PROPRIETARY TO CLOUDD8TA LLC

CLOUDD8TA MOTION PICTURE AND TELEVISION OPERATIONS MANUAL

CLOUDD8TA LLC

MOTION PICTURE AND TELEVISION OPERATIONS MANUAL 

THOMAS JENNINGS, AUTHOR

VERSION 20160420

A. Pilot/Operator Organization: CLOUDD8TA LLC - NEVADA

· Pilot/operator name: Thomas Jennings

· Address: 505 Fairway Dr, Tahoe City CA 96145

· Telephone number of applicant or responsible person: 1-530-386-6677

B. Distribution and Revision. This section contains procedures for revising the 

operations manual to ensure that all manuals are kept current. Revisions for the 

accepted operations manual shall be forwarded to the FSDO at least 15 days before the 

proposed effective date.

1. CloudD8ta Manuals with changes and version control numbers shall be posted here.

MPTOM Version 1.0 — NO REVISIONS as of 20160420;

2. Aircrew are responsible for reading, understanding and following the latest version of 

the CLOUDD8TA LLC Motion Picture & Television Operations Manual.

3. Current, FAA-approved versions will be emailed to aircrew and available digitally for 

reference at areas of CloudD8ta operations.

4. Approved versions will be submitted to the local FSDO with each production request 

to ensure CloudD8ta and the FAA are synced. CloudD8ta aircrew shall sign a GO/NOGO that they have read ad understand this document, and that they have access to 

online flight resources including this document before flying operations in support of a 

commercial production begin.

C. 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. This operations manual includes procedures listed below to 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 
PROPRIETARY TO CLOUDD8TA LLC

200 feet if an equivalent level of safety can be achieved and the Administrator has 

approved it. For example, an equivalent level of safety may be determined by an aviation 

safety inspector’s (ASI) evaluation of the filming production area to note terrain features, 

obstructions, buildings, etc. Such barriers may protect nonparticipating persons (e.g., 

observers, the public, or news media) from debris in the event of an accident.

1. Pre-Production through Production - CloudD8ta is a part of the filmmaking process 

from concept to debrief, promoting an aviation culture of safety and risk mitigation. 

Education of FAA and safety-driven MPTOM requirements, production procedures and 

set safety enforcement will begin each production process to ensure safe aerial 

operations standards.

2. Before Production - CloudD8ta pilots, aircrew or qualified air representatives will 

attend production meetings to identify and mitigate risk to an acceptable level, opting the 

more conservative value of either CloudD8ta or Production. Everyone’s safety is our 

number one priority.

3. Before Production - CloudD8ta pilots will educate key production personnel on 

operations and hazard areas associated with CloudD8ta’s UAS operations, and in 

particular UAS takeoff, transit corridors and divert zones.

3.1. A “divert zone” is a pre-identified area to land as soon as possible or ditch an 

emergency aircraft that cannot make it to a pre-planned landing zone. CloudD8ta will 

work with local authorities and/or production to define a divert zone before flying takes 

place.

3.2. No persons are allowed within 500 feet of the area except those consenting to be 

involved and necessary for the filming production. Colored cones that mark 500 feet 

and/or 200 feet from the Take-off Zone will enforce this and all expected flight zones. 

Personnel consenting to be within this zone must consent by signing a LETTER OF 

CLOUDD8TA OVERFLIGHT OF PRODUCTION SET; UAS or AERIAL AWARENESS

with production on behalf of CloudD8ta, for which consenting set or production personnel

will receive approval to work near UAS systems.

3.3. Personnel working under an aircraft (Manned or UAS) or at 100 feet or less shall be 

issued a CloudD8ta wristband, colored hat or colored jacket to clearly communicate with

CloudD8ta Aircrew that they are approved for production work at 100 feet or less during 

aerial operations. Hazards shall be thoroughly briefed by CloudD8ta Aircrew.

