15, 2015

U.S. Department of Transportation

Document Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14

C.F.R., Part 11, George Walsh d/b/a GP Walsh Productions (“GP Walsh Productions”), operator 

of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial videography of 

professional football game and training facilities, requests a limited exemption from the belowlisted regulations to allow commercial operation of its sUASs, provided that the proposed sUAS

operations comply with the conditions outlined below or as established by the Federal Aviation

Administration (“FAA”) under Section 333.

The name and address of the applicant is: GP Walsh Productions, 3576 E Longhorn Dr, 

Gilbert, AZ 85297, c/o George Walsh,(480) 275-4526, info@gpwalshproductions.com

GP Walsh Productions makes this request under the “summary grant” process that the

FAA announced in April 2015.

1 This request is similar in all material respects to a number of

recent grants of exemption, including Grant of Exemption No. 11488 to Advanced Aerial 

Cinematography, LLC (FAA Docket No. 2014-0090).

2

Regulations from which the exemption is requested:

14 C.F.R. § part 21 subpart H

14 C.F.R. § 45.23 (b)

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 91.7 (a)

14 C.F.R. § 91.9 (b) (2)

14 C.F.R. § 91.103 (b)

14 C.F.R. § 91.109

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a) & (b)

1

See FAA Summary Grants Speed UAS Exemptions, available at

https://www.faa.gov/news/updates/?newsId=82485.

2 The use limitations and arguments in this application are nearly identical to those contained in Advanced Aerial

Cinematography’s November 24, 2014 application and the FAA’s May 5, 2015 approval of that application

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14 C.F.R. §§ 91.203 (a) & (b)

14 C.F.R. § 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. § 409 (a)

14 C.F.R. §§ 417 (a) & (b)

GP Walsh Productions proposes that it receive an exemption to use sUAS to create 

video and photographic footage. GP Walsh Productions would use the imagery and footage for 

Real Estate sales, Wedding videography and photography, land surveying, aiding civil 

authorities and emergency personal, commercial and corporate videography and photography, 

documentaries, structural inspections, production of television programs, and educational 

purposes. in the event of a “closed set” and whenever in the presence of personnel GP Walsh 

Productions would obtain the consent of all personnel in the vicinity in which the sUAS may

operate.

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system (“NAS”) or to persons and property on the ground. GP Walsh Productions

proposes that the exemption apply to civil aircraft that operate within the limitations listed below. 

These

limitations were established in the FAA’s grant of Advanced Aerial Cinematography’s request for an

exemption:

1. The sUAS will weigh 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 sUAS may not be operated at a speed exceeding 87 knots (100 miles per hour). 

GP Walsh Productions 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 sUAS operating airspeed 

recommended by the aircraft manufacturer.

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

(AGL). Altitude will be reported in feet AGL.

5. The sUAS will be operated within visual line of sight (VLOS) of the Pilot in Charge 

(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 will utilize a visual observer (VO). The sUAS will be operated within 

the 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 the VLOS capability. The VO and 

PIC will be able to communicate verbally at all times; electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC will ensure that the VO can perform the duties required of the VO.

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7. This exemption and all documents needed to operate the sUAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents will be accessible during sUAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and will be

followed. Otherwise, GP Walsh Productions will follow the procedures as outlined 

in its operating documents. GP Walsh Productions may update or revise its

operating documents. It is GP Walsh Productions’ responsibility to track such

revisions and present updated and revised documents to the Administrator or any

law enforcement official upon request. GP Walsh Productions will also present 

updated and revised documents if it petitions for extension or amendment to this 

grant of exemption. If GP Walsh Productions determines that any update or

revision would affect the basis upon which the FAA granted this exemption, then GP 

Walsh Productions 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. GP Walsh Productions 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 will conduct a pre-flight inspection and determine the

sUAS is in a condition for safe flight. 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 form operating until the necessary maintenance has been

performed and the sUAS is found to be in a condition for safe flight.

11. GP Walsh Productions will follow the sUAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components.

12. Each sUAS operated under this exemption will comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC 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.

