July 31, 2015

Exemption No. 12270

Regulatory Docket No. FAA–2015–2138

Mr. Nick Gruber

President

ReelSkies

5341 West Chanceler Court

Lincoln, NE 68521

Dear Mr. Gruber:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of ReelSkies (hereinafter petitioner or operator) for an exemption. The petitioner

requested to operate an unmanned aircraft system (UAS) to conduct aerial photography and 

videography.

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

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 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 part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (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.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our 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, ReelSkies is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(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), and 91.417(a) and (b), to the 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, ReelSkies is hereafter referred to as the operator.

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 DJI Inspire 1when 

weighing less than 55 pounds including payload. Proposed operations of any other 

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

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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 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. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4

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 or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. 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 an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. 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.
5

14. The operator may not permit any PIC to operate unless the PIC 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). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations 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.

15. 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. 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.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

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. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or 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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

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

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. 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 for each flight to be conducted.

28. 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.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming 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−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

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 permission 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.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

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.
8

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 21, 2015

U. S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE

Washington, DC 20590 

Regarding: 

Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 

of the Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 

91.109(c); 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). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform 

Act) and 14 CFR Part 11, ReelSkies which is an owner and operator of Small Unmanned 

Aircraft Systems (sUAS) equipped to conduct commercial aerial photography and 

videography for agricultural inspection, real estate, and other commercial operations 

hereby applies for an exemption from the listed Federal Aviation Regulations (FAR) to 

allow commercial operation of its sUAS, 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. 

The Reform Act gives the Secretary of Transportation the authority to determine if 

certain sUAS may operate safely in the national airspace system (NAS) before 

completion of the FAA’s plan and rulemaking to integrate sUAS into the NAS. The 

Reform Act directs the Secretary to consider which types of sUAS as a result of their 

size, weight, speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace or a threat to national security. If the Secretary determines that such vehicles 

may operate safely in the NAS, the Secretary “shall establish requirements for the safe 

operation of such aircraft.” 

The granting of this exemption request will provide immediate benefit to both the 

agricultural and real estate industries by authorizing highly controlled sUAS operations at

or below 200 feet above ground level (AGL), in line of sight of an FAA Certificated 

Airline Transport Pilot during daylight hours and above controlled privately owned and 

operated property. 

ReelSkies sUAS shall weigh less than 10 pounds including the payload. They will 

operate at no more than 30 knots and have the capability to hover, and move vertically 

and horizontally simultaneously. 

Operations would be conducted above privately owned and operated properties, with the 

consent of the owner/operator. ReelSkies operations will be performed by a professional 
pilot; this will insure that the sUAS will not create a hazard to users of the national

airspace system or the public.

The grant of this exemption request is in the public interest, does not create a hazard to 

users of the NAS or the public, or pose a threat to national security. 

In the following pages ReelSkies addresses all areas of concern to include:

 Equivalent levels of safety

 Exemptions requested

The name and address of the applicant is: 

ReelSkies

ATTN: Nick Gruber

Phone: (402) 318-8093

Email: nick.j.gruber@gmail.com

Address: 5341 West Chanceler Court

 Lincoln, NE 68521

ReelSkies appreciates your consideration in this matter. 

Best Regards, 

Nick Gruber

PresidentReelSkies

Included in this Exemption Letter:

 Operations

 Regulations for which exemptions are requested

To follow this Exemption Letter and/or on request:

 ReelSkies Operating Manual

 Inspection Program

 Aircraft Operating Manual (AOM)
Table of Contents

Operations and How They Serve the Public Interest

About ReelSkies

ReelSkies sUAS Description

Safety

Maintenance

Permissions and Permitting

Operations

Flight Time and Flight Durations

Exemptions from which Regulations
Operations and How They Serve the Public Interest

Real Estate Photography by sUAS

 SUAS allow aerial video and photography of real estate property without the use 

of full size aircraft.

 Use of sUAS in real estate, as well as other sectors, is more efficient, less costly, 

and environmentally friendly. 

