Roger L. Smith

1444 Crystal Springs Drive

Woodland, CA

95776-5769

(530) 662-7672

Email: jdcokejb@hotmail.com

January 8, 2016

U.S. Department of Transportation

Docket Operations

West Building, Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14

CFR Part 11, I, Roger L. Smith, an operator of Small Unmanned Aircraft Systems (“sUAS”):

1. 3DR SOLO Quadcopter Max Take Off Weight: 4.4 lbs.

2. DJI Phantom 3 Professional Quadcopter Max Take Off Weight: 2.8 lbs.

Hereby apply for the exemptions to the below listed Federal Aviation Regulations (“FARs”):

 14 CFR 21

 14 CFR 45.23

 14 CFR 45.29

 14 CFR 61.3

 14 CFR 61.113 (a) & (b)

 14 CFR 91.7 (a) & (b)

 14 CFR 91.9 (b)(2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151 (a)

 14 CFR 91.203 (a) & (b)

 14 CFR 91.319 (a) (1)

 14 CFR 91.405 (a)

 14 CFR 91.407 (a) (1)

 14 CFR 91.409 (a) (1) & (2)

 14 CFR 91.417 (a) & (b)
The requested exemption would authorize Roger L. Smith, commercial operations using his 3DR SOLO 

and DJI Phantom 3 Professional for: 

 Aerial photography

 Videography

 surveying of boats, real estate, and landscape

 surveying for natural resources, endangered species

 mining operations

 support event marketing

 industrial and agricultural inspections

 mapping and GIS (survey-grade construction mapping and monitoring)

 cellular tower and compound surveys for wireless providers

 aerial photography and videography for the marine industry

 sUAS flight training

 aerial inspection of facilities and structures

 news gathering

 aerial search and rescue operations

 training, and inspection of public, utility, and residential structures infrastructure

 video data gathering for clients in the motion picture and television industry

 closed set motion picture and filming

So long as such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

Commercial operation of sUAS, as described herein, which are equipped with cameras and sensors,

would operate in the following manner:

1. Aerial video/photography or providing live video feed to assist Federal, State, County, and Local

Rescue Teams with search and rescue operations in cases of an emergency or natural disaster.

 2. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

 3. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering.

 4. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

 5. The ability to offer training to persons individually or belonging to both private and/or public

organizations that have interests in the use and application of sUAS for the purpose of the safe

operation of sUAS.

As described fully below, the requested exemption would permit the operation of sUAS under

controlled conditions in the NAS that would be:

a) limited

b) controlled

c) predetermined

d) will provide safety enhancements to the already safe operations in the industry presently 

using conventional aircraft.
Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe

operation of such aircraft systems in the national airspace system.”

The name and address of the applicant is:

Roger L. Smith

1444 Crystal Springs Drive

Woodland, CA

95776-5769

(530) 662-7672

Email: jdcokejb@hotmail.com

Roger L. Smith’s sUAS are multi-rotor craft weighing no more than 55lbs. including payload. Under 

normal conditions they operate at speeds of no more than 50kts and have the ability to hover and move 

along a vertical and horizontal plane simultaneously. They will operate in line of sight and can operate 

within a closed off and predetermined area owned and/operated by the property representative. Given 

the small size of the sUAS and the controlled environment provided, the proposed operations will 

adhere to the Reform Act’s safety requirements.

The approval of this application presents no national security issues.

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in

environmental impacts, including but not limited to reduced emissions and noise, the grant of the

requested exemption is in the public interest. Accordingly, Roger L. Smith requests that the FAA grant 

the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will

further enhance the safety of the persons and/or property using conventional aircraft. These limitations

and conditions to which the applicant agrees to adhere to when conducting commercial operations

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. Flight operations will be conducted in accordance with the FAA Modernization and Reform Act of 

2012 with regard to model aircraft operations and limits and with the Academy of Model Aeronautics 

Safety Code which follows

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer (VO) and

may include but not limited to a Camera Operator.

4. The sUAS pilot will be a designated Pilot in Command (PIC) and the sUAS pilot will be an FAA licensed 

airman with at least a sport or recreational pilot's certificate and Class III airman medical certificate or 

Government, State or United States Possession or Territory issued driver’s license.

5. A briefing will be performed regarding the planned sUAS operations prior to each day’s flight

consisting of all the days’ flight activities.

6. The PIC and VO will have been trained in the operation of sUAS and receive up-to-date information

for the particular sUAS to be operated.

7. The PIC and VO will be able to communicate by voice, or radio at all times.

8. If the sUAS loses communications or loses GPS signal, the sUAS will have the capability to return

to a pre-determined location within a designated location and land autonomously.
9. The sUAS Pilot will have the authority to abort a flight in case of unpredicted obstacles, weather, or

emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with

the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size,

weight, speed, operational capability, and proximity to airports and populated areas of the particular

sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive

materials or flammable liquid fuels, and operates exclusively within a secured and designated area.

