Original Dated 10/29/2015 - 1 -

EMMU LLC

Motion Picture and Television 

Operations Manual

(MPTOM)

Unmanned Aircraft System 

Operations

Dave Crago, (dba) EMMU LLC

1579 Outrigger Cir. Rockledge, FL, 32955

Cragod1@gmail.com

(407) 690-8319

Original Publication Date: 10/29/2015
Original Dated 10/29/2015 - 2 -

TABLE OF CONTENTS

Table of Contents – pg.2

Revisions - pg.3

1. UNMANNED AIRCRAFT SYSTEMS (UAS) PROCEDURES:

A. Purpose - pg.4

B. Owner/Pilot/Operator Organization - pg.4

C. Persons Authorized - pg.4

D. Area of Operations - pg.5

E. Plan of Activities - pg.5

F. Permission to Operate - pg.5

G. Security - pg.6 

H. Briefing of Pilot/Production Personnel - pg.6

I. Certification/Airworthiness - pg.7

J. Pilot Personnel/Minimum Requirements - pg.8

K. Communications - pg.8 

L. Accident Notification - pg.8

M. Recall/Stop Procedures - pg.8

N. Special Provisions - pg.8 

2. Duties and Responsibilities:

A. Owner/Operator - pg.10

B. Pilot in Command - pg.10 

Appendix A 

1 List of Approved Pilots - pg.11

2 List of Approved Aircraft - pg.12 

3 Permission Form (sample) - pg.13

4 Revision Memo (sample) - pg.14

Appendix B 

Check List (Briefing and Pre-flight) - pg.15 –

Latest COA and Exemption No.13123 issued to EMMU LLC (attachment)
Original Dated 10/29/2015 - 3 -

Revisions:

A copy of the latest revision page along with any revised pages will be sent to the appropriate 

Flight Safety District Office (FSDO) with the original MPTOM to ensure an up to date MPTOM 

has been given to appropriate FAA authorities. Revision dates listed below should ensure all 

copies are up to date. Revisions should include revision description, revision number, page 

number, and date of revision. Be advised that a page may have more than one revision and 

revision number associated with that page.

REVISIONS

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________

___________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 
Original Dated 10/29/2015 - 4 -

1. UNMANNED AERIAL SYSTEMS (UAS) PROCEDURES

A. Purpose:

This manual has been developed by Dave Crago, doing business as EMMU LLC, hereafter 

referred to as EMMU. This manual will be used in conjunction with a Certificate of

Authorization (FAA FORM 7711-1 UAS COA) and a Section 333 Exemption No.13123 for the 

purpose of establishing procedures for the use of small Unmanned Aircraft Systems (UAS) in 

closed-set motion picture and television filming. EMMU pilots, operators, and other company 

personnel when applicable shall comply with the policies, procedures, and conditions of this 

manual, whenever motion picture or television flight operations are performed.

B. Owner/Operator Organization:

Dave Crago, Managing Partner

EMMU LLC

1579 Outrigger Cir. Rockledge, FL, 32955

Cragod1@gmail.com

(407) 690-8319

C. Persons Authorized:

FAR 91.119 (c) is waived only with respect to those persons, vehicles and structures directly

involved in the performance of the actual filming. The 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 production. 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. 

An equivalent level of safety may be determined by an evaluation of the filming production area 

to note terrain features, obstructions, buildings, etc. Such barriers may protect nonparticipating 

persons (observers, the public, news media, etc.) from debris in the event of an accident.

D. Area of Operations:

EMMU’ approved area of operations will be Continental United States, Alaska Hawaii, its

possessions, and its territories.

E. Plan of Activities:

At least three (3) days prior to any scheduled filming EMMU will submit a written plan of 

activities to the local FSDO having jurisdiction over that area. The three (3) day notification 

requirements may be waived and the operator should contact the FSDO as soon as possible with 

this request and be prepared to explain in detail why the three (3) day notification is not practical.

The plan of activities should include the following:

(1) Dates and times for all flights.

(2) Name and phone number of person responsible for the filming production event.
Original Dated 10/29/2015 - 5 -

(3) Name and phone number of person responsible for aircraft.

(4) Make, model, and serial number of UAS aircraft to be used.

(5) Name and certificate number of pilots (if required) involved in the filming production event.

(6) A statement that the waiver holder or parent production company 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.

(7) Signature of waiver holder or representative.

(8) 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 operations. 

