Filming with a Drone/UAS

Film SF - UAS/Drone Filming Policy:

All drone requests are in addition to our permit application/Use Agreement. Please send in the permit documents before or along with the drone application (details below). Permits are required for all drone flight that is on, from, within and over City property.

Film SF follows the guidelines set out by the California Film Commission. In addition, before we approve a drone film shoot, we currently have the City Administrator sign off on approval.

All materials must be delivered by email to Film SF seven (7) business days prior to the requested shoot date in order for Film SF to consider processing requests for film permits that include the use of drones, and be aware that the process will not begin until all required documentation has been submitted.

Also note that meeting all qualifications required of a Remote Pilot does not guarantee that permission to fly a small UAS over City property will be granted.  Film SF reviews applications on a case-by-case basis and consent or deny requests based on location conditions and specific agency guidelines.

The following are the steps Film SF follows for permitting a film shoot:

Documents required to be submitted (along with a permit application):

  1. UAS Form for Film Productions
  2. Detailed Flight Plan (Example)
  3. Drone Insurance (Example)
  4. Pilots License (Example)
  5. Drone Registration Certificate (Example)

Risk Management has added insurance language to our Use Agreement to cover UAS filming: (from Use Agreement)

If an Unmanned Aircraft System (UAS) is used for any purpose under this permit either directly by the Contractor or by a subcontractor to the Contractor, the Contractor shall ensure that such activity is covered by Unmanned Aircraft Systems insurance. The Contractor must submit proof of UAS insurance with an aggregate limit of at least $2,000,000. The certificate of insurance must include a separate policy endorsement showing proof of UAS coverage which at a minimum shall include coverage for damage to person and property. A second (separate) endorsement must be submitted naming the City and County of San Francisco, its officers, agents and employees as Additional Insured for this coverage. NOTE: Each of these two endorsements require a separate attachment to the certificate of insurance.

With all requests, productions and/or drone companies will also have to provide:

  • Pilot’s License (333) or Remote Pilot Certificate (107)

  • Registration certificate for each UAS used and/or listed for the production

IF THE PILOT REQUESTING A PERMIT FOR A DRONE SHOOT HAS A 333 EXEMPTION:

  • First, the FAA has to sign off on the POA (plan of action) submitted by the pilot.

  • Pilot must work within all FAA guidelines including:

    • Unmanned aircraft must weigh less than 55 lbs. (25 kg)

    • Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer. At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

    • Small unmanned aircraft may not operate over any persons not directly involved in the operation unless the proper waiver has been obtained from the FAA. 500 feet clearance must be maintained between UAS and pedestrians/vehicles not involved in the film shoot.

    • Daylight-only operations, or civil twilight (30 minutes before official sunrise to 30 minutes after official sunset, local time) with appropriate anti-collision lighting unless the proper waiver has been obtained from the FAA.

    • Must yield right-of-way to other aircraft, manned or unmanned.

    • May use visual observer (VO) but not required.

    • First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as requirement is satisfied in other ways.

    • Maximum airspeed of 100 mph (87 knots).

    • Maximum altitude of 400 feet above ground level.

    • Minimum weather visibility of 3 miles from control station.

    • No person may act as an operator or VO for more than one unmanned aircraft operation at one time.

    • No careless or reckless operations.

    • Requires preflight inspection by the operator.

  • Film SF receives a copy of the POA and works in tandem with the FAA, going over all of the plans (time, day, location, scene) with the location manager.

  • Film SF requires production to notify (leaflet) the neighborhood about the UAS filming and the street closure in the area (to ensure the 500 feet clearance from anyone not associated with the production staying clear of the UAS.)

  • SFPD is on set with production, to control the Street Closure.

  • During filming, all pedestrian and vehicular traffic is held for the duration of the shot.  This is to ensure safety for the public.

  • Once a plan has been presented, the FAA has signed off on the POA, Film SF sends a request to City Administrator for final approval.

IF THE PILOT REQUESTING A PERMIT FOR A DRONE SHOOT HAS A PART 107 REMOTE PILOT AIRMAN CERTIFICATE:

  • Production must submit proof of Part 107 Remote Pilot Airman Certificate to Film SF

  • The Pilot must work within all FAA guidelines for Part 107 Operators, including:

    • Unmanned aircraft must weigh less than 55 lbs. (25 kg)

    • Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer. At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

    • Small unmanned aircraft may not operate over any persons not directly involved in the operation of the aircraft/drone unless the proper waiver has been obtained from the FAA.

    • Daylight-only operations, or civil twilight (30 minutes before official sunrise to 30 minutes after official sunset, local time) with appropriate anti-collision lighting unless the proper waiver has been obtained from the FAA.

    • Must yield right-of-way to other aircraft, manned or unmanned.

