Thank you fro your time in reviewing this request:

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 

CFR

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14

CFR

91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 

91.417(a)

and (b)

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act 

of

2012 (the “Reform Act”) and 14 CFR Part 11, Chinedu Ernesto, owner of UDENIHC MEDIA which 

owns and operates an Unmanned Aircraft System (UAS), hereby applies

for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation 

of

its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors,

would operate in the following manner:

- Aerial photography and/or video for public and/or private use including real estate,

architecture, surveying, engineering and other related professional activities.

- Aerial video and/or photography for public and/or private use including television, public

events, private events, cinematography and news gathering.

- Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

- Aerial inspection/photography or residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

UDENIHC MEDIA's pilot Chinedu Ernesto has one DJI Inspire 1 (4) blade quad copters weighing 6 

pounds, 7.5 ounces (see attached

manual). The UAS has a maximum airspeed of 40 miles per hour and uses a remote controller 

operating

on frequency range of 2.400-2.483 GHZ. The Inspire 1 is equipped with built-in ground support

technology that allows it to fly utilizing global positioning system (GPS) for stability, tracking, safe 

flight

mode and a return-to-home feature in the event of loss of remote control signal or critical low battery.

UAS Safety Operating Parameters

Specific Exemptions Requested

Given the size, weight, speed and limited operating area associated with the UAS, we feel an 

exemption

from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) and (b) 

(certifications

required), subject to certain conditions and limitations, is warranted and meets the requirements for an
equivalent level of safety under 14 CFR Part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not have a

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering

is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering

requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the

word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will see the 

markings.

We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot

in

Command. The applicant’s UAS do not carry any pilots or passengers nor property. The Risks 

attendant

to the operation of the UAS is far less than the risk levels inherent in the commercial activities outlined

in 14 CFR §61. The operation and limitations in the flight operation manual (FOM) will equate to the 

safe

operations of the UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operation of an aircraft without an

airworthiness certificate, since there is currently no certificate applicable to our operation, this

regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 

CFR

91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections since they only apply to aircraft 

with

an airworthiness certificate. However, as a safety precaution, we will perform a preflight inspection of

the UAS before each flight as outlined in the attached operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft,

however, since there are no pilots or passengers on board the aircraft, and given its size, this regulation

is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight

manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and

Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is being used

for flight instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 

is

capable of dual/linked controls, we will be operating with a single remote controller.

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We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of

civil aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not

operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in

safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or

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

speed of the UAS, an equivalent or higher level of safety will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the UAS

utilizes electronic GPS with a barometric sensor. We request an exemption from 14 CFR 91.151(a) 

Fuel

Requirements for Flight in visual flight rules (VFR) conditions. The UAS is 100 percent electric and 

two

low battery alerts are issued – per the operating documents, the UAS will be landed at the first alert.

Also, our flights will last only 15-20 minutes each and the UAS has an automated function, which 

results

in immediate landing when a low battery is detected. The PIC will not begin a flight unless, 

considering

wind an forecast weather conditions, there is enough power to fly to the first point of intended landing

and, assuming normal cruising speed, land the UAS with 30 percent battery power remaining.
Summary

We will comply with all of the following conditions and limitations should this grant of exemption be

provided:

1. Operations will be limited to the following aircraft described in the operating documents which

is a quad-rotor aircraft weighing less than seven pounds: DJI Inspire 1 Aircraft System.

2. The UAS will not be flown at an indicated airspeed exceeding 40 mph.

3. The UAS will be operated at an altitude of no more than 400 feet AGL, as indicated by the

procedures specified in the operating documents.

4. The UAS will be operated within VLOS of the PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS of the

VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be

designated before the flight and will not transfer his or her designation for the duration of the

flight. The PIC will ensure that the VO can perform the functions prescribed in the operating

documents.

6. The operating documents will be accessible during the UAS operations and made available to

the Administrator upon request. Any revisions to the operating documents will be presented to

the Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the

inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be

operated until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station will be included in the preflight inspection.

All maintenance and alterations will be properly documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

replacement of a flight critical component, will undergo a functional test flight. The PIC who

conducts the functional test flight will make an entry into the aircraft records.

5

9. The pre-flight inspection section in the operating documents will account for all discrepancies,

i.e. inoperable components, items or equipment not already covered in the relevant sections of

the operating documents.

10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection and life limit requirements.

11. We will carry out maintenance, inspections and record-keeping requirements, in accordance

with the operating documents. Maintenance, inspection and alterations will be noted in the

aircraft records, including total flight hours, description of work accomplished and the signature

of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action taken

against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in

which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC will have accumulated and

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot

operating the make and model of the UAS to be used in operations.

16. The PIC will not operate the UAS for the purpose of aerial videography/cinematography and

augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated

and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in

a manner consistent with the operating documents, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

17. UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All operations

will be conducted under visual meteorological conditions (VMC).
18. The UAS will not operate within five nautical miles of an airport reference point as denoted on a

current FAA-published aeronautical chart.

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a

cloud or when visibility is less than three statute miles from the PIC.

20. If a UAS loses communications or loses its GPS signal, it will return to a predetermined location

within the planned operating area and land or be recovered in accordance with the operating

documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance

with the operating documents.

22. The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is

enough power to fly at a normal cruising speed to the intended landing point and land the UAS

with 30 percent battery power remaining.

23. Before conducting operations, the radio frequency spectrum used for operation and control of

the UAS will comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requirements.

24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the PIC at

the Ground Control Station of the UAS at any time the UAS is operating. These documents will

be made available to the Administrator or any law enforcement official upon request.

Thank you again for your consideration,

Chinedu Ernesto