**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 1 of 10 Docket	No.	FAA
- 2015
- 0331 March	31 st,	2015 U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave,	SE Washington,	DC	20590 **Re:** Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation	Regulations	from 14	CFR Part 21 , 14 CFR	45.23 ; 14	CFR 91.7(a);	91.9(b) (c)(d) ; 14	CFR	91.103 ; 14	CFR	91. 119 ;	14	CFR	91 .121; 14	CFR 91.151; 14	CFR 91.203; 14	CFR	91.205;	14	CFR 91.405; 14	CFR 91.407; 14	CFR 91.409; 14	CFR 91.417
. To	Whom	It	May	Concern: I ,	Michael	Joseph	Indovi na,	am	writing	pursuant to the	FAA	Modernization	and Reform	Act	of	2012	and	the	procedures	contained	within	14	C.F.R.	11,	to	request th at	I,	Michael	Joseph	Indovina ,	an	active	Airline	Transport	Pilot	(ATP),	Certified Flight	Instructor	(CFI)	and	owner	and	o perator	of	small	unmanned	aircraft,	be exempted	from	the	Federal	Aviation	Regulations	(FARs)	listed	below	so	that	I	may operate	my	small	light	weight	Unmanned	Aircraft	System	(UAS)	commercially	in airspace	regulated	by	the	Federal	Aviation	Administration	( FAA). As	described	herein	I,	Michael	Joseph	Ind ovina,	licensed	ATP/CFI /MEI with	a background	in	the	last	decade	consisting	of	operating	as	a	full	time	commercial	pilot including	part
- 135	on
- demand	charter	operations	and	Mike	Six	Aerial	Imaging photography business	and	hobby	on	the	side .		I am also	experienced	in	flyin g	hobby remotely	controlled (RC) aircraft	for	recreational	purposes. I	have	a	hobby	grade Tarot	680	Pro hexa
- copter **1** UAS which	contains a	small,	lightweight	Sony	Nex
- 5 DSLR	camera	fixed	onto a gimbal	with	the	sole	intent	for	aerial	still
frame/cinematography	to	be	used	in	commercial	real	estate	and	personal,	private venue	photography;	following	ex emption	and	approval	by	the	FAA,	which	would thereby	reduc e the	use	of	physical manned aircraft fo r my	operations
. I	have	flown	small	RC	aircraft	for over	2	decades	(nearly	25	years)	without	incident and	am	committed	to	safety	with	each	flight. My,	Michael	Joseph	Indovina 's, exemption	request	would	permit	operation	of	my	lightweight,	UAS	(piloted	by myself	under remote	control) which	would	alleviate	the already	congested traffic load i n	the	National	Airspace	System	(NAS) .		F li ght	in	predetermined	areas	away from	the	general	public,	any	airports,	heliports	and	vehicular	traffic	within	the property	boun daries	for	individual	homeowner	real estate	listing or	private	venue videos/photos. There	are	c urrently plenty	of similar	lightweight	remotely controlled	UAS's that	are operated	daily	by	unmonitored and	unlicensed amateur hobbyists,	without	any	safety	plans, proper	FAA	Regulation	or	NAS	education,
**1** A ppendix A