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by

both the operator and under the requirements and in compliance with local public safety requirements.

These safety enhancements provide a greater degree of safety to the public and property owners than

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21,

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to

national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of

explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b) & 14 C.F.R. § 45.29. Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be

placed. Given the size of the sUAS, two-inch lettering will be impossible. The word “Experimental” will

not be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be 

provided by not having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUAS will not see the identification of the sUAS as “Experimental.”

14 C.F.R. § 61.113 (a) & 14 C.F.R. § 61.3: Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in

command of an aircraft that is carrying passengers or property for compensation or hire. Our sUAS do

not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR

61.113(a). Although helpful, a pilot’s license will not ensure remote control piloting skills. The risks

attendant to the operation of sUAS is far less than the risk levels inherent in the commercial activities

outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to the safe

operation of the sUAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be

provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material,

markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board,

but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of

safety will be maintained by keeping the flight manual at the ground control point where the pilot flying

the sUAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption

will be needed. The PIC will take all actions including reviewing weather, flight battery requirements,

landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that

is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio

communications. The FAA has approved exemptions for flight training without fully functional dual

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the

size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. As set forth herein, the sUAS will

never operate at higher than 400 AGL with the exception that in circumstances where the sUAS is used

to survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS will not be operated

more than 100' above the highest point on the structure. It will however be operated in a restricted area

with security perimeter, where buildings and people will not be exposed to operations without their

pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the

sUAS as well as the location where it is operated. No flight will be taken without the permission of the

property owner or local officials. Compared to flight operations with aircraft or rotorcraft weighting far

more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with

these operations is far less than those presently presented with conventional aircraft operating at or

below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure separation between

the sUAS operations and the operations of conventional aircraft that must comply with Section

91.119.

14 C.F.R. §91.121 Altimeter Settings.
This regulation requires 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.” As the sUAS may not have a barometric altimeter, but instead a GPS

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least

30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the sUAS

provides approximately 30 minutes of powered flight. To meet the 30-minute reserve requirement in 14

CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations

on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating

the small UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does

not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed

of the sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for

which the exemption will be granted. Applicant believes that an equivalent level of safety can be

achieved by limiting flights to 25% of battery power. This restriction would be more than adequate to

return the sUAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a

civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a)

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than 55 lbs.

and is operated without an onboard pilot. As such, there is no ability or place to carry certification and

registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot flying the sUAS will have

immediate access to them, to the extent they are applicable to the sUAS.

14 C.F.R. §91.405 (a); 407 (a)(1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because these sUASs are very limited 

in size and will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 

feet AGL. The operator will ensure that the sUAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 
person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the sUAS Manufacturer's Manual, as 

referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure 

that the sUAS is in working order prior to initiating flight and perform required maintenance as needed.

Additional Information

The applicant, Roger L. Smith, has been involved in the Aviation Industry for over 35 years. Mr. Smith 

holds an FAA Commercial Pilot Airman Certificate with an airplane single engine land and sea rating, and

is also a member of the Academy of Model Aeronautics.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 provide more than

adequate justification for the grant of the requested exemptions allowing the commercial operation of

the applicant’s sUAS. Based upon recent rulings by the FAA concerning the 333 exemption I would ask

that this request be issued under the summary grant process as this application is similar to many before

it.

Sincerely,

Roger L. Smith

Appendix A - Motion Picture and Television

Flight Operation Manual
Appendix A.

Motion Picture and Television

Flight Operation Manual

Roger L. Smith

1444 Crystal Springs Drive

Woodland, CA 95776

(530) 662-7672 • (530) 662-7672 Fax

Table of Contents

1. Introduction

A. Purpose 1

B. Pilot/Operator Organization 1

C. Persons Authorized 1

D. Area of Operations 1

E. Plan of Activities 1

F. Permission to Operate 2

G. Security 2

H. Briefing of Pilot/Production Personnel 3

I. Certification/Airworthiness 3

J. Pilot Personnel/Minimum Requirements 4

K. Communications 4

L. Accident Notification 4

M. Recall/Stop Procedures 4

N. Aerobatic Competency 4

O. Aerobatic Competency 4

2. Company Organization

A. Chief Pilot 6

B. Pilot in Command 6

Appendix A

1 List of Approved Pilots 7

2 List of Approved Aircraft 8

3 Permission Acquisition Form (sample) 9

4 Revision Letter (sample) 10
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1. Introduction

A. Purpose

This manual has been developed by Roger L. Smith, in conjunction with an application 

for a Certificate of Waiver of Authorization of the provisions of FAR 91.119 (b) and (c) 

for the purposes of filming. Roger L. Smith, other future pilots, and company personnel 

when applicable, will comply with the policies, procedures and conditions of this manual, 

whenever motion picture or television flight operations are performed that require a 

Waiver of Authorization as mentioned above.

