Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition 

Docket No. FAA-2015-0331 

March 31st, 2015 

U.S. Department of Transportation 

Docket Operations West Building 

Ground Floor, Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

_j:' 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR Part 

21,14 CFR 45.23; 14 CFR 91.7(a); 91.9(b)(c)(d); 14 CFR 91.103; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151; 

14 CFR 91.203; 14 CFR 91.205; 14 CFR 91.405; 14 CFR 91.407; 14 CFR 91.409; 14 CFR 91.417. 

To Whom It May Concern: 

I, Michael Joseph Indovina, am writing pursuant to the FAA Modernization and 

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

that I, Michael Joseph Indovina, an active Airline Transport Pilot (ATP), Certified 

Flight Instructor (CFI) and owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations (FARs) listed below so that I may 

operate my small light weight Unmanned Aircraft System (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA). 

As described herein I, Michael Joseph Indovina, licensed ATP /CFI/MEI with a 

background in the last decade consisting of operating as a full time commercial pilot 

including part-135 on-demand charter operations and Mike Six Aerial Imaging 

photography business and hobby on the side. I am also experienced in flying hobby 

remotely controlled (RC) aircraft for recreational purposes. I have a hobby grade 

Tarot 680 Pro hexa-copter1 UAS which contains a small, lightweight Sony Nex-5 

DSLR camera fixed onto a gimbal with the sole intent for aerial stillframe/cinematography to be used in commercial real estate and personal, private 

venue photography; following exemption and approval by the FAA, which would 

thereby reduce the use of physical manned aircraft for my operations. 

I have flown small RC aircraft for over 2 decades (nearly 25 years) without incident 

and am committed to safety with each flight. My, Michael Joseph Indovina's, 

exemption request would permit operation of my lightweight, UAS (piloted by 

myself under remote control) which would alleviate the already congested traffic 

load in the National Airspace System (NAS). Flight in predetermined areas away 

from the general public, any airports, heliports and vehicular traffic within the 

property boundaries for individual homeowner real estate listing or private venue 

videos/photos. There are currently plenty of similar lightweight remotely 

controlled UAS's that are operated daily by unmonitored and unlicensed amateur 

hobbyists, without any safety plans, proper FAA Regulation or NAS education, 

1 Appendix A- Tarot 680 Pro Operator Manual 

Michael Joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 1 of 10 
Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition 

limitations or controls in place to prevent catastrophes. I, Michael Joseph Indovina, 

have personally instilled safety protocols and controls2 to avoid and prevent public 

hazard, as well as manned aircraft hazards/catastrophe. This will act to further 

safety protocols exclusive to lightweight UAS's specific to real estate and/or video 

cinematography usage as I, Michael Joseph Indovina, record all flight data collected 

through permitted flight operations to assist the FAA with any future protocol and 

safety regulations. 

My UAS's August 2014 design, plan and construction were carefully considered 

when installing 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 an 

internal, 3-axis gyroscope for ship leveling and a barometric altitude sensor 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, airspeed, 

altitude, magnetic heading, battery voltage, and GPS latitude & longitudinal data to 

the ground station for an added level of control. Semi-Permanently fixed topcenter-ship are 2 batteries that provide up to 20 minutes of flight between 

swapping, 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. 

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 for the displayed flight 

information. All of the UAS RF signals are FCC compliant. 

Numerous test flights of the 3 flight modes3: GPS Loiter, Return to Launch, Altitude 

Hold; and failsafe operations: loss of radio control signal or low battery voltage 

triggering either immediate landing or a return to the launch position and land were 

all meticulously and cautiously executed at a safe and controlled field. Each flight 

session 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. 

The PIC of this UAS is myself, Michael Joseph Indovina VI, and is directly responsible 

for the operation of this UAS. 

Appendix B -Safety Protocols and Flight Controls 3 Flight Modes Available: Stabilize, GPS Loiter, Altitude Hold, & Return to Launch. See Appendix A- Flight Modes 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition 

I have proven myself true in my flight career to date, an ATP Pilot with over 4,500 

flight hours and a turbo-jet PIC rating, and hold a first class medical certificate. With 

this UAS, I have currently logged 61 flights, and accumulated more than 7 flight 

hours. I believe that the medical standards for all UAS pilots should be such that 

mimic regulations for flight of manned aircraft under FAR parts 61 & 91. Granting 

my, Michael Joseph Indovina's, request complies with the Secretary of 

Transportation's (FAA Administrator's) responsibilities and authority to not only 

integrate UAS's into the national airspace system, but to " ... establish requirements 

for the safe operation of such aircraft systems [UAS's] in the national airspace 

system" under Section 333(c) of the Reform Act specific to the use ofUAS's for 

cinematography purposes. Further I, Michael Joseph Indovina, will conduct my 

operations in compliance with the protocols described herein or as otherwise 

established by the FAA. 

