UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Michael J. Mazzone

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

14 C.F.R §§ 21; Subpart H, 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 

91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b),

CONCERNING COMMERCIAL OPERATION OF DJI-FLAME WHEEL F450, DJI-FLAME 

WHEEL F550, DJI-INSPIRE 1, DJI-INSPIRE 1 PRO, DJI INSPIRE 2, DJI-MATRICE 100, DJIPHANTOM 1, DJI-PHANTOM 2, DJI-PHANTOM 2 VISION+, DJI-PHANTOM 3 

STANDARD, DJI-PHANTOM 3 ADVANCED, DJI-PHANTOM 3 PROFESSIONAL, DJIPHANTOM 4, DJI-SPREADING WINGS S900, DJI-SPREADING WINGS S1000+ 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on 03/08/2016

Michael J. Mazzone

53 John Potter Rd.

West Greenwich, RI 02817

(401) 225-5292

Michael.J.Mazzone@gmail.com
Table of Contents

Glossary of Abbreviations................................................................................................................1

Introduction......................................................................................................................................2

Basis for the Petition........................................................................................................................3

Name & Address of the Petitioner...................................................................................................4

The Specific Sections of 14 C.F.R. from which Michael J. Mazzone Seeks Exemption................5

Reasons Why This Exemption Will Not Adversely Affect Safety Standards................................11

Public Interest Benefits..................................................................................................................12

Proposed Operations......................................................................................................................13

sUASs for Proposed Operations....................................................................................................14

Conclusion.....................................................................................................................................15

(i)
Glossary of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

sUAS Small Unmanned Aircraft System

Section 333 FAA Modernization and Reform Act of 2012 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

(1)
Introduction

To Whom It May Concern; 

 Pursuant to §333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11, Michael J. Mazzone, operator of sUASs, hereby applies for an exemption from the listed 

FARs, to allow commercial operation of his sUASs, 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 §333.

 As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive multi-rotor aircraft under controlled conditions in 

airspace that is 1.) contained 2.) predetermined and 3.) would provide increased safety and 

enhancements to the business operations of Michael J. Mazzone.

 Michael J. Mazzone, owner and PIC, has over (10) years of aviation experience. He 

graduated from the Florida Institute of Technology in 2010 with a degree in Aviation 

Management. In addition to his flight degree, he also obtained his Private, Instrument, 

Commercial, Multi-Engine & CFI-A ratings during his time spent at Florida Tech. In addition to 

being an active flight instructor, he also holds an Airline Pilot Transport certificate and works for 

SkyWest Airlines as a First Officer on the ERJ-175.

(2)
Basis For Petition

 Michael J. Mazzone submits this application in accordance with the Reform Act, 112 P.L. 

95 §§331-334. He seeks relief from the listed federal aviation regulations pertaining to sUASs, 

which prevent Michael J. Mazzone from conducting business service flight operations within the 

U.S. national airspace system. The Reform Act in §332 provides for such integration of civil 

sUASs into our national airspace system, as it is in the public's interest to do so. Michael J. 

Mazzone’s lightweight sUASs meet the definition of "small unmanned aircraft" as set forth in 

§331. Combined with a sterling safety record in similar industries, Michael J. Mazzone’s light 

duty sUASs are ideal recipients of exemption by the intent of the Reform Act.

 Considerations for relief include a combination of sUAS physical characteristics, safety 

features, and safe practices identified in §333: 

★ sUAS weight

★ sUAS overall size

★ sUAS speed over ground

★ sUAS flight zone characteristics

★ Non-operation near airports (civilian or military)

★ Tightly controlled operation in populated areas

★ Operation of the sUAS by VLOS

(3)
Name & Address of the Petitioner

Michael J. Mazzone

53 John Potter Rd.

West Greenwich, RI 02817

(401) 225-5292

Michael.J.Mazzone@gmail.com

(4)
The Specific Sections of 14 C.F.R. from which Michael J. Mazzone Seeks Exemption

