Michigan Aerial Videos, LLC

6186 Tanager Court

Kalamazoo, MI 49009

Info@michiganaerialvideos.com

April 3, 2015

U. S. Department of Transportation Docket 

Management System 1200 New Jersey Ave., 

SE Washington, DC 20590 

Re: Request for Exemption Per PL 112-95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 

CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

With that preface, pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

("FMRA") and 14 C.F.R. Part 11, Michigan Aerial Videos, LLC , developer and operator of Small 

Unmanned Aerial Vehicles ("SUAVS") equipped to conduct aerial photography/Inspection/ included 

but not limited to the following Commercial Operations:

• Real Estate listings

• Yacht brokerage/listings

• Private events: weddings, parties, etc ...

• Commercials/promotions for businesses, communities, golf courses, marinas, resorts, etc.

• Agriculture: imaging for crop health and/or production estimates

• Private land owners: pictures/video of their property

• As needed/requested to support law enforcement and/or first responders

Petitioner hereby applies for an exemption from the listed Federal Aviation Regulations

("FARs") to allow commercial operation of its SUAVs, so long as such operations are

conducted within and under the conditions outlined herein or as may be established by the

FAA as required by Section 333.

Please consider this a request for an exemption of the above applicable sections of title 14 CFR for 

Michigan Aerial Videos, LLC for the purpose of conducting commercial aerial survey and photography 

operations with its small Unmanned Aircraft System (sUAS) within controlled access airspace

employing a comprehensive safety, training, and planning program. The employment of sUAS 

platforms for these missions should provide the FAA with good cause to find that these operations 

enhance safety by eliminating the need to use conventional aircraft in the sometimes unique 

environments where an sUAS would be particularly adept, but a conventional aircraft may pose a 

hazard to its crew and those on the ground. 
Michigan Aerial Videos, LLC requests exemption from the following applicable regulations, pursuant 

to the Administrator’s authority to grant exemptions contained in 49 U.S.C. § 106(f), 40113, and 

44701: 

14 CFR 21 Part H

14 CFR 61.113(a) and (b), 

14 CFR 91.103, 

14 CFR 91.109, 

14 CFR 91.119, 

14 CFR 91.121,

14 CFR 91.151(a), 

14 CFR 91.405(a), 

14 CFR 91.407(a)(1), 

14 CFR 91.409(a)(2), 

14 CFR 91.417(a) and (b) 

OPERATION OVERVIEW 

Our operations utilize sUAS in a manner that provides services not offered by manned aircraft or 

enhances the level of safety at which the tasks can be completed in manned aircraft 

Examples of the proposed aerial photography operations include both real estate and insurance 

damage assessment. Both operations restrict the use of the sUAS to a small area typically 

encompassing a limited number of residential and commercial properties at a time. The areas in which 

the flight takes place can readily be protected with secured access by the staff of Michigan Aerial 

Videos. The structures on these properties provided sufficient protection from the sUAS and can be 

completed with much less risk than what would be assumed in a manned operation at low altitudes

with flammable fuel. 

Our intended film production operation would typically include both photography and videography 

for commercial purposes including real estate development and private events as well as promotional 

video and commercial production for businesses. These events are restricted to only the invited 

participants and are closed to the general public, providing the opportunity to operate only in an area 

where informed, consenting participants and personnel are present. By adhering to the restrictions 

and exemptions previously granted by the FAA Michigan Aerial Videos, LLC will be able to provide a 

level of safety equal to or greater than the manned aircraft that would typically provide these 

services. 

Our survey operation includes the orthomosaic mapping of both agriculture and construction sites 

utilizing our sUAS rotorcraft flying pre-programmed grids that can be interrupted and returned to a 

safe landing zone by our FAA certified pilots at any time. Currently these operations are executed by 
general aviation aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes and 

speeds. Our operation would greatly increase the level of safety, replacing large aircraft with an sUAS 

under 35 pounds and restricted to speeds no greater than 50 knots. These sites are areas that can 

readily be secured by Michigan Aerial Videos personnel and would not provide any additional risk to 

the general public. 

These operations are similar to those of Aerius Flight whom the FAA granted exemption number

11240 under the regulatory docket no. FAA-2014-0894. This is similar in all material respects to 

relief previously reguested in Grand of Exemptions Nos 11062,011109, 1112, and 11213.

All of Michigan Aerial Videos, LLC operations will be performed by FAA licensed pilots with trained 

Visual Observers and, where necessary, Site Security Coordinators, in controlled and secured 

environments only after a safety assessment has been completed and risk mitigation practices 

reviewed

1 Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer and based 

on results of the safety assessment may include a security coordinator 

2 sUAS pilot will must possess the appropriate airman certificate as prescribed by 14 CFR part 61

and a third class medical. 

3 The UAS will only operate within a confined Flight Area

4 A briefing will be conducted in regard to the planned sUAS operations prior to each day’s 

production activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

5 The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office. 

6 The operator will obtain the consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 20 feet of the flight operation. This radius may be reduced 

further based upon an equivalent level of safety determination with the advanced permission of the 

relevant FSDO. 

7 Pilot and observer will have been trained in operation of UAS generally and received 

up-to-date information on the particular UAS to be operated.

8 Observer and pilot will at all times be able to communicate by voice 

9 All required permissions and permits that are required will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

10 If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return 

to a pre-determined location within the Security Perimeter and land. 

