Heavy-lift FPV
cinematography

How to read this handbook

Audience: remote pilots in command, aircraft integrators, production management and qualified reviewers. Scope: one civil commercial aircraft in the United States, usually flown through FPV, with an independent cinema camera/gimbal operator; DFW planning context. Two camera/aircraft operators do not mean two aircraft. Actual aircraft, approvals, flight location and crew currency are unknown.

Labels mean: LEGAL REQUIREMENT identifies applicable binding authority; FAA GUIDANCE explains agency practice without creating law; APPROVAL-SPECIFIC CONDITION applies only through an operative grant/COA; MANUFACTURER LIMIT is bounded to the exact product and version; INDUSTRY GUIDANCE is nonbinding safety material; PROPOSED COMPANY SOP is this project's draft recommendation; UNRESOLVED INTERPRETATION identifies a legal or factual issue not safely resolved here. A government FAQ or industry table can be incomplete. Full current regulations and valid individual approvals control.

eCFR reports Title 14 and the relevant Title 49 text current through September 3, 2026. This is not a claim that every provision changed on that date. Section source notes are retained. House statutory pages for §§44801 and 44807 state laws in effect September 4, 2026. The Federal Register September 4-5 FAA gap query returned six documents; the only final rule concerned Point Pleasant, West Virginia Class E airspace. No intervening relevant amendment was identified. The September 4 TSA notice separately corroborates Part 108 status. A search is bounded evidence, not a guarantee against an omitted or future action.

A. Weight, operating framework and payload classification

LEGAL REQUIREMENT: Section 107.3 defines small unmanned aircraft using takeoff weight less than 55 pounds, including everything onboard or attached. Include airframe, propulsion, flight batteries, cinema body, lens, filter, gimbal, cage, plates, isolation hardware, safety retention, transmitters, antennas, Remote ID, separate batteries, cables and any landing gear. A published payload capacity is not a measured total. Exactly 55 pounds fails the definition. 14 CFR, 107.3; 49 USC 44801, Definitions, definition of small unmanned aircraft.

PROPOSED COMPANY SOP: Maintain a measured configuration sheet and scale-identification record for every payload/battery variant. If uncertainty could cross the boundary, do not characterize it as a verified under-55 configuration. Reweigh after a material change. A 54.9-pound configuration that becomes 55.1 pounds changes the framework before takeoff.

LEGAL REQUIREMENT: Part 107's applicability exceptions include operations elected under a Section 333/44807 exemption, and elected Part 91 operations using an aircraft with an airworthiness certificate. Section 107.205 only permits waiving listed operating rules, not the weight definition, recurrent-training requirement or general hazardous-operation duty. 14 CFR, 107.1; 14 CFR, 107.200; 14 CFR, 107.205.

FAA GUIDANCE / LEGAL REQUIREMENT: For civil aircraft at 55 pounds or more, the relevant planning route is Part 91 with appropriate certification and/or exemptions. Section 44807 authorizes individualized risk-based determinations about certification and safe operation. Its authority sunset is September 30, 2033, which is not the expiration of every operator grant. FAA requests CONOPS, operating/maintenance/emergency documents, checklists, pilot training, flight history and risk support, and treats COA airspace processing separately. 49 USC 44807, Special authority for certain unmanned aircraft systems, (a)-(e); Special Authority for Certain Unmanned Aircraft Systems (Section 44807); FAA AIP ENR 8.3: Large civil UAS, 2.1 and 3.1.

UNRESOLVED INTERPRETATION: No Part 91 certification path is approved for this aircraft. A remote-pilot certificate alone does not establish heavier-aircraft pilot qualification. Actual exemptions may alter certificate, medical, experience and training requirements. Standard, special and experimental airworthiness pathways have different purposes and limitations. Current §91.319(a) has enumerated compensation restrictions, while (b)-(d) and individual operating limitations remain critical. Do not repeat an older blanket compensation sentence or assume experimental certification permits a paid cinema mission. 14 CFR 91.319 Experimental certificate operating limitations, 91.319.

LEGAL REQUIREMENT: Under Part 107, secure mounted or carried objects without adverse flight characteristics or controllability. Avoid hazardous dropping. Part 133's applicability expressly excludes Part 107 aircraft. Outside Part 107, a fixed mounted camera is not automatically exempt from external-load analysis, and a suspended load adds classification/control questions. The aircraft geometry, attachment, release capability, intended operation and actual grant need review. Agricultural Part 137 does not apply merely because an aircraft lifts a camera. 14 CFR, 107.49(e); 14 CFR, 107.23(b); 14 CFR Part 133, applicability and external loads, 133.1; 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42140-42142.

APPROVAL-SPECIFIC CONDITION: Ellingson Productions LLC exemption 19430, issued September 26, 2022, authorized specified Freefly Alta X operations up to 76.9 pounds and expired September 30, 2024. Its detailed cinema, crew and separation conditions are historical precedent only. Only the first 17 pages of this historical grant were reviewed. Repeat official access failed; the complete current approval and attachments remain unverified. Newer Beverly Hills Aerials 18594E and Victor Lee 23635 were discovery records with blocked full text. See the exact limits in Approvals roadmap.

B. Roles, FPV and visual observation

LEGAL REQUIREMENT: Designate an RPIC. The RPIC has final operational authority, must ensure regulatory compliance and no undue hazard from loss of control, and must be able to direct the aircraft. A producer, director or client cannot override that authority. Under §107.12(a)(2), an uncertificated or noncurrent flight-control operator may manipulate controls only under direct RPIC supervision with the RPIC able to immediately take direct control. A voice instruction alone is not proof of that ability. 14 CFR, 107.19; 14 CFR, 107.12.

LEGAL REQUIREMENT: Section 107.31(a) requires the RPIC, the flight-control operator and any VO to be able to see the aircraft with unaided vision except corrective lenses for location, attitude/altitude/direction, traffic/hazards and people/property protection. Section 107.31(b) distinguishes who exercises this capability: either RPIC plus separate manipulator, or a VO. This distinction permits other mission-critical duties while a VO observes; it does not remove the RPIC/manipulator capability requirement. Effective communication, coordinated scanning and direct visual position awareness remain required by §107.33. 14 CFR, 107.31; 14 CFR, 107.33.

FAA GUIDANCE: FPV devices are permitted as equipment but do not satisfy VLOS. Current FAA overview instructs use of a VO for FPV. AC 107-2A §5.9.2 explains why the VO can exercise observation while the others perform mission tasks. Goggles removal and immediate reacquisition must be practical from the actual position and route. No reviewed source gives a universal allowable removal time, FPV distance or license to fly behind structures. FAA Part 107 overview, FPV observer guidance, Operating Requirements; AC 107-2A, editorial update May 26 2022, 5.9-5.9.2.

FAA GUIDANCE, with limits: The 2016 preamble expressly accepts brief sight interruptions, including some momentary obstruction, if see-and-avoid duties remain satisfied. It declines a numerical time allowance. AC §5.9 says regain sight as soon as practicable and use aircraft-appropriate preplanned procedures if unable. This is narrower than routine obscured-route permission. High speed, low altitude, close people, aircraft response and unrecoverable geometry can make even a short interruption unacceptable. PROPOSED COMPANY SOP: Do not design a shot to depend on an unvalidated obstruction exception; reposition, alter the route or seek the required specific relief. 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42095-42099; AC 107-2A, editorial update May 26 2022, 5.9.

LEGAL REQUIREMENT / FAA GUIDANCE: Multiple VOs do not legalize flight beyond the RPIC/manipulator's required sight capability. The preamble rejects observer relays for that purpose. It distinguishes a properly executed transfer of control and RPIC designation between qualified pilots that preserves sight and control. PROPOSED COMPANY SOP: Use a positive transfer call, acceptance and confirmation, with no ambiguity about controls, designation, observation or abort responsibility. 14 CFR, 107.19; 14 CFR, 107.31; 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42097-42098.

