July 20, 2015

Exemption No. 12093

Regulatory Docket No. FAA–2015–0743

Mr. Christopher P. Vlk

President and Owner

Reel Reverie MediaWorks, Inc.

2701 Little Elm Parkway #100–440

Little Elm, TX 75068

Dear Mr. Vlk:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 20, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Reel Reverie MediaWorks, Inc. (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct closed-set filming of motion pictures, music videos, web videos, corporate videos, 

television programs and commercials, wedding and entertainment venue videos, and still 

photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

DJI Inspire 2, DJI S1000+, and Tayzu Robotics Titan X8.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1 and closed set motion picture and 

filming. The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Reel Reverie MediaWorks, Inc. is granted an 

exemption from 14 CFR §§ 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)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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aerial data collection and closed set motion picture and filming. This exemption is subject to 

the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Reel Reverie MediaWorks, Inc. is hereafter referred to as 

the operator.

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, 

DJI Phantom 3, DJI Inspire 1, DJI Inspire 2, DJI S1000+, and Tayzu Robotics Titan 

X8 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 

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) of the 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 
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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 operating 

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 a VO 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. 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 

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 
5

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.

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

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

operated under this exemption, including evasive and emergency maneuvers 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 CFR § 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. UAS 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 COA 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 UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted 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 ATO-issued COA. The 
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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 COA.

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

number, registered in accordance with 14 CFR part 47, 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 and 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 
7

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 of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS 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 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 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.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
2701 Little Elm Parkway #100-440

Little Elm, Texas 75068

(469) 730-6540

Direct Dial Number: (202) 294-5162

Direct Facsimile Number: (877) 670-7469

E-Mail Address: hello@reelreverie.com 

March 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Reel Reverie MediaWorks, Inc.’s Petition for Exemption to Operate

Unmanned Aircraft Systems for Aerial Photography and Filming

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER 

Reel Reverie MediaWorks, Inc.

ATTN: CHRISTOPHER P. VLK

2701 Little Elm Parkway #100-440

Little Elm, Texas 75068

hello@reelreverie.com

(469) 730-6540

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

www.reelreverie.com
March 20, 2015

Page 2 

I. PETITION SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012,

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f),

Reel Reverie MediaWorks, Inc. (“Petitioner”) hereby petitions for exemptions from 14 C.F.R. 

Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 

91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)(1) 91.409(a)(2), 91.417(a)-(b).

The proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted 

unmanned aircraft systems (“UAS”) weighing 55 pounds or less for the purpose of closed-set 

filming of motion pictures, music videos, web videos, corporate videos, television programs and 

commercials, wedding and entertainment venue videos, and still photography.

 Based on the small size of Petitioner’s UAS, the qualifications and experience of 

Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner will 

operate, the requested exemptions fall squarely within the zone of safety envisioned by Congress 

and set forth in Section 333. Additionally, the enhanced safety achieved by replacing 

significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying 

no passengers or crew and operated under the specific guidelines and procedures proposed by 

Petitioner gives the FAA good cause to find that the UAS operations enabled by the instant 

Petition are in the public interest. Thus, the requested exemptions should be granted.

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

www.reelreverie.com
March 20, 2015

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II. BACKGROUND

For more than a decade, Petitioner’s production and filming professionals have provided 

advanced motion picture services and camera support for films, television programs, corporate 

and music videos, and events around the world. Combining the latest technology with a long 

track record of safe and successful projects, Petitioner’s technical expertise has been relied upon 

for filming projects of a wide variety. In order to continue to provide the highest level of service, 

and to promote safety by eliminating the need for large manned aircraft on a filming set, 

Petitioner seeks regulatory exemptions that will allow Petitioner to employ camera-mounted 

UAS technology in the filming and production process. 

III. STATUTORY AUTHORITY

A. Section 333

 Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the National 

Airspace System (“NAS”). Section 333(a) states that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion 

of the [comprehensive] plan and rulemaking required by section 332(b)(1) of this Act or the 

guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that 

Section 333 provides a mechanism for “expedited operational authorization.” The FAA has 

committed to complying with this mandate by granting several petitions almost identical to the 

one at hand.

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

www.reelreverie.com
March 20, 2015

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See, e.g., Exemption No. 11062, Regulatory Docket No. FAA-2014-0352 (granting regulatory 

exemptions to Astraeus Aerial for operation of unmanned aircraft systems for the purpose of 

filming for the motion picture and television industry).

 Section 333(b) identifies several factors that the FAA should consider in determining 

whether commercial UAS operations should be approved. These include UAS that, “as a result 

of their size, weight, speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the [NAS] or the public or 

pose a threat to national security.” See Section 333(b).

B. Section 44701(f)

In addition to the specific authority conferred by Section 333, the FAA Administrator has 

general authority to grant exemptions from the FAA’s safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest.

