Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging
- Section 333 Exemption Petition Docket No. FAA-2015-0331
March 31st, 2015

U.S. DepartmentofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJerseyAve, SE Washington, DC 20590 _j:'

Re: Exemption Request Section 333 ofthe FAA Reform Act ofthe FederalAviation 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; 14CFR 91.121; 14 CFR 91.151; 14CFR 91.203; 14 CFR 91.205; 14 CFR 91.405; 14 CFR 91.407; 14 CFR 91.409; 14CFR 91.417.

To Whom ItMay Concern:
I, Michael Joseph Indovina, am writing pursuantto the FAA Modernization and Reform Act of2012 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 ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed below so that Imay 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 thelast decade consisting ofoperating as a full time commercial pilot including part-135 on-demand charter operations and Mike Six Aerial Imaging photographybusiness and hobby on the side. I am also experienced in flying hobby remotely controlled (RC) aircraft for recreational purposes. Ihave a hobbygrade Tarot 680 Pro hexa-copter1 UAS which contains a small, lightweight Sony Nex-5 DSLR camera fixed onto a gimbal with the sole intentfor aerial stillframe/cinematographyto be used in commercial real estate and personal, private venue photography; following exemption and approval bythe FAA, which would therebyreduce the use ofphysical manned aircraft for my operations.
Ihave flown small RC aircraft for over 2 decades (nearly 25 years) without incident and am committed to safetywith each flight. My, Michael Joseph Indovina's, exemption requestwould permit operation ofmy lightweight, UAS (piloted by myselfunder 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 propertyboundaries for individual homeowner real estate listing or private venue videos/photos. There are currently plenty ofsimilar lightweight remotely controlled UAS's that are operated daily byunmonitored and unlicensed amateur hobbyists, without any safetyplans, proper FAA Regulation or NAS education,

1Appendix 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 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging
- Section 333 Exemption Petition limitations or controls in place to preventcatastrophes. I, Michael Joseph Indovina, have personallyinstilled safety protocols and controls2 to avoid and prevent public hazard, as well as manned aircrafthazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate and/orvideo cinematographyusage as I, Michael Joseph Indovina, record all flight data collected through permitted flight operations to assistthe FAA with any future protocol and safetyregulations. My UAS's August 2014 design, plan and construction were carefully considered when installing this system. The choice of6 power-plantmotors over 4 added an extra edge and added protection from the unexpected event ofa sudden, in-flight power orrotor-blade failure. The Flight Controller is manufactured byAPM (3dr robotics) a vastlytested 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 returnto launch and/or failsafe operations. The flight controller also transmits pitch &roll, airspeed, altitude, magnetic heading, batteryvoltage, and GPS latitude &longitudinal data to the ground station for an added level ofcontrol. Semi-Permanentlyfixed topcenter-ship are 2 batteries thatprovide up to 20 minutes offlight between swapping, and are wired in parallel to coverthe event ofa sudden loss ofcurrent from each other. Redundancy was atthe forefront ofmind 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 orinterruption. 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 ofthe UAS RF signals are FCC compliant.
Numerous test flights ofthe 3 flight modes3: GPS Loiter, Return to Launch, Altitude Hold; and failsafe operations: loss ofradio control signal orlowbatteryvoltage 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 ofall power plants, propellers and frame structure, flight mode conditions, flight data read-out display and flown only after all have been deemed satisfactoryfor flight, pursuantto 14 CFR section 91.7(b). Awireless connection to a base station, a separately powered Apple laptop runningAPM software thatprovides a up-to-the-second active display ofthe flight mode, flight attitude, ship altitude and airspeed, latitude &longitude position and batteryvoltage. All maintenance and repairs have, and always will be, performed by myselfwith compatible and/or identical parts, logged and tested priorto any subsequentflight. Again, safety is a key principle value.
The PIC ofthis UAS is myself, Michael Joseph Indovina VI, and is directly responsible for the operation ofthis 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 Michael Joseph IndovinaVI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 2 of 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging
- Section 333 Exemption Petition
Ihave proven myselftrue in my flight careerto 

### date, an ATP Pilotwith over 4,500 flight hours and a turbo-jet PIC rating, and hold a first class medical certificate. With this UAS, Ihave currentlylogged 61 flights, and accumulated more than 7 flight hours. Ibelieve thatthe medical standards for all UAS pilots should be such that mimic regulations for flight ofmanned aircraft underFAR parts 61 &91. Granting 

