Peak 3 LLC, Anchorage, AK - Section 333 Exemption Petition Page 1

September 9, 2015 

U.S. Department of Transportation

Washington DC 20590 

Re: Request for Additional Information - Peak 3 LLC

(Docket No. FAA-2015-2406)

Dear Sir or Madam,

I, Zachary Melms, Managing Member of Peak 3 LLC, am writing to provide the 

additionally requested information pertaining to Peak 3 LLC’s request for a Section 333 

Exemption. 

The additionally information requested is as follows: 

1. Describe the aircraft make(s), model(s), and type(s) (i.e., fixed-wing, rotorcraft, 

lighter-than-air) for the proposed UAS operation. The description(s) should 

include the maximum weight (including payload). This information can be 

located in the aircraft manual(s).

Response:

The aircraft proposed include: 

#1 Make: DJI Inspire 1 

Model: T600 

Type: Rotorcraft 

Maximum Weight: 2940 grams 

#2 Make: DJI Phantom 3 Professional 

Model: n/a 

Type: Rotorcraft 

Maximum Weight: 1280 grams 

2. Please provide a copy of the following referenced materials: Motion Picture and 

Television Operations Manual (MPTOM)

Response:

The requested materials are included in this document on subsequent pages. 

They have also been uploaded to the Docket No. FAA-2015-2406.

Respectfully Submitted, 

Zachary Melms,

Managing Member Peak 3 LLC 
PEAK 3 LLC - MPTOM

Motion Picture and Television

Flight Operation Manual 

Peak 3 LLC

7731 Bethany Circle

Anchorage, AK, 99507

(406) 599-3557 

Date: 5.15.2015 Page 1 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Table of Contents 

1. Introduction 

 A. Purpose 4

 B. Pilot/Operator Organization 4

 C. Persons Authorized 4

 D. Area of Operations 4

 E. Plan of Activities 5

 F. Permission to Operate 5

 G. Security 6

 H. Briefing of Pilot/Production Personnel 6

 I. Certification/Airworthiness 7

 J. Pilot Personnel/Minimum Requirements 7

 K. Communications 8

 L. Accident Notification 8

 M. Recall/Stop Procedures 8

 N. Aerobatic Competency 8

 O. Aerobatic Competency 9

2. Company Organization 

 A. Chief Pilot 9

 B. Pilot in Command 10

Appendix A 

1 List of Approved Pilots 11 

2 List of Approved Aircraft 12

3 Permission Acquisition Form (sample) 13

 4 Revision Letter (sample) 14 

Date: 5.15.2015 Page 2 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Revision Control Page 

Revision # Date Initials 

____________________________________________________________________________ 

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

Date: 5.15.2015 Page 3 of 15 Revision: Original
PEAK 3 LLC - MPTOM

1. Introduction

A. Purpose 

This manual has been developed by “PEAK 3 LLC.", hereafter referred to as “P3", in 

conjunction with an application for a Certificate of Waiver of Authorization of the 

provisions of FAR 91.119 (b) and (c) for the purposes of filming. P3 pilots and other 

company personnel when applicable will comply with the policies, procedures and 

conditions of this manual, whenever motion picture or television flight operations are 

performed that require a Waiver of Authorization as mentioned above. 

B. Pilot/Operator Organization 

Zachary Melms - Managing Member

Peak 3 LLC

7731 Bethany Circle

Anchorage, Alaska 99507 

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, buildings, etc. Such barriers may protect 

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

event of an accident. 

D. Area of Operations 

P3 approved areas of operations will be Alaska & Hawaii & the continental United 

States.

Date: 5.15.2015 Page 4 of 15 Revision: Original
PEAK 3 LLC - MPTOM

E. Plan of Activities 

At least three (3) days prior to any scheduled filming, P3 will submit a written plan of 

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

should 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 aircraft. 

(4) Make, model, and serial or N-number of 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 equipments 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 operations 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 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

Date: 5.15.2015 Page 5 of 15 Revision: Original
PEAK 3 LLC - MPTOM

(3) Fire department officials

(4) Local, State and Federal government (5) Air traffic control 

The P3 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. P3 

personnel will assure a sufficient number of those forms are available at the job site. 

