6/15/15 

June 15th, 2015 

by/for: Michael J Germond 

Owner/MGRM 

Orlando Steadicam LLC 

dba: Orlando Drones 

Contact Information: 

Phone: 616-581-2274 

Page 1 of 9 

Email: mike@orlandosteadicam.com 

www. OrlandoSteadicam .com 

Request for Section 333 Exemption 

Purpose: Closed set filming of motion pictures, music videos, web videos, 

corporate videos, television programs and commercials, and still photography 

This document constitutes an exemption Request under Section 333 of the FAA 

Modernization and Reform Act of 2012 for Aviation Unmanned to perform closed 

set filming of motion pictures, music videos, web videos, corporate videos, 

television programs and commercials, and still photography by/for Michael J 

Germond of Orlando Steadicam LLC, dba Orlando Drones. The main use of this 

UAS would be for aerial photography/videography and photogrammetry. The 

UAS systems that I plan to use include a DJIInspire 1 Quadcopter and a Kraken 

K130 Octocopter referenced in this document and also in the attached user 

manuals. 

BACKGROUND AND COMPANY DESCRIPTION 

Orlando Steadicam LLC was established on 1/3/13 in the State of Florida. 

Michael J Germond is the sole Owner and Manager/Member of this company, 

and has been operating this company as a Sole Proprietor since 2008. The 

purpose of this company is to provide Stabilized Camera Support equipment to 

the Motion Picture and Television industry to be used in the production of Film, 

Television, Commercials, Music Videos, Corporate Events, and to enhance 

listings in the Real Estate industry. Orlando Drones (dba) is the name under 

which Orlando Steadicam LLC wishes to operate our Aerial Photography and 

Videography business to expand upon our long tradition of providing safe, expert 

camera stabilization to enhance the Motion Picture and Television industry. 

Orlando Drones seeks to provide high quality imagery, dynamic footage 

previously unattainable due to size and dangers of working with full sized 

rotorcraft, and an exceptionally safe working environment for Film and Television 

productions in the United States. Our clients may include but are not limited to 

Golf Courses, Real Estate agents, Automotive Manufacturers and Dealerships, 

Theme Parks, Hotels, Film Production Studios, and a variety of Commercial and 

Corporate clients. We believe that UAS is the safest and most economical 

method of obtaining photo and video for these clients who have previously used 

heavy rotorcraft or fixed wing containing explosive fuel and carrying civilians. The 
6/15/15 Page 2 of 9 

exemptions described herein would allow us to provide similar or better quality 

photo and video with the best Public Interest in mind. 

THE UNMANNED AIRCRAFT (UA) 

DJIInspire 1 Quadcopter 

DJIInspire 1 airframe 

o Professional grade Carbon Fiber airframe 

o Dimensions: 43.8cm x 45.1 em x 30.1cm 

o All Up Weight (AUW): under 3.2 kg 

o Motors: 4 DJI 3510 350KV motors 

• Max thrust: 8.4 kg 

o Retractable landing gear 

o Support for (1) 5700mAh Lithium Polymer battery 

o Average Flight Time: 18 min 

DJI Inspire Flight Controller (FC) 

o Max Angular Velocity 

• Pitch: 300 deg/s 

• Yaw: 150 deg/s 

o Max Ascent Speed: 5 m/s 

o Max Descent Speed: 4 m/s 

o Max Ground Speed: 22 m/s 

o Built in DJI Lightbridge 2.4ghz Video/Remote Control wireless 

link (FCC licensed) 

Safety Features 

o Global Positioning System (GPS) 

• GPS Hovering Accuracy 

• Vertical: 0.5 m 

• Horizontal: 2.5 m 

• Records GPS Home Point upon takeoff 

o Vision Positioning System (VPS) 

• Utilizes sonic waves to hold aircraft position close to the 

ground 

• Automatically deploys landing gear close to the ground 

during normal flight or in the event one of the FaiiSafes is 

triggered 

o Go-Hom.e button 

• PIC can manually trigger "Return to Home" where the 

aircraft will ascend to a safe pre determined altitude and 

return to the launch point to land 

• VPS will deploy landing gear and automatically land the 

aircraft 

o Low Voltage FailSafe 

• Calculates remaining battery life based on current motor 

loads and computes time required to fly home and land 

before battery depletion 
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• Aircraft will follow the RTH procedures detailed above in 

the event of a Low Voltage warning 

o Remote Control lost-link FailSafe 

• Aircraft will follow the RTH procedures detailed above in 

the event of aRC Link Loss 

o Data logging 

• On board data logging system records flight details for 

aircraft diagnostics 

o Dynamic Home Point 

• GPS in the PIC's Remote Control can be used for the 

RTH procedure in the event that the landing location 

moves (ie. filming with boats or cars) 