3.3.1. Default color codes are as follows:

3.3.1.1. NEON GREEN = CLEARED ALL ACCESS

3.3.1.2. NEON YELLOW = CONSENTING PERSONNEL

3.3.1.3. NEON RED (or no color) = NON PARTICIPATING PERSONNEL

3.3.1.4. WHITE = SAFETY PERSONNEL

3.3.2. This provision may be reduced to no less than 200 feet if an equivalent level of

safety can be achieved and the Administrator has approved it.

3.3.3. Cordon rope, Safety Cones or signs will match the default colors above:

3.3.3.1. NEON GREEN = TAKEOFF, CORRIDOR, SET OR LANDING ZONE

3.3.3.2. NEON YELLOW = 100 FEET TO UAS / AIR OPERATIONS

3.3.3.3. NEON RED = 500/200 feet to UAS / AIR OPERATIONS

3.3.3.3.1. These colors help personnel to know where they may work by matching their 

color to where they must stop on set when UAS / Aerial

Operations are in effect.

4. Day of Production - CloudD8ta pilot in command (PIC) will attend the production day’s 

(or location’s) safety brief or initiate a safety brief at the appropriate time to include all 
PROPRIETARY TO CLOUDD8TA LLC

affected ‘entities’ on set. Each entity (ie Department Head) is responsible share the day’s 

specific aerial risks, mitigation plan and safety plan (such as times of operations, what to 

expect from CloudD8ta aircrew, and how a set member should react during an 

emergency) with all members of their entity.

5. Throughout Production - Signs and placards will be on set at entry and gathering 

points to educate and inform crew members of UAS operations and identify key safety 

features on set.

5.1. Closed-set entry and exit points will include a placard which informs and educates 

personnel of the UAS operations, foreseeable hazards associated with typical UAS

operations and boundaries on set.

6. Throughout Production - A cohesive, well communicated CloudD8ta UAS Aviation 

Operations

Plan will dominate each production day, with the FSDO in the loop before and during 

UAS operations. Clear communication of expectations is key.

7. Before Takeoff - All CloudD8ta Aircrew, Operations Support Crew and Safety Crew 

are identified by unique clothing such as colored vests, wrist-bands, jackets and hats 

that identify them as part of (UAS) FLIGHT OPERATIONS.

7.1. To clear for takeoff, the safety observer will first receive the “Personnel, All Clear”

from non-participants through a Production representative, followed by a “Take-Off, All 

Clear” by CloudD8ta Safety.

8. Takeoff - With the set or flight path cleared of non-participants to 500’/200’ the Pilot in

Command will visually scan for movement near the lift-off area before flight. For UAS, 

this includes a scan before arming or unlocking the UAS. (locks restricting lift off) With 

100’ minimum clear and no movement toward the 100’ lift-off zone, the PIC, when he or 

she believes all safety of flight requirements have been met including stable 

environmental conditions, will request a loud solid-state tone for 2-3 seconds or utilize a 

suitably loud Public Address system to announce “(UAS) AERIAL OPERATIONS ARE 

NOW IN EFFECT.”

After the tone or announcement is complete, the PIC may lift off for flight.

9. UAS Flight - CloudD8ta will utilize marked “UAS CORRIDORS” to follow from the lift 

off location to the film location. This allows non-participating ground personnel to avoid 

active UAS operations areas by 500 feet or 200 feet when waived by the Administrator 

(3.3.1).

10. Flight - CloudD8ta Safety may clear non-aircrew set personnel across transit 

corridors or lift-off zones once the UAS is outside of 500’/200’ from the affected zone. 

CloudD8ta Safety connected visually and/or by radio will attempt to keep the regions 

clear during air operations. Five minutes before return, the transit corridor and lift-off 

zone will be cleared.

11. Throughout the Flight - A red safety flag will be hoisted and/or flashing lamp will be 

illuminated to indicate a CloudD8ta UAS or asset is airborne. This red flag and lamp will 

be placed near the production crew and/or on set. CloudD8ta Safety Observer or a 

delegate is responsible for raising and lowering the flag and illuminating or extinguishing 

the set safety lamp.

12. Flight Return - At five minutes to return, Safety will verbally announce the time to 

return, counting down each minute to 1 minute.

12.1. Safety and designated set safety personnel will physically point toward the UAS 

with a red flag as it returns. At no time will a UAS overfly a non-participating individual.