For the reasons stated below I, Michael Joseph Indovina, respectfully request the 

grant of an exemption allowing me to operate my lightweight, remotely controlled 

UAS to reduce manned aircraft operations in the NAS while also to benefit/stimulate 

attraction and enhance real estate and private venue listing photos & videos for 

homeowners and clients who cannot afford expensive manned aircraft for the same 

purpose. My operations will promote local economic growth through increased 

sales and increased tax base; all with public safety in mind by reducing the use of 

much heavier manned aircraft containing combustible fuel, which continually poses 

potential public hazards. 

I. Contact Information: 

Michael Joseph Indovina VI, 

ATP CFI MEl- 3146873 

Mike Six Imaging 

8000 West Manchester Ave. #222 

Playa Del Rey, CA 90293 

Phone: (805) 455-9041 

Email: Vl@mikesix.com 

II. Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Michael Joseph Indovina Requests Exemption: 

14 CFR 21; 

14 CFR 45.23; 

14 CFR 91.7 (a); 

14 CFR 91.9 (b)( c)( d); 

14 CFR 91.103 (b); 

14 CFR 91.119; 

14 CFR 91.121; 

14 CFR 91.151; 

14 CFR 91.203; 

14 CFR 91.205; 

14 CFR: 91.405, 91.407, 91.409, and 91.417. 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition 

III. The Extent of relief Michael Joseph Indovina seeks and the Reason He 

Seeks Such Relief: 

I, Michael Joseph Indovina, submit this application in accordance with the Reform 

Act, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FARs 

operating to prevent me, Michael Joseph Indovina, educated Commercial and Airline 

Transport Pilot, from flight operations with a UAS within the NAS. The Reform Act 

in Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public's interest to do so. My, Michael 

Joseph Indovina's, lightweight UAS certainly meets the definition of "small 

unmanned aircraft" as defined in Section 3 31 and therefor the integration of my 

lightweight UAS is expressly contemplated by the Reform Act The Reform Act 

guides the Secretary in determining the types ofUAS's that may operate safely in 

our national airspace system. These considerations include the weight, size, speed 

and overall capabilities of the UAS; whether the UAS will be operated near airports 

and/or heavily populated areas; and, whether the UAS will be operated by line of 

sight 112 P.L. 95 § 333 (b)1. Each of these items reflects in favor of an exemption 

for me, Michael Joseph Indovina. My UAS utilizes six (6) counter-rotating propellers 

for balance, control, stability and safety. My UAS is equipped with GPS and battery 

voltage auto return safety technology. Weighing less than ten (10) pounds (far 

below the maximum 55-pound limit) including camera with gimbal. 

As with any aircraft, flight operations would be tailored to meet the need to prepare, 

prevent and reduce the risk of any injuries or events for each flight by maintaining a 

clear and unobstructed area below the ship while it is in flight It is that I, Michael 

Joseph Indovina, consider safety foremost with each flight My small, unmanned 

aircraft is designed to hover in place via GPS and operate in less than 20 knots (23 

mph) wind velocity. For safety, stability and fear of financial loss I will not fly in 

sustained winds exceeding 15 knots (17 mph). Built in safety systems include a GPS 

Loiter mode that allows my UAS to hover in place when radio controls are released. 

With three flight modes to choose from, I utilize the Loiter mode4 for aerial 

videography /photography. This is the safest, most reliable and stable mode to 

prevent accidents or hazards. If communication is lost between the UAS and the 

PIC, with an adequate GPS signal the ship is designed climb to a pre-determined safe 

altitude of sixty (60) feet, and return directly to the launching spot and slowly 

descend to a safe landing. I do not operate my UAS near airports, Hospitals or police 

heliports, and do not operate near areas where the general, uninvolved public is 

within fifty (50) feet, depending on location. Flight conditions will be conducted 

during daylight hours (sunrise to sunset) and at all times maintain clear of clouds. 