 Utilizing sUAS for real estate is safer than utilizing full-scale aircraft which pose 

a greater risk to people and property

 Operations will be conducted below 200 feet AGL, at slow speeds, and within 

line of sight of a certificated pilot.

Agricultural Inspection by sUAS

 SUAS inspection is of higher quality, more reliable, and can be reviewed in real 

time. SUAS inspections allow for the collection, dissemination and permanent 

storage of photos and videos of agricultural inspections. 

 SUAS inspection is more efficient and less costly. 

 SUAS inspection is safer than traditional manned commercial aircraft. SUAS’s 

are less likely to cause damage to property or life in the event of an accident.

Inspection of Construction Areas

 SUAS use at construction sites will provide an aerial view of the area to interested 

parties such as financier of the project.

 Due to the small size of sUAS they pose less risk of damage to people or property 

when properly used then full size aircraft.

About ReelSkies

President

 Nick J. Gruber, a graduate of Embry-Riddle Aeronautical University, leads 

ReelSkies as President. He graduated with a Bachelor’s in Aeronautics minor in 

management.

 Nick Gruber holds an Airline Transport Pilot (ATP) Certificate along with 

Certified Flight Instructor (CFI), Instrument (CFII), and Multi-engine (MEI) 

certificates. He also holds a Commercial Rotorcraft Helicopter with Instrument 

certificate. He currently flies for a Part 121 airline.

 Nick has extensive experience in both commercial aviation and radio control 

aircraft operations including helicopters and multi-copters.

 ReelSkies sUAS are outfitted for aerial photography and videography for use in 

agricultural inspection and real estate industries.
Experience 

As a professional pilot, Nick Gruber understands that safety is paramount and will always 

hold safety ahead of any commercial endeavor.

 Individuals within ReelSkies have only operated sUAS as hobbyists. To date,

ReelSkies members have not engaged in any commercial activity to ensure it is in 

compliance with any applicable FARs or local, state, and federal laws. 

 ReelSkies has a detailed sUAS operating manual and aircraft inspection manual 

that it shall follow, should this exemption be approved. 

ReelSkies sUAS Description

ReelSkies intendeds to operate DJI sUAS multi-rotor aircraft for the purpose of obtaining 

photographs and video for agricultural inspection, real estate, and other commercial 

endeavors. 

These aircraft have fail-safe features to include geo-fencing and lost link return home 

capability. DJI is the manufacturer of multi-rotors weighing less than 25 pounds and has 

developed technology that will enhance safe sUAS operations within the NAS. 

T600/DJI Inspire 1

Model T600/Inspire 1

Weight (Battery Included) 2935g 6.5 pounds

Battery 22.2V, 4500mAh

Hovering Accuracy Vertical: 0.5m 1.7 feet

Horizontal: 2.5m 8.2 feet

Max Angular Velocity Yaw/Pitch: 150°/s /300°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s 11.2 mph

Max Descent Speed 4 m/s 9 mph

Max Speed 22 m/s 49.2 mph

Max Flight Time 18 min

Operating Temperature Range 

-10° to 40°C

Dimensions 438x451x301 mm 17x18x12 inches 

Specifications and Design: 
A. All sUAS flown under this exemption shall be less than 10 pounds including 

aircraft and payload. This exemption requests permission only with respect to the 

specific use of the DJI Inspire 1 Model T600, which weighs less than 10 pounds 

including payload. 

B. The radio frequency spectrum used for operation and control of the sUAS shall 

comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. The DJI Inspire uses 

spread spectrum technology operating in the 2.4 Ghz range and is compliant with 

all FCC regulations as demonstrated in the aircraft manual.

C. Maximum speed shall be less than 30 knots. 

D. The sUAS shall be equipped with Inertial Navigation Sensor(s) and Gyroscopes 

(IRS/IRU/Accelerometer/MEMS Gyroscopes). 

E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source). 

F. The sUAS shall be equipped with a Global Positioning System (GPS) guidance 

system. 

