AprilS, 2015 

Updated Information July 9, 2015 

FAA 

Docket Management Facility 

U.S. Department of Transportation 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

NAME AND ADDRESS OF PETITIONER 

Above Orange County 

Attn: Michael Hull 

21580 Yorba Linda Blvd. 

Yorba Linda, CA 92887 

714.906.0761 

aboveorangecounty@gmail.com 

www.aboveorangecounty.com 
In addition to what was submitted previously on April 8, 2015, 

below is a further explanation of Above Orange County's 

Petition for Exemption 14 CFR 11.81 

Your name and mailing address. You may include other 

contact information such as a fax number, telephone number, or email address; 

Name: Michael Hull/Above Orange County 

Address: 21580 Yorba Linda Blvd. Yorba Linda, CA 92887 

Phone: 714-906-0761 

Email: aboveorangecounty@gmail.com 

The specific section or sections of 14 CFR from which you seek an exemption; 

14CFR: parts 21; 45.23{b); 45.29; 61.113(a); 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 

91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b). 

The extent of relief you seek and the reason you seek the relief; 

Above Orange County/Michael Hull respectfully submits this petition seeking relief from any currently 

applicable federal aviation regulations FARs pertaining to UAS and operating to prevent Above Orange 

County from commercial photographic flight operations within the U.S. National Airspace System. Above 

Orange County's small and lightweight UAS, not exceeding 71bs, meet the definition of "small 

unmanned aircraft". Above Orange County's lightweight UAS are in line with the Reform Act and would 

be good candidates for exemption. I am a skilled operator with over 3 years of experience without a 

single incident, big or small, and am simply petitioning for an exemption to provide a commercial service 

to private land owners and companies who wish to obtain and capture aerial photos & videos of said 

property for purposes including real estate listings and as a marketing tool for their business. I would 

like to be able to accept payment for these services therefore making this a commercial use of UAS. We 

understand that the FAA is committed to safely integrating UAS into national airspace and believe that 

Above Orange County would be a strong candidate for exemption because of our experience level, 

commitment to safe operating procedures, and desire to further educate the public about safe use of 

UAS by way of example. Safety is Above Orange County's primary focus and we request you also 

consider the following: 

1. The size and weight of our UAS are under 7 lbs 

2. Our UAS travel at low speeds always less than 20 knots 

3. Our UAS are outfitted with the most up to date safety and fail safe features 

4. The operator for Above Orange County is a very experienced UAS operator 

How your request would benefit the public as a whole; 

My request benefits the public as a whole by providing an opportunity for small business owners, real 

estate agents, and others who wish to document their land or property to take advantage of technology 
that now exists in the form of UAS's and allows them to do so by using an experienced pilot in command 

that understands how to safely operate such technology. 

The impact of an exemption for Above Orange County to use UAS will reach far beyond the company 

and the clients that we serve. Granting an exemption for Above Orange County would allow the 

company to immediately transition into providing services that are safer, more environmentally friendly, 

and economically accessible. 

As highlighted throughout our petition, Above Orange County believes the substitution of small UAS in 

place of traditional aircraft to accomplish the same objectives provide a large number of safety benefits. 

The UAS are considerably safer 

Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule; 

Above Orange County is fully capable of integrating UAS in a manner that will not adversely affect 

safety. We have also put forth that integrating UAS for the purpose of obtaining real estate photos and 

videography not only meets but exceeds the current level of safety offered through traditional manned 

aircraft. 

The UAS we plan to use are the DJI Phantom 3 Professional & OJ I Inspire 1. Both devices are commonly 

used and have the most advanced safety features available. Both UAS are small and the design, 

operational characteristics and specs for each type are attached as separate documents. 

Michael Hull will be the sole operator. Mr. Hull has extensive experience operating UAS. Along with 

several other types of quadcopters, he has owned and operated DJI UAS and has accumulated hundreds 

of hours of flight time during recreational flights since the technology first became available years ago. 

Mr. Hull will be furthering his education by completing flight training in order to obtain a sport pilot 

certificate. Mr. Hull will always be accompanied by a spotter who will act as a visual observer. These 

spotters are fully trained and are committed to ensuring safe and productive UAS operations. 

