Exemption Request for FAR 333 

Larry Bossone 

MCS Communications 

27 Bodine Rd. 

Berwyn, PA 19312 

(610) 648-0385 

MCS Communications request to seeking exemptions from the following FAR Parts 

in title 14 Code of Regulations. 

Following are Parts seeking an exemption with abbreviation of rules and alternate 

proposals for exemption 

Part 21 Procedural requirements for fixed wing and changing design approval 

production approvals, airworthiness certificates and airworthy approval 

REASON REQUEST EXEMPTION: Size, weight, speed, limited operating area 

(See specifications S900 & S1000 ©)meets the equivalent level of safety under 14 

CFR part 21 Subpart H. 

45.23 (b) Registration numbers 

REASON REQUEST EXEMPTION: Size of UAV makes it impossible to have 2" 

lettering. 

ALTERNATE PROPOSAL: Lettering designed in accordance with 14 CFR part 4 7 and 

having identification (N number) markings in accordance with 14 CFR part 45 (c) as 

large as practicable. 

61.133 Commercial Pilot. FAA has already granted exemptions for UAVoperations. 

Private pilot license is deemed sufficient for operation of UAV. 

ALTERNATE PROPOSAL: Operator will be Private Pilot with currency as required by 

14 CFR 61: 56; 61:57, as well as requirements under 14 CFR 61:51(b) 

91.7 No person may operate aircraft unless in airworthy condition 

ALTERNATE PROPOSAL (see Assembly and Flight Cautions from DJI manual©) 

Page4 

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91.9 (b) Flight Manual (see DJI user manual©) 

91.103 Preflight Actions: 

Alternate Proposal (See Checklist and manufacturers Safety Cautions from DJI 

manual ©) Pilot will perform all functions before beginning flight 

91.109 Dual Controls for flight instruction -

Flight training will be accomplished at remote field approved by owner of location. 

No persons allowed within 500 feet of operation except those required for safe 

operation of training. (see training syllabus) 

91.119 Minimum Safe Altitudes: All flights will be conducted below 400 feet AGL. 

Will operate only in safe areas away from public and traffic, thus providing a level of 

safety at least equivalent to or better than full size of aircraft currently used for 

these operations with weights of over 5000 lbs. AUV gross weight will weigh under 

40 lbs., carry no liquid fuel and operate under speeds of 40 mph. 

91.121 Altimeter Settings: Regulation is inapplicable for this type aircraft. UAV 

utilizes a GPS with barometric sensor. 

91.151 (a) Fuel Requirements- Land with minimum 25% battery power (indicated 

on transmitter screen and video monitor) 

91.203 (a) Appropriate airworthy certificate (See certificate DJI Specifications S900 

andS 1000 © 

91.405 Maintenance Required 

Alternate Proposal: Pilot will inspect aircraft using D}I Cautions © (Page 4) before 

each flight. Pilot will perform minor maintenance such as replacements of 

propellers, minor adjustments, weights and balance. Major modifications or repairs 

will be performed by manufacturers representatives or persons skilled in 

electronics of DJI S900 or DJI S1000. 

91:409 (a) (1) (2) Inspections (See above) 

91.417 Maintenance Records- Owner will keep log of all maintenance performed. 

MCS Communications- FAR 333 Exemption Request 

2 
MCS Communications request exemptions for the above items for the purpose of 

operating a UAV for close set filming for the motion picture and television industry. 

The flights will be below 400 feet AGL and not exceed a ground speed of 40 knots. 

One of two aircraft, depending on the assignment, will be used for the flights. This 

will be either the DJI S900 or DJI S1000. Neither aircraft will exceed 55 pounds (see 

specifications). 

The aircraft will be operated within visual line of sight of the PIC at all times. All 

operations will consist of a separate camera-person to operate the camera gimbal 

and at least one visual observer to confirm position. All persons shall be able to 

communicate at all times while aircraft is operating. 

The aircraft will only operate in a "sterile area" not be operating within 500 ft. of 

non - participating persons except those consenting to be involved and necessary 

for the filming production. An aviation safety inspector may approve a smaller 

radius consistent with safety requirements. 

MCS Communications will submit a written "Plan of Activities" to FSDO 3 days 

before the proposed shoot. 

