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United States of America

Department of Transportation

Docket Operations West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Regulatory Docket No: _______________________________

Petition for exemption of Title 14 of the Code of Federal Regulations, sections:

21 Subpart H, 45.23(b), 61.113 (a) & (b), 91.103(b)(2), 91.105, 91.109, 91.119, 91.121, 91.151(a) 

91.203(a) & (b), 91.405, 91.407, 91.409, 91.417 (a) & (b),

pursuant to Section 333 of the FAA Reform Act.

July 24, 2015

Robert A. Goddard

EagleVision Productions, LLC

18 Heritage Ln, Suite 101

Wakefield, MA 01880

Tel: 617-512-0333
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Table of Contents

Introduction and Overview.................................................................. Page 3

Summary Basis for Exemptions previously granted by the FAA ..................... Page 5

Applicant Name, Address and Contact Information..................................... Page 13

Specific Sections from Which an Exemption is Sought................................. Page 14

14 C.F.R. Part 21 Subpart H: Airworthiness Certificates

14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in Comman

14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness

14 C.F.R. § 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. § 91.103(b) Pre-flight Action

14 C.F.R. § 91.105 Flight Crewmembers at Stations

14 C.F.R. § 91.119 Minimum Safe Altitudes

14 C.F.R. § 91.121 Altimeter Settings

14 C.F.R. § 91.151(a) Fuel Requirements of Flight in VFR Conditions

14 C.F.R. § 91.203 Civil Aircraft: Certification Required

14 C.F.R. § 91.405 Maintenance Required

14 C.F.R. § 91.407 Operation after Maintenance, Preventative Maintenance, Rebuilding

and Alteration

14 C.F.R. § 91.409 Inspections

14 C.F.R. § 91.417 Maintenance Records

Why Granting the Exemptions Would be in the Public Interest............................... Page 29

Why Granting the Exemptions would provide an Equivalent Level of Safety to Current Rules Page 30

A Summary that can be Published in the Federal Register....................................... Page 31
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Introduction and Overview

Pursuant to Section 333 of the Federal Aviation Administration Modernization and Reform Act

of 2012, (Reform Act) and 14 C.F.R. § 11.61(b) EagleVision Productions, LLC., hereby petitions for

exemption from 14 C.F.R. §§ 21 Subpart H, 61.113 (a) & (b), 91.7(a), 91.9(b), 91.103(b)(2), 91.105, 

91.109, 91.119, 91.121, 91.151(a), 91.203(a) & (b), 91.405, 91.407, 91.409, 91.417 (a) & (b) of the 

Federal Aviation Regulations (FARs).

EagleVision Productions, LLC [hereinafter "EVP"] and its principals, Mr. Robert A. Goddard, 

Jesse R. Dacri and Jonathan M. Berecz currently work with film makers, film production companies, 

film and television education, insurance companies, construction companies and real estate brokerage 

firms in the capture of “land based photography” and now seek to compliment that enterprise with the 

pursuit of “aerial video acquisition” for a variety of reasons dependent on each industry sector. EVP

was formed for the purpose of creating an entity that would commercially pursue the “safe” and 

effective use of emerging technology to compliment their respective careers in land based photography. 

EVP strives to lead this emerging industry by setting an example of the safe and well trained operations 

of UAS aircraft with strict adherence to the existing FAR’s in addition to the proposed FAA regs 

announced in February of this year and currently under review and comment from the public.

A Brief Description of the exemptions EagleVision Productions, LLC Seeks:

These exemptions will permit EagleVision Productions LLC., to operate small 

Unmanned Aircraft Systems (UAS) for aerial cinematography and photography at 

controlled locations for use in motion picture, television, and music industries, and 

other legally permissible uses.

Briefly, the educational qualifications of EVP’s principals are: Mr. Goddard holds a BSBA cum 

laude from Northeastern University and an MBA from the Harvard Business School. Mr. Dacri holds a 
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BS cum laude from Ithaca College in Cinematography and Mr. Berecz holds a BA in Media Studies and 

a Masters Degree in Technology and Education. 

