Eagle-Eye Drone Service

5966 Beaver Creek Trl.

Kewadin, MI 49648

eagleeyedroneservice@gmail.com

231-360-0636

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

Eagle-Eye Drone Service writing pursuant to the FAA Modernization and Reform 

Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that 

Eagle-Eye Drone Service, an owner and operator of small unmanned aircraft 1, be 

exempted from the Federal Aviation Regulations (“FARs”) listed below so that 

Eagle-Eye Drone Service, may operate a small light weight unmanned aircraft 

system (“UAS”) commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”).

As described herein, Eagle-Eye Drone Service is experienced in testing and flying 

hobby helicopters for recreational purposes. Eagle-Eye Drone Service has added a 

hobby grade quad-copter UAS to their inventory equipped with an internal 

camera extremely high quality and a removable 4GB micro SD card. It shoots full 

HD video at 1080p/30fps and 720p/60fps with intent for aerial videography/

cinematography to enhance academic community awareness for those individuals 

and companies unfamiliar with the geographical layout of the northwest Michigan 

area, and augment real estate listing videos; following exemption and approval by 

the FAA. Thereby enhancing their academic research experience for greater 

northwest Michigan region.

I have flown small RC electric helicopters and fixed wing planes for over four (4) 

years without incident. Committed to safety with each flight. Eagle-Eye Drone 

Service exemption request would permit operation of light weight (less than 5 

1

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
lbs), unmanned (piloted by remote control) and comparatively inexpensive UAS(s) 

in tightly controlled and limited airspace.2 Predetermined in areas away from 

general public, airports, helipads and vehicular traffic for community videos, and 

within property boundaries for individual homeowner real estate listing videos/

photos. Currently, similar lightweight, remote controlled UAS's are legally 

operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. The Pilot of eagle-Eye Drone Service, has personally 

instilled safety protocols and controls3 to avoid and prevent public hazard, as well 

as manned aircraft hazards/catastrophe. This will act to further safety protocols 

exclusive to lightweight UAS's specific to real estate video and photography usage 

as recorded flight data and other information gained through permitted flight 

operations to share with the FAA through any required FAA reports to assist with 

future protocol and safety regulation.

Granting Eagle-EyeDrone Service’ request comports with the Secretary of 

Transportation’s (FAA Administrator’s) responsibilities and authority to not only 

integrate UAS's into the national airspace system, but to “...establish requirements 

for the safe operation of such aircraft systems [UAS's] in the national airspace 

system” under Section 333(c) of the Reform Act specific to the use of UAS's for 

real estate purposes. Further, Eagle-Eye Drone Service will conduct operations in 

compliance with the protocols described herein or as otherwise established by 

the FAA.

For the reasons stated below, Eagle-Eye Drone Service, respectfully request the 

grant of an exemption allowing to operate light weight, remote controlled UAS’s 

for academic community awareness to benefit/stimulate attraction to the greater 

northwest Michigan area and to enhance real estate listing videos for 

homeowners who cannot afford expensive manned aircraft for the same purpose. 

Both of which will promote local economic growth through increased 

employment and increased tax base. Both with public safety in mind by keeping 

heavier manned aircraft containing combustible fuel that that poses potential 

public hazard.

1 Appendix A - DJI Phantom Vision 2+ quad-copter Operator Manual 

2 Appendix B - Cherry Capital Airport Map area 5 mile airport radius maps

3 Appendix C - Personal Protocols and Control

2

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
I. Contact Information:

Greg MacMaster, Owner

Eagle-Eye Drone Service

Office/Mobile: (231) 360-0636 Email: eagleeyedroneservice@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal 

Regulations From Which Eagle-Eye Drone Service Requests 

Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Eagle-Eye Drone Service seeks and the 

Reason it seeks Such Relief:

Eagle-Eye Drone Service, submit this application in accordance with the Reform 

Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent Eagle-Eye Drone Service contemplated commercial 

cinematic, academic and other flight operations within the national airspace 

system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s 

interest to do so. Eagle-Eye Drone Service’s, ultra light weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and therefore the 

integration of my ultra light weight UAS is expressly contemplated by the Reform 

Act. We would like to operate the ultra light weight UAS prior to the time period 

by which the Reform Act requires the FAA to promulgate rules governing such 

craft. Thereby, providing direct experience and valuable information for formal 

regulation that can be administered uniformly to all real estate related UAS aerial 

video and photography. The Reform Act guides the Secretary in determining the 

types of UAS's that may operate safely in our national airspace system. 

