Indovina 1

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	N ational Airspace System

. For	nearly	the	last eight	years	I	have flown as	a	full	time commercial	pilot in	traffic watch,	flight	instruction and	p a rt
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- demand	charter	operations and	operated Mike	Six	Aerial	Imaging photography	business	and	hobby on	the	side.		In	recent word	of	the	proposed	laws	re garding	UAS	drones	I	began to decid e this	would	be	a perfect	addition	to	my	work,	given	my	training, extensive	knowledge and background in	this	area

. Having flown both rem otely	controlled and fixed	wing aircraft at	a	young	age give s me	a	strong and	stable foundation	in	this industry	as my	pe rformance	has	continued	to	develope	into	an	instinct.		Working in the	system for	the	past	decade	in combin ation 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	mys elf	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

. The se 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	certifi cate. I	wish	to	support	the	growth	of	this	industry by	maintaining and	complying	with in a	strongly	structured	business	plan and FAA approval	in combin ing	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	mo tors	with	the	capability o f	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 wei ght	of less	than 2	pounds .		The UAS s hips ’ only	purpose	is to	be used	in still /motion	framed filming,	compliant	with in Line	of	Sight	control, flight altitudes well below	400	feet	above ground l evel with	a total combined	flight weight	of 8	pounds	including its twin batteries. Its	fli ght 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.Indovina 2

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	twi st	to	my	photography	business	with the	usage	of	my personally	assembled dr one	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 through out my	work performance

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Developmental, O perational H istory and	Limitations : August	2014	design, plan and	construction	were all carefully	cons idered	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	a n internal, 3

- axis	gyroscope for	ship leveling	and a	b arometric	altitude	se nsor 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,	airsp eed, altitude,	magnetic	heading,	battery	voltage,	and	GPS	latitude	&	longitudinal data	to the	ground	station	for	an	added	level	of	control. Fixe d	opposite	of	each	other	to counter
- balanc e each	others weight	are	2	lipo	batteries	that	provide up	to 20 minutes	of	flight	between	swapp ing,	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	Laun ch, 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	cautiou sly executed at	a safe	and controlled	field.		Each	flight ses sion 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.Indovina 3

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	f or	the displayed	flight information .		All	of	the UAS	RF signals	are	FCC	compliant. The PIC	of	this	drone	is	myself,	Michael	Joseph	Indovina	VI,	a nd is directly responsible	for	the	operation	of	this	UAS.		I	am	an	ATP	Pilot	with over 4,500 flight hours	and hold	a	firs t	clas s	medical	certificate.		With	this UAS,	I	have currently logged	49 fli ghts,	an d	accumulated	more	than	5	flight	hours

. Medical	standards	for the	pilot	would	be	such	that	mimic	regulations	for	flight	in	aircraft	under	FAR	parts 6 1 & 91

. F l ight	operations	would	include	myself,	a	camera	operator	and	a minimum	of	one flight	observer	to	ai d	and	assist with flight operations .		Both	assistants wi ll	obtain qualifications	of ground instruction	and a	satisfactory demonstration	of knowledge and perfo rmance 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	are a	will	b e	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

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- 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	o f	20%	battery	charge	( 6	minutes	of flight time remaining as	a reserve . ) Flights	are n ever to be conducted	over	people	or	a	crowd,	and	operate d at a	minimum	safe	altitude	over	objects	or	property	as	n ot	to	create	a	collision	hazard. F light	altitudes	will	n ever be	conducted above	400	feet	Above G round L evel

. 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 condition s	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	contro lling	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	m ounted by	metallic screws and	in	someIndovina 4

cases adhesive	tape	an d	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,	f ire	and	injury risks c ould	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	C onclusion:
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 fo r	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	des ire 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	uni nvolved .		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

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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

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