Thomas Michael Haley 

725 Kapiolani Blvd. c-311 

Honolulu, Hawaii 96813 

.~! ,-: .• l :..""', ., j • ' I' /~\ ; i : t! R L 

U.S. Department ofTransportafiOn 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter ofthe petition of DOUGLAS 

TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matterofthe petition of ADVANCED 

AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the petition of FLYING CAM INC 

4) FAA Exemption No. 11062 Regulatory Docket No. FAA-2014·0352 in the matter of the petition of ASTRAEUS AERIAL 

5) inspire 1 Pro User Manuals- http:/Jwww.dji.comfproductllnspire-1-pro-and-raw/info#downloads 

6) ShotoverU1 information • http:/fwww.shotover.com/u1 

7) OJI Phantom 3 Professional manuals· http:/lwww.dji.com/productlphantom-3/download 

8) Alta Freefly -

9) G30 Robotics Solo- https:/13dr.comlwp--contentluploads/2016/01/v8_01_05_16.pdf 

Attachment 

1) Motion Picture and Television Operations Manual for Thomas Michael Haley 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, Thomas MiChael Haley referred to hereafter as 

the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations 

§§ 61.113(a); 61.113(b); 91.119 (b}&(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 91.417(a)&(b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) for the purposes of aerial data collection, closed set cinematography, and other flight 

operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within 

the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request 

of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and 

raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-4. 
The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a SPORT 

PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any 

conditions as set forth and in a similar fashion to the previously granted exemptions. 

91.119(b) & (c) As discussed in Reference 1, Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential 

persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or 

exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner requests 

waiver for this condition to allow reasonable and responsible operations in developed areas as required. As 

discussed in reference 4 Exemption 11 062 (ASTRAEUS AERIAL) The petitioner additionally request exemption to 

conduct "Closed set" cinematography for the purpose of scripted, filming for the motion picture and television 

industry. Petitioner proposes operations in a "sterile environment" of closed-set motion-picture filming. In this 

controlled environment, their operations will remain within visual line of sight (VLOS) and below 400 feet AGL. 

Petitioner has attached a copy of a proposed Motion picture and television operations manual (Attachment 1) 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not 

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has 

been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 

5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, 

and 1 0673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA 

batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents 

discusses procedures regarding remaining battery power management. Those documents contain a condition in 

which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations 

on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum 

power reserve for flight in daytime VFR conditions was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS 

TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance 

with the operating documents. The FAA found that adherence to the petitioner's operating documents and the 

conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, 

were sufficient to ensure that safety would not be adversely affected. 

----·-·- 
Conclusion 

The petitioner is requesting this exemption for the purposes of aerial data collection and closed set 

cinematography. The reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities 

as they may arise in the future without the long turnaround time associated with additional exemptions. The 

petitioner's business model is based on the idea of offering ad hoc small UAS services to individuals or companies 

who wish to employ these services as a safe, effective, and legal option to enhance their business. The primary 

purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance. 

The petitioner is an individual with numerous years of experience in general aviation and holds an airman certificate, 

PRIVATE PILOT, as well as current FAA medical certificate. 

Respectfully submiHed, 

/ltoM "'- AA ){;. fy 

Thomas Michael Haley 
The sUAS 

DJI Inspire 1 Pro/Raw 
OJI Phantom 3 professional 

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PHANTOM3 
Working .Voltage 
Alta Freefly 

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. 

DIMENSIONS 

UNFOLDED 

Diameter 

Height (to base of TITH} 

FOLDED 

Pia meter 

Height (to base of TITH) 

1126 mm 

220mm 

550mm 

220mm 
fROPf;LLERS 

Material 

fropeller Orientation 

Propeller Type 

BATTERY 

Nomjnal Battery Voltage 

Maximum Battery Size 

Maximum Battery Quantity 

Battery Connectors 

WEIGHTS 

Maximum Gross for Takeoff! 