Considerations include: 

The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will 

be operated near airports or heavily populated areas; and, Whether the UAS will 

be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in 

favor of an exemption for Eagle-Eye Drone Service.

3

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Our UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability. Our UAS is equipped with GPS and auto return safety technology. 

Weighing less than five (5) pounds (far below the maximum 55 pound limit); 

including camera with gimbal.

Eagle-Eye Drone Service considers safety as foremost with each flight. Our small 

unmanned aircraft is designed to hover in place via GPS and operate in less than a 

36 mph wind. For safety, stability and fear of financial loss, we will not fly in winds 

exceeding 10 mph. Built in safety systems include a GPS mode that allows our 

UAS to hover in place when radio controls are released. With three modes to 

choose from, we utilize the Smart Mode4 for aerial videography/photography. This 

is the safest, most reliable and stable mode to prevent accident and hazard. When 

pilot communication is lost UAS is designed slowly descend to point of take off. 

We do not operate the UAS near airports, Hospitals nor Police heliports, and do 

not operate near areas where general public is within fifty to one hundred 

(50-100) yards depending on location, conditions and weather. We are constantly 

on alert for any manned aircraft (Police/Medical helicopters, etc.) and prepared to 

land/abort immediately to the nearest and safest ground point should a manned 

aircraft approach my location or we suspect manned aircraft may approach near 

my location. Our UAS is capable of vertical and horizontal operations, and are 

flown only within my line of sight of the operator/pilot, as the remote control 

pilot. Utilizing battery power rather than combustible fuels, flights generally last 

between three (5) to seven (10) minutes, with an altitude under one hundred fifty 

(150) feet. 

Eagle-Eye Drone Service utilizes a fresh fully charged battery with each flight as a 

safety precaution; full flight time limit for each battery is 25 minutes as tested. We 

do not operate my UAS at or below manufacture recommend minimum charge 

levels for operation; preferring to remain well within a safe operating range to 

insure adequate communication between radio control and UAS to eliminate 

potential for crash, loss of control or hazard. Reserve batteries are at hand with 

each exercise to insure replacement for sufficient safe level of operation. We do 

not believe in taking risk that may cause a crash, that could create hazard to the

4 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, and 

safety control to return home or land in the event of communication interruption between RC transmitter and UAS. See 

Appendix A - Operator Manual.

public/property/manned aircraft, and have no desire to lose an investment. We 

have clocked numerous practice flights in remote areas as a hobbyist simulating 

flights for future commercial use to gain familiarization with the characteristics of 

4

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
this specific UAS's performance under different temperature and weather 

conditions. We also practice computerized simulated flights to maintain adequate 

skills and response reflex time. All for the sake of safety.

Eagle-Eye Drone Service is extremely cautious when operating the UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the national 

airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and 

weight of the UAS it falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. Eagle-Eye Drone Service’s UAS, used in hobby 

flight, has a demonstrable safety record and does not pose any threat to the 

general public or national security.

IV. How Eagle-Eye Drone Service’s Request Will Benefit the 

Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. 

For small budget real estate companies and average homeowners the expense of 

such aerial videography is cost prohibitive. Only large companies and high end 

Realtors or luxury homeowners can afford to absorb such expense. Depriving 

non-luxury homeowners and lower budget Realtors from a valuable marketing 

tool. 

Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS's into the national airspace system, hence the passing of 

the Reform Act. Furthermore, the Michigan Legislature passed a House 

Concurrent Resolution (HCR 16), sponsored by the owner of Eagle-Eye Drone 

Service, in December 2013. Supporting Michigan’s Advanced Aerial Systems 

Consortium as one of the test sites designated by the FAA.

http://www.legislature.mi.gov/documents/2013-2014/concurrentresolutionadopted/

House/pdf/2013-HACRH-0016.pdf 

Granting Eagle-Eye Drone Services’ exemption request furthers the public interest 

through academic/visual awareness of the geographical benefits in and around the 

greater Grand Traverse area. Our ultra light weight UAS is battery powered and 

creates no emissions that can harm the environment. The consequence of our 

ultra light weight UAS crashing is far less than a full size helicopter or fixed wing 

aircraft; which are heavy, contain combustible fuel and can cause catastrophic 

devastation to the public.