13. Landing - The PIC must ensure the landing zone, a circular zone with a 100’ radius 

for UAS, is clear. Cones, placards, signs and/or colored paint on the ground may be 
PROPRIETARY TO CLOUDD8TA LLC

used to indicate safety distances for LZ entry and exit.

14. UAS After Landing - After the UAS has landed and there are no UAS operations in 

effect, a double tone will sound or a public address announcement stating “UAS FLIGHT

OPERATIONS ARE COMPLETE. NO AIRCRAFT ARE AIRBORNE AT THIS TIME.”

15. Post Flight - After the system is locked in place or de-armed, personnel may be 

permitted to transit lift-off zones and transit corridors. This will be signaled by lowered 

flags, no set safety lights illuminated, and/or safety crew motioning or vocalizing that 

production personnel are cleared to pass.

D. Area of Operations. There will be a variety of operational needs, depending upon 

the activities of the applicant. CloudD8ta pilot/operators may conduct activities 

throughout the entire United States and its territories and possessions. CloudD8ta

defines the area authorized by the Certificate of Waiver as the entire United States and 

its territories and possessions. While the waiver is issued by the pilot/operator’s local 

FSDO, the pilot/operator must coordinate with the FSDO having geographic 

responsibility over the area of the filming operations. 

E. Plan of Activities. CloudD8ta pilot/operators will submit an Aerial Production 

Integration (API) plan 3 days before the first scheduled filming is to take place. This 

written plan of activities will be delivered to the local FSDO having jurisdiction over the 

area of proposed filming. CloudD8ta understands the 3‐day notification may be waived 

with the concurrence of the FSDO provided justification for the exception to the 3‐day 

requirement is included as a required item. The CloudD8ta API, with a plan of activities, 

shall include the following as a minimum:

5. Dates and times for all flights.

5.1. UAS - A Flying Window to include all expected flight times will be provided for UAS 

flights, which often take off, and land several times per hour.

5.1.1. Example: UAS AM GO: 0900L - 1030L, UAS PM GO: 1230L - 1630L.

6. Name and phone number of person responsible for the filming production event.

6.1. Cell or mobile number will be included for on set contact with production leadership.

7. Name and phone number of person responsible for the aircraft.

7.1. Cell or mobile address should be included for on-set contact with PICs.

8. Make, model, and serial or N-number of aircraft to be used and type of airworthiness 

certificate, including CAT.

9. Name and certificate number of pilots involved in the filming production event, 

including any notation of external load endorsements or aerobatic competency, if 

required.

10. A statement that the waiver holder 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 from the waiver 

holder.

10.1. CloudD8ta must integrate with production for approvals. When approved in writing, 

include the paperwork here or as an attachment.

11. Signature of waiver holder or representative.

12. 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 minimum altitudes 

essential to accomplish the operation.

F. Permission to Operate. This motion picture and television operations manual 

specifies the requirements and procedures for the pilot/operator to obtain permission 

from property owners and/or local officials (e.g., police, sheriff, or fire departments) as 

appropriate for the conduct of all operations when operating under the provision of the 
PROPRIETARY TO CLOUDD8TA LLC

waiver.

CloudD8ta will comply film production requirements and procedures. Sources cited 

include:

1. Production operating in the area in which aerial filming has been requested.

2. State or Local resources listing film requirements and procedures for aerial 

production.

3. Local production resources such as guilds, law enforcement agencies and service 

providers.

4. Other online resources from official sources.

G. Security. CloudD8ta will, in association with the production being supported (film, 

commercial, etc...) specify the method of security to be provided to exclude all persons 

not directly involved with the operation from the location. In the interest of safety, 

provisions will be made to stop activities when unauthorized persons, vehicles, or aircraft 

enter the operations area, or for any other reason. If security is not needed “Not 

Applicable” will be entered.

