Attorney, Jerald A. Lavin,

Jerald A. Lavin LTD.

324 Osprey Point Drive

Osprey, FL 34229

941-320-0077

lavin77@comcast.net

PETITIONER:

Matthew D. Lavin a/k/a Aerography

1350 45th AVE, #B

Capitola, CA 95010

Tel- 917-509-3201

matthew@aerography.net

Filed Electronically Via Regulations.gov October 21, 2015

Dan Ngo

FAA Office of Rulemaking

800 Independence Ave. SW 

Washington, DC 20591

Re: FAA-2015-1901

Dear Mr. Ngo:

Attached please find a Motion Picture and Television Operations Manual (“MPTOM”) prepared 

by Matthew D. Lavin a/k/a Aerography for the above-referenced docket. The MPTOM includes, 

at Appendix B, a description of the aircraft makes, models, and types, as requested, for the

proposed UAS operation.

This letter and the attachment were filed online at regulations.gov in Docket No. FAA2015-1901.

Please contact me if you have any questions.

Sincerely,

Attorney, Jerald A. Lavin,

 Jerald A. Lavin LTD.

324 Osprey Point Drive

Osprey, FL 34229

941-320-0077

lavin77@comcast.net

Attachment

Motion Picture and Television

Flight Operation Manual

Matthew D. Lavin a/k/a Aerography

1350 45th AVE, #B

Capitola, CA 95010
2

Table of Contents

A. Purpose............................................................................................................................... 4

B. Pilot/Operator Organization............................................................................................ 4

C. Pilots To Be Used During Filming................................................................................... 4

D. List of Aircraft by Make, Model and Serial or Registration Number ......................... 4

E. Distribution and Revision ................................................................................................ 4

F. Persons Authorized........................................................................................................... 5

G. Area of Operations............................................................................................................ 5

H. Plan of Activities ............................................................................................................... 5

I. Permission to Operate ...................................................................................................... 6

J. Security .............................................................................................................................. 6

K. Briefing of Pilots and Production Personnel .................................................................. 7

L. Certification/Airworthiness ............................................................................................. 7

M. Pilot Personnel—Minimum Requirements..................................................................... 7

N. Limitations......................................................................................................................... 7

O. Communications ............................................................................................................... 7

P. Accident Notification ........................................................................................................ 8

Q. Recall/Stop Procedures..................................................................................................... 8

R. Aerobatic Competency ..................................................................................................... 8

Appendix A 

Appendix B
3

Revision Control Page

Revision # Date Initials
4

Motion Picture and Television Flight Operation Manual

A. Purpose

This Manual has been developed by Matthew D. Lavin a/k/a Aerography (“Aerography”) in 

conjunction with an application for an exemption from a limited number of regulations pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as 

outlined in Aerography’s exemption application dated May 08, 2015, for use of sUAS to gather 

footage from closed-set locations in the NAS. Aerography, and other personnel when applicable 

will comply with the policies, procedures and conditions of this manual, whenever motion 

picture or television flight operations are performed.

B. Operator Organization

Matthew D. Lavin a/k/a Aerography- Operator

1350 45th AVE, #B, Capitola, CA 95010

# 917-509-3201

C. Pilots To Be Used During Filming

Pilots to be used during filming will be included in the Plan of Activities to be filed at least three 

(3) days prior to each scheduled filming, pursuant to Section H, infra, with the local FSDO 

having jurisdiction over the area of proposed filming. The list of pilots will include each pilot’s 

pilot certificate number as well as special pilot authorizations or endorsements, if applicable.

D. List of Aircraft by Make, Model and Serial or Registration Number

A list of aircraft to be used appears in Appendix B, infra. Furthermore, any aircraft to be used in 

the proposed filming shall be listed by make, model and serial or registration number in the Plan 

of Activities to be filed at least three days prior to each scheduled filming, pursuant to Section H, 

infra, with the local FSDO having jurisdiction over the area of proposed filming.

E. Distribution and Revision

Aerography will issue a copy of this manual, including all revisions, to all personnel involved in 

sUAS operation. All recipients are required to keep their manuals up-to-date with any furnished 

revisions.

Amendments in FARs and normal usage will frequently indicate a need for additions, deletions, 

or corrections of selected subject matter in this manual. Revisions to the manual will be issued 

periodically to reflect these changes. In addition, manual users who observe or experience a 

need for change are encouraged to submit their suggestions to the Chief Financial Officer for 

review and consideration.

Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at 

least 15 days before the proposed effective date. Revisions will be noted on the Revision
5

Control Page at the front of this Manual and will be noted in bold in this Manual. Each 

subsequent revision of the Manual will be distributed to all company personnel involved in 

sUAS operation.

F. Persons Authorized

Section 91.119(c) is waived only with respect to those participating persons, vehicles, and 

structures directly involved in the performance of the actual filming. The pilot-in-command and 

certificate holder shall ensure that no persons are allowed within 500 feet of the area except those 

consenting to be involved and necessary for the filming production. This provision may be 

reduced to no less than 200 feet in the event that a suitable, equivalent level of safety can be 

achieved. An equivalent level of safety may be determined by evaluation of the filming 

production area and the degree of terrain features, buildings, etc. that will provide a safety barrier 

to observers.

Prior to any filming, the pilot-in-command and certificate holder shall be responsible for 

obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as 

outlined above) of the filming. Such consent forms shall be maintained by the operator for a 

period of at least six (6) months following the filming.