In setting forth with the business plan of EVP and its operations, a company decision was made back 

in late 2014 to pursue the absolute appropriate and proper way to set out its plans should we be 

successful in being granted an exemption pursuant to Section 333 of the Federal Aviation 

Administration Modernization and Reform Act of 2012 by following deliberate steps as outlined below:

1. Each operator would log, in excess of 100 hours of “trainer” UAS’s that possess no technical 

enhancements that assist in the flight operation of the crafts, thus establishing a basis for the 

understanding of operating in a safe and sound manner in various flying and weather conditions. 

For the purpose of this initial step, the purchase of Hubsan X-4 and SYMA XC5 craft were 

utilized.

2. Subsequently, [with the exception of Mr. Dacri who has logged in over 300 hours of flight time 

in various UAS’s since late 2013] the purchase of DJI Phantom 2 and Phantom 2+ craft and the 

applied flight skills from the flight trainer’s listed in #1 above were a natural progression. These 

craft are in constant training utilization and along with the recent purchases of a DJI Inspire 1 

and Three (3) Phantom 3 Professional Quad Copters comprise the majority of our UAS fleet. 

EVP maintains an online “cloud based” Flight Log for each flight taken by these craft with 

substantial supporting documentation and maintenance records and each principal of EVP now 

has over 75 hours of logged flight time on each of the above listed aircraft.

3. EVP proceeded next to pursue insurance coverage for its anticipated activities and filed 

applications with numerous carriers that now insure UAS’s for both physical and liability

protection and coverage. EVP was granted approval by two highly regarded carriers and has 

received quotes from both for coverage. Execution of that coverage was completed on June 30, 
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2015 insuring all aircraft listed above and providing $1 million dollars of property and personal 

liability coverage. The policy is underwriting by Starr Companies, a Global Indemnity and 

Liability Company.

4. EVP decided next to pursue the current FAR requirement for a Sport Pilot’s License for each 

operator acting as a PIC. To that end, as noted above, the principals have each obtained their 

Student Pilot’s Certificates and are currently being trained by certified FAA CFI’s.

Each of the principals is enrolled in flight school now and has obtained their Student Pilot Certificates as 

follows:

Robert A. Goddard - Cert. #AR1749037

Jonathan M. Berecz – Cert. #AR1212616

Jesse R. Dacri – Cert. # AR1295803

as required by the current regulations for granting of an exemption. They are slated for completion of 

their required Flight Training, Ground School, FAA knowledge test and fulfilling the requirements for 

Sport Pilots Licensing by August 31, 2015.

Summary Basis for Petitions similar in nature granted by the FAA.

The Federal Aviation Administration, in its review of petitions submitted previously which we 

believe are similar in all material respects to those presented in our petition, namely: Exemption Nos. 

11641 to Steven J. Massi; 11313 to DeGrazia Music, LLC; 11062 to Astraeus Aerial; 11109 To Clayco, 

Inc; 11112 to VDOS Global, LLC and 11213 to Aeryon Labs, Inc. wherein the FAA found that the 

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

petitioner and also described in our petition and carrying no passengers or crew, rather a manned aircraft 
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of significantly greater proportions, carrying crew in addition to flammable fuel, gave the FAA good 

cause to find that the UAS operations enabled by these exemptions is in the public interest.

Self Imposed Conditions and Limitations should our petition be granted

Should our request for exemption by granted, EagleVision Productions, LLC is hereafter referred to 

as the operator or “EVP”. We understand that failure to comply with any of the following conditions 

and limitations of our proposed grant of exemption would be grounds for the immediate suspension or 

rescission of the requested exemptions.

1. Operations authorized by the proposed grant of exemptions are limited to the DJI Inspire, DJI 

Phantom 3 Professional when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft would be submitted to the FAA under a new petition or a petition 

to amend this proposed exemption.

2. Operations for the purpose of closed-set motion picture and television is requested and 

permission sought.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). The requesting 

exemption holder [in this case EVP] would use groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case would any UAS be operated greater 

than the maximum UAS operating airspeed recommended by the aircraft manufacturer.

4. The UAS, would be only operated at an altitude of no more than 400 feet above ground level 

[AGL]. Altitude would be reported in feet AGL and logged in each flight in EVP’s log books.

