June 5, 2015

Exemption No. 11749

Regulatory Docket No. FAA–2015–0872

Mr. Blaine N. Miller

Owner

Elevated Cinematics LLC

623 Grecken Green

Peachtree City, GA 30269

Dear Mr. Miller:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 26, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Elevated Cinematics LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct collection of 

aerial photo and video assets.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 and the Tarot 680

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 
2

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Elevated Cinematics LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Elevated Cinematics LLC is hereafter referred to as the operator.

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.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and 

Tarot 680 when weighing 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 motion picture and television filming are 

not permitted. 

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

exemption holder 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.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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 airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (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 VLOS 

capability. The VO and PIC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations 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 operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

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

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator 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.

9. The operator 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 must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must 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 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 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 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.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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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 must 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 UAS in a manner consistent with how the UAS 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 must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

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

denoted in the current FAA Airport/Facility Directory (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 must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is 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 five 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 shall 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 must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must 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. The operator must 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 must 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 or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall 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.

28. 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.

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.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must 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;

b. Name and phone number of the operator for the UAS aerial filming 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 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 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.

31. 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 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.

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

John S. Duncan

Director, Flight Standards Service

Enclosures
Elevated Cinematics LLC 

623 Grecken Green 

Peachtree City GA 30269 

PH: (770) 377-7469 

March 26, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Operations 

1200 New Jersey Avenue SE 

Washington DC 20590 

Re: Petition for an exemption seeking relief from specific sections of Title 14 

 CFR under Section 333 of the FAA Modernization and Reform Act of 

 2012 (Public Law 112-95) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Elevated Cinematics LLC hereby seeks an exemption from the Federal Aviation Regulations as 

detailed below for the purpose of conducting commercial Unmanned Aerial System (UAS) 

operations in the National Airspace System (NAS). 

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TABLE OF CONTENTS 

 Page 

GLOSSARY OF ABBREVIATIONS..................................................................3 

NAME AND ADDRESS OF THE PETITIONER...................................................4 

BACKGROUND AND OPERATING DESCRIPTION.............................................5 

SPECIFIC SECTIONS OF 14 CFR FROM WHICH 

ELEVATED CINEMATICS LLC SEEKS EXEMPTION AND 

THE EXTENT OF RELIEF SOUGHT AND THE REASON 

THAT THE RELIEF IS SOUGHT......................................................................9 

THE REASONS WHY GRANTING THE REQUEST 

WOULD BE IN THE PUBLIC INTEREST..........................................................13 

THE REASONS WHY GRANTING THE REQUEST 

WOULD NOT ADVERSELY AFFECT SAFETY...................................................14 

SUMMARY SUITABLE FOR THE PUBLIC REGISTER.........................................14 

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS 

AVAILABLE TO SUPPORT ELEVATED CINEMATICS LLC’S REQUEST...................15 

ADDENDUM..............................................................................................16 

 

 - Elevated Cinematics LLC Preflight Safety Checklist

 - DJI Phantom 2 Manual 

 - Tarot 680 with DJI Naza Flight Controller 

 - Tarot 680 Ground Control System 

 - FCC License 

 - AMA Safety Code 

 

2 
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

ATC Air Traffic Control 

ATO Air Traffic Organization 

UAV Unmanned Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control System 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot in Command 

Section 333 FAA Modernization and Reform Act of 2012 Section 333 

SOP Standard Operating Procedures 

VFR Visual Flight Rules 

VLOS Visual Line of Sight 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VTOL Vertical Takeoff and Landing

3 
NAME AND ADDRESS OF THE PETITIONER: 

The name and address of the petitioner is: 

Elevated Cinematics LLC 

Blaine N Miller, Owner 

623 Grecken Green 

Peachtree City GA 30269 

(770) 377-7469 

Airline Transport Pilot # 3286199 

FAA First Class Medical Certificate issued 07/21/2014 

Southwest Airlines B737 First Officer 

FCC Amatuer Radio License # 0023625049 (Copy of FCC License in Addendum) 

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BACKGROUND AND OPERATING DESCRIPTION 

Elevated Cinematics LLC seeks exemption from the requirements of 14 CFR FAR Parts 91.7 (a), 

91.9 (b) 2, 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a)1, 91.409 (a) 1 and 2, 91.417 (a) 

and (b) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. This 

exemption will permit Elevated Cinematics LLC to obtain an appropriate Certificate of 

Authorization to operate the described UAV aircraft below within the NAS for the commercial 

purpose of collecting aerial photo and video assets. 

