May 20, 2015

U.S. Department of Transportation

Document Management System

1200 New Jersey Ave., SE

Washington, DC 20590

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R., Part 11, NFL Productions LLC d/b/a NFL Films (“NFL Films”), operator of Small 

Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial videography of professional 

football game and training facilities, requests a limited exemption from the below-listed 

regulations to allow commercial operation of its sUASs, provided that the proposed sUAS

operations comply with the conditions outlined below or as established by the Federal Aviation 

Administration (“FAA”) under Section 333.

The name and address of the applicant is: NFL Productions LLC, One Sabol Way, Mt. 

Laurel, N.J. 08054, c/o Barry M. Wolper, Chief Financial Officer, (856) 222-3545, 

barry.wolper@nfl.com.

NFL Films makes this request under the “summary grant” process that the FAA 

announced in April 2015.1 This request is similar in all material respects to a number of recent 

grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial 

Cinematography, LLC (FAA Docket No. 2014-0090).2

Regulations from which the exemption is requested:

14 C.F.R. part 21

14 C.F.R. § 45.23 (b)

14 C.F.R. §§ 61.113 (a) & (b)

 

1 See FAA Summary Grants Speed UAS Exemptions, available at 

https://www.faa.gov/news/updates/?newsId=82485. 

2 The use limitations and arguments in this application are nearly identical to those contained in 

Advanced Aerial Cinematography’s November 24, 2014 application and the FAA’s May 5, 2015 

approval of that application. 
U.S. Department of Transportation

May 20, 2015

Page 2

14 C.F.R. § 91.7 (a)

14 C.F.R. § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. §§ 91.203 (a) & (b)

14 C.F.R. § 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. §§ 417 (a) & (b)

NFL Films proposes that it receive an exemption to use sUAS to gather footage from 

closed-set locations in and around NFL stadiums (on non-game days) and NFL practice 

facilities. NFL Films would use the footage for the production of television programs. NFL 

Films would obtain the consent of all personnel in the stadiums and practice facilities in the 

vicinity in which the sUAS may operate. 

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system (“NAS”) or to persons and property on the ground. NFL Films proposes that 

the exemption apply to civil aircraft that operate within the limitations listed below. These 

limitations were established in the FAA’s grant of Advanced Aerial Cinematography’s request for 

an exemption:

1. The sUAS will weigh 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 

permitted.

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

hour). NFL Films may use either groundspeed or calibrated airspeed to 

determine compliance with the 87 knot speed restriction. In no case will the UA 
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Page 3

be operated at airspeeds greater than the maximum UA operating airspeed

recommended by the aircraft manufacturer. 

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

level (AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge 

(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 will utilize a visual observer (VO). The UA will be operated within 

the 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 the VLOS capability. The VO 

and PIC will be able to communicate verbally at all times; electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated 

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

flight. The PIC will ensure that the VO can perform the duties required of the VO.

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

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

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

operating documents will be accessible during sUAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in the exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and 

will be followed. Otherwise, NFL Films will follow the procedures as outlined in 

its operating documents. NFL Films may update or revise its operating 

documents. It is NFL Films’ responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement 

official upon request. NFL Films will also present updated and revised 

documents if it petitions for extension or amendment to this grant of exemption. 

If NFL Films determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then NFL Films must petition for an 

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS80) 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. 
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May 20, 2015

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9. NFL Films 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 will conduct a pre-flight inspection and determine 

the sUAS is in a condition for safe flight. The pre-flight inspection will 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 sUAS, 

the aircraft will be prohibited form operating until the necessary maintenance 

has been performed and the sUAS is found to be in a condition for safe flight.

11. NFL Films will follow the sUAS manufacturer’s maintenance, overhaul, 

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

components.

12. Each sUAS operated under this exemption will comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC 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 

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

Federal Government. 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. 

14. NFL Films will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the sUAS in a manner consistent with how the sUAS 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 will 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 sUAS in a manner consistent

with how the sUAS 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 will operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

NFL Films will not operate flights under special visual flight rules (SVFR).

16. The UA will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Director (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 
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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 will 

be made available to the Administrator or any law enforcement official upon 

request.

17. The UA will 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 sUAS loses communications or loses its GPS signal, the UA will return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC will be 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 will 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. 

22. All aircraft operated in accordance with this exemption will 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 

will be as large as practicable.

23. Documents used by NFL Films to ensure the safe operation and flight of the sUAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to 

the PIC at the Ground Control Station of the sUAS any time the aircraft is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

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

activities at all times.

25. The sUAS will not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations will 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. NFL Films will ensure that nonparticipating persons remain 
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under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UA, flight 

operations will 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, essential persons, or individuals who have signed 

consent forms are not considered nonparticipating persons under this 

exemption.

27. All operations will 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 will be 

reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

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. NFL Films will have a motion picture and television operations manual 

(MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, NFL Films will 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 sUAS aerial filming 

conducted under this grant of exemption;

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

operation of the sUAS;

d. Make, model, and serial or N-Number of the sUAS to be used;
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e. Name and certificate number of sUAS 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 will 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, the sUAS operations will comply with all applicable parts of 

14 CFR including, but not limited to, parts 45, 47, 61, and 91. NFL Films incorporates all 

arguments in support of the petition made in Advanced Aerial Cinematography’s November 24, 

2014 application for exemption. 

Federal Register Notice

As stated above, publication in the Federal Register is unnecessary because this 

application meets the FAA’s criteria for summary approval. To the extent that the FAA 

determines that publication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, 

subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 

(b)(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) and (b); 

91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 (a) & (b) 

to operate commercially a small unmanned vehicle (55 lbs or less) in 

videography operations.

The Exemption is in the Public Interest 

As demonstrated above, the proposed sUAS operations would minimize the risk of harm 

to individual safety or damage to the NAS and property. The operations proposed by NFL Films 

would provide tremendous public benefits by enabling millions of NFL fans to view footage that 

could not be captured via any other technology. The sUAS operations as described in this 

application will be far safer and more efficient than use of helicopters or other aircraft to capture 

the required footage.

The conditions outlined in this petition clearly satisfy Section 333’s exemption criteria

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

and operation within visual line of sight,” and therefore the proposed operations would not 
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“create a hazard to users of the national airspace system or the public or pose a threat to 

national security.” As discussed above, NFL Films agrees to use limitations that are substantially 

identical to those contained in the FAA’s recent grant of exemption for Advanced Aerial 

Cinematography. Accordingly, the proposed UAS operations of NFL Films should not raise 

safety or national security concerns, and should receive summary approval. 

Please do not hesitate to contact the undersigned if you need additional information. 

Respectfully submitted,

Kurt Wimmer

Jeff Kosseff