5. The UAS would be operated within visual line of sight [VLOS] of the PIC at all times. This 

would require 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.
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6. All operations would utilize a visual observer [VO]. They UAS would be operated within the 

VLOS of the PIC and VO at all times. The VO might be used to satisfy the VLOS requirement 

as long as the PIC always maintains VLOS capability. The VO and PIC will ensure that they

always have the ability to communicate verbally at all times; electronic messaging or texting 

would never be permitted during flight operations. The PIC would be designated prior to any

flight and would not transfer his or her designation for the duration of the flight. The PIC would 

ensure that the VO can perform the duties required of the VO.

7. Should this proposed exemption be granted, any and all documents needed to operate the UAS 

and conduct its operations in accordance with the conditions and limitations set forth above and 

which may be amended or added to in the granting of the exemption request, are hereinafter 

referred to as the operating documents. These operating documents would be accessible during 

UAS operations and made available to the Administrator upon request. If or should there be any 

discrepancy that exists in the final conditions and limitations in the proposed exemption and the 

procedures outlined in the operating documents, the final conditions and exemptions would take 

precedence and would be followed. Otherwise, the operator would follow the procedures as 

outlined in its operating documents. The operator may, from time to time or as required by

stipulated FAA guidelines and regulations cause the operating documents to be revised as 

necessary. It would be 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 would also present updated or revised documents if it petitions for extension or 

amendment to the requested exemption. If or should the operator determine that any update or 

revision would affect the basis upon which the FAA might favorably grant the requested 

exemption, then the operator must petition for an amendment to the proposed grant of exemption. 

The FAA’s UAS Integration Office (AFS-80) would be contacted should questions arise 

regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operations or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional flight 

test prior to conducting further operations under this proposed exemptions. Said maintenance 

shall always be noted and recorded in the operator’s maintenance log. 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 flight test must and would be conducted in such a manner so as not to pose an 

undue hazard to persons and/or property.

9. The operator is and will always be responsible for maintaining and inspecting the UAS in it’s 

pre-flight check list, a copy of which shall always be maintained prior to each flight and stored 

electronically within the operators Flight Log and Maintenance Log systems to ensure that it is in 

a condition for safe operation.
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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 request 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 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 proposed exemption are permitted under the terms of proposed exemption. 

However, the operator must petition for an amendment to its grant of exemption, should one be 

issued. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. Training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119. 

15. UAS operations will not be conducted during nighttime, 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. 
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16. The UAS will 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 will be 

made available to the Administrator or any law enforcement official upon request. 

17. The UAS will not be operated at any altitude greater than 400 feet AGL, unless specific 

permission to do so has been received in writing via a COA from the local FSDO.

18. If the UAS loses communications or loses its GPS signal, the UAS automatically returns to a 

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

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the intended 

operation and to operate after that for at least 5 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 proposed exemption holder 

may apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the terms of an existing COA. 

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

number, registered in accordance with 14 CFR part 47, and will have identification (N−Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable. 
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23. Documents will be 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. 

24. The UAS will remain clear and give way to all manned aviation operations and activities at all 

times. 

25. The UAS will not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UAS and/or debris in the event of an accident. The operator 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 UAS, 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 will not be considered nonparticipating 

persons under this proposed 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 will be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents will be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

If this proposed exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, FOR WHICH WE ARE SEEKING PERMISSION TO DO 

SO, the following additional conditions and limitations apply. 
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29. The operator will have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. (included in our petition)

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption will

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.

This petition is submitted as a request to allow EagleVision Productions, LLC to commercially

operate small Unmanned Aerial Systems (UAS), in accordance with petitioner’s Motion Picture and 

Television Operational Handbook (MPTOM), and Flight Operations & Company Operations Handbook

(FLCOH), and those conditions that may be established by the FAA as required by Section 333. In brief, 

the requested exemptions would permit the operation of UAS that are less than 55 lbs:
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1) by an FAA licensed pilot;

2) at less than 400 feet of altitude above ground level (AGL)

3) in an area that is limited and predetermined;

4) where public access to such area is controlled;

5) where operational intentions are communicated to the local FSDO

6) in accordance with any other rules set forth by the FAA, or which may be subject to change, 

at any given time.

