Mark	McBride,	President

Aerial	Media	One Inc.

8115	Grenada	Drive	 Brighton,	MI	48116	 Phone:	517.404.1930

E-Mail:	aerialmediainc@gmail.com  Web:	www.aerialmediaone.com

May	25,	2015

U.S.	Department	of	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590

RE:	Exemption	Request Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform	

Act),	and	14	C.F.R.	Part	11,	Aerial	Media	One Inc. (AM1),	a	complete	Unmanned	Aircraft	

Systems	(UAS)	service	provider, hereby	applies	for	an	exemption	from	the	Federal	Aviation	

Regulations	(FARs)	listed	below	to	allow	operation	of	our	Small	Unmanned	Aircraft	

Systems	(sUAS)	commercially in	airspace	regulated	by	the	Federal	Aviation	Administration	

(FAA)	so	long	as	such	operations	are	conducted	with	and	under	the	conditions	outlined	

herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333.

The	requested	exemptions	would	permit	Aerial	Media	One Inc. to	provide services	to	

clients	using	sUAS	devices in	the	following	commercial	markets:	

• Real	Estate

• Agriculture

• Utility	Grid	Management

• Utility	Customer	Service

• Mapping

• Cinematography

• Videography/Photography

• Advertising

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

small,	unmanned	and	relatively	inexpensive	UAS	under	controlled	conditions	in	airspace	

that	is	limited,	predetermined,	controlled	as	to	access,	and	would	provide	safety	

enhancements	to	the	already	safe	operations	using	conventional	aircraft.	

The	petitioner	requests	relief	from	the	following:	

• 14	C.F.R	Part	21
• 14	C.F.R.		45.23	(b)	

• 14	C.F.R.		61.113	(a)	&	(b)

• 14	C.F.R.		91.7	(a)

• 14	C.F.R.		91.9	(b)	(2)

• 14	C.F.R.		91.103

• 14	C.F.R.		91.109

• 14	C.F.R.		91.119

• 14	C.F.R.		91.121

• 14	C.F.R.		91.151	(a)

• 14	C.F.R.		91.203	(a)	&	(b)

• 14	C.F.R.		91.401	– 91.417

Extent	of	Relief	Sought

Aerial	Media	One Inc.	is	petitioning for	an	exemption	to	operate	sUAS	weighing	less	than	55	

lbs	at	altitudes	at	or	below	400	ft	above	ground	level	(AGL),	not	within	3	nautical	miles	of	

an	airport.	

Aerial	Media	One	Inc.	will	only	operate	its	sUAS	in	visual	line	of	sight	of	a	pilot	and	visual	

observer,	and	will	operate	at	sites	that	are	sufficient	distance	from	populated	areas,	clouds	

and	full-scale	aircraft.	

Such	operations	will	ensure	that	the	sUAS	will	not	create	a	hazard	to	users	of	the	national	

airspace	system	or	the	public.	

Exemption	Requests by	14	C.F.R. Section,	Including	Relief	Sought,	Purpose	for	Relief,		

and	Safety	Implications

14	C.F.R	Part	21,	Airworthiness	Certificates

14	C.F.R.	21,	Subpart	H,	entitled	Airworthiness	Certificates.

This	regulation sets	forth	requirements	for	procurement	of	necessary	airworthiness	

certificates	in	relation	to	FAR	§	91.203(a)(1).	The	size,	weight	and	enclosed	operational	

area	of	Aerial	Media	One	Inc. UAS	permits	exemption	from	Part	21	because	AM1	UAS	meet	

(and	exceed)	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	Act.	The	

FAA	is	authorized	to	exempt	aircraft	from	the	airworthiness	certificate	requirement	under	

both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	of	the	Reform	Act.	Both	pieces	of	

legislation	permit	the	FAA	to	exempt	UAS's	from	the	airworthiness	certificate	requirement	

in	consideration	of	the	weight,	size,	speed,	maneuverability	and	proximity	to	areas	such	as	

airports	and	dense	populations.	Aerial	Media	One	Inc.’s	current	and	projected	UAS's	meet	

or	exceed	each	of	the	elements.

