Harbor Media Group 

239 West May Street 

Benton Harbor, Michigan 49022 

May 1, 2015 

U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

RE: Exemption Request Section 333 ofthe FAA Reform Act of Federal Aviation Regulations 

(14 CFR 45.23(b), 14 CFR Part 21, 14 CFR 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 

119.121, 91.15l(a), 91.203 (a) and (b), 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b)) 

Dear Sir or Madam: 

Harbor Media Group is writing pursuant to the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 20 12 and the procedures contained within 41 CFR 11 to request that Harbor Media Group, which 

utilizes small unmanned aircraft\ be exempted from the Federal Aviation Regulations (FAR) listed below so that 

Harbor Media Group pilot Jim Stringer may operate a small lightweight unmanned aircraft system (UAS) 

commercially in airspace regulated by the FAA. 

As described herein, Harbor Media Group pilot Jim Stringer is experienced in testing and flying hobby helicopters 

for recreational purposes. Harbor Media Group has added a hobby grade quad-copter UAS to its inventory, equipped 

with an internal camera of extremely high quality and a removable 4GB micro SD card. It shoots full HD video at 

1 080p/30fps and 720p/60fps with intent for aerial videography/cinematography to enhance academic community 

awareness for those individuals and companies unfamiliar with the geographical layout of the Southwest Michigan 

area and augment real estate listing videos, following exemption and approval by the FAA. Thereby, enhancing 

academic research experience for the greater Southwest Michigan region. 

I (Jim Stringer) have flown small RC electric helicopters and fixed wing planes for over four years without 

incident as I am committed to safety with each flight. Harbor Media Group's exemption request would permit 

operation of lightweight (less than Sibs), unmanned (piloted via remote control) and comparatively inexpensive 

UAS(s) in tightly-controlled and limited airspace. 2 This predetermined airspace will be in areas away from general 

public, airports, helipads, and vehicular traffic for community videos and within property boundaries for individual 

homeowner real estate listing videos and/or photos. Currently, unmonitored amateur hobbyists with no safety plan or 

controls in place to prevent catastrophe legally operate similar lightweight remote-controlled UASs. The pilot of 

Harbor Media Group has personally instilled safety protocols and controls3 to avoid and prevent public hazard as 

well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UASs 

specific to real estate video and photography usage as recorded flight data and other information gained through 

permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol 

and safety regulation. 

Granting Harbor Media Group's request comports with the Secretary of Transportation's and FAA 

Administrator's responsibilities and authority to not only integrate UASs into the national airspace system, but to 

"establish requirements for the safe operation of such aircraft systems (UASs) in the national airspace system" 

under Section 333(c) of the Reform Act specific to the use ofUASs for real estate purposes. Further, Harbor Media 

Group will conduct operations in compliance with the protocols described herein or as otherwise established by the 

FAA. 

1 Appendix A - DJI Phantom Vision 2+ Quad-copter Operator Manual 

" Appendix B - Southwest Michigan Regional Airport Map area with 5-mile airport radius maps 3 Appendix C - Personal Protocols and Control 
Harbor Media Group 

Drone Exemption Application Page 2 

For the reasons stated below, Harbor Media Group respectfully requests the grant of an exemption allowing 

them to operate lightweight, remote-controlled UASs for academic community awareness to benefit/stimulate 

attraction to the greater Southwest Michigan area and to enhance real estate listing videos for homeowners who 

cannot afford expensive manned aircraft for the same purpose. Both of which will promote local economic growth 

through increased employment and tax base. All with public safety in mind by keeping heavier manned aircraft 

containing combustible fuel that poses potential public hazard. 

Contact Information: 

Harbor Media Group, 239 West May Street, Benton Harbor, Michigan 49022 

Randy Willis, Owner, 269-252-3090, hrbrphoto@gmail.com 

Jim Stringer, Pilot 331-725-9432, jimbostringer@gmail.com 

Specific Sections of Title 14 of the Code of Federal Regulations from which Harbor Media Group Requests 

Exemption From: 

14 CFR 45.23(b), 14 CFR Part 21, 14 CFR 61.113(a) and (b), 91.7(a), 91.9(b)(2), 9l.l03(b), 9l.l09, 119.121, 

91.151(a), 91.203 (a) and (b), 91.405(a), 91.407(a)(I), 91.409(a)(2), 9l.417(a) and (b) 

The Extent of Relief Harbor Media Group Seeks and the Reason It Seeks Such Relief 

Harbor Media Group submits this application in accordance with the Reform Act, 112 PL 95 § §331-334 

seeking relief from any currently applicable FARs operating to prevent Harbor Media Group's contemplated 

commercial, cinematic, academic, and other flight operations within the national airspace system. 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. Harbor Media Group's ultra-lightweight UAS meets the definition of"small 

unmanned aircraft" as defined in Section 331, and, therefore, the integration of my ultra-lightweight UAS is 

expressly contemplated by the Reform Act. We would like to operate the ultra lightweight UAS prior to the time 

period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing 

direct experience and valuable information for formal regulation that can be administered uniformly to all real 

estate-related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of 

UASs that may operate safely in our national airspace system. Considerations include the weight, size, speed and 

overall capabilities of the UASs, whether the UAS will be operated near airports or heavily-populated areas, and 

whether the UAS will be operated by line of sight. 112 PL 95 §333(a). Each of these items reflect in favor of an 

exemption for Harbor Media Group. 

