NFL Films FAA Exemption

From:
To:
Subject:
Date:
aaron.gordon@vice.com
7-AWA-ARC-FOIA (FAA)
Request under the Freedom of Information Act, 5 U.S.C. 552
Thursday, September 24, 2015 3:27:12 PM
Aaron Gordon
VICE Media
99 N 10th St
Brooklyn, NY 11249
September 24, 2015
FOIA REQUEST
ARM
2016-000323
TO: _____________
CONTROL NO. _____________________
11/6/2015 FEE CATEGORY: _______________________
Media
DUE: _____________
460077
WEB ID: ___________________
Federal Aviation Administration

National Freedom of Information Act Staff, ARC-40
800 Independence Avenue, SW
Washington, DC 20591
FOIA Coordinator:
This is a request under the Freedom of Information Act. I request that a copy of the
following documents (or documents containing the following information) be
provided to me:
I request any and all records regarding exemption number 12911, including letters
received from Kurt Wimmer on May 20, 2015 and August 11, 2015, and any and all
internal communications regarding this exemption. INSTRUCTIONS REGARDING
SEARCH 1. Instructions Regarding Leads: As required by the relevant case law, the
FAA should follow any leads it discovers during the conduct of its searches and
perform additional searches when said leads indicate that records may be located in
another system. Failure to follow clear leads is a violation of FOIA. 2. Request for
Public Records: Please search for any records even if they are already publicly
available. 3. Request for Electronic and Paper/Manual Searches: I request that
searches of all electronic and paper/manual indices, filing systems, and locations for
any and all records relating or referring to the subject of my request be conducted.
4. Request for Search of Filing Systems, Indices, and Locations: I request that the
FAA search all of its offices and components, which are likely to contain responsive
records. 5. Request regarding Photographs and other Visual Materials: I request that
any photographs or other visual materials responsive to my request be released to
me in their original or comparable forms, quality, and resolution. For example, if a
photograph was taken digitally, or if the FAA maintains a photograph digitally, I
request disclosure of the original digital image file, not a reduced resolution version
of that image file nor a printout and scan of that image file. Likewise, if a
photograph was originally taken as a color photograph, I request disclosure of that
photograph as a color image, not a black and white image. Please contact me for
any clarification on this point. 6. Request for Duplicate Pages: I request disclosure of
any and all supposedly duplicate pages. Scholars analyze records not only for the
information available on any given page, but also for the relationships between that
information and information on pages surrounding it. As such, though certain pages
may have been previously released to me, the existence of those pages within new
context renders them functionally new pages. As such, the only way to properly
analyze released information is to analyze that information within its proper context.
Therefore, I request disclosure of all duplicate pages. 7. Request to Search Emails:
Please search for emails relating to the subject matter of my request. 8. Request for
Search of Records Transferred to Other Agencies: I request that in conducting its
search, the FAA disclose releasable records even if they are available publicly
through other sources outside the FAA, such as NARA. 9. Regarding Destroyed
Records If any records responsive or potentially responsive to my request have been
destroyed, my request includes, but is not limited to, any and all records relating or
referring to the destruction of those records. This includes, but is not limited to, any
and all records relating or referring to the events leading to the destruction of those
records. INSTRUCTIONS REGARDING SCOPE AND BREADTH OF REQUESTS Please
interpret the scope of this request broadly. The FAA is instructed to interpret the
scope of this request in the most liberal manner possible short of an interpretation
that would lead to a conclusion that the request does not reasonably describe the
records sought. EXEMPTIONS AND SEGREGABILITY I call your attention to President
Obama's 21 January 2009 Memorandum concerning the Freedom of Information Act,
in which he states: All agencies should adopt a presumption in favor of disclosure, in
order to renew their commitment to the principles embodied in FOIA [....] The
presumption of disclosure should be applied to all decisions involving FOIA. In the
same Memorandum, President Obama added that government information should
not be kept confidential merely because public officials might be embarrassed by
disclosure, because errors and failures might be revealed, or because of speculative
or abstract fears. Finally, President Obama ordered that "The Freedom of
Information Act should be administered with a clear presumption: In the case of
doubt, openness prevails." Nonetheless, if any responsive record or portion thereof is
claimed to be exempt from production, FOIA/PA statutes provide that even if some
of the requested material is properly exempt from mandatory disclosure, all
segregable portions must be released. If documents are denied in part or in whole,
please specify which exemption(s) is (are) claimed for each passage or whole
document denied. Please provide a complete itemized inventory and a detailed
factual justification of total or partial denial of documents. Specify the number of
pages in each document and the total number of pages pertaining to this request.
For classified material denied, please include the following information: the
classification (confidential, secret or top secret); identity of the classifier; date or
event for automatic declassification or classification review or downgrading; if
applicable, identity of official authorizing extension of automatic declassification or
review past six years; and, if applicable, the reason for extended classification
beyond six years. In excising material, please black out the material rather than
white out or cut out. I expect, as provided by FOIA, that the remaining nonexempt portions of documents will be released. Please release all pages regardless
of the extent of excising, even if all that remains are the stationery headings or
administrative markings. In addition, I ask that your agency exercise its discretion to
release records which may be technically exempt, but where withholding serves no
important public interest. ADDITIONAL INSTRUCTIONS REGARDING REQUEST
Please produce all records with administrative markings and pagination included.
Please send a memo (copy to me) to the appropriate units in your office to assure
that no records related to this request are destroyed. Please advise of any
destruction of records and include the date of and authority for such destruction.
FORMAT I request that any releases stemming from this request be provided to me
in digital format (soft-copy) on a compact disk or other like media. FEE CATEGORY
AND REQUEST FOR A FEE WAIVER I am a reporter with VICE Media. I am willing to
pay any reasonable expenses associated with this request, however, as the purpose
of the requested disclosure is in full conformity with the statutory requirements for a
waiver of fees, I formally request such a waiver. I request a waiver of all costs
pursuant to 5 U.S.C. 552(a)(4)(A)(iii) (Documents shall be furnished without any
charge ... if disclosure of the information is in the public interest because it is likely
to contribute significantly to public understanding of the operations or activities of
the government and is not primarily in the commercial interest of the requester.).
Disclosure in this case meets the statutory criteria, and a fee waiver would fulfill
Congresss legislative intent in amending FOIA. See Judicial Watch, Inc. v. Rossotti,
326 F.3d 1309, 1312 (D.C. Cir. 2003) (Congress amended FOIA to ensure that it be
liberally construed in favor of waivers for noncommercial requesters.). I incorporate
by reference the explanation and attached materials in the above sections which
demonstrates why the requested information is in the public interest. DoD 5400.7-R
C6.1.4.1 provides that documents shall be furnished without charge, or at a charge
reduced below fees assessed to the categories of requesters in subsection C6.1.5.,
below, when the Component determines that waiver or reduction of the fees is in
the public interest because furnishing the information is likely to contribute
significantly to public understanding of the operations or activities of the Department
of Defense and is not primarily in the commercial interest of the requester. Should
my request for a fee waiver be denied, I request that I be categorized as a member
of the news media for fee purposes pursuant to DoD 5400.7-R C6.1.5.7. According
to 5 U.S.C. 552(a)(4)(A)(ii), which codified the ruling of Natl Security Archive v.
Dept of Defense, 880 F.2d 1381 (D.C. Cir. 1989), the term a representative of the
news media means any person or entity that gathers information of potential
interest to a segment of the public, uses its editorial skills to turn the raw materials
into a distinct work, and distributes that work to an audience. This is consistent with
the definition provided in DoD 5400.7-R C6.1.5.7.1. As the legislative history of FOIA
reveals, It is critical that the phrase representative of the news media be broadly
interpreted if the act is to work as expected. . . . In fact, any person or organization
which regularly publishes or disseminates information to the public . . . should
qualify for waivers as a representative of the news media. 132 Cong. Rec. S14298
(daily ed. Sept. 30, 1986) (emphasis in original quotation); and 2) A request by a
reporter or other person affiliated with a newspaper, magazine, television or radio
station, or other entity that is in the business of publishing or otherwise
disseminating information to the public qualifies under this provision. 132 Cong.
Rec. H9463 (Oct. 8, 1986) (emphasis in original quotation)). Therefore, in
accordance with the Freedom of Information Act and relevant case law, I, Aaron
Gordon, should be considered a representative of the news media. I have the intent
and ability to disseminate this significant expansion of public understanding of
government operations. The public interest in this significant expansion of public
understanding of government operations far outweighs any commercial interest of
my own in the requested release. Accordingly, my fee waiver request amply satisfies
the rules of DoD 5400.7-R C6.1.4.1. Legislative history and judicial authority
emphatically support this determination. For these reasons, and based upon their
extensive elaboration above, I request a full waiver of fees be granted. I will appeal
any denial of my request for a waiver administratively and to the courts if necessary.
In order to determine my status to assess fees, you should know that my fee
category is:
a representative of the news media.
The maximum dollar amount I am willing to pay for this request is $0. Please notify
me if the fees will exceed $25.00 or the maximum dollar amount I entered.
Thank you for your consideration of this request.
Sincerely,
Aaron Gordon
Staff Writer
Phone: 2036102162
aaron.gordon@vice.com
Form URL: http://www.faa.gov/foia/email_foia/review/
Remote host: 155.178.201.21
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FOIA Program Management Branch

800 Independence Avenue SW
October 08, 2015

Mr. Aaron Gordon
Staff Writer
VICE Media
99 N 10th Street
Brooklyn, NY 11249
Re: Freedom of Information Act (FOIA) Request 2016-000323
Dear Mr. Gordon:
This letter acknowledges receipt of your FOIA request dated September 24, 2015, concerning any and all
records regarding exemption number 12911, including letters received from Kurt Wimmer on May 20, 2015
and August 11, 2015, and any and all internal communications regarding this exemption.
Your request has been assigned for action to the office(s) listed below:
Office of the Chief Counsel, AGC-200
Contact: Ebony Powell

FOIA CoordinatorRegulations
(202) 267-3824

Office of Rulemaking, ARM-1
Contact: Judine Slaughter

FOIA Coordinator
(202) 267-3793

FOIA Program Management Branch (AFS-1)
800 Independence Avenue SW
Contact: Derek Honda

