This	document	is	in	response	to	a	letter	written	by	Brittany	Newton,	Program	

Analyst,	Aircraft	and	Airport	Rules	Division	(FAA)	on	July	23,	2015	in	which	the	FAA	

alerted	Michael	C	Carlini	that	the	request	could	not	be	processed	without	further	

information. The	letter	noted	that	the	following	information	must	be	submitted:	

 The	reasons	why	the	exemption	would	not	adversely	affect	safety	or	how	the	

exemption	would	provide	a	level	of	safety	at	least	equal	to	that	provided	by	

the	rule	from	which	you	seek	an	exemption

 Any	additional	information,	views,	or	arguments	available	to	support	your	

request.

The	following	is	additional	information	that	is	requested	by	the	FAA	for	further	

processing.	Michael	C	Carlini	requests	this	information	be	considered	as	soon	as	

possible	to	allow	for	further	processing	of	the	request.	Thank	you.

-----

MICHAEL	CARLINI’S EXEMPTION	WILL	NOT	ADVERSELY

AFFECT	SAFETY	AND	WILL	PROVIDE	A	LEVEL	OF	SAFETY	AT	LEAST	EQUAL	TO	

EXISTING	FAA	STANDARDS

Michael	Carlini’s exemption	will	not	adversely	affect	safety,	as	it	will	in	fact	enhance	

safety.	Michael	Carlini’s ability	to	log	significant,	controlled	and	monitored	flight	

time	in	FAA	controlled	airspace	as	a	licensed	ASEL/AMEL	Instrument	Rated	pilot	in	

a	variety	of	aircraft	sizes	will	allow	Michael	Carlini to	contribute	to	the	innovation	

and	implementation	of	new,	novel	and	undiscovered	safety	protocols	for	

commercial	drone	operators that	may	be	embraced	by local	drone	operators,	both	

commercial	and	recreational.	Additionally,	the	FAA	may	utilize	the	new	safety	

protocols	for	the	use	of	UAS in	FAA	controlled	airspace	for	all	industries.	Michael	

Carlini	considers	himself	primarily	an	airplane	pilot	and	secondarily	a	UAS pilot,	and	

is	a	proponent	of	the	FAA’s	recent	proposal	to	require	a	license	to	fly	an	UAS.	

Michael	Carlini	frequents various online	communities	to	address	misconceptions	

about	the	dangers	of	flying	UAS.	As	an	airplane	pilot	who	flies	frequently,	Michael	

Carlini	considers	informing	recreational	UAS pilots	of	the	potential	consequences	of	

breaking	rules	and	guidelines	a	personal	responsibility,	benefiting	the	safety	of	both	

the	public	and	himself.	Michael	Carlini submits	the	following	representations	of	

enhancements to	his aerial	photography,	cinematography,	videography,	inspections	

and	other	flight	operations request:

 Michael	Carlini’s UAS weighs less	than	2.8	pounds, complete	with	the	camera	

and	gimbal	assembly;

 UAS	takeoff	and	landing	is	always	conducted	via	flat	ground,	away	from	

people	or	structures,	and	only	where	wind	speeds	remain	under	5	knots;

 Michael	Carlini will	only	operate	his UAS below	three	hundred	(300)	feet	

which	is well	within	the	four	hundred	(400)	feet	ceiling	having	been	

established	by	the	Reform	Act	of 2012;
 Michael	Carlini's	UAS only	operate	for	fifteen	(15)	minutes	per	flight;

 Michael	Carlini lands	his UAS prior	to	manufacturer's	recommended

minimum	level	of	battery	power;

 Michael	Carlini's	pilots	operate	the	UAS through	Visual	Line	of	Sight	only;

 Michael	Carlini's	UAS have	a	GPS	flight	safety	feature	whereby	the	UAS

returns	to	a	preset	“home”	point, hovers	and	then	slowly	lands	if	

communication	with	the	pilot	is	lost or	if	battery	power	falls	below	a	certain	

threshold;

 Michael	Carlini actively	analyzes	its	flight	data	and	other	sources	of

information	to	constantly	update	and	enhance	its	safety	protocols;

 Michael	Carlini only	operates	in	reasonably	safe	environments	which	are	

strictly	controlled	and	away	from	power	lines,	elevated	lights,	airports,	

crowds, and	actively	populated	areas.	Before	each	flight,	proximity	to	

previously	mentioned	environments	are	re-confirmed;

 Michael	Carlini conducts	extensive	pre-flight	inspections	and	protocol	to	

ensure	safety	remains	the	primary	concern;

 Michael	Carlini always	obtains	all	necessary	permissions	from	the	FAA	and	

landowners	prior	to	the	operation	his	UAS and;

Michael	Carlini has	established	safety	procedures	in	place	to	abort	flights	in	the	

event	of	safety	breaches	or	any	potential	danger.	Michael	Carlini's	safety	protocols	

provide	a	level	of	safety	equal to	or	exceeding	existing	FAA	rules.	It	is	important	to	

note	that	absent	the	integration	of	commercial UAS into	our	national	airspace	

system,	manned	fixed	wing	airplanes	and	helicopters	are	the	primary	means	of	

aerial	photography,	aerial	cinematography,	videography,	inspections	and	real	estate	

uses.	While	the	safety	record	of	such	helicopters	is	outstanding,	there	have	been	

incidents	involving	loss	of	life	as	well	as	extensive	property	damage	due	to	crashes	

of	these	manned	aircraft	and	it	is	far	safer	and	less	expensive	to	operate	a	battery	

powered	Michael	Carlini's	ultralight UAS to	accomplish	the	same	task.	The	potential	

for	loss	of	life	is	great	diminished	with	a	UAS as	Michael	Carlini's	UAS carry	no	

people	or	fuel	on	board	and	the	UASs	are	also	very	small	and	versatile	which	allows	

