Running head: FLIGHT OPERATION MANUAL 1

Independent Droneography

Motion Picture and 

Television Flight 

Operation Manual

UAS 333 Exemption for Motion Pictures

Michael Duncan

12/7/2015
FLIGHT OPERATION MANUAL 2

Date: 12.05.2015 Revision: Original

Motion Picture and Television Flight Operation Manual

By

Michael Duncan

Independent Film UAS Operator

Petition for FAA 333 Exemptions

07.13.2015

ID: FAA-2015-2757-0001
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Revision Control Page

Revision: # Date: Initials:
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Contents

1. Introduction...............................................................................................................................................5

A. Purpose.....................................................................................................................................................5

B. Pilot/Operator Organization .....................................................................................................................5

C. Persons Authorized ..................................................................................................................................5

D. Area of Operations...................................................................................................................................6

E. Plan of Activities......................................................................................................................................6

F. Permission to Operate...............................................................................................................................6

G. Security ....................................................................................................................................................7

H. Briefing of Pilot/Production Personnel ....................................................................................................7

I. Certification/Airworthiness ......................................................................................................................8

J. Pilot Personnel/Minimum Requirements ..................................................................................................9

K. Communications ......................................................................................................................................9

L. Accident Notification .............................................................................................................................10

M. Recall/Stop Procedures..........................................................................................................................10

N. Aerobatic Competency...........................................................................................................................10

O. Special Provisions..................................................................................................................................10

2. Company Organization ...........................................................................................................................11

Appendix A .1.............................................................................................................................................13

Appendix A .2.............................................................................................................................................14

Appendix A .3.............................................................................................................................................15

Appendix A .4.............................................................................................................................................16

Appendix B .1 .............................................................................................................................................17
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1. Introduction

A. Purpose

This manual has been developed by Michael Duncan, an independent film Unmanned Aerial 

System (UAS) Operator, hereafter referred to as “Independent UAS Operator”, in conjunction 

with an application for a Certificate of Waiver or Authorization of the provision of the General 

Operating and Flight Rules of FAR 91.119 (b) and (c) for the purpose of filming. Independent 

UAS Operators pilots and other company personnel when applicable will comply with the 

policies, procedures and conditions of this manual, whenever motion picture or television flight 

operation are performed that require a Waiver of Authorization as mentioned above. 

B. Pilot/Operator Organization

Michael Duncan – Airline Transport Pilot, Certificate

Independent UAS Operator

224 Curtiss Park Way, Suite 1

Miami Springs, FL 33166 

Michael Duncan – Director of Operations 404.663.4389

C. Persons Authorized

FAR 91.119 (c) is waived only with respect to those persons, vehicles and structures directly 

involved in the performance of the actual filming. The certificate holder shall 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 an

equivalent level of safety can be achieved and the Administrator has approved it. For example, 

an equivalent level of safety may be determined by an ASI’s evaluation of the filming production 

area to note terrain features, obstructions, building, etc. Such barriers may protect 

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

accident.
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D. Area of Operations

Michael Duncan, Independent UAS Operation, shall conduct approved areas of operation and 

activities throughout the continental United States, excluding Alaska and Hawaii. While the 

waiver is issued by the pilot/operator’s local Flight Standards District Officers (FSDO), the 

pilot/operator must coordinate with FSDO having geographic responsibility over the area of the 

filming operations.

E. Plan of Activities

Michael Duncan, pilot/operator shall submit 3 days before scheduled filming a written plan of 

activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of 

activities will include the following.

1. Dates and times for all flights.

2. Name and phone number of person responsible for the filming production event.

3. Name and phone number of person responsible for UAS aircraft.

4. Make, model, and serial or N-number of UAS aircraft to be used and type of

airworthiness certificate, including category.

5. Name and certificate number of pilots involved in the filming production event, including 

any notation of external load endorsements or aerobatic competency, if required.

6. A statement that the waiver holder 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 from the waiver holder.

7. Signature of waiver holder or representative.

8. 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 minimum altitudes 

essential to accomplish the operations.

The three (3) day notification equipment may be waived; however, the operator should contact 

the FSDO as soon as possible with this request and be prepared to explain in detail why the three 

(3) day notification is not practical.

F. Permission to Operate

Before any flight operation is conducted at less than 500 feet under the provisions of the 

certificate of waiver and this manual, the operator will obtain permission to conduct these
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operations from property owners and local officials as necessary or appropriate. Persons from 

whom permission may be required are listed below.

1. Property owners

2. Law enforcement officials

3. Fire department officials

4. Local, State and Federal government

5. Air traffic control

Michael Duncan, Independent UAS operator, and personnel obtaining such permission will do so 

in writing whenever practical, however, verbal permission is acceptable otherwise, a standard 

permission form is provided in Appendix A and may be used when obtaining written permission. 

Independent UAS operators will ensure that a sufficient number of those forms are available at 

the job site. Written permission forms will be maintained at the job site until the flight operations 

are completed, and then turned into the pilot/UAS flight operations manager to be kept on file for 

a minimum of six (6) months. These forms will be made available for inspection to the FAA or 

other official personnel upon request.

