J 

June 9, 2015 

U.S. Department of Transportation, Docket Operations M30 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590-0001 

Petition of Sky Lens LLC dba Film and Flight for Exemption Pursuant to Section 

333 ofthe FAA Modernization and Reform Act of2012. 

To Whom It May Concern: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR 

Part 11, SkyLens LLC, dba Film and Flight, hereby applies for exemption from the 

aforementioned Federal Aviation Regulations (FARs) to allow commercial operation of 

its Unmanned Aircraft Systems (UASs). 

This exemption is in accordance with the conditions outlined herein, the enclosed Film 

and Fli~ht General Operations Manual1

, DJI UAS User's Manuals, DJI Quick Start 

Guides , and all other requirements established by the FAA pursuant to Section 333 of 

the Modernization and Reform Act. 

This exemption would allow Sky Lens LLC to perform commercial operations using DJI 

Phantom 3 and DJI Inspire 1 UAS for the purposes of aerial photography and 

videography. These operations would be operated in airspace that is 1) limited 2) 

predetermined 3) has controlled access and 4) would provide safety enhancements to the 

already safe operations in the film and television industry using conventional aircraft. 

The name and address of the applicant is: 

Sky Lens LLC, dba Film and Flight 

Attn: Terra S. Merriman 

Ph: (904) 377-0036 

Email: §h11mi,m9rrim?n@gmgiJ,Gm:n 

Address: 14 Court Theophelia • Saint Augustine, FL 32084 

1 SkyLens LLC is submitting its General Operations Manual (GOM) as a confidential 

document under 14 CFR35(b), the entire content of the GOM contains confidential 

commercial and proprietary information that Sky Lens has not and will not share with 

others. This manual contains operating procedures that are not available to the public and 

are protected from release under the Freedom oflnformation Act, 5 USC § 552 (b) ( 4). 

2 In an effort to reduce the unnecessary printing of materials, DJI User Manuals and 

Quick Start Guides can be downloaded from the DJI support website at: 

www.dji.com/support 

SkyLens LLC. Exemption Request 1 
SkyLens LLC's UAS are multi rotor aircraft, weighting less than 55 lbs. including 

payload. They operate, under normal conditions at a speed of no more than 100 mph 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 the 

sterile area described in the Film and Flight General Operating Manual, (hereinafter 

"GOM"). Such operations will insure that the UAS will "not create a hazard to users of 

the national airspace system or the public". 

Given the small size of the UAS 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 ofUASs to commence immediately. Also due 

to the size of the UASs and the restricted areas in which the relevant UAS 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 aerial filming, 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. 

SkyLens LLC's GOM provides procedures and limitation under which the operator will 

be bound by. 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 represent a safety enhancement to the already safe aerial filming operations 

conducted with conventional aircraft. 

The limitations and conditions to which SkyLens LLC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. Minimum crew will consist of a PIC and a Visual Observer (VO). 

2. All operations will be conducted under daytime VFR conditions. 

3. Flights will be operated within Visual Line Of Sight (VLOS) ofthe PIC and VO. 

4. If the PIC or VO lose sight of the UAS, the PIC will immediately active the 

"return to home" function of the aircraft. 

5. Pilot in Command and Visual Observer will at all times be able to communicate 

by voice. 

6. Prior to flight the PIC will insure there is enough available power for the UAS to 

conduct the intended operation and to operate thereafter for at least five minutes 

or the reserve power recommended by the manufacturer whichever is if greater. 

7. Flights will be operated at an altitude of no more than 400 feet AGL. 

SkyLens LLC. Exemption Request 2 
8. 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 UAS and/or debris in the event of an accident. 

The operator will 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 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. 

9. The UAS will operate only within a confined "Sterile Area" as defined in the 

GOM. 

10. In accordance with the GOM a briefing will be conducted in regard to the planned 

UAS operations prior to each day's missions. It will be mandatory that all 

personnel who will be performing duties within the boundaries of the sterile area 

be present for this briefing. 

11. In the event of an accident involving a Film and Flight UAS, the PIC will 

immediately cease operations and report the accident to the NTSB and AFS-80. 