Our UAS utilizes four (4) counter-rotating propellers for balance, control, and stability. Our UAS is 

equipped with GPS and auto-return safety technology. The UAS weighs less than five (5) lbs., which is far below 

the maximum 55 lb. limit, including the camera with gimbal. 

Harbor Media Group considers safety as foremost with each flight. Our small-unmanned aircraft is 

designed to hover in place via GPS and operate in less than 36 mph wind. For safety, stability and fear of financial 

Joss, we will not fly in winds exceeding I 0 mph. The built-in safety systems include a GPS mode, allowing our UAS 

to hover in place when radio controls are released. While there are three modes to choose from, we utilize Smart 

Mode4 for aerial videography/photography. This is the safety, most-reliable, and stable mode to prevent accident and 

hazards. When pilot communication is lost with the UAS, it is designed to slowly descend to the point of takeoff. 

We do not operate the VAS near airports, hospitals/police heliports, or near areas where general public is within 

fifty to one-hundred ( 50-1 00) yards, depending on location, conditions, and weather. We are constantly on alert for 

any manned aircraft (police/medial helicopters, etc.) and are prepared to land or abort immediately to the nearest and 

safest ground point should a manned aircraft approach our location or we suspect manned aircraft may approach the 

4 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home 

feature, and safety control to return home or land in the event of communication interruption between RC 

transmitter and UAS. Details are included in Appendix A (Owner's Manual). 
Harbor Media Group 

Drone Exemption Application Page 3 

location. Our UAS is capable of vertical and horizontal operations are flown only within my line of sight ofthe 

operator/pilot as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last 

between three and seven (3-7) minutes with an altitude that will not exceed one-hundred fifty (150) feet. 

Harbor Media Group utilizes a fresh, fully-charged battery with each flight as a safety precaution; full flight 

time is limited to 25 minutes each battery (as tested). We do not operate the UAS at or below manufacturerrecommended minimum charge levels for operation and prefer 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. 

Reserve batteries are on-hand with each exercise to insure replacement for sufficient safe level of operation. We do 

not believe in taking risks that may cause a crash that could create a hazard to the public, property or manned 

aircraft and have no desire to lose an investment. We have clocked numerous practice flights in remote areas as 

hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of this specific 

U AS's performance under different temperature and weather conditions. We also practice computerized flight 

simulations to maintain adequate skills and response reflex time. All of this is done to insure safety at all times. 

Harbor Media Group is extremely cautious when operating the UAS or other ultra lightweight unmanned 

aircraft and will not "create a hazard to users of the national airspace system or the public" (112 PL 95 §333(b )). 

Given the small size and weight of the UAS, it falls well within Congress' contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. 

Harbor Media Group's UAS- used in hobby flight- has a demonstrated safety record and does not pose any threat 

to the general public or national security. 

How Harbor Media Group's Request Will Benefit the Public As a Whole: 

Aerial videography for geographical awareness and real estate marketing has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget real estate companies and the average 

homeowner, the expense of such aerial videography is cost-prohibitive. Only large companies and high-end realtors 

or luxury homeowners can afford to absorb the expense, depriving the non-luxury and lower budget homeowner and 

realtor from a valuable marketing tool. 

Congress has already proclaimed that it is in the public's interest to integrate commercially flown UASs 

into the national airspace system by passing the Reform Act. Furthermore, the Michigan Legislature passed HCR 

165 (sponsored by the owner of Eagle-Eye Drone Service) in December 2013, supporting Michigan's Advanced 

Aerial Systems Consortium as one of the test sites designated by the FAA. 

Granting Harbor Media Group's exemption request furthers the public interest through academic/ visual 

awareness of the geographical benefits in and around the greater Southwest Michigan area. Our ultra lightweight 

UAS crashing is battery-powered and creates no emission that can harm the environment. The consequence of our 

ultra lightweight UAS crashing is far less than a full-size helicopter or fixed-wing aircraft, which are heavy, contain 

combustible fuel, and can cause catastrophic devastation to the public. The public's interest is furthered by 

minimizing ecological and crash threats by permitting aerial video/photo capture through the battery-operated, ultra 

lightweight UAS. Permitting Harbor Media Group to immediately fly within national airspace furthers economic 

growth. Granting our exemption requests substantially furthers the economic impact for the Southwest Michigan 

community for companies looking to relocate or build in the area as well as individuals looking to relocate for 

careers advancement through academic and geographical awareness. Both serve as stimulus to the community. 

