Michael A. Comella

1509 Bultman Rd.

Madison WI, 53704

(608) 509-1341

ComellaFilms@gmail.com

www.recordthis.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H

14 CFR 45.23(b) 14 CFR 61.113(a) and (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 

14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2) 14 CFR 91.417(a) and 

(b)

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

and 14 CFR Part 11, Michael Comella, operator of Unmanned Aircraft Systems (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of designated UAS, provided such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 

333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news-gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS.

As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the 

safe operation of such aircraft systems in the national airspace system.”
I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned 

aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a 

quad-copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that 

are driven by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s.

Given the small size of the UAS involved and the restricted controlled environment within which 

it will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UAS and the controlled areas in which the 

relevant UAS will operate, approval of the application presents no national security issue. Given 

the following, the grant of the requested exemptions is clearly in the public interest: Michael 

Comella proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which Michael 

Comella agrees to be bound when conducting commercial operations under an FAA issued 

exemption including:

1. The UAS will weigh less than 55 lbs 

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes.

4. Flights will be terminated at 15% battery power reserve.

5. Flights will be operated at an altitude of no more than 400 feet AGL

6. UAS operator will be trained and certified in the proper safety and operations of the UAS.

7. The UAS will only operate within a controlled area as defined in the Procedures.

8. The operator will post advisor notice around the controlled area.

9. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required.

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land.

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and 

are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

additional information or clarifications are needed.

Respectfully, 

Michael A. Comella