U.S. Department of Transportation 

Document Management System 

1200 New Jersey Ave. 

SE Washington, DC 20590 

October 15, 2015 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., Part 

11, Terrance Miller dba Unmanned Risk Management, operator of Small Unmanned Aircraft 

Systems (“sUAS”) equipped to conduct aerial videography of alpine snow sport competitions 

and alpine snow sport training facilities, requests a limited exemption from the below-listed 

regulations to allow commercial operation of its sUASs, provided that the proposed sUAS 

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

Administration (“FAA”) under Section 333. 

The name and address of the applicant is: Terrance Miller dba Unmanned Risk Management 

 12424 Big Timber Drive, #5 

 Conifer, CO 80433 

 720-208-0844 AlpineSkier@Rocketmail.com 

 

Terrance Miller dba Unmanned Risk Management makes this request under the “summary 

grant” process that the FAA announced in April 2015. (1) This request is similar in all material 

respects to a number of recent grants of exemption, including NFL Productions LLC dba NFL 

Films Grant of Exemption No. 12911 (Regulatory Docket No. FAA–2015–2139). (2) 

Regulations from which the exemption is requested: 

14 C.F.R. part 21 

14 C.F.R. § 45.23 (b) 

14 C.F.R. §§ 61.113 (a) & (b) 

1 See FAA Summary Grants Speed UAS Exemptions, available at 

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

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

NFL Productions LLC dba NFL Films May 20, 2015 application and the FAA’s September 17, 

2015 approval of that application. 
U.S. Department of Transportation 

October 15, 2015 

Page 2 

14 C.F.R. § 91.7 (a) 

14 C.F.R. § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F.R. § 91.119 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151 (a) 

14 C.F.R. §§ 91.203 (a) & (b) 

14 C.F.R. § 91.405 (a) 

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

14 C.F.R. § 409 (a) (2) 

14 C.F.R. §§ 417 (a) & (b) 

Terrance Miller dba Unmanned Risk Management proposes that it receive an exemption to use 

sUAS to gather footage from closed-set locations in and around alpine snow sport venues and 

alpine snow sport training facilities. Terrance Miller dba Unmanned Risk Management would 

use the footage for the production of training aids and marketing materials. Terrance Miller dba 

Unmanned Risk Management would obtain the consent of all official representatives of teams, 

sanctioning body and group personnel at the venues and training facilities in the vicinity in which 

the sUAS may operate. 

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

system (“NAS”) or to persons and property on the ground. Terrance Miller dba Unmanned Risk 

Management proposes that the exemption apply to civil aircraft that operate within the 

limitations listed below. These limitations were established in the FAA’s grant of NFL 

Productions LLC dba NFL Films request for an exemption: 

1. The sUAS will weigh less than 55 pounds, including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set marketing video, alpine snow sport training video, 

motion picture and television filming are permitted. 

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

Terrance Miller dba Unmanned Risk Management may use either groundspeed or calibrated 

airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be 

operated at airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 
U.S. Department of Transportation 

October 15, 2015 

Page 3 

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

Altitude will be reported in feet AGL. 

5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge (PIC) at all 

times. This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license. 

6. All operations will utilize a visual observer (VO). The UA will be operated within the VLOS of 

the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as 

the PIC always maintains the VLOS capability. The VO and PIC will be able to communicate 

verbally at all times; electronic messaging or texting will not be permitted during flight 

operations. The PIC will be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the duties 

required of the VO. 

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

accordance with the conditions and limitations stated in the grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents will be accessible during 

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

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

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

followed. Otherwise, Terrance Miller dba Unmanned Risk Management will follow the 

procedures as outlined in its operating documents. Terrance Miller dba Unmanned Risk 

Management may update or revise its operating documents. It is Terrance Miller dba Unmanned 

Risk Management’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. Terrance Miller 

dba Unmanned Risk Management will also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If Terrance Miller dba 

Unmanned Risk Management determines that any update or revision would affect the basis 

upon which the FAA granted this exemption, then Terrance Miller dba Unmanned Risk 

Management must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions 

to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property. 
U.S. Department of Transportation 

October 15, 2015 

Page 4 

9. Terrance Miller dba Unmanned Risk Management is responsible for maintaining and 

inspecting the UAS to ensure that it is in a condition for safe operation. 

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the sUAS is in 

a condition for safe flight. The pre-flight inspection will account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the sUAS, the aircraft will be prohibited form operating until the 

necessary maintenance has been performed and the sUAS is found to be in a condition for safe 

flight. 

11. Terrance Miller dba Unmanned Risk Management will follow the sUAS manufacturer’s 

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

aircraft components. 

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

13. Under this grant of exemption, a PIC will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal Government. The PIC also will meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. 

