March 24, 2015

Exemption No. 11230 Regulatory Docket No. FAA− 2014−0604

Mr. Ronald Wingo

Chief Executive Officer Montico, Inc.

2710 N orth Argyle Fresno, CA 93727

Dear Mr. Wingo :

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.

The Basis for Our Decision

By letter dated August 8, 2014

, 1 you petitioned the Federal Aviation Administration (FAA)

on behalf of Montico, Inc. (hereinafter petitioner or operator) for an exemption. The exemption would allow the petitioner to operate an unmanned ai rcraft system (UAS) to

conduct tower inspections and mapping operations to an existing tower structure

.

See Appendix A for the petiti on submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

1 By FedEx delivery on February 19, 2015, the petitioner responded to the FAA’s request for information.2

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on September 8, 2014, ( 79 FR 53249 )

. Three comments were received. The Small UAV Coalition (Coali tion) supported the petition, while t he Air Line Pilots Association, International (ALPA) and the National Agricultural Aviation Association (NAAA) opposed it.

I n supp o r t of the p e tition, the C o a lition st a t e d the p e tition e r h a s p r opos e d to a bide b y st r o n g e r

s a fe t y m e a su re s th a n hob b y a nd mod e l e r g r oups op e r a ting simil a r a i r c raf t. The C o a lition

st a t e d th a t it do e s not b e li e ve th a t h e i g ht e n e d s a f e t y m ea su r e s should be re qui re d f or the

p e tition e r simp l y b eca use o f the c omm e rc i a l n a tu r e of its op e ra tions. The C o a lition u r g e d the

F AA to a dopt a n e v a l u a tion fra m e w o r k f or U AS op era tions und e r s e c t ion 333 of P ub. L

. 112

– 95 th a t w e i g hs the r e l a tive s a f e t y issu e s a nd r isks of UAS b y c l a ss a nd op era tion al

c i rc umst a n c e s, ra th e r th a n a dopting a r ti f i c i a l distin c tions a mong unm a n n e d aer i a l v e h i c l e s

b a s e d on c omm erc i a l a nd no n c omm erc i a l op e r a tions. The p e tition er’ s UAS pose

c onsid e ra b l y l e ss s afe t y r isk th a n l ar g e r U AS. The C o a lition a ss er t e d th a t b e ca use UAS

op era tions like the p e tition er’ s pose minim a l r isk to s afe t y , th e y should be subj ec t to minim a l

a nd a pp r op r i a te r e g ul a tions.

The C o a lition not e d the F AA is to c onsid e r t h e s e v e n fac t o r s 2 in s ec tion 333 a s a minimum.

The C o a lition st a t e d the p e tit i on shows the F AA shou l d c onsid e r f a c to r s oth e r t h a n those

sp ec i f i e d in s ec tion 333, such as: location, the altitude of its small UAV operations, proven
experience pursuant to Certificates of Authorization in the United States and similar approvals

in Canada. The C o a lition m a int a in e d th a t the p e tition er’ s p r opos e d op era tions s a tis f y the

s e v e n fac t o r s in s ec tion 333 a nd in c lude s e v e ra l a ddition a l miti g a ting f a c t o r s to e nsu r e the

s afe t y a n d s ec u r i t y of the p r opos e d UAS op e r a tions. The C o a lition e mph a si z e d the F AA must

e v a l u a te e a c h f a c tor within the c ont e x t of the p e tition er’ s p r opo s e d UAS op e r a tions.

The C o a lition a lso c omm e nt e d th a t the F AA should g r a nt re li e f fr om the r e qui re m e nt to hold

a n a i r m a ns c er ti f i ca t e. The Coalition further stated that if an airman certificate is required

then, a t a minimum the, F AA should p r ovi d e a n e x ce ption fr om the t ra ini n g a nd t e sting

r e quirements in part 61 in favor of requirements p er tin e nt to the a i r c raf t a nd op era tion

p r opos e d. The C o a lition a lso a ss er t e d th a t in s ec tion 333 Congress intended for the FAA to

2 Section 333(b) of P.L. 112

- 95 states, in part: “In making the determination under subsection (a), the Sec retary 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 creat e a hazard to users of the national airspace system or the public or pose a threat to national security; . . . .”3

consider n a tion a l s ec u r i t y with respect to the operation as opposed to addressing it through
pilot certification.

The FAA notes that

, a s dis c uss e d in the g r a nt of e x e mption to T r imble N a vig a tion L td.
(Exemption No. 1111 0 ) , n e ith e r s ec tion 333, nor th e F A A ’ s exemption authority 3 allows

the F AA e x e mpt pilots from the st a tuto r y r e qui r e m e nt to hold a n a i r m a n c e r ti f i ca te a s

p re s cr ib e d in 49 U S C § 44711.

