August 20, 2015

Exemption No. 12548

Regulatory Docket No. FAA–2015–2211

Mr. Brian J. Kelly

Principal 

Single Malt Media, LLC

13101 Blue Willow Place

Clifton, VA 20124

Dear Mr. Kelly:

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 letter dated May 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Single Malt Media, LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

cinematography in closed set filming in motion picture and television production.

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 are a DJI Spreading Wings S900 and DJI S800 EVO.

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 
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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 aerial data collection1 and 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, Single Malt Media, 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 closed set motion picture and filming. This exemption is subject to the conditions and 

limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Single Malt Media, 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 DJI Spreading 

Wings S900 and DJI S800 EVO 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.
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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.
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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 August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Single Malt Media, L.L.C. Section 333; Exemption Petition 1

May 21, 2015

United States Department of Transportation 

Docket Operations, M-30

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 

RE: Exemption Request Pursuant to Section 333 of the FAA

Reform Act of 2012.

Dear Sir or Madam,

We are writing regarding the FAA Modernization and Reform Act of 2012, and 

the procedures contained within 14 C.F.R 11, to request that Single Malt Media, 

LLC, be exempted from the Federal Aviation Administration’s (“FARs”) listed 

below so that Single Malt Media may operate it’s lightweight unmanned aircraft

systems (UAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA).

The conditions identified and proposed by the applicant are drawn from:

Order 8900.1 CHG 0, Volume 3, Chapter 8-issue a Certificate of Waiver for 

Motion Picture and Television Filming, as well as similar prior Exemptions 

granted by the Federal Aviation Administration.

Single Malt Media is an established media production company who’s principal 

Brian J. Kelly, has over 30 years experience in the television and motion picture 

industry. Mr. Kelly has previously held senior staff positions at the network 

television level (Discovery Communications) as well as several high profile 

production companies prior to launching Single Malt Media in 2009. Mr. Kelly 

was one of the earliest advocates for the safe and effective use of UASs in 

motion picture and television production while on staff at Discovery 

Communications in 2007. In his 30 years in television and film production, Mr. 

Kelly has used both fixed wing aircraft and helicopters for filming purposes on 

over 50 projects spanning 5 continents. Mr. Kelly has filmed from U.S. military

aircraft and helicopters as well as numerous civilian aviation platforms. 
Single Malt Media, L.L.C. Section 333; Exemption Petition 2

Motivated by the loss of several industry colleagues in a tragic helicopter crash 

(killing a Discovery Channel film crew) in February of 2013, Mr. Kelly launched a 

UAS cinematography division for Single Malt Media. The significant risk

associated with aerial filming is an issue that has haunted our industry for many

years. The issue is outlined in stark detail in an article on the industry website 

deadline.com which chronicles this ongoing dilemma and outlines multiple 

accidents and tragic deaths of media professionals as a result of aviation 

accidents occurring during aerial cinematography operations. The article can be 

found by following the link.

http://deadline.com/2014/04/helicopter-crash-deaths-hollywood-safety-history709487/

The bottom line -- since 1980, 33 television and film crewmembers have been 

killed in aviation related accidents while on the job. That is an average of one a 

year. While these accidents and the associated loss of life were tragic in of 

themselves -- they also posed a significant risk to the general public.

Recognizing the value of UAS’s as a “game changer” (nearly a decade ago), Mr. 

Kelly has been involved in thousands of hours of testing and evaluation of UASs 

furthering their viability as safe and effective camera platforms. It is worth noting, 

(as a credit to both the technology we use and our internally mandated, 

redundant, operational and safety procedures) Single Malt Media has never 

experienced a UAS mishap. Single Malt also has UAS PICs holding recreational 

pilot certificates.

The evolution and current advancements of UAS technology represents a clear 

and present economic opportunity for companies around the country and a giant

leap forward for our industry to reduce the significant safety risk (as well as 

reducing noise and environmental pollution) associated with the use of 

helicopters and fixed wing aircraft. The convergence of UAS technology along 

with the miniaturization of cameras (and gyroscopically stabilized camera 

mounts) is perhaps the greatest development in the television and film industry in 

the last 50 years -- creating a new trade specialization and an enormous 

opportunity for jobs and economic growth.

Therefore, Single Malt Media respectfully requests that the FAA grant Single Malt 

Media an exemption allowing it to operate lightweight UAS for the purpose of 

aerial cinematography in closed set motion picture and television production, as 

well as on restricted access locations and on pre-approved private property with 

all appropriate permissions and waivers and meeting all other FAA stipulations, 

conditions and limitations.
Single Malt Media, L.L.C. Section 333; Exemption Petition 3

Contact Information

Brian J. Kelly

Principal

Single Malt Media

13101 Blue Willow Place

Clifton, Virginia 20124

703-298-2681

brian@singlemaltmediatv.com

The Specific Sections of Title 14 of the Code of Federal 

Regulations From Which SMM, LLC Requests Exemption Are:

14 CFR 21, 14 CFR 45.23 (b), 14 CFR 61.113 (a) & (b), 14 CFR 61.3 (a) (1) (i) –

(While we have staff members with recreational certificates, we also have staff 

with over 500 hours of UAS flight experience currently not holding certificates).