FOIA Coordinator
(202) 267-4190
Should you wish to inquire as to the status of your request, please contact the assigned FOIA coordinator(s).
Please refer to the above referenced number on all future correspondence regarding this request.
Upon review of your request for fee waiver, we have made a determination to grant you a fee waiver.
Sincerely,
Elena Richardson
FOIA Management Specialist
The table below is a list of the records regarding exemption number 12911.
Attachment A
Attachment B
Attachment C
Attachment D
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
Attachment K
Attachment L
Letter dated May 20, 2015 from Kurt Wimmer

Internal FAA Section 333 Review
Draft Text for Request for Information (RFI)
RFI email to Barry Wolper
Regulations.gov receipt for RFI
Letter dated August 11, 2015 from Stephen Kiehl
FAA draft response
FAA draft response with edits
FAA draft response with concurrences
Email confirming verbal permission to move
forward with petition in place of signature on S-1
Determination Memo
Email from Contractor with Certificate of Waiver
(COA) and FAA response with signature block
Regulations.gov receipt for response letter
Attachment A
May 20, 2015

U.S. Department of Transportation
Document Management System
1200 New Jersey Ave., SE
To Whom It May Concern:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14
C.F.R., Part 11, NFL Productions LLC d/b/a NFL Films (NFL Films), 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: NFL Productions LLC, One Sabol Way, Mt.
Laurel, N.J. 08054, c/o Barry M. Wolper, Chief Financial Officer, (856) 222-3545,
barry.wolper@nfl.com.
NFL Films 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). 2
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)
See FAA Summary Grants Speed UAS Exemptions, available at
https://www.faa.gov/news/updates/?newsId=82485.
1
The use limitations and arguments in this application are nearly identical to those contained in
Advanced Aerial Cinematographys November 24, 2014 application and the FAAs May 5, 2015
approval of that application.
2

May 20, 2015
Page 2
14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 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)
NFL Films proposes that it receive an exemption to use sUAS to gather footage from
closed-set locations in and around NFL stadiums (on non-game days) and NFL practice
facilities. NFL Films would use the footage for the production of television programs. NFL
Films would obtain the consent of all personnel in the stadiums and practice facilities in the
vicinity in which the sUAS may operate.
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. NFL Films proposes that
the exemption apply to civil aircraft that operate within the limitations listed below. These
limitations were established in the FAAs grant of Advanced Aerial Cinematographys 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 closed-set motion picture and television filming are
permitted.
3. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per
hour). NFL Films may use either groundspeed or calibrated airspeed to
determine compliance with the 87 knot speed restriction. In no case will the UA

May 20, 2015
Page 3
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 PICs FAA-issued
airman medical certificate or U.S. drivers 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 the 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, NFL Films will follow the procedures as outlined in
its operating documents. NFL Films may update or revise its operating
documents. It is NFL Films responsibility to track such revisions and present
updated and revised documents to the Administrator or any law enforcement
official upon request. NFL Films will also present updated and revised
documents if it petitions for extension or amendment to this grant of exemption.
If NFL Films determines that any update or revision would affect the basis upon
which the FAA granted this exemption, then NFL Films must petition for an
amendment to its grant of exemption. The FAAs UAS Integration Office (AFS80) 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.

May 20, 2015
Page 4
9. NFL Films 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. NFL Films will follow the sUAS manufacturers 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. Under this grant of exemption, a PIC will hold either an airline transport,
commercial, private, recreational, or sport pilot certificate. The PIC will also hold
a current FAA airman medical certificate or a valid U.S. drivers license issued by
a state, the District of Columbia, Puerto Rico, a territory, a possession, or the
Federal Government. The PIC also will 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. NFL Films 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
operators PICs and VOs (training, proficiency, and experience-building) and
determining the PICs 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
experience-building 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.
15. 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).
NFL Films will not operate flights under special visual flight rules (SVFR).
16. 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

May 20, 2015
Page 5
the current FAA-published aeronautical chart, unless a letter of agreement with

that airports 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.
17. 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.
18. 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.
19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.
20. 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.
21. 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.
22. 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
(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings
will be as large as practicable.
23. Documents used by NFL Films 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.
24. The UA will remain clear and give way to all manned aviation operations and
activities at all times.
25. The sUAS will not be operated by the PIC from any moving device or vehicle.
26. 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. NFL Films will ensure that nonparticipating persons remain

May 20, 2015
Page 6
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.
27. 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.
28. 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 FAAs 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:
29. NFL Films will have a motion picture and television operations manual
(MPTOM) as documented in this grant of exemption.
30. At least 3 days before aerial filming, NFL Films 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;

May 20, 2015
Page 7
e. Name and certificate number of 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.
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 holders MPTOM.
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. NFL Films incorporates all
arguments in support of the petition made in Advanced Aerial Cinematographys November 24,
2014 application for exemption.
Federal Register Notice
As stated above, publication in the Federal Register is unnecessary because this
application meets the FAAs 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 NFL Films
would provide tremendous public benefits by enabling millions of NFL 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 333s 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

May 20, 2015
Page 8
create a hazard to users of the national airspace system or the public or pose a threat to
national security. As discussed above, NFL Films agrees to use limitations that are substantially
identical to those contained in the FAAs recent grant of exemption for Advanced Aerial
Cinematography. Accordingly, the proposed UAS operations of NFL Films should not raise
safety or national security concerns, and should receive summary approval.
Please do not hesitate to contact the undersigned if you need additional information.
Respectfully submitted,
Kurt Wimmer
Jeff Kosseff
Attachment B
Part 11/Section 333 Review

Petitioner: NFL Productions LLC dba NFL Films
Docket No: FAA-2015-2139
Petitioner Contact Info: Barry M. Wolper, barry.wolper@nfl.com
Signatory - Kurt Wimmer

Point of Contact - Barry M. Wolper, Kurt Wimmer, Jeff Kosseff
Counsel - Kurt Wimmer, Jeff Kosseff
Operation Type: Aerial videography and closed-set motion picture and television filming
Part 11 Checklist (If any of this info is missing a rejection letter is issued)
Check (if in petition or original
Criteria
submission materials)
Specific section(s) of 14 CFR from which the petitioner seeks an
Y, pp. 12
exemption
Reason relief sought by petitioner
Y, p. 1
Why granting the request would be in the public interest; that is,
how it would benefit the public as a whole (note: cannot use
Y, p. 7
economic benefit)
Why granting the exemption would not adversely affect safety,
or how the exemption would provide a level of safety at least
Y, pp. 27
equal to that provided by the rule from which the petitioner seeks
the exemption
Request for Information (RFI) Triggers
Criteria
Description
Aircraft Make/Model/Type
Need aircraft, see RFI
Aircraft maximum weight (including
payload) less than 55lbs (Y/N) (If no, add Y, p. 2
weight)
Closed-Set Filming (Y/N) (if yes,
Y, need MPTOM, see RFI
MPTOM is required)
Further analysis needed (Ex. new aircraft,
gas-powered, operations outside of aerial
Y, need aircraft and MPTOM, see RFI
data collection and closed-set filming,
etc.)
If a petition meets part 11 and section 333, please move forward and draft the decision document. For
those petitions that do not meet part 11, please draft the rejection letter. For petitions that appear to not
meet section 333 (i.e. missing aircraft, MPTOM needed), please draft an RFI and decision document.
Attachment C
TEXT FOR RFI E-MAIL
Dear Mr. Wimmer:

This letter is to inform you that the following information is missing from your petition
(Docket No. FAA-2015-2139). This information is necessary for the Federal Aviation
Administration (FAA) to process your petition.
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).
Your petition references the material listed below, however the material was not
submitted for the record. Please provide a copy of the following referenced materials:
o Motion Picture and Television Operations Manual (MPTOM)
Please submit the additional information (non-proprietary) to your docket at

www.regulations.gov and submit any proprietary information to the FAA Headquarters or
electronically via email to 333exemptions@faa.gov. If you want us to process your request any
further, we must receive the information described above by MM/DD/YY. If we do not receive
the information, we will close the docket without notifying you further.
If you have any questions, please feel free to contact me at (202) 267-XXXX.
Sincerely,
Attachment D
7/28/2015
RequestforInformationFAA20152139
RequestforInformationFAA20152139
9AWAAVS333Exemptions(FAA)
Sent:Tuesday,July28,20158:33AM
To: barry.wolper@nfl.com
DearMr.Wolper:
Thisletteristoinformyouthatthefollowinginformationismissingfromyourpetition(DocketNo.FAA20152139).
ThisinformationisnecessaryfortheFederalAviationAdministration(FAA)toprocessyourpetition.
Describetheaircraftmake(s),model(s),andtype(s)(i.e.,fixedwing,rotorcraft,lighterthanair)forthe
proposedUASoperation.Thedescription(s)shouldincludethemaximumweight(includingpayload).This
informationcanbelocatedintheaircraftmanual(s).
ProvideacopyoftheMotionPictureandTelevisionOperationsManual(MPTOM)whichisrequiredbyOrder
8900.1,Volume3,Chapter8,Section1.Ifyouwishforustoproceedwithoutthismanualandremove
closedsetfilmingfromyourproposedoperationpleaseinformofusofyourintentionbytherequested
responsedatelistedbelow.
Pleasesubmittheadditionalinformation(nonproprietary)toyourdocketatwww.regulations.govandsubmitany
proprietaryinformationtotheFAAHeadquartersorelectronicallyviaemailto333exemptions@faa.gov.Ifyouwant
ustoprocessyourrequestanyfurther,wemustreceivetheinformationdescribedaboveby8/11/15.Ifwedonot
receivetheinformation,wewillclosethedocketwithoutnotifyingyoufurther.
Ifyouhaveanyquestions,pleasefeelfreetocontactmeat(202)2674264.
Sincerely,
DanNgo
FAAOfficeofRulemaking
https://email.dot.gov/owa/9AWAAVS333Exemptions@faa.gov/?ae=Item&t=IPM.Note&id=RgAAAABFvqQJAFf5SI8crGhIsEIyBwD3qfMUO7BCQ74YBi9P12
1/1
Attachment E
7/28/2015
Regulations.govYourReceipt
Your comment was submitted successfully!