The sUAS shall be designed, should it lose communications or lose its GPS signal, to 

return to a pre-determined location within the area of operations and land or be recovered 

in accordance with ReelSkies sUAS operating manual.

Safety

ReelSkies proposes that the exemption requested applies to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe operations conducted with conventional aircraft. 

This Exemption Request is for Use of sUAS subject to Extensive Operational and 

Safety Requirements 

These limitations and conditions to which ReelSkies agrees to be bound when conducting 

commercial operations under an FAA issued exemption at a minimum include:

A. The sUAS Pilot in Command (PIC) shall possess at a minimum, a private pilot 

certificate and current third-class medical certificate. 

 The PIC shall also meet the flight review requirements specified in 14 

CFR §61.56 in an aircraft in which the PIC is rated on their pilot 

certificate. 
 The PIC shall be trained in the operation of the specific make and model 

of the sUAS being piloted and successfully completed all training 

required. 

 The PIC shall have accumulated and logged, in a manner consistent with 

14 CFR §61.51 (b), a minimum of 200 flight cycles and 25 hours of total 

time as a sUAS pilot and at least five hours logged as a sUAS pilot with a 

similar sUAS type (multi-rotor/helicopter/airplane). Prior documented 

flight experience that was obtained in compliance with applicable 

regulations may satisfy this requirement. 

 For currency the PIC shall have accumulated and logged, in a manner 

consistent with 14 CFR §61.51 (b), a minimum of five hours as sUAS 

pilot operating the make and model of sUAS to be utilized for operations 

under the exemption and three takeoffs and three landings in the preceding 

90 days. Flight time and number of takeoffs and landings will be recorded 

in a logbook for purposes of demonstrating currency.

 Training, proficiency, and experience-building flights can also be 

conducted under this grant of exemption to accomplish the required flight 

cycles and flight time. 

B. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered non- participants, and the PIC must 

operate the sUAS with appropriate distance from non-participants in accordance 

with 14 CFR §91.119. 

C. The PIC shall always be within visual line of sight (VLOS) of the sUAS while 

conducting operations.

D. A risk mitigation survey will be conducted prior to each flight to ensure VLOS 

can be maintained at all times, hazards are properly identified, and that all 

regulatory perimeters can be met.

Maintenance 

A. SUAS shall be maintained in accordance with the manufacturer’s 

recommendations and ReelSkies sUAS operating manual. 

B. ReelSkies will document and maintain a record of the sUAS maintenance, 

preventative maintenance, alterations, and status of replacement, overhaul 

component parts, and the total time in service of the sUAS. These records will be 

maintained at the principle base for operation for the life of the aircraft or as 

required by Federal Aviation Regulations. See ReelSkies sUAS operating manual. 



C. ReelSkies shall comply with all manufacturer Safety / Service Bulletins or 

equivalent pertaining to the sUAS aircraft. 
D. The PIC shall perform a preflight inspection of the sUAS, controller, and ground 

control station prior to each flight to ensure it is operational with no discrepancies. 

The preflight inspection checklist can be found on page 48 of the AOM. If the 

preflight inspection reveals discrepancies, repairs or maintenance shall be 

performed prior to flight and logged in the maintenance log. The sUAS will only

be operated if all systems are operating per manufacture’s specifications and in a 

discrepancy free condition. 

E. Maintenance or repairs that may affect the sUAS operation or flight characteristics 

shall undergo a functional test flight when required in accordance with 

manufactures recommendations and ReelSkies sUAS operating manual. This 

functional test flight shall be recorded in the sUAS’s records. If the functional test 

flight is completed successfully, the sUAS can be returned to service by the PIC. 



F. ReelSkies shall follow the manufacturer’s sUAS maintenance, overhaul, 

replacement, inspection, and life limit requirements. When not provided by the 

manufacturer aircraft maintenance, component, overhaul, replacement, and 

inspection maintenance requirements shall be established and included in 

ReelSkies sUAS operating manual. 