91.7 (a); 91.9 (b) (2); 91.103 (b); 91.105; 91.109; 91.119; 91.121; 91.151 (a); 

91.203 (a); 91.203 (a) & (b); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b)

Single Malt Media’s request for relief is first and foremost that without an FAA 

exemption our new business unit would not be viable. But beyond this

immediate remedy we strongly believe that this exemption will allow us to 

contribute significantly to an emerging field that represents a very real growth 

opportunity to the film and television industry while enhancing safety to the 

general public. As a result, granting of this exemption to Single Malt Media is 

clearly in the public interest by way of obviating the need for aircraft of 

significantly greater proportions carrying multiple crew as well as highly 

flammable fuel in our production operations.

112 P.L. 95 §§ 331-334

Single Malt Media is seeking relief from any currently applicable FARs to prevent 

us from working on closed set film or television production. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft into our

national airspace as it is in the public interest to do so. Single Malt Media’s 

lightweight UAS meet the definition of “small unmanned aircraft” as defined in 

section 331, and therefore the integration of Single Malt Media’s UAS’s are 

expressly contemplated by the Reform Act. Single Malt Media would like to 

operate its lightweight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such aircraft.
Single Malt Media, L.L.C. Section 333; Exemption Petition 4

The FAA has granted similar exemptions in material respect by way of

Exemption Nos. 11062 to Astraeus Aerial; 11109 to Clayco, Inc.; 11112 to VDOS 

Global, LLC.; and 11213 to Aeryon Labs, Inc. In these cases the FAA found that 

the enhanced safety achieved using an unmanned aircraft (AU) is in the public 

interest.

Each of the following (SMM operational and safety issues) urges in favor of an 

exemption for Single Malt Media:

Single Malt Media UAS’s SOPs and Equipment:

 Aircraft: DJI Spreading Wings, S800 EVO and S900 carbon fiber frame 

equipped with the industry leading DJI A2 flight control system. These are 

among the most stable and reliable airframes commercially available.

 All our airframes are (by design) equipped with a minimum of 6-engines.

While provide exceptional stability, this feature also provides critical safety 

redundancies. As opposed to quad-copters, 6-engine and 8-engine 

airframes can land safely even in the event of the loss of one engine. This 

is an area where we have actively lobbied manufactures and distributors 

to limit the distribution of quad-rotors because of the “total loss” caused by

single engine or rotor blade failure. 

 All crews consist of 2 persons. A PIC and a Camera Operator/Spotter. 

The camera operator/spotter is also fully qualified to operate the UAS in 

the event of an emergency.

 Preflight and post flight inspections are conducted in accordance with a 

Single Malt Media flight operations manual that PIC’s are required to have 

read and have in their possession during all flight operations.

 Crews use (2) Industry leading Futaba 14 channel radios. Complying with 

limits for Class B digital device, pursuant to Part 15 of the FCC Rules.

 Airframes are well below the FAA mandated 55 lbs. Fully loaded and 

(depending on the camera) most flights are in the 16lb (min) - 30lb (max)

range.

 All aircraft are quipped with the A2 GPS flight control system with several 

levels of redundant safety features including a “go home” feature that 

allows the aircraft to return to the landing zone and land safely in the event 

of radio communications loss. 
Single Malt Media, L.L.C. Section 333; Exemption Petition 5

 All aircraft have a maximum altitude governor set for 50 feet below the 

FAA mandated 400 foot ceiling. All aircraft are also quipped with an iOSD 

providing the PIC real time visual information including battery level, 

altitude, attitude, air speed, heading and ascent or descent speeds. While 

commercially available this is a Single Malt Media mandated safety 

feature on all of our aircraft.

 All aircraft have an air speed governor set for 30-knots. This is a Single 

Malt Media mandated software based safety feature and cannot be altered 

by PIC.

 All aircraft have a maximum distance governor set for 500-yard maximum 

down range distance from aircraft’s designated home point. This is a 

Single Malt Media mandated safety feature and cannot be altered by the 

PIC.

 All aircraft are battery powered by (2) lithium polymer batteries. Another 

(redundant) Single Malt Media mandated safety feature. It is worth noting 

that this is another area where we have lobbied the industry for a “best 

practices” guideline of dual battery configurations for safety reasons (in 

the event of battery failure). No combustible fuels are used on any of our 

aircraft. PIC’s are advised to land when battery power reaches 40%, 

which is reinforced by a LED warning light on the airframe. Single Malt 

Media aircraft must land at 35% battery power.