See U.S.C. § 44701(f). 

IV. REQUESTED EXEMPTIONS

Petitioner requests relief from the following regulations: 

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and changing 

design approvals, production approvals, airworthiness certificates, and airworthiness approvals.

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Little Elm, Texas 

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Section 61.113 prescribes that “no person who holds a private pilot certificate may act as 

a pilot in command of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft,”

(see Section 61.113(a)), and that “a private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire,” (see Section 61.113(b)). 

Section 61.133(a) sets forth privileges for persons holding commercial pilot certificates, 

including a provision impliedly limiting to persons holding a commercial pilot certificate the 

ability to act as pilot in command of an aircraft “[f]or compensation or hire.” 

Section 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft 

unless it is in an airworthy condition. 

Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, 

before beginning a flight, become familiar with all available information concerning that flight, 

to include, “For any flight, runway lengths at airports of intended use,

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

www.reelreverie.com
March 20, 2015

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and the following takeoff and landing distance information: ... For civil aircraft for which an 

approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is 

required, the takeoff and landing distance data contained therein.” 

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: “Over other than congested areas. 

An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure.” 

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport 

or an appropriate altimeter setting available before departure.” 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to 

fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes.

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless 

it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the second 

copy of the Aircraft Registration Application as provided for in § 47.31(c). 

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

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March 20, 2015

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Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless the 

airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have 

the aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in Part 43 of the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft 

that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless it has 

been approved for return to service by a person authorized under § 43.7 of the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that -

 (a) Each registered owner or operator shall keep the following records

 for the periods specified in paragraph (b) of this section:

 (1) Records of the maintenance, preventative maintenance, and

 alteration and records of the 100-hour, annual, progressive,

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

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March 20, 2015

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 and other required or approved inspections, as appropriate,

 for each aircraft (including the airframe) and each engine,

 propeller, rotor, and appliance of an aircraft. The records

 must include- 

(i) A description (or reference to data acceptable to the

 Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person 

approving the aircraft for return to service. 

(2) Records containing the following information:

 (i) The total time in service of the airframe, each engine,

 each propeller, and each rotor. 

(ii) The current status of life-limited parts of each

 airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on

 the aircraft which are required to be overhauled on a

 specified time basis. 

(iv) The current inspection status of the aircraft, including

 the time since the last inspection required by the 

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Little Elm, Texas 

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March 20, 2015

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 inspection program under which the aircraft and its 

appliances are maintained.

 (v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for

 each, the method of compliance, the AD or safety

 directive number and revisions date. If the AD or

 safety directive involves recurring action, the time

 and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this

 chapter for each major alteration to the airframe and

 currently installed engines, rotors, propellers,

 and appliances. 

(b) The owner or operator shall retain the following records for the

 periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall

 be retained until the work is repeated or superseded by other

 work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be

 retained and transferred with aircraft at the time the aircraft is sold.

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Little Elm, Texas 

www.reelreverie.com
March 20, 2015

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 (3) A list of defects furnished to a registered owner or operator

 under § 43.11 of this chapter shall be retained until the defects

 are repaired and the aircraft is approved for return to service. 

V. PETITIONER’S PROPOSED OPERATIONS SATISFY SECTION 333.

A. Unmanned Aircraft System

 The UAS to be operated under this request are less than 55 lbs. fully loaded, will be 

operated at a speed of no more than 50 knots, carry neither a pilot nor passenger, carry no 

explosive materials or flammable liquids, and operate exclusively within a secured area. 

Petitioner’s UAS use a radio frequency spectrum for operation and control that complies with 

Federal Communications Commission (“FCC”) requirements, and Petitioner has integrated 

safety features into the UAS, as described in Petitioner’s Flight Operations and Procedures 

Manual (“FOPM”) and Motion Picture and Television Flight Operation Manual (“MPTFOM”)

(collectively, “operations manuals”).1

Petitioner’s UAS are equipped with redundant safety mechanisms allowing them to 

operate safely after experiencing certain in-flight failures. If a lost-link event occurs, including 

the loss of ground communications and/or the loss of a GPS signal, Petitioner’s UAS have the 

ability to perform a pre-coordinated, predictable, automated flight 

1 The MPTFOM and FOPM will be submitted separately and confidentially under 14 C.F.R. 11.35(b), as the 

manuals contain proprietary information that the applicant has not and will not share with others. The manuals 

contain operating conditions and procedures that are not available to the public and are protected from release under 

the Freedom of Information Act, 5 U.S.C. §§ 552, et seq.

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Little Elm, Texas 

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March 20, 2015

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maneuver and return to a predetermined location within a designated security perimeter for 

landing. The UAS further have the ability to abort a flight in the event of unpredicted obstacles 

or emergencies. All flights will be terminated after a maximum of 30 minutes or with 25% 

remaining battery power, whichever occurs first. Thus, good cause exists for granting Petitioner’s 

requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for flight in

VFR conditions). 

