Mike Zuniga Films, LLC

Contact: Mike Zuniga, Director

Address: 1130 N Kraemer Blvd Ste F

Anaheim, CA 92806

Email: MikeZunigaFilms@gmail.com

Phone: (714)-277-9573

October 20, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

RE: Exemption Request Under Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 CFR Part 11, Mike Zuniga Films, LLC, a video production 

company that owns and operates small Unmanned Aircraft Systems (UAS), 

requests to be exempted from the Federal Aviation Regulations (FAR) listed 

below allowing Mike Zuniga Films, LLC to operate UAS commercially in airspace 

regulated by the Federal Aviation Administration (FAA) being that operations are 

conducted under the conditions stated established by the FAA required by 

Section 333 or herein this document. 

Company Background and Planned Operations 

Mike Zuniga Films, LLC is a Southern California based Limited Liability Company 

(LLC) operated by Mike Zuniga, Nathan Nguyen, and Thy Nguyen. Mike Zuniga 

is the majority partner and specializes in cinematography with 3 years of 

experience and operating small multi-propeller aircraft with one year of 

experience without incident. Nathan and Thy Nguyen both have a combined 

business management and finance experience of 15 years. With experience in 

UAS operations Mike Zuniga will be the designated PIC. Mike Zuniga Films, LLC 

has added the DJI Phantom 3 Professional and DJI Inspire 1 UAS into its 

inventory with intent to conduct aerial cinematography. Operations will increase 

the academic enhancement of community awareness to geographical areas 

within but not limited to the Southern California region which may be unfamiliar to 

individuals or other companies. Photographic and cinematic operations will also 

be conducted for the production of promotional material, real estate listings, 

travel and tourism industries, commercial business, and social events such as 

weddings. Mike Zuniga Films, LLC never operates over persons not directly 
involved with the UAS. 

UAS Devices

Specifics DJI Phantom 3 

Professional DJI Inspire 1

Type RC Helicopter (4 

Propellers)

RC Helicopter (4 

Propellers)

Diagonal Size (Including 

Propellers) 590mm 559mm to 581mm

Weight 2.82 lbs 6.47 lbs

Flight Time Approx. 23 min. Approx. 18 min. 

Flight Speed (max) 31.1 knots (16 m/s) 42.76 knots (22 m/s)

Camera Integrated Integrated

Hover Accuracy

Vertical: +/- 0.1m (when 

Vision Positioning is 

active) or +/-0.5 m

Horizontal: +/- 1.5 m

Vertical: 0.5m

Horizontal: 2.5m

Max Ascent Speed 9.72 knots (5 m/s) 9.72 knots (5 m/s)

Max Descent Speed 5.83 knots (3 m/s) 7.78 knots (4 m/s)

Ground Operations

• A Pilot in Command (PIC) will be in control of flight operations of the UAS 

from start to finish (pre-takeoff, while in the air, and post-landing).

• A 2.4GHz radio transmitter/controller operated by the PIC to control the 

UAS while in flight.

• A radio receiver receiving live video and flight data from the integrated 

camera projects it all together onto a screen (mobile device, tablet, or 

external monitor) connected to the controller for the PIC to view during the 

flight. 

• A Visual Observer (VO) is an individual who provides a second pair of 

eyes to visually track the UAS while in flight. 

Reason for an Equal Level of Safety Through Operation 

The requested exemption will permit the operation of a (under 55 lbs. total 

takeoff weight) UAS within controlled conditions for commercial use. In 

comparison to using a manned aircraft of greater proportion that carries a crew 

and flammable fuel, a UAS (battery powered, small in size, light weight/high 

maneuverability, low altitude operation, and high responsiveness) reduces 

current risk levels and increases safety for the public interest. The UAS also 

decreases the risk of serious injury or death. With an approximate flight time of 

23 min. (DJI Phantom 3 Professional) and 18 min. (DJI Inspire 1) there is less 
risk to national security due to being in flight in less time. The UAS will be 

beneficial for commercial use through the quick and accurate collection of 

information with a reduced environmental impact. All operations will be 

conducted from appropriate distances with the public’s right to privacy 

safeguarded at all times. A UAS has the ability to capture videos and photos from 

a low level allowing to display characteristics of complex properties, buildings, 

and natural landscape. The UAS does not have to be extremely close to the 

objects that it’s camera is capturing as the still images and video can be enlarged 

in the post production editing process. A full-sized helicopter for this purpose has 

been proven more costly than many potential clients can afford. The improved 

quality and reduced cost of a UAS will benefit many clients which may include 

buyers and sellers for real estate and marine properties. Accordingly, the UAS(s) 

of Mike Zuniga Films, LLC have been experimentally operated for familiarization/

competency and will continue to operate at and above current safety levels. 