 Michael J. Mazzone kindly requests a grant of an exemption of the following sections of 

Title 14 of the Code of Federal Regulations: 

★ 14 C.F.R. § 21; Subpart H

★ 14 C.F.R. § 45.23(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(b)

★ 14 C.F.R. § 91.203(a) & (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. § 91.417(a) & (b)

 Specific consideration is outlined below:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

 14 C.F.R. § 21; Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). 

Given the size and limited operating area associated with the sUAS, an exemption from Part 21 

Subpart H would be needed. This meets the requirements of an equivalent level of safety under 

Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 

of the Reform Act both authorize the FAA to exempt 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 sUAS. In all cases, an analysis of 

these criteria demonstrates that the sUAS operated without an airworthiness certificate in a 

restricted environment and under the conditions proposed, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft), operating with an airworthiness certificate 

without the restrictions and conditions proposed.

 The sUASs to be operated by Michael J. Mazzone are less than 11 kg (with maximal 

payload consisting of remote sensing instrumentation), carry no persons, carry no explosive or 

flammable materials (including combustible fuels), and operate exclusively within a secured 

area. These enhancements to current safety practices and regulations, which already apply to 

civil aircraft, provide a greater degree of safety to the public and property owners in comparison 

to conventional aircraft operations conducted with airworthiness certificates issued under 14 

(5)
C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

intrinsic credible threat to national security posed by the sUASs, due to their size, speed of 

operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load.

14 C.F.R. §45.23(b) Display of Marks: General

 14 C.F.R. §45.23(b) requires that when “the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited;' "restricted;' "light-sport;' "experimental;' or "provisional;' as 

applicable.”

 Even though the sUASs will not have an airworthiness certificate, an exemption may be 

needed, as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the 

word "Experimental" can be placed. Given the size of the sUASs, two-inch lettering will be 

impossible.

 An equivalent level of safety will be provided by having the sUASs marked on their 

fuselage, as required by §45.29(f), where the pilot and others working with the sUASs will see 

the identification as "Experimental". The FAA has issued the following exemptions to this 

regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

 14 C.F.R. §91.7(a) requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the sUAS, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft, the requirements contained in the manual for maintenance, and use 

of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. §91.9(b)(2): Civil Aircraft Flight Manual

 14 C.F.R. §91.9(b)(2) states that “no person may operate a U.S. registered civil aircraft: 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.”

 The sUASs, given their size and configuration, have no ability to carry a physical flight 

manual onboard the aircraft. The equivalent level of safety will be maintained by keeping the 

flight manual at the ground control point where the pilot flying the sUAS will have immediate 

(6)
access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. §91.103: Preflight Action

 14 C.F.R. §91.103 requires each PIC to take certain actions before flight to ensure the 

safety of its operation. As FAA approved Rotorcraft Flight Manuals will not be provided for the 

aircraft, an exemption will be needed. The PIC will take all actions, including reviewing weather, 

flight battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 C.F.R. §91.105: Flight Crew Members at Stations

 14 C.F.R. §91.105 requires that “during takeoff and landing, and while en route, each 

required flight crew member shall: (1) Be at the crew member station and (2) Keep the safety 

belt fastened while at the crew member station.” Furthermore, it states that, “each required flight 

crew member of a U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her 

shoulder harness fastened while at his or her assigned duty station.” Since the sUASs (which will 

become U.S. registered aircraft upon Michael J. Mazzone being granted the exemption) are 

incapable of carrying crew members, an exemption will be needed. Michael J. Mazzone will 

ensure however that he, the qualified PIC, will maintain a VLOS at all times with the rotorcraft.

14 C.F.R. §91.109: Flight Instruction

 14 C.F.R. §91.109 details that “no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction, unless that aircraft has fully functioning 

dual controls.” sUASs and remotely-piloted aircraft, by their design, do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft, more specifically, Exemption nos. 5778K & 9862A. 

