February 10, 2016

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE.,

Room W12-140, West Building Ground Floor

Washington, DC 20590-001

RE: Section 333 exemption

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R., 

Part 11, ZUFFA, LLC, (“ZUFFA”), operator of Small Unmanned Aircraft Systems (“sUAS”) 

equipped to conduct aerial videography of professional football game and training facilities, 

requests a limited exemption from the below-listed regulations to allow commercial operation of 

its sUASs, provided that the proposed sUAS operations comply with the conditions outlined 

below or as established by the Federal Aviation Administration (“FAA”) under Section 333. The 

name and address of the applicant is: ZUFFA, LLC, 2960 W. Sahara, Las Vegas, NV 89102, c/o 

Tim Bellamy, Senior Vice President & Associate General Counsel, (702) 851-2478, 

tbellamy@ufc.com.

ZUFFA makes this request under the “summary grant” process that the FAA announced in 

April 2015.1 This request is similar in all material respects to a number of recent grants of 

exemption, including Grant of Exemption No. 11488 to Advanced Aerial Cinematography, LLC 

(FAA Docket No. 2014-0090).

Regulations from which the exemption is requested:

14 C.F.R. part 21 

14 C.F.R. § 45.23 (b) 

14 C.F.R. §§ 61.113 (a) & (b)

14 C.F.R. § 91.7 (a) 

14 C.F.R. § 91.9 (b) (2) & (c)

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F.R. § 91.119 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151 (a) 

14 C.F.R. §§ 91.203 (a) & (b) 

14 C.F.R. § 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. § 409 (a) (2) 

14 C.F.R. §§ 417 (a) & (b)
 

ZUFFA proposes that it receive an exemption to use sUAS to gather footage from UFC 

Events held throughout the nation. ZUFFA would use the footage in its sports and entertainment 

programming. 

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system (“NAS”) or to persons and property on the ground. ZUFFA proposes that the 

exemption apply to civil aircraft that operate within the limitations listed below. These limitations 

were established in the FAA’s grant of Advanced Aerial Cinematography’s request for an 

exemption:

1. The sUAS will weigh 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 picture and television filming are permitted.

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

hour). ZUFFA 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 will be operated at an altitude of no more than 400 feet above ground level 

(AGL) Altitude will be reported in feet AGL

5. The UA will be operated within visual line of sight (VLOS) of the Pilot in Charge 

(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 will utilize a visual observer (VO). The UA will be operated within the 

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 the VLOS capability. The VO 

and PIC will be able to communicate verbally at all times; electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC will ensure that VO can perform the duties required of the VO.

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

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

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

documents will be accessible during sUAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and will be 

followed. Otherwise, ZUFFA will follow the procedures as outlined in its operating 

documents. ZUFFA may update or revise its operating documents. It is ZUFFA’s 

responsibility to track such revisions and present updated and revised documents 

to the Administrator or any law enforcement official upon request. ZUFFA will also 

present updated and revised documents if it petitions for extension or amendment 
 

to this grant of exemption. If ZUFFA determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then ZUFFA 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. ZUFFA 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 will conduct a pre-flight inspection and determine the 

sUAS is in a condition for safe flight. The pre-flight inspection will 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 sUAS, the 

aircraft will be prohibited form operating until the necessary maintenance has 

been performed and the sUAS is found to be in a condition for safe flight.

11. ZUFFA will follow the sUAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each sUAS operated under this exemption will comply with all manufacturer 

safety bulletins.

13. ZUFFA will not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the sUAS in a manner consistent with how the sUAS will be 

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 will 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 sUAS in a manner consistent 

with how the sUAS 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 experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

ZUFFA will not operate flights under special visual flight rules (SVFR).
 

15. The UA will not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Director (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 will be 

made available to the Administrator or any law enforcement official upon request.

16. The UA will 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.

17. If the sUAS loses communications or loses its GPS signal, the UA will return to a 

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

18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC will be 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.

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations will 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.

21. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will 

be as large as practicable.

22. Documents used by ZUFFA to ensure the safe operation and flight of the sUAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available 

to the PIC at the Ground Control Station of the sUAS any time the aircraft is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

23. The UA will remain clear and give way to all manned aviation operations and 

activities at all times.

24. The sUAS will not be operated by the PIC from any moving device or vehicle.

25. All Flight operations will 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. ZUFFA 

will 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 will 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, essential persons, or individuals who have signed consent 

forms are not considered nonparticipating persons under this exemption.

26. All operations will 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.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents 

will 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:

28. At least 3 days before aerial filming, ZUFFA will 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 sUAS aerial filming 

conducted under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the sUAS;

d. Make, model, and serial or N-Number of the sUAS to be used;

e. Name and certificate number of the sUAS 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 will be made available to the inspector 

upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and 

the altitudes essential to accomplish the operation.

29. Flight operations may be conducted closer than 500 feet from participating 

persons consenting to be involved and necessary for the filming production.

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 

CFR including, but not limited to, parts 45, 47, 61, and 91. ZUFFA incorporates all arguments in 
 

support of the petition made in Advanced Aerial Cinematography’s November 24, 2014 

application for exemption.

Federal Register Notice

As stated above, publication in the Federal Register is unnecessary because this application 

meets the FAA’s criteria for summary approval. To the extent that the FAA determines that 

publication is necessary, the following summary is provided:

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 

14 C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 

91.119; 91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.409 

(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs or less) in 

videography operations.

The Exemption is in the Public Interest

As demonstrated above, the proposed sUAS operations would minimize the risk of harm to 

individual safety or damage to the NAS and property. The operations proposed by ZUFFA 

would provide tremendous public benefits by enabling millions of UFC fans to view footage that 

could not be captured via any other technology. The sUAS operations as described in this 

application will be far safer and more efficient than use of helicopters or other aircraft to capture 

the required footage.

The conditions outlined in this petition clearly satisfy Section 333’s exemption criteria 

regarding “size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight,” and therefore the proposed operations would not 

“create a hazard to users of the national airspace system or the public or pose a threat to 

national security.” As discussed above, ZUFFA agrees to use limitations that are substantially 

identical to those contained in the FAA’s recent grant of exemption for Advanced Aerial 

Cinematography. Accordingly, the proposed UAS operations of ZUFFA should not raise safety 

or national security concerns, and should receive summary approval.

Should you have any questions or concerns, please do not hesitate to contact me

Best regards,

Timothy Bellamy

Zuffa LLC d/b/a Ultimate Fighting Championship®

Senior Vice President and Associate General Counsel