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To	Whom	It	May	Concern:

I	am	a	Los	Angeles	native, active	Airline	Transport	Pilot,	CFI	and	aerial	

photographer	operating	under Mike	Six	Imaging.		This	letter	is	written	to	request	for	

an	exemption	to	Section	333	for	UAS	drone	filming	for	commercial	gain with	the	

intent	to	comply	with	all	existing	and	future	FAA	Regulations	under	the	National	

Airspace	System.

For	nearly	the	last	eight	years	I	have	flown as	a	full	time commercial	pilot	in	traffic	

watch,	flight	instruction and	part-135	on-demand	charter	operations and	operated	

Mike	Six	Aerial	Imaging	photography	business	and	hobby	on	the	side.		In	recent	

word	of	the	proposed	laws	regarding	UAS	drones	I	began	to	decide this	would	be	a	

perfect	addition	to	my	work,	given	my	training, extensive	knowledge	and	

background	in	this	area.	 Having flown	both	remotely	controlled	and	fixed	wing	

aircraft at	a	young	age gives me	a	strong	and	stable foundation	in	this industry	as	

my	performance	has	continued	to	develope	into	an	instinct.		Working in	the	system	

for	the	past	decade	in	combination with my	knowledge	of	the	airspace,	regulations

and	procedures	I feel that	I	would	be	an	ideal	candidate	and pilot	in	the	eyes	of	the	

FAA with UAS	drone	operations.			I	have	proven	myself	true	in	my	flight	career	to	

date,	I	have	logged	more	than	4,500	hours	total	time	and	hold	a	jet	PIC	rating,	with	

not	one	violation	of	regulations	or any incidents.

These recent	changes	for	usage	of	remotely	controlled	devices	for	film	and	

photography	create	an	advantage	to	many, including	myself,	who have	the	

background	in	remotely	controlled	aircraft	operations	whom also	hold a	pilot’s	

license and	current	medical	certificate.		I	wish	to	support	the	growth	of	this	industry	

by	maintaining	and	complying	within a	strongly	structured	business	plan and	FAA	

approval	in	combining	my	efforts	with	you	as	the	system	continues	to grow.

Design:

My	UAS	system	is	comprised	of	lightweight,	exceptionally strong	foldable	carbon	

fiber	frame	with six	brushless	motors	with	the	capability	of	generating	over	19lbs	of	

lift.		Affixed	within	are	GPS,	magnetic	compass, and	barometric	altitude	sensors	with

a	3-axis gyroscope to	maintain	stability	and	remotely	controlled	via	a	radio	

transmitter.		Permanently	mounted	below as	payload,	center-ship is	a	Sony	Nex-5	

small and	lightweight DSLR	camera	fixed	on	a	3-axis,	self-righted	camera	gimbal,

with	a	total	combined	weight	of	less	than 2	pounds.		The UAS ships’ only	purpose	is	

to	be	used	in	still/motion	framed	filming,	compliant	within Line	of	Sight	control,	

flight	altitudes	well	below	400	feet	above	ground	level	with	a total	combined	flight	

weight	of 8	pounds	including its twin	batteries.		Its	flight speeds	are	flown	very	

slow,	much	below	mandated	speeds	of	50kts, and	has	four	fail-safe	modes:	one	for	

radio	failure,	one	for	GPS	failures	and	2	for	battery	low	conditions.		
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To	date,	I	have	kept	an	extensive	flight	log	including	maintenance	performance tests,	

removal,	repair	& preventative	maintenance	with return	to	service descriptions	and	

have	logged	over	5	hours of	flight	time.		

My	plan	is	to	offer	a	creative	twist	to	my	photography	business	with the	usage	of	my	

personally	assembled	drone	to	capture	shots,	reducing	the	traffic	load	on	the	NAS	by	

splitting	events	between	the	use	of	aircraft	and	my	drone.		My	photos	are intended

primarily for	commercial	real	estate	and/or	personally	invited	events,	and	would	

not	in	any	way	adversely	affect	or	jeopardize anyone’s	safety.		I	plan	to provide	the

level	of	safety	standards	equal	to	what’s	required	under	FAR	parts	61	and	91.		My	

system	was	designed	with	safety	and	professionalism	in	mind,	and	shows	

throughout my	work performance.

