Jeremy Salo

26652 Wilton Court

New Hudson, MI 48165

(248) 207-3056

jsalo@clvpro.com

October 29, 2015

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

(Submitted electronically to the Federal Docket Management System)

Re: Request for Exemption under section 333 of the FAA Reform Act

I am seeking relief from these sections in order to operate a Phantom 2 unmanned aerial system for

purposes of capturing photography and video for commercial purposes. I am seeking complete or 

partial exemptions from the following sections of 14 CFR as you seem appropriate:

Part 21 Airworthiness Certification

21, Subpart H -Certification procedures for products and parts, Airworthiness Certificates

Part 61 Certification: Pilots, Light Instructors, and Ground Instructors

Part 91 

General Operating and Flight Rules

91.103(b)(2) - Preflight action

91.105 - Flight crewmembers at stations

91.109 - Flight instruction

91.119 - Minimum safe altitudes

91.121 - Altimeter settings

91.151 - Fuel requirements for flights in VFR conditions

91.405 - Maintenance required

91.407 - Operation after maintenance

91.409 - Inspections

91.417 - Maintenance records

The public will benefit from this exemption as I will be able to provide a service for them in a safe 

manner instead of them purchasing a cheaper unmanned aircraft and operating it themselves. For 

example, perhaps a local golf course would like a promotional video that shows their landscape. 

Currently minimal options exist in my area for them to hire a local freelance company to get these 

images within a reasonable fee. So instead they may go to the local shopping mall and purchase a cheap 
quad chopper to fly and record the footage themselves. They will most likely not know the regulations 

of the FAA and general conditions of operating a Unmanned Aircraft System - UAS. For example, they 

may not understand wind directions and that a UAS can increase it’s speed over 10 times when changing 

directions according to the wind masses and speed. This may not allow them enough time to safely land 

the UAS before their battery runs out of charge. I have studied the FAA rules and guidelines for 

maintaining a safe airspace and understand them . Furthermore, I have over 8 months of experience and 

250 hours of flight time operating my UAS as a hobbyist and understand it’s capabilities and limitations.

Also, my Phantom 2 has many safety features built in, such as returning home when the battery is low 

using GPS, GPS stabilization, and will not fly into restricted areas. These cheaper models that some store 

owners may use now typically do not have these functions. The unmanned aircraft system I fly, my 

experience and knowledge will make the processing and capturing low altitude aerial footage much 

safer than the current process of each person buying their own cheaper model and flying it themselves.

It is also less dangerous for this small unmanned light weight UAS to record the footage than putting a 

live crew in a smaller aircraft with combustible fuel into the air.

The exemptions would not adversely affect safety. In fact, I will be an advocate for having an unmanned 

vehicle registered, learning the FAA rules and guidelines and teaching these to others. I am a college 

professor at a community college that teaches photograph and video production. We do not have any 

current plans to include UAS directly in our curriculum, but students seek guidance from me about 

current and emerging technology. I provide them with the information they need or direct them to the 

appropriate areas to learn more. I am attaching the Phantom 2’s aircraft flight manual along with my 

other accessories for detailed specifications and design of the units and how they help maintain a safe 

airspace.

I understand national airspace and would not fly above 200 feet for commercial purposes without a 

Certificate of Waiver for Authorization . Most of the time the UAS will be traveling a slow speed in order 

to capture a nice smooth video image. At no point would the UAS exceed 100 Miles per hour. I will keep 

the UAV under the recommended maximum speed as mentioned in the aircrafts manual attached. 

I will maintain a safe distance from all aircraft and avoid collision with them. I will also not fly directly 

over people. Most photography and flights will be over less populated areas including nature 

landscapes. I will keep the UAS within the direct line of sight or have a spotter that can see the UAS and 

communicate with me at all times. Here is an example of what a spotter would do. There is a tree that 

may temporally be in my line of site as the operator (pilot in command). The spotter would be on the 

opposite side of the tree so they can see it directly when I can only see the video signal. They would 

verbally tell me if any obstructions or other situations are an issue that I cannot see on the live video 

feed.