Above Orange County will incorporate thorough safety policies and operating procedures. Both UAS 

listen above will be flown in adherence to supplemental information attached entitled "Conditions & 

Limitations" along with the following restrictions: 

a. The operator will obtain a sport pilot certificate along with 35 hours total flight time with each 

UAS for commercial purposes. 

b. The operator will maintain a valid U.S. driver's license 

c. No flight will exceed 400ft AGL 

d. Airspeed of UAS will not exceed 20 knots 

e. All flights will be restricted to 7 lbs gross weight 

f. All flight conducted will have a pilot in command and a spotter 

g. UAS will be operated within visual line of sight at all times 

h. UAS will be operated on private property with exclusive permission of the owner 

i. UAS will not be operated over any groups or persons other than the operator and spotter 
j. A thorough inspection of the UAS's operational readiness will be conducted before each and 

every flight in accordance to manufacturer's recommendations. All recommendations can be 

found in attached documents 

k. A flight plan will be drafted before each operation and reviewed by both operator and spotter 

I. The operator and spotter will conduct an area sweep where each operation is to be conducted 

to ensure a safe environment 

m. The operator and spotter will have on their persons the necessary documents needed to verify 

legality of operation 

n. The operator will keep flight records in order to stay in line with manufacturer's 

recommendations for maintenance and replacement standards 

o. UAS will not be operated within 5 nautical miles of an airport 

p. UAS will not be operated less than 500 feet below or less than 200 feet horizontally from a cloud 

q. Operator will abort any flight operation where conditions become unpredictable or in the case 

of an emergency 

r. UAS will not operate without a clear connection to GPS stability 

s. All manuals for each UAS being operated will be available and on hand to the operator and 

spotter any time the UAS is operating 

t. The operator will operate the UAS from a stable position and will not operate from a moving 

vehicle or while traversing hazardous terrain 

u. Always keep aircraft in sight and under control 

v. Always keep people and pets at least 35 feet away when the battery is connected 

w. Keep children out of vicinity of this product at all times 

x. Always use fully charged batteries 

y. Always keep transmitter powered on while aircraft is powered 

z. Always remove batteries before disassembly 

aa. Always keep moving parts clean 

bb. Always keep all parts dry 

cc. Always let parts cool before touching 

dd. Always have a first aid kit on hand, including fire extinguisher 

ee. Never operate UAS with damaged wiring 

ff. Never touch moving parts 

A summary we can publish in the Federal Register, stating: 

Pursuant to 14 CFR part 11, the following summary is provided for publication in the Federal register: 

Above Orange County seeks an exemption from the following: 

14CFR: parts 21; 45.23(b); 45.29; 61.113(a); 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 

91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b). 

An exemption for Above Orange County will allow commercial operations of UAS under strictly 

controlled conditions for the purpose of real estate photography, videography, and marketing. The 

operator, Michael Hull, will obtain a sport pilot certificate and will be accompanied by a spotter. The 
operator for Above Orange County plans to use the DJI Phantom 3 Professional and the DJI Inspire 1. 

Both UAS are outfitted with numerous safety features and are commonly used. They are both small, 

lightweight, and pose minimal risks to property and people. The UAS's physical characteristics and fail 

safe features combined with Above Orange County's commitment to safe operating procedures and 

policies meets or exceeds the level of safety commonly accepted with traditional manned aircraft. 

An exemption as requested in this petition should be granted and will allow Above Orange County the 

ability to impact safety, the environment, and the economy of society as a whole. 

Any additional information, views, or arguments available to support your request; 

Above Orange County is fully aware of the pre-flight safety checks and procedures implicated in the 

operation manual for both UAS's we plan on using and intend to implement pre-flight safety checks and 

utilize the safety technology provided with this unit. I intend to only fly in non-populated, residential, or 

rural areas and stay clear of all utility lies, etc. We intend to be fully aware of my surroundings at all 

times and to only fly the UAS within a visual line of sight and only in Visual Flight Conditions. We 

understand and will comply with all the health and safety regulations for UAS and Michael Hull will be 

the only operator under this exemption. 

If you want to exercise the privileges of your exemption outside the United States, you must state the 

reason. 

We do not seek to exercise the privileges of an exemption outside the United States. 

I appreciate the FAA's consideration of the petition for this exemption. 

Michael Hull/Above Orange County 

21580 Yorba Linda Blvd. Yorba Linda, CA 92887 

714-906-0761 

aboveorangecounty@gmail.com 
7/1612015 Phantom 3- Specs I DJI 

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Aircraft Weight (Including Battery And Propellers) 1280g 

Diagonal Size (Including Propellers) 590mm 

Max Ascent Speed 5m/s 

Max Descent Speed 3m/s 

Hover Accuracy • Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

• Horizontal: +/- 1.5 m 

Max Speed 16 m/s (A TTl mode, no wind) 