MCS Communications will obtain the consent of all persons involved in the filming 

and insure that only consenting persons are allowed within 100 ft. of the flight 

operation and this radius may be reduced to 30 feet based upon an equivalent level 

of safety. However, the advanced permission of the relevant FSDO, operation at 

closer range can be approved. 

Written and/or oral permission from the relevant property holders will be obtained. 

All required permissions and permits will be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

government agencies. 

A briefing will be held before each flight. All persons involved in the filming must be 

present and understand the purpose and parameters of flight. 

MCS Communications- FAR 333 Exemption Request 

3 
The aircraft will be available with an emergency return to home condition in case of 

failure of all components. 

Using a UAV for filming on a close set will bring more production crews into areas 

not normally served by the film industry. Providing a more economical method of 

filming aerials will allow also shots to be produced safer than current methods. 

Having this capability outside the normal Hollywood and New York areas will bring 

work for production crew, provide income to ancillary business such as restaurants 

and hotels, and create tourist who come to see the areas shown in films produced in 

the area where the UAVs are provided for production. 

Because of it's smaller size and operating in a restricted area, our UAVs for film and 

video production will not only provide a safer alternative to the public than heavier 

aircraft, but will lower the noise factor, save the ecology by using less fuel & 

pollution. 

Based on all above MCS Communications request an exemption under Section 333 

to provide a safer alternative to producing aerial footage associated with motion 

picture and video production 

NOTE: 

The accompanying manuals are confidential documents and contain proprietary 

information that has not and will not share with the public and are protected from 

release under Freedom of Information Act 5 USC 552 et.sc 

Check List and Training Syllabus may be modified slightly as safety conditions 

warrant better methods of providing safety and training. 

MCS Communications- FAR 333 Exemption Request 

4 
DJI 900 and 1000 Check List 

START UP PROCEDURE 

Camera Operator Calf out each Item 

Pilot to confirm item has been accomplished 

No Person other than 

* Clear Area Pilot within 20 ft. 

1 All Switches 

2 Transmitters 

3 Transmitter Screen 

4 Battery on DJI 

5 Camera Platform 

6 Nose Position Fix 

Toward Antenna 

Power On 

Check Model Selection & 

Transmitter Voltage 

Connect/Confirm 

Rotate/lock (Green) 

Green Flashes 

7 Confirm Sat. Acquisition =>1 RED FLASH 

8 Switch Man to Alt 2 Yellow Flashes 

9 Switch Alt to GPS 2 Magenta Flashes 

10 Switch GPS back to ALT 2 Yellow Flashes 

11 Switch Course Lock IOC 2 Green Flashes 

12 Re-switch Alt to GPS Double Green Flash 

13 Perform CSC + 10% Aqua Flash 

14 Operate Cyclic Check All Modes 

15 Throttle up to Hover Hover (Green Blink) 

16 Hover @ 5-6 Feet Rotate 90 Degrees 
17 Establish IOC w/cyclic Test 2 Directions 

18 Check area for people Perform normal flight 

MCS Checklist 2015 
Assembly Cautions 

1. Use a bracket to mount the GPS module on the center frame to avoid 

interference with the power board. 

2. Ensure the IMU is mounted with the arrow pointing toward the nose of the 

aircraft. 

3. If using a receiver, attach it under the bottom board of the center frame with 

the end of the antenna facing downwards and away from obstructions to 

avoid signal loss. 

4. Ensure frame arms are mounted correctly. 

(a) Motor mounts with CCW marks should be mounted to the center frame 

positions with the following marks: M1, M3, MS and M7. 

5. Do not remove any glued-in screws. 

6. Screws that already have blue glue can be used once without thread locker. 

On other occasions, apply appropriate thread locker first 

7. The 51000+ should be lifted off the ground when testing landing gear or 

recalibrating servo travel. 
Flight Cautions 

1. ESC are not water-proof, please do not fly in rain or snow. 

2. Ensure all soft dampers and vibration absorbers are in good condition 

before every flight. If not, replace immediately. Otherwise the flight 

performance of your aircraft will be adversely affected. 

3. Ensure all parts are in good condition before each flight. Do not fly with 

worn or broken parts. 

4. Ensure propellers and motors are installed correctly and propellers are 

unfolded before flying. 

5. Ensure ESC signal connectors and power cable connectors are tight before 

every flight. 

6. When flying, maintain a safe distance away from people, buildings, highvoltage lines, tall trees, water and other hazards. 