5

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
The public’s interest is furthered by minimizing ecological and crash threat by 

permitting aerial video/photo capture through the battery operated ultra light 

weight UAS's. Permitting Eagle-Eye Drone Service, to immediately fly within 

national air space furthers economic growth. Granting our exemption request 

substantially furthers the economic impact for the Grand Traverse community for 

companies looking to relocate or build in the area as well as individuals looking to 

relocate for career advancement through academic and geographical awareness. 

Both of which serve as a stimulus to the community.

V. Reasons Why Eagle-Eye Drone Service’s Exemption Will Not 

Adversely Affect Safety Or How The Exemption Will Provide a 

Level of Safety At Least Equal To Existing Rule:

Eagle-Eye Drone Service’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated, permitting Eagle-Eye Drone Service, to log more 

flight time in FAA controlled airspace, with communication with the FAA, will 

allow us to contribute to the innovation and implementation of new and novel, as 

of yet undiscovered safety protocols for Realtors that can be embraced by the 

NAR5, MAR6, and TAAR7 for development in cooperation with the FAA. In 

addition, Eagle-Eye Drone Service, submit the following representations of 

enhancements to current aerial videography and photography for real estate:

Our UAS weighs less than 4 pounds complete with a small ultra light weight high 

quality HD camera;

We only operate my UAS below 200 feet8 (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012);

• Our UAS only operate for 5-10 minutes per flight;

_______________________________

5 National Association of Realtors, http://www.realtor.org/

6 Michigan Association of Realtors, http://www.mirealtors.com/

7 Traverse Area Association of Realtors, http://www.taars.com/

8 DJI Phantom Vision 2+ quad-copter altitude ceiling is 147 feet when flown in Smart mode (see Appendix A Operator 

Manual)

• We land my UAS prior to manufacturer recommended minimum level of battery 

power;

6

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
• We pilot the UAS through remote control only by line of sight;

• The UAS has GPS a flight safety feature whereby it hovers and then slowly lands 

if communication with the remote control pilot is lost;

• We actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

• We only operate in reasonably safe environment that are strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas;

• We conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance;

• We always obtains all necessary permissions prior to operation; and,

• We have procedures in place to abort flights in the event of safety breaches or 

potential danger.

Eagle-Eye Drone Service’, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the primary 

means of aerial video and photography for community awareness and real estate. 

While the safety record of such helicopters is remarkably astounding, there has 

been local incident involving loss of life as well as extensive property damage; it is 

far safer to operate a battery powered light weight UAS.

First, the potential loss of life is diminished because UAS's carry no people on 

board and we only operates my UAS in specific areas away from mass 

populations. Second, there is no fuel on board a UAS and thus the potential for 

fire or explosions is greatly diminished.

Third, the small size and extreme maneuverability of my UAS allow Eagle-Eye 

Drone Service to remotely pilot away from and avoid hazards quickly and safely.

Lastly, given its small size and weight, even when close enough to capture amazing 

images, the UAS need not be so close to the objects they are focused on through 

the technology and use of post editing software allowing pan and zoom.

Accordingly, our UAS has been experimentally operated for familiarization/

competency and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

7

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of Eagle-Eye 

Drone Servicve’s, UAS permits exemption from Part 21 because my UAS meets 

(and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform 

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. 

Eagle-Eye Drone Service’ current and projected UAS's meet or exceed each of 

the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are 

no on board pilots or passengers, and given the size of the UAS's, this Regulation 

is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/

flight manual delineating areas of where safety can be defined.9 The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS 

utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining any 

such required certifications and registrations by the owner, Greg MacMaster

9 Appendix D - Safety/Flight Manual

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

8

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. Our UAS are, by definition, unmanned. They therefore do 

not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such small aircraft with 

dimensions smaller that minimal lettering requirement. Regardless, we will mark its 

UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its 

fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting 

me as a spotter with the UAV will see the markings. The FAA has previously issued 

exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. Eagle-Eye Drone Service, can achieve an equivalent level 

of safety as achieved by current Regulations because our UAS does not carry any 

pilots or passengers. Further, while helpful, a pilot license will not ensure remote 

control piloting skills. The risks attended to the operation of my UAS is far less 

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, 

et seq. Thus, allowing Eagle-Eye Drone Service to operate their UAS meet and 

exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 200 AGL; safely below the standard 

of 400 AGL. Eagle-Eye Drone Service, will however operate the UAS in safe areas 

away from public and traffic, providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety will 

be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections.