 At a minimum the following will be meet: 

1. Actuators / Servos 

2. Powerplant(s) (motors) 

3. Propellers 

4. Electronic speed controller(s) 

5. Batteries 

6. Remote controllers and Ground control station 

Permissions and Permitting 

A. All required permissions and permits shall be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, or other appropriate 

governmental agencies. 

B. At least three days before a scheduled operational flight, ReelSkies shall submit a 

written plan of activities to the local flight standards district office (FSDO) with 

jurisdiction over the area of the proposed flight. The 3-day notification may be 

waived with the concurrence of the FSDO. 
 The plan of activities shall include at least the following: 

1. Dates and times for all requested flights 

2. Name and phone number of ReelSkies sUAS Flight Operations 

3. Name, certificate, phone number of the PIC responsible 

4. Make, model, and serial number of sUAS to be used 

5. Statement from ReelSkies that it will be operating on approved privately owned and 

operated property; the list of those who gave permission shall be made available 

to the inspector upon request. 

6. Description of the flight activity, including maps or diagrams of any area over which 

flights will be conducted, the relationship of that area to any nearby city, town, 

etc., and the altitudes essential to accomplish the operation 

7. Signature of exemption-holder or representative 

C. Documents required per 14 CFR §91.9 and §91.203 shall be readily available to 

the PIC any time the aircraft is in operation. These documents shall be made 

available to the Administrator or any law enforcement official upon request. 

D. ReelSkies shall obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this 

grant of exemption.

E. ReelSkies shall obtain the consent of all persons involved in the operation and 

ensure that only consenting persons be allowed within 500 feet of the Operations 

Area. 

Operations 

A. The sUAS shall not operate within 5 nautical miles of the geographic center of 

any airport as denoted on the 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. 

This letter of agreement with the airport management shall be made available to 

the Administrator upon request. 

B. The sUAS will only operate within the lateral boundaries of approved privately

owned and operated property. An Operations Area within those boundaries will 

be established for each flight. These areas will be free of unnecessary hazards or 

risks and non-participating personnel. 
 The sUAS shall only operate within a pre-defined area of operations that 

shall be thoroughly inspected by the PIC for buildings, overhangs, 

obstacles, wires, poles, people, vehicles, shadows, glare, reflective 

surfaces, clouds, smoke, and terrain among other potential hazards. 

C. Flights shall be conducted under day visual meteorological conditions (VMC)

only. 

 In addition, the sUAS shall 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. 

 SUAS operations shall not be conducted at night, as defined in 

14 CFR §1.1. 

 Flights shall not be conducted under special visual flight rules (SVFR). 

D. Flights shall be operated at an altitude at or below 200 feet AGL, as indicated by

the procedures specified in ReelSkies sUAS operating manual.

E. Groundspeeds will not exceed 30 knots as indicated by the aircraft GPS.

F. The PIC shall be prohibited from operating the sUAS from any moving device or 

vehicle. 

G. The sUAS shall be operated within VLOS of the PIC. 

The PIC shall maintain VLOS without the aid of telescopes, cameras or 

other devices.

The PIC will maintain VLOS with their own vision, which includes the 

use of eyeglasses or corrective lenses as specified on the PIC’s medical 

certificate. 

H. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc. 

I. ReelSkies will require the PIC to have successfully completed a qualification 

process which will include ground and flight training, as outlined in the ReelSkies

sUAS Operating Manual. 

J. The PIC’s primary responsibility while in flight is the safe operation of the sUAS. 



Flight Time and Flight Durations 
The PIC will commence the landing sequence when 25% battery life remains. The 

aircraft will automatically return to base when it triggers a low battery warning.

Exemptions from which Regulations

Unless otherwise requesting an exemption, ReelSkies, the PIC, and the sUAS shall 

comply with all applicable parts of 14 CFR including, but not limited to, Parts 45, 47, 61, 

and 91.

ReelSkies is requesting exemptions from the following Federal Aviation Regulations to 

the extent necessary to enable the requested sUAS operations for the reasons detailed 

below. 