– Tarot 680 Pro Operator Manual**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 2 of 10 limitations	or	controls	in	place	to	prevent	catastrophes. I,	Michael Joseph Indovina, have	personally	instilled	safety	pro tocols	and	controls **2** to	avoid	and	prevent	public hazard,	as	well as manned	aircraft	hazards/catastrophe.	This	will	act	to	further safety	protocols	exclusive	to	lightweight	UAS's	specific	to	real	estate and/ or	video cinematography	usage as	I,	Michael	Joseph Indovina,	record all flight	data collected through	permitted	flight	operations to	assist the	FAA with	any future	protocol	and safety	regulation s . My	UAS’s	August	2014	design,	plan	and	construction	were	carefully	considered when	installing	this	system.		T he	choice	of	6	power
- plant	motors	over	4	added	an extra	edge	and	added	protection	from	the	unexpected	event	of	a	sudden,	in
- flight power	or	rotor - blade	failure.		The	Flight	Controller	is	manufactured	by	APM	(3dr robotics)	a	vastly	tested	and	trusted	compan y	in	the	industry,	which	contains	an internal,	3
- axis	gyroscope	for	ship	leveling	and	a	barometric	altitude	sensor	which offers	altitude	hold	operations.		The	GPS	antenna	and	on
- board	compass	module	can be	used	for	position	logging,	position	hold,	GPS	guid ed,	and	return	to	launch	and/or failsafe	operations.		The	flight	controller	also	transmits	pitch	&	roll,	airspeed, altitude,	magnetic	heading,	battery	voltage,	and	GPS	latitude	&	longitudinal	data	to the	ground	station	for	an	added	level	of	control.		Semi
- Permanently	fixed	top
center - ship	are	2 batteries	that	provide	up	to	20	minutes	of	flight	between swapping,	and	are	wired	in	parallel	to	cover	the	event	of	a	sudden	loss	of	current from	each	other.		Redundancy	was	at	the	forefront	of	mind	in	the	design. Radio	control	is	accomplished	via	a	2.4	GHz,	pre
- bound	(singular	bonded)	signal with	frequency	hopping	technology	to	prevent	signal	interference	or	interruption.		A 933MHz	signal	is	established	between	ground	control	unit	(laptop	&	APM	software) and	APM	co ntroller,	operated	as	an	optional	unit	for	the	displayed	flight information.		All	of	the	UAS	RF	signals	are	FCC	compliant. Numerous	test	flights	of	the	3	flight	modes **3** :	GPS	Loiter,	Return	to	Launch,	Altitude Hold;	and	failsafe	operations:	loss	of	radio	co ntrol	signal	or	low	battery	voltage triggering	either	immediate	landing	or	a	return	to	the	launch	position	and	land	were all	meticulously	and	cautiously	executed	at	a	safe	and	controlled	field.		Each	flight session	begins	with	an	extensive	preflight	inspec tion	of	all	power	plants,	propellers and	frame	structure,	flight	mode	conditions,	flight	data	read
- out	display	and	flown only	after	all	have	been	deemed	satisfactory	for	flight,	pursuant	to	14	CFR	section 91.7(b).		A	wireless	connection	to	a	base	station, a	separately	powered	Apple	laptop running	APM	software	that	provides	a	up
- to - the
- second	active	display	of	the	flight mode,	flight	attitude,	ship	altitude	and	airspeed,	latitude	&	longitude	position	and battery	voltage.		All	maintenance	and	repairs	have,	an d	always	will	be,	performed	by myself	with	compatible	and/or	identical	parts,	logged	and	tested	prior	to	any subsequent	flight.		Again,	safety	is	a	key	principle	value. The	PIC	of	this UAS is	myself,	Michael	Joseph	Indovina	VI,	and	is	directly	responsible for	the	operation	of	this	UAS.
**2** Appendix B

– Safety Protocols and Flight Controls **3** Flight Modes Available: Stabilize, GPS Loiter, Altitude Hold, & Return to Launch. See Appendix A

– Flight Modes**Michael Joseph Indovina VI, A TP** **/CFI, Mike Six Imaging -**  **Section 333 Exemption Petition**

