Fine Mark Media

Corey Hannigan

723 Nova Court

Worthington, Ohio 43085

614.595.8503

Sales@FineMarkMedia.com

December 29, 2015

U.S. Department of Transportation Federal Aviation Administration

Docket Management System 800 Independent Ave., S.W.

1200 New Jersey Avenue Washington, D.C. 20591

SE Washington, DC 20590 

FAA Section 333 Application filed via FAA Section 333 Petitions Shell Docket

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of 

the FAA Regulations and certain parts of the FARs. 

Dear Representative of the Federal Aviation Administration:

Please be advised that by this letter I am writing as President of Fine Mark Media 

to request an exemption pursuant to Section 333 of the FAA Modernization 

Reform Act of 2012 and the procedures contained within 14. C.F.R. §11 to 

operate an unmanned aircraft system (UAS) to conduct aerial photography and 

videography of real estate, marketing events, agricultural resources, roofing

repairs, weddings, landscape and property photography. Fine Mark Media will 

operate one or more of the following UAS’: Yuneec Q500, DJ1 Inspire 1. This 

exemption request is more fully detailed below.

In order to provide safe and environmentally-friendly aerial videography and 

photography for public and business interests, I, Corey Hannigan, President of 

Fine Mark Media, formally submits this request for exemptions from the following 

Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 

61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 

C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 

91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 

91.417(a) and (b), so that I may operate the Yuneec Q500 and DJ1 Inspire 1 in 

accordance with the guidelines of the UAS’ operator’s manuals

1

as well as in 

accordance with current FAA guidelines for UAS flight. These UAS will be 

equipped with detachable cameras and sensors.

																																																							

1 The	manuals	of	the	Yuneec	Q500	and	DJI	Inspire	1	will	be	submitted	upon	request.
The unmanned aircraft systems Fine Mark Media intends to use for personal and 

business purposes will be safely operated according to the manufacturer’s 

guidelines and in compliance with all mandates of the FAA. To illustrate Fine 

Mark Media’s commitment to safety and to evidence the operation of our UAS’ is 

in the public’s best interest so the FAA can find good cause to grant our 

requested exemption, I provide you with the following information concerning the 

UAS’ we intend to use - Yuneec Q500 and DJ1 Inspire 1:

1. Each UAS (listed above) weighs less than four pounds including the battery 

and camera. 

2. Each UAS (listed above) will be operated/flown at an altitude of no more than 

400 feet above ground level (AGL) and not more than 200 feet above an 

elevated platform from which any planned filming would take place.

3. Each UAS (listed above) is electrically powered by a lithium polymer battery 

which limits maximum flight time for each operation flight to less than 30 minutes. 

In accordance with manufacturer’s guidelines each flight will be terminated at 

25% battery power reserve or 30 minutes flight times, whichever occurs first.

4. Each UAS (listed above) will have a maximum operating speed of 50 mph, but 

will be operated at speeds less than 40 mph.

5. All flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO). Fine Mark Media intends to use 2 operators on site 

for every filming endeavor. The pilot will maintain a clear line of sight with the 

UAS and a visual observer will always be in communication with the PIC at all 

times.

6. In addition to the PIC and VO, Fine Mark Media will employ a separate 

camera operator (CO) for filming when necessary.

7. Prior to every UAS flight, a safety briefing will be conducted by the UAS pilot -

advising all involved in the flight of the laws governing UAS’ (both locally and 

federally) and of the manufacturer’s instructions and safety guidelines –

concerning the production activities of the day. Additionally - prior to each flight -

the Pilot in Charge (PIC) will perform a pre-flight safety inspection of each UAS 

intended for flight. 

8. Fine Mark Media will log all flight activities and, furthermore, will maintain the 

logs for inspection of local, state and federal review.

9. Fine Mark Media will only fly UAS” when permitted by Visual Flight Rules 

Meteorological Conditions (VMC) - or when VMC deems flying appropriate.

10. Fine Mark Media’s UAS’ do not have the capability of carrying combustible 

fuel, nor are they able to carry crew. As such, in accordance with FAA 

guidelines, Fine Mark Media will not carry crew or carry combustible fuel on any 

UAS.

11. No flights conducted by Fine Mark Media will take place closer than a 5 mile 

radius of an uncontrolled) by an airport.

12. Fine Mark Media commits that it will obtain (documented) verbal or written 

permission from all persons (including private land owners) within 100 feet of all

flight operations.

13. Each Fine Mark Media PIC, VO and CO will receive training on the operation 

of all UAS prior to any planned flight.
14. Each Fine Mark PIC, VO, and CO – at all times during operation of UAS –

will have the ability to verbally communicate by voice or radio with each other.

15. In the event any UAS loses communication via remote controller or in the 

event the UAS loses its GPS signal, every Fine Mark Media UAS has the ability 

to return to a pre-determined location and thereafter land autonomously. 