Max Altitude Above Sea Level 6000m 

Operating Temperature O'Cto40'C 

GPS Mode GPS/GLONASS 

Camera Sensor Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

Lens FOV 94' 20 mm (35 mm format equivalent) f/2.8, focus at ~ 

ISO Range 100-3200 (video) 100-1600 (photo) 

Shutter Speed 8s -1/SOOOs 

Image Max Size 4000x 3000 

Still Photography Modes • Single Shot 

• Burst Shooting: 3/5/7 shots 

• Auto Exposure Bracketing (AEB): 3/5 

• Bracketed Frames at 0. 7EV Bias 

• Time-lapse 

Video Recording Modes Phantom 3 Professional 

• UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

• FHD: 1920x1080p 24/25/30/48/50/60 

• HD: 1280x720p 24/25/30/48/50/60 

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Supported SO Card Types 

Max Bitrate Of Video Storage 

Supported File Formats 

Operating Temperature 

Gimbal Controllable Range 

Stabilization 

Vision Positioning Max Velocity 

Altitude Range 

Operating Range 

Operating Environment 

Remote Controller Operating Frequency 

Max Distance 

Video Output Port 

Operating Temperature 

Battery 

Mobile Device Holder 

Receiver Sensitivity (1%PER) 

Transmitter Power (EIRP) 

Working Voltage 

Battery Charger Voltage 

Rated Power 

http://www.dji .com/product/phantom-3/spec 

Phantom 3- Specs I DJI 

Phantom 3 Advanced 

• FHD: 1920x1080p 24/25/30/48/50/60 

• HD: 1280x720p 24/25/30/48/50/60 

Micro SD 

Max capacity: 64 GB. Class 10 or UHS-1 rating required 

Phantom 3 Professional 

60 Mbps 

Phantom 3 Advanced 

40 Mbps 

• FAT32/exFAT 

• Photo: JPEG, DNG 

• Video: MP4, MOV (MPEG-4 AVC/H.264) 

O"Cto40"C 

Pitch -90" to +30" 

3-axis (pitch, roll, yaw) 

Less than 8 m/s (when 2 m above ground) 

30 cm-300 em 

30 cm-300 em 

Surface with clear pattern and adequate lighting (Lux > 15) 

2.400 GHz-2.483 GHz 

2000m (outdoors and unobstructed) 

USB 

O"C-40"C 

6000 mAh LiPo 2S 

For tablet or phone 

-101 dBm ±2 dBm 

• FCC: 20 dBm 

• CE: 16 dBm 

1.2A@7.4V 

17.4 v 

Phantom 3 Professional 

• 100W 

213 
7/1612015 Phantom 3- Specs 1 DJI 

., 

Intelligent Flight Battery Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

Max Flight Time 

Operating Temperature 

Max Charging Power 

App I Live View MobileApp 

EIRP 

Live View Working Frequency 

Live View Quality 

Latency 

Required Operating Systems 

Recommended Devices 

Phantom 3 Advanced 

• 57W 

4480 mAh 

15.2V 

UPo4S 

68Wh 

365 g 

Approximately 23 minutes 

-10oC to 40°C 

100W 

DJI Pilot 

100mW 

2.4GHz ISM 

720P @ 30fps (depending on conditions and mobile device) 

220ms (depending on conditions and mobile device) 

• iOS 8.0 or later 

• Android 4.1.2 or later 

• iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air V\11-Fi + Cellr 

2, iPad mini 2 V\11-Fi + Cellular, iPad Air 2, iPad Air 2 V\11-Fi + Cellular, iP; 

iPad mini 3 V\11-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 

6 Plus 

• Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, GOO! 

Mi 3, Nubia Z7 mini 

• *Support for additional Android devices available as testing and developr 

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Aircraft Model 

Weight (Battery Included) 

Hovering Accuracy (GPS Mode) 

Max Angular Velocity 

Max Tilt Angle 

Max Ascent Speed 

Max Descent Speed 

Max Speed 

Max Flight Altitude 

Mu Wind Speed Resistance 

Max Flight Time 

Motor Model 

Propeller Model 

Indoor Hovering 

Operating Temperature Range 

Diagonal Distance 

Dimensions 

Gimbal Model 

Output Power (With Camera) 

Operating Current 

http://www.dji .com/product/inspire-1/spec 

Buv Now (Htip:liStote.Dii.Corn/Productllnspire-i ?F10m~l1r:v now) 

T600 

2935g 

Vertical: 0.5 m 

Horizontal: 2.5 m 

Pitch: 300°/s 

Yaw. 150°/S 

35° 

5m/s 

4m/s 

22 m/s (A Til mode, no wind) 