The C o a lition c omm e nt e d th a t a visual observer ( VO) should not be re qui r e d f or a ll sm a ll
UAS op era tions. The C o a lition f u r th e r a s s er t e d th a t the p re s e n c e of one o r mo r e VOs m a y

a llow the UAS to be op era t e d b e y o nd visual line of sight ( V L OS) of the pilot in command
( P I C) a nd th a t the p e tition er’ s p r o p os a l to op era te the unmanned aircraft (UA) within V L OS

of the P I C and/or VO should b e p er mitt e d.

The F AA n ot e s th a t one of the d e t er min a tions f or op e ra t ions und e r s ec tion 333 is op era tion

within visu a l line of si g ht. T h e P I C must m a int a in V L OS w hile op era ti n g the UA. The F AA

finds th a t a VO c o mpl e m e nts the P I C’ s ca p a bili t y to s e e a nd a void oth e r a i r cr a f t, in c luding

wh e n t h e P I C m a y b e mom e nt ar i l y a tt e ndi n g to oth e r f l y

i n g t a sks. The VO p r ovid e s a n

a ddition a l l e v e l of op e ra tion a l s a f e t y

.

ALPA expressed concern regarding several aspects of the petition. ALPA noted that while the
proposed operations will avoid congested or populated areas and operate under VLOS in
Visual Metrological Conditions (VMC)

, the petitioner did not provide detailed procedures for
controlling the airspace or area of operation. Specifically, ALPA stated, “there must be means
both to ensure that the sUAS remains within the Class G airspace under 400’AGL and to
ensure that the hazard of other aircraft intruding on the op eration is mitigated.”

The FAA believes the limitations under which the petitioner will operate (i.e. VLOS and at or
below 400 feet above ground level (AGL)) are sufficient mitigations to this risk so that the
operations will not adversely affect safety.

ALPA noted that the petitioner does not state how the pilot and the observer will be able to
communicate with each other. ALPA stated that text messaging, either by mobile phone or
other means, could have an unknown latency and extend to several minutes

. NAAA stated
UAS observers must be present and able to communicate with the operator from the most
minimal distance possible. The conditions and limitations regarding PIC and VO

communications address those concerns.

3 49 USC § 44701(f)4

ALPA asserted the UA’s lithium polym er 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 ope rating 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 commented that while the petitioner’s aircraft has a barometric sensor, the platform
does not have a barometric altimeter as required by 14 CFR § 91.121. ALPA stated that
processes or mitgations must be in place to ensure the UA can accurately maintai n altitude
including engineering processes, software development and control, electronic hardware
development and control, configuration management, and design assurance to ensure the
aircraft and its control system(s) operate to the same level of safety a s other aircraft operated
commercially in the National Airspace System (NAS).

ALPA commented 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 fly

aways or other scenarios. The FAA has inserted conditions and limitations in this exemption
to mitigate the risk associated with such failures.

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

therefore contend s 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. Similarl y, ALPA

asserted 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 t o 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.5

The FAA has reviewed the knowledge and training requirments of sport, recreational, privat e

and commercial certificates and concluded that a UAS PIC holding a minimum of a sport pilot
certificate, and operating under this exemption, would not adversely affect operations in the
NAS or present a hazard to persons or property on the ground. Additi onal discussion of the
FAA’s review is found in the FAA’s Analysis section of this exemption.

A L P A not ed the p e tition e r must sp ec i f y a m ea ns to m ee t s e e a nd a void re qu i re m e nts in

§ 91.113 g i v e n the a bs e n c e of a n onbo ar d pilot. The FAA notes that all flights must be
operated within VLOS of the PIC and VO.

ALPA also expressed concern that the petition makes no reference to compliance with, or a request for waiver from, 14 CFR 61.195, Flight instructor limitations and qualifications

, which defines the r equirements for flight instructors. A certificated flight instructor is authorized to provide the instruction required for the certificates or ratings or currency listed in 14 CFR § 61.193. A person instructing on how to operate the UAS under the petition er’s training program would not need to be a certificated flight instructor because the instruction is not being provided for a certificate or rating listed in § 61.193. We note that none of the UAS operations proposed by the petitioner require such flight instruction because § 61.31( l ) allows for operation of the UAS by an airman who is current per 14 CFR § 61.56 without a category and class rating. Instruction provided toward obtaining the pilot certificate required by this exemption would need to be pro vided by a certificated flight instructor.

