U. S. Department of Transportation

Docket Management System

1200 New JerseyAve.

Washington, DC 20590

RE: Exemption Request Section 333 of the FAAReformAct 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 aerial 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 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 exemption is similar to previous FAA issued grants of 

exemption including but not limited to Exemption 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 

responsible 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 the flight.

Mako Media will only pilot an sUAS 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 Aircraft 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 permission, 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 commercial 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, construction, and utilities 

industries

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

races

All of Mako Media's sUAS 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 11398

DJI Phantom 3 Standard

DJI Inspire 1

The sUAS uses an operating radio frequency of 2.400 - 2.483 as outlined in the aircraft's 

documentation. Documentation on the sUAS is not provided with this application as it has 

already been considered when approving other exemption requests.

Mako Media, LLC | www.makonetwork.com | (407) 412-9586
These sUAS all weigh 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 Media 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 requirements. 

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 regulations 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) 412-9586
The 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 withoutsaid restrictions.

14 CFR 91.103

As FAAapproved flight manuals will not be provided for the aircraft an exemption will be

needed. Normal proceduresincluding 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 ofsafety 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 the 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, or 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 

inapplicable.

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) 412-9586
14 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 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 

reserve 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 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". 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 to 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, 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. 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 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 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. We 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 Community

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 from 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 terms 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