Relief sought from 14 CFR ReelSkies Statement 

21 Stated Below 

61.113(a) and (b) Stated Below 

91.103 Stated Below 

91.119(c) Stated Below 

91.121 Stated Below 

91.151(a)(1) Stated Below

91.405(a) Stated Below 

91.407(a)(1) Stated Below 

91.409(a)(1) and (2) Stated Below

91.417(a) and (b) Stated Below 

14 CFR 21 – Requirements to Secure Airworthiness Certificates 

1. Certificate exemptions should be given because size, weight, and operation areas of the 

sUAS meet the level of safety necessary for exemption under Section 333 of the 

Reform Act. 

2. FAA has the authority to exempt aircraft from airworthiness certificate requirements 

under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. 
14 CFR 61.113 (a) and (b) – Private Pilot Privileges and Limitations; Pilot in 

Command 

1. Due to the fact that there are no standards for private or commercial sUAS operations, 

ReelSkies requests to utilize at least private pilots with a third class medical in 

support of its own operations. 

2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), 

along with the ability to physically manipulate the controls of the sUAS are the 

critical aspects of the requested operation. ReelSkies feels this can be 

accomplished by a private pilot that has specific training on the sUAS aircraft and 

operates in accordance with the ReelSkies sUAS Operating Manual, Federal 

Aviation Regulations, local, state and federal laws. 

3. The risks associated with the operation of a sUAS are so diminished from the level of 

risk associated with commercial aviation operations contemplated by Part 61 

when drafted, that allowing operations of the sUAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 

(a) & (b). 

4. Equivalent or better safety levels will be achieved as there will be no human beings on 

board the sUAS aircraft. In addition, people will not be allowed in the area of 

operation.

5. FAA has authority to waive pilot requirements for commercial operations under 49 

U.S.C §44701(f). 

14 CFR 91.103 – Preflight Action 

1. The PIC shall perform a preflight inspection in accordance with the manufacturer’s 

recommendations and the ReelSkies sUAS Operating Manual of the controller, 

ground control station and associated equipment prior to each flight to ensure it is 

free of all discrepancies. 

2. Equivalent safety levels will be met through preparation and compliance according to 

ReelSkies’s sUAS Operating Manual; including but not limited to, weather 

reports, forecasts, wind, temperature, battery requirements and other information, 

relating to aircraft performance, gross weight, shall be considered. 

14 CFR 91.119(c) – Requirements for Minimum Safe Altitudes for Civil Aircraft 

Operation 

1. The sUAS will be operated at or below 200 feet AGL. 
2. ReelSkies shall obtain the consent of all persons involved in the operation and ensure 

that only consenting persons be allowed within 500 feet of the Operations Area. 

3. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be 

established for each flight. These areas will be free of unnecessary hazards or 

risks and non- participating personnel. 

4. Given the size, weight, speed, material, and operation of the sUAS aircraft, equivalent 

levels of safety will be achieved. 

14 CFR 91.121 – Altimeter Settings 

1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out 

indication instead, so an exemption may be needed. 

2. The operator will achieve an equivalent level of safety as the sUAS uses AGL height 

from its initialization/takeoff point. 

14 CFR 91.151 (a) (1) – Fuel Requirements for Flights in VFR Conditions 

1. The FAA has previously issued exemptions for fuel requirements in VFR conditions 

including Exemptions 2689F, 5745, 10673, and 10808. 

2. ReelSkies feels an equivalent level of safety can be obtained by terminating the flight 

prior to the following. 

Aircraft Fuel (Battery) Requirements 

DJI Inspire - 18 minutes which allows for 5 minutes reserve.

1. The DJI Inspire has a second level of safety that is achieved through the use of an 

aircraft battery monitoring system. The aircraft system will alert the operator of 

low battery voltage and return the aircraft to its take off location before battery

capacity is depleted. 

2. ReelSkies will not operate sUAS at night in accordance with 14 CFR 1.1 

3. An equivalent level of safety will be achieved because these sUAS are limited in size, 

operational purposes of the sUAS, and shall only fly above approved privately

owned and operated property at or below 200 feet AGL, it does not bear the same 

risks associated with this section’s requirements. 