1. CloudD8ta will work with production to ensure persons not directly involved with the 

operation from the location are excluded. Sources of exclusion can include:

1.1. Airport Security

1.2. Set Security provided by Production

1.3. Police and Law Enforcement to include Flightline Security

1.4. CloudD8ta Set Safety (Part of CloudD8ta)

1.4.1. CloudD8ta Set Safety members wear white or black with the word SAFETY

1.5. Other measures to include proven and emerging technology

H. Briefing of Pilot/Production Personnel. CloudD8ta procedures will include an 

instructional brief for participating personnel of the risks involved, emergency 

procedures, and safeguards to be followed during the filming production event. 

Production personnel will also be briefed on additional provisions that may be issued by 

the FSDO that has geographic responsibility for the operational area, including the 

location of boundaries or time limits. The CloudD8ta briefing shall cover:

• Authorization for motion picture and television certificate of waiver and the attached 

special provisions,

• Operations manual,

• Plan of activities,

• Aircraft parking and starting to include UAS T/O and Transit Corridors,

• Taxi procedures,

• Radio communications,

• Takeoff procedures to include additional UAS precautions,

• Aviation activities to be conducted during the filming production event,

• Approach and landing procedures to include UAS specific events,

• Recall procedures,

• Emergency procedures to include UAS Lost Link and Auxiliary ‘Divert’ zones,

• Risks to participating personnel, UAS Risk Mitigation and

• How to control nonparticipating persons.

I. Certification/Airworthiness. The aircraft may be certificated in any CAT, including 

experimental, provided the requirements of §§ 91.203, 91.313, and 91.319 are met. For 

UAS specific operations, a COA or Waiver stating aircraft approved for flight will be 

maintained.

Procedures shall be included to ensure that aircraft inspections will be in accordance 

with the applicable parts of 14 CFR part 43 or 91, or the assigned operating limitations.
PROPRIETARY TO CLOUDD8TA LLC

1. CLOUDD8TA LLC 333 Exemption No. 14248, Regulatory Docket No. FAA-2015-4863

J. Pilot Personnel—Minimum Requirements. CloudD8ta establishes and specifies the 

minimum pilot requirements. Minimum requirements shall meet or exceed the following:

1. A current U.S. pilot certificate with ratings appropriate to the CAT, class, and type (if 

applicable) of aircraft to be used under the terms of the waiver.

2. At least 500 hours logged as the PIC and at least 20 hours logged as the PIC in the 

aircraft type.

2.1. UAS Standards

2.1.1. At least 500 hours logged as a PIC with 20 hours logged as PIC in similar Aircraft 

Type.

2.1.1.1. At least 100 hours of UAS total time as a UAS/RPA pilot.

2.1.1.2. Revised UAS currency requirement includes at least 10 UAS takeoffs and 

landings with a similar UAS type in the preceding 30 days.

3. A minimum of 100 hours in the CAT and class of aircraft to be used.

3.1. Defined - UAS Class: Rotorcraft (Quad versus Hexi) using similar control software 

are considered to be the same class.

4. A minimum of 5 hours in the make and model aircraft to be used under the waiver.

4.1. UAS - At least 5 hours logged as a UAS pilot with a similar UAS type (single blade 

or multi-rotor).

K. Communications. The following procedures shall provide communications capability 

to all participants during the actual operation and filming. The communications 

procedures outlined below will be able to keep all the participants apprised of the current 

status of the operation.

1. General: Radio communications between aircraft and ATC are essential. Frequency

plans will be included under the API: COMM PLAN to the FSDO and shared with the 

ATC facility serving the Flight.

2. Radio communication between Flight and Production shall be handled on two or more 

radios. A primary radio will be reserved for ATC and air traffic-related communications

while a secondary radio shall be for inter-flight and production-to-flight communications.

2.1. Aircraft equipped with a single radio may be utilized provided the aircraft is cleared 

by ATC (over the radio or by a brief) to be switch to a discrete Production frequency. 

This Production frequency will be deconflicted and optional check-in times may be 

prebriefed or shared with ATC as desired.

2.2. A production number near the set should be passed to the servicing ATC facility as 

a secondary form of communication in order to communicate with the filming location (a

pre-designated person called a Production Representative), should the need arise.

2.2.1. ie - If terrain is blocking an ATC call to the Flight, the production number can be 

utilized to communicate with the Production Rep and indirectly with the flight.

