Request	for	FAA	Exemptions:	

Michael	Carey	Goudeau

8309	Bella	Famiglia	Ave.

Las	Vegas,	NV.	89178

goudeau@gmail.com

(702)	496-7702 February	4,	2015

I	wish	to	petition	the	Federal	Aviation	Administration	(FAA)	for	an	exemption	from	

part	21,	subpart	H;	and	Sections	45.23(b),	61.113(a)	and	(b),	91.7(a),	91.9(b)(2),	

91.119,	91.121,	91.151(a),	91.203(a)	and	(b),	91.405(a),	91.407(a)(1),	91.409(a)(2),	

and	91.417(a)	and	(b)	of	Title	14,	Code	of	Federal	Regulations	(14	CFR).	

I	would	like	to	be	permitted	to	operate	a	DJI	PHANTOM	2	Vision+	quad-copter	

unmanned	aircraft	system	(UAS)	to	conduct	aerial	videography	and	

cinematography.	I	currently	work	for	the	Nevada	Public	Broadcasting	System	for	an	

upcoming	television	show	called	“Outdoor	Nevada.”		This	show	is	designed	to	

increase	community	awareness	of	the	many	scenic	places	and	outdoor	activities	

within	the	state	of	Nevada.		

I	am	a	licensed	private	pilot	(Certificate	number	3233835)	with	over	150	hours	as	

PIC.		The	quad-copter	will	be	flown	within	sight	and	below	400	ft.	AGL.		

Attached	are	documents	regarding	the	type	of	UAS I	fly.	PHANTOM	Flying	Flow	

Chart	V1.0	(Simplified	Version),	PHANTOM	Quick	Start	Manual	v1.7,	PHANTOM	

Advanced	Manual	v.1.4,	3)	PHANTOM	2	User	Manual

I	plan	to	operate	a	UAS,	a	PHANTOM	2	Vision+,	which	is	comprised	of	an	unmanned	

aircraft	(UA	or	PHANTOM)	and	a	transportable	ground	station.	The	PHANTOM	is	

referred	to	as	a	quad-copter	and	has	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	30	knots.	I	plan	to	attach	a	small	ultralightweight	GoPro	3+	camera	to	the	UA	and	operate	the	UA over	various	areas	

within	the	state	of	Nevada.	

 I	will	only	operate	the	UA	in	reasonably	safe	environments	that	are	strictly	

controlled,	are	away	from	power	lines,	elevated	lights,	airports	and	actively	

populated	areas.

 I	will	conduct	extensive	preflight	inspections	and	protocols,	during	which	

safety	carries	primary	importance.	
Given	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	aircraft	

I	believe	an	exemption	from	14	CFR	part	21,	Subpart	H	(Airworthiness	Certificates)	

and	§	91.203	(a)	and	(b)	(Certifications	required),	subject	to	certain	conditions	and	

limitations,	is	warranted	and	will	meet	the	requirements	for	an	equivalent	level	of	

safety	under	14	CFR	part	11	and	Section	333	of	P.L.	112-95	(Section	333).	

I	also	request	an	exemption	from	§	45.23	Marking	of	the	aircraft	because	the	

PHANTOM	UA	does	not	have	a	cabin,	cockpit	or	pilot	station	upon	which	to	place	the	

markings.	Two-inch	lettering	is	difficult	to	place	on	such	a	small	aircraft	with	

dimensions	smaller	than	the	minimal	lettering	requirement.	

I	also	request	an	exemption	from	§§	91.405(a),	91.407(a)(1),	91.409(a)(2)	and	

91.417(a)	and	(b)	Maintenance	inspections.	 As	a	safety	precaution	I	will	perform	a	

preflight	inspection	of	the	PHANTOM	UAS	before	each	flight	as	outlined	in	the	

operations	manual.

UAS	Pilot	in	Command	(PIC)	

Under	§	61.113	(a)	and	(b)	private	pilots	are	limited	to	non- commercial	operations,	

however	the	UAS	does	not	carry	any	pilots	or	passengers	and	so	poses	very	little	

risk	to	persons	or	property.	The	risks	of	operating	a	UAS	are	far	less	than	the	risk	

levels	inherent	in	the	commercial	activities	outlined	in	14	CFR	part	61,	et	seq.