Petitioner’s UAS will be identified by serial number, registered in accordance with

14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R.

Part 45, Subpart C. Markings will be as large as practicable. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), 

Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter 

onboard the UAS. Instead, altitude information will be provided to the UAS PIC via a digitally 

encoded telemetric data feed, which downlinks from the aircraft to a ground-based on-screen 

display. The altitude information will be generated by equipment installed onboard the UAS, 

using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by the UAS PIC. Thus, good cause exists for granting the requested relief 

from 14 C.F.R. § 91.121.

 Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H

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(Airworthiness Certificates), subject to certain conditions and limitations, is warranted

(if necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R.

Part 11 and Section 333. The UAS operated without an airworthiness certificate in the restricted 

environment and under the conditions and limitations proposed by Petitioner will be at least as 

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not subject to the 

proposed limitations and conditions. 

Petitioner will strictly comply with safety and maintenance procedures included in all 

applicable UAS manufacturer’s instructions and operating manuals. To the extent such 

information is not included in the guidelines developed by the manufacturers, Petitioners will 

develop and document maintenance, overhaul, replacement, and inspection requirements, 

procedures to document and maintain maintenance records with regard to Petitioner’s UAS,

and UAS technician qualification criteria. Petitioner’s operations manuals will include 

maintenance requirements for Petitioner’s UAS, including “on-condition” maintenance and 

modifications. In light of these mitigating factors, exemptions from 14 C.F.R. §§ 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) are warranted. 

B. UAS Pilot in Command

 Petitioner’s UAS pilot in command (PIC) shall have passed the FAA ground school 

examination and shall hold at least a third-class medical certificate but shall not be

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required to hold a current pilot’s license. Since there are no standards for either private or 

commercial UAS pilot certificates, knowledge of airspace regulations acquired from FAA ground 

school and dexterity in the control and operation of the UAS acquired from actual operation of 

the aircraft will be the most important factors in establishing an equivalent level of safety. 

According to the FAA, “the FAA considers the overriding safety factor for the limited operations 

proposed by the petitioner to be the airmanship skills acquired through UAS-specific flight 

cycles, flight time, and specific make and model experience, culminating in verification through 

testing.” See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 18. With those 

factors in mind, Petitioner’s UAS PIC shall be required to meet several conditions and 

limitations as outlined in the FOPM and MPTFOM, including the following: 

• The UAS PIC will have accumulated and logged a minimum of 200 flight

 cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours

 logged as a UAS pilot with a similar UAS type (single blade or multirotor). 

• The UAS PIC will have accumulated and logged a minimum of five hours

 of flight time with the specific make and model of the UAS to be utilized

 for operations under the exemption and three take-offs and landings in the

 preceding 90 days. 

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• The UAS PIC will have successfully completed the qualification process as

 specified in the operations manuals, to include a knowledge and skill test.2

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s

understanding that Petitioner’s UAS will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) is therefore 

unnecessary. To the extent such an exemption is deemed necessary, Petitioner asserts that it 

should be granted in light of the safety procedures proposed herein. In accordance with the 

pertinent part of 14 C.F.R. § 91.7(b), the operator in command of Petitioner’s UAS shall be 

responsible for determining whether the aircraft is in a safe condition for flight. Petitioner’s 

manuals for maintenance and operations shall include safety checklists to be used by the operator 

in command prior to each flight. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft flight 

manual, marking, and placard requirements and § 91.203(a) and (b), (Civil aircraft: certifications 

required), it is Petitioner’s understanding that relief from these regulations is no longer necessary 

in light of the FAA Memorandum “Interpretation regarding whether certain required documents 

may be kept at an unmanned aircraft’s control station,” dated August 8, 2014.

2 Prior to operating, the PIC will be required to pass the knowledge and airmanship test qualifications developed by 

Petitioner for the UAS (which will be included in Petitioner’s operations manuals). There are no established 

practical test standards that support a jurisdictional FAA FSDO (“Flight Standards District Office”) evaluation and 

approval of company designated examiners. Petitioner will conduct these tests in accordance with its operations 

manuals. Given the constraints of the proposed operations, this procedure for testing will not adversely affect the 

safety of the NAS. 

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To the extent the FAA deems an exemption from this section necessary for Petitioner’s proposed 

operations, such exemption should be granted in light of the mitigating fact that Petitioner will 

maintain the documents required under 14 C.F.R. §§ 91.9 and 91.203 at the UAS ground control 

station during flights. 

Additionally, 100% of Petitioner’s operations will utilize a visual observer (“VO”). The 

VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and the PIC will be able to communicate verbally at all times during 

operational flights. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will 

comply with the other applicable procedures and requirements stated in § 91.103(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before initiation of a 

flight. The PIC will also account for all relevant site-specific conditions in their preflight 

procedures. Risks presented by sun glare will be mitigated by the PIC’s and VO’s ability to see 

other air traffic and initiate a return-to-home sequence if needed. 