12. 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. 

13. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC, the VO, or the UAS. 

14. Procedures have been established in Film and Flight's GOM to contact ATC prior 

to operating in the National Airspace System (NAS). 

SkyLens LLC. Exemption Request 3 
Sky Lens LLC. Is requesting exemption from the following F ARs: 

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)(l) 

91.405(a) 

91.407(a)(1) 

91.409(a)(1) and (2) 

91.417(a) and (b) 

SkyLens LLC operates UASs in a manner consistent with prior section 333 exemptions. 

Many previous cases have set precedent in which the FAA has granted relief from the 

listed FARs (See: Nos 11062, Nos 11109, Nos 11112, and Nos 11213). Since SkyLens 

LLC falls squarely within the already established zone for exemption, and would not set a 

precedent for exemption from the listed F ARs, they will forgo elaboration of the FAR 

definitions and necessary reasons for exemption. 

Regards, 

Terra S. Merriman, Manager 

SkyLens LLC. dba Film and Flight 

Cell Phone: (904) 377-0036 

filmandflight@gmail.com 

SkyLens LLC. Exemption Request 4 
FILM tf1 FLIGHT 

GENERAL OPERATIONS MANUAL 

Sky Lens LLC dba Film and Flight 

14 Court Theophelia • Saint Augustine, FL 32084 

(904) 377-0036 

Date: 5.25.2015 1 Revision: Original 
Table of Contents 

1. INTRODUCTION ................................................................................................................ 4 

2. AIRCRAFT ........................................................................................................................... 4 

2.1. DJI PHANTOM 3 .............................................................................................................................. 4 

2.1.1. Description ................................................................................................................................................ 4 

2.1.2. Specifications and Limitations .......................................................................................................... 4 

2.2. DJI INSPIRE 1 ................................................................................................................................... 5 

2.2.1. Description .................................................................................................................................................. S 

2.2.2. Specifications and Limitations ........................................................................................................... 6 

3. PILOT IN COMMAND ....................................................................................................... 6 

3.1. RESPONSIBILITIES ........................................................................................................................... 6 

3.2. QUALIFICATIONS .............................................................................................................................. 7 

3.3. EXPERIENCE ..................................................................................................................................... 7 

3.4. TRAINING .......................................................................................................................................... 7 

4. VISUAL OBSERVER .......................................................................................................... 7 

4.1. RESPONSIBILITIES .......................................................................................................................... 7 

4.2. QUALIFICATIONS ............................................................................................................................. 8 

4.3. EXPERIENCE .................................................................................................................................... 8 

5. MAINTENANCE .................................................................................................................. 8 

5.1. PRE-FLIGHT INSPECTION .............................................................................................................. 8 

5.2. FUNCTIONAL TEST FLIGHTS ......................................................................................................... 8 

6. OPERATIONS ..................................................................................................................... 9 

7.1. OVERVIEW ....................................................................................................................................... 9 

6.2. AREA OF OPERATIONS ................................................................................................................... 9 

6.3. PREFLIGHT BRIEFING ..................................................................................................................... 9 

6.4. UAS CHECKLIST .............................................................................................................................. 9 

7. WEATHER ........................................................................................................................ 11 

8. ACCIDENT /INCIDENT REPORTING: ........................................................................ 12 

9. GLOSSARY ....................................................................................................................... 12 

APPENDIXA ............................................................................................................................ 14 

A.1 FILM AND FLIGHT PERMISSION ACQUISITION FORM ................................................................... 14 

A.2 VISUAL OBSERVER BRIEFING GUIDE ............................................................................................. 15 

A.3 REVISION LETTER ............................................................................................................................. 16 

Date: 5.25.2015 2 Revision: Original 
Revision Control Page 

Revision# 

Date: 5.25.2015 

Date Initials 

3 Revision: Original 
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j 

1. Introduction 

The General Operations Manual (GOM) has been developed by SKYLENS LLC dba 

FILM AND FLIGHT in conjunction with an application for exemption under section 333 

of the FAA Modernization and Reform Act of2012 for the purpose of aerial filming. The 

policies, procedures, and conditions contained within this manual shall be followed at all 

times during operations that require a section 333 exemption. 