FAA GUIDANCE / UNRESOLVED INTERPRETATION: FAA's indoor-only FAQ says Part 107 does not apply to fully indoor-only operations. Crossing outdoors creates an outdoor compliance segment; starting inside provides no exception for the outside portion. A tent, roof, open-sided hangar or doorway boundary is not automatically an enclosed indoor space. Resolve the actual geometry, visibility, land access and risk. FCC/workplace/property obligations remain separate. FAA FAQ: commercial UAS indoors only.

The complete staffing matrix and camera/VO conflict analysis are in Crew roles and FPV visibility. Section 107.35 addresses more than one aircraft at a time, not the two-operator cinema concept. No universal three-person FAA staffing mandate was found. 14 CFR, 107.35.

C. Registration, custom builds and Remote ID

LEGAL REQUIREMENT: Part 107 requires registration through §91.203(a)(2). For a qualifying small aircraft, Part 48 provides individual registration for commercial/nonrecreational use; Part 47 is another registration path and relevant for heavier aircraft. Part 48's recreational exception is not a commercial exemption for sub-0.55-pound aircraft. Part 48 registrations normally last three years. Part 47's current duration provisions differ, generally seven years, and the actual certificate controls. Maintain accurate records, owner eligibility and aircraft identifiers. 14 CFR, 107.13; 14 CFR Part 48, 48.15; 14 CFR Part 48, 48.100; 14 CFR Part 47, 47.40.

LEGAL REQUIREMENT: Part 48 markings must remain affixed and legible on an external surface. Part 47 registration also requires applicable Part 45 identification/marking compliance, which must be reviewed for the exact airframe and certificate; a Part 48 sticker rule is not a universal substitute. Part 48 §48.110 specifies Standard RID or broadcast-module serial information, including restrictions on duplicate registration use. Required changes are generally updated within 14 calendar days under §48.115. 14 CFR Part 48, 48.110; 14 CFR Part 48, 48.115; 14 CFR Part 48, 48.205; 14 CFR Part 47, 47.14.

LEGAL REQUIREMENT: Part 89 applies to registered/required-to-be-registered UAS and relevant foreign operations, with stated exceptions. Standard RID under §89.110 requires the applicable compliant design/production basis, matching registration information, operative compliant functionality and broadcast from takeoff to shutdown. Section 89.110(b)(1) permits either a serial listed on an accepted DoC or a Part 21 design/production approval meeting Subpart F; the latter is a distinct alternative. A separately advertised transmitter, telemetry connection or software checkbox is not proof. Inspect the FAA DoC entry, make/model, serial range, FCC equipment, labeling and installation/operating instructions. 14 CFR, 89.101; 14 CFR, 89.110; 14 CFR, 89.305; 14 CFR, 89.530.

LEGAL REQUIREMENT: For a broadcast module, §89.115(a) requires compliant equipment with its serial on an FAA-accepted DoC, appropriate registration entry, required broadcasts, a preflight functionality check, and the flight-control manipulator's ability to see the aircraft throughout. Loss of required broadcast means land as soon as practicable. Standard RID's failure rule also requires landing as soon as practicable. The module transmits takeoff location rather than the Standard RID control-station location information; the two compliance options are not interchangeable. 14 CFR, 89.110; 14 CFR, 89.115; 14 CFR, 89.305; 14 CFR, 89.315.

UNRESOLVED INTERPRETATION: Part 89 does not explicitly adopt §107.31(b)'s observation substitution. We found no controlling FAA clarification specifically approving this custom goggles/module arrangement based merely on removing goggles. Do not assert that all module-equipped FPV is categorically forbidden, or that adding a VO automatically satisfies it. Establish compliance with both parts or obtain explicit applicable authorization. Section 107.200 only waives listed Part 107 provisions; it is not Part 89 relief. 14 CFR, 89.105; 14 CFR, 89.115; 14 CFR, 107.200.

LEGAL REQUIREMENT: FRIA operations without RID require both the aircraft and manipulator to remain within the recognized area's boundaries, with the manipulator able to see the aircraft throughout. FRIA status does not waive Part 107, land permissions or airspace restrictions. 14 CFR, 89.115(b).

LEGAL REQUIREMENT / UNRESOLVED INTERPRETATION: Part 89's defined home-built aircraft is one an individual built solely for education or recreation. A custom build intended for commercial cinema does not automatically meet that exception. Section 89.501(c) concerns production exceptions, not a general operational RID exemption. The builder's circumstances, production date, Standard RID producer obligations under §§89.505-89.535 and any authorized alternative need review. Do not assume fitting a broadcast module cures every production-compliance issue for a newly produced commercial aircraft. 14 CFR, 89.1; 14 CFR, 89.501; 14 CFR, 89.515; Remote ID for Industry and Standards Bodies.

PROPOSED COMPANY SOP: Keep configuration photographs, DoC/serial evidence and a preflight functional record. Reassess changes to antenna, RF settings, RID hardware/software, aircraft identity and registered module allocation. A category/RID declaration for a different configuration does not carry over without its required compliance basis.

D. People, production crew, vehicles and boats

LEGAL REQUIREMENT: §107.39 provides three branches: direct participants; people under qualifying covered structures or inside protective stationary vehicles; or aircraft/operations meeting a Subpart D category. Do not substitute a signed release or universal briefing for any of those branches. 14 CFR, 107.39.

FAA GUIDANCE: Direct participation concerns tasks necessary to safe aircraft operation, such as RPIC, flight-control operator, VO and potentially an actual perimeter-safety function. Actors, clients, extras, stunt performers, ordinary film crew, drivers and boat occupants are not direct participants merely because they support the film, consent or have been briefed. A camera-only operator is not automatically a safe-flight participant. Assigning a title solely to evade §107.39 does not supply the substantive role. 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42128-42131; AC 107-2A, editorial update May 26 2022, 5.1 and 8.3.

These are injury-performance requirements, not a field kinetic-energy calculation authorizing a heavy drone. A guard or parachute is only a component of an eligibility argument. Each selected operating category must actually be satisfied. 14 CFR, 107.110; 14 CFR, 107.115; 14 CFR, 107.120; 14 CFR, 107.125; 14 CFR, 107.130; 14 CFR, 107.140; 14 CFR, 107.150.

LEGAL REQUIREMENT: §107.145 separately governs overflight of people in moving vehicles. Categories 1-3 require the aircraft to qualify and either operation within/over a closed or restricted-access site with people in moving vehicles on notice, or no sustained flight over moving vehicles. Category 4 follows its approved limitations. A brief public-road crossing is not automatically permitted for an ineligible aircraft. A vehicle roof does not create the stationary-vehicle exception while moving. 14 CFR, 107.145.

LEGAL REQUIREMENT: Operating FROM a moving car or boat is a different issue under §107.25(b): the aircraft must be over a sparsely populated area and must not be transporting another person's property for compensation or hire, absent applicable relief. Paid cinematography is not automatically prohibited just because it is paid, but ownership/carriage and the actual operation need analysis. Some waiver provisions cannot authorize compensated carriage of another person's property. 14 CFR, 107.25; 14 CFR, 107.205(a),(c).

PROPOSED COMPANY SOP: For vehicle tracking or wakeboarding, plot the aircraft's route and foreseeable failure trajectory separately from the moving subject and operator platform. A shoreline pilot following a boat is not operating from the boat. A boat-based pilot triggers the moving-platform analysis as well. Boat occupants and riders are not aircraft crew by consent; exposure at turns, speed changes, towline arcs, other lake traffic and recovery needs change the risk. Side-offset filming avoids overflight only if the actual geometry supports that conclusion and does not create an undue hazard. For talent approaches and events, define abort points and site control before rehearsals.

