March	8,	2015 REVISION	TO	MARCH	6	LETTER	&	DOCUMENTS

Page	1 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

396 Washington Street

Suite 260

Wellesley Hills, MA 02481-6209

U. S. Department of Transportation 

Docket Management System 

Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 

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) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & 

(b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, VizTools LLC, operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography for the motion picture and 

television industry for scripted closed set filming, hereby submits a replacement 

application for its previously submitted application for exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as 

such operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 

4) would provide safety enhancements to the already safe operations in the film and 

television industry presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the safe operation of 

such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

VizTools LLC 

Attn: Roland J. Boucher, Jr.

Ph: 781-789-9026

Email: rboucher@viztools.tv

Address: 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

																																																							 1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue 

a Certificate of Waiver for Motion Picture and Television Filming.
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Page	2 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 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 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following: 

• _The UAS’s size, weight, speed, and operational capability; 

• _Operation of the UAS in close proximity to airports and populated areas; and 

• _Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” Id. 

§333(c) (emphasis added)2

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

term is defined under §40101 of the Act,that includes sUASs, from the requirement that 

all civil aircraft must have a current airworthiness certificate. 

																																																							 2 Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, 

if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for 

approval.
March	8,	2015 REVISION	TO	MARCH	6	LETTER	&	DOCUMENTS

Page	3 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

VizTools LLC’s sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. 

They will operate only in line of sight and will operate only within the sterile area 

described in the VizTools Operations Manual, attached as Exhibit 1 (hereinafter “the 

Manual”)3. Such operations will insure that the sUAS will “not create a hazard to users of 

the national airspace system or the public.”4

Given the small size of the sUASs involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also due to 

the size of the UASs and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with allowing UASs for movie and 

television operations, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe movie and television filming operations 

conducted with conventional aircraft. 

																																																							 3 Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual 

contains proprietary information that the applicant has not and will not share with others. The manual 

contains operating conditions and procedures that are not available to the public and are protected from 

release under the Freedom of Information Act 5 USC 552 et.seq. 

4 Reform Act Section 333 (b).
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Page	4 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

These limitations and conditions to which VizTools LLC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 15 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 15

minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not 

more than 200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual 

Observer, and the Camera Operator. 

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also 

present on set (i.e. the Aerial Coordinator), that person can also be designated 

as PIC. 

8. The UAS will only operate within a confined “Sterile Area” as defined in the 

Manual. The Manual requires the establishment of a “Security Perimeter” for the 

flight operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s production activities. It will be mandatory that all personnel who will 

be performing duties within the boundaries of the safety perimeter be present for 

this briefing. 

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in 

light of the requested exemption, with the appropriate Flight Standards District 

Office. 

11. The operator will obtain the consent of all persons involved in the filming and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and this radius may be reduced to 30 feet based upon an equivalent 

level of safety determination, as required the Manual. With the advanced 

permission of the relevant FSDO, operations at closer range can be approved. 

12. The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed shoot as required in the Manual. 

13. Pilot and observer will have been trained in operation of sUAS generally and 

received up-to-date information on the particular sUAS to be operated as 

required by the Manual. 

14. Observer and pilot will at all times be able to communicate by voice and/or 

text. 

15. Written and/or oral permission from the relevant property holders will be 

obtained. 

16. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

17. If the sUAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Security Perimeter and 

land. 

18. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.
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Page	5 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 

(a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operation capability, and proximity to 

airports and populated area of the particular UAS. In all cases, an analysis of these 

criteria demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and operates exclusively within a secured area as set out in the Manual. Unlike other 

civil aircraft, operation under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the Manual’s requirements, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area 

of operation as is now done with conventional filming. The FAA will have advance notice 

of all operations. These safety enhancements, which already apply to civil aircraft 

operated in connection with motion picture and television production, provide a greater 

degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

14 C.F.R. § 45.23 (b). Making of the Aircraft

The regulation requires:

When marks include only the Roman capital letter “N” and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor mores than 6 inches high, the 

words “limited,” :restricted,” “light-sport,” “experimental,” or “provisional,” 

as applicable.

Even though the UAS will have no airworthiness certificates, an exemption may 

be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word “Experimental” can be place. Given the size of the sUAV, two-ince 

lettering will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its 
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Page	6 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the sUAS is remotely controlled with no living thing on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Manual. The level of safety provided by the requirements 

included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with 

the operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations 

of the sUAS as requested with a private pilot as the PIC exceeds the present level of 

safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the 

Manual for maintenance and use of safety check lists prior to each flight, as set forth in 

Sections J, L and Q, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required 

by §21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof.
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Page	7 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

The sUAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. An equivalent level of safety will 

be provided as set forth in the Manual. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. 

sUASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or 

not more than 200 above an elevated platform from which filming is planned, an 

exemption may be needed to allow such operations. As set forth herein, except for the 

limited conditions stated in the Manual, the UAS will never operate at higher than 400 

AGL. It will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained 

consent.
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Page	8 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

The equivalent level of safety will be achieved given the size, weight, speed of 

the UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be 

aware of the planned flight operations as set forth in the Manual. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating 

at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the 

sUAS will ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 15 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights 

would not be possible. Given the limitations on the UAS’s proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for 

flight in daylight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 

to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed, with less than 15 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. Additionally, grounding sUAS flights which do not have 

sufficient reserves, would greatly reduce the utility for which the exemption will be 

granted.

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 15 minutes or 25% of battery power whichever happens first. This restriction 

would be more than adequate to return the sUAS to its planned landing zone from

anywhere in its limited operating area.
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Page	9 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil 

aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to them, 

to the extent they are applicable to the sUAS. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain 

the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook as 

referenced in the Manual.(See Sections L and Q) An equivalent level of safety will be 

achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no higher than 

400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.
March	8,	2015 REVISION	TO	MARCH	6	LETTER	&	DOCUMENTS

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10

VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 

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 (55lbs or less) in motion 

picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in the film 

industry will enhance safety by reducing risk. Conventional film operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from the subject being 

filmed and in extreme proximity to people and structures; and present the risks 

associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large 

amounts of jet A or other fuel (140 gallons for jet helicopters shown below). Such aircraft 

must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. 

and powered by batteries eliminates virtually all of that risk given the reduced mass and 

lack of combustible fuel carried on board. The sUAS is carried to the film set and not 

flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Filming will be of people who have also 

consented to being filmed or otherwise have agreed to be in the area where filming will 

take place. 

All filming is to be conducted during daylight hours.
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11

VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s UAS in the motion picture and television industry pursuant to the Manual 

appended hereto. 

Sincerely, 

Roland J. Boucher, Jr.

President

VizTools LLC. 

Enclosures:

These	are	to	be	considered	proprietary	documents	and	are	not	to	be	published	in	

the	Federal	Record.

VizTools	Operations	Manual	(Revised)

S1000	Plus	User	Manual	v1.2

S800	EVO	User	Manual	v1.10

Z15	5D	III	HD	User	Manual	v1.2

Z15-GH4	HD	User	Manual	v1.2