2. Aircraft 

Film and Flight utilizes DJI Phantom 3 and DJI Inspire 1 UAS for aerial filming and 

photography. 

2.1. DJI Phantom 3 

2.1.1. Description 

The Phantom 3 (P3) is a Small Unmanned Aircraft System (sUAS). The aircraft's weight 

including battery is 1280g (2.82lbs). The dimensions of the P3 are 

28.9cmX28.9cmX18.5cm (LxWxH). The P3 is a multirotor aircraft consisting of four 

propellers driven by four independent brushless electrical motors. Electrical power is 

provided by an interchangeable Intelligent Flight Battery (PH3-4480), which powers the 

motors, camera, onboard flight controller and all other electric components. The P3 has 

the capability to move along the vertical and horizontal planes as well as hover in 

position. The P3 contains a Ground Positioning System (GPS) receiver as well as Visual 

Positioning technology that allows it to follow precise tracks both indoors (via visual 

positioning) as well as outdoors (via GPS). Attached to the bottom of the P3 is a 3-Axis 

gimbal containing a small High Definition (HD) camera. The camera is capable of 

recording 4K video as well as taking still images. In addition, the camera transmits a live 

video feed back to sUAS operator. The P3 is controlled by a hand held Remote 

Controller. The Remote Control operates in the frequency range between 2.400 GHz and 

2.483 GHz, and has a maximum transmission distance of 2km (outdoors and 

unobstructed). In addition to the remote controller, advanced settings and controls can be 

accessed via the DJI pilot app on a connected tablet. In the event the P3 loses 

communication or its GPS signal, it has the ability to return to a predetermined position 

within the Area of Operation. Both the P3 as well as the Remote Controller have been 

certified in compliance with part 15 or the FCC Rules. 

2.1.2. Specifications and Limitations 

Weight (including battery) ................. 1280 g 

Max Ascent Speed ........................... 5 m/s 

Max Descent Speed ......................... 3 m/s 

Max Speed .................................... 16 m/s (ATTI mode, no wind) 

Max Flight Altitude .......................... 6000 m 

Max Flight Time ............................. Approximately 23 minutes 

Operating Temperature Range ............ 0°C to 40°C 

GPS ........................................... GPS/GLONASS 

P3 Intelligent Flight Battery (PH3-4480 mAh-15.2V): 

Date: 5.25.2015 4 Revision: Original 
j 

1 

1 

Capacity ..................................... .4480 mAh 

Voltage ....................................... 15.2 V 

Battery Type ................................. LiPo 4s 

Energy ........................................ 68 Wh 

Net Weight ................................... 365 g 

Operating Temperature ..................... -l0°C to 40°C 

Max Charging Power ....................... 1 OOW 

Phantom 3 Remote Controller: 

Operating Frequency ...................... .2.400 GHz- 2.483 GHz 

Max Transmission Distance ............... 2 km (outdoors and unobstructed) 

Operating Temperature .................... 0°C to 40°C 

Battery ........................................ 6000 mAh LiPo 2S 

Transmitter Power (EIRP) ................. FCC: 20 dbm; CE: 16 dbm 

Working Voltage ............................ l.2 A@ 7.4 V 

A comprehensive list of specifications and limitations can be found in the DJI Phantom 3 

Quick Start Guide and DJI Phantom 3 User Manual. 

2.2. DJI Inspire 1 

2.2.1. Description 

The Phantom Inspire 1 (Inspire!) is a Small Unmanned Aircraft System (sUAS). The 

aircraft's weight including battery is 1935g (6.47lbs) and has a maximum weight 

including payload of3400g (7.49lbs). The dimensions ofthe Inspire! are 

43.8cmX45.lcmX30.1cm (LxWxH). The Inspire I is a multirotor aircraft consisting of 

four propellers driven by four independent brushless electrical motors. Electrical power is 

provided by an interchangeable Intelligent Flight Battery (TB4 7 or TB48), which powers 

the motors, camera, onboard flight controller and all other electric components. The 