LEGAL REQUIREMENT / APPROVAL-SPECIFIC CONDITION: No universal FAA film-set separation distance was identified in ordinary Part 107. Sections 107.19(c), 107.23 and 107.49 still apply. Numeric distances in a grant, site permit or manufacturer limitation apply within their own scope. Do not generalize historical 500-foot, 100-foot or speed-based cinema-grant conditions into ordinary Part 107. 14 CFR, 107.19; 14 CFR, 107.23; 14 CFR, 107.49.

E. Airspace, night and flight-day restrictions

LEGAL REQUIREMENT: Obtain prior ATC authorization for Class B/C/D and the airport-designated Class E surface area described in §107.41. LAANC provides eligible airspace authorization; DroneZone handles other supported requests and combined waiver/airspace cases. Neither proves BVLOS, OOP, RID, property or aircraft approval. UAS Facility Maps are processing aids, not clearances or new airspace. A zero grid requires analysis, not a blanket claim of impossibility. 14 CFR, 107.41; LAANC airspace authorization overview; UAS Facility Maps FAQ.

LEGAL REQUIREMENT: Ordinary Part 107 operating limits are 87 knots/100 mph groundspeed; ordinarily 400 feet AGL, with the two-part structure exception; at least 3 statute miles control-station flight visibility; 500 feet below and 2,000 feet horizontally from clouds. These are ceilings/minima, not safe performance targets. Airspace authorization, aircraft and grant limitations may be tighter. 14 CFR, 107.51.

LEGAL REQUIREMENT: Night requires the qualifying post-April-6-2021 initial test/training and anticollision lighting visible at least 3 statute miles with adequate flash rate. Civil twilight also requires the light; Texas uses the specified 30-minute sunrise/sunset intervals. Intensity can be reduced for safety but not extinguished under the current rule. Night does not remove VLOS, other training, airspace, OOP or RID requirements. 14 CFR, 107.29; 14 CFR, 107.65.

LEGAL REQUIREMENT: Yield to all other aircraft/airborne vehicles, stay well clear and avoid airport/heliport/seaplane-base interference. Check §§91.137-91.145 and §99.7 restrictions through §107.47, plus prohibited/restricted-area agency permission under §107.45. Military operating/training areas require assessment even when not simply prohibited airspace. Emergency aircraft, firefighting and medical flights have priority; media status is not an emergency-flight entitlement. 14 CFR, 107.37; 14 CFR, 107.43; 14 CFR, 107.45; 14 CFR, 107.47; FAA Temporary Flight Restrictions.

FAA GUIDANCE / LEGAL REQUIREMENT: The familiar sporting-event restriction is generally 3 NM through 3,000 feet AGL around qualifying events at venues seating at least 30,000, from one hour before scheduled start to one hour after actual end. It is not every event or every stadium at all times. The FAA's current directory links FDC 0/0367; older references differ. Use current text, exceptions and event timing. Other public-gathering/security TFRs can apply independently, and Texas has a different venue statute. A saved NOTAM is never live clearance. FAA Stadiums and Sporting Events; FAA FDC 0/0367 PDF, Parts 2-3.

PROPOSED COMPANY SOP: DFW planning requires the exact polygon, altitude AGL/MSL, route, contingency areas, date and local/UTC time. Check current sectional/terminal/helicopter charts and Chart Supplement; nearby DFW, Love Field, Addison, Alliance, Meacham, Dallas Executive, hospital heliports and military facilities where relevant. Refresh FAA TFRs, NOTAM Search, current SUA/MTR information, Aviation Weather Center, on-site weather and actual authorization conditions. Recheck after delays or changes. No location was declared clear in this project.

F. Aircraft practices, emergency planning and reporting

LEGAL REQUIREMENT: Preflight and continued safe condition are required, together with environment assessment, informed participants, functioning control links, sufficient energy and secure payload. No known unsafe condition can be cured by a director accepting the risk. 14 CFR, 107.15; 14 CFR, 107.17; 14 CFR, 107.49.

INDUSTRY GUIDANCE: CSATF Bulletin 36, revised May 29, 2025, addresses command/abort authority, cleared routes, public control, exclusion areas, modification approval, inspections, RF coordination, battery risks, environmental effects, CG, stunt coordination, briefings and call-sheet notification. Bulletin 36A is a secondary FAA summary and includes a historical 2016 attachment. Neither overrides current CFR. Safety Bulletin 36: Unmanned Aircraft Systems, pp. 1-4; Safety Bulletin 36A: FAA Regulations.

MANUFACTURER LIMIT: Nikon ZR specifications distinguish body-only and battery/card weight; actual mounted camera mass must be measured. The guide is bounded to firmware coverage, with the exact installed version unresolved. Nikon warns about shock/vibration, moisture and interference. DJI RS 4 Pro and RS 5 have different tested payloads; balancing, grip/battery, temperature and water limits do not establish aircraft suitability. Obtain flight-controller, ESC/motor/propeller, battery, radio and aircraft-specific manuals before completing limits. Nikon ZR reference guide specifications; Nikon ZR technical cautions; DJI RS 4 and RS 4 Pro User Manual v1.0; DJI RS 5 User Manual v1.0; DJI RS 5 specifications.

PROPOSED COMPANY SOP: The draft manual covers mass/CG, mount retention, travel clearance, vibration, propeller danger, battery condition/reserve methodology, thermal load, RF coexistence/antennas, maintenance/configuration control and post-change review. Rehearse the communication and abort sequence without treating a rehearsal as proof of airworthiness. Heat, fatigue, high-speed low-altitude work, public incursions and production distractions require explicit risk review. Aircraft qualification/controlled validation must be separately planned by the qualified operator, not improvised from this handbook.

LEGAL REQUIREMENT / PROPOSED COMPANY SOP: Separate FPV-video loss from camera-video loss; also separately address flight-control link, gimbal control, GNSS, RID, crew comms, low power, payload instability, flyaway and unexpected people/aircraft. The RPIC must use the actual approved/validated contingency. Do not assume hover, return-home, obstacle avoidance or motor-out capability. No generic disarm setting, battery percentage, return height or numerical safety buffer is prescribed here. Part 107 emergency deviation is limited to what an actual immediate emergency requires, with a written explanation upon FAA request; it is not a planned filming authorization. 14 CFR, 107.21; 14 CFR, 107.19; 14 CFR, 89.110; 14 CFR, 89.115.

Sources: 14 CFR, 107.9; 49 CFR Part 830, 830.2; 49 CFR Part 830, 830.5; 49 CFR Part 830, 830.6; 49 CFR Part 830, 830.10; 49 CFR Part 830, 830.15; NTSB 2022 amendment to unmanned aircraft accident definition, effective August 15, 2022.

FAA GUIDANCE / SOURCE CONFLICT: AC 107-2A's NTSB discussion still contains the old 300-pound language. It is excluded from default retrieval on that point. Current §830.2 controls. FAA serious-injury guidance and NTSB's definition are separate; NTSB lists specified hospitalization, fracture, hemorrhage/nerve/muscle/tendon, organ and burn criteria. A genuine flyaway can be a flight-control failure; an expected lost-link response is not automatically such a failure. Evaluate the actual event rather than treating every video glitch as a reportable accident.

G. Non-FAA appendix

See Texas, local access and FCC for Texas statutes and judicial status, local/public-land access, FCC radio and procurement issues, workplace obligations and insurance. None is replaced by FAA authorization.

LEGAL REQUIREMENT, reporting clarification: Section 830.5(b) separately requires immediate notification when an aircraft is overdue and believed involved in an accident. The seven-day still-missing written report in §830.15(a) does not postpone that immediate duty. 49 CFR 830.5(b) and 830.15(a).

LEGAL REQUIREMENT, Part 45 marking detail: For the Part 47/45 route, review §45.21 permanence/contrast/legibility, §45.23 N-number display, rotorcraft location in §45.27(a), and §45.29 size rules including the insufficient-surface exception in (f). Section 45.22(d) permits an application for a different procedure if configuration makes compliance impossible; it is not self-authorization. Cinematography does not automatically justify removing marks under §45.22(a). 14 CFR 45.21, 45.22, 45.23, 45.27, 45.29. Selected Part 45 captures state coverage September 2, 2026; see manifest and gap review.