Furthermore, each PIC operating a flight with a UAS owned Fine Mark Media has 

the capability of aborting the flight in case of an emergency at which point the 

Return Home Function of the UAS will automatically function. Every Fine Mark

Media UAS has the capability of aborting a flight in the event an unpredicted 

obstacle is encountered, or in bad weather or in the event of a low battery or 

other unpredicted emergency.

16. Fine Mark Media agrees to notify the FAA in the event any incident, accident 

or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA within 24 hours. All accidents 

will be reported to the National Transportation Safety Board (NTSB) pursuant to 

the instructions provided on the NTSB website. www.ntsb.gov.

The exemptions proposed will allow me to operate Fine Mark Media’s Yuneec	

Q500,	 DJ1	 Inspire	 1	 UAS’ as a service to the public and business interests for 

the personal and commercial purposes outlined above – specifically for 

performing aerial videography and photography as a service to public and 

business interests, including: real-estate photography and videography, wedding 

and private individual photography and videography, public and commercial 

photography and videography, and agricultural photography and videography

(including landscapes and properties) and for photography and videography of 

marketing events. 

The FAA recently approved similar use of the UAS owned by Fine Mark Media.

2

 

These UASs have been proven reliable and safe flying machines managed by 

gyroscopically-stabilized flight, ground detection, GPS-aided navigation, a built-in 

compass, blinking LED lights, manual and automatic failsafe modes for returning 

to the controller, and propeller guards in order to protect both the UAS and the 

environment. The models I’ve listed combine state-of-the-art, proven technology 

with high quality manufacturing and user-friendly control to ensure safe operation 

and easy maintenance. 

Specific section or sections of 14 CFR from which I seek relief and the 

reason I seek relief: 

14 C.F.R. Part 21: Airworthiness Certificates 

Given the size and limited operating areas associated with the aircrafts to be 

utilized by Fine Mark Media, an exemption from Part 21 is appropriate. The UAS’ 

listed in this application meet the requirements of an equivalent level of safety 

																																																							

2 See	FAA-2015-3210,	FAA-2015-3329,	FAA-2015-4365	and	FAA-2015-4414.
under Part 11 and Section 333 of the Reform Act. Pursuant with Exemption No. 

12045, “in all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than conventional 

aircraft operating with an airworthiness certificate without restrictions and 

conditions proposed.” 

14 C.F.R. 45.23: Display of marks: general 

Because our UAS’, the Yuneec	 Q500,	 DJ1	 Inspire	 1,	 will not have a cabin, 

cockpit, pilot station, fuselage, boom, or tail on which to mark words, numbers, or 

phrases, I request exemption from the above regulation as the regulation 

appears inapplicable.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command 

Pursuant to Exemption 12045, “The FAA has previously declared that additional 

manned airship experience of a commercially certified pilot would not correlate to 

the airmanship skills necessary for similarly proposed operations in previously 

issued exemptions to this regulation through Exemption Nos. 11062 and 11138.” 

14 C.F.R 91.7: Civil aircraft airworthiness 

Currently there is no certificate applicable to UAS, and therefore it will be up to 

me, Corey Hannigan – President of Fine Mark Media, to determine the 

airworthiness of the Yuneec	 Q500,	 DJ1	 Inspire	 1	 in accordance with the official 

operating manuals of each unit. Pre-/ post-flight inspections of the propellers, 

motors, frame, landing stands, camera and gimbal will be performed before and 

after each flight, accurate records of which will be kept with the UAS’s storage 

and transportation system at all times. 

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard 

requirements 

Please note that pursuant to Exemption 12045, since there are “no pilots or 

passengers on board this aircraft, and given its size, this regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the operator.” 

14 C.F.R. 91.119(c): Minimum safe altitudes

As indicated above, I, Corey Hannigan – President of Fine Mark Media - will 

ensure that any UAS owned and operated by Fine Mark Media does not operate 

any higher than 400 feet above ground level. I will not fly over congested areas. I 
will plan operations beforehand for proper flight safety and proper height analysis 

as to avoid collisions. 

14 C.F.R. 91.121: Altimeter settings 

Both the Yuneec	 Q500 and	 the DJ1	 Inspire	 1	 utilize electronic GPS with 

barometric sensors with live data output to the mobile device attached to the 

transmitter. An equivalent level of safety will be achieved by using this function. 

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions 

As indicated above, the UAS that Fine Mark Media will fly are electricallypowered by lithium ion batteries specifically manufactured for each particular 

UAS. They are rated at no longer than 30 minutes of flight time. Therefore, due to 

the limitations of the batteries, it is currently impossible to comply with part 

91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness certificates for the 

mentioned UAS’. I, Corey Hannigan – President of Fine Mark Media, however,

will always that I fly safely while having the manuals of the Yuneec	 Q500	 and	 the	

DJ1	Inspire	1 available.

14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation 

after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 

91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 (a) and (b): Maintenance 

records:

Maintenance inspections for all Fine Mark Media UAS’ will be performed prior to 

every flight. Further maintenance inspections may be required and should be 

granted since they only apply to aircraft with an airworthiness certificate. 