2.2.1.1. Timing may be used to climb and re-establish contact at pre-planned intervals if 

communication gaps are anticipated.

2.2.1.2. Pre-planned telephonic check-ins by production crew (on location) may be 

requested to relay information from aircrew to ATC or a controlling agency.

3. UAS: PIC and designated aircrew (Pilot, Payload, Safety Observer) will communicate 

through the Pilot to build situational awareness (SA). Communications to the UAS flight

will be routed through the PIC.

3.1. The PIC may designate a qualified aircrew member to receive and transmit 

communications or relay information using crew resource management (CRM).

3.1.1. Good CRM Techniques to load share communications responsibilities include: 
PROPRIETARY TO CLOUDD8TA LLC

3.1.1.1. Pre-briefing expectations.

3.1.1.2. Positive hand-off of item or event.

3.1.1.3. Verbal explanation of expectation during a non-critical phase of flight.

3.2. Verbal communication, amplified voice, audio signals and radio devices will be

utilized to connect aircrew with production to maximize safety and situational awareness 

during all closed-set UAS operations.

3.2.1.Inter-crew communications will be primarily verbal while UAS operations are

LOS. Crew communication audio will be recorded under all circumstances.

3.2.1.1. The Safety Observer may at times be some distance away from the PIC to gain 

a different vantage or light angle. During such times, amplified audio such as a bull-horn 

type device, lights or radio device will be utilized.

3.2.1.2. Every effort shall be made to utilize hands-free radio systems to include 

headsets or multi-way communications setups to preclude heads-down use.

3.2.2. On set communications between Aircrew and Production will be verbal and/or over 

a radio utilizing a discrete UAS OPS frequency.

3.2.2.1. An additional AIR OPS EMER frequency channel will be kept clear when

2 or more UAS systems are planned to be airborne simultaneously.

3.3. The Safety Observer and all appointed set safety crew (visually spanning the 

planned film production location) will primarily utilize voice and/or hand-held battery

powered radio devices. A loudspeaker system will be utilized to communicate key

portions of flight in order to increase production crew awareness of UAS operations.

3.3.1. UAS EMERGENCY COMMUNICATIONS include:

3.3.1.1. Three short tones repeated or the words “Emergency, Emergency,

Emergency.” and a phrase such as “All UAS Systems Land as Soon as

Possible.” For on-set personnel intrusions incurring a potential safety hazard, a 

malfunction such as UAS control issue, a communication disruption or visibility inhibiting 

LOS requirements.

3.3.1.2. A long tone or wavering tone or the words “Take Cover! Take Cover! Take

Cover!” for UAS systems that have suffered a critical malfunction and cannot be 

controlled. (not for Lost Link when the UAS is following a pre-planned return route that 

appears to be correct.)

3.3.1.3. Three long tones or the words “UAS System Malfunction.” and

“Impending Loss of Power, Seek Shelter.” This will be used for emergencies where 

partial control is maintained and the UAS can be communicated with.

Every attempt shall be made to evacuate non-essential personnel and seek a suitable 

ditch or divert location. Plain English will be used to communicate the PICs intention with 

those on location. Avoid over flight of personnel.

4. UAS Operations within 5NM of an Airfield or UAS Operations in or near High Traffic

Area: Provided the airspace request is approved, all UAS production events within a 5-

mile / high-density traffic zone must be able to communicate with the appropriate ATC

agency.

4.1. A communication plan will be drafted and adopted between UAS Aircrew and ATC 

to build maximum situational awareness and ensure traffic deconfliction.

4.1.1. CloudD8ta PICs will deconflict with the FSDO and appropriate ATC agencies such 

as the closest Control Tower before initiating UAS production flights, to include 

communicating the PIC’s intended UAS flight operations plan with planned 

communications events, highlighting unique aspects of UAS contingencies and 

emergencies.

4.2. Communications will be established and monitored during all UAS operations within
PROPRIETARY TO CLOUDD8TA LLC

5 nautical miles of a control tower or in areas with known high traffic density such as a 

flight arrival or departure corridor.