Role and qualification matrix

Sources: 14 CFR, 107.3; 14 CFR, 107.12; 14 CFR, 107.17; 14 CFR, 107.19; 14 CFR, 107.31; 14 CFR, 107.33; 14 CFR, 107.65; AC 107-2A, editorial update May 26 2022, 5.1-5.3 and 5.9.

Five realistic arrangements

Legal anchors: 14 CFR, 107.31; 14 CFR, 107.33; 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42095-42099. Two operators for one aircraft do not violate §107.35's multiple-aircraft rule, but a person simultaneously controlling/observing another aircraft raises it. 14 CFR, 107.35.

Capability versus exercise

LEGAL REQUIREMENT: Section 107.31(a) is the capability obligation. Section 107.31(b) says who exercises it. The RPIC and manipulator must remain able to see enough to make the required location, attitude, traffic and hazard assessments; recognizing a distant speck is not automatically enough. Corrective lenses are permitted. A zoom camera, binoculars or FPV display is not the required unaided view.

FAA GUIDANCE: A VO can exercise observation while the RPIC/operator uses a display. The current FAA overview specifically calls for a VO with FPV. The physical arrangement must preserve the ability to stop using goggles and see the aircraft; the route cannot be hidden from that position. No reviewed authority supplies a universal number of seconds to remove goggles or reacquire. AC 107-2A, editorial update May 26 2022, 5.9.1-5.9.2; FAA Part 107 overview, FPV observer guidance, Operating Requirements.

FAA GUIDANCE: Brief obstruction or glances can be acceptable only while the relevant see-and-avoid duties remain achievable. The preamble explicitly discusses rooftop/smoke examples and rejects a numerical safe interval. It does not authorize all trees/buildings, repeatable hidden sections or high-speed blind turns. PROPOSED COMPANY SOP: A planned occluded cinema route remains on hold until its particular legal and safety basis is documented. 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42095-42099.

Part 89 is a separate gate

LEGAL REQUIREMENT: For module RID, the person manipulating flight controls must be able to see the aircraft at all times throughout the operation, unless otherwise authorized. A FRIA has its own similar manipulator-visibility requirement and boundary limits. Standard RID does not add this same express module visibility sentence, but Part 107 still applies. 14 CFR, 89.110; 14 CFR, 89.115(a)(2)(ii),(b).

UNRESOLVED INTERPRETATION: We did not find a definitive primary FAA interpretation resolving the exact goggles-on/module arrangement where the operator can remove goggles. Do not claim the VO automatically satisfies the module clause. Do not claim a §107.31 waiver automatically provides §89.115 relief. The question for FAA must identify exact RID type, control operator, observer position, physical visibility and proposed goggles procedure. If the route exceeds the manipulator's sight capability, a Part 107 waiver alone plainly leaves a separate Part 89 problem.

Handoff card

The following is PROPOSED COMPANY SOP, pending equipment validation. A positive handoff can occur only within the applicable regulatory/approval limits.

1. Before takeoff, record initial RPIC, control operator, observing VO, backup and camera operator; control-station mapping; takeover capability; communication method; and failed-transfer response.
2. Before a planned transfer, outgoing pilot states aircraft position, attitude/direction, energy, mode, route, hazards and any discrepancy. Incoming qualified pilot confirms required sight, controls and readiness.
3. Outgoing: "You have aircraft control." Incoming: "I have aircraft control." Outgoing confirms. Separately state and acknowledge any RPIC designation transfer.
4. VO observation continues with explicit responsibility; a VO handoff does not extend legal sight capability.
5. Abort the transfer if acknowledgment, sight, link or control status is uncertain. Use the aircraft-specific prebriefed contingency. Do not assume automatic hover or return-home.

LEGAL REQUIREMENT: RPIC designation and direct-control capability must remain compliant throughout; these calls are a proposed implementation, not mandated FAA wording. 14 CFR, 107.12; 14 CFR, 107.19; 14 CFR, 107.31; 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42097-42098.

Evidence still needed

Certificate and recurrent-training records; actual goggles/removal/reacquisition method; unaided sight trial from the planned positions; exact control-transfer architecture; RID type/serial/DoC; radio/communications checks; route/obstructions; any active waivers and their specific clauses. A certificate photograph or a crew member's experience claim alone does not verify those facts.

Each row is conditional planning research. No row is flight authorization. Labels distinguish legal assessment from proposed company staffing/safety choices. Source dates and limits are listed in the source directory below.

S01: 54.9 lb all-in, goggles pilot + dedicated VO + camera

S02: 55.0 lb at takeoff

S03: 55.1 lb at takeoff

S04: Lens/battery change takes 54.9 to 55.1 lb

S05: Goggled pilot + camera operator continuously watching monitor

S06: Both crew members wear goggles throughout take

S07: Separate RPIC supervises uncertificated flight operator

S08: Distant VO sees aircraft behind building; control operator cannot

S09: Momentary tree occlusion with immediate reacquisition proposed

S10: Indoor take passes through door into exterior

S11: Module RID aircraft has Part 107 VLOS waiver

S12: Custom commercial build called home-built to skip RID

S13: Every actor signs release on closed set

S14: Prop guards or parachute advertised as OOP compliant

S15: Chase car with occupants on public road

S16: Pilot stands on shore tracking wakeboarder and boat

S17: Pilot controls aircraft FROM moving boat

S18: Night shoot with trained pilot but no required light

S19: LAANC approval obtained for route over uninvolved people

S20: Manufacturer or another company holds exemption

S21: Expired grant or proposed Part 108 rule appears in search

S22: Saved stadium TFR map says clear for tomorrow

S23: Unknown custom controller assumed to return home on FPV loss

S24: Certificate available; recurrent-training record missing

S25: USACE lake chosen because airspace is Class G

No application was prepared for submission, submitted or discussed with an agency. These are research pathways, not an estimate that FAA will approve the concept. UNRESOLVED INTERPRETATION applies to the unknown actual configuration; each rule/guidance basis below retains its stated conditions.

LEGAL REQUIREMENT: 14 CFR Part 107, 107.200; 14 CFR Part 107, 107.205; 14 CFR Part 107, 107.41; 49 USC 44807, Special authority for certain unmanned aircraft systems, (a)-(e); 14 CFR Part 89, 89.105. FAA GUIDANCE: Part 107 Waivers: current process; FAA Part 107 Airspace Authorizations; Special Authority for Certain Unmanned Aircraft Systems (Section 44807); FAA AIP ENR 8.3: Large civil UAS, 2.1, 3.1. FAA's published DroneZone lead-time advice is planning guidance, not a guaranteed response time or approval.

Evidence package for a concrete heavy-aircraft review

FAA GUIDANCE / PROPOSED COMPANY SOP: Build a coherent holder-specific package: legal applicant/operator identity; exact aircraft and maximum/configuration weights; proposed activities and operating environment; CONOPS; flight/emergency/checklists; pilot and VO training/currency; maintenance and configuration control; validated aircraft/link/containment performance; risk analysis and supporting flight history; camera/payload geometry; people/vehicle controls; RF basis; registration/marking/RID; requested regulatory relief; airworthiness rationale; proposed COA geography and operating limits. Identify which material is proprietary and retain it locally unless its owner authorizes an actual submission. FAA's §44807 page lists expected supporting documents and a separate CAPS COA process. Special Authority for Certain Unmanned Aircraft Systems (Section 44807).

FAA-linked blanket COA template

APPROVAL-SPECIFIC CONDITION: The seven-page August 2024 template is a real FAA-linked document, not an issued approval for the operator. It is effective only with an applicable valid §44807 exemption, is nontransferable, does not waive regulations, and describes Class G operations at or below 400 feet AGL subject to all its conditions. Its term is tied to the grant. Distances, weather, NOTAMs, RF, lost-link procedures and reports cannot be selectively borrowed. Section 44807 Blanket COA Template, August 2024, pp. 1-7.