Maximum Useful Load& 

Maximum Payload~ 

Typical Standard Empty Weight 

Carbon fiber with balsa core 

(3) cw and (3) ccw erops 

18 x 6 Folding 

6S /22.2V 

240x 180x80 mm 

2 Battery facks (Parallel) 

2x EC5 (Parallel) 

13.6 kg (30.0 lbs) 

9.1 kg (20.0 lb§) 

6.8 kg (15.0 lbs) 

4.5 kg (10.0 lbs) 
FLIGHT CONTROLLER 

Modtl Name 

Flight Modes 

Height Hold 

Position Mode 

Return-To-Home 

Auto-land 

Supported Inputs 

Supported Radios 

DSMX. DSM2 (Spektrum/JR) 

PPM. PPM Invert, PPM Graupner 

Supported Radio Controller 

Telemetry Systems 

LIGHtiNG AND INDICAIION 

Orientation Lights 

Orientation Light Locations 

Orientation Light Color 

Freefly Synapse Flight Controller 

Manual 

DSMX. DSM2. S.Bus, S.Bus 2. PPM, FPV 

SDYideo 

Futaba S.Bus & S.Bus 2 

Futaba w/built-in voltage sense port 

3 Watt RGB LEOs 

Outboard on Soom Ends 

Red. Yellow, Blue. Green, White 
Shotover U1 

Shotover U1 

WEIGHT Empty - 1 0=5kg (231bs) 

MAXIMUM WEIGHT - LESS THAN 55 lbs 

FLIGHT TIME 9-22 Minutes 

U1 SYSTEM SPECIFICATIONS POWER 12S 100 Amps Max Draw (at 44V) 

ENVIRONMENTAL Operating temperature 

.. 2Q to +50 degrees oc (=4 to 122 degrees 08) 
Payload capacity: 1.11bs. (500 g) 

Cruise speed: 5.7 mph (2.5 m/s) 

Maximum speed: 55 mph (25.5 m/s) 

Maximum climb rate: 11 mph (5.0 m/s) 

Maximum descent rate: 5.5 mph (2.5 m/s) 

Headwind limitation: 25 mph (11 m/s) 

Crosswind limitation: 25 mph (11 m/s) 

Camera: Streaming video compatible with GoPro® HERO 3. 3+ or 4 Full 

compatibility with GoPro® HERO 4 Solo app compatibility: iOS 8.0 or later I 

Android 4.3 or later 

Operating temperature: 32° F - 113° F (0° C - 45° C) 

Operating relative humidity: 0-85% RH 

*Flight time varies with payload. wind conditions. elevation. temperature, 

humidity, flying style. and pilot skill. Listed flight time applies to elevations less 

than 2,000 ft above sea level. 

**Range varies with location. antenna orientation, background noise and 

multi-path. 
MOTION PICTURE AND 

TELEVISION OPERATIONS 

MANUAL 

Thomas Michael Haley 

725 Kapiolani Blvd. C-311 

Honolulu, Hawaii 96813 
Table of Contents 

• 1. Introduction 

o A. Purpose 

o B. Pilot/Operator Organization 

o C. Persons Authorized 

o D. Area of Operations 

o E. Plan of Activities 

o F. Permission to Operate 

o G. Security 

o H. Briefing of Pilot/Production Personnel 

o I. Certification/Airworthiness 

o J. Pilot Personnel/Minimum Requirements 

o K. Communications 

o L. Accident Notification 

o M. Recall/Stop Procedures 

o N, Special Provisions 

• 2. Company Organization 

o A. Chief Pilot 

o B. Pilot in Command 

• AppendixA 

o 1 List of Approved Pilots 

o 2 List of Approved Aircraft 

o 3 Permission Acquisition Form (sample) 

o 4 Revision Letter (sample) 

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15 
Revision Control Page Revision# Date Initials 

------------------------------Date: 

01.07.2016 Revision: Original Page 4 of 15 
1. Introduction 

A. Purpose 

This manual has been developed by Thomas Michael Haley, hereafter referred to 'The 

Operator", in conjunction with an request for an amendment of part 333 Exemption and 

Certificate of Authorization regarding the provisions of FAR 91.119 (b) and (c) for the purposes 

of filming. The Operator's pilots and other company personnel will comply with the policies, 

procedures and conditions of this manual, whenever motion picture or television flight 

operations are performed under the authority of the part 333 Exemption and Certificate of 

authorization as mentioned above, or any superseding authorization that may result from future 

rulemaking. 

B. Pilot/Operator Organization 

Thomas Michael Haley - Manager, Chief pilot 

C. Persons Authorized 

FAR 91.119 (c) is waived only with respect to those persons, vehicles and structures 

directly involved in the performance of the actual filming. The certificate holder shall ensure that 

no persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced if an equivalent level of 

safety can be achieved and the Administrator or their designee has approved it. For example, 

an equivalent level of safety may be determined by an ASI's evaluation of the filming production 

area to note terrain features, obstructions, buildings, etc. Such barriers may protect 

nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an 

accident. 
D. Area of Operations 

The Operator's approved area of operations will be the United States, to include Alaska 

and Hawaii. 