 An equivalent level of safety will be provided with the fact that neither a pilot nor 

passengers will be carried in the aircraft, and by the smaller size and slower speed of the sUAS. 

Enhancing this safety is the technology inherent in the remote controls, utilizing digital 

communications that are paired to the sUAS, making it nearly impossible to unintentionally or 

intentionally have the control communications interrupted.

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

 14 C.F.R. §91.119 establishes safe altitudes for operation of civil aircraft. §91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

(7)
FAA. As this exemption is for a sUAS that closely mimics the behavior of a helicopter, and the 

exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed 

to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 

AGL or beyond unaided VLOS, whichever is closer. It will however be operated in a secure area, 

where buildings and people will not be exposed to operations without their pre-obtained 

permission.

 The equivalent level of safety will be achieved given the size, weight and speed of the 

sUAS, as well as the location where it is operated. No flight operation will be taken without the 

permission of the property owner, in the case of private property, or the permission of local 

officials, in the case of public property or private property with public interests. Because of the 

advanced notice to the property owner and participants in the remote sensing activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighing far more than the maximum 11 kg proposed herein, as well as the 

lack of flammable fuel, any risk associated with these operations is far less than those that 

presently exist with conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations of the sUAS will ensure separation between small sUAS operations and the 

operations of conventional aircraft that must comply with §91.119.

14 C.F.R. §91. 121 Altimeter Settings

 14 C.F.R. §91.121 requires that each person operating an aircraft maintain a 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.” As the sUAS does not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. The PIC will also ensure effective pairing 

with multiple GPS sources to guarantee accurate detection of height.

14 C.F.R. §91.15l(b): Fuel Requirements for Flight in VFR Conditions

 14 C.F.R. §91.151(b) prohibits an individual from beginning “a flight in a rotorcraft 

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 cruising speed, to fly after 

that for at least 20 minutes.” The shortest life of a battery powering a sUAS operated by Michael 

J. Mazzone is (15) minutes of powered flight. Consequently, these sUASs will not be able to 

meet the (20) minute reserve requirement in 14 C.F.R. §91.151(b). Operating the sUAS in a 

tightly controlled area where only informed persons and property owners or official 

representatives who have signed waivers will be allowed, having less than (20) minutes of 

reserve power, does not endanger the type of risks that section 9l.l51(b) was intended to 

alleviate, given the size and speed of these sUASs. Michael J. Mazzone believes that an 

equivalent level of safety can be achieved by limiting flights to less than 25% of battery power. 

This restriction would be more than adequate to return the sUAS to its planned landing zone 

(8)
from anywhere in its limited operating area. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203(a) & (b): Civil Aircraft: Certifications Required

 14 C.F.R. §91.203 provides in pertinent to parts (a) & (b):

 “(a) Except as provided in §91.715, no person may operate a civil aircraft unless it 

 has within it the following: (1) An appropriate and current airworthiness 

 certificate.”

 “(b) No person may operate a civil aircraft unless the airworthiness certificate 

 required by paragraph (a) of this section or a special flight authorization issued 

 under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

 passengers or crew.”

 Fully loaded, the heaviest sUAS in Michael J. Mazzone’s fleet weighs no more than 11kg 

and is operated without an onboard pilot. As such, there is no ability or location to carry 

certification and registration documents or to display them on the sUAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point, where the pilot 

flying the sUAS will have immediate access to them, to the extent applicable. The FAA has 

issued numerous exemptions to this regulation. These include Exemption nos. 9565, 9665, 9789, 

9789A, 9797, 9797A, 9816A, and 10700.

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

 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. Given 

that this section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to our operation. Maintenance will be accomplished by the operator, pursuant to 

the flight manual. An equivalent level of safety will be achieved because these sUASs are very 

limited in size, will carry a small payload, and will operate only in designated areas for limited 

periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating 

from no higher than 400 feet AGL. The PIC will, (1) ensure that the sUAS is in working order 

prior to initiating flight, (2) will perform required maintenance, and (3) will keep a log of any 

maintenance performed. Moreover, the PIC 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.

