May 5, 2015 

 Exemption No. 11488 

 Regulatory Docket No. FAA–2014–0990 

Mr. Lane Wooder 

Advanced Aerial Cinematography, LLC 

5909 Chatham Court 

Tucker, GA 30084 

Dear Mr. Wooder: 

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

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

including the date it ends. 

By letters dated November 24, 2014 and January 21, 2015, you petitioned the Federal 

Aviation Administration (FAA) on behalf of Advanced Aerial Cinematography, LLC 

(hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an 

unmanned aircraft system (UAS) to conduct aerial videography and photography for closed 

set filming for the motion picture, television, and commercial videography industry. 

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

the regulations that the petitioner seeks an exemption. 

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

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

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

Airworthiness Certification 

The UAS proposed by the petitioner is a Cinestar 8. 
2 

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

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

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

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

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for closed set motion picture and filming. The FAA has 

issued grants of exemption in circumstances similar in all material respects to those presented 

in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to 

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

Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an 

unmanned aircraft (UA) with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying 

crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation 

enabled by this exemption is in the public interest. 

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

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

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

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

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Advanced Aerial Cinematography, LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection and/or closed set motion picture and filming. This exemption is subject 

to the conditions and limitations listed below. 
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Conditions and Limitations 

In this grant of exemption, Advanced Aerial Cinematography, LLC is hereafter referred to as 

the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the Cinestar 8 when 

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

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

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

permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

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

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

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

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

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

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

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

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

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

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

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

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

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

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

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

in a condition for safe operation. 

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

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

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

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

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

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

aircraft components. 

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

safety bulletins. 

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

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

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

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

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

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

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

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

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

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

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

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

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

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

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

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

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

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

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

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

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

power recommended by the manufacturer if greater. 

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

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

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

operations that cannot be conducted under the terms of the attached COA. 
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 

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

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

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

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

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless: 

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

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

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

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

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

present an undue hazard. 

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

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
7 

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

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

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

as documented in this grant of exemption. 

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

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

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

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

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

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

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

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

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

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

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

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

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

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
Lane Wooder 

T: +1 404 919 8430 

lane@advancedaerialcine.com 

November 24, 2014 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23 (b); 14 C.F.R. 21; 14 C.F.R. 61.113 (a) & (b); 

14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103 (b); 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. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.417 

(a) & (b). 

Dear Sir or Madam: 

 

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

Reform Act) and 14 C.F.R. Part 11, Advanced Aerial Cinematography LLC, operator of 

Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial videography 

and photography for the motion picture, television, and commercial videography industry 

for closed set filming, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

 

 As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in the NAS that is 1) limited 2) predetermined 3) controlled as to access. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” Section 

333(c) of the Reform Act. 

The name and address of the applicant is: 

 Advanced Aerial Cinematography LLC 

 Attn: Lane Wooder 

 Ph: 404-919-8430 

 Email: lane@advancedaerialcine.com 

 Address: 5909 Chatham Court 

 Tucker, GA 30084 
Regulations from which the exemption is requested: 

14 C.F.R. 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113 (a) & (b) 

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) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS or 

the public or pose a threat to national security in light of the following: 

 • The UAS’s size, weight, speed, and operational capability; 

 • Operation of the UAS in close proximity to airports and populated areas; and 

 • Operation of the UAS within visual line of sight of the operator. 

 Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish requirements

for the safe operation of such aircraft in the national airspace system.” Id. § 333 (c) 

(emphasis added). 

 The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

term is defined under §40101 of the Act, that includes sUASs, from the requirement that 

all civil aircraft must have a current airworthiness certificate. 

 The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701 (f) 

See also 49 U.S.C. § 44711 (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1). 
 Advanced Aerial Cinematography's sUASs are rotorcraft, weighting 50 or fewer 

lbs. including payload. They operate, under normal conditions at a speed of no more than 

40 knots and have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate only in line of sight and will operate only within a 

predetermined and closed off property area under the permission of the property 

representative. Such operations will insure that the sUAS will “not create a hazard to 

users of the national airspace system or the public” as per the Reform Act Section 333 

(b). 

 Given the small size of the sUASs involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and 

commercial videography operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

 The applicant proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These 

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

under the current regulatory structure because the proposed operations are conducted on 

closed off property under the permission of the property owner or property 

representative. 

 

 These limitations and conditions to which Advanced Aerial Cinematography 

agrees to be bound when conducting commercial operations under an FAA issued 

exemption include: 

1. The sUAS will weigh no more than 50 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will 

 be terminated at 30% battery power reserve should that occur prior to the 20 minute 

 limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 

 200 feet above an elevated platform from which filming is planned. If a structure being 

 filmed or photographed has a height which exceeds 400 feet AGL, the UAS will not 

 exceed 100 feet in height above the highest point on that structure. 