TheFederalAviationAdministration(FAA)Other:NFLProductionsLLCd/b/aNFLFilms
Exemption/Rulemaking
Forrelatedinformation,OpenDocketFolder
Your Receipt
Your Comment Tracking Number:

1jz8k8c50lu
Yourcommentmaybeviewableon
Regulations.govoncetheagencyhas
reviewedit.Thisprocessisdependent
onagencypublicsubmission
policies/proceduresandprocessing
times.Useyourtrackingnumberto
findoutthestatusofyourcomment.
Email Receipt
EmailAddress
Yourcomment:
Comment:
PleaseattachtherequesttoNFLProductions(FAA20152139)
UploadedFile(s)
(Optional)
RequestforInformationFAA20152139.pdf:success
Thisinformationwillappearon
Regulations.gov:
Thisinformationwillnotappearon
Regulations.gov:
FirstName:
Anonymous
Country:
UnitedStates
LastName:
Anonymous
Stateor
Province:
DC
Phone
Number:
2022679677
Mailing
http://www.regulations.gov/#!submitCommentD=FAA201521390001p=1
1/2
7/28/2015
Regulations.govYourReceipt
Address:
800
Independence
AveSW
City:
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ZIP/Postal
Code:
20591
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Attachment F
Filed Electronically Via Regulations.gov
August 11, 2015
Dan Ngo
FAA Office of Rulemaking
800 Independence Ave. SW
Re: FAA-2015-2139
Dear Mr. Ngo:
Attached please find a Motion Picture and Television Operations Manual (MPTOM)
prepared by NFL Films for the above-referenced docket. The MPTOM includes, at Appendix B,
a description of the aircraft makes, models, and types, as requested, for the proposed UAS
operation.
This letter and the attachment were filed online at regulations.gov in Docket No. FAA2015-2139.
Please contact me if you have any questions.
Sincerely,
/s/ Stephen Kiehl
Stephen Kiehl
Attachment
DC: 5806013-1
Motion Picture and Television

Flight Operation Manual
NFL Productions LLC d/b/a NFL Films

One Sabol Way
Mt. Laurel, NJ 08054
(856) 222-3545 | (856) 291-5455 (Fax)
Date: August 11, 2015
Version: Original
Table of Contents
A.
Purpose............................................................................................................................... 4
B.
Pilot/Operator Organization ............................................................................................ 4
C.
Pilots To Be Used During Filming ................................................................................... 4
D.
List of Aircraft by Make, Model and Serial or Registration Number ......................... 4
E.
Distribution and Revision ................................................................................................ 4
F.
Persons Authorized ........................................................................................................... 5
G.
Area of Operations ............................................................................................................ 5
H.
Plan of Activities ............................................................................................................... 8
I.
Permission to Operate ...................................................................................................... 9
J.
Security .............................................................................................................................. 9
K.
Briefing of Pilots and Production Personnel ................................................................ 10
L.
Certification/Airworthiness ........................................................................................... 10
M.
Pilot PersonnelMinimum Requirements................................................................... 10
N.
Limitations ....................................................................................................................... 10
O.
Communications ............................................................................................................. 10
P.
Accident Notification ...................................................................................................... 11
Q.
Recall/Stop Procedures ................................................................................................... 11
R.
Aerobatic Competency ................................................................................................... 11
Appendix A
Appendix B
Appendix C
Page 2 of 14
Revision Control Page

Revision #
Date
Initials
______________________________________________________________________________
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______________________________________________________________________________
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______________________________________________________________________________
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______________________________________________________________________________
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Page 3 of 14
Motion Picture and Television Flight Operation Manual

A.
Purpose
This Manual has been developed by NFL Productions LLC d/b/a NFL Films (NFL Films) in
conjunction with an application for an exemption from a limited number of regulations pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as
outlined in NFL Films exemption application dated May 20, 2015, for use of sUAS to gather
footage from closed-set locations in and around NFL stadiums (on non-game days) and NFL
practice facilities. NFL Films 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 an exemption.
B.
Pilot/Operator Organization
NFL Productions LLC d/b/a NFL Films -- Operator

One Sabol Way
Barry M. Wolper - Chief Financial Officer and applicant/responsible person - (856) 222-3545
C.
Pilots To Be Used During Filming
Pilots to be used during filming will be included in the Plan of Activities to be filed at least three
(3) days prior to each scheduled filming, pursuant to Section H, infra, with the local FSDO
having jurisdiction over the area of proposed filming. The list of pilots will include each pilots
pilot certificate number as well as special pilot authorizations or endorsements, if applicable.
D.
List of Aircraft by Make, Model and Serial or Registration Number
A list of aircraft to be used appears in Appendix B, infra. Furthermore, any aircraft to be used in
the proposed filming shall be listed by make, model and serial or registration number in the Plan
of Activities to be filed at least three days prior to each scheduled filming, pursuant to Section H,
infra, with the local FSDO having jurisdiction over the area of proposed filming.
E.
Distribution and Revision
NFL Films will issue a copy of this manual, including all revisions, to all personnel involved in
sUAS operation. All recipients are required to keep their manuals up-to-date with any furnished
revisions.
Amendments in FARs and normal usage will frequently indicate a need for additions, deletions,
or corrections of selected subject matter in this manual. Revisions to the manual will be issued
periodically to reflect these changes. In addition, manual users who observe or experience a
need for change are encouraged to submit their suggestions to the Chief Financial Officer for
review and consideration.
Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at
least 15 days before the proposed effective date. Revisions will be noted on the Revision
Page 4 of 14
Control Page at the front of this Manual and will be noted in bold in this Manual. Each
subsequent revision of the Manual will be distributed to all company personnel involved in
sUAS operation.
F.
Persons Authorized
Section 91.119(c) is waived only with respect to those participating persons, vehicles, and
structures directly involved in the performance of the actual filming. The pilot-in-command and
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 in the event that a suitable, equivalent level of safety can be
achieved. An equivalent level of safety may be determined by evaluation of the filming
production area and the degree of terrain features, buildings, etc. that will provide a safety barrier
to observers.
Prior to any filming, the pilot-in-command and certificate holder shall be responsible for
obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as
outlined above) of the filming. Such consent forms shall be maintained by the operator for a
period of at least six (6) months following the filming.
G.
Area of Operations
The area of operations shall cover all NFL stadiums and practice facilities in the United States,
including:
NFL Stadiums
Arizona Cardinals
University of Phoenix Stadium
Glendale, AZ 85305
Miami Dolphins
Sun Life Stadium
Miami Gardens, FL 33056
Atlanta Falcons
Georgia Dome
Atlanta, GA 30313
Minnesota Vikings
TCF Bank Stadium
Minneapolis, MN 55455
Baltimore Ravens
M&T Bank Stadium
Baltimore, MD 21230
New England Patriots

Gillette Stadium
Foxboro, MA 02035
Buffalo Bills
Ralph Wilson Stadium
Orchard Park, NY 14127
New Orleans Saints

Mercedes-Benz Superdome
New Orleans, LA 70112
Carolina Panthers
Bank of America Stadium
Charlotte, NC 28202
New York Giants

MetLife Stadium
East Rutherford, NJ 07073
Page 5 of 14
Chicago Bears
Soldier Field
Chicago, IL 60605
New York Jets

MetLife Stadium
Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH
Oakland Raiders
O.co Coliseum
Oakland, CA 94621
Cleveland Browns
FirstEnergy Stadium
Cleveland, OH 44114
Philadelphia Eagles
Lincoln Financial Field
Philadelphia, PA 19148
Dallas Cowboys
Cowboys Stadium
Arlington, TX 76011
Pittsburgh Steelers
Heinz Field
Pittsburgh, PA 15212-5721
Denver Broncos
Sports Authority Field at Mile High
Denver, CO 80204
St. Louis Rams

Edward Jones Dome
St. Louis, MO 63101
Detroit Lions
Ford Field
Detroit, MI 48226
San Diego Chargers

Qualcomm Stadium
San Diego, CA 92108
Green Bay Packers

Lambeau Field
Green Bay, WI 54304
San Francisco 49ers

Levis Stadium
Santa Clara, CA 95054
Houston Texans
NRG Stadium
Houston, TX 77054
Seattle Seahawks
CenturyLink Field
Seattle, WA 98104
Indianapolis Colts
Lucas Oil Stadium
Indianapolis, IN
Tampa Bay Buccaneers

Raymond James Stadium
Tampa, FL 33607
Jacksonville Jaguars
EverBank Field
Jacksonville, FL 32202
Tennessee Titans
Nissan Stadium
Nashville, TN 37213
Kansas City Chiefs

Arrowhead Stadium
Kansas City, MO 64129
Washington Redskins
FedEx Field
Landover, MD 20785
Page 6 of 14
NFL Practice Facilities

Arizona Cardinals
Glendale, AZ 85305
Miami Dolphins
Miami Dolphins Training Facility
Davie, FL 33314
Atlanta Falcons
Atlanta Falcons Training Complex
Flowery Branch, GA 30542
Minnesota Vikings
Minnesota State University Mankato
Mankato, MN 56001
Baltimore Ravens
Baltimore Ravens Under Armour Performance
Center
Owings Mills, MD 21117

Gillette Stadium
Foxboro, MA 02035
Buffalo Bills
St. John Fisher College
Rochester, NY 14618
New Orleans Saints

The Greenbrier
White Sulpher Springs, WV 24986
Carolina Panthers
Wofford College
Spartanburg, SC 29303-3663
New York Giants

Quest Diagnostics Training Center
1925 Giants Drive
Chicago Bears
Olivet Nazarene University
Bourbonnais, IL 60914
New York Jets

Atlantic Health Jets Training Center
Florham Park, NJ 07932
Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH 45202
Oakland Raiders
Napa Valley Marriott Hotel
Napa, CA 94558
Cleveland Browns
Cleveland Browns Training Facility
Berea, OH 44017
Philadelphia Eagles
NovaCare Complex/Lincoln Financial Field
Dallas Cowboys
Marriott Residence Inn
Oxnard, CA 93036
Pittsburgh Steelers
St. Vincents College
Latrobe, PA 15650
Cowboys Center
Irving, TX 75063-4999
UPMC Sports Performance Complex

Denver Broncos
Paul D. Bowlen Memorial Broncos Center
Englewood, CO 80112
St. Louis Rams

Rams Park Training Facility
Earth City, MO 63045
Page 7 of 14
Detroit Lions
Detroit Lions Training Facility
Allen Park, MI 48101
San Diego Chargers