F. Permission to Operate:

Before any UAS flight operation is conducted on private property or controlled access property 

under the provisions of the COA and this manual, the operator will obtain permission to conduct 

these operations from property owners and government 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 

(5) Air traffic control 

The permission shall be obtained in writing whenever practical, however, documented verbal 

permission is acceptable otherwise. A standard permission form is provided in Appendix A and 

may be used when obtaining written permission. Copies of signed permission forms shall be 

maintained at the job site until flight operations are completed and shall be made available for 

inspection by the FAA or other official personnel upon request. Original signed permission 

forms shall be kept on file at EMMU for a minimum of six (6) months. Blank permission forms 

shall be available at the job site for use as required.

G. 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 and vehicles. 

Provision will be made to immediately discontinue operations should the area(s) become 

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

H. Briefing:
Original Dated 10/29/2015 - 6 -

Briefing of production personnel prior to the start of any operation under the provisions of this 

manual will be conducted by the chief pilot in command/operator. The briefing should include 

the risks involved, emergency procedures, and safeguards to be followed during the aerial part of 

the 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 briefing will cover:

(1) Certificate of Authorization (COA), exemptions, and the provisions for motion picture and 

television production.

(2) Operations manual (MPTOM) procedures.

(3) Plan of aviation activities to be conducted during the filming production.

(4) Aircraft starting point(s) and operations area boundaries.

(5) Allowed personnel in the operations area.

(6) Allowed radio communications and the potential radio, cell phone, and computer interference 

considerations. 

(7) Takeoff and landing procedures.

(8) Recall, automatic landing functions/procedures, delays, and emergency procedures.

(9) Risks to participating personnel.

(10) How to control nonparticipating persons.

(11) Weather forecast safety: wind, temperature, potential lightning, rain or flooding, etc.

(12) Camera director’s or cinematographer’s set-up considerations especially affecting the UAS 

configuration or the timing of the flights.

(13) Lighting, rigging, ground crew and camera location considerations.

(14) Unwanted artifacts in the aerial shots.

(15) Matting considerations.

(16) Altitude maximum and minimum needs with respect to ground, overhead wires and rigging,

tree, and vehicle clearance considerations, legal safety requirements, and cinematography

considerations.

(17) Actors, ground crew, vehicles, and ground equipment positioning.

(18) UAS camera/pilot point of view (POV) considerations with respect to collision hazards.

(19) Weight of camera and lenses.

(20) Battery recharging station and charging time considerations.

(21) Camera memory cards and copy/erase station (data wrangling).

(22) Visual Line of Sight (VLOS) and use of Visual Observers (VO) considerations.

(23) Site security.

(24) Liability insurance requirements.

(25) Government officials on site, their needs, positioning, liaisons, etc.

(26) Videography considerations with UAS flight motions: stationary, forward or backward 

motion, fly by, altitude change, each of the previous motions with camera pan or other camera 

motions.
Original Dated 10/29/2015 - 7 -

(27) Coordination with ground personnel discussion: flights are limited to 20 minutes or 30% of 

battery power, whichever occurs first, multiple shots can occur in that time frame. Operations

can continue with a ground crew handling data copying from the camera’s removable memory, 

extra battery charging, and initial review of the previous flights video for feedback to the pilot 

and the director of cinematography. Takeoff and landing platforms, wind breaks and security 

barriers, if needed, are set up as planned. Pre-flight routine can continue as soon as the director 

has set up the next shot. Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy by the pilot, as well as GPS acquisition by the UAS (6 satellites 

minimum).

I. Certification/Airworthiness:

All EMMU aircraft used in filming and video operations will be UAS permitted aircraft listed in 

the COA with their own approved maintenance and operating procedures. All aircraft will have a 

serial number and shared operations logbook with the appropriate serial number in lieu of a 

certificate number or N designation. A section for malfunctions is also found in the flight log. 

The pilot in command will assure the aircraft to be flown is in airworthy condition and all 

required inspections and maintenance has been completed before each flight. 

Maintenance requirements will be adhered to by the operator on an as needed process. The 

operator will follow any manufacturers’ recommended instructions and procedures when those 

maintenance procedures exist for certain components of its UAS.

J. Pilot/Personnel - Minimum Requirements:

EMMU will not permit the any pilot to operate the UAS for the purpose of aerial 

videography/cinematography (or similar operations), unless the PIC has demonstrated the ability

to safely operate the UAS in a manner consistent with how the UAS will be operated during such 

operations, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. Minimum requirements shall meet or exceed the 

following:

The PIC must hold an FAA airman certificate and/or a pilot medical certificate or driver’s

license to be used under the terms of the waiver. (2) At least 25 hours logged in category of UAS 

(rotorcraft) as PIC and at least 10 hours logged as the PIC in the UAS aircraft type to be used in 

the operation.

Visual Observer: The Visual Observer shall hold a current FAA airman medical certificate or a 

valid U.S. driver’s license.