5. Minimum crew for each operation will consist of the sUAS Pilot, and the Visual 
 Observer. 

6. sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 40 

 hours of flight time with the specific sUAS equipment Advanced Aerial 

 Cinematography operates. The experience of the PIC will be certified by Advanced 

 Aerial Cinematography through background checks and, if necessary, testing. The PIC 

 will also have passed the FAA Airman Knowledge Test for Private Pilots (Test Code: 

 PAR or PRH). Advanced Aerial Cinematography will maintain flight logs of all PICs it 

 employs, and provide full transparency to the FAA regarding the logs and records of 

 these PICs. 

7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited 

 structures, buildings, vehicles, vessels, or people not associated with the operation or 

 who have not signed a waiver in advance of the operation. 

8. A briefing will be conducted in regard to the planned sUAS operations prior to each 

 day’s production activities. It will be mandatory that all personnel involved with the 

 operational duties of the flight within the boundaries of the safety perimeter be present 

 for this briefing. 

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

 requested exemption, with the appropriate local Flight Standards District Office. 

10. The operator will obtain the consent of all persons involved in the filming and ensure 

 that only consenting persons will be allowed within 100 feet of the flight operation, 

 and this radius may be reduced to 30 feet based upon an equivalent level of safety 

 determination. With the advanced permission of the relevant FSDO, operations at 

 closer range can be approved. 

11. PIC and Visual Observer will have been trained in the operation of the specific sUAS 

 equipment used by Advanced Aerial Cinematography, and received up-to-date 

 information on the particular sUAS to be operated. 

12. The PIC designated for any operation will have at least a Class 2 medical certificate. 

13. Visual Observer and PIC will at all times be able to communicate by voice, radio, 

 and/or text. 

14. Written and/or oral permission from the relevant property holders or property 

 representatives will be obtained. 

15. All required permissions and permits will be obtained from territorial, state, county or 

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

 governmental agencies. 

16. If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will 

 have the capability to return to a pre-determined location within the Security Perimeter 

 and land autonomously. 

17. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, 

 weather, or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 
Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation 

Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that 

the sUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 

The sUAS to be operated hereunder is 50 lbs. or less fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements, to provide security 

for the area of operation as is now done with conventional filming. The FAA will have 

advance notice of all operations. These safety enhancements, which already apply to civil 

aircraft operated in connection with motion picture and television production, provide a 

greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited", "restricted", "light-sport", "experimental", or 

"provisional", as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which 

the word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering 

will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer, and others working with the 

sUAS will see the identification of the sUAS as “Experimental”. The FAA has issued the 
following exemptions to this regulation as Exemption Numbers 10700, 8738, 10167 and 

10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft 

to have no less than 40 hours of flight time with the specific sUAS equipment Advanced 

Aerial Cinematography operates. The experience of the PIC will be certified by 

Advanced Aerial Cinematography through background checks and, if necessary, testing. 

The PIC will also have passed the FAA Airman Knowledge Test for Private Pilots (Test 

Code: PAR or PRH). Advanced Aerial Cinematography will maintain flight logs of all 

PICs it employs, and provide full transparency to the FAA regarding the logs and records 

of these PICs. The PIC designated for any operation will have at least a Class 2 medical 

certificate. The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the sUAS by a PIC meeting the standards of 

Advanced Aerial Cinematography (listed above) exceeds the present level of safety 

achieved by 14 C.F.R. § 61.113 (a) & (b). 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. Currently there are no 

pilot licenses that are specific for UAS operators, and no current FAA sanctioned pilot 

license of any type requires training with, and knowledge of, UAS equipment greater 

than the requirements Advanced Aerial Cinematography uses to certify its PICs. 

Therefore, the requirement of any available FAA sanctioned pilot license to operate a 

sUAS does not make a PIC a more competent operator than one meeting the requirements 

of Advanced Aerial Cinematography. Our company hopes the FAA develops a new Pilot 

License specific for UAS and sUAS commercial operation, one that sets high standards 

on the quality of pilots and increases the professionalism of our emerging industry. If the 

FAA does this, Advanced Aerial Cinematography's PICs will be some of the first to file 

for these licenses. Our company would also be happy to work with the FAA to help 

develop the standards for new licenses, and any other regulations the FAA is developing 

for UAS operation. 

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance, and use of safety check lists 

prior to each flight (summaries listed below), an equivalent level of safety will be 

provided. Summarized Safety Checklists: 
 1. Aircraft: All adjustment points will be checked for tightness; all motors and 

 props will be inspected; all wiring will be double checked; all systems will be 

 powered up and checked for errors. 

 2. Battery: Confirmation will be made that batteries are fully charged and 

 installed/connected properly. 

 3. Calibration: Pre-flight motor/gyro calibration followed by confirmation of no 

 errors with the flight and navigation systems. 

 4. Transmitter: Confirm radio transmitter has sufficient charge, and is both 

 working properly and receiving telemetry from the sUAS; confirm all switches 

 are in pre-flight mode. 