As an operator, I will still see the video signal which shows me ultra-wide angle of view at approximately 

a 15-mm equivalent as compared to a 35mm lens format. The spotter will either be in talking distance or 

will be communicating through a cellphone or similar communication device. As an operator of the UAS, 
I was have an earpiece for communication or speaker if necessary but will always have both hands 

available to control the UAS. 

I will not fly the aircraft in restricted areas and within close proximity of an airport. This aircraft has built 

in GPS controls that automatically restrict flight into these restricted areas. I will inspect the UAS before 

each flight to make sure it is flight ready. The Phantom 2’s aircraft flight manual details the preflight 

routine I follow in more detail.

I also make sure the firmware of the aircraft and it’s individual components are up to date by plugging 

in the device to my computer, scanning all components, and having the software check online to make 

sure they are all up to date. The program is called DJI Phantom 2 Vision Assistant_3.8. It also digitally 

verifies the integrity of the components of the aircraft. I can calibrate the aircrafts controller using this 

software or make other changes needed before a flight. I do this once a month or more if I receive an 

email notification about updates or if I visually notice anything that appears abnormal about the aircraft.

This software also updates restricted areas or air space heights that the FAA and other governing bodies 

enter into the system. 

I will make sure I have enough battery charge for the duration of the intended flight plus a reserve 

amount as recommended in the manual.

The operating Frequency of the aircraft’s controller is 2.4GHz ISM. The unit is approved for such use by the 

FCC.

An Immersion RC Transmitter installed on the aircraft to send a live video signal to me. This shows a video 

stream from the aircraft and other information about the flight as listed below and on the attached documents. 

The transmitter operates on a 600mw 5.8 GHz frequency. The unit is approved for such use by the FCC. 

I have a DJI iOSD Mini On-Screen Display for real- time flight information installed in the aircraft. This provides 

me the information while I’m controlling the aircraft such as its pitch, yaw, and roll amounts, velocity, height and 

distance from take-off point, plus amount of battery power The User Manual is attached for full details.

I use a GoPro Hero 4 Black Edition camera to see a live stream from the UAV and record the aerial footage. 

The camera with battery and memory card weighs about 3 ounces. I attached the user manual for detailed 

information about the unit. I do not turn on the Bluetooth signal during flights. I start the recording of the camera 

before I start the aircraft. The camera both records to the internal card and sends a signal for live preview 

simultaneously.

I use a Zenmuse H4-3D gimbal that stabilizes the camera during flight. This gives me a more stable image 

during flight that aids with control of the aircraft and also provides a much smoother video recording. 

The manual is attached for detailed specifications of the unit. 

I use a monitor on the ground to see the signal sent from the transmitter of the aircraft. Currently the model of 

monitor I use is the FlySight 32 Ch Black Pearl 5.8 Ghz 7” Diversity monitor.

I would like to exercise my privileges to fly outside the United States of America . I am a US citizen and 

have been since I was born in the USA. One reason I would like permission to fly outside the US is that I 

live in Michigan close to the great lakes such as Lake Erie. Sometimes I record footage of the lakes. One 

side of the lake is US waters and the other side is Canadian waters. It would make sense to have the 
option to fly from the safest positon of the lake. I have crossed the border into Windsor to take 

photographs and video of Michigan from the other side in Canada from the ground but have not yet 

recorded any aerial images out of the country. 

Also, I currently distribute some other videos internationally. There is a possibility that I may travel to 

other countries to promote videos , record new footage or whatever needs a client requests. The 

exemption would be in compliance with the Standards of the International Civil Aviation Organization 

(ICAO) and I would make sure to follow those standards and other rules of the country.

I am in the process of having my unmanned aircraft registered according to the Aircraft Registration 

requirements and directions provided in 14 Code of Federal Regulations Part 47 .

If I intend to conduct operations such as motion picture and television filming which have existing 

requirements, I will notify Flight Standards District Offices (FSDOs) prior to operations to describe the 

intended coordination in this regard for the proposed operation(s).

Please let me know if I have left anything out in this request. A timely response and approval of this 

exemption will be the safest solution to the amateurs not as familiar with UAS and FAA rules currently 

flying and recording footage around my area. I would follow any modifications, additions or subtracts 

you send with the approval of this request along with what is already stated.

Sincerely,

Jeremy salo