Reasons Why Harbor Media Group's Exemption Will Not Adversely Affect Safety or How the Exemption 

Will Provide Level of Safety At Least Equal to Existing Rule: 

Harbor Media Group's exemption will not adversely affect safety. For the reasons stated, permitting Harbor 

Media Group to log more flight time in FAA-controlled airspace with communication will allow us to contribute to 

the innovation and implementation of new, novel and undiscovered safety protocols for Realtors that can be 

embraced by the National Association of Realtors, Michigan Association of Realtors, and local realtor associations 

5 http://www .legislature .mi .gov /documents/20 13-20 14/concurrentresolutionadopted/house/pdf/2013-HACRH0016.pdf 
Harbor Media Group 

Drone Exemption Application Page 4 

for development in cooperation with the FAA. IN addition, Harbor Media Group submits the following 

representations of enhancements to current aerial videography and photography for real estate: 

• 

• 

• 

Our UAS weights less than 4 lbs. complete with a small, ultra lightweight, high-quality HD camera. 

We only operate the UAS below 200 feet6, which is well-within the 400-foot permissible ceiling set by the FAA 

Modernization and Reform Act of2012. 

Our U AS only operates for 5-l 0 minutes each flight. 

We land the UAS prior to manufacturer-recommended minimum battery power levels. 

We pilot the UAS through remote control only by line of sight. 

The UAS has a GPS flight safety feature, whereby it hovers and slowly lands if communication with the remote 

control pilot is lost. 

We actively analyze flight data and other sources of information to constantly update and enhance safety 

protocols. 

We only operate in reasonably-safe environments that are strictly controlled and are away from power lines, 

elevated lines, airports and active-populated area. 

We conduct extensive preflight inspections and protocol during which safety carries primary importance . 

We always obtain all necessary permission before operation . 

We have procedures in place to abort flights in the events of safety breaches or potential danger. 

Harbor Media Group's safety protocols provide a level of safety that is equal to or exceed existing rules. It is 

important to note that absent the integration of commercial UAS into our national airspace system, helicopters were 

the primary means of aerial video and photography for community awareness and real estate. While the safety 

record of such helicopters as remarkably astounding, there has been local incident 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 our UAS carries no people and will be operated in specific areas away from the mass 

population. Second, there is no fuel onboard the UAS, limiting the potential for fire or explosions. Third, the small 

size and extreme maneuverability of the UAS allows Harbor Media Group to remotely pilot away from and avoid 

hazards quickly and safely. Lastly, given its small size and weight, the UAS need not be so close to objects it is 

focused on through technology and use of post-editing software. 

Accordingly, our UAS has been experimentally-operated for familiarization and competency and will continue 

to be operated at and above current safety levels. 

A Summary the FAA May Publish in the Federal Register: 

A. 14 CFR 21 and 14 CFR 91: Airworthiness Certificates, Manuals and Similar 

14 CFR 21, Subpart H, "Airworthiness Certificates" sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of 

Harbor Media Group's UAS permits exemption from Part 21 because the 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 Act 49 USC§ 4470l(f) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability, and proximity to areas, such as airports and dense 

populations. Harbor Media Group's current and projected UASs meet or exceed each of the elements. 

14 CFR 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certification will be applicable in the form contemplated by the FAR, this regulation is not applicable. 

14 CFR § 91. 9(b )(2) requires an aircraft flight manual in the aircraft. As there will not be pilots or passengers 

onboard the U AS and given the size of the UAS, this regulation is not applicable. An equivalent level of safety 

will be achieved by maintaining a safety/flight manual delineating area where safety can be defined? The FAA 

6 DJI Phantom Vision 2+ quad-copter altitude ceiling is 147 feet when flow in Smart Mode. See Appendix A 

(Operator Manual). 7 Appendix D- Safety/Flight Manual 
Harbor Media Group 

Drone Exemption Application Page 5 

has previously issued exemptions to this regulation in Exemption# 8607, 8737, 8738, 9299, 9299A, 9565, 

95658, 10167, 10602, 10700 and 32827. 

14 CFR § 91.121 regarding altimeter settings is not applicable insofar as our UAS utilizes electronic global 

positioning systems (GPS) with a barometric sensor. 

14 CFR § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are 

not applicable for the same reasons as described above. The equivalent level of safety will be achieved by 

maintaining any such required certifications and registration the UAS pilot/owner James Stringer. 

