U. S. Department of Transportation
Docket Management System

1200 New Jersey Ave.

W

ashington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

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, Mako Media LLC (Mako Media), a Florida based limited liability company operating Small Unmanned Aircraft System (sUAS) equipped to conduct aer ial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so l ong 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 exemption is similar to previous FAA issued grants of exemption including but not limited to Ex emption Nos. 11062, 11109, 11112, 11213 and 11295.



### Regarding the UAS

All commercial sUAS flights conducted by Mako Media will consist of a minimum of a pilot and observer. The pilot will be responsible for safe operation of the sUAS. The observer is

resp onsible for keeping a constant visual on the sUAS, and reporting any potential obstacles to the pilot. Flights will be performed only after potential obstacles have been accounted for, and a safe minimum and maximum altitude will be determined prior to th e flight.

Mako Media will only pilot a n s UAS after completing an extensive pre

- flight checklist that will consist of but not be limited to the following:

• Inspect weather and wind conditions

• Verify location is greater than 5 miles from nearest airport

• Check the sky for any obstacles that may prevent unsafe UAS operation

• Inspect all rotors and blades and ensure that they are installed correctly and are not damaged

• Ensure GPS mode is enabled to help maintain control and positioning of the aircraft at
all times

• Check that the compass is calibrated and is responding normally

• Set the home location of the aircraft to return to in the event of a loss of signal

• Ensure the takeoff point is a safe distance from any foot activity or obstructions

• Ensure the connection of controller to UAV

Mako Media, LLC | www.makonetwork.com | (407) 412

- 9586

### Regarding the Unmanned Ai **rcraft PIC**

All of Mako Media's pilots will be required to demonstrate their knowledge and skill in sUAS operation prior to being utilized for commercial applications. All training and practice will take place on private property with the owner's permissio n, and will be conducted under a Mako Media approved sUAS pilot or observer.

Any PIC or observer who is unable to demonstrate their ability to operate a sUAS in a safe manner will not be considered for commercial flights.



### Regarding the Operation of the **Unmanned Aircraft**

Our comme rcial activities would include: The requested exemption would permit Mako Media LLC to pursue its commercial interests in providing services to consumers interested in aerial photography using a small advanced sUAS in the following areas:

• Aerial Photography and Videography for the real estate, construct ion, and utilities
industries

• Aerial Photography for private sporting events such as triathlon, marathons, and general

races

All of Mako Media's s UAS flights that will occur over private or controlled access property will do so with the property owner's prior consent and knowledge. Only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured in any photos or videos.

sUAS Safety Procedures We are petitioning from exemption to enable Mako Media to operate a series of UAS platforms that have been previously approved by exemption. Namely:

DJI Phantom 3 Professional

- Similar to Exemption 11310
DJI Phantom 3 Advanced

- Similar to Exemption 11 398
DJI Phantom 3 Standard DJI Inspire 1

The sUAS uses an operating radio f requency of 2.400

- 2.483 as outlined in the aircraft's
documen tation. Doc umentation on the sU AS is not provided with this application as it has already been considered when approving other exemption requests.

Mako Media, LLC | www.makonetwork.com | (407) 412

- 9586These s UAS all we igh less than 55 lbs, have a built

- in capability to limit the height flown above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return to Home and will land safely.

This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions.

The above specifications meet standards listed below:

• Mako Medi a will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public."

• Mako Media will not operate sUAV within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a
COA issued to Mako Media.

• Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the
60 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more
than 400 feet AGL.

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safety requirement s.

We respectfully request exemption under Section 333 to enable Mako Media to operate safe,
low

- risk commercial sUAV operations for the activities stated. RFS at all times will respect the space and privacy of citizens and property whilst keeping our skies safe.



### Exemption Requests and Equivalent Level of Safety

Mako Media requests an exemption from the following regula tions as well as any additional regulations that may technically apply to the operation of the sUAV System:

14 CFR Part 21 subpart H

Mako Media, LLC | www.makonetwork.com | (407) 412

- 9586The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given the size, weight, speed, and limited operating area associated with the
aircraft to be utilized, I request exception. In the restricted environment and under the
conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be
needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment "DJI
Pilot Training". An equivalent level of safety will be provided by established pre

- flight protocols

to properly match the machine.

14 CFR 61.23 Medical Certificates The regulation provides that a person requires a first or second class medical to act as pilot in Command of an aircraft for compensation or hire. Since the aircraft cannot carry passengers or property, we feel we meet th e intent of 61.23 even though the intent of this application is to
conduct a business.

14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, o r Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. 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 CFR 91.7 Civil Aircraft Airworthiness This Section prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inap plicable.

14 CFR 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 persons where permission has been obtained and careful pre

- planned 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.

Mako Media, LLC | www.makonetwork.com | (407) 412

- 958614 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 abo ve 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 CFR 91.151 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

rese rve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM fr om 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". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use: This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace must be equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations. Due t o the small size and lifting capabilities of our UASs we cannot carry a traditional transponder. All of our operations will be under 250’ if we are operating within the 30mi reach of a mode c vail.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventi ve 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 "app roved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

The PI C 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 performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. W e feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Mako Media, LLC | www.makonetwork.com | (407) 412

- 9586

### How this Request is to the Betterment of our Communit **y**

We believe that our services will contribute to the safe advancement of aerial imaging. The
ability to use a sUAV to capture aerial images and video in place of a helicopter will eliminate

unnecessary risks that are assumed with larger aircraft. Further, the unmanned aircraft does
not carry any persons or flammable liquids, reducing public exposure in the event of an

incident. The unmanned aircraft can be launched and recovered f rom the property in which we are contracted to image, reducing the need to overfly public and private properties.



### Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" COAs to applicants requesting exemptions from the Federal Aviation Regulations
under Section 333 of the FAA Modernization and Reform Act of 2012.

The Applicant hereby requests that a "blanket" COA that conforms to the te rms set forth in https://www.faa.gov/news/updates/?newsId=82245 upon approval of Mako Media ’ s exemption request.

Sincerly,

Richard Anderson Owner and Operator Mako Media, LLC
503 San Sebastian Prado Altamonte Springs, FL 32714 (407) 412

- 9586

Mako Media, LLC | www.makonetwork.com | (407) 412

- 9586