Statutory Authority for Exemptions

Mike Zuniga Films, LLC submits this application in accordance with the 

Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable 

FARs operating to prevent Mike Zuniga Films, LLC from future commercial use of 

is UAS’s to operate in the national airspace system as described below. The 

Reform Act in Section 332 provides for such integration of civil unmanned aircraft 

systems into our national airspace system it is in the public’s interest to do so. 

Mike Zuniga Films, LLC UAS(s) meet the definition of “small unmanned aircraft” 

as defined in Section 331 and therefore the integration of the UAS are expressly 

contemplated by the Reform Act. Mike Zuniga Films, LLC would like to operate 

its UAS(s) prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such aircraft. 

The Reform Act directs the Secretary of Transportation to determine 

whether certain UAS’s would operate safely in national airspace before 

completion of the rule making required under Section 332 of the Reform Act. The 

Secretary of Transportation is required to determine which UAS poses a threat to 

the public or create hazard to the national airspace system within the following: 

The UAS size, weight, speed, and operational capability; the operation of the 

UAS in close proximity to populated areas and airports; UAS operation within 

visual line of sight of the operator. 

Reform Act 333(a) states that if the secretary determines that such vehicles 

“may operate safely in the National Airspace System, the secretary shall 

establish requirements for the safe operation in national airspace. Mike Zuniga 

Films, LLC operates unmanned multi-propellor RC helicopters designed to hover 

in place via a set GPS location. These UAS weigh less than 55 lbs and operate 

in wind speeds of less than 24 knots (15 mph). Approval of this exemption will not 

pose any threat to national airspace security due to the size, low altitudes of 

operation, and controlled areas of the UAS. Our UAS(s) have built in safety 
systems that includes GPS mode. Mike Zuniga Films, LLC operates under Smart 

Mode for aerial cinematography/photography. This mode is the most reliable and 

safest mode to prevent accidents and potential hazard. In the event where 

communication is lost between the UAS and pilot, the UAS is designed to slowly 

descend to its original point of take off. Mike Zuniga Films, LLC does not operate 

near hospitals, airports, police heliports, and areas where the general public is 

within fifty to one hundred (50 to 100) yards depending on location, weather and 

conditions. We are constantly on alert during UAS operation for any manned 

aircraft (police/medical helicopters, etc.) and are prepared to land immediately to 

the nearest safety area should a manned aircraft approach our location. Our UAS 

is flown within the line of sight of the PIC and VO at all times and is capable of 

vertical and horizontal operations. Since the UAS is powered by batteries instead 

of combustible fuels, our flights generally last between 4 to 9 minutes with an 

average altitude of one hundred fifty (150) feet or less. We utilize a fully charged 

battery before every flight along with a fully charged backup battery. Mike Zuniga 

Films, LLC operates well above minimum charge levels and within a safe flight 

range for adequate communication between the UAS and remote control. Mike 

Zuniga Films, LLC has conducted numerous hours of experimental flight 

operation in remote areas to become familiarized with the characteristics of the 

UAS performance under different conditions. We also routinely conduct computer 

simulated flights throughout he mobile application of the UAS for further training 

and familiarization. For safety and financial reasons, Mike Zuniga Films, LLC 

does not take risks that would cause damage to manned aircraft, the public, 

property, and the UAS itself. Mike Zuniga Films, LLC demonstrates a safety 

record and does not pose a threat to the public or national security. Accordingly, 

the applicant requests that the FAA grant the requested exemption. 

Regulations for Exemption Request

Mike Zuniga Films, LLC respectfully requests the grant of exemption for the 

following specific sections of the Title 14 Code of Federal Regulations allowing it 

to operate UAS(s) for commercial use:

• 14 CFR 21, subpart H

• 14 CFR 45.23 (b)

• 14 CFR 61.113 (a) & (b) 

• 14 CFR 91.7 (a)

• 14 CFR 91.9 (b)(2)

• 14 CFR 91.103 (b)

• 14 CFR 91.109

• 14 CFR 91.119

• 14 CFR 91.121

• 14 CFR 91.151 (a)

• 14 CFR 91.203 (a) & (b)

• 14 CFR 91.405 (a)
• 14 CFR 91.407 (a)(1)

• 14 CFR 91.409 (a)(2)

• 14 CFR 91.417 (a) & (b)

Operational Risk Management: Conditions and Limitations

• Flights will only be operated during daytime hours.