Chargers Park
San Diego, CA 92123
Green Bay Packers

St. Norbert College/Don Hutson Center
Green Bay, WI 54304
San Francisco 49ers

SAP Performance Facility & Levis Stadium
Houston Texans
Houston Texans Practice Facility
Houston, TX 77054
Seattle Seahawks
Seattle Seahawks Headquarters Virginia
Mason Athletic Center
Renton, WA 98056
Indianapolis Colts
Anderson University
Anderson, IN 46012-3495

Tampa Bay Buccaneers Training Facility
Tampa, FL 33607
Indiana Farm Bureau Football Center

Indianapolis, IN 46254
EverBank Field
Tennessee Titans
St. Thomas Sports Park
Nashville, TN 37228
Kansas City Chiefs

Missouri Western State University
St. Joseph, MO 64506
Washington Redskins
Bon Secours Washington Redskins Training
Center
Richmond, VA 23220
The pilot/operator shall coordinate with the FSDO having geographic responsibility over the area
of the filming operations.
H.
Plan of Activities
At least three (3) days prior to any scheduled filming, NFL Films shall submit a written plan of
activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of
activities shall include the following:
1)
Dates and times for all flights.
2)
Name and phone number of operator responsible for the filming production
event.
Name and phone number of the person responsible for the on-scene operation
of the sUAS.
3)
4)
Make, model, and serial number or registration number of aircraft to be used

and type of airworthiness certificate, including Category (CAT).
Page 8 of 14
5)
Names and certificate numbers of pilots involved in the filming production

event.
6)
A statement that permission has been obtained 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.
7)
Signature of exemption holder or a designated representative.
8)
A general outline, description or summary of the flight activity schedule,

including maps or diagrams of any area, city, town, country, and/or state over
which filming will be conducted and the altitude essential to accomplish the
operation.
At the discretion of the FSDO, the 3-day notification may be waived. Justification of the
exception to the 3-day requirement is needed.
NFL Films acknowledges that prior to the beginning of any filming operations, the plan of
activities must be accepted by the FAA.
I.
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
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
The NFL Films 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. Written permission forms will
be maintained at the job site until flight operations are completed, and then turned over to NFL
Films 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.
J.
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, vehicles and
Page 9 of 14
aircraft. Provisions will be made to immediately discontinue operations should the area(s)
become unsecured or for any other reason in the interest of safety.
K.
Briefing of Pilots and 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 following during the filming production event. Personnel will
also be briefed on any additional provisions that may be issued by the local FSDO, including the
location of boundaries or any other time limits.
L.
Certification/Airworthiness
Prior to any flight operation, the pilot in command will conduct a pre-flight inspection in
accordance with Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 91 and
applicable operating limitations. 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 from
operation until the necessary maintenance has been performed and the sUAS is found to be in a
condition for safe flight.
NFL Films will follow the sUAS manufacturers maintenance, overhaul, replacement, inpsection
and life limit requirements for the aircraft and aircraft components. Each sUAS operated under
this exemption will comply with all manufacturer safety bulletins.
The aircraft to be used may be certificated in any CAT, including experimental, provided the
requirements of 14 CFR part 91, 91.7, 91.9, and 91.203 are met.
M.
Pilot PersonnelMinimum Requirements
The pilot in command will hold either an airline transport, commercial, private, recreational, or
sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid
U.S. drivers license issued by a state, the District of Columbia, Puerto Rico, a territory, a
possession, or the Federal Government. The PIC also will 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.
N.
Limitations
Aircraft operations shall conform with the limitations set forth in NFL Films request for a
limited exemption, dated May 20, 2015, attached to this Manual as Appendix C.
The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL).
Altitude will be reported in feet AGL.
The aircraft will not be operated during night, as defined in 14 CFR 1.1.
O.
Communications
Page 10 of 14
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 apprised of the current status of the operation.
P.
Accident Notification
Should an accident or incident requiring notification of the NTSB occur, the operator would
immediately notify the NTSB pursuant to 49 CFR 830 and take steps to preserve and protect
the accident scene.
Q.
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.
R.
Aerobatic Competency
If the filming operations require the issuance of FAA Form 8710-7, see Volume 5, Chapter 9,
Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.
Page 11 of 14
Appendix A
NFL Films
Permission to Conduct Operations Form
In signing this form, I am giving NFL Films permission to operate its 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:
____________________________
Location:
____________________________
Date of
Operation:
____________________________
Basis of Authority to Grant Permission:

______________________________________________________________________
Signature:
____________________________
Date:
____________________________
NFL Films Representative Receiving Permission:

________________________________________
Page 12 of 14
Appendix B
NFL Films
List of Approved Aircraft
Make and Model
Type
Weight
DJI Innovations Phantom 1
Quad-rotor
3 lbs. (inclusive of
camera and battery)
Quad-rotor
camera and battery)
DJI Innovations Inspire 1
Quad-rotor
camera and battery)
Page 13 of 14
Appendix C
NFL Films Letter Requesting Limited Exemptions
Page 14 of 14
May 20, 2015

14 C.F.R. part 21
14 C.F.R. 45.23 (b)
14 C.F.R. 61.113 (a) & (b)
1
2

May 20, 2015
Page 2
14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 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)
an exemption:
this exemption.
permitted.

May 20, 2015
Page 3


May 20, 2015
Page 4
components.
safety bulletins.
pilot certificate.

May 20, 2015
Page 5

request.
PIC.

May 20, 2015
Page 6

exemption.
apply:
following:

May 20, 2015
Page 7
f.

upon request;

(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)

May 20, 2015
Page 8
Kurt Wimmer
Jeff Kosseff
Attachment G
CONCURRENCES
ROUTING SYMBOL
TT ARM
INITIALS/SIG
JT
DATE
9/15/15
ROUTING SYMBOL
ARM-1
INITIALS/SIG
Month XX, 2015
DATE
ROUTING SYMBOL
AFS-1
Exemption No. xxxx

Regulatory Docket No. FAA20152139
INITIALS/SIG
DATE
ROUTING SYMBOL
Mr. Kurt Wimmer

Counsel for NFL Productions LLC dba NFL Films
One CityCenter
850 Tenth Street, NW.
Washington, DC 20001-4956
INITIALS/SIG
DATE
ROUTING SYMBOL
INITIALS/SIG
Dear Mr. Wimmer:

DATE
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 letters dated May 20, 2015, and August 11, 2015, you petitioned the Federal Aviation
Administration (FAA) on behalf of NFL Productions LLC dba NFL Films (hereinafter
petitioner or operator) for an exemption. The petitioner requested to operate an unmanned
aircraft system (UAS) to conduct aerial videography and closed-set motion picture and
television filming.
See Appendix A for the petition submitted to the FAA describing the proposed operations
and the regulations that the petitioner seeks an exemption.
ROUTING SYMBOL
INITIALS/SIG
DATE
ROUTING SYMBOL
INITIALS/SIG
DATE
ROUTING SYMBOL
INITIALS/SIG
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 1, DJI Phantom 2, and DJI Inspire
1.
DATE
2
The petitioner requested relief from 14 CFR part 21, Certification procedures for products
and parts, Subpart HAirworthiness Certificates. In accordance with the statutory criteria
provided in Section 333 of Public Law 11295 in reference to 49 U.S.C. 44704, and in
consideration of the size, weight, speed, and limited 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 the requested relief from
14 CFR part 21, Certification procedures for products and parts, Subpart HAirworthiness
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 collection 1 and closed set motion picture and
filming. 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. FAA20140352), 11109 to Clayco, Inc. (see Docket No.
FAA20140507), 11112 to VDOS Global, LLC (see Docket No. FAA20140382), and
11213 to Aeryon Labs, Inc. (see Docket No. FAA20140642), 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, NFL Productions LLC dba NFL Films 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
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.
3
aerial data collection and closed set motion picture and filming. This exemption is subject to
the conditions and limitations listed below.
Conditions and Limitations
In this grant of exemption, NFL Productions LLC dba NFL Films 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 1,
DJI Phantom 2, and DJI Inspire 1 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 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 PICs FAA-issued airman medical certificate or
U.S. drivers 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
4
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.
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
operators 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 FAAs
UAS Integration Office (AFS80) 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 manufacturers 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. drivers license issued by a
state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal
5
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
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 operators PICs and VOs
(training, proficiency, and experience-building) and determining the PICs 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 airports
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
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.
operations shall be conducted in accordance with an ATO-issued COA. The
6
22. All aircraft operated in accordance with this exemption must be identified by serial
(NNumber) 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
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
boundaries of the operational area as defined by the applicable COA must be reported
to the FAA's UAS Integration Office (AFS80) within 24 hours. Accidents must be
7
reported to the National Transportation Safety Board (NTSB) per instructions
contained on the NTSB Web site: www.ntsb.gov.
television filming and production, the following additional conditions and limitations apply.
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:
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 NNumber 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;
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 holders 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.
8
This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.
Sincerely,
John S. Duncan
Director, Flight Standards Service
Enclosures
Attachment H
CONCURRENCES
ROUTING SYMBOL
TT ARM
INITIALS/SIG
DATE
ROUTING SYMBOL
ARM-1
INITIALS/SIG
Month XX, 2015
DATE
ROUTING SYMBOL
AFS-1
Exemption No. xxxx

INITIALS/SIG
DATE
ROUTING SYMBOL
Mr. Kurt Wimmer

One CityCenter
INITIALS/SIG
DATE
ROUTING SYMBOL
INITIALS/SIG
Dear Mr. Wimmer:

DATE
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 May 20, 2015, you petitioned the Federal Aviation Administration (FAA)
on behalf of NFL Productions LLC dba NFL Films (hereinafter petitioner or operator) for
an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to
conduct aerial videography and closed-set motion picture and television filming.
ROUTING SYMBOL
INITIALS/SIG
DATE
ROUTING SYMBOL
INITIALS/SIG
Comment [KE1]: pp. 1 & 2
DATE
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.
ROUTING SYMBOL
INITIALS/SIG
DATE
The UAS proposed by the petitioner is a .
Comment [KE2]: Aircraft not listed in petition.

See RFI.
2
not necessary.
You have requested to use a UAS for aerial data collection 1 or/and closed set motion picture
and filming. The FAA has issued grants of exemption in circumstances similar in all material
Our Decision
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
aerial data collection and/or closed set motion picture and filming. This exemption is subject
to the conditions and limitations listed below.
3
the operator.
1. Operations authorized by this grant of exemption are limited to the AIRCRAFT 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.
(not) permitted.
required of the VO.
Comment [KE3]: Aircraft not listed in petition.

