### 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 directlyinvolved 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 lessrisk 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, LLChave 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 safetysystems 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 havea 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 morethan 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 ManufacturersOperating 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, meetsthe 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 lineof 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 betweenrequired 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/