G. Security

Prior to any flight the operator will coordinate with the appropriate production personnel to 

devise a plan of action for securing the area(s) of operation from all unauthorized persons and 

vehicles. Provisions will be made to immediately discontinue operations should the area(s) 

become unsecured or for any other reason in the interest of safety.

H. Briefing of Pilot/Production Personnel

Prior to the start of any operation under the provisions of this manual, the pilot/ UAS Operator in 

command will conduct a briefing of all procedures to participating personnel of the risks 

involved, emergency procedures, and safeguards to be followed during the filming production 

event. Personnel will also be briefed on additional provisions that may be issued by the FSDO 

that has geographic responsibility for the operational area, including the location of boundaries 

or time limits. The briefing shall cover the following:

 Authorization for motion picture and television certificate of waiver and the attached 

special provisions

 Operation manual

 Plan of activities
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 Aircraft parking and starting

 Taxi procedures

 Radio communications

 Takeoff procedures

 Aviation activities to be conducted during the filming production event

 Approach and landing procedures

 Recall procedures

 Emergency procedures

 Risks to participating personnel

 How to control nonparticipating persons

I. Certification/Airworthiness

All of Michael Duncan’s, UAS aircrafts, will be used in operations requiring a waiver of FAR 

91.119 (b) and (c) for the purpose of filming will be property certified and hold airworthiness 

certificates. However, restricted category aircraft cannot be used as the filming “vehicles” in

motion picture and television filming. Also, aircraft in the experimental category must have an 

airworthiness certificate issued for the purpose of exhibition in order to be used in motion picture 

and television filming. The aircraft will have a 100hr/annual inspection program. Other required 

tests and inspections (transponder, emergency locator transmitter, (ELT), etc., will be performed 

as per Part 91 when necessary. Each aircraft will have a flight log containing upcoming 

scheduled maintenance and inspections and the dates or time they must be performed. A section 

for discrepancies is also found in the flight log. The pilot/operator in command will assure that 

the aircraft to be flown is in airworthy condition and all required inspections and maintenance 

has been completed before each flight.

Additionally, the aircraft may be certificated in any category, including experimental, provided 

the requirement of 14 CFR 91.313, 91.319 and 91.203 are met. Procedures shall be included to 

ensure that aircraft inspections will be in accordance with the applicable part 43, 91, or the 

assigned operating limitation. Michael Duncan, Independent film UAS pilot/operator has 

requested an exemption from 14 CFR 21(h). This exemption meets the requirements for an 

equivalent level of safety pursuant to Section 333 based on the small size, light weight, relatively 

slow speed, and use in controlled environment on private land, as described in the petitioner,

petition for an FAA 333 Exemption. In Exemption No. 11138, the FAA stated that the Secretary 

of Transportation has determined that a member of the DJI Phantom 2 family, the Phantom 2 

Vision+ meets the statutory conditions of Section 333, considering the size, weight, speed, and 

limited operating area associated with the aircraft and its operation.
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Equivalent level of safety: Michael Duncan’s proposed exemption meets the requirements for 

an equivalent level of safety of this section, pursuant to Section 333, based on the following 

factors: reference petitioner’s petition for FAA 333 exemption dated 07/13/2015, ID: FAA-2015-

2757-0001.

J. Pilot Personnel/Minimum Requirements

The pilot/operator shall establish and specify the minimum pilot requirements. Minimum 

requirements shall meet or exceed the following:

1. A Current U.S. Commercial pilot certificate with ratings appropriate to the category, 

class and type (if applicable) of aircraft to be used under the terms of the waiver.

2. At least 500 hours logged as Pilot-in-Command (PIC), and at least 20 hours logged as the 

PIC in the aircraft type.

3. A minimum of 100 hours in the category and class of aircraft to be used.

4. A minimum of 5 hours in the make and model aircraft to be used under the waiver.

5. In the event that the 1,500-foot minimum standard contained in the 14 CFR 91.303 (e) is 

to be waived, the pilot performing aerobatic maneuvers must hold FAA form 8710-7, 

Statement of Aerobatic Competency, to perform the operations.

6. In the event the operation to be conducted contains elements of an external-load 

operation, whether fixed or rotary wing operations, pilots used in the operation shall be 

qualified. This qualification may be obtained through a knowledge test (which may be 

oral and/written) and/or skill. The inspector or another company pilot approved by the 

geographically responsible FSDO who is qualified to carry loads externally will give the 

test(s) which are similar to Part 133 requirements and cover the following subjects:

a) Steps to be taken before starting operations, including a survey of the flight area.

b) Proper method of loading, rigging, or attaching the external load,

c) Aircraft performance capabilities under motion picture operating procedures and the 

aircraft flight manual.

d) Proper instructions for flight and ground crew personnel.

e) Aircraft flight manual, pilot operations handbook, or a rotorcraft-load combination flight 

manual and limitations, if appropriate.