G. Area of Operations

Aerography’s area of operations shall be within the continental United States.

The pilot/operator shall coordinate with the FSDO having geographic responsibility over the area 

of the filming operations.

H. Plan of Activities

At least three (3) days prior to any scheduled filming, Aerography shall submit a written plan 

of activities to the local FSDO having jurisdiction over the area of proposed filming. The plan 

of activities shall include the following:

1) Dates and times for all flights.

2) Name and phone number of operator responsible for the filming production 

event.

3) Name and phone number of the person responsible for the on-scene operation 

of the sUAS.

4) Make, model, and serial number or registration number of aircraft to be used 

and type of airworthiness certificate, including Category (CAT).
6

5) Names and certificate numbers of pilots involved in the filming production 

event.

6) A statement that permission has been obtained from property owners and/or 

local officials to conduct the filming production event; the list of those who 

gave permission will be made available to the inspector upon request.

7) Signature of exemption holder or a designated representative.

8) A general outline, description or summary of the flight activity schedule, 

including maps or diagrams of any area, city, town, country, and/or state over 

which filming will be conducted and the altitude essential to accomplish the 

operation.

At the discretion of the FSDO, the 3-day notification may be waived. Justification of the 

exception to the 3-day requirement is needed.

Aerography acknowledges that prior to the beginning of any filming operations, the plan 

of activities must be accepted by the FAA.

I. Permission to Operate

Before any flight operation is conducted at less than 500 feet under the provisions of the 

certificate of waiver and this Manual, the operator will obtain permission to conduct these 

operations from property owners and local officials as necessary or appropriate. Persons from 

whom permission may be required are listed below:

1) Property owners

2) Law enforcement officials

3) Fire department officials

4) Local, state and federal government

Aerography personnel obtaining such permission will do so in writing whenever practical; 

however, verbal permission is acceptable otherwise. A standard permission form is provided in 

Appendix A and may be used when obtaining written permission. Written permission forms will 

be maintained at the job site until flight operations are completed, and then turned over

Aerography to be kept on file for a minimum of six (6) months. These forms will be made

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

J. Security

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

to devise a plan of securing the area(s) of operation from all unauthorized persons, vehicles and
7

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

become unsecured or for any other reason in the interest of safety.

K. Briefing of Pilots and Production Personnel

Prior to the start of any operation under the provisions of this Manual, the pilot in command will 

conduct a briefing of all procedures to participating personnel of the risks involved, emergency 

procedures, and safeguards to be following during the filming production event. Personnel will 

also be briefed on any additional provisions that may be issued by the local FSDO, including the 

location of boundaries or any other time limits.

L. Certification/Airworthiness

Prior to any flight operation, the pilot in command will conduct a pre-flight inspection in 

accordance with Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 91 and 

applicable operating limitations. The pre-flight inspection will 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 sUAS, the aircraft will be prohibited from 

operation until the necessary maintenance has been performed and the sUAS is found to be in a 

condition for safe flight.

Aerography will follow the sUAS manufacturer’s maintenance, overhaul, replacement, 

inpsection and life limit requirements for the aircraft and aircraft components. Each sUAS

operated under this exemption will comply with all manufacturer safety bulletins.

The aircraft to be used may be certificated in any CAT, including experimental, provided the 

requirements of 14 CFR part 91, §§ 91.7, 91.9, and 91.203 are met.

M. Pilot Personnel—Minimum Requirements

The pilot in command will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will 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 also will 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.

N. Limitations

Aircraft operations shall conform with the limitations set forth in Aerography’s request for

a limited exemption, dated May 08, 2015, docket number FAA-2015-1901.

The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude will be reported in feet AGL.

The aircraft will not be operated during night, as defined in 14 CFR § 1.1.

O. Communications
8

Prior to the start of any operation covered by this Manual, the pilot in command will formulate a 

plan to provide communications capability to all participants during the actual operation and 

filming. Oral, visual or radio communications may be used as long as it is effective and is 

capable of keeping the participants continuously apprised of the current status of the operation.

P. Accident Notification

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

immediately notify the NTSB pursuant to 49 CFR § 830 and take steps to preserve and protect 

the accident scene.

Q. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the participants 

continuously apprised of the current status of operation.

R. Aerobatic Competency

If the filming operations require the issuance of FAA Form 8710-7, see Volume 5, Chapter 9, 

Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.
9

APPENDIX A

Aerography’s 

Permission to Conduct Operations Form

In signing this form, I am giving Aerography permission to operate its aircraft at less 

than 500 feet from property, or, in some jurisdiction in which I am responsible for or 

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

Name:

Title:

Location:

Date of

Operation:

Basis of Authority to Grant Permission:

Signature:

Date:

Aerography Representative Receiving Permission:
10

APPENDIX B

Aerography

List of Approved Aircraft

1

Make and Model

Gryphon Dynamics GD-6-

HX900F

Type

Hexacopter

Weight

25 lbs. (inclusive of 

camera and battery)

 2 DJI S900 Hexacopter 25 lbs. (inclusive of 

camera and battery)

3 DJI S1000 Octocopter 25 lbs. (inclusive of 

camera and battery)

4 DJI Innovations Inspire 1 Quad-rotor 6 lbs. (inclusive of 

camera and battery)