Approval of the requested exemptions will create a structure within which EagleVision Productions, 

LLC., can mitigate or eliminate potential hazards to the public during UAS filming operations. 

Approval of these exemptions would create no safety concerns regarding the National Airspace System 

and will fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “establish 

requirements for the safe operation of such aircraft systems in the National Airspace System” Section 

333(c) of the Reform Act

Airworthiness Certifications (Manufacturer’s Safety Guidelines) and Proposed Aircraft to be 

Listed for Approved Flight

1. DJI Inspire

2. DJI Phantom 3 Professional
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Applicant Name, Address and Contact Information

Pursuant to 14 C.F.R. § 11.81(a) the name and address of the Applicant is:

Robert A. Goddard, Managing Member

EagleVision Productions, LLC.

18 Heritage Ln, Suite 101

Wakefield, MA 01880

617-512-0333

Email: bob@eaglevisionllc.com
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Specific Sections From Which an Exemption is Sought

14 C.F.R. Part 21 Subpart H: Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR § 91.203 (a)(1).

Basis for Request for Exemption

Petitioner requests exemption from the requirements for an airworthiness certificate, pursuant to 

49 U.S. Code § 44701(f) and Section 333 of the Reform Act. While the UAS here are manufactured 

without an airworthiness certificate and there are no mechanics to certify these aircraft, an equivalent 

level of flight safety is attained by special pilot training, ground based security procedures, redundant 

safety procedures as well as safety features programmed into the UAS to guard against lost or degraded 

communications, lost satellite reception, geomagnetic interference. The UAS to be operated are less 

than fifty-five (55) lbs. fully loaded, fly at a speed of no more than forty (40) knots, fly at altitudes of 

less than four-hundred (400) feet above ground level (AGL), have a total flight time of no more than 

twenty five (25) minutes, and are controlled by a licensed pilot that will maintain continuous line of 

sight (CLOS) of the UAS, assisted at all times by a Visual Observer (VO), pursuant to the Flight 

Operations & Company Operations Handbook (FLCOH). Further, the UAS carry neither pilot nor 

passengers, carry no flammable liquid or explosive materials and operate in an area that is secured to 

prevent public entry as described in the Motion Picture and Television Operations Manual and Company

Operations Manual (MPTOM) and FLCOH.

The Federal Aviation Act § 49 U.S.C. §44701 (f) and Section 333 authorize the FAA to exempt 

aircraft, upon consideration of the size, weight, speed, operational capability and proximity to airports 

and populated areas. Application of those criteria to the proposed UAS operations and procedures in the 

MPTOM, and FLCOH demonstrate that the UAS can be operated in a manner that is at least as safe or 

safer than conventional aircraft with airworthiness certificates. Additionally, there is no threat to 
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National Airspace System (NAS) or National Security as the MPTOM and FLCOH clearly define limits 

that the aircraft cannot be operated within five (5) miles of any airport and notice will be given to the 

local Flight Service District Office (FSDO) prior and well in advance of any flight operations that might 

come within six (6) miles of restricted airspace.

14 C.F.R § 45.23(b) Marking of the Aircraft

(A) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital 

letter “N” (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.

(B) (b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Basis For Request for Exemption 

An exemption is requested, or in the alternative, a finding that § 45.23(b) does not apply as the 

UAS herein will not be issued experimental certificates. The UAS here has no cabin, nor 

entrance to the cabin, and no cockpit or pilot station on which the word “experimental” could be 

placed. The Applicant has submitted Form 8050-1 for each of the specified aircraft and will 

apply those “N” numbers to the fuselage of each aircraft in a maximum size as practical.

An equivalent level of safety is achieved by placing the word "Experimental" on the fuselage in 

compliance with §45.29(f) in a manner, which is readable, by the pilot and ground crew during 

pre-flight inspection.
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14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in command 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as 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. 

(b) 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. 

Basis For Request for Exemption 

Petitioner requests an exemption from the limitations of § 61.113 as an equivalent level of safety can 

achieved through specialized flight experience in piloting UAS, specialized knowledge of cinematic 

operations with UAS, and the operational guidelines in the MPTOM,and FLCOH designed for closedset filming with UAS. The training and knowledge required for Commercial pilots of conventional 

aircraft would not necessarily make a Commercial pilot safe to operate a UAS. . 