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 3 of 10 I	have	proven	myself	true	in	my	flight	career	to	date,	an ATP	Pilot with	over	4,50 0 flight	hours and	a	turbo
-jet	PIC	rating, and	hold	a	first	class	medical	certificate.		With this	UAS,	I	have	currently	logged	61	flights,	and	accumulated	more	than	7 flight hours.		I believe	that	the	medical standards	for	all UAS pilots sh ould	be	such	that mimic	regulations	for	flight	of	manned	aircraft	under	FAR	parts	61	&	91. Granting my, Michael	Joseph	Indovina ’s, request	comp lies with	the	Secretary	of Transportation’s	(FAA	Administrator’s)	responsibilities	and	authority	to	not	only integrate	UAS's	into	the	national	airspace	system,	but	to	“...establish	requirements for	the	safe	operation	of	such	aircraft	systems	[UAS's]	in	the	national	airspace system”	under	Section	333(c)	of	the	Reform	Act	specific	to	the	use	of	UAS's	for cinematography	purpos es . Further	I, Michael	Joseph	Indovina,	will	conduct	my operations	in	compliance	with	the	protocols	described	herein	or	as	otherwise establ ished	by	the	FAA
. For	the	reasons	stated	below	I, Michael	Joseph	Indovina,	respectfully	request	the grant	of	an	exemption	allowing	me	to	operate my	lightweight,	remote ly	controlled UAS to reduce	manned	aircraft	operations	in	the	NAS	while	also	to	benefit/ stimulate attraction	and enhance	real	estate and	private	venue listing photos	& videos	for homeowners and	clients who	cannot	afford	expensive	manned	aircraft	for	the	same purpose. My	operations will	promote	local	economic	growth	through	increased sales	an d	increased	tax	base;	all with	public	safety	in	mind	by reducing	the	use	of much heavier	manned	aircraft containing	combustible	fuel,	which	continually poses potential	public	hazard s . **I.	Contact	Information:** Michael	Joseph	Indovina	VI , ATP	CFI MEI
- 31468 73 Mike	Six	Imaging 8000	West	Manchester	Ave.	#222 Playa	Del	Rey,	CA	90293 Phone :	( 805)	455
- 9041 Email: VI@mikesix.com **II**
. **Specific	Sections	of	Title	14	of	the	Code	of	Federal	Regulations	From	Which Michael	Joseph	Ind**  **ovina Requests	Exemption**  **:** 14	CFR	21; 14	CFR 45.23; 14	CFR 91.7 (a) ; 14	CFR	91.9	(b)(c)(d); 14	CFR	91.103	(b); 14	CFR	91.119; 14	CFR	91.121; 14	CFR	91.151; 14	CFR	91.203; 14	CFR 91.2 05 ; 14	CFR : 91. 40 5 , 91.407, 91.409 ,	and 91.41 7
.**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 4 of 10 **III.	The	Extent	of	relief Michael	Joseph	Indovina**  **seeks	and	the Reason	He**  **Seeks	Such	Relief:** I, Michael	Joseph	Indovina ,	submit	this	application	in	accordance	with	the	Reform Act,	112	P.L.	95	§§	331
- 334,	seeking	relief	from	any	currently	applicable	FARs operating	to	prevent	me, Michael	Joseph	Indovina , educated	Commercial and	Airline Transport	Pilot,	from flight	operations with a	UAS within	the NAS
. The	Reform	Act in	Section	332	provides	for	such	integration	of	civil	unmanned	aircraft	systems	into our	national	airspace	system	as	it	is	in	the	public’s	in terest	to	do	so. My, Michael Joseph	Indovina ’s ,	lightweight	UAS certainly meets	the	definition	of	“small unmanned	aircraft”	as	defined	in	Section	331	and	therefor	the	integration	of	my lightweight	UAS	is	expressly	contemplated	by	the	Reform	Act. The	Refo rm	Act guides	the	Secretary	in	determining	the	types	of	UAS's	that	may	operate	safely	in our	national	airspace	system. These	considerations	include the weight,	size,	speed and	overall	capabilities	of	the	UAS ;	whether	the	UAS	will	be	operated	near	airports and/ or heavily	populated	areas;	and,	w hether	the	UAS	will	be	operated	by	line	of sight.	112	P.L.	95 §	333 (b)1 .	Each	of	these	items reflects in	favor	of	an	exemption for	me, Michael	Joseph	Indovina
. My	UAS	utilizes six	(6 )	counter
- rotating	prop ellers for balance,	control, stability and	safety
. My	UAS	is	equipped	with	GPS	and battery voltage auto	return	safety	technology. Weighing	less	tha n	ten	(10 )	pounds	(far below	the	maximum 55
- pound limit) including	camera	with	gimbal. As	with	any	aircraft,	f