Elevated Cinematics LLC was formed in 2015 by Blaine N Miller. Mr. Miller is an active Part 

121 commercial pilot for Southwest Airlines, holding ATP certificate # 3286199 with Type 

Ratings in the EMB 120, EMB145, DC-9, and B737 aircraft, and holds a valid FAA First Class 

Medical Certificate. Mr. Miller has been flying RC aircraft recreationally and competitively for 

over 30 years and has 2 years of experience operating the type of UAVs that will be flown under 

the desired exemption. 

Elevated Cinematics LLC seeks to provide aerial photo and video services for a variety of clients 

to include residential/commercial real estate brokers, insurance companies, and roofing / 

construction contractors. As set forth in this petition, Elevated Cinematics LLC seeks to 

commercially operate it UAVs with the highest level of safety and professionalism consistent 

with Mr. Miller’s long history as an aviation professional. 

Description of the UAV aircraft and ground control station (GCS): 

DJI Phantom 2: 

The DJI Phantom 2 is a small quadcopter that takes off and lands vertically (VTOL) and is 

powered by 4 electric motors and a 5200 milliampere lithium polymer battery pack. It has a 

ready to fly gross weight of 2.2 pounds and can fly a mission of about 14 minutes duration on a 

fully charged battery, and has a maximum airspeed of approximately 29 knots. It has a 

sophisticated onboard flight controller with GPS integration that provides stabilized flight and 

extremely precise control from the portable Ground Control Station (GCS). There is a flight 

telemetry system that delivers flight data from the onboard flight computer to the GCS including 

altitude AGL, horizontal and vertical speed, battery voltage, compass direction of flight and 

direction back to the takeoff point. The flight controller also has many built-in safety features 

that will command the Phantom to return to the takeoff point in the event of a Loss of Link 

(LOL). There is a low battery voltage indication at 20% battery power remaining, and a “hard” 

warning at 15% remaining that will begin a slow descent for landing. The user can define 

maximum flight parameters such as altitude and/or lateral distance from the GCS. The Phantom 

2 has a 3 axis gimbal that provides stabilization for a small digital camera allowing for smooth 

5 
and accurate photo and video acquisition. The Phantom 2 carries a low power Video Transmitter 

that transmits live video feed data to a 7 inch LCD screen that displays live video data to the 

operator and/or Visual Observer (VO). In the Addendum below is the DJI Phantom 2 User 

Manual.

Tarot 680: 

The Tarot 680 is a small VTOL hexacopter that is powered by 6 electric motors and a 5000 

milliampere lithium polymer battery pack. It has a motor to motor “wingspan” of 30 inches, and 

has a ready to fly gross weight of 3.8 pounds. It can fly a mission of about 12 minutes on a fully 

charged battery pack, and has a maximum airspeed of approximately 29 knots. The Tarot 680 

has an onboard flight controller (DJI Naza) with GPS integration that has the exact same 

operating and safety features and flight characteristics as the Phantom 2 described above 

(including the two battery low level warnings). The camera and camera gimbal carried onboard 

the Tarot 680 is the same as carried on the Phantom 2. The GSC for the Tarot 680 consists of a 

Spectrum DX9 RC transmitter used by the operator to control the UAV, as well as the same 7 

inch LCD screen to view live video downlink images. In the Addendum below is a photograph 

of the Tarot 680 UAV and the related Ground Control System. 