Kraken K130 Octocopter 

K130 Custom Airframe 

o Heavy duty Aluminum and Carbon Fiber frame 

o Dimensions: 179cm x 179cm x 64cm 

o Maximum All Up Weight (AUW): 20 kg 

o Motors: 8 T -Motor U7 420KV motors 

• Max Thrust: 30 kg 

• Waterproof, Dirt Resistant 

o Retractable landing gear 

o Support for (2) 16,000mAh Lithium Polymer batteries 

o Average Flight Time: 12 min 

DJI A2 Professional Flight Controller (FC) 

o Max Angular Velocity: 150 deg/s 

o Ascent/Descent: 6 m/s 

o Max Ground Speed: 22 m/s 

o Built in 2.4ghz FASST Remote Control receiver (FCC licensed) 

o 1.2ghz Wireless Video transmitter (FCC licensed) 

Safety Features 

o Global Positioning System (GPS) 

• GPS Hovering Accuracy 

• Vertical: 0.5 m 

• Horizontal: 1.5 m 

• Records GPS Home Point upon startup 

o Go-Home button 

• PIC can manually trigger "Return to Home" where the 

aircraft will ascend to a safe pre determined altitude and 

return to the launch point to land 

• FC will deploy landing gear and automatically land the 

aircraft in the event a FailSafe is triggered 

o Low Voltage FailSafe 

• Dual level Low Voltage FailSafe alerts the PIC of a 30% 

battery remaining condition 
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• When the FC determines 1 0% battery remaining, 

the Aircraft will follow the RTH procedures detailed 

above 

o Remote Control lost-link FailSafe 

• Aircraft will follow the RTH procedures detailed above in 

the event of aRC Link Loss 

o Data logging 

• On board data logging system records flight details for 

aircraft diagnostics 

GROUND STATION EQUIPMENT 

- The OJ I Inspire 1 ground station is comprised of 2 Remote Controls via 

the 2.4ghz (FCC licensed) combined Video/RC wireless link 

o Primary controller is for the Pilot in Command (PIC) 

• Operates the Aircraft pitch, roll, yaw, and altitude 

• iPad Mini 2 on controller displays 4k HD video camera 

output shared with Camera Operator (CO) 

• Telemetry overlay displays speed, altitude, pitch/roll/yaw, 

GPS location, Home Point location, GPS satellites 

connected, battery life, strength of RC Link, strength of 

H D video link 

o Secondary controller (optional) is for the Camera Operator (CO) 

• Operates the camera gimbal and does not affect aircraft 

control 

• iPad Mini 2 on controller displays 4k HD video camera 

output 

• Telemetry overlay displays camera information as well as 

duplicates all PIC information 

- The Kraken K130 ground station is comprised of 2 Remote Controls 

o Primary controller is for the Pilot in Command (PIC) 

• 2.4ghz (FCC licensed) frequency 

• Operates the Aircraft pitch, roll, yaw, and altitude 

• 1.2ghz Video Receiver displays 480i Standard Definition 

(SO) video with Telemetry overlay from the First Person 

View (FPV) camera locked on the nose of the Aircraft 

• Telemetry displayed includes speed, altitude, 

pitch/roll/yaw, GPS location, Home Point location, 

GPS satellites connected, battery life 

o Secondary controller (optional) is for the Camera Operator (CO) 

• 2.4ghz (FCC licensed) frequency 

• Operates the camera gimbal and does not affect aircraft 

control 

• 5ghz Video Receiver displays 1 080P High Definition (HD) 

video from the Movie Camera 
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GROUND CREW 

Pilot in Command (PIC) 