B. Pilot/Operator Organization

Roger L. Smith – Pilot/Operator

1444 Crystal Springs Drive

Woodland, CA 95776

(530) 663-7672 Office (530) 662-7672 Fax

jdcokejb@hotmail.com

C. Persons Authorized

FAR 91.119 (c) is waived only with respect to those persons, vehicles and

structures directly involved in the performance of the actual filming. The certificate

holder shall 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 an equivalent level of safety

can be achieved and the Administrator has approved it. For example, an

equivalent level of safety may be determined by an ASI’s evaluation of the filming

production area to note terrain features, obstructions, buildings, etc. Such barriers

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

from debris in the event of an accident.

D. Area of Operations

Roger L. Smith's approved area of operations will be the entire United States, including 

the District of Columbia, all the United States possessions and territories. 

E. Plan of Activities

At least three (3) days prior to any scheduled filming, ROGER L. SMITH and personnel 

will submit a written plan of activities to the local FSDO having jurisdiction over that 

area. The plan of activities should include the following:

(1) Dates and times for all flights.
(2) Name and phone number of person responsible for the filming production

event.

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial or N-number of aircraft to be used and type of

airworthiness certificate, including category.

(5) Name and certificate number of pilots involved in the filming production

event, including any notation of external load endorsements or aerobatic

competency, if required.

(6) A statement that the waiver holder has obtained permission from property

owners and/or local officials to conduct the filming production event. The

list of those who gave permission must be made available to the inspector

upon request from the waiver holder.

(7) Signature of waiver holder or representative.

(8) 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

minimum altitudes essential to accomplish the operations.

The three (3) day notification requirement may be waived, however, the operator

should contact the FSDO as soon as possible with this request and be prepared to

explain in detail why the three (3) day notification is not practical.

F. Permission to Operate

Before any flight operations is conducted at less than 500 feet under the

provisions of the certificate of waiver and this manual, the operator will obtain

permission to conduct these operations from property owners and local officials as

necessary or appropriate. Persons from whom permission may be required are

listed below:

(1) Property owners

(2) Law enforcement officials

(3) Fire department officials

(4) Federal, State and Local governments

(5) Air traffic control

ROGER L. SMITH and personnel obtaining such permission will do so in writing 

whenever practical, however, verbal permission is acceptable otherwise. A standard

permission form is provided in Appendix A and may be used when obtaining

written permission. ROGER L. SMITH and personnel will assure a sufficient number of 

those forms are available at the job site. Written permission forms will be maintained at 

the job site until flight operations are completed, and then turned in to the chief pilot to 

be kept on file for a minimum of six (6) months. These forms will be made available

for inspection by the FAA or other official personnel upon request.

G. Security
Prior to any flight operation the operator will coordinate with appropriate

production personnel to devise a plan of securing the area(s) of operation from all

unauthorized persons and vehicles. Provisions will be made to immediately

discontinue operations should the area(s) become unsecured or for any other

reason in the interest of safety.

H. Briefing of Pilot/Production Personnel

Prior to the start of any operation under the provisions of this manual, the pilot in

command will conduct a briefing of all procedures to participating personnel of the

risks involved, emergency procedures, and safeguards to be followed during the

filming production event. Personnel will also be briefed on additional provisions

that may be issued by the FSDO that has geographic responsibility for the

operational area, including the location of boundaries or time limits. The briefing

shall cover:

• Authorization for motion picture and television certificate of waiver and the

attached special provisions

• Operations manual

• Plan of activities

• Aircraft parking and starting

• Taxi procedures

• Radio Communications

• Takeoff procedures

• Aviation activities to be conducted during the filming production event

• Approach and landing procedures

• Recall procedures

• Emergency procedures

• Risks to participating personnel

• How to control nonparticipating persons

I. Certification/Airworthiness

All ROGER L. SMITH aircraft used in operations requiring a waiver of FAR 91 .119 (b) 

and (c) for the purpose of filming will be properly certified and hold airworthiness 

certificates.

However, restricted category aircraft cannot be used as the filming "vehicle" in

motion picture and television filming. Also, aircraft in the experimental category

must have an airworthiness certificate issued for the purpose of exhibition in order

to be used in motion picture and television filming. The aircraft will be

100hr/annual inspection program. Other required tests and inspections

(transponder, E.L.T., etc.) will be performed as per Part 91 when necessary. Each

aircraft will have a flight log containing upcoming scheduled maintenance and

inspections and the dates or times they must be performed. A section for

discrepancies is also found in the flight log. The pilot in command will assure the
aircraft to be flown is in airworthy condition and all required inspections and

maintenance has been completed before each flight.