Please see RFI.
4
safety bulletins.
5
6
7
the UAS;
parts 45, 47, 61, and 91.
8
This exemption terminates on Month DD, YYYY2017, unless sooner superseded or
rescinded.
Sincerely,
John S. Duncan
Enclosures
9
Project Officer: _______________
MR KURT WIMMER
COUNSEL FOR NFL PRODUCTIONS LLC DBA NFL FILMS
ONE CITYCENTER
850 TENTH ST NW
WASHINGTON DC 20001-4956
Attachment I
Attachment J
ACTION MEMORANDUM TO THE SECRETARY

From:
Michael P. Huerta, Administrator

x73111
Prepared by: Margaret Gilligan, Associate Administrator for Aviation Safety

x73131
Subject:
Section 333 Applicability to Proposed Unmanned Aircraft System (UAS)

Operations
_______________________________________________________________________
SUMMARY
The Federal Aviation Administration (FAA) has received requests to authorize UAS
operations under Section 333 of the FAA Modernization and Reform Act of 2012 (PL
112-95). Section 333 requires the Secretary to make a finding that, based on size, weight,
speed, operational capability, proximity to airports and populated areas, and operation
within visual line of sight, a UAS operation does not create a hazard to users of the
National Airspace System (NAS) or the public or pose a threat to national security, and
an airworthiness certification is not required.
BACKGROUND
The petitioners noted below submitted request for consideration of relief based on
Section 333 of PL 112-95. Based upon FAA review and analysis of the information
provided by the petitioners regarding the type of UAS to be operated, and the operational
environment, the FAA considers that the operations proposed by the petitions would not
create a hazard to users of the NAS or the public or pose a threat to national security and
that an airworthiness certification would not be required for the operations proposed.
While you have previously approved the proposed operations listed in the attachment, the
UAS are new and require your approval. The list includes Amazons request for
additional aircraft. Amazon has requested confidential treatment of its proposed UAS.
In addition to these new UAS that require approval, we have also received, and
recommend you approve, a petition from the NFL Productions LLC d/b/a NFL Films
(Docket no. FAA-2015-2139). The petitioner is proposing to use a small UAS to gather
footage from closed-set locations in and around NFL stadiums on non-game days and
NFL practice facilities.
RECOMMENDATION
The FAA recommends concurrence with its findings regarding the UAS operators noted.
The Secretary
APPROVED:
______________________
DISAPPROVED:
______________________
COMMENTS:
______________________
DATE: ___________________
ATTACHMENT
Date
February
2, 2015
Petitioner
XO Innovations
FAA-2015-0344
Proposed Operation
Aerial photography - industrial,
real estate, agriculture, motion
picture, and television industry
Early stage disease detection
Crop inventory
Mapping
Aerial photography
Aerial surveys
Aerial surveys
Inspections
Inspection and patrol of facilities
Aerial photogrammetry agriculture, ranching, landscape,
mining and infrastructure
Scripted, closed-set filming
February
9, 2015
AGERpoint, Inc.
FAA-2015-0323
March 19,
2015
March 23,
2015
Jonathan Doud
FAA-2015-0686
Pacific Gas & Electric Co.
FAA-2015-0708
April 16,
2015
April 23,
2015
Modern Technology Solutions,

Inc.
FAA-2015-1039
HeliVideo Productions LLC
FAA-2014-0354
April 27,
2015
SkyCam Media
FAA-2015-1240
Aerial photography
Closed-set filming
April 28,
2015
Green Bee, LLC

FAA-2015-1288
May 1,
2015
R.C. Aztec Enterprises Inc.

FAA-2015-1391
May 5,
2015
Monar Aero
FAA-2015-1447
May 6,
2015
SkyNet Aerial Media LLC

FAA-2015-1296
Aerial photography and

videography
Inspections
Aerial photography
Inspections, survey, and
monitoring
Closed-set filming of motion
pictures
Music videos
Web videos
Corporate videos
Television programs and
commercials
Still photography
Aerial photography
Unmanned Aircraft
System
DJI Matrice 100
Skyhunter 1.8 by
FPV Model
Flite Test Dragonfly
InspecTools-X-8
C-Astral Aerospace
BRAMOR rTK
Evolution Matrix
XL/Davinci
(EMXLD)
(Amendment)
DT C8S1300mm
Octocopter
Sky Hero Spyder 6
1000mm Hex
SkyCam Frame 4
1000mm Quad
DJI Matrix
RF 70
Monar Aero,
Heavy Lifter X8
Monar Aero
GoPro Quad V4
SkyHero Little
Quad
May 6,
2015
UAS Maui
FAA-2015-1459
May 6,
2015
NorthWest Aerial Perspectives

FAA-2015-1460
May 6,
2015
Cody Anderson
FAA-2015-1468
May 6,
2015
Ryan Switala
FAA-2015-1477
May 7,
2015
May 7,
2015
May 8,
2015
Adam J. Bausch
FAA-2015-1504
Modovolate
FAA-2015-1486
Above All Imaging
FAA-2015-1535
May 11,
2015
Alert Enterprises
FAA-2015-1305
May 11.
2015
IR DISTRO INC
FAA-2015-1565
May 14,
2015
Duke University
FAA-2015-1679
May 14,
2015
May 15,
RPSearch Services, Inc.

FAA-2015-1590
Elevated Productions, LLC
Ground and flight instruction

Aerial photography
Videography
Surveying
Site mapping
Aerial photography
Videography
Inspections
Aerial photography
Videography
Cinematography
Mapping
Surveying
Inspections
Aerial photography
Videography
Cinematography
Aerial photography
Videography
Aerial data collection
Cheerson CX20
Aerial Photogrammetry
cinematography
Industrial inspections
Search and rescue
Analyses
Real estate
Marketing
Surveying
Industrial surveying
Special events
Sales demonstration
CarbonCore H650

videography
Research and development
Demonstrations
Research
Education
Training
Search and rescue
ProSearch XLF Hex

ProCargo XLF x8
Aerial videography - internet,
Mid Atlantic X-8
SynDrone X8
Gemini fixed-wings
UAS
Quantum Nova
JJRC H16 YiZhan

Tarantula X6
Zeta Science FX-79
FreeFly ALTA.
InstantEye Mk-2
Gen 3
Microkopter Hex
XL
Spectra AP
2015
May 18,
2015
Strat Aero International Inc.

FAA-2015-1606
May 18,
2015
CameraBee, LLC
FAA-2015-1755
May 19,
2015
Unlimited Aerial Systems

FAA-2015-1717
May 19,
2015
Aerial Technology International,

LLC
FAA-2015-1780
May 19,
2015
Starnes Aviation
FAA-2015-1784
May 19,
2015
Straight Up Imaging
FAA-2015-1599
May 19,
2015
May 21,
2015
Strix Imaging LLC

FAA-2015-1734
Airvision LLC
FAA-2015-1859
May 21,
2015
Vision Pictures, LLC

FAA-2015-0423
May 26,
2015
Matthew D. Lavin aka

Aerography
commercials, marketing, and

closed-set motion picture and
television filming
Training
Aerial photography
Surveillance of events and
facilities
Closed-set motion picture and
filming
Research
Aerial surveys
Mapping
Inspections
Training
Agriculture
Inspection
Filming and surveying services
Aerial photography and video
education
Training and demonstration for
emergency first responders
Filmmaking
Cinematography
Photography and videography
Precision agriculture
Monitoring
Surveying
Inspections
Public entity support operations
Aerial survey
Aerial photography and filming
Closed-set filming
television filming
videography
STR8
Hoverfly
Systems/Aeronavics
Model Erista
8/Skyjib 8 Hoverfly
Systems/SkyHero
Model Spyder 700
Quad
Unlimited Aerial
Systems
Boomerang
AgBot
Thor X4
AgGasser
Lumenier QAV 500
Team Black Sheep
Discovery Pro
M451
Swift Radioplanes
Lynx
Remote Aerial
Cinematography
Systems UAS
FX8 Elite Pro
(Amendment)
Gryphon Dynamics
900
May 26,
2015
May 26,
2015
May 26,
2015
May 27,
2015
May 28,
2015
May 28,
2015
May 29,
2015
June 1,
2015
June 2,
2015
FAA-2015-1901
Jesse Slesar
FAA-2015-1913
Aerial imaging, photography, and

videography
Flightline Geographics, LLC

FAA-2015-1925
Matthew D. Lavin a/k/a
Aerography
FAA-2015-1901
Astraeus Aerial
FAA-2015-0352
Peter Sachs
FAA-2015-1810
MotoMon, Inc.
FAA-2015-1980
Tonon USA Engineering,
Measurements and Testing, LLC
FAA-2015-2014
SkyNet Aerial Media,LLC
FAA-2015-2017
AirGon, LLC
FAA-2015-1881

videography
videography
Aerial photography and data
collection
June 3,
2015
Woods Hole Oceanographic

Institution
FAA-2015-2067
June 3,
2015
June 4,
2015
KVARA, Inc
FAA-2015-1970
Flight AV, Inc.
FAA-2015-2111
June 5,
2015
Digital GIS, LLC

FAA-2015-2141
June 5,
2015
NFL Productions LLC dba NFL

Films
June 10,
2015
Colorado Aerial Imaging, LLC

FAA-2015-2209

videography
Closed-set filming
Aerial photography
Aerial photography
Data collection
Training programs
Demonstration flights
Research, education and UAS
platform development in the areas
of oceanography, limnology, and
environmental science
videography
Aerial surveying
Photography
Cinematography
Inspections
Aerial videography
television filming
videography
Syndrone frame
with Mikrokopter
flight controller
RPA Technologies
Ltd RQ-265
Gryphon Dynamics
900
Lumenier QAV250
Lumenier QAV400
Lumenier QAV500
(Amendment)
Tailor Toys
PowerUp 3.0
Hubscan H109S
CineCopter II
Vulcan Black
Widow 950mm
AV-900
APH-22
Mariner
Microdrones MD43000
xFold Cinema
Heavy Lifter MultiRoter
Xactsense Titan
Xactsense Max-8
Xactsense Mapfly6
DJI Phantom 1
DJI Phantom 2
DJI Inspire 1
Quanum 680 UC
Pro Hex-Copter
June 11,
2015
National UAS Solutions, LLC