Camera Operator (optional). The Camera operator controls the camera 

onboard the aircraft for photography and videography miss ions 

o For photogrammetry missions, the camera is locked in a fixed 

position and the Camera Operator is not necessary 

- Visual Observer (VO). The visual observer will provide additional 

situational awareness during flight operations 

OPERATIONAL PARAMETERS 

1. Neither UAS will exceed 551bs 

2. Flights will be operated within visual line of sight of the PIC and VO 

3. Maximum total flight time for both UAS shall not exceed 30 minutes 

flight time 

4. Flights for both UAS will be manually terminated at 30% battery 

remaining by the PIC, although FaiiSafes are in place to prevent 

batteries from being depleted in the event of an emergency 

5. Flights will be operated at an altitude of no more than 400 feet Above 

Ground Level (AGL) 

6. Minimum crew for each operation will consist of the PIC and the VO 

7. The PIC for all missions shall be Michael J Germond, Owner/MGRM of 

the company requesting exemption (Orlando Steadicam LLC) 

8. The PIC shall have logged at minimum 50 flight hours with each of the 

UAS Aircraft requested in this exemption 

9. The PIC and VO shall be in Vocal or Radio Communication range of 

each other any time the UAS is in the air 

1 0. The UAS will only be operated during daytime hours in VFR weather 

conditions 

11 . Written and/or oral permission will be obtained from the property owner 

12.AII "No Fly Zones" shall be observed and avoided unless expressly 

granted by a COA 

a. 5 nautical miles (NM) from an airport having an operational 

control tower; or 

b. 3 NM from an airport with a published instrument flight 

procedure, but not an operational tower; or 

c. 2 NM from an airport without a published instrument flight 

procedure or an operational tower; or 

d. 2 NM from a heliport with a published instrument flight 

procedure 

13. Maximum ground speed of 50mph 

PRE-FLIGHT CHECKLIST 

1. Weather conditions are suitable for VFR flight and wind is 15m ph or 

less 

2. Measure battery voltage of Aircraft and UAS to make sure batteries are 

sufficiently charged before takeoff 
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3. Ensure all motor arms are extended and locked in their flight position 

4. Attach all propellers and check that they are secure, free from dirt, 

cracks, and chips 

5. Verify all wiring connections are tight on the UAS and Groundstation 

6. Power up all Groundstation equipment 

7. Power up the RC Transmitters and ensure all switches are in their 

takeoff positions 

a. K 130: all switches down 

b. Inspire 1 : all switches to the right 

8. Install main UAS battery and check balance 

9. Power up the UAS and allow automated startup calibrations to 

complete 

10. Perform a manual Compass Calibration at takeoff location 

11. Check the OSD Telemetry display to ensure the Flight Controller reads 

GPS mode for takeoff 

a. Takeoff will be held until the GPS unit connects to a minimum of 

10 GPS satellites as indicated by the OSD Telemetry 

12.Announce intention to take off by vocalizing "TAKING OFF" 

DOCUMENTATION 

The following documents are attached and provided to support this petition 

OJI Inspire 1 User Manual v1.2 

DJIInspire 1 Safety Guidelines v1 .0 

Kraken K130 Manual v2 

DJI A2 Flight Controller Quick Start Guide v1.22 

Motion Picture and Television Flight Operation Manual 

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION 

A 14 C.F.R. Part 21 Certification Procedures for Products and Parts, 

Subpart H - Airworthiness Certificates 

a. Establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR§ 91 .203(a)(1 ). 

b. Given the size and limited operating area associated with the 

UAS, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and 

Seciton 333 of the Reform Act. The Federal Aviation Act (49 

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

authorize the FAA to exempt an Aircraft from the requirement 

for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment 

and under the conditions proposed will be at least as safe, or 
6/15/15 Page 7 of 9 

safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate under the same 

conditions. 

B. 14 C.F.R. §§ 61 .113(a) and (b) Private pilot privileges and limitations 

a. An exemption is requested from the limitation that a private pilot 

may not engage in compensation or hire operations. The UAS is 

remotely controlled by a ground-based operator, and all flights 

are planned and coordinated in advance. The level of safety 

exceeds that provided by a single individual holding a 

commercial pilots certificate operating a conventional aircraft. 

The risks associated with the use of a UAS are so diminished 

from the risks associated with commercial operations so that an 

equivalent level of safety can be achieved by allowing UAS use 

by a private pilot. 