K. Communications

Prior to the start of any operation covered by this manual, the pilot in command will formulate a 

plan to provide communications capability to all participants during the actual operation and 
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filming. Oral, visual or radio communication may be used as long as it is effective and capable of 

keeping the participants continuously appraised of the current status of the operation.

L. Accident Notification

Should an accident or incident requiring notification of the NTSB occur, the notification and 

reporting of accidents notifying the National Transportation Safety Board 14 CFR part 830, and 

protection of the accident scene will be comply with.

M. Recall/Stop Procedures

Radio communication, oral, visual or a combination will be utilized to keep the participants 

continuously apprised of the current status of the operation.

N. Aerobatic Competency

If the filming operation requires the issuance of FAA Form 8710-7, Statement of Aerobatic 

Competency, refer to Volume 5, Chapter 9, Issue/Renew/Rescind a Statement of Aerobatic 

Competency.

O. Special Provisions

The controls, procedures, and conditions set forth in the Independent film UAS, motion picture 

and television operations manual is the primary assurance that persons on the surface will not be 

jeopardized.

The aircraft UAS and pilots under this authorization and/or waiver will only be those specified in 

the Independent film UAS motion picture and television operations manual (“Appendix A” page 

12) or associated plan of activities. Each pilot’s name and certificate number shall appear on 

each daily plan of activity. All civil aircraft and pilot(s) participating in the activity shall be 

available for FAA inspection before the scheduled event.

Each pilot-in-command conducting operations authorized under this certificate understands the 

conditions of issuance, and that it constitutes a waiver of FAR 91,119 (b) and (c) (see attached 

document under “Appendix B” page 16).
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Rotorcraft takeoff and landing areas will be protected in a manner that will prevent unauthorized 

persons from entering the takeoff and landing area.

Independent UAS Films will ensure that the participating persons involved in the operations are 

thoroughly briefed on special procedures, communication, emergency procedures, and on the 

provisions of the authorization and/or waiver before beginning the activities. No person may 

participate in any event unless that person has received a briefing on the provisions of the 

waiver.

2. Company Organization

A. Chief UAS Operator/Pilot

Duties and Responsibilities:

 Final word in the formulation of policy and procedures concerning this Motion Picture 

and Television Operation Manual.

 Will act as liaison between Independent UAS Films and the FAA on matters concerning 

this manual.

 Assure that each approved pilot is issued a copy of this manual and obtain a signed 

statement from each that they have read and understand its contents.

 Maintain a current copy of this manual at the main base of operations for Independent 

UAS Films.

 Responsible for assuring that all revisions to this manual are distributed and processed 

properly.

 Must approve or disapprove each proposed job or operation performed by Independent 

UAS Films, under the provisions of this manual.

 Assume the responsibilities of pilot in command when acting as such.

 The UAS operator/pilot may delegate functions to other personnel but retains the 

responsibility.

B. Pilot in Command

Duties and Responsibilities:

 Assure that aircraft to be flown is in an airworthy condition and all inspections and 

required maintenance have been performed as per the appropriate FAR’s.

 Acquire permission from the chief UAS operator/pilot before any operation under the 

provisions of this manual.
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 Be very knowledgeable of contents of this manual and abide by the procedures, policies 

and conditions contained herein.

 Coordinate with movie and television personnel to formulate plans, routes, locations, etc., 

with the safety of all persons involved as the primary concern.

 Maintain their copy of this manual in current condition and have it on site at any job or 

operation requiring the waiver.

 The PIC may delegate functions to other personnel, but retains responsibility.
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Appendix A .1

List of Approved Pilots/ UAS Operators

Chief UAS Operator/Pilot

Name Michael Duncan

Certificate Number 215994

Grade Airline Transport Pilot-Multi Engine L 

Medical Class/Date First Class 07/2015

Contact Number 404.663.4389
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Appendix A .2

List of Approved Aircraft

Make and Model Registration Number

Tarot FY680-Hexacopter N566UD

Walkera QR X800-Quadcopter N564QD
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Appendix A .3

Independent UAS Films

Permission Acquisition Form

In signing this form, I am granting the pilot of Independent UAS Films, Permission to operate 

their aircraft UAS at less than 500 feet from the property, or in some jurisdiction in which I am 

responsible for or affiliated with, for the purpose of film or television production.

Name: ______________________________________________________

Title: ________________________________

Basis of Authority to Grant Permission: ____________________________

Location: ____________________________________________________

Date of Operation: ______________________

Signature: ____________________________________________________

Date: _________________________________

Independent UAS Films Reprehensive Receiving Permission 
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Appendix A .4

Revision Letter

Revision# Section Page Action Remarks Initials

(R) Remove and Replace (D) Delete and Destroy (N) Insert New Page

Manual Serial# Issued To

Revised by Date

This form must be returned to the Chief no later than 3 days from receipt.
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Appendix B .1

APPLICATION FOR

CERTIFICATE OF WAIVER

OR AUTHORIZATION
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Notes
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Notes