In addition, safety for the public, pilot, and crew is achieved through the design limits of the aircraft and 

petitioner's adherence to the MPTOM and FLCOH. Here, the risk to the public is mitigated because the 

small size of the UAS prevents carrying pilot or passengers or any cargo other than a camera. As Pilot 

In Command (PIC), Visual Observer (VO) and crew will always remain on the ground, the level of 

safety is thereby greater than what can be achieved in traditional aircraft. Additionally, the MPTOM, 

and FLCOH prescribe further safeguards through advanced flight planning and operations in a 

controlled environment. Granting exemption here will permit UAS operation will mitigate potential 

hazards to the public without being unduly burdensome to the operation of the UAS. As such, petitioner 

seeks exemption from 14 C.F.R. § 61.113 to allow commercial operation of UAS.
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14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

§ 91.7 Civil aircraft airworthiness. 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is 

in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. 

Basis For Request for Exemption 

Petitioner seeks exemption to the extent this rule requires an airworthiness certificate. As no such 

certificates exist for UAS. An equivalent level of safety will be achieved as the PIC of the UAS will 

ensure the airworthiness of the UAS through use of the procedures prescribed in the FLCOH for preflight inspection, review of logs, and test flights. 

14 C.F.R. § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft 

§ 91.9 Civil aircraft flight manual, marking, and placard requirements. 

(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft 

without complying with the operating limitations specified in the approved Airplane or Rotor 

craft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating 

authority of the country of registry. 

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotor craft Flight Manual is required by § 21.5 of this chapter 

unless there is available in the aircraft a current, approved Airplane or Rotor craft Flight Manual 

or the manual provided for in § 121.141(b); and 

(2) For which an Airplane or Rotor craft Flight Manual is not required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotor craft Flight Manual, 

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

Basis For Request for Exemption 

Petitioner seeks exemption because there is no approved Flight Manual for the proposed UAS. An 

equivalent level of safety can be achieved through adherence to petitioner's MPTOM and FLCOH which 
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includes aircraft specifications, aircraft operational limitations, an operations check-list, and updated 

information equivalent to placards. The pilot in command will keep the MPTOM and FLCOH on site 

during flight operations. 

14 C.F.R. § 91.103(b) Pre-flight Action 

§ 91.103 Pre-flight action. 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include—

(a) (Omitted by Petitioner as it applies to IFR flight)

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotor craft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under?????????? what

(3) Expected values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature. 

Basis For Request for Exemption 

Petitioner seeks exemption to the extent the rule requires the PIC to have runway data because the 

proposed UAS are Vertical Take-off and Landing (VTOL) and will not be operated within five (5) miles 

of any public airport. An equivalent level of safety and public benefit is achieved by the comprehensive 

flight planning and communications with FSDOs as required in the MPTOM and FLCOH. 

14 C.F.R. § 91.105 Flight Crewmembers at Stations 

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in connection 

with the operation of the aircraft or in connection with physiological needs; and 
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(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and 

landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This 

paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness 

fastened. 

Basis For Request for Exemption 

Petitioner seeks exemption as the UAS have no ability to carry pilot or crew, and thereby have no seats, 

seat belts, or crew stations. The pilot always having positive control of the remote control can achieve an 

equivalent level of safety and maintaining VLOS with the UAS at all times. 

Should the pilot become physiologically unable to continue as PIC, the UAS has a “Return To Home 

and Land” override function as well as other actions more fully described in the MPTOM and 

FLCOH. 
Page 20 of 31

14 C.F.R. § 91.119 Minimum Safe Altitudes 

§ 91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. 

(c) 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. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section. 

Basis For Request for Exemption 

Petitioner seeks exemption here because flight operations will always be below four hundred (400) feet 

AGL. An equivalent level of safety will be achieved through pre-flight planning, communication with 

the local FSDO, securing the flight area to prevent the public from entering, briefing all crew on 

emergency procedures, and ensuring operation of aircraft safety systems. Protections equivalent to 

minimum safe altitudes are created because, in the event of low-battery power, loss of communication or 

interference with communication between the remote control and the aircraft, on-board safety programs 
Page 21 of 31

will automatically land the UAS at a predetermined safe area. Similarly, the operational environment 

will be controlled to keep out the public. 

