DC: 5806013

- 1 Filed Electronically Via Regulations.gov August 11, 2015

Dan Ngo FAA Office of Rulemaking 800 Independence Ave. SW Washington, DC 20591

Re: FAA

- 2015

- 2139

Dear Mr. Ngo:

Attached please find a Motion Picture and Television Operations Manual (“MPTOM”) prepared by NFL Films for the above

- referenced docket. T he MPTOM includes, at Appendix B

, a description of the aircraft makes, models, and types, as requested, for the proposed UAS operation

.

This letter and the attachment were filed online at regulations.gov in Docket No. FAA

2015

- 2139.

Please contact me if you have any questions.

Sincerely,

/s/ Stephen Kiehl

Stephen Kiehl

Attachment

# Motion Picture and Television Flight Operation Manual

NFL Productions LLC d/b/a NFL Films
One Sabol Way Mt. Laurel, NJ 08054 (856) 222

- 3545 | (856) 291

- 5455 (Fax)

Date: August 1 1 , 2015 Version: OriginalPage 2 of 14 

## Table of Contents

A. Purpose

................................ ................................ ................................ ............................... 4

B. Pilot/Operator Organization

................................ ................................ ............................ 4

C. Pilots To Be Used During Filming

................................ ................................ ................... 4

D. List of Aircraft by Make, Model and Serial or Registration Number

......................... 4

E. Distribution and Revision

................................ ................................ ................................ 4

F. Persons Authorized

................................ ................................ ................................ ........... 5

G. Area of Operations

................................ ................................ ................................ ............ 5

H. Plan of Activities

................................ ................................ ................................ ............... 8

I. Permission to Operate

................................ ................................ ................................ ...... 9

J. Security

................................ ................................ ................................ .............................. 9

K. Briefing of Pilots and Production Personnel

................................ ................................ 10

L. Certification/Airworthiness

................................ ................................ ........................... 10

M. Pilot Personnel

— Minimum Requirements

................................ ................................ ... 10

N. Limitations

................................ ................................ ................................ ....................... 10

O. Communications

................................ ................................ ................................ ............. 10

P. Accident Notification

................................ ................................ ................................ ...... 11

Q. Recall/Stop Procedures

................................ ................................ ................................ ... 11

R. Aerobatic Competency

................................ ................................ ................................ ... 11

Appendix A

Appendix B

Appendix CPage 3 of 14 

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## Motion Picture and Television Flight Operation Manual

A. Purpose

This Manual has been developed by NFL Productions LLC d/b/a NFL Films (“NFL Films”) in conjunction with an application for an exemption from a l imited number of regulations pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as outlined in NFL Films’ exemption application dated May 20, 2015 , for use of sUAS to gather footage from closed

- set locations in a nd around NFL stadiums (on non

- game days) and NFL practice facilities

. NFL Films’ pilots and other company personnel when applicable will comply with the policies, procedures, and conditions of this Manual , whenever motion picture or television flight ope rations are performed that require an exemption.

B. Pilot/Operator Organization

NFL Productions LLC d/b/a NFL Films

-- Operator One Sabol Way Mt. Laurel, NJ 08054 Barry M. Wolper

- Chief Financial Officer and applicant/responsible person

- (856) 222

- 3545

C. Pilots To Be Used During Filming

Pilots to be used during filming will be included in the Plan of Activities to be filed at least three (3) days prior to each scheduled filming, pursuant to Section H

, infra , with the local FSDO having jurisdiction over the area of proposed filming. The list of pilots will include each pilot’s pilot certificate number as well as special pilot authorizations or endorsements, if applicable.

D. List of Aircraft by Make, Model and Serial or Registration Number

A list of aircraft t o be used appears in Appendix B, infra . Furthermore, a ny aircraft to be used in the proposed filming shall be listed by make, model and serial or registration number in the Plan of Activities to be filed at least three days prior to each scheduled filming , pursuant to Section H

, infra , with the local FSDO having jurisdiction over the area of proposed filming.

E. Distribution and Revision

NFL Films will issue a copy of this manual, including all revisions, to all personnel involved in sUAS operation . All recipients are required to keep their manuals up

- to

- date with any furnished

revisions.

Amendments in FARs and normal usage will frequently indicate a need for additions, deletions, or corrections of selected subject matter in this manual. Revisions to t he manual will be issued periodically to reflect these changes. In addition, manual users who observe or experience a need for change are encouraged to submit their suggestions to the Chief Financial Officer for

review and consideration.

Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at least 15 days before the proposed effective date. Revisions will be noted on the RevisionPage 5 of 14 Control Page at the front of this Manual and will be noted in bold in this Manual. Each subsequent revision of the Manual will be distributed to all company personnel involved in sUAS operation.

F. Persons Authorized

Section 91.119(c) is waiv ed only with respect to those pa rticipating persons, vehicles, and structures directly involved in the pe rformance of the actual filming. The pilot

- in

- command and 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

reduc ed to no less than 200 feet in the event that a suitable, equivalent level of safety can be achieved. An equivalent level of safety may be determined by evaluation of the filming production area and the degree of terrain features, buildings, etc. that will provide a safety barrier

to observers.