light	operations	would	be	tailored	to	meet	the	need	to	prepare, prevent	and	reduce	the	risk	of any injuries	or	events	for	each	flight	by	maintaining	a clear	and	unobstructed	area	below	the	ship	while	it	is	in	flight. It	is	that I, Michael Joseph	Indovina, consider	safety foremost	with	each	flight. My	small, unmanned aircraft	is	designed	to	hover	in	place	via	G PS	and	operate	in	less	than 20 knots (23 mph)	wind velocity
. For	safety,	stability	and	fear	of	financial	loss	I	will	n ot	fly	in sustained winds	exc eeding	15 knots (17 mph). Built	in	safety	systems	include	a	GPS Loiter mode	that	allows	my	UAS	to	hover	in	place	when	radio	controls	are	released. With three flight modes	to	choose	from,	I	utilize	the Loiter mode **4** for	aerial videography /photography. Th is	is	the	safest,	most	reliable	and	stable	mode	to prevent	accidents or hazard s . If communication	is	lost between	the UAS and	the PIC ,	with	an	adequate	GPS	signal the	ship is	designed climb	to	a	pre
- determined safe altitude	of sixty	(60)	feet,	and	return directly	to	the	launching	spot and slowly descend	to a	safe	landing
. I	do	not	operate	my	UAS	near	airports,	Hos pitals	or	po lice heliports,	and	do	not	o perate	near	areas	where	the	general,	uninvolved public	is within	fifty ( 50) feet, depending	on	location
. Flight	conditions will	be	conducted during	daylight	hours	(sunrise	to	sunset)	and	at	all	times	maintain	clear	of	clouds. Operations	in	visible	moisture	will	be	strictly	prohibited
. I, Michael	Joseph	Indovina, and	the	flight	observer will	be	constantly alert	for	any	manned	aircraft (Police/Medical	helicopters,	etc.)	and	prepared	to	land/abort	immediately	to	the nearest	and	safest	ground	point	should	a	manned	aircraft	approach , or suspect that a manned	aircraft	approach	near	my	location. My	UAS	is	capabl e	of	vertical	and horizontal	operations,	and	are	flown	only	within	my visual line
- of
- sight,	as	the remote	control Pilot	In	Command.
**4** See Appendix B

– Safety Protocols and Flight Controls**Michael Joseph Indovina VI, A TP** **/CFI, Mike Six Imaging -**  **Section 333 Exemption Petition**

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 5 of 10 Utilizing	battery	power	rather	than	combustible	fuels,	flights will generally	last between five	(5) to	ten	(10) minutes,	with	an	altitude below two hundred	( 20 0)	feet AGL
. I, Michael Joseph	Indovina,	utilize fresh, fully	charged	batteries with	each	flight as	a	safety	precaution;	full	flight	time	limit	for	each	battery set is fifteen ( 15 )	to twe nty ( 20 ) minutes	as	tested. I	do	not	operate	my	UAS	at	or	below	manufacture recommend minimum	charge	levels	for	operation;	preferring	to	remain	well	within a	safe	operating	range	to	insure	adequate	communication	between	radio	c ontrol and	UAS	to	eliminate	potential	for	crash,	loss	of	control	or	hazard. Fully	charged r eserve	batteries	are	at	hand	with	each	exercise	to	insure	replacement	for	sufficient safe	level	of	operation. I	do	not take risks that would cause	a crash	or create	hazard to	the	public/property/manned	aircraft,	and	have absolutely	no	desire	to	lose	o n my investment. I	have logged numerous	practice	flights	in	remote	areas	as	a	hob byist, simulating	flights	for	future	commercial	use	to	gain	familiarization	with the characteristics	of	this	specific	UAS's	performance	under	different	temperature s and atmospheric weather	conditions ,	and	to	date	have	more	than	7 flight hours with	this UAS. I, Michael	Joseph	Indovina,	am	extremely	cautious when	operating	of	my UAS/lightweight	unmanned	aircraft	and	will	not	“create	a	hazard	to	users	of	the national	airspace	system	or	the	public.”	112	P.L.	95	§	333	(b). Given	the	small	size and	weight	of	my	UAS , it	falls	well	within	Congress’s	contemplated	s afety	zone	when it advocated the	Reform	Act	and	the	corresponding	directive	to	integrate	UAS's	into the	national	airspace	system. My, Michael	Joseph	Indovina ’s UAS used	in	hobby flight,	has	a	demonstrable	safety	record	and	does	not	pose	any	threat	to	the general public	or	national	security.
**IV.	How Michael	Joseph	Indovina** **’s	Request	Will	Benefit	the	Public	As	A	Whole:** Aerial	videography	for	geographical survey, real	estate	marketing,	and	for	the theatrical	film	industry has	been	around	for quite	some	time through	manned	fixed wing	aircraft	and rotorcraft
. For	small	budget	real	estate	companies	and	average homeowners	the	expense	of	such	aerial	videography	is	cost	prohibitive. Only	large companies	and	high	end	Realtors	or	luxury	homeowners	c an	afford	to	absorb	such an	expense,	which	d eprives non - luxury	homeowners	and	lower	budget	Realtors from	a	valuable	marketing	tool. Manned	aircraft	pose	a	threat	to	the	public	through potential	catastrophic	crash	that	the aviation community	has	experience d numerously with airspace and	ground	terrain congestion, nearly e ach	situation causes combustible	fuel to ignite on	impact	and often	results	in subsequent loss	of life. Manned	aircraft	operations have had	to	make	emergency	landings	within the city	limits and	as	the	city	continually	grows,	options	for	such	are	greatly diminishing
. My, Michael	Joseph	Indovina 's,	UAS	pose	no	such	threat	since its size and	lack	of	combustible	fuel	alleviates	any	potential	threat	to	the	public,	and	is	much easier	to	maneuver to	a	safe	landing	under	conditions	any	manned	aircraft	can obtain
. Congress	has	already	proclaimed	that	it	is	in	the	public’s	interest	to	integrate**Michael Joseph Indovina VI, A TP** **/CFI, Mike Six Imaging -**  **Section 333 Exemption Petition**

