Motion Picture and Television Operations Manual (MPTOM)

Operations conducted for the purpose of motion picture filming (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51 (b), a minimum of five hours as a UAS pilot operating the make and model of UAS to be

utilized for operations under the exemption and three take­offs and three landings in the

preceding 90 days. Training, proficiency, experience­building, and take­off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight time and

90 day currency. During training, proficiency, experience building, and take­off and landing

currency 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. Prior to any flight operations authorized by this grant of exemption, the

PIC and VO must have successfully completed a qualification process, as outlined in the

operator’s manual. As this is a requirement stipulated by the operator, the test must be

developed and implemented by a qualified person designated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and made

available to the Administrator

of the FAA (the “Administrator”) upon request. Prior to operations conducted for the purpose of

motion picture filming (or similar operations), a flight demonstration, administered by an

operator­approved and qualified pilot must be successfully completed and documented. This

documentation must be available for review upon request by the Administrator. Because the

knowledge and airmanship test qualifications have been developed by the operator, and there

are no established practical test standards that support a jurisdictional FAA FSDO evaluation

and approval of company designated examiners, the petitioner will conduct these tests in

accordance with the operator’s manual. The UAS will not be operated directly over any person,

except authorized and consenting production personnel, below an altitude that is hazardous to

persons or property on the surface in the event of a UAS failure or emergency. Regarding the

distance from participating persons, the operator’s manual has safety mitigations for authorized

and consenting production personnel. At all times, those persons must be essential to the

closed­set film operations. Because these procedures are specific to

participating persons, no further FSDO or Aviation Safety Inspector (“ASI”) approval is

necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent

with the manned aircraft procedures described in FAA Order 8900.1, Volume 3, Chapter 8,

Section 1 Issue a Certificate of Waiver for Motion Picture and Television Filming(the “Order”)

Regarding distance from non­participating persons, the operator will 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 to no less than 200 feet if it

would not adversely affect safety and the Administrator has approved it. For example, an

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the

filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such

barriers may protect non­participating persons (e.g. observers, the public, news media)from

debris in the event of an accident. This is also consistent with the Order. If the UAS loses

communications or loses its GPS signal, the UAS
must return to a predetermined location within the security perimeter and land or be recovered

in accordance with the operator’s manual.

This is additional information requested from Debra Rodeson to add to my Petition for the FAA

333 exemption. This will cover the Closed set filming for MPTOM

Operations conducted for the purpose of motion picture filming (or similar operations), the PIC

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a

minimum of five hours as a UAS pilot operating the make and model of UAS to be utilized for

operations under the exemption and three take­offs and three landings in the

preceding 90 days. Training, proficiency, experience­building, and take­off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight time and

90 day currency. During training, proficiency, experience building, and take­off and landing

currency 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. Prior to any flight operations authorized by this grant of exemption, the

PIC and VO must have successfully completed a qualification process, as outlined in the

operator’s manual. As this is a requirement stipulated by the operator, the test must be

developed and implemented by a qualified person designated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and made

available to the Administrator

of the FAA (the “Administrator”) upon request. Prior to operations conducted for the purpose of

motion picture filming (or similar operations), a flight demonstration, administered by an

operator­approved and qualified pilot must be successfully completed and documented. This

documentation must be available for review upon request by the Administrator. Because the

knowledge and airmanship test qualifications have been developed by the operator, and there

are no established practical test standards that support a jurisdictional FAA FSDO evaluation

and approval of company designated examiners, the petitioner will conduct these tests in

accordance with the operator’s manual. The UAS will not be operated directly over any person,

except authorized and consenting production personnel, below an altitude that is hazardous to

persons or property on the surface in the event of a UAS failure or emergency. Regarding the

distance from participating persons, the operator’s manual has safety mitigations for authorized

and consenting production personnel. At all times, those persons must be essential to the

closed­set film operations. Because these procedures are specific to

participating persons, no further FSDO or Aviation Safety Inspector (“ASI”) approval is

necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent

with the manned aircraft procedures described in FAA Order 8900.1, Volume 3, Chapter 8,

Section 1 Issue a Certificate of Waiver for Motion Picture and Television Filming(the “Order”)

Regarding distance from non­participating persons, the operator will 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 to no less than 200 feet if it

would not adversely affect safety and the Administrator has approved it. For example, an

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the

filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such

barriers may protect non­participating persons (e.g. observers, the public, news media)from
debris in the event of an accident. This is also consistent with the Order. If the UAS loses

communications or loses its GPS signal, the UAS

must return to a predetermined location within the security perimeter and land or be recovered

in accordance with the operator’s manual.

At least three days before scheduled filming, the operator of the UAS affected by this exemption

must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of

proposed filming. The 3­day 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 filming production conducted under this

grant of exemption

c. Name and phone number of the person responsible for the on­scene operation of the UAS

d. Make, model, and serial or N­number of UAS to be used

e. Name and certificate number of UAS PICs involved in the filming production event

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 exemption­holder or representative The documents required under 14 CFR §

91.9 and § 91.203 will 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. The UAS will

remain clear and yield the right of way to all other manned operations and activities at all times

(including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, hang gliders, etc.). UAS operations will not be conducted during night, as

defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions

(“VMC”). Flights under special visual flight rules (“SVFR”) are not authorized. The UAS will be

operated by the PIC from any moving device or vehicle.

The UA will 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. The UA will not operate in

Class B, C, or D airspace without written approval from the FAA. The UA will not operate within

5 nautical miles of the geographic center of a non­towered

airport as denoted on a current FAA­published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in accordance with a

NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

Any 1) incident, 2) accident, or 3) 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 UAS Integration Office (AFS­80) within 24 hours. Such accidents must be reported to the

National Transportation Safety Board (“NTSB”per instructions contained on the NTSB Web site:

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident,

or transgression is reviewed by AFS­80 and authorization to resume operations is provided.

Unless otherwise specified in this grant of exemption, the UAS, PIC, and operator must comply
with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.The

Federal Aviation Administration by and through its authorized representative is requested to

approve this petition based on the above terms and conditions for a certificate of authority and

certificate of exemption to operate within the above parameters for compensation or hire within

the United States National Air Space.