B. 14 CFR 45.23: Marking of the Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. Our 

UAS are- by definition- unmanned. They, therefore, do not have a cabin, cockpit, or pilot station on which to 

mark certain words or phrases. Further, two-inch lettering is difficult to place on a small aircraft with 

dimensions smaller that minimal lettering requirement. Regardless, we will mark the UAS in the largest 

possible lettering with the word "Experimental" on its fuselage as required by 14 CFR § 45.29(f) so that the 

pilot or anyone assisting as a spotter with the UA V will see the markings. The FAA has previously issued 

exemptions to this regulation through Exemption# 8738, 10167, 10167A, and 10700. 

C. 14 CR § 61.113: Private Pilot Privileges and Limitations, PIC 

Pursuant to 14 CFR § 61.113(a) and (b), private pilots are limited to noncommercial operations. Harbor Media 

Group can achieve an equivalent level of safety as achieved by current regulations because our UAS does not 

carry any pilots or passengers. Further, while helpful, a pilot license will not insure remote control piloting 

skills. The risks attended to the operation of the UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR § 61, et. seq. Thus, allowing Harbor Media Group to operate their UAS will meet 

and exceed current safety levels in relation to 14 CFR 61.113(a) and (b), 

D. 14 CFR § 91.119: Minimum Safe Altitudes 

14 CFR § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated 

at lower altitudes in certain conditions. Our UAS will never operate at an altitude greater than 200 AGL, safely 

below the standard of 400 AGL. Harbor Media Group will however operate the UAS in safe areas away from 

pub lie and traffic, providing a level of safety at least equivalent to or below minimum safe altitudes. Given the 

size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. 

E. 14 CR 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b): Maintenance Inspections 

The above-cited regulations require 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 

Harbor Media Group's UAS. However, as a safety precaution, we inspect the UAS before and after each flight. 

A Summary the FAA may public in the Federal Register: 

14 CFR 21 Subpart H "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 ofthe 

UAS permits exemption from Part 21 because Harbor Media Groups' UAS meets an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft form the airworthiness 

certificate requirement under both the 49 USC 44701(f) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. The UAS meets 

or exceeds each of the elements. 14 CFR 91.7(a) prohibits the operation of an aircraft with an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the F ARs, this regulation is not 

applicable. 14 CFR 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As thee are no pilots or passengers 

and given the size of the UASs, this regulation is not applicable. An equivalent level of safety will be achieved by 

maintaining this manual. The FAA has previously issued exemptions to this regulation in Exemption# 8607, 8737, 

8738, 9299, 9299A, 9565, 95658, and 10167. As the maintenance program will involve regular software updates 

and curative measures for any damaged hardware, an equivalent level of safety will be achieved. 
Harbor Media Group 

Drone Exemption Application Page 6 

In summary, Harbor Media Group seeks an exemption from the following regulations: 14 CFR21, subpart 

H, 13 CFR 45.23(b), 13 CFR 61.113(a) and (b), 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.103(b), 13 CFR 

91.109, 14 CFR 91.119, 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)(l), 14 CFR 91.409(a)(2), 14 CFR 91.409(a)(2), and 14 CFR 91.417(a) and (b) to commercially operate a 

small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and real estate operations 

and to develop economic platforms for real estate to enhance the experience of those seeking to relocate to the 

Southwest Michigan area. Currently, area awareness and real estate aerial photography/videography relies primarily 

on the use of larger aircraft running on combustible fuel, posing potential risk to the public. Granting Harbor Media 

Group's request for exemption will reduce current risk levels and, thereby, enhance safety. The UAS craft does not 

contain potentially-explosive fuel and is smaller, lighter and more maneuverable than conventional real estate video 

and photographic aircraft with much less flight time. Further, we operate at lower altitudes and in controlled 

airspace, eliminating potential public risk involved in flying to and from established air fields. Harbor Media Group 

has been informally analyzing flight information and will compile safety protocols and the implementation of a 

flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. 

Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols 

for compliance with the FAA Modernization and Reform Act of2012. There are no personnel onboard the UAS, 

and the likelihood of death or seriously bodily injury is significantly diminished as a result. Harbor Media Group's 

operation of the UAS (which weighs less than 5 lbs. and will travel at lower speeds within the limited areas) will 

provide an equivalent level of safety as that achieved under current F ARs. Accordingly, Harbor Media Group 

respectfully requests that the FAA grant our exemption request. We are willing to cooperate in sharing information 

to the benefit of the FAA, the continuing safety of manned aircraft, and the general public at-large. 