FAA-2015-0
June 23,
2015
Amazon
FAA-2014-0474
Surveying
Aerial data
Amazon has requested
confidential treatment of its
proposed UAS.
Mozi Robotics
Quadthrust 350
(Amendment)
Amazon Logistics,
Inc. Mk021
Amazon Logistics,
Inc. Mk023
Pilot-RC Fun Flyer
3D
Amazon Logistics,
Inc. FF3D Quad
E-flight
Carbon-Z Cub
Amazon Logistics,
Inc. Carbon Quad
3D Robotics DIY
Quad Kit
Aimdroix Evo One
(Amendment)
Attachment K
From:
To:
Subject:
Date:
Attachments:
Sandkam, Margaret CTR (FAA)

Ngo, Dan (FAA)
FW: FAA-2015-2139 NFL Productions LLC dba NFL Films
Friday, September 25, 2015 12:53:35 PM
Section 333 Blanket 200 COA Effective 7-1-2015.pdf
NFL Productions LLC dba NFL Films - 12911.pdf
Is this what youre looking for, Dan?
-Peg Sandkam
Editor, PAI Consulting
From: Sandkam, Margaret CTR (FAA)

Sent: Thursday, September 17, 2015 3:07 PM
To: 'barry.wolper@nfl.com'
Subject: FAA-2015-2139 NFL Productions LLC dba NFL Films
Mr. Wolper,
Please see attached decision document and COA. If you have any questions, please send them to
333exemptions@faa.gov. Please note that you will receive an automated response, but your email will be answered.
-Peg Sandkam
Editor, PAI Consulting
FAA FORM 7711-1 UAS COA

Page 1 of 6
Blanket COA for any Operator issued a valid Section 333 Grant of Exemption
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
CERTIFICATE OF WAIVER OR AUTHORIZATION
ISSUED TO
Any Operator with a valid Section 333 Grant of Exemption
This certificate is issued for the operations specifically described hereinafter. No person shall conduct
any operation pursuant to the authority of this certificate except in accordance with the standard and special
provisions contained in this certificate, and such other requirements of the Federal Aviation Regulations not
specifically waived by this certificate.
OPERATIONS AUTHORIZED
Operation of Unmanned Aircraft Systems in accordance with the operators Section 333 Grant of
Exemption at or below 200 feet Above Ground Level (AGL) in the National Airspace System (NAS).
LIST OF WAIVED REGULATIONS BY SECTION AND TITLE
N/A
STANDARD PROVISIONS
1. A copy of the application made for this certificate shall be attached and become a part hereof.
2. This certificate shall be presented for inspection upon the request of any authorized representative of the
Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing
local laws or regulations.
3. The holder of this certificate shall be responsible for the strict observance of the terms and provisions
contained herein.
4. This certificate is nontransferable.
Note-This certificate constitutes a waiver of those Federal rules or regulations specifically referred to
above. It does not constitute a waiver of any State law or local ordinance.
SPECIAL PROVISIONS
Special Provisions are set forth and attached.
This certificate has the same effective dates as the Grant of Exemption and is subject to cancellation at any
time upon notice by the Administrator or his/her authorized representative.
BY DIRECTION OF THE ADMINISTRATOR
/S/
FAA Headquarters, AJV-115
(Region)
Jacqueline R. Jackson
(Signature)
Manager, UAS Tactical Operations Section
(Title)
This COA terminates two years from the date of a valid Section 333 Grant of Exemption, unless sooner
superseded, rescinded, or cancelled.
FAA Form 7711-1 (7-74)
Small UAS Operations 200 feet and below for
Commercial Purposes July 2015

Page 2 of 6
STANDARD PROVISIONS
A. General.
1. The approval of this COA is effective only with an approved Section 333 FAA Grant of
Exemption.
2. A copy of the COA including the special limitations must be immediately available to all
operational personnel at each operating location whenever UAS operations are being
conducted.
3. This authorization may be canceled at any time by the Administrator, the person
authorized to grant the authorization, or the representative designated to monitor a
specific operation. As a general rule, this authorization may be canceled when it is no
longer required, there is an abuse of its provisions, or when unforeseen safety factors
develop. Failure to comply with the authorization is cause for cancellation. The operator
will receive written notice of cancellation.
B. Safety of Flight.
1. The operator or pilot in command (PIC) is responsible for halting or canceling activity in
the COA area if, at any time, the safety of persons or property on the ground or in the air
is in jeopardy, or if there is a failure to comply with the terms or conditions of this
authorization.
See-and-Avoid
Unmanned aircraft have no on-board pilot to perform see-and-avoid responsibilities;
therefore, when operating outside of active restricted and warning areas approved for
aviation activities, provisions must be made to ensure an equivalent level of safety exists
for unmanned operations consistent with 14 CFR Part 91 91.111, 91.113 and 91.115.
a. The pilot in command (PIC) is responsible:
To remain clear and give way to all manned aviation operations and activities at
all times,
For the safety of persons or property on the surface with respect to the UAS, and
For compliance with CFR Parts 91.111, 91.113 and 91.115
b. UAS pilots will ensure there is a safe operating distance between aviation activities
and unmanned aircraft (UA) at all times.
c. Visual observers must be used at all times and maintain instantaneous communication
with the PIC.

Page 3 of 6
d. The PIC is responsible to ensure visual observer(s) are:
Able to see the UA and the surrounding airspace throughout the entire flight, and
Able to provide the PIC with the UAs flight path, and proximity to all aviation
activities and other hazards (e.g., terrain, weather, structures) sufficiently for the
PIC to exercise effective control of the UA to prevent the UA from creating a
collision hazard.
e. Visual observer(s) must be able to communicate clearly to the pilot any instructions
required to remain clear of conflicting traffic.
2. Pilots are reminded to follow all federal regulations e.g. remain clear of all Temporary
Flight Restrictions, as well as following the exemption granted for their operation.
3. The operator or delegated representative must not operate in Prohibited Areas, Special
Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone.
Such areas are depicted on charts available at
http://www.faa.gov/air_traffic/flight_info/aeronav/. Additionally, aircraft operators
should beware of and avoid other areas identified in Notices to Airmen (NOTAMS)
which restricts operations in proximity to Power Plants, Electric Substations, Dams,
Wind Farms, Oil Refineries, Industrial Complexes, National Parks, The Disney Resorts,
Stadiums, Emergency Services, the Washington DC Metro Flight Restricted Zone,
Military or other Federal Facilities.
4. All aircraft operated in accordance with this Certificate of Waiver/Authorization must be
identified by serial number, registered in accordance with 14 CFR part 47, and have
identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C.
Markings must be) as large as practicable.
C. Reporting Requirements
1. Documentation of all operations associated with UAS activities is required regardless of
the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are
required.
2. The operator must submit the following information through
mailto:9-AJV-115-UASOrganization@faa.gov on a monthly basis:
a. Name of Operator, Exemption number and Aircraft registration number
b. UAS type and model
c. All operating locations, to include location city/name and latitude/longitude
d. Number of flights (per location, per aircraft)
e. Total aircraft operational hours
f. Takeoff or Landing damage

Page 4 of 6
g. Equipment malfunctions. Reportable malfunctions include, but are not limited to the
following:
(1) On-board flight control system
(2) Navigation system
(3) Powerplant failure in flight
(4) Fuel system failure
(5) Electrical system failure
(6) Control station failure
3. The number and duration of lost link events (control, performance and health monitoring,
or communications) per UA per flight.
D. Notice to Airmen (NOTAM).
A distant (D) NOTAM must be issued when unmanned aircraft operations are being
conducted. This requirement may be accomplished:
a. Through the operators local base operations or NOTAM issuing authority, or
b. By contacting the NOTAM Flight Service Station at 1-877-4-US-NTMS (1-877-4876867) not more than 72 hours in advance, but not less than 24 hours prior to the
operation, unless otherwise authorized as a special provision. The issuing agency will
require the:
(1) Name and address of the pilot filing the NOTAM request
(2) Location, altitude, or operating area
(3) Time and nature of the activity.
(4) Number of UAS flying in the operating area.
AIR TRAFFIC CONTROL SPECIAL PROVISIONS
A. Coordination Requirements.
1. Operators and UAS equipment must meet the requirements (communication,
equipment and clearance) of the class of airspace they will operate in.
2. Operator filing and the issuance of required distance (D) NOTAM, will serve as
advance ATC facility notification of UAS operations in an area.
3. Operator must cancel NOTAMs when UAS operations are completed or will not be
conducted.
4. Coordination and deconfliction between Military Training Routes (MTRs) is the
operators responsibility. When identifying an operational area the operator must

Page 5 of 6
evaluate whether an MTR will be affected. In the event the UAS operational area
overlaps (5 miles either side of centerline) an MTR, the operator will contact the
scheduling agency 24 hours in advance to coordinate and deconflict. Approval from
the scheduling agency is not required. Scheduling agencies are listed in the Area
Planning AP/1B Military Planning Routes North and South America, if unable to gain
access to AP/1B contact the FAA at email address
mailto:9-AJV-115-UASOrganization@faa.gov with the IR/VR routes affected and the
FAA will provide the scheduling agency information. If prior coordination and
deconfliction does not take place 24 hours in advance, the operator must remain clear
of all MTRs.
B. Communication Requirements.
1. When operating in the vicinity of an airport without an operating control tower,
announce your operations in accordance with the FAA Aeronautical Information
Manual (AIM) 4-1-9 Traffic Advisory Practices at Airports without Operating Control
Towers.
C. Flight Planning Requirements.
Note: For all UAS requests not covered by the conditions listed below, the exemption
holder may apply for a new Air Traffic Organization (ATO) Certificate of Waiver or
Authorization (COA) at https://oeaaa.faa.gov/oeaaa/external/uas/portal.jsp
This COA will allow small UAS (55 pounds or less) operations during daytime VFR
conditions under the following conditions and limitations:
(1) At or below 200 feet AGL; and
(2) Beyond the following distances from the airport reference point (ARP) of a public use
airport, heliport, gliderport, seaplane base and military airports listed in the
Airport/Facility Directory, Alaska Supplement, or Pacific Chart Supplement of the
U.S. Government Flight Information Publications.
a) 5 nautical miles (NM) from an airport having an operational control tower; or
b) 3 NM from an airport having a published instrument flight procedure, but not
having an operational control tower; or
c) 2 NM from an airport not having a published instrument flight procedure or an
operational control tower; or
d) 2 NM from a heliport, gliderport or seaplane base
D. Emergency/Contingency Procedures.
1. Lost Link/Lost Communications Procedures:

Page 6 of 6
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 and land.
The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
boundaries defined in this COA must be reported to the FAA via email at
mailto:9-AJV-115-UASOrganization@faa.gov 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
AUTHORIZATION
This Certificate of Waiver or Authorization does not, in itself, waive any Title 14 Code of
Federal Regulations, nor any state law or local ordinance. Should the proposed operation
conflict with any state law or local ordinance, or require permission of local authorities or
property owners, it is the responsibility of the operator to resolve the matter. This COA does not
authorize flight within Special Use airspace without approval from the scheduling agency. The
operator is hereby authorized to operate the small Unmanned Aircraft System in the National
Airspace System.