11 The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 
AIRCRAFT 

Michigan Aerial Videos, LLC will operate variations of the four-rotor DJI Phantom Vision+, DJI Phantom 

Vision, and the DJI Inspire which are commercially available off-the-shelf sUAS. The sUAS are 

rotocopter configuration and will weigh no more than 35 pounds. They will operate no faster than 50 

knots groundspeed. The aircraft are agile, having the ability to hover, and move about its three axes 

simultaneously. The aircraft will be operated below 400 feet Above Ground Level (AGL) and 

continuously within the Pilot in Command’s (PIC) line of sight, so as to not create a hazard to users of 

the national airspace system or public. The aircraft are equipped with failsafe protocols that return 

the aircraft to a predetermined point and land if any abnormalities are present. Because of the sUAS’ 

specifications and flight characteristics, it poses no threat to national security. 

These limitations and conditions that Michigan Aerial Videos, LLC agrees to be bound to 

include: 

1 The sUAS will weigh less than 35 lbs. 

2 Flights will be operated within line of sight of a pilot and/or observer. 

3 Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 

4 Flights will be operated at an altitude of no more than 400 feet AGL. 

AIRWORTHINESS CERTIFICATION 

Manned aircraft conducting aerial photography operations can weigh thousands of pounds or more 

and are operated by an onboard pilot and may carry other onboard crewmembers, as well as carry 

large quantities of fuel. The petitioner’s unmanned aircraft (UA) weighs less than 8 pounds, including 

payload. The pilot and crew will be remotely located from the aircraft. The limited weight and 

construction reduces the potential for harm to persons or damage to property in the event of an 

incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated 

with the use of a UAS for the proposed operation.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The UA 

carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is 

eliminated.

The petitioner’s UAS has the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses a failsafe mode to return to home and land when connection is lost. 

The UAS is also able to respond to a loss of the global positioning system (GPS) or a lost-link event 

with pre-coordinated automated flight maneuvers. These safety features provide an equivalent level 

of safety compared to a manned aircraft holding a restricted airworthiness certificate performing a 

similar operation.
FLIGHT CREW 

Flight Crew (14 CFR 61.113 (a) and (b)) Prior to flight, the PIC and Visual Observer (VO) (“flight crew”) 

will have completed the qualification process as outlined in the operator’s manual. The Pilot in 

Command will possess the appropriate airman certificate as prescribed by 14 CFR part 61 and a third 

class medical certificate and meet applicable recent flight experience requirements. The Visual 

Observer will be trained in accordance with the company’s Flight Operations Manual and will undergo 

routine competency checks. 

PREFLIGHT ACTION 

In accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather briefing, survey the 

launch and recovery environments and review takeoff and landing distances and other applicable 

aircraft performance data, check the aircraft and ground station/transmitter battery levels, and brief 

the Visual Observer (VO) and any other supporting crew on the mission, safety, and contingencies. All 

flights will be conducted in Day VMC conditions. Minimum flight crew shall include the PIC, Visual 

Observer to assist with seeing-and-avoiding other aircraft, a Site Security Coordinator as determined 

by preflight risk analysis. 

FLIGHT INSTRUCTION 

Flight Instruction (14 CFR 91.109), No pilot or passengers will be carried aboard. 

MINIMUM SAFE ALTITUDES Michigan Aerial Videos, LLC requests authority to operate at altitudes 

up to but not exceeding 400 feet AGL within a specifically defined, controlled, restricted perimeter 

per 14 CFR 91.119. Michigan Aerial Videos, LLC will establish and maintain a security perimeter for 

the purpose of protecting structures and people not associated with the operation. In establishing 

the security perimeter, Michigan Aerial Videos, LLC will receive the permission of the owner of the 

property upon which the ground crew will stage and above which the aircraft will operate, and at 

no time will the sUAS be operated directly over a person. Should the flight take place over public 

lands, Michigan Aerial Videos LLC will obtain the permission of the governing body of jurisdiction. 

Obtaining permission to operate will serve as notification to the property owner or governing body 

that operations will be taking place. The sUAS will be continuously operated at an altitude which 

will allow a safe descent and recovery should a mechanical issue arise. 

ALTIMETER SETTING 

The sUAS does not have a barometric altimeter but does have a GPS altimeter. In meeting 14 CFR 

91.121, an equivalent level of safety provided is by preflight action where the PIC will compare the 

GPS altimeter with the MSL altitude of the safe operating perimeter as ascertained by applicable 

aeronautical and topographical charts and make an calibration as necessary. 

FUEL REQUIREMENTS 
Michigan Aerial Videos, LLC seeks exemption from 14 CFR 91.151(a). The sUAS is powered by a 

battery, which provides unto 30 minutes of powered flight. Because of the absence of flammable 

operating fluids, an sUAS would not pose the same level of risk as a conventional aircraft. All 

participants in safe operating perimeter have been informed and educated, and have indicated 

consent. All Michigan Aerial Videos, LLC PICs will terminate flights when remaining battery power level 

reaches 25%. 

sUAS MAINTENANCE 

Michigan Aerial Videos, LLC requests exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 

91.409(a)(2), 14 CFR 91.417(a) and (b). The sUAS does not have an airworthiness certificate. Michigan 

Aerial Videos, LLC will conduct all maintenance on the sUAS in accordance with the flight operations 

manual. All maintenance will be conducted by a trained Michigan Aerial Videos, LLC associate. 

Because of relatively small operating perimeter, any mechanical issues that may arise during flight 

could be quickly mitigated by terminating the flight. 

PRIVACY

All applicable laws and regulations regarding privacy will be adhered to. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of 

sight and national security) provide more than adequate justification to grant Michigan Aerial Videos, 

LLCs requested exemption, allowing for Michigan Aerial Videos, LLC’s UAS commercial operations for 

the purpose of photography, film and survey pursuant to the confidential Flight Operations Manual

included herewith. 

Sincerely, 

Ryan Boucher

President - Michigan Aerial Videos, LLC