Specifics of the UAS: 

UAV/UAS/UA Clarification8 -

The UAVIUAS/UA which Harbor Media Group ("Petitioner") will be operating is a DJI Phantom 2 

Vision+, referred hereafter as "Phantom". The inherent safety features, sophistication, programmability, GPS 

navigation, return home capability, airport vicinity no-fly feature and restricted altitude feature combined with 

differentiating radio frequency (rt) for aircraft controller/receiver and the camera makes this a much safer UA V for 

the purposes of this petition. This is a hobby-grade, radio-controlled UAV that has the capacity for software 

upgrades and is light (weighing less than 3 lbs. including battery and camera). Incorporated into the programming of 

the Phantom is an automatic return home feature that directs the craft back to point oftakeoffshould communication 

with the transmitter be lost. The Phantom has a cruising speed of20MPH with a maximum speed of36 MPH and a 

maximum flight time of25 minutes. It also has a gross weight of2.86 lbs. The Phantom has an additional 

communication link between the camera and craft on a different rf for a smart phone connection, allowing the 

operator/pilot in command (PIC) to monitor battery level, altitude (AGL), distance from PIC< camera imagery, and 

control camera angle. 

The software for the Phantom allows the operator/PIC to set maximum altitude AGL for each flight with 

customization of flights to no higher than 100ft., 150ft. or 250ft. AGL for example. The 400ft maximum AGL can 

be programmed into the UA V's software pre-flight to insure compliance with FAA standards, adding to the safety 

capabilities of the UA V. This UAV is programmed to remain in position when controls are released, maintaining 

altitude and GPS location. The Phantom has an altitude and radar monitoring function that allows the operator more 

precise determination of height and direction of flight and distance from the operator/PIC. The operator/PIC can 

monitor GPS lock status while UAV is in flight with the ability to anticipate loss ofGPS locking so the operator/PIC 

can land the UAV as a precaution. 

The Phantom has a 2.4 ghz transmitter/controller/receiver rffor managing flight with a 5.8 ghz rf 

transmitter/received for video/photography functions that eliminated the rf conflict that is experienced wit the Blade 

350 QX and is by far the safer of the two when considering public and NAS safety. Considering the 

programmability and safety features of this UAV, it serves as the best option to protect the public and NAS for the 

purposes ofthis petition. 

8 The best explanation of the Phantom's sophistication and capabilities can be observed through a series of 

manufacturer videos; it maintains all capabilities defined in the video. http://www.dii.com/productlphantom-2-

v ision-plus 
Harbor Media Group 

Drone Exemption Application Page 7 

The Harbor Media Group petition is for UA V operation without pilot, passengers or property onboard. The 

U A V is a sophisticated hobby-grade quad copter with a gross weight of less than 3 lbs. Aerial video/photography 

operations for this petition will provide serve for those businesses, transferees, retirees and others considering 

relocating to the Southwest Michigan region who are unfamiliar with the geographical characteristics, communities, 

services and other benefits of the area. Aerial video/photography operations for private property owners will be 

aided with an enhanced perspective of the characteristics, amenities and benefits a private property has that cannot 

be displayed through ground level video/photography. Harbor Media Group charges no additional fees for ground 

level video/photography. Aerial video/photography represents a small portion of videos and photos currently offered 

at ground level for the community as well as private properties marked for sale. Aerial video/photography is an 

enhancement to videos/photography already offered to homeowners and the public. In most cases, aerial video will 

represent 4-20 seconds of a 2-3 minutes video. 

Harbor Media Group is using a UAC that has the capability for taking off/landing at a single point 

(identical to a helicopter). No runways, takeoff apparatuses, or routes that need to be flown to the areas being 

photographed/records are required, allowing for a more reduced and confined area of flight. Homeowner consent in 

writing for aerial video/photography will be obtained prior to flight. Signs will be posted cautioning anyone within 

the vicinity to remain back at a minimum of200 ft. Observer(s) to assist and warn/advice the PIC will be utilized 

where spectators may be within 500ft. of the flight area. To alleviate additional privacy concerns, petitioner has the 

ability to cover up areas in movie postproduction by shading out objects in the immediate vicinity. 

The single UA V utilized in this petition is a hobby-grade quad copter that does not require an airman 

certificate for noncommercial fight involving less restrictive/less regulated flight. UA V flight competency can be 

verified/obtained through AMA standards/procedures as well as downloading the flight data from the onboard data 

logger. The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition are not 

complicated. Engineering and design allows layman maintenance. Recording part replacement for this UA V may 

prove redundant due to the simplicity ofthe craft. While the petitioner request waiver/exemption for maintenance 

records, it would be understandable ifthe FAA requires such data for its rule-making process. However, preflight 

inspection for cracks, damage or other physical conditions that hamper safe flight is a reasonable expectation as well 

as post flight inspection may aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. 

Thorough inspection ofUAV shall be conducted and flight response tested should a hard landing or crash 

occur. Insuring that the UAC can operate in a safe manner before conducting any further video/photography. 

Petitioner requests waiver/exemption for markings due to the small size of the fuselage of the Phantom 2 

Vision+. 