J. Pilot Personnel/Minimum Requirements

The pilot/operator shall establish and specify the minimum pilot requirements.

Minimum requirements shall meet or exceed the following:

The pilot in command will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by the Federal Government, a 

State, the District of Columbia, Puerto Rico, a possession, or a territory. The PIC also 

will 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. 

K. Communications

Prior to the start of any operation covered by this manual, the pilot in command

will formulate a plan to provide communications capability to all participants

during the actual operation and filming. Oral, visual or radio communications may

be used as long as it is effective and is capable of keeping the participants

continuously appraised of the current status of the operation.

L. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the

notification requirements of FAR Part 830 would comply.

M. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the

participants continuously apprised of the current status of operation.

N. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, Statement of

Aerobatic Competency, refer to Volume 5, Chapter 9, Issue/Renew/Rescind a

Statement of Aerobatic Competency.

O. Special Provisions

The controls, procedures, and conditions set forth in the ROGER L. SMITH motion 

picture and television operations manual is the primary assurance that persons on the

surface will not be jeopardized.
The aircraft and pilots used under this authorization and/or waiver will only be

those specified in the ROGER L. SMITH motion picture and television operations 

manual (“Appendix A” page 11) or associated plan of activities. Each pilot’s name and

certificate number shall appear on each daily plan of activity. All civil aircraft and

pilot(s) participating in the activity shall be available for FAA inspection before the

scheduled event. Each pilot-in-command conducting operations authorized under this 

certificate understands the conditions of issuance, and that it constitutes a waiver of 

FAR 91.119 (b) and (c). Rotorcraft takeoff and landing areas will be protected in a 

manner that will prevent unauthorized persons from entering the takeoff and landing 

area.

ROGER L. SMITH and personnel will ensure that the participating persons involved in 

the operations are thoroughly briefed on special procedures, communication, 

emergency procedures, and on the provisions of the authorization and/or waiver before

beginning the activities. No person may participate in any event unless that

person has received a briefing on the provisions of the waiver.
2. Company Organization

A. Chief Pilot

Duties and Responsibilities:

• Final word in the formulation of policy and procedures concerning this

manual.

• Act as liaison between ROGER L. SMITH and personnel and the FAA on matters 

concerning this manual.

• Assure that each approved pilot is issued a copy of this manual and obtain a

signed statement from each that they have read and understand its contents.

• Maintain a current copy of this manual at the main base of operations for ROGER L. 

SMITH.

• Responsible for assuring that all revisions to this manual are distributed and

processed properly.

• Must approve or disapprove each proposed job or operation performed by ROGER L. 

SMITH and personnel under the provisions of this manual.

• Assume the responsibilities of pilot in command when acting as such.

• The chief pilot may delegate functions to other personnel but retains responsibility.

B. Pilot in Command

Duties and Responsibilities:

• Assure that aircraft to be flown is in airworthy condition and all inspections and

required maintenance have been performed as per appropriate FAR's.

• Acquire permission from the chief pilot before any operation under the

provisions of this manual.

• Be very knowledgeable of the contents of this manual and abide by the

procedures, policies and conditions contained herein.

• Coordinate with movie and television personnel to formulate plans, routes,

locations, etc. with safety of all persons involved in the primary concern.

• Maintain their copy of this manual in current condition and have it on site at any

job or operation requiring the waiver.

• The pilot in command may delegate functions to other personnel, but retains

responsibility.
Appendix A. 2

List of Approved Pilots

Chief Pilot

Name: Roger L. Smith

Certificate Number: 1961234

Type: Commercial

Contact Number: (530) 662-7672
Appendix A. 3

List of Approved Aircraft

Make and Model Registration Number

1. 3DR SOLO N637VS 

2. DJI Phantom 3 Professional N636FS

3.
Appendix A. 4

ROGER L. SMITH 

Permission Acquisition Form

In signing this form, I am giving the pilots of ROGER L. SMITH permission to operate

their aircraft at less than 500 feet from property, or in some jurisdiction in which I am

responsible for or affiliated with, for the purpose of film or television production:

Name:

Title:

Basis of Authority to Grant Permission:

Location:

Date of Operation:

Signature __________________________________________________

Date __________________________

ROGER L. SMITH Representative Receiving Permission

_______________________________________________________________
Appendix A. 5

Revision Letter

Rev# Section Page Action Remarks Initials

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

R Remove and Replace D Delete and Destroy N Insert New Page

Manual Serial# ___________________ Issued To ___________________________

Revised by _________________________________

Date _______________________

This form must be returned to the Chief Pilot no later than _____________________________