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 6 of 10 commercially	flown	UAS's	into	the	national	airspace	system,	hence	the	passing	of the	Reform	Act. Granting my, Michael	Joseph	Indovina ’s,	exemption	request furthers	the	public	interest	through reducing	potential	threats	of	manned	aircraft incidences
. Furthermore,	my	lightweight	UAS	is	battery	powered	and	creates	no emissions	that	can	harm	the	environment. Th e consequence	of	my	lightweight	UAS crashing	is	far	less	than	a	full	size	helicopter	or	fixed	wing	aircraft;	which	are extremely heavy,	contain many	gallons combustible	fuel	and	can	cause	catastrophic devastation	to	the	public. M inimizing	ecological and crash	threats furthers	th e	public’s	interest	by permitting aerial	video/photo	capturing th rough the	use	of battery	operated, lightweight	UAS's. Permitting	me, Michael	Joseph	Indovina,	to	immediately	fly	within the	NAS continues economic	growth. Granting	my	exemption	request will	substantially further the	economic	impact	for	the greater	Los	Angeles community	for	companies looking	to	relocate	or	build	in	the	area	as	well	as	individuals	looking	to survey properties
. Both	of	which	serve	as	a	stimulu s	to	the	community,	and	national economy. **V.	Reasons	Why Michael	Joseph	Indovina**  **’s	Exemption	Wi ll	Not	Adversely**  **Affect	Safety	and/o r	How	The	Exemption	Will	Provide	a	Level	of	Safety	At**  **Least	Equal	To	Existing	Rule:** My, Michael	Joseph	Indovina ’s,	exempti on	will	not	adversely	affect	safety,	and	it	is with	my	utmost	desire	to	comply	within	your	authorization,	to	minimize	the potential	risks,	hazards	and/or	unnecessary	congestion	to	the	National	Airspace System	where	applicable,	and	eliminate	any	imposed	thr eats	to	any	person	or property	to	the	uninvolved.		By	permitting	this	exemption,	you will	allow	the logging of more flight	time	in NAS , communication	with	the	FAA,	and	allow me	to continue to contribute with my	longstanding	support	i n	the	growing	aviation industry.		This would further	build	my	reputation	of	safety,	performance	and	reliability	in	the	face of	the	FAA, and	my ATP oath	of	good	moral	character,	to	the	public	for	the	growing NAS	structure	at	the	forefront	of	today’s	technology	and	changing	times with	my operations development	in	cooperation	with	the	FAA. In	addition	I, Michael	Joseph	Indovina,	submit	the	following	representations for	the exemption	of	Section	333	for	Mike	Six	Imaging :

