Conditions and Limitations

Relative to this grant of exemption, 4Rotor Filming llc is hereafter referred to as the operator.

The Flight Operations and Procedures Manual (FOPM) and Motion Picture and Television 

Operations Manual (MPTOM) are hereafter collectively referred to as the operator’s 

manual.

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.

The operator proposed the following conditions and/or limitations, which were accepted by the 

FAA.* 

 

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy 

source(s) and equipment. Operations authorized by this grant of exemption are limited to 

the following aircraft described in the operator’s manual: DJI S900 N545YK serial # 

0370060608. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

2. The UA may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator’s manual. All altitudes 

reported to ATC must be in feet AGL.

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.

6. The operator’s manual is considered acceptable to the FAA, provided the additional 

requirements identified in these conditions and limitations are added or amended. The 

operator’s manual and this grant of exemption must be maintained 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 operator’s manual, the 

conditions and limitations herein take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operator’s manual. The operator may 

update or revise its operator’s manual. 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. If the operator determines that any update or revision would affect the basis 

for which the FAA granted this exemption, then the operator must petition for amendment to 

their exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operator’s manual 

 

 * Conditions and limitations outlined by the operator may have been modified for clarity. 
7. 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, if 

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

be properly documented in the aircraft records.

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 in accordance with the operator’s manual. The PIC who conducts the 

functional test flight must make an entry in the UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight and aircraft record entry must be 

added to the operator’s manual.

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

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance 

requirements must be established and identified in the operator’s manual. At a minimum, 

requirements for the following must be included in the operator’s manual: 

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;

10. The Pilot In Command (PIC) must possess at least a private pilot certificate and at least 

a current third-class 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.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 
 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type 

(single blade or multirotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During 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.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

 14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations under the exemption and three take-offs and 

three landings in the preceding 90 days. Training, proficiency, experience-building, and 

take-off and landing currency flights can be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 

experience- building, and take-off and landing currency 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.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must 

have successfully completed a qualification process, as outlined in the operator’s 

manual. As this is a requirement stipulated by the operator, the test must be developed 

and implemented by a qualified person designated at the sole discretion of the operator. 

A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified 

pilot must be successfully completed and documented. This documentation must be 

available for review upon request by the Administrator. Because the knowledge and 

airmanship test qualifications have been developed by the operator, and there are no 

established practical test standards that support a jurisdictional FAA FSDO evaluation 

and approval of company designated examiners, the petitioner will conduct these tests 

in accordance with the operator’s manual.

15. The UA may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the 

surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those 

persons must be essential to the closed-set film operations. Because these procedures 

are specific to participating persons, no further FSDO or aviation safety inspector 

approval is necessary for reductions to the distances specified in the petitioner’s 

manuals. This is consistent with the manned aircraft procedures described in FAA Order 

8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television 

Filming. 
17. Regarding distance from nonparticipating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved 

and necessary for the filming production. This provision may be reduced to no less than 

 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

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

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25% battery 

power remaining, whichever occurs first. 

In addition to the conditions and limitations proposed by the operator, the FAA has determined 

that any operations conducted under this grant of exemption must be done pursuant to the 

following conditions and limitations:

21. 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.

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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.

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

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all discrepancies, 

i.e. inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual. 
27. 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. 

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;

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 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 aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

30. The UA must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

31. 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.

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

33. 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. 
34. The UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport 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.

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 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. Further flight operations may not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to 

resume operations is provided.

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.