Developmental,	Operational	History and	Limitations:

August	2014	design,	plan	and	construction	were all	carefully	considered	when	

piecing	together	this	system.		The	choice	of	6	power-plant	motors	over	4	added	an	

extra	edge	and	added	protection	from the	unexpected	event	of a	sudden,	in-flight	

power	or	rotor-blade	failure.		The	Flight	Controller	is	manufactured	by	APM (3dr	

robotics) a	vastly	tested	and	trusted	company	in	the	industry,	which	contains	an	

internal, 3-axis	gyroscope	for	ship	leveling	and a	barometric	altitude	sensor	which	

offers altitude	hold	operations.		The	GPS	antenna	and	on-board	compass	module	can	

be	used	for	position	logging,	position	hold,	GPS	guided,	and	return	to	launch	and/or	

failsafe	operations.		The	flight	controller	also	transmits	pitch	&	roll,	airspeed,	

altitude,	magnetic	heading,	battery	voltage,	and	GPS	latitude	&	longitudinal data	to	

the	ground	station	for	an	added	level	of	control.		Fixed	opposite	of	each	other	to	

counter-balance each	others weight	are	2	lipo	batteries	that	provide	up	to 20	

minutes	of	flight	between	swapping,	and	are	wired	in	parallel	to	cover	the	event	of	a	

sudden	loss	of	current from	each	other.		Redundancy	was	at	the	forefront	of	mind in	

the	design.

Numerous	test flights	of	the	3	flight	modes:	GPS	lock,	Return	to	Launch,	Altitude	

Hold;	and	failsafe	operations: loss	of	radio	control	signal	or	low	battery	voltage	

triggering	either	landing or	a	return	to	the	launch	position	and land	were all	

meticulously	and	cautiously	executed at	a	safe	and	controlled	field.		Each	flight	

session	begins	with	an	extensive	preflight	inspection	of	all	power	plants,	propellers

and	frame	structure,	flight	mode	conditions,	flight	data	read-out	display	and	flown	

only	after	all	have	been deemed	satisfactory	for	flight,	pursuant	to	14	CFR	section	

91.7(b).		A	wireless	connection	to	a	base	station,	a	separately	powered	Apple	laptop	

running	APM	software	that	provides	a	up-to-the-second	active	display	of	the	flight	

mode,	flight	attitude,	ship	altitude and airspeed,	latitude	&	longitude	position	and	

battery	voltage.		All	maintenance	and	repairs	have, and	always	will	be, performed	by	

myself	with	compatible	and/or	identical	parts,	logged	and	tested	prior	to	any	

subsequent	flight.		Again,	safety	is	a	key	principle	value.
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Radio	control	is	accomplished	via	a	2.4	GHz,	pre-bound	(singular	bonded)	signal	

with	frequency	hopping	technology	to	prevent	signal	interference	or	interruption.	 A	

933MHz	signal	is	established	between	ground	control	unit	(laptop	&	APM	software)	

and	APM	controller, operated	as	an	optional	unit	for	the displayed	flight	

information.		All	of	the UAS	RF signals	are	FCC	compliant.

The	PIC	of	this	drone	is	myself,	Michael	Joseph	Indovina	VI,	and	is directly	

responsible	for	the	operation	of	this	UAS.		I	am	an	ATP	Pilot	with	over	4,500	flight	

hours	and	hold	a	first	class	medical	certificate.		With	this UAS,	I	have	currently	

logged	49 flights,	and	accumulated	more	than	5	flight	hours.	 Medical	standards	for	

the	pilot	would	be	such	that	mimic	regulations	for	flight	in	aircraft	under	FAR	parts

61 & 91.	

Flight	operations	would	include	myself,	a	camera	operator	and	a minimum	of	one	

flight	observer	to	aid	and	assist with flight operations.		Both	assistants	will	obtain	

qualifications	of	ground	instruction	and	a	satisfactory	demonstration	of	knowledge	

and	performance prior	to any service.		The	observer’s	primary	objective	will	be	to

notify	of	any	aircraft	in	the	proximity	to	cease	flight	activities,	and	most	importantly	

for	population	control	to	maintain	a	clear	area	in	the	flight	environment.		A	

quarantined	area	will	be	used	for	drone	departures	&	arrivals,	including	all	flight	

paths,	which	will	be	segregated	from	any	interference	as	an	added	safety	barrier.		

