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. The 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. FAA2015-2139.

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 11, 2015 Version: Original
Page 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 C
Page 3 of 14

Revision Control Page

Revision # Date Initials

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Page 4 of 14

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 limited 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 and 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 operations 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 to be used appears in Appendix B, infra. Furthermore, any 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 the 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 Revision 
Page 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 waived only with respect to those participating persons, vehicles, and 

structures directly involved in the performance 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 

reduced 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 Stadiums

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 07073
Page 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

Indianapolis, IN

Jacksonville Jaguars

EverBank Field

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 Coliseum

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 20785
Page 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 Rutherford, 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 63045
Page 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 coordinate 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 responsible 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 production 

event.

6) A statement that permission has been obtained 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.

7) Signature of exemption 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 essential 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 Films 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 permission 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 personnel 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 and 
Page 10 of 14

aircraft. Provisions will be made 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 pilot 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 Code 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 affects 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, overhaul, 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, including 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 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.

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. Communications
Page 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 apprised 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 production.

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 Exemptions
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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May 20, 2015

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. 
U.S. Department of Transportation

May 20, 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 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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May 20, 2015

Page 5

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 
U.S. Department of Transportation

May 20, 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 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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May 20, 2015

Page 7

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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May 20, 2015

Page 8

“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