The PIC’s UAS operation will be limited to a unique and restricted environment. Given 

the (1) separation of closed-set filming operations from other manned operations, (2) parallel 

nature of aeronautical knowledge requirements incumbent in the FAA ground school exam and 

the process of obtaining a private pilot’s license, and (3) the proposed UAS airmanship skills of 

Petitioner’s PICs, the additional manned airmanship experience

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of a private pilot would not correlate to the airmanship skills necessary for Petitioner’s proposed 

unmanned operations. Thus, Petitioner’s request for relief from 14 C.F.R. § 61.113(a) and (b) and 

§ 61.133(a) should be granted. 

C. Operating Parameters of Petitioner’s UAS

Petitioner’s UAS operations will be conducted within a sterile environment of closed-set 

filming. In this controlled environment, Petitioner’s operations will remain within VLOS of the 

PIC and VO, below 400 feet AGL, and at speeds below 50 knots. Only participating persons will 

be permitted within the operating area.3 

Consistent with the relief typically provided to manned operations under FAA Order 

8900.1, Volume 3, Chapter 8, Section 1, Petitioner requests relief from 14 C.F.R. § 91.119(c) 

with respect to those participating persons, vehicles, and structures directly involved in the 

performance of the actual filming. Regarding distance from participating persons, the operations 

manuals set forth safety factors for authorized and consenting production personnel. Because 

those procedures are specific to participating persons, no further FSDO or aviation safety 

inspector approval is necessary for reductions to the distances specified in Petitioner’s manuals.

 Regarding the distance from nonparticipating persons, Petitioner will ensure that no 

persons are allowed within 500 feet of the operating area except those consenting to 

3 Pursuant to Order 8900.1 V3, C8, S1, “participating persons” includes all persons associated with the filming 

production. Participating persons will be briefed on the potential risk of the proposed flight operations and must 

acknowledge and accept those risks prior to participation.

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be involved and necessary for the filming production, with the possibility of reducing this 

distance to no less than 200 feet if it would not adversely affect safety and the Administrator has 

approved it. This is consistent with FAA Order 8900.1, V3, C8, S1. 

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic 

center of a non-towered airport unless a letter of agreement with that airport’s management is 

obtained and the operation is conducted in accordance with a Notice to Airmen (“NOTAM”). 

Additionally, Petitioner will not operate in Class B, C, or D airspace without written approval 

from the FAA. Nor will Petitioner operate the UAS 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.

 Petitioner’s UAS will remain clear and yield the right of way to all manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders). 

Although Petitioner seeks to comply with the waiver process as described in FAA Order 

8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion Picture and 

Television Filming), the current section of Order 8900.1 has specific processes that preclude a 

jurisdictional FAA FSDO from issuing the required Certificate of Waiver, because the section did 

not originally provide for UAS operations. Thus, Petitioner seeks exemption from the applicable 

regulations normally waived during that process. Petitioner proposes that the FAA include the 

required notifications and

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coordination with jurisdictional FSDOs through the conditions and limitations accompanying the 

requested exemption, and that the exemption sought herein will take the place of the Certificate 

of Waiver normally issued by a jurisdictional FSDO under 8900.1. Under this rubric, Petitioner 

will notify every FSDO with jurisdiction over the area that Petitioner plans to operate, just as 

with manned filming operations, and those FSDOs will have the ability to coordinate further 

conditions and limitations with the UAS Integration Office to address any local concerns.

 Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or 

Authorization (“COA”) prior to conducting any operations under this grant of exemption. In 

fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not 

more than 72 hours in advance, but not less than 48 hours prior to the operation. 

D. The Requested Exemption Promotes the Public Interest

The enhanced safety achieved by replacing significantly larger manned aircraft carrying 

crew and flammable fuel with small UAS carrying no passengers or crew and operated under the 

specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find that 

the UAS operations enabled by the instant Petition are in the public interest. Moreover, as the 

FAA has already recognized, “UAS provide an additional tool for the filmmaking industry, 

adding a greater degree of flexibility, which supplements the current capabilities offered by 

manned aircraft.” See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 22.

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VI. CONCLUSION

 For the foregoing reasons, the regulatory exemptions requested herein should be granted 

and Petitioner should be permitted to conduct small UAS operations for the purpose of

closed-set filming.

Respectfully submitted, 

 REEL REVERIE MEDIAWORKS, INC.

 A Texas Corporation

 

 By 

 Christopher P. Vlk

 President and Owner

 Reel Reverie MediaWorks, Inc.

Reel Reverie MediaWorks, Inc. 

Little Elm, Texas 

www.reelreverie.com