Mitchell Meszaros

1381 Missile Base road

Judsonia, Arkansas 72081

(501) 882-9013

mitchellmeszaros@hotmail.com

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

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

Act) and 14 C.F.R. Part 11, I, Mitchell Meszaros, operator of Small Unmanned Aircraft 

System (“sUAS”) equipped to conduct aerial photography and videography, News 

gathering, and Aerial Surveying, hereby apply for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as 

such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333.1 As described more fully 

below, the requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that is 1)limited 2) 

predetermined and 3) controlled. The proposed exemption, if granted, would allow 

myself to conduct commercial operations of small unmanned aircraft systems (“UAS”). I 

will meet or exceed all of the operational and safety requirements that Congress has set 

forth in Section 333. I ask that if any part of this request is deemed not in compliance, 

that part be removed and process the remaining of this request as applicable. I, 

furthermore, plan to exploit the capabilities of Unmanned Aerial Systems to offer a 

multitude of services, including:

 Aerial surveying

 Event Photography/Videography

 News Gathering 

 Agriculture purposes

 Real Estate Photography

 Aerial filmmaking and photography

 Construction site inspections and monitoring

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil 

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system 

before completion of the (comprehensive) plan and rulemaking required by section 

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b) (1), Congress made it clear that Section 333 provides a mechanism for
“expedited operation authorization” if several factors are met. Petitioner meets all 

requirements to permit FAA approval of commercial UAS operations. Small Unmanned 

Aircraft Systems are oftentimes seen as superior to helicopters due to the smaller 

devices, cheaper equipment and personnel cost, reduced noise and as such, a much 

smaller environmental impact which promotes public safety. I am petitioning for 

exemption to enable myself to operate the DJI Phantom 3 Professional equipped with a 

two-axis camera gimbal and using a High-Def camera. This sUAS has a built-in 

capability to limit the height it flies above the ground, to limit the radius of the distance it 

flies from the operator. They also have the failsafe function of the autopilot system 

which means when the communication between the Main Controller and the transmitter 

is disconnected i.e. lost, the outputs of all command sticks from controller will go to the 

center position. If GPS signal is available, the system will automatically trigger Return to 

Home and will land safely. Aircraft Gross weight is less than 2.8 pounds with battery 

and camera payload. A Pre-flight inspection will be performed by myself in accordance 

with the factory instruction manual. An added step will be incorporated; the inspection of 

the propellers. Any propeller will be replaced if it has any grooves and cracks with a 

manufacturers authorized propeller. The sUAS will be maintained in accordance with 

the manufacturer’s instruction manual and only manufacturer's authorized replacement 

parts will be used.

FCC Information

This transmitters used for controlling the sUAS complies with part 15 of the FCC rules.

Operation is subject to the following two conditions: (1) This device may not cause 

harmful interference, and (2) this device must accept any interference received, 

including interference that may cause undesired operation. The radio transmitters used 

for controlling the sUAS is wireless technology which has been tested and found to be 

compliant with the applicable regulations governing a radio transmitters in the 2.400GHz 

to 2.4835GHz frequency range.

Antenna Separation Distance

When operating my transmitters, I will maintain a separation distance of at least

5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the 

antenna to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command Qualifications and Duties

I will maintain a driver’s license and I have flown over 20 hours of flight time, thus 

including takeoffs and landings within the last calendar year in the form of recreational 

use. I am solely responsible for the safe and efficient operation of the aircraft. Specific 

duties include all preflight preparation, in flight operation, post flight requirements, and 

all procedures including but not limited to:

 Safe in flight operations

 Pre/Post Flight inspections and upkeep 

 Risk mitigation to persons and property

 Airfield Suitability
General Operating Standards

• I will only operate the sUAS in line of sight and will operate at sites that are a 'sufficient 

distance' from populated areas. I will insure that the sUAS will "not create a hazard to 

users of the national airspace system or the public."

• Before an operation of a sUAV within 5NM of an airport with a control tower, the 

control tower will be called to gain permission to operate the sUAS. I will give the 

position, altitude and the times the sUAV will be operated. The sUAS will not be 

operated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles visibility 

and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a non-tower 

controlled, airport operators will be notified and I will always give the right of way to and

avoid flying in the proximity of full-scale aircraft. At no time will the sUAV be operated 

within the final approach course and the takeoff course of any runway. The sUAV will 

not be operated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles 

visibility and a 1000 foot ceiling.

 Maximum flight time for each operational flight will be 25 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 

25 minute limit.

 The sUAV will be programmed so that it will be operated at an altitude of no more 

than 400 feet AGL.

 The sUAV operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbals).

 The sUAV will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally.

Given the small size of the sUAV and the restricted sterile environment within which 

they will operate, the sUAV operations adhere to the Reform Act's safety requirements. 

The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and 

diminish the likelihood of death or serious bodily injury. With a small payload and 

maximum flight time of only 20 minutes per battery cycle, this offers little to no risk to 

national security. Low level oblique photos and video from several angles are far more 

effective than ground based imagery for displaying the characteristics of large, complex 

properties with several buildings and large trees. The benefits of reduced cost and 

improved quality of presentation from the UA will be valuable to and benefit many 

buyers and sellers of real property as well as mitigating risk by not carrying personnel 

for flight operations.
(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at 

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All required permits will be obtained from state and local government prior to 

operation;

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I, Mitchell Meszaros request an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned 

Aerial Systems, I request an experimental certificate be issued for the DJI Phantom 3 

under either or both of the following provisions: 21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including flights to 

show compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function 

and reliability requirements of the regulations. Since the experimental certificate can be 

used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit 

our commercial purpose as well. The aircraft will not carry persons or property, will not 

carry fuel, and will only fly under strict operational requirements.