Inspire I features retractable landing gear that can be raised in flight to provide 

unobstructed visibility of the onboard camera. The Inspire I has the capability to move 

along the vertical and horizontal planes as well as hover in position. The Inspire 1 

contains a Ground Positioning System (GPS) receiver as well as Visual Positioning 

technology that allows it to follow precise tracks both indoors (via visual positioning) as 

well as outdoors (via GPS). Attached to the bottom of the Inspire! is a ZENMUSE X3, 

3-Axis gimbal, containing a small High Definition (HD) camera. The camera is capable 

of recording 4K video as well as taking still images. In addition, the camera transmits a 

live video feed back to sUAS operator. The Inspire I is controlled by a hand held remote 

controller, and additionally a second remote controller can be used to operate the camera 

gimbal. The Remote Control operates in the frequency range between 2.400 GHz and 

2.483 GHz, and has a maximum transmission distance of 2km (outdoors and 

unobstructed). In addition to the remote controller, advanced settings and controls can be 

accessed via the DJI pilot app on a connected tablet. In the event the Inspire 1 loses 

communication or its GPS signal, it has the ability to return to a predetermined position 

within the Area of Operation. Both the Inspire! sUAS as well as the Remote Controller 

have been certified in compliance with part 15 or the FCC Rules. 

Date: 5.25.2015 5 Revision: Original 
2.2.2. Specifications and Limitations 

Weight (including battery) ................. 2935 g (3400 g max) 

Max Ascent Speed ........................... 5 m/s 

Max Descent Speed ........................ .4 m/s 

Max Speed ................................... .22 m/s (ATTI mode, no wind) 

Max Flight Altitude ......................... .4500 m 

Max Flight Time ............................. Approximately 18 minutes 

Operating Temperature Range ............ -10°C to 40°C 

GPS ........................................... GPS/GLONASS 

Inspire1 Intelligent Flight Battery (Model:TB47): 

Capacity ..................................... .4500 mAh 

Voltage ....................................... 22.2 V 

Battery Type ................................. LiPo 6s High voltage Battery 

Energy ........................................ 99.9 Wh 

Net Weight ................................... 570 g 

Operating Temperature ..................... -10°C to 40°C 

Max Charging Power. ..................... .180W 

Inspire1 Intelligent Flight Battery (Model:TB48, Optional): 

Capacity ...................................... 5700 mAh 

Voltage ....................................... 22.8 V 

Battery Type ................................. LiPo 6s High voltage Battery 

Energy ........................................ 129.6 Wh 

Net Weight ................................... 670 g 

Operating Temperature ..................... -10°C to 40°C 

Max Charging Power. ...................... 180W 

Inspire 1 Remote Controller: 

Operating Frequency ...................... .2.400 GHz- 2.483 GHz 

Max Transmission Distance ............... 2 km (outdoors and unobstructed) 

Operating Temperature .................... 0°C to 40°C 

Battery ........................................ 6000 mAh LiPo 2S 

Transmitter Power (EIRP) ................. FCC: 20 dbm; CE: 16 dbm 

Working Voltage ............................ 1.2 A@ 7.4 V 

A comprehensive list of specifications and limitations can be found in the DJI Inspire 1 

Quick Start Guide and DJI Inspire 1 User Manual. 

3. Pilot In Command 

3.1. Responsibilities 

The Pilot in Command (PIC) has full Operational Control over the flight mission. The 

PIC has the ability to initiate as well as terminate a flight and must do so in the event of 

unpredicted obstacles or emergencies. Each PIC must meet all qualifications experience 

requirements described in sections 3.2 and 3.3 of this GOM. Additionally the PIC is 

Date: 5.25.2015 6 Revision: Original 
responsible for being familiar with and following all procedures, guidelines, and safety 

bulletins established by the UAS Manufacturer. The PIC will adhere to all applicable 

F ARs, and requirements set forth in all FAA exemption documents. 

3.2. Qualifications 

Each 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. 

3.3. Experience 

All PICs must meet the following minimum level of flight experience: 

1. The PIC must have accumulated and logged a minimum of 100 flight cycles and 

25 hours oftotal time as a UAS pilot with at least 10 hours logged as a UAS pilot 

with a similar UAS type (single-blade or multi-rotor) and 5 hours in the make and 

model of U AS aircraft to be flown. 