• A.7, PDF page 2, makes spectrum/equipment suitability a material heavy-UAS review item. Do not assume Part 15 consumer FPV equipment automatically satisfies this COA language.
• Airport/heliport distance branches, applicable conditions and exceptions on pages 3-4 must be read together. Do not transpose these into universal Part 107 buffers.
• The NOTAM clause generally requires notice 24-72 hours before covered 55-plus operations, with an exception requiring less than 55 pounds AND maximum airspeed at most 100 mph/87 knots, unless the grant specifically requires a NOTAM. It is not a general Part 107 NOTAM duty.
• Monthly zero/activity reports, 24-hour event reporting and required notifications are distinct from FAA §107.9 and NTSB duties.

All of these remain approval-specific. Actual operative grant/COA and attachments must be reopened before planning an operation under them.

Public approval research register

The full contemporary approval/attachment verification remained access-limited. No listed approval is established as applicable to the operator. The first row is historical evidence with partial document review and failed repeat access. Other rows are discovery leads. None establishes current operating authority.

The next approval-research milestone is the full original of one relevant still-operative manual-control cinematography grant, every amendment and incorporated attachment, verified holder/aircraft/activities/dates and a condition-by-condition comparison. If official access remains unavailable, obtain the documents from their authorized holder before relying on them. Do not bypass access controls.

Part 108 status and alternative frameworks

UNRESOLVED INTERPRETATION, current permission not established: The current subchapter lists Parts 108-109 reserved. The September 4, 2026 TSA notice describes FAA/TSA final BVLOS rules as forthcoming. The 2025 NPRM remains a proposal in this library; proposed weight/automation provisions do not authorize this manual FPV concept. Do not substitute proposal text for an issued waiver/exemption or effective rule. 14 CFR Subchapter F: Parts 108-109 reserved; TSA September 4 2026 notice: BVLOS final rules forthcoming, Background and Participation; 2025 BVLOS Part 108 proposed rule, scope excerpt, proposed rule; selected opening text only.

Draft questions, not sent

Use the narrow questions and missing facts in Aircraft and operation intake. First choose the measured aircraft and shot envelope. A generic "Is FPV legal?" inquiry is less useful than supplying exact role/sight/RID/approval facts and identifying the clauses requiring interpretation.

APPROVAL-SPECIFIC CONDITION: The August 2024 blanket COA G.1, PDF page 6, requires return to a predetermined location within the operating area and landing after lost communications or GPS when that COA applies. F.3 includes specified lost-link/abnormal event reporting within 24 hours. The actual airframe must demonstrate compatibility with its operative approval; this does not establish generic return-home capability or direct a settings change. FAA blanket COA, PDF page 6.

DRAFT. NOT APPROVED FOR FLIGHT. All procedures below are PROPOSED COMPANY SOP unless another authority label is stated. Blank aircraft-specific fields are release blockers, not permission to improvise. The designated RPIC, qualified aircraft integrator and relevant approval holder must complete and validate them. This research did not conduct flight tests or change equipment.

1. Concept of operations and boundaries

Purpose: controlled commercial cinema work with one aircraft, usually an FPV flight-control operator, a dedicated visual observer and a separate camera/gimbal operator. A separate RPIC or backup is added when the actual supervisory/control arrangement calls for it. Start with a specific shot envelope: route, altitude band, speed envelope, flight time, people/vehicles, launch/landing and emergency areas, visibility, RF environment and weather. No approved envelope is supplied here.

The initial planning branch is a verified under-55-pound configuration under Part 107, with legally supportable visibility, people separation and compliant RID. This is a planning preference, not a finding that the candidate build qualifies. At 55 pounds or more, replace the legal basis with the exact Part 91 certification/exemption/COA package before adapting this manual. Do not mix provisions from different regimes or copy another operator's grant.

LEGAL REQUIREMENT: The RPIC decides operational safety and compliance, including no undue hazard if control is lost. Aircraft condition, preflight assessment, crew briefing, links, power and payload security must meet applicable rules. In a supervised-control arrangement, the RPIC must be able to immediately take direct control. 14 CFR Part 107, 107.12; 14 CFR Part 107, 107.19; 14 CFR Part 107, 107.15; 14 CFR Part 107, 107.49.

2. Flight-release prerequisites

No row is satisfied by this document. See Aircraft and operation intake for the intake.

3. Crew assignment and authority

Use one flight-specific assignment sheet:

Anyone may call ABORT for a perceived safety problem. The RPIC directs the aircraft response; production stops conflicting action and keeps emergency areas clear. A camera operator cannot direct the pilot to continue an unsafe take. For sustained goggles-on cinema work, keep camera operation separate from the observing VO. This staffing baseline is company SOP, not a universal three-person law.

LEGAL REQUIREMENT / FAA GUIDANCE: All required sight capability, actual observation and effective communications must be maintained. Multiple VOs cannot create unlimited range. The Part 89 module condition needs its own assessment. See Crew roles and FPV visibility; 14 CFR Part 107, 107.31; 14 CFR Part 107, 107.33; 14 CFR Part 89, 89.115.

4. Configuration and maintenance control

Maintain one controlled configuration sheet per variant:

Inspect structure, fasteners, propulsion, wiring, connectors, batteries, antennas, payload restraint and gimbal before operation using the exact manuals. Keep configuration photographs and change history. Isolate any damaged, swollen, overheated or otherwise suspect battery under the manufacturer's procedures and the site's emergency plan. Charging, transport and fire response must be reviewed for the actual chemistry and site; no generic extinguishing procedure is validated here.

After a changed battery, lens, mount, propeller, firmware, tune, RF mode, RID or safety-critical component, document its effect on weight, CG, electrical load, cooling, control, compliance and prior validation. Complete the appropriate ground review and a qualified validation plan in a separately lawful controlled environment before production use. This manual does not direct an unapproved test flight.

MANUFACTURER LIMIT: DJI RS 4 Pro and RS 5 tested gimbal payload figures are not drone payload ratings. Nikon ZR shock/vibration/temperature cautions do not certify an aerial mount. Read model/version-specific source instructions and obtain an integrator's evidence for the complete aircraft. DJI RS 4 and RS 4 Pro User Manual v1.0, v1.0, Introduction and balancing; DJI RS 5 User Manual v1.0, v1.0, balancing and safety; DJI RS 5 specifications; Nikon ZR technical cautions. Controller/airframe manuals remain missing.

5. Site plan and risk assessment

Produce a map with aircraft path and contingency paths, station locations, sight obstructions, public approaches, roads, boat routes, powerlines, antenna/magnetic/RF sources, airports/heliports and emergency access. Separate the flight envelope from the camera frame: framing a person does not require aircraft overflight. A lake is not automatically empty or sparsely populated. Account for towlines, riders, boat occupants and independent public water users.

Set exclusion boundaries and buffers from the specific failure consequences, validated stopping/recovery behavior, wind, public access, crewed traffic and applicable approval. No universal FAA stand-off or validated numerical buffer is supplied. Do not use a radius from another exemption as authority.

Record risks before rehearsal and re-evaluate changes:

Use plain low/medium/high likelihood and consequence with the rationale written out. An unknown catastrophic failure mode is unresolved, not low risk. This qualitative worksheet is a proposed review method, not a certified risk model or FAA approval.

6. Briefing, rehearsal and normal operation

Before each new route/configuration, explain role assignments, the shot and flight path, person/vehicle status, legal dependencies, launch/landing zones, emergency paths, public controls, expected modes, link-failure cues and abort calls. Confirm everyone understands the same words. Set aircraft-relative directions or a consistent map convention; avoid ambiguous "left" calls between camera and pilot.

