AFS-15-013-E

 Exemption No. 11159

 Regulatory Docket No. FAA-2014-0784

Mr. Alan D. Purwin

Director

Shotover Camera Systems L.P.

16303 Waterman Drive

Van Nuys, California 91406

Dear Mr. Purwin:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated September 29, 2014, which referenced supplemental proprietary information 

submitted to the Federal Aviation Administration (FAA) under separate cover, you petitioned 

the FAA on behalf of Shotover Camera Systems L.P. (Shotover) for an exemption 

from §§ 61.113(a) and (b), 91.103, 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 

91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The 

exemption would allow Shotover to operate its Gryphon Dynamics X8 with an eight rotor, 

eight motor quadcopter and a DJI S1000 eight rotor, eight motor octocopter, unmanned 

aircraft systems (UAS) for aerial photography in the motion picture and television industry.

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on October 28, 2014 

(79 FR 64242). The FAA received three comments on the petition for exemption; 

one commenter supported the exemption request and two opposed it. 

In support of the petition, the Small UAV Coalition (Coalition) states the petitioner has 

proposed to abide by stronger safety measures than hobby and modeler groups operating 
2

similar aircraft. The Coalition states that it does not believe that heightened safety measures 

should be required for the petitioner simply because of the commercial nature of its 

operations. The Coalition urged the FAA to adopt an evaluation framework for UAS 

operations under section 333 of Pub. L. 112–95 that weighs the relative safety issues and risks 

of UAS by class and operational circumstances, rather than adopting artificial distinctions 

among unmanned aerial vehicles based on commercial and noncommercial operations. The 

Coalition suggested FAA safety regulations be proportionate to the risks posed by the 

particular proposed UAS operations by distinguishing between UAS. The petitioner’s UAS 

pose considerably less safety risk than larger UAS used for defense and aerospace purposes. 

The Coalition asserted that because UAS operations like the petitioner’s pose minimal risk to 

safety, they should be subject to minimal and appropriate regulations.

The Coalition noted the FAA is to consider the seven factors1 in section 333 as a minimum. 

The Coalition stated the petition shows the FAA should consider factors other than those 

specified in section 333, such as location, altitude of its UAS, and pilot training and 

experience. The Coalition maintained that the petitioner’s proposed operations satisfy the 

seven factors in section 333 and include several additional mitigating factors to ensure the 

safety and security of the proposed UAS operations. The Coalition emphasized the FAA must 

evaluate each factor within the context of the petitioner’s proposed UAS operations.

The Coalition also commented that the FAA should grant relief from the requirement to hold 

an airman’s certificate, but stated that at a minimum the FAA should provide an exception 

from part 61 and approve training and testing regiments that pertain to UAS commercial 

operations pertinent to the aircraft and operation proposed. The Coalition also asserted that 

Congress intended the section 333 national security criterion to focus on the operation rather 

than on the pilot and that shifting that focus imposes an unnecessary burden.

In response, as discussed in the grant of exemption to Trimble Navigation Ltd. (No. 11110), 

neither section 333 nor the FAA’s authority to exempt from its regulations found in 49 USC 

44701(f), authorizes the FAA to provide exemption to the statutory requirement to hold an 

airman certificate as prescribed in 49 USC § 44711. The FAA notes that under this 

exemption the petitioner proposed to use pilots holding private certificates and it will be able 

to use the training program it proposed. Finally, the FAA does not agree that relying on the 

pilot certificate for a national security finding poses an unnecessary burden because pilots 

under this exemption, and the exemptions granted previously to section 333 requests, are 

already required to hold a pilot certificate to satisfy 29 USC 44711.

The Coalition commented that a visual observer (VO) should not be required for all small 

UAS operation. The Coalition further asserted that the presence of one or more VOs may 

 

1 Section 333(b) of P.L. 112-95 states, in part: “In making the determination under subsection (a), the Secretary 

shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, as a result of their size,

weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national 

security; ...”
3

allow the UAS to be operated beyond VLOS of the PIC and that the petitioner’s proposal to 

operate the UA within VLOS of the PIC and/or VO should be permitted. The FAA notes that 

one of the determinations for operations under section 333 is operation within visual line of 

sight. As the PIC is determined to be in command of the UA, he must maintain VLOS while 

operating the UA. The FAA also notes that a visual observer complements the PICs 

capability to see and avoid other aircraft, including when the PIC may be momentarily 

attending to other flying tasks (e.g., maneuvering the aircraft close to actors and actresses and 

other objects on a film set). The VO provides an additional level of operational safety.

The FAA received comments opposing the petition from two individuals, the Air Line Pilots 

Association, International (ALPA), and the National Agricultural Aviation Association 

(NAAA). One of the two individual commenters states the exemption does not serve the 

public interest.