Operations in visible moisture will be strictly prohibited. I, Michael Joseph Indovina, 

and the flight observer will be constantly alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft approach, or suspect that 

a manned aircraft approach near my location. My UAS is capable of vertical and 

horizontal operations, and are flown only within my visual line-of-sight, as the 

remote control Pilot In Command. 

See Appendix B -Safety Protocols and Flight Controls 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging - Section 333 Exemption Petition 

Utilizing battery power rather than combustible fuels, flights will generally last 

between five (5) to ten (10) minutes, with an altitude below two hundred (200) feet 

AGL. I, Michael Joseph Indovina, utilize fresh, fully charged batteries with each flight 

as a safety precaution; full flight time limit for each battery set is fifteen (15) to 

twenty (20) minutes as tested. I do not operate my UAS at or below manufacture 

recommend minimum charge levels for operation; preferring to remain well within 

a safe operating range to insure adequate communication between radio control 

and UAS to eliminate potential for crash, loss of control or hazard. Fully charged 

reserve batteries are at hand with each exercise to insure replacement for sufficient 

safe level of operation. I do not take risks that would cause a crash or create hazard 

to the public/property /manned aircraft, and have absolutely no desire to lose on my 

investment. I have logged numerous practice flights in remote areas as a hobbyist, 

simulating flights for future commercial use to gain familiarization with the 

characteristics of this specific UAS's performance under different temperatures and 

atmospheric weather conditions, and to date have more than 7 flight hours with this 

UAS. 

I, Michael Joseph Indovina, am extremely cautious when operating of my 

VAS/lightweight unmanned aircraft and will not "create a hazard to users of the 

national airspace system or the public." 112 P.L. 95 § 333 (b). Given the small size 

and weight of my UAS, it falls well within Congress's contemplated safety zone when 

it advocated the Reform Act and the corresponding directive to integrate UAS's into 

the national airspace system. My, Michael Joseph Indovina's UAS used in hobby 

flight, has a demonstrable safety record and does not pose any threat to the general 

public or national security. 

IV. How Michael Joseph Indovina's Request Will Benefit the Public As A Whole: 

Aerial videography for geographical survey, real estate marketing, and for the 

theatrical film industry has been around for quite some time through manned fixed 

wing aircraft and rotorcraft. For small budget real estate companies and average 

homeowners the expense of such aerial videography is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford to absorb such 

an expense, which deprives non-luxury homeowners and lower budget Realtors 

from a valuable marketing tool. Manned aircraft pose a threat to the public through 

potential catastrophic crash that the aviation community has experienced 

numerously with airspace and ground terrain congestion, nearly each situation 

causes combustible fuel to ignite on impact and often results in subsequent loss of 

life. Manned aircraft operations have had to make emergency landings within the 

city limits and as the city continually grows, options for such are greatly 

diminishing. My, Michael Joseph Indovina's, UAS pose no such threat since its size 

and lack of combustible fuel alleviates any potential threat to the public, and is much 

easier to maneuver to a safe landing under conditions any manned aircraft can 

obtain. 

Congress has already proclaimed that it is in the public's interest to integrate 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition 

commercially flown UAS's into the national airspace system, hence the passing of 

the Reform Act. Granting my, Michael Joseph Indovina's, exemption request 

furthers the public interest through reducing potential threats of manned aircraft 

incidences. Furthermore, my lightweight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my lightweight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; which are 

extremely heavy, contain many gallons combustible fuel and can cause catastrophic 

devastation to the public. 

Minimizing ecological and crash threats furthers the public's interest by permitting 

aerial videojphoto capturing through the use of battery operated, lightweight UAS's. 

Permitting me, Michael Joseph Indovina, to immediately fly within the NAS 

continues economic growth. Granting my exemption request will substantially 

further the economic impact for the greater Los Angeles community for companies 

looking to relocate or build in the area as well as individuals looking to survey 

properties. Both of which serve as a stimulus to the community, and national 

economy. 

V. Reasons Why Michael Joseph Indovina's Exemption Will Not Adversely 

Affect Safety and/ or How The Exemption Will Provide a Level of Safety At 

Least Equal To Existing Rule: 

My, Michael Joseph Indovina's, exemption will not adversely affect safety, and it is 

with my utmost desire to comply within your authorization, 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 uninvolved. By permitting this exemption, you will allow the logging 

of more flight time in NAS, communication with the FAA, and allow me to continue 

to contribute with my longstanding support in the growing aviation industry. This 

would further build my reputation of safety, performance and reliability in the face 

of the FAA, and my ATP oath of good moral character, to the public for the growing 

NAS structure at the forefront of today' s technology and changing times with my 

operations development in cooperation with the FAA. 

