Mike Levin

Mike Levin Photography & Digital Imaging

2941 Susquehanna Rd.

Roslyn, PA. 19001

http://mklphoto.com

I, the (PIC) would like to be considered under the ‘new blanket COA’ for flights at or 

below 200 feet, within VLOS and safe separation from airports or heliports. Unmanned 

Aircraft System (UAS) usage for for aerial photography, real estate, architectural, 

engineering, construction industry sites, motion picture and television operations. I have 

been a photographer for over 30 years, am in good health and was recently published in 

Editor and Publisher regarding drones in Journalism. http://

www.editorandpublisher.com/Columns/Article/Editorial--Drone-Talk-is-Droning. I’ve 

recently attend a VTOL conference at the University of Maryland with the FAA’s Earl 

Lawrence. I am a member of the AMA, AUVSI, and Drone Journalism.org.

With regard to my initial Section 333 request. I will be using a KongCopter X8 small 

UAS, along with a 3Dr (3D Robotcs) Iris+ small UAS. Both units run the same software 

code as found in the already FAA approved 3Dr Iris+. I have been flying for three years 

without incident, and I keep a maintenance and flight log. I would use the X8 for 

situations where motor redundancy is paramount in terms of safety, and or extra 

payload of a slight larger camera.

In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in 

reference to 49 USC § 44704, and in consideration of the size, weight, speed, both 

aircraft meet the conditions of Section 333. 

The KongCopter is being custom built, with stronger more reliable components by 

DebonairUAS, a long time UAS Alabama based UAS manufacturing company. https://

debonairuastechnologies.wordpress.com/

The KongCopter test flight can be seen here. https://www.youtube.com/watch?v=0IiQAO7M2Y

-Manned aircraft conducting aerial photography operations can weigh thousands of 

pounds or more, are operated by an onboard pilot and may carry other onboard crew 

members, as well as carry large quantities of fuel. The petitioner’s unmanned aircraft 

(UA) weighs approximately 4 pounds. 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.

Both UAS have the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability and 

control. Both UAS are also able to respond to a loss of global positioning system (GPS) 

or a lost-link event with a pre-coordinated, predictable, automated flight maneuver. 
These safety features

provide an equivalent level of safety compared to a manned aircraft holding a restricted 

airworthiness certificate performing a similar operation. Both UAS being under 5 lbs., 

will provide me with the ability to provide aerial vistas for my customers, without 

resorting to the high cost, high noise, passenger, crew, fuel explosion danger, and waste 

of fossil fuels, thereby providing public benefit with limited impact. Manned aircraft are at 

risk of fuel spillage and fire in the event of an incident or accident. Both UAS carries no 

fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is 

eliminated.

Request relief from 14 CFR §§ 91.405(a) Maintenance required, 91.407(a)(1) Operation 

after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(2) 

Inspections, and 91.417(a) and (b) Maintenance records. Operating documents contain 

preflight and post flight checks for the UAS. Request relief from § 91.409(a)(1) because 

of alternate inspection requirements of § 91.409(a)(2). Operating documents, as should 

be sufficient to ensure that safety is not adversely affected. 

Requested relief from 14 CFR § 61.113(a) and (b), Private pilot privileges and 

limitations. I plan to operate in uncontrolled airspace and over private property with 

controlled access. Given: 1) the similar nature of the petitioner’s proposed operating 

environment to that of Astraeus, 2) the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial requirements as discussed in 

Exemption No. 11062, and 3) the limited airmanship skills necessary to operate the 

UAS, the FAA found that the additional manned airmanship experience of a 

commercially certificated pilot, would not correlate to the airmanship skills necessary for 

the petitioner’s specific proposed operations.

As the PIC, I will enroll in appropriate training for fixed wing aircraft, if required. I will 

operate the UAS in a manner consistent with and including evasive and emergency 

maneuvers while maintaining appropriate distances from people, vessels, vehicles, and 

structures. 

Request Relief from 14 CFR § 91.121 Both UAS uses information generated from GPS 

to transmit altitude information to the PIC. 

Requested relief from § 91.151(a) Fuel requirements.No fuel required. Similar UASspecific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The petitioner proposes to land the UAS after 10 minutes in flight or 

prior to 30% battery power remaining. The operating documents indicate that the UAS 

will return to the launch point and land when the battery reaches 30% of capacity. I will 

contact ATC if at any time I am needing to operate within 5 NM of an airport, and will 

comply with all NOTAMs. I have studied to be an ATC in the past.

This serves as a summary which you may publish in the Federal Register.