Ground Control Station (GCS): 

The GCS consists simply of a hand-held RC transmitter used to pilot the UAV and a 7 inch LCD 

screen attached to the RC transmitter to view the live image of the on board camera. This makes 

the GCS very portable and allows for flexibility and ease of use. It is also very non-intrusive for 

observers and non-participants.

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The RC transmitter transmits on the 2.4 GHZ band at a power of 100mw and requires no FCC 

license to operate.The 7 inch LCD screen receives and displays the video signal being 

transmitted from the 5.8 GHZ 400 mw video transmitter on board the UAV. This system does 

require an Amateur Radio License from the FCC. Mr. Miller holds a Technician Operator 

License from the FCC ( FCC Registration # 0023625049 granted 05-12-2014) - a copy is 

included in the Addendum. 

Pilot in Command: 

Blaine N Miller is the founder and owner of Elevated Cinematics LLC and will be the sole PIC 

and operator of the UAV being flown. Mr. Miller is an active Part 121 air carrier pilot with more 

than 17 years of airline experience and over 14,000 flight hours logged. Mr. Miller currently 

holds and maintains an FAA First Class Medical certificate. Mr. Miller was graduated in 1995 

from Embry-Riddle Aeronautical University with the degree of Bachelor of Science in 

Aeronautical Science. He has flown RC aircraft of various types for more than 30 years and has 

participated in competitions at the national level. He is a long time member of the Academy of 

Model Aeronautics (AMA # 154165). He has 2 years experience flying the UAV aircraft that 

will be flown under the desired exemption, with more than 50 hours of flight time and over 250 

flight cycles flying the UAVs to be utilized. He is fully capable and familiar with the various 

operating procedures, limitations, and safety features of the equipment to be utilized as described 

in detail above and referenced in the applicable manufacturer manuals (see attached 

manufacturer manuals in the Addendum). Mr. Miller’s qualifications and experience will allow 

him to maintain a safe and efficient operation that will preserve public safety and provide a 

useful and valuable service to both the clients of Elevated Cinematics LLC and the general 

public. 

Visual Observer (VO): 

Elevated Cinematics LLC will utilize a VO consistent with FAA and AMA established best 

practices. 

- All operations will utilize a VO 

- The PIC and VO will be able to communicate by voice at all times 

- The PIC will brief the VO and others concerning the hazards unique to each flight 

- The VO may not operate the aircraft 

- The UAV will be operated in VLOS of the PIC and VO at all times 

- The PIC will be aware of the sight limitations of the VO and plan the flight accordingly 

- Electronic messaging, texting, or any other distracting activity shall not be permitted during 

flight operations 

- The PIC shall be responsible to ensure that the VO is fully capable of performing the required 

duties 

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Operating Procedures: 

UAV operations will be conducted for the purpose of collecting photo and video footage that will 

be used for assisting real estate brokers in advertising real property for sale, assisting 

construction and roofing contractors with detailed site inspection and project progress, and 

capturing other photo and video footage that would be either impractical or impossible using full 

size aircraft. The proposed operations would be conducted as follows: 

- Before and after each flight, a Preflight Safety Checklist will be completed to ensure UAV and 

GSC airworthiness and status, as well as the consistency of condition that checklist usage 

provides instead of reliance on memory (see detailed Preflight Safety Checklist in 

Addendum). 

- All aircraft will be maintained as part of the Preflight Safety Checklist, which mandates that 

before flight the UAV, GSC, and its separate components must be updated with the latest 

firmware version from the manufacturer as spelled out in the applicable Operating Manual. 

Aircraft will be checked before flight for overall condition, nicks or cracks in propellors, 

security of all fasteners, and for proper LED status light indications. Flight battery packs will 

not be used beyond the manufacturers recommended maximum number of cycles. 