14. Terrance Miller dba Unmanned Risk Management will not permit any PIC to operate unless 

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

sUAS will be operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC 

qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 

61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, 

and experience-building) and determining the PIC’s ability to safely operate the sUAS in a 

manner consistent with how the sUAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC will 

operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 

91.119. 

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

operations will be conducted under visual meteorological conditions (VMC). Terrance Miller dba 

Unmanned Risk Management will not operate flights under special visual flight rules (SVFR). 
U.S. Department of Transportation 

October 15, 2015 

Page 5 

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

denoted in the current FAA Airport/Facility Director (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption holder. The 

letter of agreement with the airport management will be made available to the Administrator or 

any law enforcement official upon request. 

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the sUAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

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

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

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

operation and to operate after that for at least three minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

will be conducted in accordance with an ATO-issued COA. The exemption holder may apply for 

a new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the attached COA. 

22. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

23. Documents used by Terrance Miller dba Unmanned Risk Management to ensure the safe 

operation and flight of the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 

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

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

official upon request. 

24. The UA will remain clear and give way to all manned aviation operations and activities at all 

times. 
U.S. Department of Transportation 

October 15, 2015 

Page 6 

25. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures, unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. NFL Films will ensure that nonparticipating 

persons remain 

under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring 

the safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees, essential persons, or individuals who have signed consent 

forms are not considered nonparticipating persons under this exemption. 

26. All operations will be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

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

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

of the operational area as defined by the applicable COA will be reported to the FAA’s UAS 

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

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

www.ntsb.gov. 

If this exemption permits operations for the purpose of closed-set motion picture and television 

filming and production, the following additional conditions and limitations apply: 

28. Terrance Miller dba Unmanned Risk Management will have a motion picture and television 

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

29. At least 3 days before aerial filming, Terrance Miller dba Unmanned Risk Management will 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights; 
U.S. Department of Transportation 

October 15, 2015 

Page 7 

b. Name and phone number of the operator for the sUAS aerial filming conducted under this 

grant of exemption; 

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

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

e. Name and certificate number of sUAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission will be 

made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, 

and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation. 

30. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 CFR 

including, but not limited to, parts 45, 47, 61, and 91. Terrance Miller dba Unmanned Risk 

Management incorporates all arguments in support of the petition made in NFL Films 

application for exemption May 20, 2015. 

Federal Register Notice 

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

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

publication is necessary, the following summary is provided: 

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

45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 91.121; 

91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 (a)(2) and 91.417 

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

operations. 
U.S. Department of Transportation 

October 10, 2015 

Page 8 

The Exemption is in the Public Interest 

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

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

Miller dba Unmanned Risk Management would provide tremendous public benefits by enabling 

thousands of alpine snow sports fans, coaches, athletes and sanctioning bodies to view footage 

that could not be captured via any other technology. The sUAS operations as described in this 

application will be far safer and more efficient than use of helicopters, hand-held poles and 

devices or other aircraft to capture the required footage. 

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

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

operation within visual line of sight,” and therefore the proposed operations would not. 

“create a hazard to users of the national airspace system or the public or pose a threat to 

national security.” As discussed above, Terrance Miller dba Unmanned Risk Management 

agrees to use limitations that are substantially identical to those contained in the FAA’s recent 

grant of exemption for Advanced Aerial Cinematography. Accordingly, the proposed UAS 

operations of Terrance Miller dba Unmanned Risk Management should not raise safety or 

national security concerns, and should receive summary approval. 

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

Respectfully submitted, 

Terrance Miller dba Unmanned Risk Management 
Appendix A 

Terrance Miller dba Unmanned Risk Management 

Permission to Conduct Operations Form 

In signing this form, I am giving Terrance Miller dba Unmanned Risk Management 

permission to operate its aircraft at less than 500 feet from property, or, in some jurisdiction 

in which I am responsible for or affiliated with, for the purpose of film or television 

production. 

Name: ____________________________ 

Title: ____________________________ 

Location: ____________________________ 

Date of 

Operation: ____________________________ 

Basis of Authority to Grant Permission: 

______________________________________________________________________ 

Signature: ____________________________ 

Date: ____________________________ 

Terrance Miller dba Unmanned Risk Management Representative Receiving Permission: 

________________________________________ 
Appendix B 

Terrance Miller dba Unmanned Risk Management 

 

List of Approved Aircraft 

Make and Model Type Weight 

1 DJI Innovations 

Phantom 2 

Quad-rotor 3 lbs. (inclusive of 

camera and battery) 

2 DJI Innovations 

Phantom 3 

Quad-rotor 3 lbs. (inclusive of 

camera and battery) 

3 

4 

 

DJI Innovations 

Inspire 

AirDog 

Quad-rotor 

Quad-rotor 

6 lbs. (inclusive of 

camera and battery 

3 lbs. (inclusive of 

cameral and batter)