Minimum Crew: The minimum crew for flight operations shall consist of at least a PIC and a 

Visual Observer. In certain cases, an extra pilot and/or camera operator will be utilized. All crew 

responsibilities shall be designated prior to flight.
Original Dated 10/29/2015 - 8 -

K. Communications:

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.

The pilot will monitor air traffic when needed through an FCC approved portable transceiver and 

headset/ microphone combination capable of communication with control towers and manned 

aircraft in the vicinity of the operations area.

L. Accident Notification:

Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA shall be reported to the FAA's UAS 

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

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

M. Recall/Emergency/Stop Procedures:

Should any unsafe situation arise that is not an emergency the PIC shall utilize two-way

communication to abort the mission and recall the aircraft to the designated landing area.

In the event of an in-flight system malfunction or emergency the following procedures shall be 

executed. Pilot at the controls shall:

(1) Maintain control of the Unmanned Aircraft (UA) to the max extent possible.

(2) Fly the UA to a safe area free of persons and property.

(3) Abort the operation.

(4) Land the aircraft as soon as practicable as determined by the PIC. 

NOTE: Flight operations shall not be resumed until the cause of the malfunction/emergency is 

identified and corrected.

N. Aerobatic Competency:

Aerobatic Competency will not be applicable to the small Unmanned Aircraft Systems by

EMMU.

O. Special Provisions

The controls, procedures, and conditions set forth in EMMU’s Motion Picture and Television 

Operations Manual exist to ensure the safety of crew, persons, and/or property.
Original Dated 10/29/2015 - 9 -

The aircraft and pilots that will participate in closed-set filming shall only be those specified in 

the associated plan of activities submitted to and approved by the appropriate FSDO. Each 

pilot’s name and certificate number shall appear on each daily plan of activity. All aircraft and 

pilot(s) participating in the activity shall be available for inspection by all appropriate governing 

authorities upon request.

The Pilot in Command shall ensure that all participating persons involved in or affected by flight 

operations are thoroughly briefed on special procedures, communication, emergency procedures, 

and on the provisions of any exemption, authorization, and/or waiver before beginning the 

activities. No person may participate in any flight operation unless that person has received a 

preflight briefing as specified in section H of this manual.

The PIC shall ensure that the UA remains clear and gives way to all manned aviation operations 

and activities at all times.

The PIC shall ensure that the maximum in flight-weight including payload of any Unmanned 

Aircraft utilized for filming shall be no greater than 55lbs.

Documents used by EMMU to ensure the safe operation and flight of the UAS, any documents 

required under 14 CFR §§ 91.9 and 91.203, and any exemptions, permissions, and/or waivers 

shall be available to the PIC at the Ground Control Station of the UAS any time the aircraft is 

operating. These documents must be made available to the administrator or any law enforcement 

official upon request.

The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.

UAS takeoff and landing areas will be protected in a manner that will prevent unauthorized 

persons from entering the takeoff and landing areas. Production security personnel will be 

responsible for securing the takeoff and landing areas. 

The UA shall be operated within the visual line of sight (VLOS) of the PIC and VO at all times. 

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

VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic 

messaging or texting is not permitted during flight operations. The PIC will be designated before 

the flight and cannot transfer his or her designation for the duration of the flight.
Original Dated 10/29/2015 - 10 -

No UA shall be operated at a speed exceeding 87 knots (100 miles per hour). The pilot may use 

either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case shall the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a 

letter of agreement with that airport’s management is obtained or otherwise permitted by a COA 

issued to the exemption holder.

All operations shall be conducted in accordance with an ATO-issued COA. EMMU may apply 

for a new or amended COA if intended operations cannot be conducted under the terms of the 

approved COA.

2. Duties and Responsibilities:

A. Owner/Operator Duties and Responsibilities:

(1) Have the final word in the formulation of policy and procedures concerning this manual.

(2) Act as liaison between EMMU and the FAA on matters concerning this manual.

(3) Assure that each approved pilot is issued a copy of this manual and obtain a signed statement 

from each that they have read and understood its contents. 

(4) Maintain a current copy of this manual at the main base of operations for EMMU.

(5) Be responsible for assuring that all revisions to this manual are distributed and processed 

properly.

(6) Must approve or disapprove each proposed job or operation performed by EMMU under the 

provisions of this manual. 

(7) Assume the responsibilities of pilot in command when acting as such.

(8) May delegate functions to other personnel but retain responsibility. 

B. Pilot in Command Duties and Responsibilities:

(1) Assure that rotorcraft to be flown is in airworthy condition and all inspections and required 

maintenance have been performed as per the appropriate manufacturer’s operating manual.