Prior to any filming, the pilot

- in

- command and certificate holder shall be responsible for obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as outlined above) of the filming. Such consent forms shall be maintained by the operator for a period of at least six (6) months following the filming.

G. Area of Operations

The area of operations shall cover all NFL stadiums and practice facilities in the United States, including:

NFL Sta diums

Arizona Cardinals University of Phoenix Stadium Glendale, AZ 85305

Atlanta Falcons Georgia Dome Atlanta, GA 30313

Baltimore Ravens

M&T Bank Stadium Baltimore, MD 21230

Buffalo Bills Ralph Wilson Stadium Orchard Park, NY 14127

Carolina Panthers

Bank of America Stadium Charlotte, NC 28202 Miami Dolphins

Sun Life Stadium Miami Gardens, FL 33056

Minnesota Vikings

TCF Bank Stadium Minneapolis, MN 55455

New England Patriots

Gillette Stadium Foxboro, MA 02035

New Orleans Saints

Mercedes

- Benz Superdome New Orleans, LA 70112

New York Giants

MetLife Stadium East Rutherford, NJ 07073Page 6 of 14 Chicago Bears

Soldier Field Chicago, IL 60605

Cincinnati Bengals

Paul Brown Stadium Cincinnati, OH

Cleveland Browns FirstEnergy Stadium Cleveland, OH 44114

Dallas Cowboys Cowboys Stadium Arlington, TX 76011

Denver Broncos Sports Authority Field at Mile High
Denver, CO 80204

Detroit Lions

Ford Field Detroit, MI 48226

Green Bay Packers

Lambeau Field Green Bay, WI 54304

Houston Texans

NRG Stadium Houston, TX 77054

Indianapolis Colts

Lucas Oil Stadium

Indiana polis, IN

Jacksonville Jaguars

EverBank F ield Jacksonville, FL 32202

Kansas City Chiefs

Arrowhead Stadium Kansas City, MO 64129 New York Jets

MetLife Stadium East Rutherford, NJ 07073

Oakland Raiders

O.co Coliseu m Oakland, CA 94621

Philadelphia Eagles

Lincoln Financial Field Philadelphia, PA 19148

Pittsburgh Steelers

Heinz Field Pittsburgh, PA 15212

- 5721

St. Louis Rams

Edward Jones Dome St. Louis, MO 63101

San Diego Chargers Qualcomm Stadium San Diego, CA 92108

San Francisco 49ers

Levi’s Stadium Santa Clara, CA 95054

Seattle Seahawks CenturyLink Field Seattle, WA 98104

Tampa Bay Buccaneers Raymond James Stadium Tampa, FL 33607

Tennessee Titans

Nissan Stadium Nashville, TN 37213

Washington Redskins

FedEx Field Landover, MD 20785Page 7 of 14 NFL Practice Facilities

Arizona Cardinals University of Phoenix Stadium Glendale, AZ 85305 Miami Dolphins Miami Dolphins Training Facility Davie, FL 33314

Atlanta Falcons Atlanta Falcons Training Complex Flowery Branch, GA 30542 Minnesota Vikings Minnesota State University

– Mankato Mankato, MN 56001

Baltimore Ravens

Baltimore Ravens Under Armour Performance

Center Owings Mills, MD 21117 New England Patriots

Gillette Stadium Foxboro, MA 02035

Buffalo Bills St. John Fisher College Rochester, NY 14618 New Orleans Saints

The Greenbrier White Sulpher Springs, WV 24986

Carolina Panthers Wofford College Spartanburg, SC 29303

- 3663 New York Giants Quest Diagnostics Training Center

1925 Giants Drive

East R utherford, NJ 07073

Chicago Bears Olivet Nazarene University Bourbonnais, IL 60914 New York Jets Atlantic Health Jets Training Center Florham Park, NJ 07932

Cincinnati Bengals

Paul Brown Stadium Cincinnati, OH 45202 Oakland Raiders Napa Valley Marriott Hotel Napa, CA 94558

Cleveland Browns Cleveland Browns Training Facility
Berea, OH 44017 Philadelphia Eagles NovaCare Complex/Lincoln Financial Field Philadelphia, PA 19145

Dallas Cowboys

Marriott Residence Inn Oxnard, CA 93036

Cowboys Center Irving, TX 75063

- 4999 Pittsburgh Steelers St. Vincent’s College Latrobe, PA 15650

UPMC Sports Performance Complex Pittsburgh, PA 15203

- 2349

Denver Broncos

Paul D. Bowlen Memorial Broncos Center Englewood, CO 80112 St. Louis Rams

Rams Park Training Facility Earth City, MO 63045Page 8 of 14 Detroit Lions Detroit Lions Training Facility Allen Park, MI 48101 San Diego Chargers Chargers Park San Diego, CA 92123

Green Bay Packers St. Norbert College/Don Hutson Center Green Bay, WI 54304 San Francisco 49ers SAP Performance Facility & Levi’s Stadium Santa Clara, CA 95054

Houston Texans Houston Texans Practice Facility Houston, TX 77054 Seattle Seahawks Seattle Seahawks Headquarters Virginia

Mason Athletic Center Renton, WA 98056

Indianapolis Colts Anderson University Anderson, IN 46012

- 3495

Indiana Farm Bureau Football Center Indianapolis, IN 46254 Tampa Bay Buccaneers Tampa Bay Buccaneers Training Facility Tampa, FL 33607

Jacksonville Jaguars

EverBank Field Jacksonville, FL 32202 Tennessee Titans St. Thomas Sports Park Nashville, TN 37228

Kansas City Chiefs Missouri Western State University St. Joseph, MO 64506 Washington Redskins Bon Secours Washington Redskins Training

Center Richmond, VA 23220

The pilot/operator shall co ordinate with the FSDO having geographic responsibility over the area of the filming operations.