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

completed, and then turned into the chief pilot to be kept on file for a minimum of six 

(6) months. These forms will be made available for inspection by the FAA or other 

official personnel upon request. 

G. Security 

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

personnel to devise a plan of 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 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: 

• Authorization for motion picture and television certificate of waiver and the 

attached special provisions 

• Operations manual

• Plan of activities

• Aircraft parking and starting

• Taxi procedures

• Radio Communications

• Takeoff procedures

Date: 5.15.2015 Page 6 of 15 Revision: Original
PEAK 3 LLC - MPTOM

• 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 P3 aircraft used in operations requiring a waiver of FAR 91 .119 (b) and (c) for the 

purpose of filming will be properly certified and hold airworthiness certificates. 

However, restricted category aircraft cannot be used as the filming "vehicle" 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 be 

100hr/annual inspection program. Other required tests and inspections (transponder, 

E.L.T., 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 times they must be performed. A section for discrepancies is also found in 

the flight log. The pilot in command will assure the aircraft to be flown is in airworthy 

condition and all required inspections and maintenance has been completed before 

each flight. 

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 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 Acrobatic Competency, to perform the operations. 

Date: 5.15.2015 Page 7 of 15 Revision: Original
PEAK 3 LLC - MPTOM

(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 filming. Oral, visual or radio communications may be used as 

long as it is effective and is 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 requirements of FAR Part 830 would comply. 

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 operation. 

N. Aerobatic Competency 

If the filming operations require 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.

Date: 5.15.2015 Page 8 of 15 Revision: Original
PEAK 3 LLC - MPTOM

O. Special Provisions

The controls, procedures, and conditions set forth in the P3 motion picture and 

television operations manual is the primary assurance that persons on the surface 

will not be jeopardized. 

The aircraft and pilots used under this authorization and/or waiver will only be those 

specified in the P3 motion picture and television operations manual (“Appendix A” 

page 11) 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). 

Rotorcraft takeoff and landing areas will be protected in a manner that will prevent 

unauthorized persons from entering the takeoff and landing area. 

P3 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 Pilot 

Duties and Responsibilities: 

• Final word in the formulation of policy and procedures concerning this 

manual. 

• Act as liaison between P3 and the FAA on matter 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. 

Date: 5.15.2015 Page 9 of 15 Revision: Original
PEAK 3 LLC - MPTOM

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

P3. 

• 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 

P3 under the provisions of this manual. 

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

• The chief pilot may delegate functions to other personnel but retains 

responsibility. 

B. Pilot in Command 

Duties and Responsibilities: 

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

and required maintenance have been performed as per appropriate FAR's. 

• Acquire permission from the chief pilot before any operation under the 

provisions of this manual. 

• Be very knowledgeable of the 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 safety of all persons involved in 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 pilot in command may delegate functions to other personnel, but 

retains responsibility. 

Date: 5.15.2015 Page 10 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Appendix A.1 

List of Approved Pilots 

Chief Pilot 

Name : 

Certificate Number Grade : 

Medical Class/Date : 

Contact Number :

Pilots

Name : 

Certificate Number Grade : 

Medical Class/Date : 

Contact Number : 

Name : 

Certificate Number Grade : 

Medical Class/Date : 

Contact Number :

Date: 5.15.2015 Page 11 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Appendix A.2 

List of Approved Aircraft

Make and Model Registration Number

1.

2.

3.

4.

5.

6.

7.

Date: 5.15.2015 Page 12 of 15 Revision: Original
PEAK 3 LLC - MPTOM

A.3 

Peak 3 LLC

Permission Acquisition Form (example)

In signing this form, I am giving the pilots of Peak 3 LLC. permission to operate their 

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:

Basis of Authority to Grant Permission: Location:

Date of Operation: 

Signature __________________________________________________

Date __________________________ 

Peak 3 LLC Representative Receiving Permission 

_______________________________________________________________ 

Date: 5.15.2015 Page 13 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Appendix A.4 

Revision Letter

Rev# 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 Pilot no later than _____________________ 

Date: 5.15.2015 Page 14 of 15 Revision: Original
PEAK 3 LLC - MPTOM

Notes:

Date: 5.15.2015 Page 15 of 15 Revision: Original