9

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections, except as provided in paragraph (c) of 

this section, have discrepancies repaired as prescribed in part 43 of this 

chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to Eagle-Eye Drone Service's, UAS. However, as a safety 

precaution we inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart 

H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of my UAS permits exemption from Part 21 

because Eagle-Eye Drone Service’s, UAS meets an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UAS's from the airworthiness certificate requirement 

in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. My UAS meets or exceeds each of the 

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular 

software updates and curative measures for any damaged hardware. Therefore, an 

equivalent level of safety will be achieved.

In summary, Eagle-Eye Drone Service seeks an exemption from 

the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 14 

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, 

10

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Eagle-Eye Drone Service's, small unmanned vehicle/lightweight unmanned aircraft 

vehicle in community awareness and real estate operations, and to develop 

economic platforms for real estate to enhance the experience of those seeking to 

relocate to the northwest Michigan area. Currently, area awareness and real estate 

aerial videography/photography relies primarily on the use of larger aircraft 

running on combustible fuel. Posing potential risk to the public. Granting Eagle-Eye 

Drone Service’s, request for exemption will reduce current risk levels and thereby 

enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional real estate video and 

photographic aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and 

from established air fields. Eagle-Eye Drone Service, have been informally analyzing 

flight information and will compile safety protocols and the implementation of a 

flight operations manual for real estate usage that exceeds currently accepted 

means and methods for safe flight. Formal collection of information shared with 

the FAA will enhance the FAA's internal efforts to establish protocols for 

complying with the FAA Modernization and Reform Act of 2012. There are no 

personnel on board Eagle-Eye Drone Service’s, UAS and therefore the likelihood 

of death or serious bodily injury is significantly diminished. Eagle-Eye Drone 

Service’s, operation of my UAS, weighing less than 5 pounds and traveling at lower 

speeds within limited areas will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly Eagle-Eye Drone Service, respectfully 

request that the FAA grant our exemption request and am willing to cooperate in 

sharing information to benefit the FAA, safety of manned aircraft, and the general 

public at large.

Specifics of the UAS;

UAV/UAS/UA Clarification

The UAV/UAS/UA which Eagle-Eye Drone Service, Petitioner, will be operating is 

the DJI Phantom 2 Vision +, referred hereafter as Phantom. The inherent safety 

features, sophistication, programmability, GPS navigation, return home capability, 

airport vicinity no-fly feature and restricted altitude feature, as well as 

differentiating radio frequency (rf) for aircraft controller/receiver and for the 

camera make this a much safer UAV for the purposes of this petition. This is a 

hobby grade radio controlled UAV that has the capacity for software upgrades. It 

is light, less than 3 pounds including battery and camera. Incorporated into the 

programming of the Phantom is an automatic return home feature that 

automatically directs the craft back to point of take off should communication 

with the transmitter be lost. The Phantom has a cruising speed of 20 mph, with a 

11

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
maximum speed of 36 mph. Maximum flight time is 25 minutes. Gross weight is 

2.86 pounds.

The Phantom has an additional communication link between the camera and craft 

on a different rf for a smart phone connection. Allowing the operator or Pilot In 

Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle.

The software for the Phantom allows the operator or PIC to set maximum 

altitude AGL for each flight, allowing customization of flights to no higher than 100 

feet, 150 feet, or 250 feet AGL as an examples. The 400 foot maximum AGL can be 

programmed into the UAV's software pre-flight to insure compliance with FAA 

standards. Adding to the safety capabilities of this UAV. This UAV is programmed 

to remain in position when controls are released. Maintaining altitude and GPS 

location.

The Phantom has an altitude and radar monitoring function that allows the 

operator more precise determination of height, direction of flight and distance 

from the operator PIC. The operator or PIC can monitor GPS lock status while 

UAV is in flight, with the ability to anticipate loss of GPS locking so the operator 

or PIC can land the UAV as a precaution.

Best explanation of the Phantom's sophistication and capabilities can be observed 

through a series of manufacture videos explaining the Phantom 2 Vision + through 

this link ( http://www.dji.com/product/phantom-2-vision-plus ). The Phantom 2 

Vision + maintains all capabilities defined in the video.

The DJI Phantom 2 Vision +'s 2.4 ghz transmitter/controller/receiver rf for 

managing flight with a 5.8 ghz rf transmitter/receiver for video/photography 

functions eliminates the rf conflict experienced with the Blade 350 QX, and is by 

far the safer of the two when considering public and NAS safety. Considering the 

programmability and safety features of this UAV (Phantom 2 Vision +), it serves as 

the best option to protect the Public and NAS for the purposes of this petition.

