Michael C. Carlini

274 Orchard View Terrace

Medford, OR 97504

Cell (541) 326-1745

Email: Michael.carlini@gmail.com 

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 2012 

Attachments:

1) Phantom 2 Vision+ User Manual V1.8

2) Phantom 2 Vision Plus (Quick Start Guide) 

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 

in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in 

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 

in the matter of the petition of FLYING CAM INC 

May 4th, 2015

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I Michael C. Carlini, 

referred to hereafter as the petitioner, request exemption from the following sections of 

Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 

(a)(1); 91.409(a)(2); 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude 

within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only at the request of and with the authorization and permission of 

clients or their authorized agents in order to facilitate commerce and raise awareness of 

the beneficial uses of small unmanned air systems. 
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. The conditions 

identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 

The petitioner seeks exemption from the above-mentioned FARs for the following 

reasons;	

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an FAA licensed and 

current Private Pilot (Michael Curtiss Carlini, Cert # 3571047) with the addition of a 

visual observer. All pre-flight inspection, maintenance and flight logs will be saved and 

made available to the FAA and Secretary of Transportation (SoT) for review; with the 

purpose of safely integrating civil UAS operation in the National Airspace System. 

91.119(c) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 

than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the 

terms “congested areas”	and “densely populated”. The petitioner requests waiver for this 

condition to allow reasonable and responsible operations in areas of subdivisions and 

neighborhoods if required. 

The petitioner will primarily operate the UAS between ground level and 200 feet. The 

UAS will be operated over designated properties with the owner’s consent and while 

maintaining a safe distance from persons. The petitioner will compile flight data from the 

logs. This data may assist the FAA in development of regulations for commercial 

operations in low-risk, controlled environments.

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information.

91.151(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior 

relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS 

specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The UAS provides battery power remaining in percent to the PIC. The 

UA batteries provide approximately 25 minutes of powered flight. Information provided 
in the operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a 

landing procedure when battery remaining reaches a specified level. Given the limitations 

on proposed operations and the location of those proposed operations, The FAA found 

that a reduced minimum power reserve for flight in daytime VFR conditions was 

reasonable.

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

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to 

inspect and ensure that the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the requirements for 

maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected. 

The UAS 

The DJI Phantom 2 Vision Plus is a highly successful consumer grade small rotorcraft in 

the quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum 

speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per 

minute (6 m/s). It is powered by four electric motors with a distance between motors of 

less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted 

back to a ground control station allowing the operator and/or PIC to monitor battery 

level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and 

control camera angle. It has failsafe modes of operation for either loss of RC or GPS 

signal. Altitude can be limited by the onboard flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 25 

minutes. The onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination of flight and 

controlled automatic landing will be initiated when the battery reaches a predetermined 

low state. It is anticipated that flights will usually last less than 12 minutes. More 

information is available in attachment 1. 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist will be developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure prone components. These documents will be made available to the FAA and SoT 
to assist in future implementation of safety standards and regulations. The petitioner will 

only operate the UAS over designated properties with the owner’s consent. Flight plans 

will be predetermined to limit the UASs flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight obstacles prior 

to operating the UAS. UAS operation will always be within VLOS of the PIC and the 

observer. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and 

enhance personal photography. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide 

clients with photographic data for these purposes on a ‘for hire’	basis acting as an 

independent contractor. A visual observer will be utilized. Flight data including UA flight 

time, Control Unit operation time, incident, accident, and details concerning any 

deviations from normal operations will be available to FAA for use in collecting data 

regarding the use of UAS as part of this application. This data may be submitted to FAA 

via traditional means or other means as required. 

Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, inspections and other flight operations”. The reason for 

such a general and broad based request is that the petitioner wishes to utilize a business 

strategy of horizontal integration and maximize economies of scope in order to capitalize 

on opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions. The petitioner's business model is based on the 

idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business or 

hobby. The primary purpose of seeking this exemption is to obtain the capability to offer 

those services while remaining in compliance. 

Respectfully submitted,

Michael C. Carlini