4.2.1. FSDO or FAA-Approved plan / COA supersedes previous.

4.3. With FSDO approval and/or awareness of UAS operations within 5NM of an airfield 

or within a High Traffic Area, 2-way communication between UAS Aircrew and ATC will 

be established before UAS operations begin, checking in and out for each flight.

4.3.1. FSDO or FAA-Approved plan / COA supersedes previous.

4.4. Communication priority will be set by the most expeditious means available that both 

ATC and the UAS Aircrew agree upon, such as a UHF/VHF radio, phone or online 

communication application.

4.4.1. FSDO or FAA-Approved plan / COA supersedes previous.

L. Accident Notification. The procedures for notification and reporting of accidents, 

notifying the National Transportation Safety Board (NTSB), 49 CFR part 830, and 

protection of the accident scene are as follows:

1. ALL: CLOUDD8TA LLC closed-set aviation will comply with all reporting requirements 

under NTSB 49 CFR part 830. Accidents involving CLOUDD8TA LLC aviation resources 

shall be photographed and preserved, with notification to the nearest NTSB as soon as 

possible not to exceed one business day.

2. ALL: Catastrophic damage or destruction of a CLOUDD8TA LLC aerial system, or 

bodily harm requiring medical service directly caused by a CLOUDD8TA LLC system,

shall be grounds for termination of all on-set aerial operations.

3. ALL: In the event of an accident involving loss of life or craft, the scene of the incident 

shall be preserved IAW 49 CFR 830. All CLOUDD8TA LLC flying operations shall cease 

until it is deemed safe to continue by CloudD8ta’s Chief Pilot and/or the FAA.

4. ALL: Aerial systems involved in or directly related to the mishap system, including 

visual information from on-set sources when available, shall be impounded and 

preserved for NTSB investigation as required.

5. ALL: Mishaps or Accidents not leading to loss of life or significant property damage 

will adhere to NTSB standards and resume operations when cleared by the Chief Pilot. 

The Chief Pilot will alter or determine future air operations in the interest of public safety 

and the interest of CloudD8ta aircrews. Production may request CloudD8ta aircrews’ 

return to flying status only with Chief Pilot’s written approval. Aircrew status can be: 

DNIF, Grounded or Mission Capable.

M. Recall/Stop Procedures. The applicant can use radio communications, oral, visual, 

or any combination acceptable to the Administrator as long as it keeps the participants 

continuously apprised of the current status of the operation.

1. UAS: The PIC has a responsibility to safely operate his or her UAS. In the event of a 

recall or stop procedure, the PIC will acknowledge verbally and on radio or over 

loudspeaker / PA. The transit corridor and landing zone or divert / ditch zone will be 

sanitized and confirmed verbally as free from non-participating and non-essential 

personnel.

2. UAS: The PIC should elect to land in a divert zone or ditching area if weather or safety 

considerations in the landing zone or transit corridor preclude a standard return to base.

3. UAS: Lights and or other non-radio means of communications may be used in addition 

to radio in order to communicate a PICs intention during non-standard events such as a

weather recall.

4. UAS: Care shall be given to ensure at least 100 feet separates the UAS and 

production personnel during takeoff, landing and transition procedures. A safe zone will 

be clearly announced and marked with neon-yellow signs, safety cones and or placards.
PROPRIETARY TO CLOUDD8TA LLC

—

K. Special Provisions. The following statement must appear as a special provision:

• “The certificate holder must adhere to the accepted motion picture and television 

operations manual.”

• The pilot in command (PIC) may remove and install specialty equipment authorized in

accordance with an exemption issued for that purpose or under the terms of a 

Supplemental Type Certificate (STC) or field approval.

• Traditional seating for the PIC of various aircraft does not always lend itself to be the 

safest position from which to conduct a flight. The primary seat may not be the optimal 

location, depending on the subject aircraft. The decision on where to sit may be 

determined by the PIC.

• Additional provisions deemed appropriate to the Administrator to ensure safety of the 

operation should be prescribed by the FSDO (Figure 3-55, Sample Motion Picture and

Television Operations Manual Special Provisions).