- Aircraft flights will terminate with not less than 20% useable battery life, or 3 minutes of 

flight time remaining 

- Aircraft will be flown at a maximum altitude of 400 AGL and not more than 1/2 mile lateral 

distance from the PIC and VO to ensure VLOS at all times. Most flight missions require 

much less than these maximum distance values. These vertical and horizontal distance limits 

shall be monitored in real time by the telemetry data displayed on the GSC and will be set 

within the DJI Flight Controller as manual limits per the DJI Operator Manuals. 

- Aircraft will be flown at a maximum airspeed of 30 knots (35 MPH) 

- The minimum flight visibility for operations shall be 3 statute miles, and a minimum distance 

from clouds will be maintained (500 ft below and 2000 ft horizontally) 

- Aircraft will never be flown via First Person View (FPV) by either the PIC or VO 

- No flight operations will be conducted at night as defined by 14 CFR 1.1 

- No flight operations shall be conducted closer than 5 nautical miles from any airport 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 UAV will remain clear and yield the right-of-way to all manned aircraft at all times 

- The UAV will not be operated closer than 500 feet to any nonparticipating persons, vehicles, 

or vessels unless there is a structure or barrier to protect such persons or property from the 

UAV or debris in the event of an accident, or unless the owner of such vehicles/vessels has 

granted permission and the PIC has made a safety assessment of risk of operating closer to 

those objects and determined that it does not present an undue hazard, and that operations 

nearer to the PIC, VO, operator trainees or other essential persons do not present an undue 

hazard to those persons per FAR 91.119(a) 

- The UAV will not be operated over any congested or densely populated areas.

8 
- All provisions of the AMA Safety Code (see Addendum) will be adhered to as part of a best 

practices strategy. 

Maintenance: 

- All UAV and GSC equipment will be maintained by checked for manufacturer Firmware 

updates and Safety Bulletins 

- No alterations or modifications will be performed unless such action will not pose any 

degradation in safety of performance, and a functional flight test will be performed to verify 

functionality and safety of the affected equipment. 

- Any maintenance, repair, or alteration will be recorded in an aircraft logbook. PIC performed 

maintenance will be limited to replacing faulty/worn out components and updating Firmware 

per manufacturers specifications. Any other maintenance will be performed by the applicable 

manufacturer or their approved repair facility. 

- Total flight time of the UAV and GSC shall be recorded in the aircraft logbook. 

- Lithium polymer batteries shall not be used beyond the recommended service life or number 

of cycles as specified by the manufacturer. 

The petitioner believes that the described operating procedures and limitations, maintenance 

plan, combined with the low weight, speed, and limited area of operation described for the 

intended missions will ensure a measure of safety equal to or greater than a full-size aircraft, and 

that the public will not be subject to any undue hazard. 

SPECIFIC SECTIONS OF 14 CFR FROM WHICH 

ELEVATED CINEMATICS LLC SEEKS EXEMPTION AND 

THE EXTENT OF RELIEF SOUGHT AND THE REASON 

THAT THE RELIEF IS SOUGHT 

- The petitioner believes that as per Section 333 of PL 112-95, and in consideration of the size, 

weight, speed, and limited operating area associated with the aircraft and it’s operation, that 

relief from 14 CFR Part 21 Subpart H regarding Airworthiness Certificates is not necessary 

and therefore relief is not sought. 

FAR Part 91.7(a) prescribes that - 

 

 No person may operate a civil aircraft unless it is in an airworthy condition.

9 
Relief is requested to maintain an airworthy condition by compliance with the operating 

procedures, checklists, and documents prescribed in this petition prior to every flight. 

Far Part 91.9 (b) 2 prescribes that - 

 (b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter unless there is available in the aircraft a current, approved Airplane or 

Rotorcraft Flight Manual or the manual provided for in § 121.141(b); and 

(2) (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.

Relief is requested to comply by keeping all relevant company operating procedures, limitations, 

logbooks, and checklists in a location accessible to the PIC. 