2. Within the preceding 90 days, the PIC must have accumulated and logged a 

minimum of five Flight Cycles (as defined in the glossary) as UAS pilot with the 

make and model ofUAS to be utilized as well as performed three takeoffs and 

landings. 

The PIC must also meet the flight review requirements specified in 14 CFR Part 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate. 

3.4. Training 

Flight training for the purposes of experience building and proficiency will be conducted 

during dedicated training sessions. During such training sessions, all persons not essential 

for flight operations are considered nonparticipants, and the PIC must operate the UAS 

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

4. Visual Observer 

4.1. Responsibilities 

All persons serving as a Visual Observer (VO) will meet the qualifications and 

experience requirements of sections 4.2 and 4.3 of this GOM. The visual observer (VO) 

is responsible for assisting the PIC in the duties associated with collision avoidance. The 

VO serves as a second set of eyes and will supply their total and undivided attention to 

the UAS and its surroundings. The VO will remain near the PIC and will use voice to 

communicate. The VO will exercise Crew Resource Management (CRM) and aid to 

insure the safety of the operation and its participants. Additionally the VO will help the 

Date: 5.25.2015 7 Revision: Original 
PIC insure that: 

1. The UAS remains within Visual Line of Sight range (VLOS). 

2. The Area Of Operation remains sterile. 

3. The following are identified and avoided: Non-participating aircraft, clouds, 

obstructions and terrain. 

4.2. Qualifications 

Each VO must hold at a minimum a drivers license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or a Federal government. This license 

requirement will serve to insure that the V 0 possesses adequate health and vision to 

perform the functions required. 

4.3. Experience 

Prior to acting as aVO during a Flight Mission, each VO will be required to read the 

Visual Observer Briefing Guide in Appendix A to insure they understand their role and 

posses the required qualifications. 

5. Maintenance 

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

a condition for safe operation. 

5.1. Pre-Flight Inspection 

Prior to each flight, the PIC must conduct a pre-flight inspection and determine the U AS 

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 U AS is found to 

be in a condition for safe flight. 

The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

5.2. Functional Test Flights 

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. Functional test flights may 

only be conducted by a PIC with aVO 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. 

Date: 5.25.2015 8 Revision: Original 
6. Operations 

7.1. Overview 

The operator uses UAS to conduct aerial filming and photography. When engaging in 

commercial operations, these flights will be referred to as Flight Missions. 

6.2. Area of Operations 

Prior to each flight mission an area of operations must be established. The PIC will 

designate both a lateral area over the ground as well as a vertical area in which the U AS 

will be operated. Prominent landmarks should be picked in advance to mark the lateral 

boundaries, and a height above ground level should be used to mark the vertical 

boundaries. Prior to each flight mission, the PIC will insure that the designated area of 

operation meets the following requirements: 

-The area falls within the approved Certificate of Operation (COA). 

-Permission has been obtained from all appropriate entities including territorial, 

state, county or city jurisdictions, local law enforcement, fire or other appropriate 

governmental agencies. 

- And finally that the area is, and will remain a sterile area. 

6.3. Preflight Briefing 

Prior to each flight mission, the PIC will conduct a preflight briefing. All pilots, VOs, and 

other participants are required to attend the preflight briefing. The following items are 

mandatory briefing items. To insure FAA and GOM compliance, the PIC will use the 

preflight checklist below. 

PREFLIGHT BRIEFING: 

-Flight Mission objective: Define the mission for the day's operation. 

-Assign/verify roles of all participants: 

-Weather: Insure the Mission is in compliance with section 7 ofthe GOM. 

-Area of Operation: Insure compliance with COA as well as any local rules and 

regulations. Verify all permission forms, as well as required permits are complete. 

Additionally insure that the Area of Operation is sterile. 

-Review contingency plans in case of the need to abort the mission. 

-Verify the UAS meets all maintenance requirements of section 5 ofthe GOM. 

-Questions? 

6.4. UAS Checklist 

In addition to the preflight briefing, the following UAS checklist must be referenced prior 

to flight. 

