The Visual Arts Group, LLC 

Media in Motion 

www.thevisualartsgroup.com

July 6, 2015

U.S Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Amendment to Exemption No 11733 Issued to The Visual Arts Group, LLC pursuant to Section 

333 of the FAA Reform Act (Docket No. FAA-2015-0036)

Dear Gentlemen:

The Visual Arts Group, LLC was issued exemption No. 11733 on June 2, 2015 (hereafter “the 

Exemption”) allowing the petitioner to operate a UAS to perform aerial data collection and closed set 

motion picture filming. The Visual Arts Group, LLC hereby requests an amendment to the exemption 

that will allow the PIC to operate a UAS from a moving vehicle. 

This request for amendment specifically addresses rule #25 within the Conditions and 

limitations that prohibits the operation of a UAV from a moving vehicle or devise. Should this 

amendment be granted, all other conditions and limitations listed under “Conditions and Limitations” as 

specified under this Exemption would be adhered to. The Visual Arts Group, LLC believes that an 

amendment allowing UAV operation from a moving vehicle is in the public’s interest as it would reduce 

the distance between the PIC and the UAV. 

A constant shorter distance between the UAS and PIC can be maintained at all times. The closer 

proximity between the PIC and UAS would facilitate more precise and safer camera shots. The moving 

vehicle would be operated at speeds at or below 25mph and would add increased safety to the line of 

sight distance limit, as specified in the “Conditions and Limitations” of the Exemption. The moving 

vehicle amendment will allow the PIC to follow and film an action scene down a path or roadway while 

operating under the operating procedures set forth in the Movie Production and Television Operations 

Manual (MPTOM). Examples of moving vehicles would be golf carts, camera dollies and other slow 

moving vehicles customarily used on motion picture and TV sets for the purpose of transporting movie 

cameras during the filming process. The moving vehicles would be operated within safety boundaries 

clearly set up and marked for the purpose of safety to all personal and equipment located within the 

movie and TV production “sterile set” area of operation. 
An additional crew member beyond the spotter, camera operator and PIC will be utilized as a 

driver/operator of the moving vehicle transporting the PIC. The moving vehicle will not have any 

obstructed view of the flight area such as a roof over the area where the PIC is located on the vehicle. 

The vehicle will be open above the PIC with a 360 degree overhead view of the area of UAS operations. 

The moving PIC vehicle will operate only in the designated “sterile area” of the set.

The Visual Arts Group, LLC respectfully submits that this amendment qualifies for summary grant 

approval. Grant of Exemption to The Visual Arts Group, LLC, Exemption No. 11733. Given that the 

proposed operations will fully comply with the other conditions of the Exemption, there is no need for 

the FAA to repeat the analysis performed for the original exemption on which this amendment is based. 

For these same reasons, good cause exists so that notice does not need to be published in the Federal 

Register for the requested amendment. If you have any questions, or need any additional information to 

process the requested amendment to allow UAS operations from a moving vehicle for the purpose of 

closed-set motion picture and television filming, please do not hesitate to contact the undersigned. 

Very Truly Yours,

Wm. Howell Upchurch

President

The Visual Arts Group, LLC