Far Part 91.119 prescribes in part that - 

 Except when necessary for takeoff or landing, no person may operate an aircraft 

 below the following altitudes:

 (c) Over other than congested areas. An altitude of 500 feet above the surface, 

 except over open water or sparsely populated areas. In those cases, the aircraft 

 may not be operated closer than 500 feet to any person, vessel, vehicle, or 

 structure. 

 

Relief is sought for FAR 91.119 (c) because that UAV aircraft will be operated below 400 feet 

AGL and would not be able to comply with this subparagraph. Petitioner would operate in 

accordance with the limitations described in this petition or by any other limitations the FAA 

deems necessary. 

Far Part 91.121 prescribes in part that - 

 

 (a) Each person operating an aircraft shall maintain the cruising altitude or flight 

 level of that aircraft, as the case may be, by reference to an altimeter that is set, 

 when operating— 

 (1) Below 18,000 feet MSL, to—

10 
 (i) The current reported altimeter setting of a station along the route and within 

 100 nautical miles of the aircraft; 

 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

 section, the current reported altimeter setting of an appropriate available station; 

 or

 (iii) In the case of an aircraft not equipped with a radio, the elevation of the 

 departure airport or an appropriate altimeter setting available before departure; 

 or 

 (2) At or above 18,000 feet MSL, to 29.92′′ Hg.

Relief is sought because the UAV aircraft does not have a typical barometric altimeter on board, 

and all reported altitudes will be reported in feet AGL. 

Far Part 91.151(a) prescribes that - 

 

 (a) No person may begin 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. 

 (b) No person may begin a flight in a rotorcraft 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, to fly 

 after that for at least 20 minutes.

Relief is sought to operate at less than the prescribed minimums because UAV will never be 

flown more than 1/2 mile from the point of intended landing, and that safety will be maintained 

by monitoring the elapsed time in flight, real time battery voltage condition, and the 2 level low 

battery warnings detailed above in the UAV description. The PIC will never begin a flight unless 

there is enough power to fly to the intended point of landing at normal cruising speed and still 

land with 20% battery power remaining. 

Far Part 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) prescribe that - 

 91.405 (a)

 Each owner or operator of an aircraft—

11 
 (a) 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;

 91.407 (a) 1 

 (a) No person may operate any aircraft that has undergone maintenance, 

 preventive maintenance, rebuilding, or alteration unless— 

 (1) It has been approved for return to service by a person authorized under §43.7 

 of this chapter; and

 91.409 (a) 1 and 2 

 (a) Except as provided in paragraph (c) of this section, no person may operate an 

 aircraft unless, within the preceding 12 calendar months, it has had—

 (1) An annual inspection in accordance with part 43 of this chapter and has been 

 approved for return to service by a person authorized by §43.7 of this chapter; or 

 (2) An inspection for the issuance of an airworthiness certificate in accordance 

 with part 21 of this chapter.

 91.417 (a) and (b) 

 (a) Except for work performed in accordance with §§91.411 and 91.413, each 

 registered owner or operator shall keep the following records for the periods 

 specified in paragraph (b) of this section: 

 (1) Records of the maintenance, preventive maintenance, and alteration and 

 records of the 100-hour, annual, progressive, and other required or approved 

 inspections, as appropriate, for each aircraft (including the airframe) and each 

 engine, propeller, rotor, and appliance of an aircraft. The records must include— 

 (i) A description (or reference to data acceptable to the Administrator) of the 

 work performed; and 

 (ii) The date of completion of the work performed; and 

 (iii) The signature, and certificate number of the person approving the aircraft for 

 return to service. 

 (2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each propeller, and each 

 rotor. 

 (ii) The current status of life-limited parts of each airframe, engine, propeller, 

 rotor, and appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which are 

 required to be overhauled on a specified time basis. 

 (iv) The current inspection status of the aircraft, including the time since the last 

 inspection required by the inspection program under which the aircraft and its 

 appliances are maintained. 