Petitioner requests modification, waver or exemption and clarification within reason concerning section 

91.119 on the prohibition of flight in congested areas. Such restriction puts homeowners in subdivisions at a 

disadvantage by limited enhanced marketing of their homes, thereby discriminating against them. Vertical 

takeoff/landing while video recording or photographing can allow an enhanced perspective for view or proximity of 

mountains, golf courses, manmade lakes, or other attractions not possible through ground level recording or 

photography. Petitioner requests waiver for this condition to allow reasonable and responsible aerial 

video/photography in congested areas of subdivisions and neighborhoods. In cases where altitude within airports is 

an issue, aerial video can be achieved under 100 ft. 

In compliance with Section 90.151(a), the Phantom is a battery-operated UAV/UAS with battery level 

monitoring capability. Fully-charged battery flight time is rated at 25 minutes with videos/photos taking much less 

time to record. The operator/PIC is warned when battery level is low. 

Petitioner requests waiver/exemption from Section 91.203(a) since the Phantom is a hobby-grade 

U A V /U AS that should not require an airworthiness or registration certificate. Posting a special flight authorization 

would not be possible since the Phantom has no cabin and is not large enough to carry a certificate. However, a 

special flight authorization can be maintained by the operator to make available upon request. 

DJI Phantom 2 Vision+ 

Serial Number: 

1. Height limitation set for maximum of 300 ft. AGL 
" 2. Radius distance from controller set for maximum of 1000 ft. 

3. Both to aid in VLOS 

Harbor Media Group 

Drone Exemption Application Page 8 

4. Flight testing at the RIC air park has proven that due to UAS size of the Phantom 2 Vision+, firmware 

programmed for maximum 300 ft. AGL and 1000 distance are limited distance for maintaining VSOL without 

assistance of binoculars or other devices. Most of the intended operation will only require ranges of20 to 100 

AGL and less than 200 ft. lateral distance from PIC. Limited stated distance for VSOL will be rare, if ever 

needed. 

Current Firmware Upgrades for 

5. Main Controller 

6. GPS 

7. Received 

8. Battery 

9. Zen IMU 

Petitioner would like to seek a reasonable exemption with restriction solely to UAS operation at AGL below 

300 feet with distance of flight no greater than 1000 ft. Currently, there are no provisions within the FAA for 

governing UAS, such as the DJI Phantom 2 Vision+ for hobby or commercial use in Southwestern Michigan. With 

Phantom 2 Vision+ alone, sales have been "exponentially higher than the 7,500 in 5-years estimate that the FAA put 

forward a year ago ... "UAS potentially being flown without guidelines by unfamiliar and untrained individuals not 

belonging to professional organizations like the AMAM pose a threat to the nAS, the public and responsible parties 

like the petitioner. 

Thank you for your consideration, and please let us know if you have any questions regarding this application. 

97/JI '1/1 

Randy Willis Stringer 

Owner, Harbor Media Group Ha<boc Mod•a Gwup 

Appendices 

DJI Phantom Vision 2+ Owners Manual 

• A Available at http://download.djiinnovations.com/downloads/phantom _ 2 _vision _plus/en/Phantom_ 2_ Vision_Plus_ User_ Manual_ v 1.8 _ en.pdf 

• B Southwest Regional Airport Vicinity and SNM Circle 

• C Protocols and Controls for Aerial Community and Real Estate Videos 

• D Safety Flight Manual (Checklist Format) 

• E Caution Sign Placard 

• F Phantom Flying Flowchart Vl.O (Simplified Version) 
Drone Exemption Application- Appendixes (1) 

Appendix A 

DJI Phantom Vision 2+ Owners Manual 

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5km 

Drone Exemption Application -Appendixes (2) 

AppendixB 

Southwest Regional Airport Vicinity and SNM Circle 

Royilllton T wp 

Satellite 

Coloma Twp 

~~ -~ 

"*·- · Coloma . Wat«Vliet 

Bainbridge Twp 

- Pipestone Twp · 
Drone Exemption Application -Appendixes (3) 

Appendix C 

Protocols and Controls for Aerial Community and Real Estate Videos 

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and 

photography. As such, safety protocols and controls must be implemented through pre-flight preparation and during flight. 

Pre-Right Protocol 

Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries for damage or leakage that may affect 

proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult five (5) mile radius map for airport vicinity. Contact respective airport to advise of estimated flight time, estimated flight 

duration, estimated elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports 

Vicinity of medical helipads/heliports 

Vicinity of light poles 

Vicinity or utility wires 

Vicinity of trees 

Rocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted 

Public gatherings that may attract viewers 

Optional point of control for best visual site of UAS while in flight 

Takeoff/Landing 

Inspect area for best and safest point of takeoff and landing If in a subdivision or area that is within 150 feet of a residential street, post 

warning sign(s)/stand(s) "Attention Aerial Photography In Progress- Remain Back 150 Feet" 

Right Protocol 

Takeoff and land from same location 

Remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation 

or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results 

Remain prepared for emergency landing at all times 

Pay attention to flight time. If possible, set a timer as a safety alert 

Land UAS and shut down propulsion immediately following landing 

Post flight: 

Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight o pilot is being distracted from focusing 

on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 
Drone Exemption Application -Appendixes ( 4) 

Appendix D 

Safety Flight Manual (Checklist Format) 

Phantom 2 Vision + 

Mission Checklists 

Arrival Checklist 

1. If day and operating out of .back of 

vehicle, point vehicle :into sun. 