ALPA expresses concern regarding several aspects of the petition. ALPA notes the 

petitioner’s reference to operations conducted within “limited or predetermined” sterile areas 

is not defined, nor does the petitioner detail procedures for controlling the airspace or area of 

operation. Specifically, ALPA states “there must be means both to ensure that the sUAS 

remains within the defined airspace and to ensure that the hazard of other aircraft intruding on 

the operation is mitigated.” The FAA believes the limitations under which the petitioner will 

operate (i.e. VLOS and at or below 400 feet AGL) are sufficient mitigations to this risk so that 

the operations will not adversely affect safety.

Regarding the petitioner’s statement that the PIC and observer will be able to communicate by 

voice or text, ALPA notes that text messaging could have an unknown latency extending to 

several minutes. ALPA also states that the pilot and observer should be able to maintain a 

visual observation of the aircraft and area of operation when using voice communication. 

NAAA states UAS observers must be present and able to communicate with the operator from 

the most minimal distance possible. The FAA has inserted a condition regarding PIC and 

visual observer communications.

ALPA asserts the UAS’s lithium polymer batteries have numerous associated fire and 

explosion hazards as outlined in DOT/FAA/AR-09/55, “Flammability Assessment of 

Lithium-Ion and Lithium-Ion Polymer Battery Cell Designed for Aircraft Power Usage 

(January 2010),” and that the safe carriage of the batteries and the mitigations in place for 

known risks should be addressed. The referenced study was primarily conducted to determine 

how certain battery cells react in a fire situation aboard manned airplanes. Given the size of 

the battery and the operating conditions of the UAS, the FAA concludes that the use of a 

lithium polymer battery will not pose an undue safety risk for the proposed operations.

ALPA comments that command and control (C2) link failures are one of the most common 

failures on a UAS, and that lost link mitigations should require safe modes to prevent flyaways or other scenarios. The FAA agrees and carefully examined the proposed operation to 

ensure that the vehicle design and the petitioner’s operating documents addressed potential 

hazards related to C2 failure. The FAA finds that the UAS to be operated by the petitioner 
4

has sufficient design features to address these hazards. The FAA also finds that the operating 

documents have incorporated safety procedures to be followed by all operational participants 

should a C2 failure occur. Further detail is contained in the analysis of the UAS below.

ALPA also notes that the petitioner’s proposed operations are for “compensation or hire,” and 

argues the pilot must hold at least a current FAA commercial pilot certificate with an 

appropriate category and class rating for the type of aircraft being flown, as well as specific 

and adequate training on the UAS make and model intended to be used. Similarly, ALPA 

asserts a current second-class airman medical certificate should be required. NAAA also 

commented on pilot qualification, stating—

Just as manned aircraft pilots are required to undergo a rigorous 

training curriculum and show that they are fit to operate a commercial 

aircraft, so too must UAS operators. Holding a commercial certificate 

holds UAS operators to similar high standards as commercial aircraft 

operators and ensures they are aware of their responsibilities as 

commercial operators within the NAS. Medical requirements ensure 

they have the necessary visual and mental acuity to operate a 

commercial aircraft repeatedly over a sustained period of time.

The FAA has reviewed the knowledge and training required by holders of both private and 

commercial certificates. Additional details are available in the ensuing analysis of this issue 

with regards to 14 CFR § 61.113.

ALPA opposes an exemption from the pre-flight action requirements of § 91.103. In addition, 

although the petitioner did not request an exemption from § 91.113, ALPA notes the 

petitioner must specify a means to meet see and avoid requirements in § 91.113 given the 

absence of an onboard pilot. This comment is addressed in detail in the FAA analysis below.

ALPA mentioned the aircraft will not have a barometric altimeter as required by 

14 CFR § 91.121, stating the ability to accurately maintain altitude must be addressed, and 

processes or mitigations, such as redundant control capability, fail-safe systems, backups and 

specific, validated procedures for system and equipment failures must be in place. The FAA 

agrees with ALPA and addresses this concern in its analysis of the exemption from 

14 CFR § 91.121, finding that the alternative means of compliance proposed by the petitioner 

does not adversely affect safety.

Regarding the fuel requirements of § 91.151, ALPA argues that using batteries as the only 

source of an aircraft’s power is a substantial shift from traditional methods of propulsion, and 

requires further research to determine best safety practices. This comment is addressed in 

detail below.

Regarding §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b), ALPA opposes 

the petitioner’s attempt to avoid compliance with established aircraft maintenance and 

recordkeeping requirements. ALPA states the UAS should comply with the same level of 
5

safety as other aircraft operated commercially in the NAS. This comment is addressed in 

detail below.