 (v) The current status of applicable airworthiness directives (AD) and safety 

 directives including, for each, the method of compliance, the AD or safety 

12 
 directive number and revision date. If the AD or safety directive involves 

 recurring action, the time and date when the next action is required. 

 (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major 

 alteration to the airframe and currently installed engines, rotors, propellers, and 

 appliances. 

 (b) The owner or operator shall retain the following records for the periods 

 prescribed: 

 (1) The records specified in paragraph (a)(1) of this section shall be retained until 

 the work is repeated or superseded by other work or for 1 year after the work is 

 performed. 

 (2) The records specified in paragraph (a)(2) of this section shall be retained and 

 transferred with the aircraft at the time the aircraft is sold. 

 (3) A list of defects furnished to a registered owner or operator under §43.11 of 

 this chapter shall be retained until the defects are repaired and the aircraft is 

 approved for return to service.

Relief from these sections is sought because it is our intention to perform any maintenance and 

inspections as described above and that this will ensure a high level of safety. As provided in the 

Preflight Safety Checklist (see Addendum) the PIC will be responsible for ensuring that the 

aircraft is in airworthy condition prior to every flight. The PIC will document any work 

performed as detailed above in the aircraft logbook as well as cumulative flight time.

 

THE REASONS WHY GRANTING THE REQUEST WOULD 

 BE IN THE PUBLIC INTEREST 

Granting the present Petition would benefit the public interest by allowing Elevated Cinematics 

LLC to safely, efficiently, and economically provide commercial aerial photo and video services 

for a variety of clients. These services will allow our clients and end users to experience these 

photo and video assets thus enhancing their own businesses and creating economic opportunities 

for everyone involved.

13 
In addition, it is our desire to play a role of constructive public education on the benefits and uses 

of civil UAV systems by being an example of what is possible when this new technology is used 

in a safe and useful manner. 

The public would benefit as well from the decrease in the air pollution, noise, and potential 

danger of using large manned aircraft with flammable fuel on board and an internal combustion 

engine to accomplish what our UAV aircraft can do using small, quiet electric motors and a small 

battery pack. 

THE REASONS WHY GRANTING THE REQUEST WOULD NOT 

ADVERSELY AFFECT SAFETY 

Because of the speed, weight, size, and limited operating area associated with the proposed UAV 

aircraft operations, the Petitioner submits that our proposed flights would not create a hazard to 

other users of the NAS or to the public, or otherwise pose a threat to the national security. We 

also submit that Elevated Cinematics LLC can safely operate in the NAS pursuant to FMRA 

Section 333 because: 

1. We have detailed the operating characteristics of the UAV system. 

2. The PIC is qualified and has an abundance of operational experience. 

3. We will operate pursuant to a detailed set of operating limitations and procedures as set forth 

in this Petition to ensure the highest level of safety to ourselves, our clients, and the public. 

SUMMARY SUITABLE FOR THE PUBLIC REGISTER 

Elevated Cinematics LLC seeks exemption from the requirements of 14 CFR Parts 91.7 (a), 91.9 

(b) 2, 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and 

(b). This exemption will permit Elevated Cinematics LLC to commercially operate a UAV 

aircraft for the purpose of collecting aerial photo and video assets for a variety a clients. 

14 
ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS 

AVAILABLE TO SUPPORT ELEVATED CINEMATICS LLC’S REQUEST 

This Petition is made pursuant to the FAA Moderization and Reform Act of 2012 Section 333. 

As stated above, Elevated Cinematics LLC will operate safely in the NAS without creating an 

undue hazard to other users of the NAS, the general public, or by posing a threat to national 

security. Elevated Cinematics LLC operation will also provide a benefit to the public interest as 

detailed in this petition. 