September 17, 2015
Exemption No. 12911

Mr. Kurt Wimmer

One CityCenter
Dear Mr. Wimmer:
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 letters dated May 20, 2015, and August 11, 2015, you petitioned the Federal Aviation
Administration (FAA) on behalf of NFL Productions LLC dba NFL Films (hereinafter
petitioner or operator) for an exemption. The petitioner requested to operate an unmanned
aircraft system (UAS) to conduct aerial videography and closed-set motion picture and
television filming.
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.
The UAS proposed by the petitioner are the DJI Phantom 1, DJI Phantom 2, and DJI Inspire
1.
2
not necessary.
You have requested to use a UAS for aerial data collection1 and closed set motion picture and
filming. The FAA has issued grants of exemption in circumstances similar in all material
Our Decision
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
1
3
aerial data collection and closed set motion picture and filming. This exemption is subject to
the conditions and limitations listed below.
the operator.
1. Operations authorized by this grant of exemption are limited to the DJI Phantom 1,
DJI Phantom 2, and DJI Inspire 1 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 permitted.
required of the VO.
4
safety bulletins.
5
6
7
the UAS;
parts 45, 47, 61, and 91.
8
This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.
Sincerely,
/s/
John S. Duncan
Enclosures
May 20, 2015

14 C.F.R. part 21
14 C.F.R. 45.23 (b)
14 C.F.R. 61.113 (a) & (b)
1
2

May 20, 2015
Page 2
14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 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)
an exemption:
this exemption.
permitted.

May 20, 2015
Page 3


May 20, 2015
Page 4
components.
safety bulletins.
pilot certificate.

May 20, 2015
Page 5

request.
PIC.

May 20, 2015
Page 6

exemption.
apply:
following:

May 20, 2015
Page 7
f.

upon request;

(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)

May 20, 2015
Page 8
Kurt Wimmer
Jeff Kosseff
Filed Electronically Via Regulations.gov
August 11, 2015
Dan Ngo
FAA Office of Rulemaking
800 Independence Ave. SW
Re: FAA-2015-2139
Dear Mr. Ngo:
Attached please find a Motion Picture and Television Operations Manual (MPTOM)
prepared by NFL Films for the above-referenced docket. The MPTOM includes, at Appendix B,
a description of the aircraft makes, models, and types, as requested, for the proposed UAS
operation.
This letter and the attachment were filed online at regulations.gov in Docket No. FAA2015-2139.
Please contact me if you have any questions.
Sincerely,
/s/ Stephen Kiehl
Stephen Kiehl
Attachment
DC: 5806013-1
Motion Picture and Television

Flight Operation Manual
NFL Productions LLC d/b/a NFL Films

One Sabol Way
(856) 222-3545 | (856) 291-5455 (Fax)
Date: August 11, 2015
Version: Original
Table of Contents
A.
Purpose............................................................................................................................... 4
B.
Pilot/Operator Organization ............................................................................................ 4
C.
Pilots To Be Used During Filming ................................................................................... 4
D.
List of Aircraft by Make, Model and Serial or Registration Number ......................... 4
E.
Distribution and Revision ................................................................................................ 4
F.
Persons Authorized ........................................................................................................... 5
G.
Area of Operations ............................................................................................................ 5
H.
Plan of Activities ............................................................................................................... 8
I.
Permission to Operate ...................................................................................................... 9
J.
Security .............................................................................................................................. 9
K.
Briefing of Pilots and Production Personnel ................................................................ 10
L.
Certification/Airworthiness ........................................................................................... 10
M.
Pilot PersonnelMinimum Requirements................................................................... 10
N.
Limitations ....................................................................................................................... 10
O.
Communications ............................................................................................................. 10
P.
Accident Notification ...................................................................................................... 11
Q.
Recall/Stop Procedures ................................................................................................... 11
R.
Aerobatic Competency ................................................................................................... 11
Appendix A
Appendix B
Appendix C
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Motion Picture and Television Flight Operation Manual

A.
Purpose
This Manual has been developed by NFL Productions LLC d/b/a NFL Films (NFL Films) in
conjunction with an application for an exemption from a limited number of regulations pursuant
to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, as
outlined in NFL Films exemption application dated May 20, 2015, for use of sUAS to gather
footage from closed-set locations in and around NFL stadiums (on non-game days) and NFL
practice facilities. NFL Films 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 an exemption.
B.
Pilot/Operator Organization
NFL Productions LLC d/b/a NFL Films -- Operator

One Sabol Way
Barry M. Wolper - Chief Financial Officer and applicant/responsible person - (856) 222-3545
C.
Pilots To Be Used During Filming
Pilots to be used during filming will be included in the Plan of Activities to be filed at least three
(3) days prior to each scheduled filming, pursuant to Section H, infra, with the local FSDO
having jurisdiction over the area of proposed filming. The list of pilots will include each pilots
pilot certificate number as well as special pilot authorizations or endorsements, if applicable.
D.
List of Aircraft by Make, Model and Serial or Registration Number
A list of aircraft to be used appears in Appendix B, infra. Furthermore, any aircraft to be used in
the proposed filming shall be listed by make, model and serial or registration number in the Plan
of Activities to be filed at least three days prior to each scheduled filming, pursuant to Section H,
infra, with the local FSDO having jurisdiction over the area of proposed filming.
E.
Distribution and Revision
NFL Films will issue a copy of this manual, including all revisions, to all personnel involved in
sUAS operation. All recipients are required to keep their manuals up-to-date with any furnished
revisions.
Amendments in FARs and normal usage will frequently indicate a need for additions, deletions,
or corrections of selected subject matter in this manual. Revisions to the manual will be issued
periodically to reflect these changes. In addition, manual users who observe or experience a
need for change are encouraged to submit their suggestions to the Chief Financial Officer for
review and consideration.
Revisions to the Manual will be forwarded to the Flight Standards District Office (FSDO) at
least 15 days before the proposed effective date. Revisions will be noted on the Revision
Page 4 of 14
Control Page at the front of this Manual and will be noted in bold in this Manual. Each
subsequent revision of the Manual will be distributed to all company personnel involved in
sUAS operation.
F.
Persons Authorized
Section 91.119(c) is waived only with respect to those participating persons, vehicles, and
structures directly involved in the performance of the actual filming. The pilot-in-command and
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 in the event that a suitable, equivalent level of safety can be
achieved. An equivalent level of safety may be determined by evaluation of the filming
production area and the degree of terrain features, buildings, etc. that will provide a safety barrier
to observers.
Prior to any filming, the pilot-in-command and certificate holder shall be responsible for
obtaining signed consent forms from any person who is allowed within 500 feet (or 200 feet as
outlined above) of the filming. Such consent forms shall be maintained by the operator for a
period of at least six (6) months following the filming.
G.
Area of Operations
The area of operations shall cover all NFL stadiums and practice facilities in the United States,
including:
NFL Stadiums
Arizona Cardinals
Glendale, AZ 85305
Miami Dolphins
Sun Life Stadium
Miami Gardens, FL 33056
Atlanta Falcons
Georgia Dome
Atlanta, GA 30313
Minnesota Vikings
TCF Bank Stadium
Minneapolis, MN 55455
Baltimore Ravens
M&T Bank Stadium
Baltimore, MD 21230

Gillette Stadium
Foxboro, MA 02035
Buffalo Bills
Ralph Wilson Stadium
Orchard Park, NY 14127
New Orleans Saints

Mercedes-Benz Superdome
New Orleans, LA 70112
Carolina Panthers
Bank of America Stadium
Charlotte, NC 28202
New York Giants

MetLife Stadium
Page 5 of 14
Chicago Bears
Soldier Field
Chicago, IL 60605
New York Jets

MetLife Stadium
Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH
Oakland Raiders
O.co Coliseum
Oakland, CA 94621
Cleveland Browns
FirstEnergy Stadium
Cleveland, OH 44114
Philadelphia Eagles
Lincoln Financial Field
Dallas Cowboys
Cowboys Stadium
Arlington, TX 76011
Pittsburgh Steelers
Heinz Field
Denver Broncos
Sports Authority Field at Mile High
Denver, CO 80204
St. Louis Rams

Edward Jones Dome
St. Louis, MO 63101
Detroit Lions
Ford Field
Detroit, MI 48226
San Diego Chargers

Qualcomm Stadium
San Diego, CA 92108
Green Bay Packers

Lambeau Field
Green Bay, WI 54304
San Francisco 49ers

Levis Stadium
Houston Texans
NRG Stadium
Houston, TX 77054
Seattle Seahawks
CenturyLink Field
Seattle, WA 98104
Indianapolis Colts
Lucas Oil Stadium
Indianapolis, IN

Raymond James Stadium
Tampa, FL 33607
EverBank Field
Tennessee Titans
Nissan Stadium
Nashville, TN 37213
Kansas City Chiefs

Arrowhead Stadium
Kansas City, MO 64129
Washington Redskins
FedEx Field
Landover, MD 20785
Page 6 of 14
NFL Practice Facilities

Arizona Cardinals
Glendale, AZ 85305
Miami Dolphins
Miami Dolphins Training Facility
Davie, FL 33314
Atlanta Falcons
Atlanta Falcons Training Complex
Flowery Branch, GA 30542
Minnesota Vikings
Minnesota State University Mankato
Mankato, MN 56001
Baltimore Ravens
Baltimore Ravens Under Armour Performance
Center
Owings Mills, MD 21117

Gillette Stadium
Foxboro, MA 02035
Buffalo Bills
St. John Fisher College
Rochester, NY 14618
New Orleans Saints