Normal operations will be less than 400 feet AGL and risk to the public and / or private property 

significantly reduced compared to film operations with traditional aircraft or helicopters. For example, a 

Bell 206 Helicopter has an approximate rotor diameter of thirty-three (33) feet and a gross weight of 

approximately three-thousand (3,000) pounds. The UAS proposed here have a total rotor area of less 

than two (2) feet and weight less than four (4) pounds. As such the risk to persons and property is 

drastically reduced. Further, the UAS will not carry fuel, flammable material, or hazardous cargo that 

would pose a hazard to persons on the ground. 

14 C.F.R. § 91.121 Altimeter Settings 

§ 91.121 Altimeter settings. 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table: (additional Tables Omitted) 
Page 22 of 31

Basis For Request for Exemption 

An exemption is sought as the UAS proposed are manufactured without an altimeter or two-way

communications radio. An equivalent level of safety is achieved through on-board systems and GPS 

sensors that couple with a geomagnetic compass to act as a barometric altimeter for stability and 

accuracy of flight. Information about the height of the UAS above ground level, specific location of the 

UAS, air speed and direction, and other pertinent data is displayed to the Pilot in Command at all times. 

An additional element of safety is achieved through the AOH requirement that the pilot verify altimeter 

ready of zero (0) feet prior to each take-off, and that the PIC maintain VLOS at all times. 

14 C.F.R. § 91.151(a) Fuel Requirements for Flight in VFR Conditions 

§ 91.151 Fuel requirements for flight in VFR conditions. 

(a) 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. 

(b) No person may begin a flight in a rotor craft 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, to fly after that for at least 20 

minutes. 

Basis For Request for Exemption 

An exemption is requested, as the normal UAS flight duration will be less than 25 minutes. An 

equivalent level of safety is achieved by implementation of a minimum battery life requirement rather 

than minimum fuel requirement. The FLCOH provides that the flight will be terminated before the 

battery voltage reaches a minimum of 25% of full capacity. An equivalent level of safety can be 

achieved as to the reserve battery power requirements proposed are comparable to the reserve fuel 

requirements in § 91.151. 
Page 23 of 31

14 C.F.R. § 91.203 Civil Aircraft: Certifications Required

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used 

to comply with this sub paragraph (except a special flight permit, a copy of the applicable 

operations specifications issued under § 21.197(c) of this chapter, appropriate sections of the air 

carrier manual required by parts 121 and 135 of this chapter containing that portion of the 

operations specifications issued under § 21.197(c), or an authorization under § 91.611) must 

have on it the registration number assigned to the aircraft under part 47 of this chapter. However, 

the airworthiness certificate need not have on it an assigned special identification number before 

10 days after that number is first affixed to the aircraft. A revised airworthiness certificate 

having on it an assigned special identification number, that has been affixed to an aircraft, may

only be obtained upon application to an FAA Flight Standards district office. 

(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), or a registration certification issued under the laws of a foreign country. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section 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. 

(c) No person may operate an aircraft with a fuel tank installed within the passenger 

compartment or a baggage compartment unless the installation was accomplished pursuant to 

part 43 of this chapter, and a copy of FAA Form 337 authorizing that installation is on board the 

aircraft. 

(d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the 

United States unless it complies with the fuel venting and exhaust emissions requirements of part 

34 of this chapter. 

Basis For Request for Exemption 

An exemption is requested as the Pilot in Command of the UAS will have an MPTOM and FLCOH that

include all documentation, safety information, and warnings required for safe operation of the UAS. The 

UAS proposed to be operated here are manufactured without the capacity to carry documents, are sold 

without Airworthiness Certificates, do not have cabin doors nor sufficient space to apply placards and do 
Page 24 of 31

not contain or carry fuel. As the UAS are always within sight of the PIC, an equivalent level of safety

can be achieved by the PIC having the MPTOM and FLCOH during flight operations and 

communicating pertinent information to crew. 

