Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition

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Docket	No.	FAA-2015-0331

March	31st,	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	Indovina,	am	writing	pursuant	to	the	FAA	Modernization	and	

Reform	Act	of	2012	and	the	procedures	contained	within	14	C.F.R.	11,	to	request	

that	I,	Michael	Joseph	Indovina,	an	active	Airline	Transport	Pilot	(ATP),	Certified	

Flight	Instructor	(CFI)	and	owner	and	operator	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	Indovina,	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	flying	hobby	

remotely	controlled (RC) aircraft	for	recreational	purposes.	 I	have	a	hobby	grade	

Tarot	680	Pro	hexa-copter1 UAS	which	contains a	small,	lightweight	Sony	Nex-5	

DSLR	camera	fixed	onto	a	gimbal	with	the	sole	intent	for	aerial	stillframe/cinematography	to	be	used	in	commercial	real	estate	and	personal,	private	

venue	photography;	following	exemption	and	approval	by	the	FAA,	which	would

thereby	reduce the	use	of	physical	manned	aircraft for 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	in	the	National	Airspace	System	(NAS).		Flight	in	predetermined	areas	away	

from	the	general	public,	any	airports,	heliports	and	vehicular	traffic	within	the	

property	boundaries	for	individual	homeowner	real estate	listing	or	private	venue	

videos/photos. There	are	currently	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

Appendix A – Tarot 680 Pro Operator Manual
Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition

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limitations	or	controls	in	place	to	prevent	catastrophes. I,	Michael	Joseph	Indovina,	

have	personally	instilled	safety	protocols	and	controls2 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	regulations.

My	UAS’s	August	2014	design,	plan	and	construction	were	carefully	considered	

when	installing	this	system.		The	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	company	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	guided,	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	topcenter-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	controller,	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	modes3:	GPS	Loiter,	Return	to	Launch,	Altitude	

Hold;	and	failsafe	operations:	loss	of	radio	control	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	inspection	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,	and	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, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition

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I	have	proven	myself	true	in	my	flight	career	to	date,	an	ATP	Pilot	with	over	4,500	

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 should	be	such	that	

mimic	regulations	for	flight	of	manned	aircraft	under	FAR	parts	61	&	91.	 Granting	

my,	Michael	Joseph	Indovina’s, request	complies 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	purposes.	 Further	I,	Michael	Joseph	Indovina,	will	conduct	my	

operations	in	compliance	with	the	protocols	described	herein	or	as	otherwise	

established	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,	remotely	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	and	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	hazards.

I.	Contact	Information:

Michael	Joseph	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

II.	Specific	Sections	of	Title	14	of	the	Code	of	Federal	Regulations	From	Which	

Michael	Joseph	Indovina 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	91.205;

14	CFR: 91.405, 91.407, 91.409,	and	91.417.
Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition

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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	interest	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	Reform	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,	whether	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	propellers	

for balance,	control,	stability and	safety.	 My	UAS	is	equipped	with	GPS	and	battery	

voltage	auto	return	safety	technology.	 Weighing	less	than	ten	(10)	pounds	(far	

below	the	maximum	55-pound limit) including	camera	with	gimbal.

As	with	any	aircraft,	flight	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	GPS	and	operate	in	less	than 20 knots (23

mph)	wind velocity.	 For	safety,	stability	and	fear	of	financial	loss	I	will	not	fly	in	

sustained	winds	exceeding	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 mode4 for	aerial	

videography /photography.	 This	is	the	safest,	most	reliable	and	stable	mode	to	

prevent	accidents or	hazards.	 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,	Hospitals	or	police	

heliports,	and	do	not	operate	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	capable	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
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Utilizing	battery	power	rather	than	combustible	fuels,	flights	will	generally	last	

between	five	(5) to	ten	(10)	minutes,	with	an	altitude	below two hundred	(200)	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	

twenty (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	control	

and	UAS	to	eliminate	potential	for	crash,	loss	of	control	or	hazard.	 Fully	charged	

reserve	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	on my

investment. I	have	logged numerous	practice	flights	in	remote	areas	as	a	hobbyist,	

simulating	flights	for	future	commercial	use	to	gain	familiarization	with the	

characteristics	of	this	specific	UAS's	performance	under	different	temperatures 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	safety	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	can	afford	to	absorb	such	

an	expense,	which	deprives 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	experienced	

numerously with	airspace and	ground	terrain congestion,	nearly	each	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	
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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.	 The 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.

Minimizing	ecological	and crash	threats furthers	the	public’s	interest	by permitting	

aerial	video/photo	capturing through	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	stimulus	to	the	community,	and	national	

economy.

V.	Reasons	Why	Michael	Joseph	Indovina’s	Exemption	Will	Not	Adversely	

Affect	Safety	and/or	How	The	Exemption	Will	Provide	a	Level	of	Safety	At	

Least	Equal	To	Existing	Rule:

My,	Michael	Joseph	Indovina’s,	exemption	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	threats	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	in	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 pounds	complete	with	a	3-axis	camera	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);

 My	UAS	only	operates 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;
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 My	UAS	has	GPS	a	flight	safety	feature	whereby	it	returns	to	launch	position	or	

hovers	and	then	slowly	lands	if	communication	between the	UAS and	the	Pilot	In	

Command	is	lost;

 I	actively	analyze	flight	data	and	other	sources	of	information	to	constantly	

update	and	enhance	safety	protocols;

 I	only	operate	in	reasonably	safe	environment	that	is strictly	controlled,	away	

from	power	lines,	elevated	lights,	airports	and	actively	populated	areas;

 I	conduct	extensive	pre-flight	inspections	and	protocol,	during	which	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	permissions	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	integration	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	board	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	avoid	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	CFR	45	and	14	CFR 91

A. 14	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	permits	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	and	dense	

populations.	

5 Tarot 680 Pro Maximum Altitude set to 400 feet AGL in any Flight Mode. See Appendix A – Geo Fence
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My,	Michael	Joseph	Indovina’s,	current	and	projected	UAS's	meet	or	exceed	each	

of	these 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	phrases.		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 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	§	91.9 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	form, delineating	areas	of	where	safety	can	be	defined.

6		

The	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	Preflight	action	of	the	PIC	shall	determine	all	applicable	

information	of	intended	airports	of	use,	and	takeoff/landing	performance	data.		

Gross	weight	and	atmospheric	conditions	pertaining	to	the	changes	of	density	

altitude	and	performance	characteristics	of	aircraft	would	not	be	applicable	to	

the	operation	of	my	UAS.

14	CFR 91.119:	Prescribes	minimum	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	higher	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
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14	CFR §	91.121	Regarding	altimeter	settings	is	inapplicable	to	my	UAS	utilizes	

electronic	Global	Positioning	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.		However, 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	regulations	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	only	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	from	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	§	91.203;	14	

CFR	91.205;	14	CFR §	91.405;	14	CFR §	91.407;	14	CFR § 91.409;	and,	14	CFR	

§91.417

It	is	in	conclusion,	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	operate	my,	Michael	

Joseph	Indovina's,	small	unmanned	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	Angeles	

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	

for	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	
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personal	UAS rather	than	fixed	wing,	manned	aircraft. My	UAS	craft	does not	

contain	potentially explosive	fuel,	is	smaller,	lighter	and	more maneuverable	than

conventional,	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 establishing 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	

request	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	Joseph	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