 Single Malt Media publishes operational and flight guidelines in flight 

manual that all PICs must follow and have in their possession during all 

flight operations.

 Single Malt Media does not conduct flight operations near airports or in 

designated “restricted” or “no fly” zones. The UASs operating software on 

all of our aircraft automatically disables the aircraft in these designated 

areas preventing it from taking off.

 All UAS flight activities are in support of main production operations and 

are used for acquiring supplemental footage, scenic scenes and b-roll. 

UAS’s will not be flown over general public and only in the vicinity of 

authorized production personnel.

 Single Malt Media carries all available liability insurance coverage for the 

use of UAS in aerial cinematography.

 All flights are limited to (VLOS) visual line of sight.
Single Malt Media, L.L.C. Section 333; Exemption Petition 6

For these reasons listed, Single Malt Media’s operation of small UAS will mitigate 

risk and not “create a hazard to users of the NAS or the public.” 112 P.L. 95 § 

333 (b). Given the small size and multiple redundant safety features inherent to 

the technology and those further mandated by Single Malt Media, combined with 

our operations within “closed sets” and or “controlled access” and “permitted”

locations, Single Malt Media’s UAS operations fall well within Congress’s 

contemplated safety parameters when it authored the Reform Act and the 

corresponding directive to integrate UASs into the national airspace. 

We also believe that Single Malt Media’s safety standards and practices 

represent a “level above” what even the FAA is seeking in granting exemptions to 

UAS operators and may even serve to further enhance the FAA’s efforts in the 

evolving process of creating industry regulations as well as “best standards and 

practices.” Single Malt Media’s UASs have an industry leading, “0-loss” safety 

record and do not pose a threat to the general public or national security.

The FAA has the authority to issue an exemption to Single Malt Media, LLC 

pursuant to: The Federal Aviation Reform Act 85 P.L. 726 (1958)

As a public benefit, Single Malt Media will advance:

 Industry “best standards and practices” for UAS safety and flight 

operations.

 Reinforce public opinion on the positive impact of UAS technology and as 

a result furthering the economic viability of the industry.

 Further a rapidly evolving art form.

 Increase the overall quality of lower budget cable television programming 

that cannot meet the financial and insurance requirements of renting 

helicopters or fixed wing aircraft for filming.

 Create jobs and contribute to economic growth in an economy (and an 

East Coast entertainment market) that desperately needs them.

 Positive environmental impact through a reduction in carbon emissions.

 Reduce the dangers of using significantly larger aircraft carrying highly 

combustible fuels and as a result save lives.
Single Malt Media, L.L.C. Section 333; Exemption Petition 7

Summary

Single Malt Media and its’ employees have accumulated a combined 100 years 

of television and film production experience. We have filmed on location in some 

70 countries and on every inhabited continent on the planet. The ability to 

capture moving images from an elevated and moving perspective is something 

motion picture professionals wish they could include in just about every project. 

But due to limited budgets, and insurance requirements aerial photography is 

often cost prohibitive. Tragically, the quest to obtain this “birds eye perspective” 

when affordable has resulted in the loss of 33 of our friends and colleagues over 

the last 30 years -- as well as creating a very real risk to property and the public 

as a whole. The use of UAS technology to capture aerial imagery represents the 

most significant advancement in motion picture technology in the last 50 years. It

also represents the most significant safety advancement. 

Single Malt Media has been at the forefront of the testing of this technology for 

almost a decade. And we have designed and implemented safety and “best 

practices” procedures that put us at the forefront of this emerging field. As a 

result of our industry leading safety protocols, redundant designs and use of failsafe technology, Single Malt Media’s use of UAS minimizes the risk to both the 

NAS and to persons and property on the ground.

In summary, Single Malt Media is seeking exemption from the following 

Regulations:

14 CFR 21, 14 CFR 45.23 (b), 14 CFR 61.113 (a) & (b), 14 CFR 61.3; (a) (1) (i); 

91.7 (a); 91.9 (b) (2); 91.103 (b); 91.105; 91.109; 91.119; 91.121; 91.151 (a); 

91.203 (a); 91.203 (a) & (b); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b); 112 

P.L. 95 §§ 331-334 to commercially operate our small lightweight UAS in closed 

set, restricted access and permitted television and motion picture operations. 

Single Malt Media respectfully requests that the FAA grant our exemption, as we 

feel that our exceptional safety record and creative professionalism are aligned 

with the FAA’s mission to provide the safest and most efficient aerospace system 

in the world and such exemption is in the public interest.

Respectfully,

Brian J. Kelly

Principal

Single Malt Media, LLC