Robert	M	Serrini

316	24th	Street

Manhattan	Beach,	Ca	90277

(917)	282-8042

www.robertoserrini.com

Petition	for	Exemption	14	CFR	§	11.81

Robert	Serrini	and	his	company,	Serriniverse	LLC.,	is	seeking	Exemption	

from	the	following	FAA	regulations	of	14	CFR	11.81:

14	CFR	PART	SUMMARY	OF	REGULATION	

Part	21	Airworthiness	Certification	

21, Subpart H Certification procedures for products and parts, Airworthiness Certificates 

Part	61	Certification:	Pilots,	Light	Instructors,	and	Ground	Instructors	

Part	91	General	Operating	and	Flight	Rules	

91.103(b)(2) Preflight action 

91.105 Flight crewmembers at stations 

91.109 Flight instruction 

91.119 Minimum safe altitudes 

91.121 Altimeter settings 

91.151 Fuel requirements for flights in VFR conditions 

91.405 Maintenance required 

91.407 Operation after maintenance 

91.409 Inspections 

91.417 Maintenance records 

Robert	Serrini	is	seeking	total	exemption	within	the	rights	of	the	law	in	order	to

operate	safely	a	UAV	for	commercial	purposes	within	the	United	States.

The	request	would	benefit	the	public	in	the	following	ways:

1) Robert	Serrini	is	an	award	winning,	socially	influential	film	director	and	

content	creator.	His	use	of	UAV	footage	will	further	the	arts	of	motion	

photography,	and	serve	as	entertainment	as	well	as	information	for	the	

public	at	large.

2) Robert	Serrini’s	work	as	a	commercial	director	directly	has	an	influence	on	

the	economy,	and	by	being	able	to	use	UAV	footage,	he	will	be	able	to	more	

effectively	stimulate	the	economy	through	his	commercial	work.	

3) Robert	Serrini	is	a	strong	believer	in	transparency,	and	in	sharing	his	

knowledge	of	craft	with	those	wishing	to	learn	it.	By	being	able	to	lawfully	

operate	a	UAV,	and	proving	that	the	system	does	work	in	a	safe	manner,	

upholding	the	FAA’s	desire	to	create	“the	safest	airspace	in	the	world”	he	can	
then	spread	this	knowledge	to	others,	strengthen	the	system,	and	directly	

upholding	the	goals	of	the	FAA.

Exception	from	the	parts	of	Rule	14	CFR	as	stated	above	will	allow	Robert	Serrini	to	

fulfill	his	need	to	fly	a	UAV	lawfully	and	safely	in	accordance	with	the	FAA.	He	will	

still	operate	the	craft	within	all	legal	parameters	as	other	governing	bodies	rule	

(such	as	local	law,	federal	law,	workman’s	comp,	Motion	Picture	and	Film	

regulations).		This	would	apply	within	the	United	States,	or	abroad,	where	he	will	be	

a	delegate	for	proper	FAA	regulation	and	following	proper	rules	of	conduct.	

Roberto	Serrini	has	won	several	awards	for	his	film	work,	and	has	been	a	conscious	

UAV	operator	since	2012.	His	knowledge	of	his	aircraft	is	that	of	a	master;	

understanding	each	component,	its	proper	use,	how	to	fix	and	regulate	it,	and	

proper	flying	method.	He	is	a	member	of	the	AMA	in	good	standing,	and	a	champion	

for	safe	UAV	flying.	He	is	a	co-founder	of	the	New	York	Drone	Film	Festival,	which	

seeks	to	educate	and	inform	the	public	of	the	abilities	of	UAV’s	and	their	safe	usage.	

He	has	never	damaged	any	property	or	person	piloting	his	UAV	and	his	large	online	

social	presence	is	used	as	a	platform	to	reinforce	the	benefit	of	legally	and	safely	

operating	UAV’s.	In	short,	he	is	seeking	exemption	from	14	CFR	so	that	he	can	

continue	to	properly	operate	his	UAV	and	continue	to	educate	the	public	of	proper	

usage.

Further	Specific	information:

1)	Type	of	craft,	and	how	craft	will	be	flown	safely	to	minimize	risk:	I	own	3	DJI	

Phantom	2	UAVs.	Each	UAV	is	kept	in	its	own,	pro,	Pelican	Case	to	keep	the	craft	

safe	during	storage	and	travel.	Each	craft	weighs	1000g,	has	a	max	flight	speed	of	

15m/s,	prop	guards,	and	soft	weighted	props	(not	carbon	fiber).	The	crafts	are	

checked	before	and	after	each	TAKE	OFF,	to	ensure	that	props,	rotors,	gimbal,	

landing	skids,	and	communication	systems	are	in	perfect	working	order.	Crafts	

are	tested	before	each	day	of	usage	before	flying	in	open	air	to	ensure	that	all	

systems	are	running	properly.	Firmware	and	computer	diagnostics	are	run	

routinely	to	ensure	all	components	are	working	and	up	to	date.	Craft	is	always	

flown	below	200	feet,	in	areas	that	comply	with	all	FAA	and	other	governing	

authority	laws,	and	always	at	least	20	feet	away	from	any	human	or	animal.		