Combined with the UA's light weight, being constructed primarily of carbon fiber and 

plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental 

airworthiness certificate is not appropriate for this application, then we request an 

exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous 

paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to 

the cabin, cockpit, or pilot station. The sUAV does not have adequate wing space in 

which the word "EXPERIMENTAL" can be placed, and do not have a registration 

number assigned to it by the FAA at this time. I, am in the process of retaining an “N-” 

registration at this time. Pending of the FAA “N” Registration, after which I will 

mark/identify the sUAV in the manner set forth. I do feel that the sUAV will need to be 
labeled on both the top side and bottom of any certain wing. As this sUAV will be in the 

air (over 8ft) when in flight. 

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 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. I assume that the intent of this requirement is to 

ensure that flight manual information is available to the aircrew while operating the 

aircraft. I request an exemption to this requirement since the aircraft is not only too 

small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that a current, approved sUAS Flight Manual must be available to 

myself at the ground station anytime the aircraft is in, or preparing for, flight.

91.119 Minimum safe altitudes:

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planned flight path has been performed. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain that due to 

the small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 

400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the sUAS on-board computer to the display screen 

held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-vFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated 

and the maximum duration of flight from a single battery charge is 15 minutes with a 

25% reserve. Since the aircraft will never fly more than 3/4 NM from the point of 
intended landing, a full battery charge at launch will ensure that we meet the reserve 

energy requirement of this paragraph. We request an exemption to the word "fuel" and 

ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew." At a 

maximum gross weight of 6.1 pounds, the sUAS is too small to carry documentation, 

does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be with the crew at the 

ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following 

information plus the “N-“ registration number to satisfy the requirement of 14 CFR 

45.23.

14 CFR 91.205(a), (b), (c) Instrument and Equipment Requirements

This regulation provides a minimum set of instruments and equipment required for day 

and night VFR flight. Due to the small size of the sUAS it would be impossible to carry 

many of these instruments. 91.205 (b) 4,5,6,7,8,13,14,16,17 are not applicable as the 

sUAS has no Reciprocating engines or seats. 91.205 (b) 2, 3, 9 are provided on the 

hand held controller. 91.205(b) 1 is not applicable as the maximum available speed of 

the sUAS is less than the maximum required by this exemption and has no effect on 

performance. 91.205 (b) 10 is not applicable as the landing gear position can be verified 

visually before landing. 91.205 (b) 15 Due to the size it would be impossible for the 

sUAS to carry any known ELT. 91.205 (c) Much of this equipment is too heavy to be 

carried by the sUAS. We feel that visual contact with the sUAS and indications provided 

via the controller that all critical information can be monitored.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, 

Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a 

person authorized under 43.7" after maintenance and inspection. It is my intention that I 

will perform maintenance and inspection of the aircraft and "be authorized to approve 

the aircraft for return to service." I will ensure that the aircraft is in an airworthy condition 

prior to every flight and in addition conduct detailed inspections after every two hours of 

flight. Maintenance performed by myself is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and firmware for the 

on-board computer. All other maintenance will be performed by the manufacturer or 
their designated repair facility. I feel that due to the size, construction, and simplicity of 

the aircraft, I can ensure an equivalent level of safety.

Safety and Benefits of the UAS

I will be using the UAS in a variety of applications that generally require expensive fullsize manned aircraft to complete. Small, light, unmanned aerial vehicles offer countless

benefits over the use of full-sized manned aircraft for electric power line inspection, 

oil/gas pipeline inspection, advanced agriculture, film and still photography; that just 

names a few. Replacing significantly larger manned aircraft thus; carrying crews and 

flammable fuels. By granting myself the requested exemptions, the FAA will help drive 

development of safe and successful commercial UAS operations and will advance the 

public knowledge base for such operations. I am committed to promoting the UAS 

research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing 

data from its commercial UAS operations and serving as a resource for future UAS 

research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion

As pointed out in this application, the sUAs which I would use, under authorization by 

the US DOT-FAA, is a small, light-weight device operated within the line of sight of the 

Pilot-in-Command, less than 400 feet above the ground and outside 5 miles from any 

airport, heliport, seaplane base, spaceport, or other location with aviation activities, 

unless the air traffic control authorities (ATC) have been notified beforehand and have 

authorized each flight within a radius of this distance. The sUAs have proven great 

capability for controlled safe flight. They are devices offered for general sale on the 

market around the world and have often been used as Model Aircraft in the USA. I am 

certain that the studies conducted until now by the FAA, about Section 332, Public Law 

112-95, 2014, have already provided you with the assurances on the airworthiness of 

SUAs such as mine. For the foregoing reasons, the exemptions requested herein 

should be granted for myself, Mitchell Meszaros, and should be permitted to conduct 

small UAS operations in accordance with its manuals and all other operating 

parameters deemed necessary and appropriate by the FAA. The submission of this 

application and its contents is the best demonstration that indeed it is possible to pursue 

the authorization process so that some SUAs may be used for legitimate commercial 

activities and under reasonably safe conditions. If any individual aspect of this request 

for exemption be unacceptable ask that it be struck alone and the remainder of the 

exemption be allowed as requested.

Signed

Mitchell Meszaros 

Owner-Operator