14 CFR 91.405 (a) – Maintenance RequiredThis section and Part 43 apply only to

aircraft with an airworthiness certificate; therefore these sections will not apply. 
In the absence of regulatory provisions dealing with sUAS operation for maintenance 

required. See ReelSkies sUAS Operating Manual, Inspection Program and Manufactures 

Maintenance Recommendations for maintenance required. 

1. Maintenance shall be accomplished by ReelSkies, pursuant to the manufacturer’s 

recommendations and ReelSkies sUAS Operating Manual and Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only. 

3. The ReelSkies sUAS Operating Manual and Inspection Program details how to enter 

worked preformed in the maintenance log for scheduled, unscheduled 

maintenance or functional test flights that are performed. 

4. ReelSkies shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition. 

5. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

ReelSkies and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition. This maintenance process 

allows for an equivalent level of safety to be achieved due to the limited size, scope and 

area of operations. 

14 CFR 91.407 (a) (1) – Operation after Maintenance, Preventive Maintenance, 

Rebuilding or Alteration 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply. 

In the absence of regulatory provisions dealing with sUAS operation after maintenance, 

preventive maintenance, rebuilding, alteration or functional test flights, ReelSkies has 

developed requirements to address these topics. See ReelSkies sUAS Operating Manual, 

Inspection Program and Manufactures User Guides. 

1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s 

recommendations and ReelSkies sUAS Operating Manual and Inspection 

Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only. 

3. Functional test flights will be performed by the PIC when required, the sUAS shall 

only be returned to service when this functional test flight is successfully 

completed. If a mechanical issue arises the sUAS can land safely or be recovered 
within the Operations Area. 

4. The ReelSkies sUAS Operating Manual details how to enter in the maintenance log 

scheduled and unscheduled maintenance or functional test flights that are 

performed. 

5. ReelSkies shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

ReelSkies and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition. These maintenance 

procedures allow for an equivalent level of safety to be achieved due to the limited size, 

scope and area of operations. 

14 CFR 91.409 (a) (1) and (2) – Inspections This section and Part 43 apply only to 

aircraft with an airworthiness certificate; therefore these sections will not apply. 

In the absence of regulatory provisions dealing with sUAS inspections, ReelSkies has 

developed requirements to address this topic. See ReelSkies sUAS Operating Manual, 

Inspection Program and the Manufactures User Guides. 

1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s 

recommendations and ReelSkies sUAS Operating Manual and Inspection 

Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only. 

3. The ReelSkies sUAS Operating Manual details how to enter into the maintenance log 

all inspections that are performed. 

4. Functional test flight will be performed by the PIC when required after inspections, the 

sUAS shall be returned to service when the flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the 

Operations Area. 

5. ReelSkies shall only operate its sUAS with all systems functioning per manufactures 

specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

ReelSkies and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and 
best suited to maintain the aircraft in an airworthy condition. These maintenance 

inspections allow for an equivalent level of safety to be achieved due to the limited size, 

scope and area of operations.

14 CFR 91.417(a) and (b) – Maintenance Records This section and Part 43 apply

only to aircraft with an airworthiness certificate; therefore these sections will not apply. 

In the absence of regulatory provisions dealing with sUAS maintenance records,

ReelSkies has developed requirements to address this topic. See ReelSkies sUAS 

Operating Manual and Inspection Program. 

1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s 

recommendations and ReelSkies sUAS Operating Manual. 

2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance 

recording keeping will be performed by trained personnel and entered in the 

respective aircraft maintenance log at completion of each event. The ReelSkies

sUAS Operating Manual details how entries are to be made in the aircraft 

maintenance log for scheduled and unscheduled maintenance or functional test 

flights that are performed. 

3. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

ReelSkies and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition. These maintenance records 

allow for an equivalent level of safety to be achieved due to the limited size, scope and 

area of operations.