• No flight will be made with a UAS that has a gross weight exceeding 55 

lbs. 

• All flight operations will occur in FAA Class G airspace at 400 ft. above 

ground level (AGL) or less, at an airspeed of no more than 50 knots and 

no further than 3/4 Nautical Miles (NM) from the PIC. 

• All operations will have a VO and PIC. Both the PIC and VO will be able to 

communicate by voice at all times during flight operation. Both the PIC and 

VO will have a visual line of sight of the UAS at all times. The PIC will be 

in control of the flight status and dynamics of the UAS while making sure 

not to exceed the factory limits of the system operations (example: battery 

power, flight range, etc.). The VO will be involved for monitoring airspace 

and aircraft, the ground for bystanders or vehicles, and other hazards that 

may hinder flight operations. 

• Operations will be conducted in reasonably safe environments that are 

strictly controlled, away from power lines, elevated lights, airports and 

actively populated areas. 

• Written and/or oral permission form the relevant property holders will be 

obtained before flights are conducted over private or controlled access 

property. 

• Flight operations will be terminated at any time the weather or wind are 

deemed unsafe for flight based on the manufacturers recommendations 

and the experience of the PIC. Operations will follow the guidelines of this 

exemption (operations under visual meteorological conditions (VMC), and 

standard visual flight rules (VFR)). 

• The PIC will inspect the UAS for airworthiness before each flight operation 

using a checklist from the manufacturer’s manual. All necessary 

calibration and tests will be performed pre-flight. 

• Prior to UAS flight operations, the PIC will conduct a final check of the 

flight area ensuring the safety of all persons and property present in the 

controlled area. 

• Weather radar, weather forecasts, and air traffic patterns for the area will 

be reviewed prior to flight operations. The proximity of the intended flight 

location in respect to airports and Temporary Flight Restrictions (TFRs) will 

be determined using the app ForeFlight Mobile on our mobile device. If 

operations are anticipated to occur within 5 NM of airport location, the Air 

Traffic Control (ATC) or airport management will be notified before flight 

operation. This notification will include the location, anticipated flight time, 

the intent of flight operations of the UAS. Mike Zuniga Films, LLC will have 
a portable radio to allow monitoring of of local air traffic and to establish 

communication with the local ATC tower if necessary. In the situation 

where a non-tower airport is near, we will monitor air traffic and inform the 

airport management of our flight operations as needed. 

• The UAS(s) will have indicators on the display monitor attached to the 

control to inform the PIC of the altitude, velocity, distance of the aircraft 

from the PIC, and its remaining battery power. 

• With built in GPS, the UAS(s) will have the ability to automatically return, 

hover and land to an established home point safely in the event of lost RC 

communication, system problem, or extremely low battery power. The 

home point will always be established before each flight operation. The 

auto return capability will be checked on a regular basis to ensure 

functionality. 

Benefits for the Public as a Whole

Approval of the request for exemption under Section 333 of the FAA Reform 

Act would allow commercial operations of small light weight UAS to provide 

numerous services that would benefit data collection and aerial imaging while 

operating under improved safety and overall less risk. In comparison, traditional 

aerial imaging aircraft such has large helicopters, with combustible fuel, fly in 

close proximity to populated areas creating a major hazard. However, the use of 

small battery powered UAS of 55 lbs. or less, flying below 400 feet AGL greatly 

reduces the risk of the public. Mike Zuniga Films, LLC is willing to allow the 

Granting the use of these small light-weight UAS by Mike Zuniga Films, LLC will 

allow companies such as ours to grow as well as add to further the economic 

growth in the Southern California area and United States. This would also allow 

us to provide our services to other companies and add to the academic 

advancement and geographical awareness of certain areas for the community. 

Conclusion

Mike Zuniga Films, LLC respectfully request that the FAA grant my exemption 

request for the requirements of 14 CFR 21, subpart H; 14 CFR 45.23 (b); 14 CFR 

61.113 (a) & (b); 14 CFR 91.7 (a); 14 CFR 91.9 (b)(2); 14 CFR 91.103 (b); 14 

CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 

91.203 (a) & (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)

(2); 14 CFR 91.417 (a) & (b). The FAA has the authority to issue the exemption 

sought by Mike Zuniga Films, LLC pursuant to the Federal Aviation Act, 85 P.L. 

