately in order to fulfill her or her duties. A 

record of training must be documented and made available upon request by the

Administrator. Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) are permitted under the terms of this 

exemption. However, training may only be conducted during dedicated training 

sessions. 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.

18) UAS operations 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.

19) The UA may not operate within 5 nautical miles of an airport reference point 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 by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 
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20) 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.

21) If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property and land or 

be recovered in accordance with the operating documents.

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

23) The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining in accordance with the operating documents.

24) 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 operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements.

25) 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

26) 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.

27) 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.

28) The UA must remain clear and yield the right of way to all other aviation operations 

and activities at all times.

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

30) The UA may not be operated over congested or densely populated areas.

31) The UA may not be operated from an elevated platform.
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32) Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet 

of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and;

c. Operations near the PIC or VO do not present an undue hazard to the PIC or 

VO per § 91.119(a).

33) All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained prior to the beginning of every flight.

34) 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.

Unless otherwise specified in this grant of exemption, the unmanned aircraft system (UAS), 

pilot in command (PIC), and operator must comply with all applicable parts of 14 CFR 

including, but not limited to, parts 45, 47, 61, and 91.

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

Issued in Washington, DC, on March 11, 2015.

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service