Michael L. Allen

6042 Instone Circle

Colorado Springs, CO 80922

Tel: (719) 310-4789

Mallen12064@gmail.com

February 2, 2016

To the FAA,

This petition is being submitted on my own behalf without legal counsel or consulting services. 

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

and 14 C.F.R. Part 11, Michael L. Allen, a private individual, operating a Small Unmanned 

Aircraft System ("sUAS") equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of my sUAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA), so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Michael L. Allen to pursue commercial interests in 

providing services to consumers interested in aerial data capture using a small advanced sUAS 

in the following areas:

 Media Production 

 Real Estate Inspection & Sales

 Agricultural, Livestock & Land Surveying 

 Aerial Mapping 

 Search and Rescue Operations

 sUAS Operator Training 

 Product Demonstrations 

 Research and Development

Michael L. Allen states that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner's prior consent and knowledge and that only people 

who have consented or otherwise have agreed to be in the area where photography and 

videography will take place will be captured in identifiable form. 

Additionally, Michael L. Allen PIC (Pilot-In-Command) holds a Commercial Pilot ASEL/AML/ 

Instrument certificate. If observers are not qualified pilots, they will be trained by Michael L. 

Allen to understand the proper roles of an observer, communication procedures, proper visual 

scan techniques, operations at non-towered airports, and appropriate sections of the 

Aeronautical Information Manual.
Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F .R. (91.401 - 91.417)

Small Unmanned Aircraft System (sUAS)

sUAS are a highly effective tool for obtaining agricultural cropland data which aides in 

determining optimal irrigation and fertilization requirements. This results in cost savings and 

avoids environmental impact from excess fertilization. Livestock safety and security also benefit 

from the sUAS as the conservative power requirements enable more frequent monitoring which 

would be cost prohibitive from a traditional manned aircraft. As an aerial camera platform, sUAS 

also perform valuable commercial media, film, photography and 3D mapping functions more 

safely and effectively than other means. Additional benefit from the sUAS also is apparent 

through assisting local authorities in coordinated Search-And-Rescue operations.

I am petitioning for exemption to operate a DJI Phantom 3 multi-rotor equipped with a three-axis 

gimbaled camera, and a DJI Inspire 1 multi-rotor equipped with a three-axis gimbaled camera. 

These sUAS all weigh less than 55 lbs., all have a built-in capability to limit the height flown 

above the ground and to limit the radius of the distance flown from the operator and to exclude 

the sUAS from Class B, C and D airspace including a no fly zone feature. Each system also 

has a failsafe function of an autopilot system, which triggers GPS Return to Home and Land 

capability in the event of disrupted communication with the Main Controller.

Each sUAS uses four counter-rotating propellers that provide balance, stability and control in all 

segments of flight. Fully equipped with battery, gimbal and camera, each sUAS weighs less 

than 55 pounds. Primary operation of the sUAS involves a visual survey of the intended subject 

area, updating the deployment destination point in the event of a return-to-home trigger, vertical 

deployment to less than 400’ AGL, enroute travel at less than 50 knot maximum speed. All 

operations are conducted under visual meteorological conditions (VMC) within visual line-ofsight (VLOS) of the remote control and PIC.
The above specifications meet standards listed below, some derived in accordance with the 

Model Aircraft Operating Standards: 

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will

operate at a 'sufficient distance' from populated areas. Such operations will insure that the 

sUAS will "not create a hazard to users of the national airspace system or the public." 

• When flying sUAS within 5 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 60 

minute limit. 

• The sUAS will be programmed so that it will not be operated at an altitude of no more than 400

feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. 

• The sUAS PIC (Pilot in Command) will hold a FAA Commercial Pilot Certificate. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). 

• The sUAS will operate at speeds of no more than 55 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which they will 

operate, the sUAS operations adhere to the Reform Act's safety requirements. 
Summary

Michael L. Allen’s operation of small unmanned aircraft will not "create a hazard to users of 

the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size 

and weight of the sUAS, combined with safety focused operation standards, Michael L. 

Allen’s flight operations fall within Congress's contemplated safety zone when it 

disseminated the Reform Act and the corresponding directive to integrate UASs into the 

national airspace system. 

Michael L. Allen has extensive knowledge of and experience with sUAS systems, and has a 

high regard to safety and coordination with commercial and general aviation. Additionally, 

the fact that Michael L. Allen holds a Commercial Pilot certificate demonstrates he has a 

high regard to safe operations with an understanding of FARs, preflight inspections, 

maintenance and repair, operations within airspace, as well as being trained to high safety 

standards.

Michael L. Allen ensures he is familiar with all applicable regulations and guidance 

documents pertaining to sUAS operation; including background information such as 

sectional aeronautical charts for each area of operation, NOTAMS and Aircraft Circulars; 

Radio Communications Procedures; Human Factors and Crew Resource Management; 

Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and 

Safe Operating Procedures.

Michael L. Allen respectfully requests exemption under Section 333 to operate safe, low-risk 

commercial sUAS operations for the activities stated. Michael L. Allen, at all times, will 

respect the space and privacy of citizens and property while keeping our skies safe.

Sincerely, 

Michael L. Allen

6042 Instone Circle

Colorado Springs, CO 80922