14	C.F.R.		45.23	(b)	
14	C.F.R.	45.23	(b) requires when	aircraft	marks	only	include	the	capital	letter	“N”	and	the	

registration	number	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	that	2	

inches	nor	more	than	6	inches	high,	the	words	“limited,”	“restricted,”	“light	sport”	

“experimental,”	or	“provisional,”	as	applicable.

Our	UAS	are,	by	definition,	unmanned.	They	therefore	do	not	have	a	cabin,	cockpit	or	pilot	

station	on	which	to	mark	certain	words	or	phrases.	Further,	two-inch	lettering	is	difficult	to	

place	on	such	small	aircraft	with dimensions	smaller	than minimal	lettering	requirement.	

Aerial	Media	One	Inc.	will	mark	its	UASs	in	the	largest	possible	lettering	by	placing	the	

word	“EXPERIMENTAL”	on	all fuselages as	required	by	14	C.F.R.	§45.29	(f)	so	that	Aerial	

Media	One	Inc.,	the	assisting	spotter,	or	others	working with	the	UAV	will	see	the	markings.	

The	FAA	has	previously	issued	exemptions	to	this	regulation	through	Exemptions	Nos.	

8738,	10167,	10167A	and	10700.

14	C.F.R.		61.113	(a)	&	(b)

14	CFR	61.113 (a) Private	Pilot	privileges	and	limitations:	Pilot	in	Command	and	61.133	

Commercial	privileges	and	limitations.

The	regulation	provides	that	no	person	who	holds a	Private	Pilot	certificate	may	act	as	pilot	

in	command	of	an	aircraft	in	connection	with	any	business	of	employment	if:	(1) The	flight

is	only	incidental	to	that	business	or	employment;	and	(2)	The	aircraft	does	not	carry	

passengers	or	property	for	compensation	or	hire.		Our	proposed	operations	require	that	

the	PIC	hold	at	least	a	Private	Pilot	Certificate	issued	by	the	FAA	and	since	the	aircraft	

cannot	carry	passengers	or	property,	we	feel	we	meet	the	intent	of	61.113	Subparagraph	

(b)	even	though	the	intent	of	this	application	is	to	conduct	a	business.

14	C.F.R.		91.7	(a)

14	CFR	91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	certificate.

As	no	such	certificate	will	be	applicable	in	the	form	completed	by	the	FARs,	this	regulation	

is	inapplicable.

14	C.F.R.		91.9	(b)	(2)

14	CFR	91.9	(b)	(2)	Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

This	regulation	provides	that	no	person	may	operate	an	aircraft	unless	a	current,	approved	

flight	manual	is	in	the	aircraft.	We	assume	that	the	intent	of	this	requirement	is	to	ensure	

that	flight	manual	information	is	available	to	the	aircrew	while	operating	the aircraft.	We	

request	an	exemption	to	this	requirement	since	the	aircraft	is	not	only	too	small	to	carry	

documentation,	but	the	documentation	would	not	be	available	to	the	crew	during	flight	

operations.	To	obtain	an	equivalent	level	of	safety	and	meet	the	intent	of	91.9,	we	propose	
that	a	current,	approved	sUAS	Flight	Manual	must	be	available	to	the	crew	at	the	ground	

station	anytime	the	aircraft	is	in or	preparing	for	flight.	

14	C.F.R.		91.103

14	C.F.R.	§	91.103:	Preflight	action

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	

insure	the	safety	of	flight.	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.		91.109