ALPA also expresses concern that the petitioner’s waiver request is not for a single specific 

operation or location, but for all operations of the same general type. ALPA states this results 

in a considerable increase in the FAA’s oversight tasks. The FAA notes ALPAs concern and 

in order to minimize potential impact to the NAS, the FAA requires each operator secure a 

Certificate of Authorization or COA which covers specific details of the petitioners operation. 

The FAA recognizes that UAS integration will generate new NAS access demand and will 

review and adjust accordingly.

NAAA states it represents the interests of small business owners and pilots licensed 

as commercial applicators. NAAA explains that its members operate in low-level airspace, 

and clear low-level airspace is vital to the safety of these operators.

NAAA states that seeing and avoiding other aircraft and hazardous obstructions is 

the backbone for agricultural safety, and agricultural pilots depend on pilots of other aircraft 

to perform their see-and-avoid functions needed to prevent collisions. NAAA believes UA 

operations at low altitudes will increase the potential of collision hazards with agricultural 

aircraft. NAAA argues that until adequate see-and-avoid technology is developed, the FAA 

should require UAS operators to post a Notice to Airmen (NOTAM) 48 to 72 hours before 

operations. NAAA proposes UAS aircraft be painted a highly visible color, be equipped with 

strobe lights, and use Automatic Dependent Surveillance–Broadcast (ADS–B) or other similar 

location reporting technology. To address these concerns the FAA has incorporated 

associated conditions and limitations into this exemption, including: a) NOTAMs issued for 

all operations, b) operations conducted within VLOS of the PIC and the VO, and c) the UAS 

PIC must always yield right-of-way to manned aircraft.

NAAA also proposes a number of operating limitations and requirements for UAS operators. 

NAAA states UAS operators should have procedures to immediately ground the UAS if 

another low-flying aircraft is within 2 miles; be attentive and free from distractions; comply 

with all applicable regulations, policies, and procedures; be equipped with aviation radios set 

to a locally defined frequency; have a separate VO with a second-class medical certificate and 

perform duties for only one UAS at a time; maintain line-of-sight operations; and be wellversed in the UAS operator document. NAAA further states UAS should be properly 

maintained, have a registered N-Number on an indestructible and unmovable plate, and be 

required to have an airworthiness certificate and liability insurance. These comments are 

addressed in the FAA’s analysis and conditions and limitations.

The FAA’s Analysis is as follows:

Although the petitioner did not seek relief from 14 CFR § 91.7(a) Civil aircraft airworthiness,

the FAA finds that relief from § 91.7(a) is necessary. While the petitioner’s UAS will not 

require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H, the FAA 
6

considers the petitioner’s compliance with its operating documents to be a sufficient means 

for determining an airworthy condition. The petitioner is still required to ensure that its 

aircraft is in an airworthy condition – based on compliance with the operating documents 

prior to every flight, and as stated in the conditions and limitations below.

The Basis for Our Decision

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grants of Exemption No. 11062 and 11158 the FAA 

found that the enhanced safety achieved using an unmanned aircraft (UA) with the

specifications described by the petitioner and carrying no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable 

fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in 

the public interest. The FAA also found that UAS provide an additional tool for the 

filmmaking industry, adding a greater degree of flexibility, which supplements the current 

capabilities offered by manned aircraft.

Having reviewed your reasons for requesting an exemption, I find that—

• they are similar in all material respects to relief previously requested in the Grants

of Exemption No. 11062 and 11158;

• the reasons stated by the FAA for granting Exemption Nos. 11062 and 11158 also 

apply to the situation you present; and 

• a grant of exemption is in the public interest. 

In accordance with the statutory criteria provided in Section 333 of PL 112-95 in reference to 

49 USC 44704, and in consideration of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, the Secretary of Transportation has determined 

that these aircraft meet the conditions of Section 333.

The table below summarizes the FAA’s determinations regarding the relief sought by the 

petitioner:
7

Relief considered (14 CFR) FAA determination (14 CFR)

61.113(a) and (b) Relief granted with conditions and 

limitations

91.7(a) Relief granted from 91.7(a), with 

conditions and limitations

91.103 Relief not necessary

91.119(c) Relief granted for Paragraph (c) with 

conditions and limitations

91.121 Relief granted with conditions and 

limitations

91.151(a) Relief granted for 91.151(a)(1), day, 

with conditions and limitations

91.405(a) Relief granted with conditions and 

limitations

91.407(a)(1) Relief granted with conditions and 

limitations

91.409(a)(2)

Relief granted with conditions and 

limitations; relief from 91.409(a)(1) also 

granted with conditions and limitations

91.417(a) and (b) Relief granted with conditions and 

limitations

The FAA’s Decision

In consideration of the foregoing, I find that a grant of exemption is in the 

public interest. Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40113, 

and 44701, delegated to me by the Administrator, Shotover Camera Systems L.P. is granted 

an exemption from 14 CFR 61.113(a) and (b); 91.7(a); 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409 (a)(2); and 91.417(a) and (b) to the extent 

necessary to allow Shotover to operate UAS for the purpose of aerial photography 

in the motion picture and television industry. This exemption is subject to the conditions and 

limitations listed below.