All	flight	operations	will	be	controlled	within	close proximity	of	the	UAS,	within	

visual	line-of-sight	(VLOS)	as	mandated	by	Section	333(b)(1).

Flight	times	are not	to	exceed	15 minutes or	operated	below	a	battery	voltage	of	

15.3, equating	to landing sooner	than	80%	of	the	total	available	capacity	and/or	

with	a	minimum	of	20%	battery	charge	(6	minutes	of	flight time	remaining as	a	

reserve.)		Flights	are	never	to	be	conducted	over	people	or	a	crowd,	and	operated at	

a	minimum	safe	altitude	over	objects	or	property	as	not	to	create	a	collision	hazard.		

Flight	altitudes	will	never	be	conducted	above	400	feet	Above	Ground	Level.		Speeds	

operated	will	be	very	slow if	not	stationary,	much	slower	than	already	limited	and	

approved	UAS	ships	at	50 knots.			Flights	will	be	conducted	daylight	conditions	

(sunrise	to	sunset.)		Operations	will	be	limited	to	wind conditions	at	or	below 15	

knots	of	velocity	and	will	at	all	times	maintain	clear	of	clouds.		Operations	in	visible	

moisture will	be	strictly	prohibited.		Any	flight	to	be	conducted	within	5	statute

miles	of	a	controlled	airport	will	require approval	from	the	controlling	agency	prior	

to	any	flight	operations.

Safety	Risks	and	Hazards:

As	with	any	aircraft,	the	primary	safety	risks	and	hazards	with	this	UAS	are	with the	

moving	propellers,	injury	from	falling	objects	and	a	fire	hazard	from	the	electronics.		

Contact	with	the	propeller	while	it	is	in	motion	could	cause	serious	injuries	and	

could	require	hospitalization.	 Camera,	sensors	and	other	objects	fixed	to	the	ship	

necessary	for	flight	will	be	permanently	mounted	by	metallic	screws	and	in	some	
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cases adhesive	tape	and	zip-tie	straps	to	prevent being	dislodged from	the	ship	and	

onto	persons	or	property below.		A	minimal	fire	hazard	could	arise	from	an	

unexpected	crash	and	contact	with	electrical	wire	or	components.		By	carrying	a	

class	AB&C	Halon	fire	extinguisher	and	a	first-aid	kit,	fire	and	injury	risks	could	be	

minimized	and	contained	should	these	events occur.		Flight	operations	would	be	

tailored	to	meet	the	need	to	prepare,	prevent	and	reduce the	risk	of	these	injuries or	

events for	each	flight	by maintaining	a	clear	and	unobstructed	area	below	the	ship	

while	it	is	in	flight.

In	Conclusion:

With	my	declaration of	purpose and	stated	limitations	within	this	document,	I	

submit	to	you	this formal request	for	a	written exemption	of	Section	333 for	Mike	

Six	Imaging.		In	the	event	that	this	letter	does	not	satisfy	the	requirements	for	an	

exemption	I	respectfully	request	any	information	or	correspondence	so	that	I	may	

provide	to	you	any	omitted	material.		Again,	it	is	with	my	utmost	desire	to	comply	

within	your authorization, any	and	all	limitations	placed	by	you to	minimize the

potential	risks,	hazards	and/or	unnecessary	congestion	to	the	National	Airspace	

System	where	applicable,	and	eliminate	any	imposed	threats	to	any	person	or	

property	to	the	uninvolved.		My longstanding	support in the	growing	aviation	

industry	will	continue	to	build	my	reputation	of safety,	performance	and	reliability	

in	the	face	of	the	FAA	and	the	public	for	the growing	NAS	structure	at	the	forefront	

of	today’s	technology	and	changing	times	with	my	operations.

Michael	Joseph	Indovina	VI

ATP	CFI	MEI		3146873

VI@mikesix.com

www.mikesix.com

8000	West	Manchester	Ave.	#222

Playa	Del	Rey,	CA	90293

805-455-9041