In addition I, Michael Joseph Indovina, submit the following representations for the 

exemption of Section 333 for Mike Six Imaging: 

• 

• 

• 

• 

• 

My UAS weighs less than 10 pounds complete with a 3-axis camera gimbal and 

small, lightweight, high quality Sony Nex-5 DSLR camera; 

I only operate my UAS below 200 Above Ground Level (AGL)S (well within the 

400 foot permissible ceiling set by the FAA Modernization and Reform Act of 

2012); 

My UAS only operates for 5-10 minutes per flight, or within 80% charged level; 

I land my UAS prior to manufacturer recommended minimum of 20% battery 

charge, 6 minutes of tested flight time remaining as reserves; 

I pilot my UAS through remote control only by visual line-of-sight; 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition 

• My UAS has GPS a flight safety feature whereby it returns to launch position or 

hovers and then slowly lands if communication between the UAS and the Pilot In 

Command is lost; . 

• I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols; 

• I only operate in reasonably safe environment that is strictly controlled, away 

from power lines, elevated lights, airports and actively populated areas; 

• I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance and keep an extensive flight log including 

maintenance performance tests, removal, repair & preventative maintenance 

with return to service descriptions; 

• I always obtain all necessary permissions prior to operation; and have 

procedures in place to abort flights in the event of safety breaches or potential 

danger. 

My, Michael Joseph Indovina's, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into the NAS, helicopters and other fixed wing aircraft are the 

primary means of aerial video and photography for aerial survey /photo 

I cinematography. While the safety record of such aircraft are remarkably 

astounding, there has been a plethora of incidents involving loss of life as well as 

extensive property damage; it is far safer to operate a battery powered, lightweight 

UAS. First, the potential loss of life is diminished because UAS's carry no people on 

board and only operate in specific areas away from mass populations. Second, there 

is no combustible fuel on board my UAS and thus the potential for fire or explosions 

is greatly diminished. Third, the small size and extreme maneuverability of my UAS 

allow me to remotely pilot away from and avoid hazards quickly and safely. 

Accordingly, my UAS has and always will continue to operate at and above current 

safety levels. 

VI. Summary The FAA May Publish in the Federal Register: 

14 CFR 21, 14 CFR 45 and 14 CFR 91 

A. 14 CFR 21, 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 enclosed operational area of my, 

Michael Joseph Indovina's, UAS permits exemption from Part 21 because my UAS 

meets (and exceeds) 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 U.S.C. § 44 701 (f)) and Section 

333 of the Reform Act. Both pieces oflegislation permit the FAA to exempt UAS's 

from the airworthiness certificate requirement in consideration of the weight, 

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

populations. 

5 Tarot 680 Pro Maximum Altitude set to 400 feet AGL in any Flight Mode. See Appendix A- Geo Fence 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging -Section 333 Exemption Petition 

My, Michael Joseph Indovina's, current and projected UAS's meet or exceed each 

of these elements. 

B. 14 CFR § 45.23: Aircraft Markings. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My UAS is, by 

definition, unmanned. It therefore does not have a cabin, cockpit or pilot station 

on which to mark certain words or phrases. Furthermore, two-inch lettering is 

difficult to impossible to place on such small aircraft with dimensions smaller 

that minimal lettering requirement. Regardless, I will mark its UASs in the 

largest possible lettering by placing the word "EXPERIMENTAL" on its fuselage 

as required by 14 C.F.R. §45.29 (f) so that I the Pilot In Command, or anyone 

assisting me as a spotter with the UAV will see these markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 

10167, 10167A and 10700. 

C. 14 CFR 91.7 Prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable. 

14 CFR § 91.9 Requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is 

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

safety /flight procedures form, delineating areas of where safety can be defined.6 

The FAA has previously issued exemptions to this regulation in exemption Nos. 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 

and 32827. 

14 CFR § 91.103 Preflight action of the PIC shall determine all applicable 

information of intended airports of use, and takeoff/landing performance data. 

Gross weight and atmospheric conditions pertaining to the changes of density 

altitude and performance characteristics of aircraft would not be applicable to 

the operation of my UAS. 