    • May use visual observer (VO) but not required.

    • First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as requirement is satisfied in other ways.

    • Maximum airspeed of 100 mph (87 knots).

    • Maximum altitude of 400 feet above ground level.

    • Minimum weather visibility of 3 miles from control station.

    • No person may act as an operator or VO for more than one unmanned aircraft operation at one time.

    • No careless or reckless operations.

    • Requires preflight inspection by the operator

  • Film SF works with pilot/production company to clarify the action and area requested for filming. Production should provide a schematic (in lieu of a POA) that shows flight take off, flight path and landing zones. 

  • Film SF requires production to notify (leaflet) the neighborhood about the UAS filming and intermittent traffic control which may occur during filming by SFPD to ensure safety of pedestrians.

  • Film SF will determine if SFPD is required on set with production to maintain safety.

With the Part 107 Remote Pilot Airman Certificate certain rules have eased up:

  • No perimeter of clearance requirement – only rule is you cannot fly UAS directly over non-participants (see below for definitions)

  • Cannot mix and match rules – Part 107 does not apply to 333 exemptions. You have to fly under one or the other.

  • POA (Plan of action) is not required under Part 107 for submission to FAA. As long as the pilot follows all the rules under Part 107, there is no need of an approval of the POA. It may be required if requesting a waiver of a rule under Part 107.

  • Most companies with 333 exemptions will eventually operate under Part 107

  • Temporary Flight Restriction locations:  https://www.faa.gov/uas/where_to_fly/airspace_restrictions/

    • Flying UAS in and around stadiums is prohibited starting one hour before and ending one hour after the scheduled time of any of the following events:

      • Major League Baseball

      • Major League Football

      • NCAA Division One Football

      • Nascar Sprint Cup, Indy Car, and Champ Series races

    • Specifically, UAS operations are prohibited within a radius of three nautical miles of the stadium or venue 1 hour before and after an event.

AIRMAP:

Airmap is an online development tool that provides live airspace data to the public based on permits provided by Film SF.  The majority of work is done by the operator (or production) as they are responsible for downloading the app and providing real-time information on their approved drone filming.  Per the Film SF UAS Requirements, productions are required to use Airmap and disclose their flight information publicly using the app.  Instructions are provided on the UAS Filming Request Form and are also below.  The app is available at airmap.com/go/ios or airmap.com/go/android

Airmap Notice Requirements for UAS Operators:

Once UAS Operations are approved by Film SF, the UAS operator must register with AirMap to submit a digital flight notice at least 2 business days prior to the shoot. Below are the steps for this process:

  1. Download AirMap for iOS (airmap.com/go/ios) or Android (airmap.com/go/android).

  2. Create an AirMap account.

  3. Choose a username that is easily associated with your production and includes 'FilmSF'. This will identify that your use of UAS has been approved by the City. As an example, your username could be "FilmSF - AirMap Commercial". This username can be edited in the future if the UAS operator is providing services for multiple video shoots.

  4. Complete your AirMap profile with up-to-date contact information and aircraft details.

  5. In the map view, tap and hold on the location of your operation to Create a Flight.

  6. Adjust flight details as needed: flight path, altitude, and duration.

  7. Opt into sharing your flight publicly on AirMap. (This is the default setting.)

  8. Press Submit.

At the designated start time, your flight plan will be viewable to the public on FilmSF.airmap.com to ensure the safety and accountability of drones, operators, and San Francisco's citizens.

Definitions:

The term “over” refers to the flight of the small unmanned aircraft directly over any part of a person. For example, a small UAS that hovers directly over a person’s head, shoulders, or extended arms or legs would be an operation over people. Similarly, if a person is lying down, for example at a beach, an operation over that person’s torso or toes would also constitute an operation over people. An operation during which a small UAS flies over any part of any person, regardless of the dwell time, if any, over the person, would be an operation over people.

In response, the FAA clarifies that this rule allows filming of non-participants at an angle as long as the small unmanned aircraft does not fly over those non-participants. 

The term “directly participating” refers to specific personnel that the remote pilot in command has deemed to be involved with the flight operation of the small unmanned aircraft. These include the remote pilot in command, the person manipulating the controls of the small UAS (if other than the remote pilot in command), and the visual observer. These personnel also include any person who is necessary for the safety of the small UAS flight operation. For example, if a small UAS operation employs a person whose duties are to maintain a perimeter to ensure that other people do not enter the area of operation, that person would be considered a direct participant in the flight operation of the small UAS.

Due to the potential for the small unmanned aircraft to harm persons on the ground, the FAA does not consider consent or the need to do other work in the area of operation to be a sufficient mitigation of risk to allow operations over people.

The FAA will continue considering flight over people on a movie- set on a case-by-case basis through the waiver process in this rule.