726 (1958) as amended (the ACT). Thank you. 
Respectfully submitted, 

Mike Zuniga

Mike Zuniga Films, LLC

1130 N Kraemer Blvd Ste F

Anaheim, CA 92806

MikeZunigaFilms@gmail.com

(714)-277-9573

Appendix A: Regulations for Requested Exemption

14 CFR 21, subpart H, 14 CFR 91.203 (a)(1): Air Worthiness Certificates

• This Regulation requires: Subpart H, entitled Airworthiness Certificates, 

sets forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR 91.203(a)(1). 

• The size, weight, and defined area of operations for Mike Zuniga Films, 

LLC UAS fights permits exception from Part 21 because they meet an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 USC 4470(f) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UASfrom 

the airworthiness certificate requirement in consideration of the weight, 

size, maneuverability, speed, and proximity to areas such as airports and 

dense populations. Mike Zuniga Films, LLC’s UAS are less than 55 lbs. 

fully loaded, carries no polite nor passengers, no explosive materials or 

combustible fuels and operates within a secured and controlled area. 

Flight operations of the UAS will be closely monitored and controlled by 

the PIC and VO to ensure safety. 

14 CFR 45.23: Marking of Aircraft

• This Regulation requires: “(a) Each operator of an aircraft must display on 

that aircraft marks consisting of the Roman capital letter “N” (denoting 

United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a 

Roman capital letter. (b) When marks include only the Roman capital letter 

“N” and the registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 
than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.”

• Applicable Codes of Federal Regulation require aircraft to be marked 

according to certain specifications. Mike Zuniga Films, LLC’s UAS by 

definition, are unmanned. Though the UAS will have no UAS airworthiness 

certificate, an exemption may be needed as the UAS will have no access 

to the cabin, cockpit or pilot station on which the word “Experimental” can 

be placed. Two-inch lettering is difficult to place on the size of this small 

aircraft with dimension smaller than the minimal lettering requirement. 

Mike Zuniga Films, LLC’s UAS will be marked with the largest lettering 

possible by placing the word “Experimental” on its fuselage as required by 

the 14 CFR 45.29(f) so that the PIC, observer and others working with the 

flight operation will see the identification of the UAS as “Experimental”. 

14 CFR 61.113 Private Pilot Privileges and Limitations

• This Regulate requires: “(a) Except as provided in paragraphs (b) through 

(h) of this section, no person who holds a private pilot certificate may act 

as pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or hire, 

act as pilot in command of an aircraft. (b) A private pilot may, for 

compensation or hire, act as pilot in command of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire.”

• Mike Zuniga Films, LLC will ensure an equivalent level of safety as no PIC 

will be allowed to operate the UAS unless the PIC has met currency and 

flight-hour requirements, demonstrating that the PIC is able to safely 

operate the UAS consistent with operation specification described in this 

exemption. These include emergency maneuvers and maintaining proper 

distance from other aircraft, people, structures, and vehicles. All flights 

conducted by the PIC pursuant to the grant of this request will be 

incidental to Mike Zuniga Films, LLC’s business, and will not carry 

passengers or property for compensation or hire. 

14 CFR 91.7(a): Civil Aircraft Airworthiness

• This Regulation requires: “(a) No person may operate a civil aircraft unless 

it is in an airworthy condition. (b) The pilot in command of a civil aircraft is 

responsible for determining whether that aircraft is in condition for safe 

flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur.”

• While this Regulation requires the operation with an airworthiness 

certificate, no certificate will be applicable in the form contemplated by the 

FARs and therefore making this Regulation inapplicable. With the size of 

the aircraft and the requirements contained in the Manufacturers 
Operating Manual for maintenance and the use of safety checklists prior to 

each flight, an equivalent level of safety will be ensured.

14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual

• The Regulation requires: “(b) No person may operate a U.S.-registered 

civil aircraft. (2) For which an Airplane or Rotorcraft Flight Manual is not 

required by §21.5 of this chapter, unless there is available in the aircraft a 

current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.”