14 CFR 91.119: Prescribes minimum Safe Altitudes. My UAS will never operate 

at an altitude greater than 200 Above Ground Level (AGL); safely well below the 

standard of 400 AGL. I, Michael Joseph Indovina, will however, operate my UAS 

in safe areas away from public and traffic, providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. Given the 

size, weight, maneuverability and speed of my UAS, an equivalent or higher level 

of safety will be achieved. This should not apply as the UAS does not fly at these 

flight altitudes, and is it at all times in a position to make an emergency landing 

without undue hazard to persons or property on the surface. 

6 Appendix B - Safety Protocols and Flight Controls - Flight Procedures Form 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition · 

14 CFR § 91.121 Regarding altimeter settings is inapplicable to my UAS utilizes 

electronic Global Positioning System with a barometric sensor, and calibrated 

from the launch position rather than to a standard datum plane. 

14 CFR § 91.151 Requires excess fuel to be carried onboard the aircraft as a 

means of reserves, based on daylight or night conditions. This UAS does not 

carry fuel and maximum flight times are less than what is required in this 

section. However, safety measures are in place regarding leaving a certain level 

of charge on board to ensure adequate power to complete flight operations. 

14 CFR § 91.203 provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining any such required 

certifications and registrations by me, Michael Joseph Indovina. 

14 CFR § 91.205 Required instruments and equipment list. None of these items 

apply to the flight operations of my UAS. 

14 CFR 91.405; 91.407; 91.409; 91.411,91.413 and 91.417: Maintenance 

Inspections. The above-cited regulations require, amongst other things, aircraft 

owners and operators to "have [the] 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 ... " 

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Michael Joseph Indovina's, UAS. However, as a 

safety precaution I inspect my UAS before and after each flight 

Michael Joseph Indovina seeks an exemption from the following Regulations: 

14 CFR 21 (h); 14 CFR 45.23; 14 CFR § 91.7 (a); 14 CFR § 91.9 (b)(c)(d); 14 CFR § 

91.103; 14 CFR § 91.119; 14 CFR § 91.121; 14 CFR § 91.151; 14 CFR § 91.203; 14 

CFR 91.205; 14 CFR § 91.405; 14 CFR § 91.407; 14 CFR § 91.409; and, 14 CFR 

§91.417 

It is in conclusion, with my, Michael Joseph Indovina's, declaration of purpose and 

stated limitations within this document, I submit to you this formal request for 

exemption for me, Michael Joseph Indovina, to commercially operate my, Michael 

Joseph Indovina's, small unmanned vehicle/lightweight unmanned aircraft vehicle 

in video cinematic and real estate operations, and to enhance the experience of 

those seeking to relocate or discover new venues within the greater Los Angeles 

area. Currently, area awareness and real estate aerial videography /photography 

relies primarily on the use of larger aircraft running on combustible fuel. Posing a 

highly potential risk to the public. Granting my, Michael Joseph Indovina's, request 

for exemption will reduce current risk levels and thereby enhance safety, with my 

plan to offer a creative twist to my photography business with the usage of my 

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Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition 

personal UAS rather than fixed wing, manned aircraft. My UAS craft does not 

contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional, manned aircraft, significantly less pollutant and economically 

beneficial. 

Further, I operate at lower altitudes and in tightly controlled airspace eliminating 

potential public risk from putting themselves into unnecessary harm. Formal 

collection of flight data information is stored and can be shared with the FAA in 

hopes to enhance the FAA's internal efforts in establishing protocols for complying 

with the FAA Modernization and Reform Act of 2012. There are no personnel on 

board my, Michael Joseph Indovina's, UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. My, Michael Joseph Indovina's, 

operation of my UAS, weighing less than 10 pounds and travelling at very slow 

speeds within limited areas will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly I, Michael Joseph Indovina, respectfully 

request that the FAA grant my exemption request and I am willing to cooperate in 

sharing information to benefit the FAA, the safety of manned aircraft, and the 

general public at large. 

Thank you for your consideration. 

Respectfully; 

Michael Joseph Indovina VI 

ATP CFI MEl: 3146873 

Mike Six Imaging 

8000 West Manchester Ave. #222 

Playa Del Rey, CA 90293 

Phone: (805) 455-9041 

Email: Vl@mikesix.com 

www.mikesix.com 

Michael joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 10 of 10