 5. Surroundings/Flight Area: Conduct one last visual inspection of the take-off 

 surroundings and area of airspace sUAS will be operating in. Confirm all 

 people in the surrounding areas are associated with the filming being done. 

 6. Take-off Announcement: Before motors are started the PIC will announce to a 

 designated Representative (person of authority) of the film crew that sUAS is 

 ready to take-off. Only after the Representative has notified all persons within 

 the surrounding areas, and confirmed to PIC that they have clearance to lift-off, 

 will the motors be started and the sUAS will conduct its operation. 

 7. Test Flight: A test flight will be conducted: after any disassembly/reassembly; 

 after replacement of any motors or flight electronics; after any pre-flight or in 

 flight equipment errors that occur not resulting from environmental conditions; 

 very first thing of any commercial operations day before filming begins; if 

 there are any concerns about environmental conditions and potential issues with 

 the flight path. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

 No person may operate a U.S.-registered civil aircraft ... 

 (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 

 this chapter, unless there is available in the aircraft a current approved 

 airplane or Rotorcraft Flight Manual, approved manual material, 

 markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the PIC flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 
This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data before initiation of flight. 

14 C.F.R. § 91.109: Flight instruction: 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. sUASs and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control is accomplished through the use of a control box 

that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 

9862A. The equivalent level of safety is provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft, and by the size and speed of the aircraft. 

14 C.F.R. § 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 feet AGL, or not more than 

200 feet above an elevated platform from which filming is planned, an exemption may be 

needed to allow such operations. As set forth herein, the sUAS will never operate at 

higher than 400 feet AGL with the exception that in circumstances where the sUAS is 

used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS 

will not be operated more than 100 feet above the highest point on the structure. It will 

however be operated in a restricted area with security perimeter, where buildings and 

people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS 

as well as the location where it is operated. No flight will be taken without the permission 

of the property owner or local officials. Because of the advance notice to the property 

owner and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 50 lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 AGL in the movie industry. In 

addition, the low-altitude operations of the sUAS will ensure separation between these 

small UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 
14 C.F.R. § 91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 

The battery powering the sUAS provides no more than 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, sUAS flights would not be 

possible due to the reserve requirement being equal to the maximum flight time. Given 

the limitations on the sUAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or 

twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 C.F.R. § 91.151 (a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 

controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151 (a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, the limitations created by this requirement for 

sUAS flights would essentially make null any utility for which the exemption will be 

granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 

20 minutes or 30% of battery power— whichever happens first. This restriction would be 

more than adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 
 (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it 

 has within it the following: 

 (1) An appropriate and current airworthiness certificate. . . . 

 (b) No person may operate a civil aircraft unless the airworthiness certificate 

 required by paragraph (a) of this section or a special flight authorization 

 issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

 legible to passengers or crew. 

The sUAS fully loaded weighs no more than 50 lbs and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents 

or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance and inspections 

will be done in accordance with the sUAS Manufacturer's Manual, and will be performed 

by employees of Advanced Aerial Cinematography following the guidelines and 

practices provided to us by the sUAS Manufacturer. An equivalent level of safety will be 

achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the sUAS can land immediately and will be operating from no higher than 

400 feet AGL. The PIC will ensure that the sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. 

Additional Views and Information 

Advanced Aerial Cinematography has realized the amazing benefits sUAS equipment can 

provide to the film and television industries. It not only provides new cinematography 
capabilities, but also increased safety over current and past practices that used larger and 

more dangerous equipment. Our company wants to have the highest levels of safety and 

professionalism, and one thing essential to this is achieving a path to commercial 

licensing with the FAA. We believe this will help reduce unsafe practices, discourage 

improper uses, and improve public perception. The commercial manufacture and use of 

sUAS equipment will create more jobs for the United States and help boost the 

economies in many sectors, and we want to help the FAA in creating regulations that will 

allow incorporation of UAS devices into our country's airspace for commercial use. 

********* 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

 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 

 (50 lbs or less) in motion picture, television, and commercial videography 

 operations. 

Approval of exemptions allowing commercial operations of sUASs in the film industry 

will enhance safety by reducing risk. Conventional film operations, using jet or piston 

power aircraft, operate at extremely low altitudes just feet from the subject being filmed 

and in extreme proximity to people and structures; and present the risks associated with 

vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or 

other fuel (140 gallons for jet helicopters.) Such aircraft must fly to and from the film 

location. In contrast, a sUAS weighing fewer than 50 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board. The sUAS is carried to the film set. The sUAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operation of small UASs, weighting less than 50 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property 

representative or owner’s prior consent and knowledge. Filming will be of people who 

have also consented to being filmed or otherwise have agreed to be in the area where 
filming will take place. All flights will occur in accordance with any state or local laws 

regarding privacy. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s sUAS equipment in the motion picture, television, and commercial 

videography industry. 

Sincerely, 

Lane Wooder 

Advanced Aerial Cinematography 

Owner and Operator