• Since there are no pilots or passengers on board of the UAS given its size, 

this Regulation is inapplicable. An equivalent level of safety will be 

achieved my maintaining a safety/flight the flight manual at the ground 

control point where the PIC flying the UAS with immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption 

Nos. 8607, 8737, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

32827, and 10700. 

14 CFR 91.103(b): Preflight Action

• The Regulation requires: “Each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight. 

This information must include—(b) For any flight, runway lengths at 

airports of intended use, and the following takeoff and landing distance 

information:(1) For civil aircraft for which an approved Airplane or 

Rotorcraft Flight Manual containing takeoff and landing distance data is 

required, the takeoff and landing distance data contained therein; and (2) 

For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature.”

• Runway distance and flight performance information are not relevant to 

UAS flight operation. The equivalent action will be that he PIC will review 

airspace considerations, flight battery requirements, weather conditions, 

land and property boundaries with respect to takeoff and landing locations. 

Operation manuals will will be available at the sight of flight operations for 

the specific aircraft in flight. 

14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and Certain Flight 

Tests

• This Regulation requires: “(a) No person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls. However, instrument 

flight instruction may be given in an airplane that is equipped with a single, 

functioning throwover control wheel that controls the elevator and ailerons, 
in place of fixed, dual controls, when—(1) The instructor has determined 

that the flight can be conducted safely; and (2) The person manipulating 

the controls has at least a private pilot certificate with appropriate category 

and class ratings.(b) An airplane equipped with a single, functioning 

throwover control wheel that controls the elevator and ailerons, in place of 

fixed, dual controls may be used for flight instruction to conduct a flight 

review required by §61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot 

stations;(2) The pilot manipulating the controls is qualified to serve and 

serves as pilot in command during the entire flight;(3) The instructor is 

current and qualified to serve as pilot in command of the airplane, meets 

the requirements of §61.195(b), and has logged at least 25 hours of pilotin-command flight time in the make and model of airplane; and(4) The pilot 

in command and the instructor have determined the flight can be 

conducted safely.(c) No person may operate a civil aircraft in simulated 

instrument flight unless—(1) The other control seat is occupied by a safety 

pilot who possesses at least a private pilot certificate with category and 

class ratings appropriate to the aircraft being flown.(2) The safety pilot has 

adequate vision forward and to each side of the aircraft, or a competent 

observer in the aircraft adequately supplements the vision of the safety 

pilot; and (3) Except in the case of lighter-than-air aircraft, that aircraft is 

equipped with fully functioning dual controls. However, simulated 

instrument flight may be conducted in a single-engine airplane, equipped 

with a single, functioning, throwover control wheel, in place of fixed, dual 

controls of the elevator and ailerons, when—(i) The safety pilot has 

determined that the flight can be conducted safely; and (ii) The person 

manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings.(d) No person may operate a civil 

aircraft that is being used for a flight test for an airline transport pilot 

certificate or a class or type rating on that certificate, or for a part 121 

proficiency flight test, unless the pilot seated at the controls, other than the 

pilot being checked, is fully qualified to act as pilot in command of the 

aircraft.”

• UAS are not designed to have fully functional dual controls as they are 

remotely piloted aircraft. A control box communicates with the aircraft via 

radio communications to accomplish flight control. The FAA has approved 

exemption for flight training without fully functional dual controls for 

experimental aircraft. These include Exemption Nos. 5778K and 9862A. 

Mike Zuniga Films, LLC will ensure an equivalent level of safety as the 

aircraft(s) will carry neither pilot nor passengers. 

14 CFR 91.119: Minimum Safe Altitudes

• This Regulation requires: “Except when necessary for takeoff or landing, 
no person may operate an aircraft below the following altitudes: (d) 

Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the 

surface— (1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person 

operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and (2) A powered parachute or 

weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section.”

• This exemption is for a UAS multi-propeller helicopter with the exemption 

requesting authority to operate at altitudes of 400 AGL or below. Given the 

weight, size, and speed of the UAS as well as location, an equivalent level 

of safety will be ensured during operation. All flights will be operated with 

the permission of local officials and property owners. 

14 CFR 91.121: Altimeter Settings

▪ This Regulation requires: “(a) Each person operating an aircraft shall 

maintain the cruising altitude or flight level of that aircraft, as the case may 

be, by reference to an altimeter that is set, when operating— (1) Below 

18,000 feet MSL, to—; i) The current reported altimeter setting of a station 

along the route and within 100 nautical miles of the aircraft; (ii) If there is 

no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure; or (2) At or above 18,000 feet MSL, to 29.92′′ Hg.”