C. 14 C.F.R. § 91. 7(a) Civil Aircraft Airworthiness 

a. While the UAS will not have an airworthiness certificate in 

accordance with 14 C.F.R. part 21, Subpart H, the airworthy 

condition of the UAS will be the responsibility of the PIC in 

accordance with 14 C.F.R. § 91.7(b). 

D. 14 C.F.R. § 91.103(b)(2) General Operating and Flight Rules, Subpart 

B - Flight Rules, Preflight action 

a. Subpart B of this regulation states that the PIC, before 

beginning a flight, shall become familiar with runway lengths at 

airports of intended use 

b. As the UAS will not be flown at airports unless specifically 

granted under a COA, and has a vertical takeoff requiring zero 

runway distance, exemption from this rule is requested 

E. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and 

other areas 

a. This regulation establishes safe altitudes for operation of civil 

aircraft over areas other than congested areas. Orlando Drones 

requests relief from this section with respect to persons involved 

in the operation as well as vehicles and structures. The UAS will 

not be operated above 400ft AGL altitude. It will be operated in 

a defined area where people and buildings will not be exposed 

to operations without their pre-obtained consent 

F. 14 C.F.R. § 91.121 Altimeter Settings 

a. This regulation requires each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set 

" ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." 

b. As the UAS does not have a barometric altimeter, an exemption 

is requested. The UAS Flight Controller utilizes GPS equipment 

aided by a static pressure sensor to determine and maintain 

altitude. The aircraft altitude above he takeoff point is provided 

in the video downlink telemetry information and provides 
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sufficient information for the PIC to maintain altitudes at or 

below the 400ft (122meter) limitations. 

G. 14 C.F.R. § 91 .151 (a) Fuel requirements for flight in VFR conditions 

a. Section 91 .151 (a) prohibits an individual from beginning "a flight 

in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cursing 

speed - ( 1 ) During the day to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes." 

b. Given that the UAS aircraft only fly for a maximum of 30 minutes 

and carry on average 15 minutes of batter power, an exemption 

is requested. The UAS operations are always conducted within 

a few minutes of the takeoff and landing point and within a 

restricted area. Orlando Drones believes that terminating the 

flight with 30% remaining battery power provides an equivalent 

amount of safety that is intended by section 191 .151 (a). 

H. 14 C.F.R. § 91.405(a) Maintenance Required; 

a. 14 C.F.R. § 91.407(a)(1) Operation after maintenance, 

preventative maintenance, rebuilding or alteration; 

b. 14 C.F.R. §§ 91.409(a) (1) and (2) Inspections; 

c. 14 C.F.R. §§ 91.417(a) and (b) Maintenance Records; 

1. These regulations require that an aircraft operator or 

owner "shall have that 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. .. ," and others shall inspect or maintain 

the aircraft in compliance with part 43. 

ii. Given that the sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not 

apply to the Petitioner. Maintenance will be accomplished 

by the operator pursuant to the Owner's Manuals. An 

equivalent level of safety will be achieved because these 

small UAS are very limited in size and will carry a small 

payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise, the UAS can 

land immediately and will be operating from no higher 

than 400 feet AGL. The operator will ensure that the UAS 

is in working order prior to initial flight, perform required 

maintenance and keep a log of any maintenance 

performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent 

level of safety. The FAA issued exemption to these 

regulations in Exemption No. 11062. 
6/15/15 Page 9 of 9 

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Petitioner: Orlando Steadicam LLC, dba: Orlando Drones 

Sections of 14 C. F. R Affected: 

Part 21 , Subpart H; §§ 61 .113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 

91 .151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and 

(b) 

Description of Relief Sought: Orlando Steadicam LLC, dba: Orlando Drones 

seeks relief from the requirements of 14 C.F.R. Part 21 , Subpart H; 14 C.F.R. §§ 

61.113(a) and (b); 14 C.F.R. § 91 .7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 

91.121 ; 14 C.F.R. § 91 .151 (a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1 ); 

14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate 

small unmanned aircraft systems (UAS) for the purpose of closed set filming of 

motion pictures, music videos, web videos, corporate videos, television programs 

and commercials and still photography 

Respectfully submitted, 

Michael J Germond 

Owner/MGRM 

Orlando Steadicam LLC 

dba: Orlando Drones 

6550 Kings Cote Ave Apt 102 

Orlando, FL 32835 

Phone: 616-581-2274