The Eagle-Eye Drone Service Petition is for UAV operation without pilot, 

passengers nor property on board. Considering that the Phantom UAV is a 

sophisticated hobby grade quad-copter with gross weight less than 3 pounds. 

Aerial video/photography operations for this petition provide service for those 

businesses, transferees, retirees and others considering relocating to greater 

northwest Michigan region who are not familiar with geographical characteristic, 

communities, services and other benefits of the area. Aerial video/photography 

operations for private property owners aide with an enhanced perspective for 

12

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
characteristics, amenities, and benefits a private property has that cannot be 

displayed through ground level video/photography. Petitioner Eagle-Eye Drone 

Service charges no additional fees for ground level video/photography. Therefore, 

there is no compensation for these services. Aerial video/photography represent a 

small portion of videos and photos currently offered at ground level for the 

community as well as private properties marketed for sale. Aerial video/

photography is an enhancement to videos/photography already offered 

homeowners and the public. In most cases aerial video will represent 4-20 

seconds of a 2-3 minute video.

Petitioner Eagle-Eye Drone Service is using a UAV that has the capability for taking 

off and landing at a single point, identical to a helicopter. There are no runways, 

aided take off apparatuses, nor routes that need to be flown to areas being aerial 

video recorded or photographed. Allowing a reduced and more confined area of 

flight.

Home owner written consent for aerial video/photography shall be obtained prior 

to flight. Signs (See Appendix E) will be posted cautioning anyone within vicinity to 

remain back a minimum of 200 feet. Observer(s) to assist and warn/advise the PIC 

will be utilized in situations where spectators may be within 500 feet of the flight 

area.

To alleviate additional privacy concerns, petitioner also has the ability to cover up 

areas in movie post-production by shading out objects (people/buildings) in the 

immediate vicinity. 

The single UAV utilized in this petition is a hobby grade quad-copter that does not 

require an airman certificate for non-commercial flight involving less restrictive 

less regulated flight. UAV flight competency can be verified/obtained through AMA 

standards and procedures as well as downloading the flight data from the on 

board data logger.

The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized 

in this petition are not complicated. Engineering and design allows layman 

maintenance. Recording part replacement for this UAV may prove redundant due 

to the simplicity of the craft. While the Petitioner requests waiver or exemption 

for maintenance records, it would be understandable if the FAA requires such data 

for its rule making process. However, pre-flight inspection for cracks, damage or 

other physical conditions that could hamper safe flight is a reasonable expectation. 

As well as post flight inspection that may aid in identifying flight conditions that 

may cause stress to propellers, landing gear, etc. 

13

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Thorough inspection of UAV shall be conducted and flight response tested should 

a hard landing or crash occur. Insuring that the UAV can operate in a safe manner 

before conducting any further video/photography.

Petitioner requests waiver or exemption for markings due to the small size of the 

fuselage for the Phantom 2 Vision +.

Petitioner requests modification, waiver or exemption and clarification (within 

reason) concerning section 91.119 prohibition of flight in congested areas. Such 

restriction puts home owners in subdivisions at a disadvantage by limiting 

enhanced marketing of their homes; thereby discriminating against them. Vertical 

takeoff and landing while video recording or photographing a home can allow an 

enhanced perspective for view or proximity of mountains, golf course, manmade 

lake or other attractions not possible through ground level video recording or 

photography. Petitioner requests waiver for this condition to allow reasonable and 

responsible aerial video/photography in congested areas of subdivisions and 

neighborhoods. In cases where altitude within airports is an issue, aerial video can 

be achieved under 100 feet.

In compliance with Section 90.151 (a) the Phantom is a battery operated UAV/

UAS with battery level monitoring capability. Fully charged battery flight time is 

rated at 25 minutes, with videos/photos taking much less time to record. 

Operator or PIC is warned when battery level is low.

Petitioner requests waiver/exemption from Section 91.203 (a) since the Phantom 

is a hobby grade UAV/UAS that should not require an airworthiness certificate 

nor a registration certificate. Posting of special flight authorization would not be 

possible since the Phantom has no cabin and is not large enough to carry a 

certificate. However, a special flight authorization can be maintained by the 

operator to make available upon request.