(2) Acquire permission from the chief pilot before any operation under the provisions of this 

manual. 

(3) PIC must be knowledgeable of the contents of this manual and abide by the procedures, 

policies and conditions contained herein.

(4) Coordinate with movie and television personnel to formulate plans, routes, locations, etc. 

with safety of all persons involved in the primary concern.
Original Dated 10/29/2015 - 11 -

(5) Maintain a copy of this manual in current condition and have it on site at any job or operation 

requiring the waiver.

(6) The pilot in command may delegate functions to other personnel, but retains responsibility. 
Original Dated 10/29/2015 - 12 -

Appendix A

(1) List of Approved Pilots:

Pilot 1 Name: , Certificate Number: , Contact Number:

Pilot 2 Name: , Certificate Number: , Contact Number:
Original Dated 10/29/2015 - 13 -

Appendix A

(2) List of Approved Aircraft (with approved specifications and operation/maintenance 

manuals):

(1) DJI Phantom 3 (approved by Exemption No.13123).

(2) DJI Inspire 1 (approved by Exemption No.13123).

(3) DJI S800 EVO (approved by Exemption No. 13123)

(4) DJI Spreading Wings S1000 (approved by Exemption No. 13123)
Original Dated 10/29/2015 - 14 -

Appendix A

(3) Sample Permission Form:

EMMU

Permission Form

In signing this form, I am giving the pilots of EMMU Permission to operate their aircraft on, or 

at less than 500 feet from the property listed below, or in some jurisdiction in which I am 

responsible for or affiliated with, on the dates listed below, for the purpose of film or television 

production.

Name: _______________________________________________________________________

Title: ________________________________________________________________________

_____________________________________________________________________________

Location: _____________________________________________________________________

_____________________________________________________________________________

Date(s) of Operation: ___________________________________________________________

Signature ____________________________________________Date: ____________________

EMMU Representative Receiving Permission: 

_____________________________________________________________________________

This form must be returned to the EMMU Representative no later than this Date: 

_________________________
Original Dated 10/29/2015 - 15 -

(4) Revision Letter (sample)

Revisions to EMMU MPTOM

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

Pages Revised: 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

Issued To: ___________________________________ Date: ____________________________

Revised By: _________________________________ Date: _____________________________ 
Original Dated 10/29/2015 - 16 -

CHECK LIST FOR BRIEFING AND/OR AERIAL PRODUCTION PLANNING

(1) The current copy of the COA must be on site and its provisions followed accordingly.

(2) The MPTOM manual must be available and its procedures utilized.

(3) Aviation activities to be conducted during the production must be planned and documented.

(4) Aircraft starting point(s) and operations area boundaries identified and planned.

(5) Designation of allowed personnel in the secure operations area.

(6) Allowed radio communications and the additional potential of radio, cell phone, and 

computer interference considered and eliminated. 

(7) Takeoff and landing procedures planned and reviewed. 

(8) Automatic landing functions / procedures, delays, and emergency procedures discussed.

(9) Risks to participating personnel discussed.

(10) Control of nonparticipating persons planned.

(11) Weather safety considerations used in go/no go planning: wind, temperature, potential 

lightning, rain or flooding, etc.

(12) The camera director’s or cinematographer’s plans and/or changes to the plans reviewed.

(13) Lighting considerations planned.

(14) Unwanted artifacts in the shots considered.

(15) Matting considerations planned.

(16) Operating altitudes (max and min) with respect to ground, wires, tree, and vehicle clearance 

considerations, legal requirements, and cinematography considerations calculated and planned.

(17) Actors, ground crew, vehicles, and ground equipment positioning.

(18) Camera/pilot Point of View (POV) considerations with respect to collision hazards.

(19) Weight of camera and lenses planned.

(20) Battery recharging station and charging time considerations.

(21) Camera memory cards and copy/erase station (data wrangling) planned.

(22) Visual Line of Sight (VLOS) considerations planned.

(23) Site security planned.

(24) Liability insurance requirements met.

(25) Government officials on site, their needs, positioning, and liaisons are provided for.

(26) Videography considerations planned with director of cinematography.

(27) Shot coordination with ground personnel: Timing of each flight is limited to 20 minutes or 

30% of battery power, whichever occurs first, multiple shots can be conducted in that time 

frame. Flight operations can continue with a ground crew handling data copying, extra battery

charging, and initial review of the previous flight’s video for feedback/planning for the pilot and 

the director of cinematography. Takeoff and landing platforms, wind breaks and security 

barriers, if needed, are set up as planned. Pre-flight routine can continue as soon as the director 

has set up the next shot. Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy by the pilot, as well as GPS acquisition by the UAS (6 satellites 

minimum).