While	I	have	no	formal	UAS	operational	training,	I	have	flown	numerous	practice	

flights	as	a	hobbyist.	I	have	often	practiced	flights	similar	to	the	ones	I	will	be	

performing	for	Outdoor	Nevada.		I	am	familiar	with	the	UAS’	performance	under	

different	altitudes,	temperatures	and	weather	conditions.	

Also,	as	part	of	my	training	I	have	spent	several	hours	practicing	computerized	

simulated	flights	(which	came	with	and	were	designed	as	training	aids	for	the	

PHANTOM	UAS)	to	maintain	adequate	skills	and	response	reflex	time.	

I	will	abide	by	the	following	additional	operating	conditions:	I	will	operate	the	UAS	

below	400	feet	AGL	and	within	a	radius	distance	of	1000	feet	from	the	controller	to	

both	aid	in	direct	line	of	sight	visual	observation.

I	will	operate	the	UAS	for	no	more	than	15	minutes	per	flight.		This	leaves	a	safety	

window	of	at	least	5	minutes	(25%)	before	battery	power	begins	to	get	low.	

I	will	only	operate	the	UAS	only	within	visual	line	of	sight	(VLOS).	Included	in	the	

operational	software	of	the	UAS	is	a	global	positioning	system	(GPS)	flight	safety	

feature	whereby	it	returns	to	the	point	of	take	off,	hovers,	and	then	slowly	lands	if	

communication	with	the	remote	control	is	lost.

I	will	conduct	all	operations	under	strict	flight	safety	protocols	(including	posting	a	

warning	sign	reading:	“Attention	Aerial	Photography	in	Progress	– Remain	Back	150	
feet”)	contained	in	the	operating	documents	and	I	will	actively	analyze	flight	data	

and	other	sources	of	information	to	constantly	update	and	enhance	my	safety	

protocols.

I	will	contact	respective	airports	if	operations	will	be	within	5	miles	to	advise	them	

of	his	estimated	flight	time,	flight	duration,	elevation	of	flight	and	other	pertinent	

information.		I	will	always	obtain	all	necessary	permissions	prior	to	operation;	and	I	

will	have	procedures	in	place	to	abort	flights	in	the	event	of	safety	breaches	or	

potential	danger.		The	UAS has	a	“return	to	home”	button	that	will	automatically	fly	

the	UAS back	to	its	point	of	take	off.		If	the	pilot	were	to	become	in	any	way	disabled	

the	UAS will	return	autonomously	

While	§	91.7(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	

certificate	there	is	currently	no	certificate	applicable	to	this	type	of	operation.	

Regulation	§	91.9(b)(2)	requires	an	aircraft	flight	manual	in	the	aircraft,	however	

since	there	are	no	pilots	or	passengers	on	board	this	aircraft	and	given	its	size,	this	

regulation	is	inapplicable.	I	will	have	a	safety/flight	manual	with	the	UAS	ground	

station.	

§	91.119	prescribes	safe	altitudes	for	the	operation	of	civil	aircraft,	but	it	allows	

helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	I	will	not	operate	

the	UAS	above	the	altitude	of	400	feet	above	ground	level	(AGL)	and	I	will	also	only	

operate	in	safe	areas	away	from	the	public	and	traffic.		I	believe	the	small	size,	low	

weight,	maneuverability,	and	low	speed	of	the	UAS,	will	proffer	an	equivalent	or	

higher	level	of	safety.	

§	91.121	Altimeter	settings	is	inapplicable.	The	UAS utilizes	electronic	GPS	with	a	

barometric	sensor.	

Regulation	§	91.151(a)	Fuel	requirements	for	flight	in	VFR	conditions is	not	relevant	

as	there	are	no	passengers	or	fuel	involved	in	flying	the	UAS.		

Aerial	videography	has	long	been	available	using	more	traditional	aircraft	but	a	

show	of	the	size	and	budget	of		“Outdoor	Nevada”	could	not	afford	such	a	luxury.		

The	UAS allows	us	to	highlight	the	beauty	and	geography	of	some	of	Nevada’s	

remote	regions.		

Granting	this	exemption	will	allow	our	small	Public	Television	program	to	provide	

our	viewers	scenic	overviews	and	geographic	orientation	of	many	beautiful	sights.	

Our	show	is	committed	to	ecological	conservation	and	we	believe	that	the	

knowledge	of	the	beauty	of	nature	will	motivate	people	to	care	for	the	land.