14 C.F.R. § 91.405 Maintenance required 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in sub part E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter; 

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance 

records indicating the aircraft has been approved for return to service; 

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by 

§91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required 

inspection; and 

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a 

placard has been installed as required by § 43.11 of this chapter. 

Basis For Request for Exemption 

An exemption is requested, as the UAS does not have specific maintenance instructions. Therefore the

MPTOM and FLCOH developed by petitioner contain instructions for maintenance and repair as 

needed. Petitioner will be responsible for inspection after maintenance, overhaul, or replacement, and 

monitoring for life limit requirements of actuators or servos, motors, propellers, electronic speed 

controller and flight control unit, batteries, remote control and any other components as determined by

the petitioner. 

The PIC will be responsible for inspecting the UAS prior to each flight and determining fitness for flight 

after maintenance. An equivalent level of safety to § 91.405 will be achieved by thorough pre-flight 
Page 25 of 31

inspections and records of all maintenance or repairs being kept in the UAS log book. Because the 

petitioner is the person most familiar with the aircraft and best suited to maintain the aircraft, an 

equivalent level of safety will be maintained and the UAS kept in an airworthy condition. 

14 C.F.R. § 91.407 Operation after Maintenance, Preventive Maintenance, Rebuilding, 

Alteration 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; 

and 

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has 

been made. 

(b) No person may carry any person (other than crew-members) in an aircraft that has been 

maintained, rebuilt, or altered in a manner that may have appreciably changed its flight 

characteristics or substantially affected its operation in flight until an appropriately rated pilot 

with at least a private pilot certificate flies the aircraft, makes an operational check of the 

maintenance performed or alteration made, and logs the flight in the aircraft records. 

(c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to 

flight, ground tests, inspection, or both show conclusively that the maintenance, preventive 

maintenance, rebuilding, or alteration has not appreciably changed the flight characteristics or 

substantially affected the flight operation of the aircraft. 

Basis For Request for Exemption 

Petitioner is seeking exemption from § 91.407 as there are currently no persons authorized under § 47.7 

to service the UAS. As with the request for exemption under § 91.405, an equivalent level of safety will 

be achieved by thorough pre-flight inspections and records of all maintenance or repairs being kept in 

the UAS log book. Further, Petitioner is the person most familiar with the aircraft and best suited to 

maintain the aircraft and perform post-maintenance, pre-flight inspections and ground tests to confirm 

that the flight characteristics of the UAS have not been substantially affected after maintenance. 
Page 26 of 31

14 C.F.R. § 91.409 Inspections 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. 

No inspection performed under paragraph (b) of this section may be substituted for any

inspection required by this paragraph unless it is performed by a person authorized to perform 

annual inspections and is entered as an “annual” inspection in the required maintenance records. 

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

carrying any person (other than a crewmember) for hire, and no person may give flight

instruction for hire in an aircraft which that person provides, unless within the preceding 100 

hours of time in service the aircraft has received an annual or 100-hour inspection and been 

approved for return to service in accordance with part 43 of this chapter or has received an 

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en route to 

reach a place where the inspection can be done. The excess time used to reach a place where the 

inspection can be done must be included in computing the next 100 hours of time in service. 

(c) Paragraphs (a) and (b) of this section do not apply to—

(1) An aircraft that carries a special flight permit, a current experimental certificate, or a lightsport or provisional airworthiness certificate; 

(2) An aircraft inspected in accordance with an approved aircraft inspection program under part 

125 or 135 of this chapter and so identified by the registration number in the operations 

specifications of the certificate holder having the approved inspection program.

Basis For Request for Exemption 

Petitioner is seeking exemption from § 91.409 for reasons similar to those articulated in the requests for 

exemption from § 91.407 and § 91.405 above. There are currently no persons authorized under § 47.7 to 

service or inspect UA, but petitioner making thorough pre-flight inspections and keeping detailed 

records of all maintenance or repairs will achieve an equivalent level of safety. As above, post-
Page 27 of 31

maintenance pre-flight inspections and ground tests will be conducted to confirm that the flight 

characteristics of the UAS have not been substantially affected. 