ALPA opposed the petitioners request to avoid providing aircraft documentation (critical for
aircraft maintenance tracking, AD issuance, related performance information) of its small

UAS. T he FAA has previously d etermined in Grant of Exemption 11062, Astraeus Aerial,

that relief from these sections is not necessary. Relevant materials may be kept in a location
accessible to the PIC in compliance with the regulations.

ALPA opposed the petitioner’s request for an exemption from the aircraft maintenance and
record keeping requirements. ALPA asserted that the petitioner’s small UAS “should comply
to the same level of safety as other aircraft operated commercially in the NAS.” The FAA
finds that adherence to the peti tioner’s operating documents, as required by the conditions and
limitations below, is sufficient to ensure that safety is not adversely affected.

ALPA also expressed concern that the petitioner’s request is not for a single specific operation

or location, but for all operations of the same general type. ALPA stated that this results in a
considerable increase in the FAA’s oversight tasks. The FAA notes ALPA’s concern and in
order to minimize potential impact to the NAS, the FAA requires that each operator secure a Certificate of Waiver or Authorization (COA) which covers specific details of the petitioner’s6

operation. The FAA recognizes that UAS integration will generate new NAS access demand
and will review and adjust accordingly.

NAAA noted that its memb ers operate in low

- level airspace, and therefore clear low

- level
airspace is vital to the safety of these operators. NAAA stated that seeing and avoiding other
aircraft and hazardous obstructions is the backbone for agricultural safety, and that
agricultur al pilots depend on pilots of other aircraft to perform their see

- and

- avoid functions
to prevent collisions. NAAA believes UAS operations at low altitudes will increase the
potential for collision with agricultural aircraft.

The FAA recognizes these conc erns and has incorporated associated conditions and
limitations into this exemption, including: (a) a Notice to Airmen (NOTAM) issued for all
operations; (b) operations conducted within VLOS of the pilot in command (PIC) and the VO;
and (c) the UAS PIC mus t always yield right

- of

- way to manned aircraft.

NAAA stated that FAA airworthiness certification should be a requirement for all unmanned
aircraft to operate within the NAS. NAAA recommended UAS be equipped with ADS

- B or
similar identification and positioning systems, strobe lights, high

- visibility mark ings and
registration numbers. NAAA also recommended UAS be operated strictly within the line

- of

sight of the ground controller, with the assistance of a VO and clear of any low

- flying manned

aircraft.

As discussed in greater detail below, Section 333 of the FAA Modernization and Reform Act
of 2012 authorizes the Secretary of Transportation to determine, considering a number of
factors laid out in the statute, that an airworthiness certificate is not necessary for certain
operations. The Secretary has ma de that determination in this case and therefore the aircraft
operated by the petitioner will not need to be certificated by the FAA.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in

consideratio n of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested reli ef from

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is

not necessary.7

The Basis for Our Decision

You have requested to use a UAS for aerial data collection . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab, Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petit ioner 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 in terest.

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

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our 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, Montico, Inc. is granted an exemptio n from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

Relative to this grant of exemption, Montico, Inc. is hereafter referred to as the operator.

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 DJI Phantom 2

Vision+ when weighing less tha n 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.8

3. The UA may not be o perated at a speed exceeding 87 knots (100 miles per hour). The exemption holder 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 th e maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. 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 airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must 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 must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure tha t the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as t he operating documents. The operating

documents 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 or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extensi on 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 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 undergo9

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 funct ional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each fligh t, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a c ondition 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.

11. The operator must follow the UAS manufacturer’s ma intenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territ ory, a possession, or the Federal government. 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.

14. The operator may not permit any PIC to operate unle ss the PIC 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. PIC qualification flight hours and currency must 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 P IC’s ability to safely operate the UAS in a manner consistent with how the UAS 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. D uring training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.10

15. 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.

16. The 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. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA mus t return to a pre

determined location within the private or controlled

- access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecas t 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.

21. Air Traffic Organization (ATO) Cer tificate of Waiver or Authorization (COA). All operations shall 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 C OA

.

22. 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 (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Marki ngs must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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 tim e the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.11

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must 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 must 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 ob jects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall 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

ob tained for each flight to be conducted.

28. 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 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

.

If this exemption permits closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming , the operator of the UAS affected by this exemption must 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 concurren ce 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 aerial filming conducted under this grant of exemption;12

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

- scene operation of the UAS;

d. Make, model, and serial or N

- Number of UAS to be used;

e. Name and certificate number of UAS 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 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 ma ps 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.

31. 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 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 March 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service