 An exemption granted to Michael J. Mazzone would permit his operation of lightweight, 

unmanned, remotely controlled, sUASs in a tightly controlled environment. Technical 

enhancements to current safety controls will allow Michael J. Mazzone to operate exceeding 

(9)
current safety specifications, and stay ahead of, or meet, new safety specifications being 

implemented by the FAA and Department of Transportation. Furthermore, Michael J. Mazzone 

conducts his operations in compliance with protocols described herein or as otherwise 

established by the FAA.

(10)
Reasons Why This Exemption Will Not Adversely Affect Safety Standards

 Michael J. Mazzone contends that operation of his sUASs will not “create a hazard to 

users of the national airspace system or the public”, as stated in 112 P.L. 95 §333(b). Given the 

diminutive size and weight of Michael J. Mazzone’s sUASs, combined with their operation in 

cordoned-off and well-controlled areas, Michael J. Mazzone’s sUASs fall within Congress’s 

contemplated safety zone. They have an established safety record, bolstered by a multi-point 

preflight checklist. As PIC, Michael J. Mazzone maintains awareness of his surroundings and has 

intimate knowledge of the behavior of the various sUAS platforms in many weather conditions. 

This safety record and implemented operational practices demonstrate an awareness of public 

safety.

 Michael J. Mazzone’s operations routinely provide a level of safety that at least, and in 

nearly every instance, exceed, existing rules. Michael J. Mazzone will attain the maximal level of 

insurance to rectify accidental damage or injury. Michael J. Mazzone does not operate his sUASs 

on or near airports and will only operate his fleet on private grounds, with cordoned-off areas or 

areas under the control of the property owner, unless additional authorization has been granted. 

Michael J. Mazzone determines the areas needed to fulfill the clients’ goals. He only operates his 

sUASs in these flight zones, and only in compliance with well regarded safety protocols set forth 

initially by the RC sUAS trade and hobby groups, and recently codified by relevant FARs.

 Michael J. Mazzone has implemented the following practices to ensure safe operation of 

his sUASs: 

★ Operation by unaided VLOS only

★ Operation in phases 10 minutes in length

★ Operation to minimal 25% battery power

★ Operation of device to GPS aided readout to 400ft at maximum

★ Numerous pre-programmed fail-safes that ensure specific behavior per issue

★ Employ controlled lifecycle management of components to guard against 

multiple failures 

★ Preform a site check day(s) before flight to identify potential issues

★ Subscribe to relevant local weather and safety alerts

★ Expertly choose data collection instruments and accessories to minimize flight 

requirements or expertise

 Michael J. Mazzone has experience in similar fields and has adapted this experience in 

his use of sUASs to increase safety. In combination to the ever expanding knowledge 

repositories from hobbyists and experts alike, Michael J. Mazzone is constantly evolving his 

practices when there is a clear benefit to operations or increased safety element. 

(11)
Public Interest Benefits

 Michael J. Mazzone believes that granting this exemption request furthers the public 

interest by providing safe (by way of an unmanned system) and efficient means to meet technical 

problems solvable by elevated data collection instruments. Michael J. Mazzone’s client base is 

typically small to medium sized business', looking to increase their public awareness through use 

of photographic and video-graphic presentation. By moving these functions onto sUASs, the 

potential for loss of life or property is diminished, due to the greater control in a smaller and 

safer aircraft that holds no persons. Additionally, there are no reactive or combustible materials 

onboard the sUAS and thus the potential for fire or explosions is greatly diminished. 

Furthermore, the small size and extreme maneuverability of Michael J. Mazzone’s sUASs allow 

him to avoid hazards. Lastly, due to the nature of the remote sensing instrumentation onboard, 

the sUAS can maintain a safe distance between the aircraft and the object(s) undergoing scrutiny. 

Accordingly, Michael J. Mazzone’s sUASs have operated and will continue to operate at and 

above current safety levels.