E. Plan of Activities 

At least three (3) days prior to any scheduled filming, The Operator will submit a written plan 

of activities to the local FSDO having jurisdiction over that area. The plan of activities should include 

the following: 

1. Dates and times for all flights. 

2. Name and phone number of person responsible for the filming production event. 

3. Name and phone number of person responsible for aircraft. 

4. Make, model, and N-number of aircraft to be used 

5. Name and certificate number of pilots involved in the filming production event 

6. A statement that the exemption holder has obtained permission from property owners, 

their designee 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 from 

the exemption holder. 

7. Signature of exemption holder or representative. 

8. 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 minimum altitudes 

essential to accomplish the operations. The three (3) day notification equipments may be 

waived, however, the operator should contact the FSDO as soon as possible with this 

request and be prepared to explain in detail why the three (3) day notification is not 

practical. 
F. Permission to Operate 

Before any flight operations is conducted within or less than 500 feet under the 

provisions of the certificate of exemption and this manual, the operator will obtain permission to 

conduct these operations from property owners, or their designees and local officials as 

necessary or appropriate. Persons from whom permission may be required are listed below; 

( 1) Property owners 

{2) law enforcement officials 

(3) Fire department officials 

{4) local, State and Federal government 

(5) Air traffic control 

The Operator's personnel obtaining such permission will do so in writing whenever 

practical, however, verbal permission is acceptable otherwise. A standard permission form is 

provided in Appendix A and may be used when obtaining written permission. The Operator or 

designee will assure a sufficient number of those forms are available at the job site. Written 

permission forms will be maintained at the job site until flight operations are completed, and 

then turned into the chief pilot to be kept on file for a minimum of six (6) months. These forms 

will be made available for inspection by the FAA or other official personnel upon request. 

G. Security 

Prior to any flight operation the operator will coordinate with appropriate production 

personnel to devise a plan of securing the area(s) of operation from all unauthorized persons 

and vehicles. Provisions will be made to immediately discontinue operations should the area(s) 

become unsecured or for any other reason in the interest of safety. 
H. Briefing of Pilot/Production Personnel 

Prior to the start of any operation under the provisions of this manual, the pilot in 

command will conduct a briefing of all procedures to participating flight personnel of the risks 

involved, emergency procedures, and safeguards to be followed during the filming production 

event. Personnel will also be briefed on additional provisions that may be issued by the FSDO 

that has geographic responsibility for the operational area, including the location of boundaries 

or time limits. The briefing shall cover: 

• Authorization for motion picture and television certificate of exemption and the attached 

special provisions 

• Operations manual 

• Plan of activities 

• Communications 

• Preflight procedures 

• Aviation activities to be conducted during the filming production event 

• Approach and landing procedures 

• Lost sight, lost communications and recall procedures 

• Emergency procedures 

• Risks to participating personnel and operational risk management 

• How to control nonparticipating persons, Interlopers, security 
I. Certification/Airworthiness 

All The Operator aircraft used in operations or the purpose of filming will be authorized 

by the Operators Exemption and Certificate of Authorization or hold airworthiness certificates as 

required by the appropriate FARs. The aircraft will be maintained and inspected in accordance 

with the manufacturer's recommended schedule as outlined in the appropriate manual(s). Other 

required tests and inspections will be performed when necessary. The operator will maintain a 

flight log containing all maintenance records as well as upcoming scheduled maintenance and 

inspections and the dates or times they must be performed. A section for discrepancies is also 

found in the flight log. The pilot in command will assure the aircraft to be flown is in airworthy 

condition and all required inspections and maintenance has been completed before each flight. 

J. Pilot Personnel/Minimum Requirements 

The pilot/operator shall establish and specify the minimum pilot requirements. Minimum 

requirements shall meet or exceed the following as required by the Conditions and limitations 

section of the operators Exemption and Certificate of Authorization : 

(1) A current U.S. Airman certificate with ratings appropriate to the category, class and type as 

required by the 

(2) A current medical certificate 

(3) Requisite training for initial and/or continuing qualification and currency as specified by the 

operator, flight manual and limitations, if appropriate. 
K. Communications 

Prior to the start of any operation covered by this manual, the pilot in command will 

formulate a plan to provide communications capability to all participants during the actual 

operation and filming that is compliant the Conditions and limitations section of the operator's 

Exemption and Certificate of Authorization in a manner that is is effective and is capable of 

keeping the participants continuously appraised of the current status of the operation. 