14 C.F.R. § 91.417 Maintenance records 

(a) Except for work performed in accordance with §§91.411 and 91.413, 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, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, 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 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 revision 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: 
Page 28 of 31

(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 

the aircraft at the time the aircraft is sold. 

(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. 

(c) The owner or operator shall make all maintenance records required to be kept by this section 

available for inspection by the Administrator or any authorized representative of the National 

Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 

described in paragraph (d) of this section for inspection upon request of any law enforcement 

officer. 

(d) When a fuel tank is installed within the passenger compartment or a baggage compartment 

pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified 

aircraft by the owner or operator. 

Basis For Request for Exemption 

Petitioner is seeking exemption from § 91.417 to the extent the rule requires a certificated person to 

perform work under § 91.417(a)(1)(iii), compliance with Airworthiness Directives under sub-section 

(a)(1)(v), and/or copies of alteration forms under (a)(1)(vi). Petitioner keeping maintenance logs and 

documentation in the FLCOH will achieve an equivalent level of safety. 
Page 29 of 31

Why Granting the Exemptions Would be in the Public Interest: 

Generally, aviation activity is in the public interest when it is regulated, predictable and has a material 

positive impact on society. The exemptions requested here would allow for aerial cinematography 

pursuant to existing FAA regulations, as well as petitioner's Motion Picture and Television Operations 

Handbook, and Flight Operations & Company Operations handbooks. The rules, procedures, and 

processes contained therein create a safe and highly predictable process by which aerial cinematography

may take place. Granting the requested exemptions will give the public access to the process of aerial 

cinematography and the products that are the result of those endeavors. 

In the past the public had access to aerial cinematography only through hiring a conventional helicopter, 

airplane, or other mechanism which, by their nature, are larger than UAS, require liquid fuel, travel at 

much higher speeds, and have a greater potential to negatively impact more people in the event of an 

incident or accident. Here all aspects of flight including pilot training and check-out, site evaluation, 

mission planning, contact with the appropriate FSDO, pre-flight inspections, crew briefings and site 

security during flight operations will ensure a level of safety to the public equivalent, or higher than that 

provided in current rules. As such the public will benefit from safe UAS operations will setting 

measures to safely integrate UAS into the NAS. 
Page 30 of 31

Why Granting the Exemptions Would Provide an Equivalent Level of Safety to Current Rules: 

Granting the requested exemptions would provide a level of safety equivalent to that provided in current 

rules, and in some cases greater, due the specificity with which Motion Picture and Television 

Operational Handbook and Flight Operations & Company Operations Handbook identify unique aspects 

of UAS, and lay out methods of operation which emphasize safety of the public, protection of private 

property, yet allows operation of UAS. In all circumstances which the FAA has already set safety 

guidelines for traditional aircraft, the operational characteristics of the UAS have been considered, and 

detailed plans put in place to adjust the current rules while maintaining safety for persons and property 

on the ground, as well as ensuring safety and security for those operating in the NAS. 
Page 31 of 31

A Summary That Can Be Published In The Federal Register: The rules from which EagleVision 

Productions, LLC. seeks exemption: 

EagleVision Productions LLC seeks exemption from the following: 14 C.F.R. §§ 21 Subpart H, 

45.23(b)??, 61.113 (a) & (b), 91.7(a), 91.9(b), 91.103(b)(2), 91.105, 91.109, 91.119, 91.121, 91.151(a), 

91.203(a) & (b), 91.405, 91.407, 91.409, 91.417 (a) & (b). 

A Brief Description of the exemptions EagleVision Productions, LLC Seeks:

These exemptions will permit EagleVision Productions LLC., to operate small Unmanned Aircraft 

Systems (UAS) for aerial cinematography and photography at controlled locations for use in motion 

picture, television, and music industries, and other legally permissible uses.

Privacy 

Applicant submits the attached Motion Picture and Television Operations Manual and Flight Operations 

& Company Operations Handbook as Confidential and Proprietary documents under 14 CFR 11.35 (b) 

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

Motion Picture and Television Operations Manual and Company Operations Handbook and Flight 

Operations & Company Operations Handbook contain operating conditions and procedures that are not 

available to the public and are protected from release under the Freedom of Information Act 5 USC 552 

et. seq.