2. Remove case and place on level surface. 

3. Check distance to nearest airport and/or 

controlled airspace using smartphone or 

tablet app. 

4. If required, use VHF aviation transceiver. 

to contact tower of field if closer than 5 

NM. 

5. Inform tower I CTAF of UAS ops, .location, 

and max height of flight 

2. Router - On 

3. Transmitter- On 

4. Toggle Switches - Full Up 

5. Video Monitor- On 

6. Remove UAS from case. 

7. Gimbal Lock & Lens Cap- Removed 

8. Micro-SO card- Inserted. 

9. UAS Battery- Inserted 

10. Place UAS in clear and safe launch and 

recovery position if it returns to home. 

11. UAS Battery - On 

12. Wifi Connection to Monitor- Vermed 

13. DJI Application - Load 

14. OJI application- Connect to Camera 

15. SO Card- Format 

16. Camera- Full Up 

17. Satellite Connections- Verified 

18. Charge Levels- Safe for Flight 

19. Video Recording - Start 

20. Takeoff 

f·eet above the 

ground to confirm UAS is under control. 

2. All sticks operate correctly while in hover 

-Verified 

2. Video Recorder- Stop 

3. Landing Zone- Clear I Safe 

1_ Battery - Remove & Replace 

2. Wifi Connection to Monitor - Verified 

3_ OJl application- Connect to Camera 

4. Takeoff 

End of Ops Checklist 

1 _ Battery - Off 

2. Transmitter- Off 

3_ Router - Off 

4_ Notify Tower/CTAF - End of Ops 

Place Caution Placards 2C•D feet from ioJ:ation. 

Weather 

Surtace Observation 

Sky:. __________ _ 

Vsby: _________ _ 

Temp: _________ _ 

Wind: __________ _ 

Gusts:. __________ __ 

Weather at Altitude: 

Flight Level Winds: _____ _ 

Forecast: Clr, Set, Bkn,Ovc (Circ!e one) 

Pcpn:. _______ _ 

Winds:. ______ _ 
Drone Exemption Application- Appendixes (5) 

Appendix E 

Caution Sign Placard 

Caution 

Aerial Photography In Progress 

Remain Back 200 Feet 
Drone Exemption Application- Appendixes (6) 

Appendix F 

Phantom Flying Flowchart VI.O (Simplified Version) 

Switch on tile transmitter. and 

:then power on the PI-'J\NTOM. 

Second Level 

041114111$411$0019 Protection Alert 

&Heq;1ht Des~nt 

FailSafe LED: Blink Yellow 

--------111-1 Qu:clly ()1!>0000000 

LED:Red+ 

Green+ Yellow 

Corrpass Error Teo Eieg ------..,. t-------111-( LED:Red+Yellaw )..... .... 

If Red LED appears in the last four "'--------+1 green flashes, lhe auto~ system 

CJinnat wan. 

1npcr.::m:: PHANTOM s 

T!O\l~d aTI:.::r ~:Y?W'E'f 

D~for~ 11~·'* rnc:ors st:arHJp < 

{f s :s:at::)na -). nn 

please c!J the 

Part means normal procedlures: 

--~::. means reg•J!ar siWaticn. 

mear.s SE<Ieata!Oie or pcssitle situation. 

T;:.(t tells the deta:l:s. 

R-.,d Part me;ms possible abnom~al situation. 

Pal'! is possible in normal or abnormal sirua'licn, 

reqwe you to coniirm by lhe T ;::~: far details. 

Part is the condition of lhe normal situation. 

Pur;Xe Part is the oond .tion: afthe abnormal s:tuation. 
Drone Exemption Application- Appendixes (1) 

Appendix A 

DJI Phantom Vision 2+ Owners Manual 

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(Instead of inserting pdf into this document, linkis provided for immediate viewing and download.) 
Drone Exemption Application - Appendixes (2) 

Appendix B 

Southwest Regional Airport Vicinity and SNM Circle 

Satellite 

.. ':eo~om~·irw~} ,.,_"-' ,-, 

... ::::r:~~ Wat«9iit 

Bainbridge Twrp 

5km 
Drone Exemption Application -Appendixes (3) 

Appendix C 

Protocols and Controls for Aerial Community and Real Estate Videos 

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and 

photography. As such, safety protocols and controls must be implemented through pre-flight preparation and during flight. 