Begin with nonflying walk-throughs and simulated communications. Any subsequent aircraft rehearsal must already satisfy the operating rules and aircraft review; a rehearsal is not an exemption. Separate stunt/boat timing from the aircraft-control decision. Establish the maximum number of takes and rest opportunities from actual personnel/conditions, without inventing a validated flight-time or fatigue limit.

For a take, production confirms protected areas and action readiness; VO confirms assigned observation and communications; camera operator confirms camera readiness; RPIC performs the flight-release assessment. Only the RPIC initiates the approved aircraft sequence. During the take the VO prioritizes aircraft/traffic awareness, the camera operator reports only actionable camera/gimbal issues, and production manages public access.

Abort or pause for an unbriefed change, public incursion, inadequate sight, conflicting crewed traffic, abnormal power/thermal/vibration/payload/link indication, lost communications, fatigue or conditions outside the reviewed envelope. Do not make a last-minute route change to save a take. On landing secure propulsion using the aircraft-specific sequence before personnel approach. Record discrepancies before the next launch.

INDUSTRY GUIDANCE: Contract Services bulletins support qualified crew, planning, briefings, authorization checks and controlled safety zones. The current main bulletin is dated May 29, 2025. Its appendix includes a historical 2016 legal comparison that cannot override current law. Safety Bulletin 36: Unmanned Aircraft Systems, pp. 1-4; Safety Bulletin 36A: FAA Regulations, 2025 main appendix, PDF pp. 1-5.

7. Abnormal and emergency response matrix

The response principles below are company SOP. Every maneuver, switch action, recovery mode and energy threshold must be completed from the exact aircraft and validated by the qualified pilot/integrator. No assumption is made that the aircraft hovers, returns home, avoids obstacles, navigates without GNSS or tolerates a motor failure. A camera-gimbal operator is not a backup aircraft pilot merely because they hold a controller.

RID authority: 14 CFR Part 89, 89.110; 14 CFR Part 89, 89.115. Crewed right-of-way: 14 CFR Part 107, 107.37. Emergency deviation is limited to an in-flight emergency requiring immediate action and only the extent needed; report in writing if FAA requests under §107.21. It is not advance permission to design a noncompliant route. 14 CFR Part 107, 107.21.

8. Event reporting and preservation

LEGAL REQUIREMENT: Under Part 107, report to FAA within 10 calendar days an operation causing serious injury or any loss of consciousness, or qualifying damage to property other than the drone. Section 107.9 excludes property events when repair (materials and labor) does not exceed $500, or total-loss fair market value does not exceed $500. Do not confuse this with NTSB's independent rules. 14 CFR Part 107, 107.9.

LEGAL REQUIREMENT: NTSB §830.5 requires immediate notification of an aircraft accident, listed serious incidents, and an overdue aircraft believed involved in an accident. Current UAS accident definition is death/serious injury, or substantial damage to an aircraft holding an airworthiness certificate; the old 300-pound threshold is obsolete. Serious incidents have their own triggers, including specified flight-control failures, in-flight fire and collisions. A routine expected lost-link event is not automatically a concluded reportable flight-control failure; establish facts without delaying a clearly required notification. 49 CFR Part 830, 830.2; 49 CFR Part 830, 830.5.

LEGAL REQUIREMENT: Written accident report is due within 10 days under §830.15; a still-missing aircraft report is due after seven days, while serious-incident written reports are submitted when requested. Seven days is not permission to delay immediate overdue-aircraft notification. Preserve wreckage, cargo, records and recorded media under §830.10, with limited exceptions for rescue, protecting wreckage from further damage, and public safety and documentation of moves. 49 CFR Part 830, 830.10; 49 CFR Part 830, 830.15.

APPROVAL-SPECIFIC CONDITION: Read actual grant/COA reporting clauses separately. The blanket 44807 template contains 24-hour event reporting and monthly activity reporting, including zero activity, for its applicable holder operations. Template text alone does not impose those obligations on every Part 107 mission. Section 44807 Blanket COA Template, August 2024, pp. 4-7.

Record: event UTC/local time; aircraft/configuration; crew; coordinates/last known path; injury/property facts; weather; control/video/RID/mode evidence; authorization IDs; witness details held privately; original logs/media; notifications with timestamps; custody and discrepancy status. Do not overwrite logs or treat edited clips as originals. Return to service only after the actual maintenance/approval conditions and qualified review are satisfied.

APPROVAL-SPECIFIC CONDITION: The August 2024 blanket COA G.1, PDF page 6, requires return to a predetermined location within the operating area and landing after lost communications or GPS when that COA applies. F.3 includes specified lost-link/abnormal event reporting within 24 hours. The actual airframe must demonstrate compatibility with its operative approval; this does not establish generic return-home capability or direct a settings change. FAA blanket COA, PDF page 6.

DRAFT: aircraft-specific review and controlled validation required. All checklist items are PROPOSED COMPANY SOP implementing the separately identified rules in the handbook. These cards do not establish numeric aircraft limits or authorize launch. Mark each item with evidence, initials and time; an unresolved required item means hold.

Card 1: before committing the shot

• [ ] Exact aircraft and payload configuration identified; measured complete takeoff weight and uncertainty recorded; correct legal regime chosen.
• [ ] Current registration/marking, RID compliance, serial/DoC or applicable alternative, FCC equipment/modes and required approval package reviewed.
• [ ] Named RPIC/control operator/VO/camera/backup; certificate and recurrent records; direct-supervision takeover capability where required.
• [ ] Route preserves each person's required unaided sight capability; active observer remains available; module RID separately resolved.
• [ ] Actual people/vehicle/boat status and OOP eligibility/waiver established. Releases and briefings are not the eligibility test.
• [ ] Property/land-manager/film/stunt/road/water access permissions; Texas privacy and facility restrictions; contract and full policy reviewed.
• [ ] Exact coordinates, date/time, altitude, duration, AGL/MSL and airspace authorization dependencies recorded.
• [ ] Integrator and RPIC have completed all aircraft-specific limits and loss-response sections of the manual.

Legal anchors: 14 CFR Part 107, 107.3, 14 CFR Part 107, 107.12, 14 CFR Part 107, 107.31, 14 CFR Part 89, 89.115, 14 CFR Part 107, 107.39, 14 CFR Part 107, 107.145. Non-FAA branches: Texas, local access and FCC.

Card 2: DFW airspace and current conditions

• [ ] Plot launch, route, crew positions, emergency landing zones and contingency envelope. Record coordinates and local/UTC times.
• [ ] Review current official chart and airport/heliport/seaplane information. Consider DFW/Dallas Love, nearby towered and untowered fields, medical/temporary heliports and military/special-use activity where relevant to the coordinates.
• [ ] Determine Class B/C/D or airport Class E surface area requirements. Check exact LAANC/DroneZone authorization, altitude/time/area, conditions and any waiver dependencies. A facility-map grid is planning data.
• [ ] Check authoritative FAA TFR and NOTAM sources for the full operation time and route, plus security/special-use/temporary emergency restrictions. Save evidence with retrieval time for the flight record, then recheck on changes.
• [ ] Screen federal sports TFRs and separate Texas stadium/critical-facility provisions. Confirm event timing and applicable exceptions rather than applying a saved map.
• [ ] Obtain current aviation weather and local site observations: visibility, clouds, wind/gusts, heat, precipitation and trends against both legal and actual equipment limits.
• [ ] Confirm airport/heliport and emergency aircraft activity, ground/boat traffic and public access controls on arrival and before each take.
• [ ] Record who performed each live check, source/time, resulting restrictions and RPIC disposition. This library cannot fill in a current clearance.