▪ An exemption will be needed as the UAS utilizes GPS altitude settings. 

The altitude information will be generated by equipment installed within the 

aircraft using a digitally encoded barometric altimeter. An equivalent level 

of safety will be enforced by the PIC using the safety check list and 

manual. 

• 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

• This Regulation requires: “(a) No person may begin a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed—(1) During the day, to fly after that 

for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes.”

• The battery power of the UAS(s) lasts approximately 23min. (DJI Phantom 

3 Professional) and 18min. (DJI Inspire 1) for the duration of the full flight. 

It’s not practical for UAS flights to meet the reserve requirement stated 

under this regulation. With these limitations, the UAS will be within the line 
of sight distances. Battery life will be monitored and the PIC will determine 

the duration of the flight. The monitor connected to the control indicates 

the remaining battery life. At 30 percent, the UAS will be landed and flight 

operation will cease. Similar exemptions to other operations have been 

granted: 2689F, 5745, 10673, 10808. 

14 CFR 91.203(a)&(b): Civil Aircraft: Certification Required

• This Regulation requires: “(a) Except as provided in §91.715, no person 

may operate a civil aircraft unless it has within it the following: (1) An 

appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight 

permit, a copy of the applicable operations specifications issued under 

§21.197(c) of this chapter, appropriate sections of the air carrier manual 

required by parts 121 and 135 of this chapter containing that portion of the 

operations specifications issued under §21.197(c), or an authorization 

under §91.611) must have on it the registration number assigned to the 

aircraft under part 47 of this chapter. However, the airworthiness certificate 

need not have on it an assigned special identification number before 10 

days after that number is first affixed to the aircraft. A revised airworthiness 

certificate having on it an assigned special identification number, that has 

been affixed to an aircraft, may only be obtained upon application to an 

FAA Flight Standards district office. (b) No person may operate a civil 

aircraft unless the airworthiness certificate required by paragraph (a) of 

this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew.”

• Since there is no onboard pilot and the UAS weighs no more than 55 lbs., 

it does not have the ability to carry registration or certification documents 

as well as display them on the UAS. However, these documents will be 

kept with the PIC for immediate access to them to the extent that they are 

applicable to the UAS. The FAA has other exemptions to this regulation 

with Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. An equivalent level of safety will be be ensured by maintaining any 

such required certifications and registrations by Mike Zuniga Films, LLC. 

14 CFR 91.405 (a); 91.407(a)(1); 91.409(a)(2); 91.417(a)&(b): Operation After 

Maintenance, Preventive Maintenance, Rebuilding, or Alteration.

• These Regulations require: An aircraft operator or owner “shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between 
required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” 

and others shall inspect or maintain the aircraft in compliance with Part 43. 

• Part 43 and these sections only apply to aircraft with an airworthiness 

certificate. They will not apply to Mike Zuniga Films, LLC’s UAS. However, 

for safety, the UAS will be inspected before and after each flight. Since the 

manufacturer doesn’t provide specific maintenance instructions, 

maintenance will be based on the current condition of each aircraft and 

each aircraft will have a maintenance log. The PIC in charge of the flight 

manual and operating handbook will be in charge of maintenance. Current 

versions of firmware and software will be consistently updated. 

References

• DJI Phantom 3 Manual

⁃ http://download.dji-innovations.com/downloads/phantom_3/en/

Phantom_3_Professional_User_Manual_v1.0_en.pdf

• DJI Inspire 1 Manual

⁃ http://download.dji-innovations.com/downloads/inspire_1/en/

Inspire_1_User_Manual_v1.0_en.pdf

• Part 91 General Operating and Flight Rules

⁃ http://www.ecfr.gov/cgi-bin/text-idx?

SID=d00c14bfef5f2eae3e9bd3f3d934bfbc&mc=true&node=pt14.2.9

1&rgn=div5

• Part 45 Identification and Registration Marking

⁃ http://www.ecfr.gov/cgi-bin/text-idx?

SID=8e8d31b5debb06c738ad8e6911b7c6bf&mc=true&node=pt14.

1.45&rgn=div5

• Petitioning for Exemption Under Section 333

⁃ https://www.faa.gov/uas/legislative_programs/section_333/

how_to_file_a_petition/