 My	UAS	weighs	less	than 10 pou nds	complete	with	a 3
- axis	cam era	gimbal	and small, lightweight, high	quality Sony	Nex
- 5	DSLR camera;  I	only	operate	my	UAS	below	200 Above	Ground	Level	(AGL) **5** (well	within	the 400	foot	permissible	ceiling	set	by	the	FAA	Modernization	and	Reform	Act	of 2012);  M y	UAS	only	operate s for 5
- 10	minutes	per	flight,	or	within	80%	charged	level ;  I	land	my	UAS	prior	to manufacturer	recommended minimum	of	20%	battery charge,	6	minutes	of	tested	flight	time	remaining	as	reserves ;  I	pilot	my	UAS	through	remote control only by visual line
- of
- sight;**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 7 of 10  My	UAS	has	GPS	a	flight	safety	feature	whereby	it r eturns to l aunch	position	or hovers	and	then	slowly	lands	if	communication between th e UAS and	the	P ilot In Command is	lost;  I	actively	analyze	flight	data	and	other	sources	of	information	to	constantly up date	and	enhance	safety	protocols;  I	only	operate	in	reasonably	safe	environment	that is strictly	controlled,	away from	power	lines,	elevated	lights,	airport s	and	actively	populated	areas;  I	conduct	extensive	pre
- flight	inspections	and	protocol,	during	whi ch	safety carries	primary	importance and keep	an	extensive	flight	log	including maintenance	performance	tests,	removal,	repair	&	preventative	maintenance with	return	to	service	descriptions ;  I	always	obtain all	necessary	permi ssions	prior	to	operation;	and have procedures	in	place	to	abort	flights	in	the	event	of	safety	breaches	or	potential danger. My, Michael	Joseph	Indovina ’s,	safety	protocols	provide	a	level	of	safety	equal	to	or exceeding	existing	rules. It	is	important	to	note	that	absent	the	integr ation	of commercial	UAS	into the NAS ,	helicopters and	other	fixed	wing	aircraft are	the primary	means	of	aerial	video	and	photography	for aerial	survey/photo /cinematography
. While	the	safety	record	of	such aircraft	are remarkably astounding,	there	has	been a	plethora	of incidents involving	loss	of	life	as	well	as extensive	property	damage;	it	is	far	safer	to operate	a	battery	powered,	lightweight UAS. First,	the	potential	loss	of	life	is	diminished	because	UAS's carry no	people	on board	and	only	operate in	specific	areas	away	from	mass	populations. Second,	there is	no combustible fuel	on	b oard	my UAS	and	thus	the	potential	for	fire	or	explosions is	greatly	diminished. Third,	the	small	size	and	extreme	maneuverability of	my	UAS allow	me	to	remotely	pilot	away	from	and	a void	hazards	quickly	and	safely
. Accordingly,	my	UAS has	and	always	will continue	to	operate	at	and	above	current safety	levels. **VI. Summary**  **The	FAA	May	Publish	in	the	Federal	Register :**  14	CFR 21 ,	14	C FR	45	and	14	CFR 91 A. 1 4	CFR 21,	Subpart	H,	entitled	Airworthiness	Certificates,	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	my, Michael	Joseph	Indovina’s,	UAS	pe rmits	exemption	from	Part	21	because	my	UAS meets	(and	exceeds)	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	a nd	dense populations.
**5** Tarot 680 Pro Maximum Altitude set to 400 feet AGL in any Flight Mode. See Appendix A