14	CFR	91.109	Flight	Instruction;	Simulated	instrument	flight	and	certain	flight	tests.	

The	regulation	states, "No	person	may	operate	a	civil	aircraft	that	is	being	used	for	flight	

instruction	unless	that	aircraft	has	fully	functioning	dual	controls."	The	sUAS	system	

ground	based	control	station	consists	of	a	handheld	radio	transmitter	and	while	it	does	not	

offer	a	second	set	of	"controls,” both	the	student	and	instructor	can,	and	will,	operate	the	

single	set	of	controls	simultaneously.	With	both	student	and	instructor	having	"hands-on"	

the	controls	during	flight,	this	technique	meets	the	intent	91.109	and	provides	an	

equivalent	level	of	safety

14	C.F.R.		91.119

91.119	Minimum	safe	altitudes:	General.

The	regulation	states	that	over	sparsely	populated	areas	the	aircraft	cannot	be	operated	

closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure.	Since	the	typical	mission	of	

the	sUAS	would	be	photography	or	survey	of	persons,	vessels,	vehicles	or	structures, it	

would	be	necessary	to	operate	closer	than	500	feet	to	the	items	listed.	Operations	will	only

be	flown	over	property	or	people	where	permission	has	been	obtained	and	careful	preplanning has	been	performed.	The aircraft	will	be	operated at	a	low	altitude	allowing,	if	a	

power	unit	fails,	an	emergency	landing	without	undue	hazard	to	persons	or	property	on	

the	surface.	Therefore	we	maintain	that	due	to	the	small	size	of	the	UAS,	the	hazard	to	

persons,	vehicles	and	structures	is	minimal	compared	to	manned	aircraft,	which	should	be	

considered	in	granting	the	exemption.	

14	C.F.R.		91.121

CFR	91.121	Altimeter	settings.
The	regulation	requires	that	aircraft	shall	maintain	cruising	altitudes	by	reference	to	an	

altimeter	setting	available	within	100	NM	of	the	aircraft.	The	sUAS	will	always	fly	below	

400	feet	AGL	and	will	not	need	to	maintain	cruising	altitudes	in	order	to	prevent	conflict	

with	other	aircraft.	An	Above	Ground	Level	altimeter	measurement	above	the	takeoff	point	

is	transmitted	via	radio	from	the	sUAS	on-board	computer	to	the	display	screen	held	by	the	

PIC,	providing	a	constantly	updated	AGL	readout.

14	C.F.R.		91.151	(a)

14	CFR	91.151	(a)	Fuel	requirements	for	flight	in	VFR	conditions.

The	regulation	provides	that	no	person	may	begin	a	flight	in	an	airplane	under	day VFR	

conditions	unless	there	is	enough	fuel	to	fly	to	the	first	point	of	intended	landing	and	to	fly	

after	that	for	at	least	30	minutes.	We	feel	the	intention	of	this	paragraph	is	to	provide	an	

energy	reserve	as	a	safety	buffer	for	delays	to	landing.	The	sUAV	is	battery	operated	and	

the	maximum	duration	of	flight	from	a	single	battery	charge	is	12	minutes	with	a	20%	

reserve.	Since	the	aircraft	will	never	fly	more	than	3⁄4	Nautical	Miles	from	the	point	of	

intended	landing,	a	full	battery	charge	at	launch	will	ensure	that	we	meet	the	reserve	

energy	requirement	of	this	paragraph.	We	request	an	exemption	to	the	word	"fuel"	and	ask	

for	an	equivalent	interpretation	with	the	word	"energy.”

14	C.F.R.		91.203	(a)	&	(b)

14	CFR	91.203(a)	&	(b)	Civil	aircraft:	Certifications	required.

The	regulation	provides	that	an	airworthiness	certificate,	with	the	registration	number	

assigned	to	the	aircraft	and	a	registration	certificate	must	be	aboard	the	aircraft.	

Additionally,	subparagraph	(b)	provides	that	the	airworthiness	certificate	be	"displayed	at	

the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew."	At	a	maximum	

gross	weight	of	less	than	13 pounds,	the	sUAS	is	too	small	to	carry	documentation,	does	not	

have	an	entrance,	and	is	not	capable	of	carrying	passengers	or	crew.	To	obtain	an	

equivalent	level	of	safety	and	meet	the	intent	of	91.203,	we	propose	that	documents	

deemed	appropriate	for	this	aircraft	by	the	FAA	will	be	co-located	with	the	crew	at	the	

ground	control	station	and	available	for	inspection	upon	request.	In	order	to	identify	the	

aircraft,	we	propose	that	the	information	found	on	airworthiness	and	registration	

certificates	be	permanently	affixed	to	the	aircraft	via	placard	containing	the	applicable

information	plus	the	word	

"EXPERIMENTAL"	to	satisfy	the	requirement	of	14	CFR	45.23.	