7. Use only 6S LiPo batteries for the power supply. 

8. Ensure all outpoint signals from M1 to M8 are in proper working order when 

using the DJI A2 flight control system to avoid damage or injury. 

9. Do not overload the system. 

10. Do not get close to or touch motors or propellers when they are spinning as 

this can cause serious injury. 

11. Disconnect the battery and remove the camera during transportation to 

avoid damage or injury. 

12. We strongly recommend using as many DJI manufactured parts as possible. 
Syllabus For Training 

Before operating on a film/video production, training pilot shall possess at least a 

Private Pilots license and current 3rd class medical 

Trainee shall perform and be proficient in the following areas. 

Understand Lipo battery safety. Perform charging and storing charge safely 

under proper conditions 

A. Quadrocopter 

1. Be familiar with manual and perform check list before flight 

2. Be able to take off and land within a 5 foot circumference 

3. Fly to a specified height, hold altitude within ( + -) 2 feet, rotate helicopter 

360 degrees in either direction 

4. Fly a straight line 20 feet from takeoff in any direction with helicopter facing 

any position requested by trainer, while keeping copter within 3 feet of 

altitude 

5. Fly a prescribe circle around a point while keeping copter within 3 feet of 

prescribe altitude. 

6. Create simulated emergency problems and perform safe operations until 

landing 

7. Have minimum of 10 hours flying time and at least 10 take off and landings 

B. DJI 900 or DJI 1000 (After successfully completing above requirements) 

1. Perform numbers 1 to 7 above 

2. Operate with camera person and perform the following maneuvers 

(a) Hover helicopter, hold position within ( +-) 2 feet while camera pans a 

scene 

(b) Fly along a line in any direction at prescribed altitude, speed and distance 

from line while camera operator shoots objects along the line 

(c) Pylon around an object at prescribed altitude, speed and distance from 

object while camera operator shoots object 

(d) Have minimum 20 Hours flying time and 10 take off and landings 

MCS Communications- Flight Training Syllabus (2015) 
SPECIFICATIONS 5900 51000 

FRAME ~~ 

5900 Englis~1 S1000 English 

ITEM S900 Metric (Approx.) 51000 Metric (Approx) 

Diagonal Wheelbase 900mm 35.5" 1045 mm 41.1" 

Frame Arm Length 358mm 14" 386mm 15.2 II 

Frame Arm Weight 316g 11.1 oz 325 grams 11.4oz 

Center Frame Diameter 272mm 10.7" 337mm 13.2" 

Center Frame weight 

w/Landing Gear 1185grams 41.7 oz 1520 grams 53oz 

460L*450W*360 18.1"*17.7"* 460mmL *511W 

Landing Gear Size Ht 14.2" *305mm H 18.1"*20"*12" 

MOTOR 

STATOR SIZE 41mm*14mm 1.6"*0.5511 41mm*14mm 1.6"*0.55" 

kV 400rpm/V 400rpm/V 

Max Power 500Watt 500 Watt 

Weight w/cooling Fan 158g 5.6oz 158g 5.6oz 

ESC 

Working Current 40A 40A 

Working Voltage 6S LiPo 65 LiPo 

Signal Frequency 30HZ-450Hz 30HZ-450Hz 

Drive PWM Frequency 8KHz 8KHz 

Weight w/Radiators 35g 1.2 oz 35g 

FOLDABLE PROPELLERS #1552/1552R 

Material High strength performance Engineered Plastic ) 

Size 15"*5.2" 15"*5.2" v 

Weight 13 gr 0.45 oz 13 gr 0.45 oz 

FLIGHT PARAMETERS 

Takeoff Weight 4. 7Kg-8.2Kg 10.3lbs-181bs 6.0 Kg-11.0 KG Blbs.-24 Lbs 

Weight (Empty) 3.3Kg 7.21bs 4.4 Kg 9.71bs 

Lipo(6s,10000mA Lipo( 6s,10000m 

Power Battery h-15000mAh, 15C(Min) Ah-20000mAh 15C(Min) 

Max Power Consumption 3000W 4000w 

12000mAh & 15000mAh & 

6.8 KgT/0 9.5KgT/O 

Hovering Time 18min@ Weight 15 minutes @' Weight 

Hovering Power Consumption T/Oweight 1500W@9.5 Kg T/Oweight 

Working Environment 

Temperature -10Cto +40C 14Fto 104F -10Cto +40C 14Fto 104F 

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