However I, Corey Hannigan – President Fine Mark Media, will perform both 

preflight and post-flight inspections of all UAS’ utilized before and after each flight 

as outlined in the operating documents. I, Corey Hannigan – President of Fine 

Mark Media, will also follow manufacturer recommendations from said operating 

documents. 

Public Interest: 

Aerial photography and videography provided to the public allows for a more 

cost-effective and environmentally-friendly method of capturing imagery than its 

alternative: manned aircraft and helicopters. Manned aircraft and helicopters are

expensive to operate. They create excessive noise and environmental pollution, 

and are much more hazardous to the public due to their size and because they 

necessarily carry combustible fuel. Without question, UAS’ are far safer than 
manned flying machines – both in terms of safety for citizens and safety for the 

environment.

In addition to using my UAS’ for commercial endeavors, Fine Mark Media will 

also offer its services - upon request - to benefit the public. While Fine Mark 

Media has no intention of soliciting gratuitous opportunities to serve the public, 

Fine Mark Media’s commits it’s services to the public upon request.

Given that there is no fuel and no crew on the UAS’ owned by Fine Mark Media, 

and considering that the Yuneec	 Q500	 and	 the DJ1	 Inspire	 1 weigh under four 

pounds, has propeller guards - as well as having a low maximum speed (less 

than 25mph) - the safe operation of Fine Mark Media’s UAS’ will not pose any 

immediate danger to the environment, wildlife, or individuals. Also, please 

consider the units described above possess GPS and ground-sensing 

capabilities, along with safety features designated as a “return” mode that will 

safely return the crafts to the PIC at the push of a button or – importantly -

automatically when the UAS is low on battery power or if the UAS encounters an 

unforeseen obstacle. These safety measures ensure all Fine Mark Media UAS’

will not remain airborne in unsafe conditions. 

The addition of UAS-controlled aerial video and photography services provides 

both public and commercial sectors with an environmentally-friendly and costeffective means by which to obtain photography and videography services. 

Because of this, an increase of commercial activity and a gaining of more 

detailed understanding of private and/or farm land would help local and area 

communities by: reducing pollution, risk, and operating costs by alternative aerial 

video and photography services such as manned airplanes and helicopters, 

reducing carbon emissions and traffic congestion by vehicles looking to view 

properties such as real-estate or farm land, and increase visibility to local 

attractions thereby bolstering local commerce and tourism. 

Summary

I seek (on behalf of Fine Mark Media) an exemption from the following rules: 14 

C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 

C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 

14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 

C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). With the exemptions of 

the aforementioned rules, Fine Mark Media will seek to make its 

photography/videography services available to public and commercial interests.

Public and commercial interests have previously sought the use of manned

aircraft to achieve what Fine Mark Media can offer. The difference is Fine Mark 

Media can offer the above referenced services in a safer, more cost-efficient and 

environmentally-friendly manner to public and private interests by not using 

combustible fuel, flying at safer heights and by strictly following the usage 
recommendations from the operating manuals of the UAS and by complying with 

federal, state and local laws. These safety measures include but are not limited 

to: 

● Flying the UAS’ safely in accordance with each’s operating manual.

● Always flying below 400 feet.

● By thoroughly inspecting each UAS before and after flights and keeping 

inspection records with the craft at all times.

● By keeping each UAS in visual sight at all times when in operation.

● By using an observer to assist the PIC on every flight.

● By remain safely clear of and do not interfere with manned aircraft operations.

● By not intentionally flying near dangerously or over unprotected persons or 

moving vehicles.

● By contact an airport or control tower before flying within 5 miles of their 

vicinity. The defined policies of Fine Mark Media will never permit flying within 5 

miles of an airport or control tower.

● By not flying in adverse weather conditions such as high winds, rain, or 

impaired visibility as outlined above.

● By never allowing a PIC to fly under the influence of alcohol or drugs. By 

mandating that at least 2 people will be present for every flight, Fine Mark Media 

is able to ensure the enforcement of this statement.

● By unfailing ensuring the operating environment for the UAS is completely 

safe.

● By ensuring every PIC will not fly over sensitive infrastructure or property such 

as power stations, water treatment facilities, correctional facilities, etc. 

● By checking, complying with and following all local, state and federal laws and 

ordinances before flying over private property.

● By forbidding all Fine Mark employees from conducting surveillance or 

photography of persons in areas where there is an expectation of privacy without 

an individual's permission.

I have carefully reviewed the criteria set forth for meeting the requirements of my 

application for an exemption. I hope I’ve accurately met the standards set forth. 

In the event I’ve omitted necessary information, it’s my hope you’ll contact me in 

so I can provide any information necessary for the granting of this application.

I sincerely appreciate your consideration of this application and look forward to 

your timely response.
Respectfully submitted, I am 

Sincerely, 

Corey Hannigan

President, Fine Mark Media