LEGAL REQUIREMENT: Part 107 groundspeed is at most 87 knots/100 mph; ordinary altitude is at most 400 feet AGL, with the specific structure exception in §107.51(b); at least three statute miles flight visibility observed from the control station, 500 feet below and 2,000 feet horizontally from clouds. These are legal ceilings/conditions, not safe aircraft performance targets. Night requires the applicable knowledge/training and anti-collision lighting; controlled airspace requires the relevant authorization. 14 CFR Part 107, 107.51; 14 CFR Part 107, 107.29; 14 CFR Part 107, 107.41; 14 CFR Part 107, 107.45; 14 CFR Part 107, 107.47.

Official starting points: FAA TFR list, FAA NOTAM Search, Aviation Weather Center, LAANC airspace authorization overview, FAA Part 107 Airspace Authorizations, FAA Stadiums and Sporting Events. Open these live for the actual mission. No location was checked or declared clear here.

Card 3: arrival, briefing and aircraft preflight

• [ ] Site walkthrough and risk sheet updated; launch/landing and emergency paths controlled; public approach monitors in place.
• [ ] Crew fitness/rest/heat exposure assessed; communications and common direction/abort language confirmed.
• [ ] Primary VO has required direct view; flight operator and RPIC retain required capability; camera duties separated from sustained observation.
• [ ] Inspect actual airframe, propulsion, fasteners, mounts, payload retention, wiring/connectors, antennas, batteries and recorded discrepancies.
• [ ] Verify exact mass/CG/loading; camera/gimbal balance, full travel, cable slack/retention, prop clearance, vibration and cooling.
• [ ] Verify aircraft, FPV, cinema, gimbal, RID and crew-radio links individually and together using approved nonhazardous procedures.
• [ ] Verify controller mode, actual lost-link behavior, energy indications/reserve plan and recovery paths against signed configuration records. No guessed settings.
• [ ] RID preflight functionality; correct identity and required broadcasts. Verify lighting if twilight/night.
• [ ] Brief each distinct loss response, takeover capability, emergency landing route, responders/site address, evidence custody and reporting owner.
• [ ] Rehearse coordination on the ground; any flight rehearsal separately satisfies all flight prerequisites.

LEGAL REQUIREMENT: §107.49 preflight and payload obligations, §107.15 safe condition, §107.33 communications and Part 89 functionality. INDUSTRY GUIDANCE: Safety Bulletin 36: Unmanned Aircraft Systems, 2025 pp. 1-4. Detailed responses: Draft operations manual.

Card 4: each take / abort

• [ ] Configuration, people, route, communications, airspace/weather and aircraft condition unchanged or reviewed again.
• [ ] Production confirms controlled areas; observing VO confirms readiness; camera operator confirms ready; RPIC makes flight decision.
• [ ] Any safety concern: call ABORT with relevant location/event. Pilot follows validated aircraft-specific response; production stops conflicting action.
• [ ] Give way to crewed aircraft. Stop the cinema task for loss of required observation/comms, intrusion or abnormal link/power/payload behavior.
• [ ] Land and secure using actual aircraft sequence; no approach while propulsion presents a hazard.
• [ ] Record take/configuration, battery and discrepancies. Repeated unexplained degradation means hold for qualified review.

Card 5: emergency and event record

• [ ] Protect life, alert emergency services if needed, secure access and provide exact site/last known aircraft position.
• [ ] Identify FPV vs camera video vs C2 vs gimbal vs GNSS vs RID vs crew-comms failure. Use only the completed aircraft-specific procedure.
• [ ] Preserve original flight/controller/video/RID/maintenance records and relevant wreckage/cargo; document necessary rescue/safety moves.
• [ ] Evaluate FAA §107.9: serious injury/any loss of consciousness or qualifying non-drone property damage; report within 10 calendar days.
• [ ] Evaluate NTSB §§830.2 and 830.5: immediate accident/listed-incident notification; immediate notification also for overdue aircraft believed involved in an accident. Do not use obsolete 300-pound language.
• [ ] Evaluate §830.15 written report: accident within 10 days; still missing after seven days; incident if requested. Do not confuse written report timing with immediate notice.
• [ ] Evaluate actual exemption/COA, insurer, employer and local reporting clauses separately. Record recipient/method/time privately.
• [ ] Quarantine unresolved discrepancies and document qualified return-to-service decision.

Sources: 14 CFR Part 107, 107.9; 49 CFR Part 830, 830.2; 49 CFR Part 830, 830.5; 49 CFR Part 830, 830.10; 49 CFR Part 830, 830.15; Section 44807 Blanket COA Template, August 2024, approval-specific only.

Texas image capture and the courts

LEGAL REQUIREMENT: Government Code §423.003 concerns capture with intent to conduct surveillance of a person or private real property. Section 423.002 supplies specific lawful-capture circumstances, including appropriate consent and public real property. Do not treat every incidental image as automatically unlawful, or invent a general commercial-cinema exception. Possession/use/disclosure and civil remedies are separate issues in §§423.004 and 423.006. A location release must cover the actual rights and intended images. Texas Government Code Chapter 423, 423.002-423.006.

LEGAL REQUIREMENT / JUDICIAL STATUS: The Fifth Circuit's substituted January 10, 2024 NPPA v. McCraw opinion rejected the facial constitutional challenges and affirmed dismissal of the preemption claim, while leaving possible as-applied defenses open. The 2022 injunction cannot be treated as a current blanket shield. Supreme Court certiorari was denied October 7, 2024, which is not a merits endorsement. No later contrary controlling primary order was found in this bounded check. NPPA v McCraw substituted Fifth Circuit opinion, PDF pp. 2 and 41; Supreme Court docket 23-1105, October 7, 2024 docket entry.

LEGAL REQUIREMENT: Section 423.0045 addresses defined critical facilities, with separate low-altitude overflight, contact and interference branches. Section 423.0046 covers qualifying sports venues with capacity at least 30,000 and has no FAA-style event-time requirement. Both include the specific FAA-compliant commercial-operation exclusion in (c)(5), along with other exceptions. Read the precise elements and all required authorizations; do not label either an unconditional statewide ban. Section 423.009 also limits local regulation subject to its exceptions. Texas Government Code Chapter 423, 423.0045, 423.0046, 423.009.

LEGAL REQUIREMENT / UNRESOLVED INTERPRETATION: Penal Code §42.15 separately addresses airports, military installations and spaceports; SB 1197's spaceport change became effective September 1, 2025. Its defenses are not identical to Chapter 423's commercial exclusion. Whether a particular FAA authorization satisfies the defense needs exact fact/document review. Ordinary Part 107 compliance should not be assumed sufficient. Texas Penal Code Chapter 42 including 42.15, 42.15; Texas SB 1197 enrolled law, spaceports amendment, sections 1-3.

SOURCE STATUS: The current Chapter 423 did not contain the proposed school §423.0047. Official HB 3662 history stopped at May 13, 2025 calendar placement. A proposed bill or a secondary 2026 summary is not enacted permission or prohibition. HB 3662 official history.

Ground access, public property and DFW lakes

FAA GUIDANCE / LEGAL REQUIREMENT: Federal flight authority does not supply land access, commercial-use permission, privacy rights or municipal traffic control. The FAA's state/local fact sheet distinguishes aviation preemption from valid local concerns including privacy and takeoff/landing or operator-location restrictions. Exact preemption disputes belong with qualified counsel. FAA State and Local Regulation of UAS fact sheet, pp. 6-7.

PROPOSED COMPANY SOP: Identify the actual owner and land manager for launch, landing, crew stations, parking, flight safety controls and emergency areas. DFW lakes can involve USACE, municipal, marina and private parcels. Do not borrow another district's process. Coordinate boat/stunt/public-road plans through the appropriate owner and production authorities. No agency or vendor was contacted.

FCC: every transmitter and mode matters

LEGAL REQUIREMENT: An amateur license does not create an ordinary paid-cinema transmission exemption. Section 97.113 restricts communications for compensation or the operator/employer's pecuniary interest, with narrow enumerated exceptions, and contains broadcast-production restrictions. A model-craft telecommand provision is not a universal video-transmitter allowance. Current 97.113 regulation, 97.113(a)(2)-(3), (b).