The Greenbrier
White Sulpher Springs, WV 24986
Carolina Panthers
Wofford College
Spartanburg, SC 29303-3663
New York Giants

Quest Diagnostics Training Center
1925 Giants Drive
Chicago Bears
Olivet Nazarene University
Bourbonnais, IL 60914
New York Jets

Atlantic Health Jets Training Center
Florham Park, NJ 07932
Cincinnati Bengals
Paul Brown Stadium
Cincinnati, OH 45202
Oakland Raiders
Napa Valley Marriott Hotel
Napa, CA 94558
Cleveland Browns
Cleveland Browns Training Facility
Berea, OH 44017
Philadelphia Eagles
NovaCare Complex/Lincoln Financial Field
Dallas Cowboys
Marriott Residence Inn
Oxnard, CA 93036
Pittsburgh Steelers
St. Vincents College
Latrobe, PA 15650
Cowboys Center
Irving, TX 75063-4999
UPMC Sports Performance Complex

Denver Broncos
Paul D. Bowlen Memorial Broncos Center
Englewood, CO 80112
St. Louis Rams

Rams Park Training Facility
Earth City, MO 63045
Page 7 of 14
Detroit Lions
Detroit Lions Training Facility
Allen Park, MI 48101
San Diego Chargers

Chargers Park
San Diego, CA 92123
Green Bay Packers

St. Norbert College/Don Hutson Center
Green Bay, WI 54304
San Francisco 49ers

SAP Performance Facility & Levis Stadium
Houston Texans
Houston Texans Practice Facility
Houston, TX 77054
Seattle Seahawks
Seattle Seahawks Headquarters Virginia
Mason Athletic Center
Renton, WA 98056
Indianapolis Colts
Anderson University
Anderson, IN 46012-3495

Tampa Bay Buccaneers Training Facility
Tampa, FL 33607
Indiana Farm Bureau Football Center

Indianapolis, IN 46254
EverBank Field
Tennessee Titans
St. Thomas Sports Park
Nashville, TN 37228
Kansas City Chiefs

Missouri Western State University
St. Joseph, MO 64506
Washington Redskins
Bon Secours Washington Redskins Training
Center
Richmond, VA 23220
The pilot/operator shall coordinate with the FSDO having geographic responsibility over the area
of the filming operations.
H.
Plan of Activities
At least three (3) days prior to any scheduled filming, NFL Films shall submit a written plan of
activities to the local FSDO having jurisdiction over the area of proposed filming. The plan of
activities shall include the following:
1)
Dates and times for all flights.
2)
Name and phone number of operator responsible for the filming production
event.
Name and phone number of the person responsible for the on-scene operation
of the sUAS.
3)
4)
Make, model, and serial number or registration number of aircraft to be used

and type of airworthiness certificate, including Category (CAT).
Page 8 of 14
5)
Names and certificate numbers of pilots involved in the filming production

event.
6)
A statement that permission has been obtained 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.
7)
Signature of exemption holder or a designated representative.
8)
A general outline, description or summary of the flight activity schedule,

including maps or diagrams of any area, city, town, country, and/or state over
which filming will be conducted and the altitude essential to accomplish the
operation.
At the discretion of the FSDO, the 3-day notification may be waived. Justification of the
exception to the 3-day requirement is needed.
NFL Films acknowledges that prior to the beginning of any filming operations, the plan of
activities must be accepted by the FAA.
I.
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
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
The NFL Films 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. Written permission forms will
be maintained at the job site until flight operations are completed, and then turned over to NFL
Films 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.
J.
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, vehicles and
Page 9 of 14
aircraft. Provisions will be made to immediately discontinue operations should the area(s)
become unsecured or for any other reason in the interest of safety.
K.
Briefing of Pilots and 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 following during the filming production event. Personnel will
also be briefed on any additional provisions that may be issued by the local FSDO, including the
location of boundaries or any other time limits.
L.
Certification/Airworthiness
Prior to any flight operation, the pilot in command will conduct a pre-flight inspection in
accordance with Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 91 and
applicable operating limitations. 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 from
operation until the necessary maintenance has been performed and the sUAS is found to be in a
condition for safe flight.
NFL Films will follow the sUAS manufacturers maintenance, overhaul, replacement, inpsection
and life limit requirements for the aircraft and aircraft components. Each sUAS operated under
this exemption will comply with all manufacturer safety bulletins.
The aircraft to be used may be certificated in any CAT, including experimental, provided the
requirements of 14 CFR part 91, 91.7, 91.9, and 91.203 are met.
M.
Pilot PersonnelMinimum Requirements
The pilot in command will hold either an airline transport, commercial, private, recreational, or
sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid
U.S. drivers license issued by a state, the District of Columbia, Puerto Rico, a territory, a
possession, or the Federal Government. The PIC also will 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.
N.
Limitations
Aircraft operations shall conform with the limitations set forth in NFL Films request for a
limited exemption, dated May 20, 2015, attached to this Manual as Appendix C.
The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL).
Altitude will be reported in feet AGL.
The aircraft will not be operated during night, as defined in 14 CFR 1.1.
O.
Communications
Page 10 of 14
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 apprised of the current status of the operation.
P.
Accident Notification
Should an accident or incident requiring notification of the NTSB occur, the operator would
immediately notify the NTSB pursuant to 49 CFR 830 and take steps to preserve and protect
the accident scene.
Q.
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.
R.
Aerobatic Competency
If the filming operations require the issuance of FAA Form 8710-7, see Volume 5, Chapter 9,
Section 1, Issue/Renew/Rescind a Statement of Acrobatic Competency.
Page 11 of 14
Appendix A
NFL Films
Permission to Conduct Operations Form
In signing this form, I am giving NFL Films permission to operate its 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:
____________________________
Location:
____________________________
Date of
Operation:
____________________________
Basis of Authority to Grant Permission:

______________________________________________________________________
Signature:
____________________________
Date:
____________________________
NFL Films Representative Receiving Permission:

________________________________________
Page 12 of 14
Appendix B
NFL Films
List of Approved Aircraft
Make and Model
Type
Weight
Quad-rotor
camera and battery)
Quad-rotor
camera and battery)
DJI Innovations Inspire 1
Quad-rotor
camera and battery)
Page 13 of 14
Appendix C
NFL Films Letter Requesting Limited Exemptions
Page 14 of 14
May 20, 2015

14 C.F.R. part 21
14 C.F.R. 45.23 (b)
14 C.F.R. 61.113 (a) & (b)
1
2

May 20, 2015
Page 2
14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121
14 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)
an exemption:
this exemption.
permitted.

May 20, 2015
Page 3


May 20, 2015
Page 4
components.
safety bulletins.
pilot certificate.

May 20, 2015
Page 5

request.
PIC.

May 20, 2015
Page 6

exemption.
apply:
following:

May 20, 2015
Page 7
f.

upon request;

(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)

May 20, 2015
Page 8
Kurt Wimmer
Jeff Kosseff
Attachment L
Regulations.gov - Your Receipt
Page 1 of 2
Your comment was submitted successfully!

The Federal Aviation Administration (FAA) Other: NFL Productions LLC d/b/a NFL Films Exemption/Rulemaking
For related information, Open Docket Folder
Your Receipt
Your Comment Tracking Number:

1jz-8l76-nofq
Your comment may be viewable on

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reviewed it. This process is dependent
on agency public submission
policies/procedures and processing
times. Use your tracking number to
find out the status of your comment.
Email Receipt
Email Address
Your comment:
Comment:
Please attach the following grant letter to NFL Productions LLC dba
NFL Films (Docket No. FAA-2015-2139).
Uploaded File(s)
(Optional)
NFL Productions LLC dba NFL Films - 12911.pdf: success
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Regulations.gov:
This information will not appear on

Regulations.gov:
First Name:
Anonymous
Phone Number:
202-267-2999
Last Name:
Anonymous
http://www.regulations.gov/
9/18/2015
Regulations.gov - Your Receipt
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Mailing Address:
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City:
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NFL Films FAA Exemption

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From:

Federal Aviation Administration

FOIA Program Management Branch

October 08, 2015

Contact: Ebony Powell

Federal Aviation Administration

Contact: Judine Slaughter

Federal Aviation Administration

Contact: Derek Honda

Letter dated May 20, 2015 from Kurt Wimmer

May 20, 2015

U.S. Department of Transportation

14 C.F.R. 91.7 (a)

U.S. Department of Transportation

be operated at airspeeds greater than the maximum UA operating airspeed

U.S. Department of Transportation

U.S. Department of Transportation

the current FAA-published aeronautical chart, unless a letter of agreement with

U.S. Department of Transportation

under such protection. If a situation arises where nonparticipating

U.S. Department of Transportation

A statement that the operator has obtained permission from property

g. Signature of exemption holder or representative; and

U.S. Department of Transportation

Part 11/Section 333 Review

Signatory - Kurt Wimmer

TEXT FOR RFI E-MAIL

Dear Mr. Wimmer:

Please submit the additional information (non-proprietary) to your docket at

Your comment was submitted successfully!

Your Comment Tracking Number:

Filed Electronically Via Regulations.gov

August 11, 2015

Motion Picture and Television

NFL Productions LLC d/b/a NFL Films

Date: August 11, 2015

Pilot/Operator Organization ............................................................................................ 4

Pilots To Be Used During Filming ................................................................................... 4

List of Aircraft by Make, Model and Serial or Registration Number ......................... 4

Distribution and Revision ................................................................................................ 4

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

Area of Operations ............................................................................................................ 5

Plan of Activities ............................................................................................................... 8

Permission to Operate ...................................................................................................... 9

Briefing of Pilots and Production Personnel ................................................................ 10

Pilot PersonnelMinimum Requirements................................................................... 10

Accident Notification ...................................................................................................... 11

Recall/Stop Procedures ................................................................................................... 11

Aerobatic Competency ................................................................................................... 11

Revision Control Page

Motion Picture and Television Flight Operation Manual

NFL Productions LLC d/b/a NFL Films -- Operator

Pilots To Be Used During Filming

List of Aircraft by Make, Model and Serial or Registration Number

Distribution and Revision

New England Patriots

New Orleans Saints

New York Giants

New York Jets

St. Louis Rams

San Diego Chargers

Green Bay Packers

San Francisco 49ers

Tampa Bay Buccaneers