H. Plan of Activities

At least three (3) days prior to any scheduled filming, NFL Films shall submit a written plan of activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of activities shall include the following:

1) Dates and times for all flights.

2) Name and phone number of operator responsible for the filming production

event. 3) Name and phone number of the person respo nsible for the on

- scene operation

of the sUAS.

4) Make, model, and serial number or registration number of aircraft to be used and type of airworthiness certificate, including Category (CAT).Page 9 of 14 5) Names and certificate numbers of pilots involved in the filming p roduction

event.

6) A statement that permission has been obtained from property owners and/or

local officials to condu ct the filming production event; the list of those who gave permission will be made available to the inspector upon request.

7) Signature of e xemption holder or a designated representative.

8) A general outline , description or summary of the flight activity schedule, including maps or diagrams of any area, city, town, country, and/or state over which filming will be conducted and the altitude esse ntial to accomplish the operation

.

At the discretion of the FSDO, the 3

- day notification may be waived. Justification of the exception to the 3

- day requirement is needed.

NFL F ilms acknowledges that prior to the beginning of any filming operations, the plan of activities must be accepted by the FAA.

I. Permission to Operate

Before any flight operation 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) Local, state and federal government

The NFL Films 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. Written permi ssion forms will be maintained at the job site until flight operations are completed, and then turned over to NFL Films 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 pers onnel upon request.

J. 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, vehicles andPage 10 of 14 aircraft. Provisions will be m ade to immediately discontinue operations should the area(s) become unsecured or for any other reason in the interest of safety.

K. Briefing of Pilots and Production Personnel

Prior to the start of any operation under the provisions of this Manual, the pilo t in command will conduct a briefing of all procedures to participating personnel of the risks involved, emergency procedures, and safeguards to be following during the filming production event. Personnel will also be briefed on any additional provisions that may be issued by the local FSDO, including the location of boundaries or any other time limits.

L. Certification/Airworthiness

Prior to any flight operation, the pilot in command will conduct a pre

- flight inspection in

accordance with Title 14 of the Cod e of Federal Regulations (14 CFR) parts 43 and 91 and applicable operating limitations. The pre

- flight inspection will account for all potential discrepancies, e.g., inoperable components, items or equipment. If the inspection reveals a

condition that af fects the safe operation of the sUAS, the aircraft will be prohibited from operation until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight.

NFL Films will follow the sUAS manufacturer’s maintenance, o verhaul, replacement, inpsection and life limit requirements for the aircraft and aircraft components. Each sUAS operated under this exemption will comply with all manufacturer safety bulletins.

The aircraft to be used may be certificated in any CAT, i ncluding experimental, provided the requirements of 14 CFR part 91, §§ 91.7, 91.9, and 91.203 are met.

M. Pilot Personnel

— Minimum Requirements

The pilot in command will hold either an airline transport, commercial, private, recreational, or sport pilot certif icate. 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 revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

N. Limitations

Aircraft operations shall conform with the limitations set forth in NFL Films’ request for a limited exemption, dated May 20, 2015, attached to this Manual as Appendix C.

The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.

The aircraft will not be operated during night, as defined in 14 CFR § 1.1

.

O. CommunicationsPage 11 of 14 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 appr ised of the current status of the operation.

P. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the operator would immediately notify the NTSB pursuant to 49 CFR § 830 and take steps to preserve and protect

the accident scene.

Q. 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.

R. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710

- 7, see Volume 5, Chapter 9, Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.Page 12 of 14 

## Appendix A

NFL Films
Permission to Conduct Operations Form

In signing this form, I am giving NFL Films permission to operate its 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 pr oduction.

Name:

____________________________

Title:

____________________________

Location:

____________________________

Date of Operation:

____________________________

Basis of Authority to Grant Permission:

__________________________________________ ____________________________

Signature:

____________________________

Date:

____________________________

NFL Films Representative Receiving Permission:

________________________________________Page 13 of 14 

## Appendix B

NFL Films List of Approved Aircraft

Make and Model Type Weight

1 DJI Innovations Phantom 1 Quad

- rotor 3 lbs. (inclusive of camera and battery)

2 DJI Innovations Phantom 2 Quad

- rotor 3 lbs. (inclusive of camera and battery)

3 DJI Innovations Inspire 1 Quad

- rotor 6 lbs. (inclusive of camera and battery)Page 14 of 14 

## Appendix C

NFL Films’ Letter Requesting Limited ExemptionsMay 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