UAS PREFLIGHT CHECKLIST: 

1. Transmitter firmware up to date 

2. UAS firmware up to date 

3. Inspect UAS for obvious defects 

4. Batteries fully charged 

Date: 5.25.2015 9 Revision: Original 
5. Propellers tightened and/or locked 

6. ND Filter needed? Yes/No 

7. SD card in camera, SD card formatted if needed 

8. Monitor brightness set to high and hood installed 

9. Transmitter antenna up 

10. Transmitter turned on 

11. U AS turned on 

12. UAS calibrated 

13. UAS placed in safe launce and recovery position 

14. Area clear of non participants 

FLIGHT: 

1. Hit record on camera? 

2. Warn bystanders of imminent takeoff 

3. Hover close for 20 seconds. Look/Listen for defects 

4. Confirm expected stick operation 

5. Monitor battery power 

6. Keep visual line of sight with UAS 

7. Monitor signal strength 

6.5. RESTRICTIONS 

All operations conducted by the operator will adhere to the following restrictions: 

1. Minimum crew will consist of a PIC and a Visual Observer (VO). 

2. All operations will be conducted under daytime VFR conditions. 

3. Flights will be operated within Visual Line Of Sight (VLOS) ofthe PIC and VO. 

4. If the PIC or VO lose sight of the UAS, the PIC will immediately active the 

"return to home" function of the aircraft. 

5. Pilot in Command and Visual Observer will at all times be able to communicate 

by voice. 

6. Prior to flight the PIC will insure there is enough available power for the UAS to 

conduct the intended operation and to operate thereafter for at least five minutes 

or the reserve power recommended by the manufacturer whichever is if greater. 

7. Flights will be operated at an altitude of no more than 400 feet AGL. 

8. 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 UAS and/or debris in the event of an accident. The 

operator will ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

Date: 5.25.2015 10 Revision: Original 
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. 

9. The UAS will operate only within a confined "Sterile Area" as defined in the 

GOM. 

10. In accordance with the GOM a briefing will be conducted in regard to the planned 

UAS operations prior to each day's missions. It will be mandatory that all 

personnel who will be performing duties within the boundaries of the sterile area 

be present for this briefing. 

11. In the event of an accident involving a Film and Flight UAS, the PIC will 

immediately cease operations and report the accident to the NTSB and AFS-80. 

12. 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. 

13. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC, the VO, or the UAS. 

14. Procedures have been established in Film and Flight's GOM to contact ATC prior 

to operating in the National Airspace System (NAS). 

7. Weather 

Prior to each flight, the PIC will check the weather to insure that current and forecast 

conditions will allow for the safe operation of the UAS. Approved sources of weather 

include aviationweather.gov, WSI Pilotbrief, and any other source that would provide an 

equivalent level of weather information. The following conditions present a danger to 

operations and prohibit the initiation of a flight mission: 

Wind gusts that exceed the UAS's recommended limits. 

Rain 

Snow 

Fog (or other atmospheric condition lowering the visibility below 3sm). 

Additionally the PIC will insure that the proposed operation will allow the UAS to 

remain 500 below and 2000 feet horizontally from all clouds. 

At any time during operation ifthe weather deteriorates, the PIC will land the UAS in an 

expeditious manner while keeping in mind the safety of persons and property. 

Date: 5.25.2015 11 Revision: Original 
8. Accident/Incident Reporting: 

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) IA W procedures contained on the 

NTSB website: www.ntsb.gov. 

9. Glossary 

Area of Operation: The designated area in which the flight mission will take place. This 

includes the lateral as well as vertical space in which the planned flight is to take place. 

Flight Cycle: A flight beginning with a fully charged battery and ending when the flight 

reserve power has been reached. 

National Airspace System (NAS): The common network of U.S. airspace; air 

navigation facilities, equipment and services, airports or landing areas; aeronautical 

charts, information and services; rules, regulations and procedures, technical information, 

and manpower and material. 

Non-Participants: Persons and property that have agreed to participate in the flight 

mission. 