4500m 

10m/s 

Approximately 18 minutes 

DJI 3510 

DJI 1345 

Enabled by default 

-10° to 40° c 

559 to 581 mm 

438x451x301 mm 

ZENMUSEX3 

Static: 9W 

In Motion: 11 W 

Station: 750 rnA 

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Angular Vibration Range 

Mounting 

Controllable Range 

Mechanical Range 

Max Controllable Speed 

Camera Name 

Model 

Total Pixels 

Effective Pixels 

Image Max Size 

ISO Range 

Electronic Shutter Speed 

FOV (Field Of View) 

CMOS 

Lens 

Still Photography Modes 

Video Recording Modes 

Max Bitrate Of Video Storage 

Supported File Formats 

Supported SO Card Types 

Operating Temperature Range 

Remote Controller Name 

Operating Frequency 

Transmitting Distance (Outdoor And Unobstructed) 

http://www.dji.com/productlinspire-1/spec 

Motion: 900 rnA 

±O.o3· 

Detachable 

Pitch: -9o• to +3o· 

Pan: ±320• 

Pitch: -125• to +45• 

Pan: ±330• 

Pitch: 120•/s 

Pan: 18o•ts 

X3 

FC350 

12.76M 

12.4M 

4000x3000 

100-3200 (video) 

100-1600 (photo) 

8s- 1/8000s 

Sony EXMOR 1/2.3" 

20mm (35mm fonnat equivalent)f/2.8 focus at " 

9 Elements in 9 groups 

Anti-distortion 

Single shoot 

Burst shooting: 3/5/7 frames 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

60 Mbps 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Micro SD 

Max capacity: 64GB. Class 10 or UHS-1 rating required. 

C1 

922.7-927.7 MHz (Japan Only) 

5.725-5.825 GHz 

2.400-2.483 GHz 

2km 

2/4 
7/1612015 

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EIRP 

Video Output Port 

Power Supply 

Charging 

Dual User Capability 

Mobile Device Holder 

Max Mobile Device Width 

Output Power 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Battery 

Charger Model 

Voltage 

Rated Power 

Battery (Standard) Name 

Model 

Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Max Charging Power 

http://www .dji .com/productlinspire-1/spec 

Inspire 1 -Specs I DJI 

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G 

USB, mini-HDMI 

Built-in battery 

DJI charger 

Host-and-81ave connection 

Tablet or Phone 

170mm 

9W 

-10• to 40• C 

Less than 3 months: -20• to 45• C 

More than 3 months: 22• to 28' C 

0-40' c 

6000 mAh LiPo 2S 

A14-100P1A 

26.3V 

100W 

Intelligent Flight Battery 

TB47 

4500 mAh 

22.2V 

LiPo 6S High voltage battery 

99.9Wh 

570 g 

-10· to 40• c 

Less than 3 months: -20• to 45• C 

More than 3 months: 22• C to 28. C 

o• to4o· c 

180W 

314 
7/16/2015 

Battery (Optional) Name 

Model 

Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Max Charging Power 

Vision Positioning Velocity Range 

Altitude Range 

Operating Environment 

Operating Range 

OJI Pilot App Mobile Device System Requirements 

Supported Mobile Devices 

Inspire 1 - Specs I DJI 

Intelligent Flight Battery 

TB48 

5700 mAh 

22.8V 

LiPo 6S 

129.96 Vllh 

670 g 

-10° to 40° C 

Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

oo to 40° C 

180W 

Below 8 m/s (2 m above ground) 

5-500 em 

Brtghtly lit (lux> 15) patterned surfaces 

0-250 em 

iOS 8.0 or later 

Android 4.1.2 or later 

• Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi 

iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + CeiiL 

3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPh 

iPhone 6 Plus. 

• Samsung 55, Note 3, Sony Xperta Z3, Google Nexus 711, Google Nexus! 

Z7 mini 

•support for additional Android devices available as testing and developmer 

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Conditions and Limitations 

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 Phantom 

2 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 

not 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) ofthe 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, 

the conditions and limitations herein take precedence and must be followed. 

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

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 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. 

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. lfthe 

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

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

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

operated under thi& exemption, including evasive and emergency 1Jlaneuvers 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 CPR§ 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. U AS 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 co A 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 U AS loses communications or loses its GPS signal, the U A must return to a 

pre-determined location within the private or controlle&-access property. 

19. The PIC must abort the flight in the event ofunpredicted 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 A TO-issued CO A. 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 CO A. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 4 7, 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 an4 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. 

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 ofthe person responsible for the on-scene operation of 

the UAS; 
d. Make, model, and serial or N-Number ofUAS to be used; 

e. Name and certificate number ofUAS 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 ofthe 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.