DJI Phantom 2 Vision +

Serial Number: PH645350820

1  Height limitation set for maximum of 300 feet AGL 

2  Radius distance from controller set for maximum of 1000 feet 

3  Both to aid in VLOS 

4  Flight testing at the R/C air park has proven that due to UAS 

size of the Phantom 2 Vision +, firmware programmed for maximum 300 

14

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
feet AGL and 1000 distance are limited distance for maintaining VSOL 

without assistance of binoculars or other assistance. Most intended 

operation will only requires range of 20-100 AGL and less than 200 feet 

lateral distance from PIC. Limited stated distance for VSOL will be rare if 

ever needed. 

Current firmware upgrades for 

5  Main Controller 

6  GPS 

7  Receiver 

8  Battery 

9  Zen IMU 

Airman Certification: 

Petitioner has been a private pilot for 34 years and is aware of FAA flight 

regulations.

Petitioner would like to seek a reasonable exemption with restriction solely to 

UAS operation at AGL below 300 feet with distance of flight no greater than 1000 

feet. Currently there are no provisions within the FAA for governing UAS such as 

the DJI Phantom 2 Vision + for hobby or commercial use in northern Michigan 

With Phantom 2 Vision + alone sales have been "...exponentially higher than the 

7,500 in 5 years estimate that the FAA put forward a year ago..." UAS potentially 

being flown without guidelines by unfamiliar, untrained individuals not belonging to 

professional organization like the AMA, who pose a threat to NAS, the public and 

responsible parties like the Petitioner. 

Respectfully submitted,

Greg MacMaster

Eagle-Eye Drone Service

5966 Beaver Creek Trail, Kewadin, MI 49648

15

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
PHANTOM Flying Flowchart V1.0 (Simplified Version)

16

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Appendix A

DJI Phantom Vision 2+ Owners Manual in PDF

http://download.dji-innovations.com/downloads/phantom_2_vision_plus/en/

Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf

Instead of inserting pdf into this document, link 

is provided for immediate viewing and 

download.

17

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Appendix B

Cherry Capital Airport Vicinity and 5NM Circle

18

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Appendix C

Protocols and Controls

Aerial Community and Real Estate Videos

Safety for public on the ground as well as manned aircraft above is an 

essential and utmost consideration for aerial videos and photography. As 

such, safety protocols and controls must be implemented through pre-flight 

preparation and during flight.

Pre-Flight Protocol:

Check batteries with voltage meter to insure fully charged and ready for use.

Inspect batteries for damage or leakage that may affect proper operation.

Inspect propellers for cracks, chips or damage that may cause sudden loss of 

propulsion or unmanageable/uncontrolled flight.

Check weather forecasts for wind advisory or other conditions that my impact 

flight.

Consult five (5) mile radius map for airport vicinity.

o Contact respective airport to advise of estimated flight time, estimated 

flight duration, estimated elevation of flight, and any other pertinent 

information.

Inspect flight area for

o vicinity of public safety helipads/heliports

o vicinity of medical helipads/heliports

o vicinity of light poles

o vicinity or utility wires

o vicinity of trees

o flocks of birds that may cause interference and potential flight impact

o vicinity of any elevated obstructions that may pose potential flight hazard 

o vicinity of roadways with moderate to heavy traffic that can be distracted 

o public gatherings that may attract viewers

o optional point of control for best visual site of UAS while in flight

19

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Takeoff and landing

o inspect area for best and safest point of takeoff and landing

o if in a subdivision or area that is within 150 feet of a residential street, post 

warning sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain 

Back 150 Feet "

Flight Protocol:

takeoff and land from same location

remain alert to birds, sound or aircraft, curious public, and approaching 

vehicles do not allow anyone to engage in conversation or distract the remote 

control pilot restrict flight to minimal elevation sufficient to acquire desired 

results

remained prepared for emergency landing at all times

pay attention to flight time

o if possible set a timer as a safety alert

land UAS and shut down propulsion immediately following landing

Aerial Community and Real Estate Videos

Post flight:

Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

o manned aircraft is heard or seen in vicinity of flight

o there is a public gathering within established safety boundary wanting to 

observe flight o pilot is being distracted from focusing on flight and safety

o sudden change in weather (wind bursts)

o sudden increase in vehicular traffic in vicinity of flight

o birds enter into proximity of flight

o any sudden unsafe event that can cause collision, distraction or 

interruption of control

20

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Appendix D

Safety Flight Manual

Checklist Format

(See next page)

21

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
22

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition
Appendix E

Caution Placard

23

Eagle-Eye Drone Service, Kewadin, MI - Section 333 Exemption Petition