– Geo Fence**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 8 of 10 My,	Michael	Joseph	Indovina’s,	current	and	projected	UAS's	meet	or	exceed	each of	the se elements. B. 14	CFR	§	45.23:	Aircraft Markings. Applicable	Codes	of	Federal	Regulation require	aircraft	to	be	marked	according	to	certain	specifications.		My	UAS	is,	by definition,	unmanned.		It	therefore	does	not	have	a	cabin,	cockpit	or	pilot	station on	which	to	mark	certain	words	or	phrase s.		Furthermore,	two
- inch	lettering	is difficult	to	impossible	to	place	on	such	small	aircraft	with	dimensions	smaller that	minimal	lettering	requirement.		Regardless,	I	will	mark	its	UASs	in	the largest	possible	lettering	by	placing	the	word	“EXPERIMENTAL ”	on	its	fuselage as	required	by	14	C.F.R.	§45.29	(f)	so	that	I	the	Pilot	In	Command,	or	anyone assisting	me	as	a	spotter	with	the	UAV	will	see	these	markings.		The	FAA	has previously	issued	exemptions	to	this	regulation	through	Exemptions	Nos.	8738, 10167 ,	10167A	and	10700. C. 14	CFR	91.7 P rohibits	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	§	91.9 Requires	an	aircraft	flight	manual	in	the	aircraft. As	there	are	no on	board	pilots	or	passengers,	and	given	the	size	of	the	UAS's,	this	Regulation	is inapplicable. An	equivalent	level	of	safety	will	be	achieved	by	maintaining a safety/flight procedures	f orm, delineating	areas	of	where	safety	can	be	defined
. **6** T he	FAA	has	previously	issued	exemptions	to	this	regulation	in exemption	Nos. 8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	10700 and	32827. 14	CFR	§	91.103 P reflight	action	of	the	PIC	shall	determine	all	applicable information	of	intended	airports	of	use,	and	take off/landing	performance	data. Gross	weight	and	atmospheric	conditions	pertaining	to	the	changes	of	density altitude	and	performance	characteristics	of	aircraft	would	no t	be	applicable	to the	operation	of	my	UAS. 14	CF R 91.119:	Prescribes	m inimum	Safe	Altitudes. My	UAS	will	never	operate at	an	altitude	greater	than	200 Above	Ground	Level	(AGL) ;	safely well below	the standard	of	400	AGL. I, Michael	Joseph	Indovina ,	will however, operate	my	UAS in	safe	areas	away	from	public	and	traffic,	providing	a	level	of	safety	at	least equivalent	to	or	below	those	in	relation	to	minimum	safe	altitudes. Given	the size,	weight,	maneuverability	and	speed	of	my	UAS,	an	equivalent	or	hig her	level of	safety	will	be	achieved. This	should	not	apply	as	the	UAS	does	not	fly	at	these flight	altitudes,	and	is	it	at	all	times	in	a	position	to	make	an	emergency	landing without	undue	hazard	to	persons	or	property	on	the	surface.

**6** Appendix B

– Safety Protocols and Flight Controls

– Flight Procedures Form**Michael Joseph Indovina VI, A TP** **/CFI, Mike Six Imaging -**  **Section 333 Exemption Petition**