Michael	Carlini to	avoid	hazards	quickly	and	safely. Furthermore,	Michael	Carlini’s	

UAS does not	emit	greenhouse	gases,	and	the	electricity	used	to	charge	Michael	

Carlini’s	batteries	is	generated	using	generators	that	burn	methane	gas collected	at	

local	landfills	as	a	result	of	decomposing	organic	material.	This	nets	a	zero	carbon	

footprint	for	the	UAS’s	operation.	Accordingly,	Michael	Carlini respectfully	requests	

that	the	FAA	grant	the	requested	exemption	without	delay.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

Michael	Carlini proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	

These	limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to	

operations	under	the	current	regulatory	structure	because	the	proposed	operations	
represent	a	safety	enhancement	to	the	operations	conducted	with	conventional	

aircraft.	The	FAA	has	noted	in	past	exemptions	that	"Conventional	aerial	video	

operations,	using	jet	or	piston-powered	aircraft	present	risks	associated	with	

aircraft	that	weigh	in	the	neighborhood	of	5,000	to	7,000	pounds	or	more,	carry	

large	quantities	of	fuel,	passengers,	and,	in	some	cases,	cargo.	Such	aircraft	must	fly	

to	and	from	the	survey	location.” Please	See	FAA	Exemption	11110.	These	

limitations	and	conditions	to	which	Michael	Carlini agrees	to	be	bound	when	

conducting	all	operations	under	an	FAA	issued	exemption	include:

1.	The	UAS will	weigh	less	than	2.8	pounds.

2.	Maximum	total	flight	time	for	each	operational	flight	will	be	fifteen	(15)	minutes.

Flights	will	be	terminated	at	or	above	thirty	percent	(30%)	battery	power	reserve	

should	that occur	prior	to the	fifteen	(15)	minute	limit.

3.	Flights	will	be	operated	at	an	altitude	of	no	more	than	three	hundred	(300)	feet	

AGL.

4.	Minimum	crew	for	each	operation	will	consist	of	the	UAS Pilot	and	a	Visual	

Observer	("VO").

5.	The	UAS will	only	operate	within	a safe	area	and	never	over	people	or	large	

crowds.

6.	A	briefing	will	be	conducted	with	regard	to	the	planned	UAS operations	prior	to	

flight	operations.	It	will	be	mandatory	that	all	personnel	who	will	be	performing	

duties	with	regard	to	the	flight	operations	be	present	for	this	briefing.

7.	The	Pilot	and	VO	will	have	been	trained	in	operation	of UASs	generally	and	

received up-to-date	information	on	the	particular	UAS to	be	operated	and	the	UAS

will	be operated	in	conformity	with	Michael	Carlini's	protocols.

8.	The	PILOT	and	VO	will	at	all	times	be	able	to	communicate	via	voice

communication.

9.	Written	and/or	oral permission	from	the	relevant	property	holder(s),	or	their

authorized	representative(s),	will	be	obtained.

10.	All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	

county or	city	jurisdictions,	including	local	law	enforcement,	fire,	or	other	

appropriate governmental	agencies.

11.	If	the	UAS loses	communications,	reaches	a	low	battery	power	threshold, or	

loses	its	GPS	signal,	the	UAS will	automatically	return	to	the launch	site	of	the	UAS,	

or	another	more	appropriate	site,	and	land.
12.	The	UAS will	have	the	capability	to	abort	a	flight	in	case	of unpredicted	obstacles	

or emergencies.

13.	The	UAS will	not	be	flown	within	close	proximity	to	any	kind	of	emergency,	

rescue,	or	firefighting	operation	without	written	consent	and	request	from	the	

participating	parties.

ADDITIONAL	INFORMATION	SUPPORTING	MICHAEL	CARLINI’S	REQUEST

As	has	been	previously	mentioned,	Michael	Carlini	considers	himself	an	airplane	

pilot	before	a	UAS	pilot.	As	all	former	CFIs,	CFIIs,	DPEs,	and	fellow	pilots	will	attest,	

Michael	Carlini	emphasizes	safety	beyond	everything	else,	and	this	trait	carries	over	

into	UAS	operations.	Michael	Carlini	actively	seeks	to	educate	other	UAS	operators	

and	would	use	any	kind	of	publicity	and/or	reputation	to	further	that	cause.	His	

stake	in	both	UAS	and	airplane	operations	gives	great	incentive	to	promote	safety	

and	responsible	UAS	use.	Michael	Carlini	would	operate	all	aspects	of	UAS	

commercial	operations	at	standards	to	which	he	would	expect	and	hope	all	other	

UAS	operators	would	attain.	Finally,	Michael	Carlini	would	seek	to	get	involved	with	

youth	and	classrooms	to	help	create	enthusiasm,	excitement,	and	interest	in	UAS	

operations	as	well	as	aviation	in	general.	Michael	Carlini	believes	that	UAS	use	will	

grow	exponentially,	especially	with	the	next	generations.	Through	this	exemption,	

Michael	Carlini	would	be	allowed	to,	taking	the	most	extensive	safety	precautions	

possible,	expose	children	to	safe	and	responsible	UAS	use and	teach	them	where	

UAS	are	being	used	and	how	UAS	may	be	able	to	benefit	the	world	in	the	future.