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14. GP Walsh Productions will not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the sUAS in a manner consistent with how 

the sUAS 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 will 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 sUAS in a manner consistent with

how the sUAS 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 will operate the sUAS with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations will be conducted under visual meteorological conditions (VMC). GP 

Walsh Productions will not operate flights under special visual flight rules (SVFR).

16. The sUAS will not operate within 5 nautical miles of an airport reference point (ARP)

as denoted in the current FAA Airport/Facility Director (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 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 sUAS loses communications or loses its GPS signal, the UAS will return 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 will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the sUAS 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 will be conducted in accordance with an ATO-issued COA. The 

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 will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be

as large as practicable. 

23. Documents used by GP Walsh Productions to ensure the safe operation and flight of 

the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be

available to the PIC at the Ground Control Station of the sUAS any time the aircraft 

is operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

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24. The sUAS will remain clear and give way to all manned aviation operations and 

activities at all times.

25. 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 sUAS and/or debris in the event of 

an accident. GP Walsh Productions will 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 will 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.

c. The PIC, VO, operator trainees, essential persons, or individuals who have

signed consent forms are not considered nonparticipating persons 

under this exemption.

26. All operations will 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.

27. 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 exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations 

apply:

28. GP Walsh Productions will have a motion picture and television

operations manual (MPTOM) as documented in this grant of exemption.

29. At least 3 days before aerial filming, GP Walsh Productions 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 sUAS aerial filming 

conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the sUAS;

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d. Make, model, and serial or N-Number of the sUAS to be used;

e. Name and certificate number of sUAS 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 will 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.

30. 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, the sUAS operations will comply with all applicable parts of

14 CFR including, but not limited to, parts 45, 47, 61, and 91. GP Walsh Productions incorporates 

all arguments in support of the petition made in Advanced Aerial Cinematography’s November 24,

2014 application for exemption.

Federal Register Notice

As stated above, publication in the Federal Register is unnecessary because this 

application meets the FAA’s criteria for summary approval. To the extent that the FAA 

determines that publication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, 

subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)

(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151(a) & (b); 91.203 (a) and (b);

91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a) and 91.417 (a) & (b)

to operate commercially a small unmanned vehicle (55 lbs or less) in 

videography operations.

The Exemption is in the Public Interest

As demonstrated above, the proposed sUAS operations would minimize the risk of harm to

individual safety or damage to the NAS and property. The operations proposed by GP Walsh 

Productions would provide tremendous public benefits by providing perspectives that would 

otherwise not be possible by any other methods. The sUAS operations as described in this 

application will be far safer, more environmentally friendly, and more efficient than use of 

helicopters or other aircraft to capture the required footage.

The conditions outlined in this petition clearly satisfy Section 333’s exemption criteria 

regarding “size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight,” and therefore the proposed operations would not “create a

hazard to users of the national airspace system or the public or pose a threat to national security.”

As discussed above, GP Walsh Productions agrees to use limitations that are substantially identical

to those contained in the FAA’s recent grant of exemption for Advanced Aerial Cinematography.

Accordingly, the proposed UAS operations of GP Walsh Productions should not raise safety or 

national security concerns, and should receive summary approval.

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Please do not hesitate to contact the undersigned if you need additional information.

Respectfully submitted,

George Walsh 

GP Walsh Productions

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GP Walsh Productions

List of Aircraft

1

Make and Model 

DJI Innovations

F550

Type 

Hexa-rotor

Weight 

6 lbs. (inclusive of camera and 

battery

DJI Innovations

Phantom 2

Quad-rotor 3 lbs. (inclusive of camera and

battery)

2 DJI Innovations

Inspire 1

Quad-rotor 6 lbs. (inclusive of camera and

battery)

3 Tarot 680 Pro Hexa-rotor 9 lbs. (inclusive of camera and 

battery

4 3D Robotics Solo Quad-rotor 4 lbs. (inclusive of camera and

battery)

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