 The impact to the general public, financial and otherwise, would be extremely minimal. 

Indeed, it's been demonstrated that sUASs have the ability to drastically increase the information 

available to policymakers at a fraction of the cost of measuring this data by terrestrial means. 

One such impact would be inconvenience to directly proximal and non-essential personnel that 

would be displaced from public or business owned-property if it is deemed to be unsafe. In this 

case we relay our needs for a flight zone with the requirement that it be safe from casual 

intrusions and allow the business time to shift operations in order to minimize potential safety 

issues. This is best performed with the aid of safety personnel that actively steer non-essential 

persons around the flight zone.

 The effect of an exemption for Michael J. Mazzone on the quality of the natural and 

social environments utilizing sUASs, minimizes the requirement for conventional aircraft. This 

eliminates the need for an onboard pilot, time consuming adherence to regulations surrounding 

bookkeeping and submission of flight paths to local civilian or military airports, and detrimental 

effects to the environment caused by operating a combustible fuel based, large scale aircraft, 

with restrictions on the proximity to the target for remote sensing.

(12)
Proposed Operations

Michael J. Mazzone wishes to provide high quality imaging for a variety of commercial 

and public uses, specifically targeting:

★ Aerial surveying

★ Aerial video and photography of real estate for landowners, business owners 

and farmers

★ Aerial video and photography for special events

★ Bridge, flare-stack, pipeline, cell tower, wind turbine, and electrical power 

line inspections

★ Construction site inspection & monitoring

★ General aerial photography and videography

★ Mosquito & insect control

★ Public entity support operations

★ Search & rescue operations under the authority & support of local authority 

officials

★ Training to persons individually, or belonging to, both private & public 

organizations, to increase awareness & improve safety for current & future 

UAS operations within the NAS

★ Wildlife & forestry monitoring

(13)
sUASs for Proposed Operations

 Michael J. Mazzone is seeking an exemption to commercially operate (15) sUAS makes 

and models, as follows: 

★ 1.) DJI - Flame Wheel F450

★ 2.) DJI - Flame Wheel F550

★ 3.) DJI - Inspire 1

★ 4.) DJI - Inspire 1 PRO

★ 5.) DJI - Inspire 2

★ 6.) DJI - Matrice 100

★ 7.) DJI - Phantom 1

★ 8.) DJI - Phantom 2

★ 9.) DJI - Phantom 2 Vision+

★ 10.) DJI - Phantom 3 Standard

★ 11.) DJI - Phantom 3 Advanced

★ 12.) DJI - Phantom 3 Professional

★ 13.) DJI - Phantom 4

★ 14.) DJI - Spreading Wings S900

★ 15.) DJI - Spreading Wings S1000+

(14)
Conclusion

 Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed.

 Michael J. Mazzone seeks an exemption from the following rules: 14 C.F.R §§ 21; 

Subpart H, 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(b), 91.203(a) 

& (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b) to operate commercially, a 

small unmanned vehicle (11 kg or less) in elevated photographic and remote-sensing operations. 

 Approval of exemptions allowing commercial operations of sUASs will enhance safety, 

by reducing risk associated with conventional aircraft operations and other means of elevated 

remote-sensing involving persons. The public benefit, served by approval of this petition, is 

increased awareness of characteristics of difficult imaging targets. A sUAS weighing 1l kg or less 

and powered by sealed batteries, eliminates virtually all associated risk inherent in operating 

conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to 

a position they would be able to collect needed data. The operation of sUASs, weighing less than 

11 kg, conducted in the strict conditions outlined above, will provide an equivalent level of 

safety supporting the grant of the exemptions requested herein, including exempting Michael J. 

Mazzone from the requirements of Part 21 and allowing commercial operations. 

 The FAA has been given the authority to issue the exemption to Michael J. Mazzone 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, Michael J. Mazzone 

humbly seeks your consideration and approval of this petition. 

Sincerely, 

Michael J. Mazzone

Michael J. Mazzone

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