 

15 
ADDENDUM 

Included in this Addendum are the following documents in this order: 

1. Preflight Safety Checklist 

2. DJI Phantom 2 User Manual 

3. Tarot 680 UAV photo 

4. Tarot 680 GCS photo 

5. FCC License 

6. AMA Safety Code 

 16 
ELEVATED CINEMATICS LLC

PREFLIGHT SAFETY CHECKLIST

PREFLIGHT

- ALL FIRMWARE UPDATES........................................................COMPLETE

- UAV/GSC BATTERIES......................................................FULLY CHARGED

- ALL FASTENERS / WIRING / CONNECTORS....................................SECURE

- PROPELLERS.......................................BALANCED, SECURE, NO DAMAGE

- FLIGHT BRIEFING...................................................................COMPLETE

BEFORE TAKEOFF

- GSC POWER........................................................................................ON

- UAV POWER.........................................................................................ON

- CAMERA..............................................................................................ON

- LED STATUS LIGHTS....................................CHECK FOR CORRECT STATUS

- COMPASS CALIBRATION.........................................PERFORM IF REQUIRED

- FINAL VISUAL CHECK OF AOA.....................................................PERFORM

AFTER LANDING

- UAV POWER..........................................................................................OFF

- GSC POWER.........................................................................................OFF

- CAMERA POWER...................................................................................OFF

- BATTERY AND MOTOR TEMPERATURE..................................CHECK NORMAL

 
 

©2013-2015 DJI. All Rights Reserved.1 | 

PHANTOM 2 User Manual V1.4 

For PHANTOM 2 Flight Controller Firmware version V3.10

& PHANTOM 2 Assistant version V3.8

& PHANTOM RC Assistant version V1.1

2015.01

Congratulations on purchasing your new DJI product. Please thoroughly read the entire contents of this manual to 

fully use and understand the product.

It is advised that you regularly check the PHANTOM 2’s product page at www.dji.com which is updated on a 

regular basis. This will provide services such as product information, technical updates and manual corrections. Due 

to any unforeseen changes or product upgrades, the information contained within this manual is subject to change 

without notice.

DJI and PHANTOM 2 are registered trademarks of DJI. Names of product, brand, etc., appearing in this manual are 

trademarks or registered trademarks of their respective owner companies. This product and manual are copy 

righted by DJI with all rights reserved.

If you have any questions or concerns regarding your product, please contact your dealer or DJI Customer Service.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TAROT 680 UAV WITH DJI NAZA FLIGHT CONTROLLER 

 
TAROT 680 GROUND CONTROL SYSTEM

 
 
 

Academy of Model Aeronautics National Model Aircraft Safety Code

Effective January 1, 2014 

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is 

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any 

additional rules specific to the flying site. 

1. Model aircraft will not be flown: 

(a) In a careless or reckless manner. 

(b) At a location where model aircraft activities are prohibited. 

2. Model aircraft pilots will: 

(a) Yield the right of way to all human-carrying aircraft. 

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) 

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator. 

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. 

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document 520-A.) 

(f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This 

does not apply to model aircraft flown indoors.) 

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555. 

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot’s ability to safely control the 

model. 

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

Exceptions: 

x Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight. 

x Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flight. Model rockets may 

be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft. 

x Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Program Document. 

(AMA Document #718.) 

(j) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510-A.) 

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: 

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. 

(b) An inexperienced pilot is assisted by an experienced pilot. 

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply 

with comparable standards. 

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 

2. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or 

repaired model aircraft. 

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) 

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. 

(b) At air shows or demonstrations, a straight safety line must be established. 

(c) An area away from the safety line must be maintained for spectators. 

(d) Intentional flying behind the safety line is prohibited. 

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly 

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA 

Documents #922 and #923.) 

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors 

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline. 

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an 

individual. 

8. RC night flying requires a lighting system providing the pilot with a clear view of the model’s attitude and orientation at all times. Hand-held illumination 

systems are inadequate for night flying operations. 

9. The pilot of an RC model aircraft shall: 

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. 

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550. 

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560. 

C. FREE FLIGHT 

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function. 

D. CONTROL LINE 

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 

2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above-ground electric utility lines. 

5. The flying area must be clear of all nonessential participants and spectators before the engine is started.