Conditions and Limitations

Relative to this grant of exemption, Shotover is hereafter referred to as the operator.
8

The petition and the following supporting documentation are hereinafter referred to as 

the operating documents: 

1) Shotover Flight Operations and Procedures Manual (FOPM), 

2) Shotover Motion Picture and Television Operations Manual (MPTOM), and 

Failure to comply with any of the conditions and limitations of this grant of exemption 

will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the following unmanned 

aircraft (UA): 1) Gryphon Dynamics X8 SN#001, quad copter with eight rotors and 

motors, and, 2) the DJI S1000, octocopter with eight rotors and motors. Each weighs less 

than 55 pounds. Proposed operations of any other UAS will require a new petition or a 

petition to amend this grant.

2. UAS operations under this exemption are limited to conducting operations for the purpose 

of aerial filming in the motion picture and television industry.

3. The Gryphon Dynamics X8 may be flown at a ground speed in excess, of 50 knots 

provided the ground speed information is available to the UAS pilot. The DJI Phantom 

may not be flown in excess of a 50 knot ground speed, with airspeed information available 

to the UAS pilot. 

4. The UA must be operated within visual line of sight (VLOS) of the 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 medical certificate.

5. All operations must utilize a visual observer (VO). 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 must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the VO can perform the functions prescribed in the operating documents.

6. The VO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not

permitted to operate the camera or other instruments.
9

7. The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in 

the operating documents, the conditions and limitations herein take precedence and must 

be followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. It is 

the operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of exemption. If 

the operator determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for 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. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. 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. The Ground Control Station must 

be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

9. 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. The PIC who conducts the functional test flight must make an entry 

in the aircraft records. 

10. The pre-flight inspection must account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating 

documents.

11. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul; replacement, inspection, and life limit requirements. 

12. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, and 

alterations must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the UAS to 

service.
10

13. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.

14. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

15. The PIC must possess at least a private pilot certificate and at least a third-class airman 

medical certificate. 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.

16. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria, completes the operator’s UAS training, and 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. The UAS may not be 

operated by any other person who does not meet the requirements above. The VO is also 

required to complete the operator’s training requirements. A record of training must be 

documented and made available upon request by the Administrator. Flights for the 

purposes of training the operator’s PICs and VOs (training, proficiency, and experiencebuilding), are permitted under the terms of this exemption. However, training operations 

may only be conducted during dedicated training sessions.

17. UAS operations may not be conducted during night, 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.

18. The UA may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.

19. The UA may 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.

20. If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.
11

21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

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

weather conditions), there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this grant of exemption. 

This COA will also require the operator to request a Notice to Airman (NOTAM) not 

more than 72 hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements in the ATO issued 

COA including class of airspace, altitude level and potential transponder requirements.

24. The UA may not be operated from an elevated platform.

25. All aircraft operated in accordance with this exemption must 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 must be as 

large as practicable. 

26. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

27. The 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 UAS is operating. These documents 

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

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local 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 filming production 

conducted under this grant of exemption;

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

UAS;
12

d. Make, model, and serial or N-number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the filming production event;

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.

29. The UA must remain clear and yield the right of way to manned aviation operations and 

activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. The UA may not be operated over congested or densely populated areas.

32. Regarding the distance from participating persons, the operating documents have safety 

procedures for UA operations to be conducted closer than 500 feet to authorized and 

consenting production personnel. At all times, operations must not present an undue 

hazard to those participating persons per § 91.119(a).

33. Regarding distance from nonparticipating persons, the operator must ensure no persons 

are allowed within the perimeter of 500 feet from the area of primary filming except those 

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

be reduced to no less than 200 feet if it would not adversely affect safety and the 

Administrator has approved it. For example, an equivalent level of safety may be 

determined by an aviation safety inspector’s evaluation of the filming production area to 

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

nonparticipating persons (observers, the public, news media, etc.) from debris in the event 

of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1.

34. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

35. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 
13

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and 

the UAS operations must comply with all applicable parts of 14 CFR including, but not 

limited to, parts 45, 47, 61, and 91.

This exemption terminates on January 31, 2017, unless sooner superseded or rescinded.

Issued in Washington, DC, on January 30, 2015.

/s/

John S. Duncan

Director, Flight Standards Service