L. Accident Notification 

Should an accident or incident requiring notification of the NTSB occur, the notification 

requirements of the exemption and certificate of authorization would comply. 

M. Recall/Stop Procedures 

Verbal, visual or a combination methods will be utilized to keep the participants 

continuously apprised of the current status of operation. 
N. Special Provisions 

The controls, procedures, and conditions set forth in the Operator's motion picture and 

television operations manual is the primary assurance that persons on the surface will not be 

jeopardized. The aircraft and pilots used under this authorization and/or exemption will only be 

those specified in the The Operator's motion picture and television operations manual 

("Appendix A" page 11) or associated plan of activities. Each pilot's name and certificate 

number shall appear on each daily plan of activity. All civil aircraft and pilot(s) participating in the 

activity shall be available for FAA inspection before the scheduled event. Each 

pilot-in-command conducting operations authorized under this certificate understands the 

conditions of issuance, and that it constitutes a waiver of FAR 91.119 (b) and (c). (see attached 

document under "Appendix 8" page 15) Rotorcraft takeoff and landing areas will be protected in 

a manner that will prevent unauthorized persons from entering the takeoff and landing area. The 

Operator will ensure that the participating persons involved in the operations are thoroughly 

briefed on special procedures, communication, emergency procedures, and on the provisions of 

the authorization and/or waiver before beginning the activities. No person may participate in any 

event unless that person has received a briefing on the provisions of the waiver. 
2. Company Organization 

A. Chief Pilot Duties and Responsibilities: 

• Final word in the formulation of policy and procedures concerning this manual. 

• Act as liaison between The Operator and the FAA on matter concerning this manual. 

• Assure that each approved pilot is issued a copy of this manual and obtain a signed 

statement from each that they have read and understand its contents. 

• Maintain a current copy of this manual at the main base of operations for The Operator. 

• Responsible for assuring that all revisions to this manual are distributed and processed 

property. 

• Must approve or disapprove each proposed job or operation performed by The Operator 

under the provisions of this manual. 

• Assume the responsibilities of pilot in command when acting as such. 

• Ensure that any other pilot in command acting on his behalf is property trained and 

qualified to comply with the conditions and limitations ofthe exemption, Certificate of 

Authorization and this manual 

• The chief pilot may delegate functions to other personnel but retains responsibility. 
B. Pilot in Command Duties and Responsibilities: 

• Conduct all required preflight mission planning and preparation as required 

• Assure that aircraft to be flown is in airworthy condition and all inspections and required 

maintenance have been performed as per appropriate FAR's. 

• Acquire permission from the chief pilot before any operation under the provisions of this 

manual. 

• Be very knowledgeable of the contents of this manual and abide by the procedures, 

policies and conditions contained herein. 

• Coordinate with movie and television personnel to formulate plans, routes, locations, etc. 

with safety of all persons involved in the primary concern. 

• Maintain their copy of this manual in current condition and have it on site at any job or 

operation requiring the exemption. 

• The pilot in command may delegate functions to other personnel, but retains 

responsibility. 
Appendix A 

1. List of Approved Pilots 

• Chief Pilot Name :Thomas Michael Haley 

• Certificate Number: #3030715 

• Grade : Private pilot 

• Medical Class: Third 

• Contact Number : 808 255 7988 
Appendix A 

2. List of Aircraft - Registration on file 

• DJI Inspire 1 Pro 

• DJI Phantom 3 Professional 

• Shotover U 1 

• Alta freefly 

• Gopro Karma 

• 30Robotics Solo 
3 Permission Acquisition Form 

In signing this form, I am giving the pilots of Thomas M Haley permission to operate their 

aircraft within or less than 500 feet from property, or in some jurisdiction in which I am 

responsible for or affiliated with, for the purpose of film or television production. 

Name: 

Title: 

Basis of Authority to Grant Permission: 

Location: 

Date of Operation: 

Signature----------------------

D~e ___________________ _ 

Thomas Michael Haley Representative Receiving Permission 

Date: __________ _ 
Appendix A 

4 Revision Letter Rev# Section Page Action Remarks Initials 

R • Remove and Replace 

D • Delete and Destroy 

N • Insert New 

Page Manual Serial# ________ lssued To------------

Revised By Date----------This 

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

Date:. ____________ _