Aircrafts	are	flown	with	constant	VLOS	and	are	equipped	with	video	feeds	for	

added	visual	guidance.	Crafts	are	never	flown	in	poor	flying	conditions	where	

weather	or	wind	is	an	issue,	and	weather	charts	are	checked	regularly	to	insure	

there	is	no	sudden	change.	The	area	of	flight	is	walked	before	flying	to	ensure	

that	the	pilot	is	aware	of	all	conditions	before	taking	off.	The	craft	is	equipped	

with	safety	measures	that	limit	speed	and	height,	as	well	as	if	there	is	a	loss	in	

radio	signal	or	battery	failure	that	it	will	return	safely	to	its	point	of	lift	off.	Crafts	

have	prop	guards,	as	well	as	water	safety	balloons	in	case	of	water	landings.	

Crafts	have	all	lighting	in	constant	working	condition,	and	are	painted	stock	

white	to	increase visibility.	
2) Pre-Flight,	Maintenance,	and	Repair	to	ensure	safest	possible	conditions:	A	

physical	check	of	the	aircraft	and	all	components	are	done	visually.	Testing	

the	rotors	and	props	by	hand,	and	communication	between	the	radio	and	

craft	before	lift	off.	Aircraft	is	equipped	with	on	board	safety	measures	to	

ensure	that	if	signal	is	lost	from	the	radio	it	will	return	to	the	location	it	took	

off	from	safely.	Any	system	that	is	not	in	perfect	order	or	physical	piece	of	the	

craft	that	is	not	as	it	should	be	is	replace	and	retested	immediately.	

3) Radio	and	transmissions	on	craft:	The	craft	uses	a	2.4GHz	ISM	Futuba	

controller	that	can	directly	control	every	aspect	of	the	aircrafts	movement.	It	

has	a	3000m	range,	but	is	always	flown	with	a	VLOS.	It	also	has	a	5.8GHz	

video	transmitter	that	feeds	live	video	from	a	GoPro	4	camera	mounted	to	a	

Zenmuse	Gimbal.

4) Pilot	history	and	certification:	Robert	Serrini	has	been	flying	consistently	

since	2012	with	thousands	of	hours	of	flight	time,	and	zero	incidents	of	

crashes	or	damages.	He	is	a	member	of	the	AMA	in	good	standing,	Holds	a	

GOES	Global	Entry	Card	(983841173),	clean	driving	record,	both	D	and	M	

Class	(NYS	725	796	720),	clean	felony	record,	hold	teaching	credentials	in	

California,	and	Duel	Citizenship	with	the	US	and	EU.

5) Medical	Standards:	Robert	Serrini	is	certified	in	CPR	and	covers	full	medical	

insurance	and	workman’s	comp	insurance	for	all	commercial	jobs.

6) Intended	UAS	Operation:	The	craft	will	be	used	mainly	for	landscape	and	

motion	filming	for	commercial	and	documentary	films.	Operating	with	a	

VLOS,	below	200	feet,	and	safely	away	from	any	living	body,	within	any	and	

all	legal	areas.	At	least	5	miles	from	any	airport,	helicopter	landing	pad,	or	

flight	path,	considerate	of	migrating	bird	paths	and	nature.	These	are	slow,	

small	UAVs	meant	for	sweeping	landscape	shots,	and	are	flown	responsibly.	

7) Maximum	Speed	and	Altitude,	other	hazards	or	considerations:	Max	speed	

will	be	5	m/s	to	maintain	control	and	filming	consistency.	Max	altitude	of	75	

meters.	Staying	well	clear	of	any	physical	hazard,	electrical	lines,	radio	

interference,	and	maintaining	a	clear	link	with	at	least	5	GPS	signals	to	

ensure	controlled	flight	at	all	times.

8) Intended	area	of	flight:	In	the	continental	US	and	abroad	in	areas	designated	

for	UAV	flight,	or	are	secured	by	the	proper	authorities	and	permitted	legally.	
9) Intention	of	flying	in	restricted	zones/airports:	none.

10)	Intention	of	operating	with	VLOS:	Constant.	

11) Procedures	implemented	for	preflight	safety	risks:	physical	check	of	aircraft,	

props,	rotors,	guards,	lights	in	proper	order,	skids,	camera	and	gimbal	

secured	with	safely	plug	intact.	Air	balloon	attached	for	emergency	water	

landing.	Radio	and	craft	properly	charged	and	in	perfect	communication.	

Engines	responsive.	Craft	able	to	lock	on	to	at	least	5	GPS	signals	for	added	

guidance.	Walking	intended	area	of	flight	to	makes	sure	all	obstacles	and	

terrain	is	noted.	Safety	meeting	with	all	people	present	to	make	sure	they	are	

aware	of	the	drone,	its	location	at	all	times,	and	how	to	act	safely	around	the	

aircraft.	Medical	team	on	hand	if	an	accident	occurs.	Ability	to	call	for	

additional	help,	known	location	of	fire/hospital,	and	transportation	available	

if	needed.	Drones	to	be	kept	locked	in	their	intended	cases	when	not	in	use.	

12)	Intent	to	notify	proper	authorities	of	flight	(FSDO,	Law	Enforcement,	MP&T	

filming):	All	local	and	national	law	enforcement	and	other	governing	bodies	

will	be	notified	before	flight	will	happen.	Any	permits	or	permission	that	

needs	to	be	secured	will	be	had	before	flight.

13)	Intent	to	obtain	a	COA:	Yes.

http://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_p

etition/media/FAA_UAS_Civil_COA_Request.pdf