14	C.F.R.		91.401	– 91.417

14	CFR	Subpart	E	91.401-91.417	Maintenance,	Preventive	Maintenance,	Alterations.

The	regulation	provides	that	the	operator	is	primarily	responsible	for	maintaining	the	

aircraft	in	an	airworthy	condition,	including	compliance	with	part	39	and	43.	Paragraphs	

91.407	and	91.409	require	that	the	aircraft	be	"approved	for	return	to	service	by	a	person	
authorized	under	43.7"	after	maintenance	and	inspection.	The	PIC will perform	

maintenance	and	inspection	of	the	aircraft	and	"be	authorized	to	approve	the	aircraft	for	

return	to	service."	The	PIC	will	ensure	that	the	aircraft	is	in	an	airworthy	condition	prior	to	

every	flight	and	in	addition	conduct	detailed	inspections	after	every	two	hours	of	flight.	

Maintenance	and	repair	will	be	performed	by	the	PIC,	as	the	PIC	has	proven	knowledge	and	

experience	with	UAS	maintenance	and	repair. The	PIC	will	document	work	performed	in	

accordance	with 91.417.	We	feel	that	due	to	the	size,	construction,	and	simplicity	of	the	

aircraft,	the	PIC	can	ensure	an	equivalent	level	of	safety.

Additional	Information	in	Support	of	Request:	

Aerial	Media	One	Inc.	currently	has	two	multirotor	aircraft.		First	a “Flying	Cinema,	

Cinetank	MK2L”	quad	rotor.		This	aircraft	weighs	4.5	pounds	ready	to	fly.		Its speed	is	less	

than	50kts,	and	a	GPS	enabled	flight	controller	allows	for	added	safety	with	fail-safe	return	

to	launch,	and	auto	land	features.			Second,	a	“Carbon	Core	950”	hexacopter.		This	aircraft	

has	a	ready	to	fly	weight	of	12.2	pounds.		The	airspeed	on	this	aircraft	is	also	less	than	

50kts	and	the	very	robust	flight	control	system	allows	for	GPS	guidance	and	fail-safe	

systems.

Aerial	Media	One	Inc.	keeps	detailed	flight	logs	of	each	of	our	aircraft.		This	coupled	with	a	

detailed	pre-flight	inspection	and	flight	time	based	maintenance/inspection	intervals,	

allows	Aerial	Media	One	Inc.	to	keep	our	aircraft	flying	safely,	by	spotting	potential

problems	before	they	arise.

Aerial	Media	One	Inc.	President,	and	Pilot	in	Command,	Mark	McBride,	has	been	operating	

UAS	since	2008.		He	has	proven	himself	to	be	a	safe, knowledgeable	pilot,	and	UAV	

Technician.		With	a	background	as	an	ASE	master	certified	automotive	technician,	and	

electrical systems	expert,	he	is	able	to	maintain	and	repair	UAS	to	the	highest	level	of	

safety.		Mark	McBride	currently	hold	a	Class	3	airman	medical,	and	is	working	to	obtain	a	

private	pilot	license.		As	of	the	time	of	this	letter	he	holds	22.5	hours	of	instructional	flight	

time,	2.5	hours	Pilot	in	Command,	has	completed	an	FAA	approved	ground	school,	and	is	

preparing	to	take	the	FAA	written	exam.		We	believe	that	these	credentials	prove	that	

Aerial	Media	One	Inc.	can	operate	in	a	safe	manner with	regard	to	privacy	of	citizens	and	

property	while	maintaining	low	risk	operations	within	the	national	airspace	system.

Sincerely,

Mark	McBride,	President

Aerial	Media	One	Inc.

8115	Grenada	Drive

Brighton,	MI	48116

517.404.1930