Operational Control: With respect to a flight, means the exercise of authority over 

initiating, conducting or terminating a flight (14 CFR § 1.1 ). 

Participants: Persons and property that have agreed to participate in a flight mission. 

Pilot in Command (PIC): The person who has final authority and responsibility for the 

operation and safety of the flight; has been designated as PIC before or during the flight; 

and holds the appropriate category class and type rating, if appropriate, for the conduct of 

the flight (14 CFR § 1.1 ). 

Sterile Area: An area that is clear and free from all nonparticipants. An area of operation 

will only be considered sterile when it is determined that the UAS operation will be able 

to comply with restrictions listed under section 6.5.8 of this GOM. 

Unmanned Aircraft System (UAS): An unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned aircraft, 

that are required for the pilot in command to operate safely and efficiently in the national 

airspace system (P.L. 112-95, Section 331). 

Date: 5.25.2015 12 Revision: Original 
UAS Certificate of Waiver or Authorization (COA): An authorization issued by the 

Air Traffic Organization to an operator for a specific unmanned aircraft activity. A COA 

is required prior to each flight in the NAS and must be obtained for the Area of Operation 

to be utilized. 

Visual Line of Sight (VLOS): Unaided (corrective lenses and/or sunglasses excepted) 

visual contact between a pilot in command and an unmanned aircraft sufficient to 

maintain safe operational control of the aircraft, know its location, and be able to scan the 

airspace in which it is operating to see and avoid other air traffic or objects aloft or on the 

ground. 

Date: 5.25.2015 13 Revision: Original 
Appendix A 

A.l Film and Flight Permission Acquisition Form 

In signing this form, I am giving the pilots of Film and Flight permission to operate their 

UAS at less than 500 feet from property, or in some jurisdiction in which I am 

responsible for or affiliated with, for the purpose of aerial filming. 

Name: 

Title: 

Basis of Authority to Grant Permission: 

Location: 

Date of Operation: 

Signature Date ------------------------------------ -----------------

Film and Flight Representative Receiving Permission 

Date: 5.25.2015 14 Revision: Original 
j 

I 

A.2 Visual Observer Briefing Guide 

Film and Flight is pleased to have you serving as a Visual Observer on todays flight 

mission. This guide will serve as your Visual Observer familiarization and briefing guide, 

so please read it carefully. We are happy to provide additional information should you 

have any questions. 

As a Visual Observer, your responsibility is to assist the PIC (Pilot In Command) in their 

duties associated with collision avoidance. In other words, you are going to serve as a 

second set of eyes and make sure the pilot doesn't hit anything! This includes, but is not 

limited to, avoidance of other traffic (aircraft), clouds, obstructions and terrain. 

The only requirement to serve as a Visual Observer is that you possess a current driver's 

license and have the ability to visually observe the unmanned aircraft in flight 

(Prescription glasses or contacts must be warn if required). Additionally during 

operations in bright sunlight we highly recommend that sunglasses are warn. 

All we ask of you during the operation is that you provide your full and undivided 

attention to watching the unmanned aircraft. Your participation is very important so we 

ask that you refrain from all unrelated distractions during the flight mission. 

If during the operation you see any obstacles (other aircraft, clouds, buildings, terrain, 

etc.), immediately inform the pilot using the following format: 

a) Obstacle description 

b) Obstacles position in relation to the unmanned aircraft (ahead, to the left, to the 

right, behind.) 

Example: if you see a tall tree that the unmanned aircraft is headed towards, call out: 

"Tall tree (obstacle description), straight ahead (obstacle position)!" 

Please feel free to speak up at any time if you have any questions or concerns regarding 

the operation. You are part of the team, and there is no such thing as a silly question. 

We hope you enjoy the experience, and thank you for your participation in todays flight 

mission! 

Date: 5.25.2015 15 Revision: Original 
A.3 Revision Letter 

Rev# Section Page Action Remarks Initials 

R • Remove and Replace D • Delete and Destroy N • Insert New Page 

Manual Serial# Issued To ------------------ ---------------

Revised By --------------------------

Date 

This form must be returned to the Chief Pilot no later than -------------

Date: 5.25.2015 16 Revision: Original