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	exe mption
 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 poss ible	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. Additi onally,	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,	vi deography,	inspections and	other	flight	operations request :

 Michael	Carlini’s UAS weigh s 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	o nly	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	Vis ual	Line	of	Sight	only;
 Michael	Carlini 's UAS have	a	GPS	flight	s afety	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 .	Befo re	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	protoc ols 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	mean s	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 peopl e	or	fuel	on	board	and	the UAS s	are	also	very	small	and	versatile	which	allows Michael	Carlini to	avoid	hazards	quickly	and	safely. Furthermore, Michael	Carlini’s UAS do es 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. Th ese	limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to operations	under	the	current	regulatory	structure	because	the	proposed	operationsrepresent	a	safety	enhancement	to	the	operations	conducted	with	conventional

aircraft.	Th e	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,	pass engers,	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	exem ption	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	Vis ual 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 UAS s	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	l and.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	requ est	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

.