Pre-Flight Protocol 

Check batteries with voltage meter to insure fully charged and ready for use. Inspect batteries for damage or leakage that may affect 

proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult five (5) mile radius map for airport vicinity. Contact respective airport to advise of estimated flight time, estimated flight 

duration, estimated elevation of flight, and any other pertinent information. 

Inspect flight area for 

• Vicinity of public safety helipads/heliports 

Vicinity of medical helipads/heliports 

Vicinity of light poles 

Vicinity or utility wires 

Vicinity of trees 

Flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted 

Public gatherings that may attract viewers 

Optional point of control for best visual site of UAS while in flight 

Takeoff/Landing 

Inspect area for best and safest point of takeoff and landing If in a subdivision or area that is within 150 feet of a residential street, post 

warning sign(s)/stand(s) "Attention Aerial Photography In Progress- Remain Back 150 Feet" 

Flight Protocol 

Takeoff and land from same location 

Remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation 

or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results 

Remain prepared for emergency landing at all times 

Pay attention to t1ight time. If possible, set a timer as a safety alert 

Land UAS and shut down propulsion immediately following landing 

Post flight: 

Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight o pilot is being distracted from focusing 

on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of t1ight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 
Drone Exemption Application -Appendixes ( 4) 

Appendix D 

Safety Flight Manual (Checklist Format) 

Phantom 2 Vision + 

Mission Checkllists 

Arrival Checklist 

1. If day and operating· out of back of 

vehicle, point vehicle into sun_ 

2. Remove case and place on level surface_ 

3. Check distance to nearest airport and/or 

controlled airspace using smartphone or 

tablet app. 

4. If required, use VHF aviation transceiver. 

to contact tower of field if clos.ec than 5 

NM. 

5_ Inform tower I CTAF of UAS ops. location. 

and max height of flight 

~;?t;3tGI 

1 . Remove transmitter_ 

2. Router - On 

3. Transmitter- On 

4_ Toggle Switches- Full Up 

5. Video Monitor- On 

6. Remove UAS from case. 

7 _ Gimbal Lock & Lens Cap - Removed 

8. Micro-SO card- Inserted. 

9. UAS Battery -Inserted 

1 o_ Place UAS in clear and safe launch and 

recovery position if it returns to home. 

11. UAS Battery- On 

12. Wifi Connection to Monitor - Verified 

13. DJI Application - Load 

14. DJI application- Connect to Camera 

15. SD Card- Format 

16. Camera - Full Up 

17. Satellite Connections- Vemied 

18. Charge Levels- Safe for Flight 

19. Video Recording - Start 

20.Takeoff 

!ifilDmm:rm;m;arm• 

1. Hover appmximately ten feet above the 

ground to confirm UAS is under control_ 

2 _ All sticks operate correctly while in hover 

-Verified 

;;uamnt.u;t!q;masraa 

1. Camera - Full Up 

2. Video Recorder - Stop 

3. Landing Zone - Clear I Safe 

1. Battery - Remove & Replace 

2. Wifi Connection to Monitor - Verified 

3. DJI application- Connect to Camera 

4. Takeoff 

Endpf\1Jps,(;he<:.ldist· 

1 _ Battery - Off 

2. Transmitter- Off 

3. Router- Off 

4. Notify Tower/CTAF - End of Ops 

Plar::e Caution Placards 200 feet from location. 

Weather 

Surface Observation 

Sky: _________ _ 

Vsby: _________ _ 

Temp: __________ _ 

Wind:. __________ _ 

Gusts: __________ _ 

Weather at Altitude: 

Flight Level Winds:. _____ _ 

Forecast: Clr, Set, Bkn}'Ovc (Circle one) 

Pcpn:. _______ _ 

Winds: ______ _ 
Drone Exemption Application- Appendixes (5) 

Appendix E 

Caution Sign Placard 

Caution 

Aerial Photography In Progress 

Remain Back 200 Feet 
L.Eo: 81iilk'1 

Green Quctly 

Record 1m: 

forward 

~~.~icn. 

Drone Exemption Application- Appendixes (6) 

Appendix F 

Phantom Flying Flowchart VI.O (Simplified Version) 

lmporunt ·s 

mcved amr~r• ;,•;a 

bil!l'l>!'e tllo? ~start-\lp 

mat ll©l'lllal. 

If .s s:atkmary 01'1 me ~UM, ple~ try me IML. 

~ .: wlibrnuoo. 

' ?:art means norma~ pwcedl.ll't!5: 

--~means .... siuation. - - II> means seleetable or posstie situ~ion. 

tells the detail, 

Ril!d Part means possible abnormal situation. 

Part is ~e in norma! or i1lmolmaJ situation. 

req:~~.We you to ccmfiml by lhe T ex! for details. 

Slue Part is the condition of lhe norma! situation. 

Pu~ Part is the condition of the amormal situati©l'l.