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 (“ s UAS”) equipped to conduct aerial videography of professional

f ootbal l game and training facilities, requests a limited exemption from the below

- listed regulations to allow commercial operation of its s UASs, provide d 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 th is 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 2 0 , 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 e xemption to use s UAS to gather footage from

cl osed

- set location s 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 s UAS 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 with in the limitations listed below. These

limitations were e stablished 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 o ther 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 s UAS 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 UAU.S. Department of Transportation May 2 0 , 2015 Page 3

be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacture r.

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 wi thin 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 wi ll 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 exemptio n and all documents needed to operate the s UAS and conduct its operations in accordance with the condition s and limitations stated in th e grant of exemption, are hereinafter referred to as the operating documents. The operating documents will be accessib le during s UAS operations and made available to the Administrator upon request. If a discrepancy exists between the

co nditions and limitations in th e 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 upd ated 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 an y 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 UA S 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 conduc ting 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 h azard to persons and property.U.S. Department of Transportation May 2 0 , 2015 Page 4

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 s UAS is in a condit ion 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 s UAS, the aircraft will be prohibi ted form operating until the necessary maintenance has been performed and the s UAS is found to be in a condition for safe flight.

11. NFL Films will follow the s UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft
components.

12. Each s UAS 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 fligh t 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 s UAS in a manner consist ent with how the s 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 will be logged in a m anner 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 s UAS in a manner consisten t with how the s UA S 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 f lights under special visual flight rules (SVFR).

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denot ed in the current FAA Airport/Facility Director (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted onU.S. Department of Transportation May 2 0 , 2015 Page 5

the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtai ned 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 fee t 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 s UAS loses communications or loses its GPS signal, the UA will return to a

pre

- determined location within the private or control led

- 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 ex emption 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 e nsure the safe operation and flight of the s UAS 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 s UAS 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 s UAS will not be operated by the PIC from any moving device or vehicle.

26. All Flight op erations 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

ac cident. NFL Films will ensure that nonparticipating persons remainU.S. Department of Transportation May 2 0 , 2015 Page 6

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 e nsuring 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 o bjects 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 conduct ed 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 inc ident, 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 additiona l 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 loc al 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 fli ghts;

b. Name and phone number of the operator for the s 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 s UAS;

d. Make, model, and serial or N

- Number of the s UAS to be used;U.S. Department of Transportation May 2 0 , 2015 Page 7

e. Name and certificate number of s 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 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.

U nless otherwise specified, the s UAS 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 p ublication 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; 91.15 1(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 s UAS op erations would minimize the risk of harm

to individual safety o r 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 s UAS 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 wi thin visual line of sigh t

, ” and therefore the proposed operations would notU.S. Department of Transportation May 2 0 , 2015 Page 8

“ create a hazard to users of the national airspace sy stem or the public or pose a threat to national security. ” As discussed above, NFL Films agrees to use limitations that are substantially

identical to thos e 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 receiv e summary approval.

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

Respectfully submitted,

Kurt Wimmer
Jeff Kosseff