UNRESOLVED INTERPRETATION, official FCC guidance: FCC Advisory DA 18-581 explains drone FPV equipment authorization and the limits of amateur-only devices. A marketing label does not establish lawful frequency/power operation. Part 15 operation must comply with the actual FCC grant, US operating mode, antenna, power and emissions limits, including accepting interference and avoiding harmful interference. There is no universal "5.8 GHz at 1 watt is legal" rule. FCC drone FPV transmitter enforcement advisory DA 18-581, pp. 1-2; Current 15.5 regulation, 15.5; 47 CFR Part 15 Subpart C, §§15.201, 15.203-15.204, 15.247 and 15.249.

PROPOSED COMPANY SOP: Build an RF sheet listing every flight-control, FPV, camera-video, camera-control, telemetry, RID and crew-radio link: model, FCC ID, grant URL, firmware/region, modulation/channel/bandwidth, output/antenna configuration, authorized operating basis, interference scan, coexistence test and failure indications. Do not change power/channel/failsafe settings from this library.

APPROVAL-SPECIFIC CONDITION / UNRESOLVED INTERPRETATION: The FAA-linked August 2024 blanket 44807 COA's A.7 addresses spectrum authority and says Part 5/15 equipment lacks the protection necessary for those covered operations. Do not assume ordinary consumer FPV links satisfy an operative heavy-UAS COA, and do not generalize that template into a universal Part 107 Part 15 prohibition. Obtain written clarification using the exact control architecture and operative grant/COA. Section 44807 Blanket COA Template, August 2024, p. 2, A.7.

LEGAL REQUIREMENT / CURRENT PROCUREMENT STATUS: FCC DA 26-870 Appendix A, updated August 20, 2026, includes foreign-produced UAS and critical components in the Covered List subject to specified exceptions. This affects equipment-authorization/procurement analysis; it is not a blanket FAA flight ban on every already-acquired DJI or foreign product. The December 2025 FCC fact sheet distinguished existing authorized equipment/use from new approvals. Model-specific restrictions and later proceedings require a current check before procurement. No purchase or actual FCC grant validation was performed. FCC Covered List update DA 26-870, Appendix A, PDF pp. 7-8; FCC fact sheet on foreign UAS equipment authorization.

Workplace, insurance and contracts

LEGAL REQUIREMENT: For covered workplaces, OSHA §1910.132 requires appropriate PPE/hazard assessment and training under its applicability conditions. PPE does not turn a person into an FAA flight participant or establish aircraft OOP eligibility. A separate employer safety program must address actual propeller, battery, heat, hearing, lifting, boat and stunt hazards. Current 1910.132 regulation, 1910.132(a),(d),(f).

LEGAL REQUIREMENT, Dallas permit schedule: Dallas's published commercial-filming requirements specify CGL of at least $1 million per occurrence/$2 million annual aggregate, and $5 million per-occurrence aircraft liability for filming that includes aircraft. Item 10 preserves greater applicable requirements. This is a permit schedule, not a universal federal minimum or proof of the operator's coverage. Read the full insurance-delivery instructions as well as the policy limits. Dallas Commercial Filming Insurance Requirements, p. 1, items 4, 6, 10.

UNRESOLVED INTERPRETATION: Actual insurance policy wording is unverified. Obtain the complete aviation policy, endorsements and binder, scheduled aircraft/build and pilot terms, hull/payload interests, commercial FPV/VLOS/BVLOS exclusions, weight/configuration limits, public/participant overflight, moving boats/vehicles, night, stunts, territories and notice duties. Verify additional-insured, waiver-of-subrogation and contractual requirements against actual issuer confirmation. A generic COI is not a coverage opinion.

PROPOSED COMPANY SOP: Contract the approved shot envelope, exclusion controls, approval dependencies and RPIC abort authority. Price changes to configuration, route, people, airspace or schedule as a fresh review. Do not promise a shot whose legality or aircraft performance remains unresolved.

The project intentionally continued across the under-55 and heavier branches. UNRESOLVED INTERPRETATION covers missing facts and unresolved legal applicability. No blank below has been treated as satisfied. Verify each pilot's certificate and recurrent-training records before assigning the role.

Intake worksheet

Questions for FAA or qualified aviation counsel, drafted only

1. Under §§107.31(a)-(b) and 89.115(a)(2)(ii), does the specified broadcast-module aircraft/control-operator arrangement comply while the operator wears removable FPV goggles, given the exact physical sight capability and dedicated observer? Identify the required ability/observation standard and any written interpretation or separate Part 89 authorization needed. Do not omit the module detail. 14 CFR Part 107, 107.31; 14 CFR Part 89, 89.115.
2. For a newly produced custom aircraft intended from inception for commercial cinema, which Part 89 design/production requirements apply, and what accepted path permits its intended operational RID configuration? Identify build date/purpose, producer and whether any §89.501 exception or Part 21 alternative actually applies. 14 CFR Part 89, 89.1; 14 CFR Part 89, 89.501; 14 CFR Part 89, 89.515; 14 CFR Part 89, 89.110.
3. For the measured 55-plus aircraft and manual FPV control system, what certification/§44807/Part 91/COA and pilot qualification package applies? Which existing grant conditions or template branches, if any, fit this exact configuration? Resolve the blanket COA A.7 RF language using actual frequencies, FCC grants and link architecture. Special Authority for Certain Unmanned Aircraft Systems (Section 44807); Section 44807 Blanket COA Template, August 2024, A.7, p. 2.
4. Does the actual mounted or suspended payload create Part 133 requirements outside Part 107, and what relief/certification/operating limitations would be needed? Provide attachment geometry, release ability, load dynamics and purpose. 14 CFR Part 133, applicability and external loads, 133.1; 14 CFR Part 107, 107.49.
5. For a proposed briefly obscured route or pilot handoff, identify the exact safe/legal basis or waiver need. Include speed, obstruction duration/geometry, people, aircraft response, observation and RID. The preamble's brief-obstruction explanation is not a generic approval. 2016 Part 107 preamble: selected crew, VLOS, people and external-load interpretations, 81 FR 42095-42099.
6. Does the exact OOP/vehicle/boat shot meet a category, protection/direct-participation branch, or require a waiver? Supply full aircraft compliance evidence and actual roles, not release forms alone. 14 CFR Part 107, 107.39; 14 CFR Part 107, 107.145; 14 CFR Part 107, 107.25.

Questions for integrator / manufacturer / qualified flight pilot, drafted only

• Identify approved/validated mass, CG, mount loading and payload-retention basis for the complete aircraft, including gimbal extremes. Do any candidate component instructions prohibit or fail to address this aerial use?
• For each mode, state actual behavior after loss of FPV, C2, GNSS, RID, camera video/control, gimbal and crew communications. Which modes depend on navigation, and what direct-control/takeover method exists? Supply evidence and limitations.
• Specify lawful, safe ground checks and a separately authorized controlled validation plan, acceptance criteria, documentation and responsible reviewer. Include vibration, heat, RF masking/coexistence, transient power and battery reserve across payload variants.
• Identify all model/firmware-specific safety notices and maintenance intervals. Are source manuals compatible with the actual release? Confirm the Nikon and DJI candidates rather than treating marketing specs as integration proof.

Questions for property manager / production / counsel / insurer, drafted only

• Who controls launch/landing, route safety, crew stations and emergency areas at the exact parcel/lake/road? Which written film, public-access, USACE, park, stunt or boat conditions apply?
• What is the exact image-capture purpose and location relative to private property, critical facilities, stadiums, airports, military installations or spaceports? Apply current Texas text and controlling decisions to those facts.
• Does the actual policy and each endorsement cover this build, weight, pilot, commercial FPV technique, RID/waiver conditions, payload, night, people/vehicles/boats and stunts? Identify exclusions, warranties, permit limits and notice duties in writing.

No questions were sent. No answers, equipment settings or approval records were invented.