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 9 of 10 14	CFR §	91.121 Regarding	altimeter	settings	is	inapplicable to my	UAS	utilizes electronic G lobal P ositioning System	with	a	barometric	sensor,	and	calibrated from	the	launch	position	rather	than	to	a	standard	datum	plane
. 14	CFR	§	91.151	Requires	excess	fuel	to	be	carried	onboard	the	aircraft	as	a means	of	reserves,	based	on	daylight	or	night	conditions.		This	UAS	does	not carry	fuel	and	maximum	flight	times	are	less	than	what	is	required	in this section .		H owever, safety	measures	are	in	place	regarding leaving a	certain	level of	charge onboard to	ensure	adequate	power to	complete flight	operations. 14	CFR	§	91.203 provides	for	the	carrying	of	civil	aircraft	certifications	and registrations. They	are	inapplicable	for	the	same	reasons	described	above. The equivalent	level	of	safety	will	be	achieved	by	maintaining	any	such	required certifications	and	registrations	by	me, Michael	Joseph	Indovina
. 14	CFR	§	91.205	Required	instruments	and equipment	list.		None	of	these	items apply	to	the	flight	operations	of	my	UAS. 14	CFR	91.405 ; 91.407;	91.409;	91.411,	91.413	and	91.417 :	Maintenance Inspections. The	above
- cited	r egulations	require,	amongst	other	things,	aircraft owners	and	operators	to “have	[the]	aircraft	inspected	as	prescribed	in	subpart E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part 43	of	this	chapter...” These	Regulations	o nly	apply	to	aircraft	with	an	airworthiness	certificate. They will	not,	therefore,	apply	to	my, Michael	Joseph	Indovina 's,	UAS. However,	as	a safety	precaution	I	inspect	my	UAS	before	and	after	each	flight. **Michael	Joseph	Indovina seeks	an	exemption	fr** **om	the	following	Regulations:** 14	CFR	21	(h) ;	14	CFR	45.23;	14	CFR	§	91.7	(a);	14	CFR	§	91.9	(b)(c) (d);	14	CFR	§ 91.103;	14	CFR	§	91.119;	14	CFR	§	91.121;	14	CFR	§	91.151 ;	14 CFR	§	9 1.203;	14 CFR	91.205; 14	CFR §	91.405;	14	CFR §	91.407 ;	14	CFR § 91.409;	and,	14	CFR §91.417 It	is	i n	c onclusion,	with	my,	Michael	Joseph	Indovina’s , declaration	of	purpose	and stated	limitations	within	this	document,	I	submit	to	you	this	formal	request	for exemption for	me,	Michael	Joseph	Indovina, to	commercially	op erate	my, Michael Joseph	Indovina 's,	small	unmann ed	vehicle/lightweight	unmanned aircraft	vehicle in video	cinematic and	real	estate	operations,	and to enhance	the	experience	of those	seeking	to	relocate or	discover	new	venues within	the	greater	Los	Angele s area . Currently,	area	awareness	and	real	estate	aerial	videography/photography relies	primarily	on	the	use	of	larger	aircraft	running	on	combustible	fuel. Posing a highly potential	risk	to	the	public. Granting	my, Michael	Joseph	Indovina ’s,	request fo r	exemption	will	reduce	current	risk	levels	and	thereby	enhance	safety, with	my plan	to	offer	a	creative	twist	to	my	photography	business	with	the	usage	of	my**Mi chael Joseph Indovina VI, A**  **TP /CFI, Mike Six Imaging**  **- Section 333 Exemption Petition** 

Michael	Joseph	Indovina	VI,	ATP
- CFI
- MEI ,	Mike	Six	Imaging,	Los	Angeles	CA

– Section	333	Exemption	Petition Page 10 of 10 personal	UAS rather	than	fixed	wing,	manned	aircraft
. My	UAS	craft	do es not contain	potentially explosive	fuel,	is	smaller,	lighter	and	more maneuverable	than c onventional,	manned	aircraft, significantly less	pollutant	and	economically beneficial
. Further,	I	operate	at	lower	altitudes	and	in tightly controlled	airspace	eliminating potential	public risk from	putting	themselves	into	unnecessary	harm
. Formal collection of flight	data information is	stored	and	can	be	shared	with	the	FAA	in hopes	to enhance	the	FAA's	internal	efforts in establish ing protocols	for	complying with	the	FAA	Modernization	and	Reform	Act	of	2012. There	are	no	personnel	on board	my, Michael	Joseph	Indovina ’s,	UAS	and	therefore	the	likelihood	of	death	or serious	bodily	injury	is	significantly	diminished. My, Michael	Joseph Indovina ’s, operation of	my	UAS,	weighing	less	than	10 pounds	and	travelling	at very	slow speeds	within	limited	areas	will	provide	an	equivalent	level	of	safety	as	that achieved	under	current	FARs. Accordingly	I, Michael	Joseph	Indovina ,	respectfully requ est	that	the	FAA	grant	my exemption	request	and	I	am willing	to	cooperate	in sharing	information	to	benefit	the	FAA, the safety	of	manned	aircraft,	and	the general	public	at	large. Thank	you	for	your	consideration.

Respectfully;

Michael	Josep h	Indovina	VI ATP	CFI	MEI:		3146873 Mike	Six	Imaging 8000	West	Manchester	Ave.	#222 Playa	Del	Rey,	CA	90293 Phone :	( 805)	455
- 9041 Email: VI@mikesix.com www.mikesix.com