### my, Michael Joseph Indovina's, request complies with the Secretary of Transportation's (FAA Administrator's) responsibilities and authorityto not only integrate UAS's into the national airspace 

### system, butto "

...establish requirements for the safe operation ofsuch aircraft systems [UAS's] in the national airspace system" under Section 333(c) ofthe Reform Act specific to the use ofUAS's for cinematographypurposes. Further I, Michael Joseph Indovina, will conduct my operations in compliance with the protocols described herein or as otherwise established bythe FAA.

For the reasons stated below I, Michael Joseph Indovina, respectfully requestthe grant ofan 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 aircraftfor the same purpose. My operations will promote local economic growth through increased sales and increased taxbase; 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 ManchesterAve. #222 Playa Del 

### Rey, CA 90293 Phone: (805) 455-9041 Email: Vl@mikesix.com

II. Specific Sections ofTitle 14ofthe Code ofFederal 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. Michael Joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 3 of 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging
- Section 333 Exemption Petition III. The ExtentofreliefMichael Joseph Indovina seeks and the Reason He Seeks Such Relief:
I, Michael Joseph Indovina, submitthis application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FARs operatingto preventme, 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 ofcivil unmanned aircraft systems into our national airspace system as itis in the public's interestto do so. My, Michael Joseph Indovina's, lightweight UAS certainly meets the definition of "small unmanned aircraft" as defined in Section 331 and thereforthe integration ofmy lightweight UAS is expresslycontemplated bythe Reform Act The Reform Act guides the Secretaryin determining the types ofUAS's that may operate safely in ournational airspace system. These considerations include the weight, size, speed and overall capabilities ofthe UAS; whetherthe UAS will be operated near airports and/orheavily populated areas; and, whetherthe UAS will be operated byline of sight 112 P.L. 95 § 333 (b)1. Each ofthese items reflects in favor ofan exemption for me, Michael Joseph Indovina. My UAS utilizes six (6) counter-rotatingpropellers for balance, control, stabilityand safety. My UAS is equipped with GPS and battery voltage auto return safetytechnology. Weighing less than ten (10) pounds (far belowthe maximum 55-pound limit) including camerawith gimbal.
As with any aircraft, flight operations would be tailored to meetthe need to prepare, prevent and reduce the risk ofany injuries or events for each flight by maintaining a clear and unobstructed area belowthe ship while itis in flight Itis that I, Michael Joseph Indovina, consider safetyforemost with each flight My small, unmanned aircraft is designed to hoverin placevia GPS and operate in less than 20 knots (23 mph) wind velocity. For safety, stability and fear offinancial loss I will notfly 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, mostreliable and stable mode to prevent accidents orhazards. Ifcommunication is lostbetween the UAS and the PIC, with an adequate GPS signal the ship is designed climb to a pre-determined safe altitude ofsixty (60) feet, and return directlyto the launching spot and slowly descend to a safe landing. I do not operate my UAS near airports, Hospitals orpolice 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 ofclouds. Operations in visible moisture will be strictlyprohibited. I, Michael Joseph Indovina, and the flight observer will be constantlyalertfor any manned aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediatelyto the nearest and safestground point should a manned aircraft approach, or suspectthat a manned aircraft approach near mylocation. My UAS is capable ofvertical and horizontal operations, and are flown onlywithin myvisual line-of-sight, as the remote control Pilot In Command.

See Appendix B -Safety Protocols and Flight Controls Michael Joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 4 of 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging
- Section 333 Exemption Petition 

### Utilizing batterypower rather than combustible fuels, flights will generally last between five (5) to ten (10) minutes, with an altitude belowtwo 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 atorbelow manufacture recommend minimum charge levels for operation; preferringto remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss ofcontrol orhazard. Fully charged reserve batteries are athand with each exercise to insure replacement for sufficient safe level ofoperation. Ido nottake risks thatwould cause a crash or create hazard to the public/property /manned aircraft, and have absolutely no desire to lose on my investment. Ihave logged numerous practice flights in remote areas as a hobbyist, simulating flights for future commercial use to gain familiarization with the characteristics ofthis 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 ofmy VAS/lightweight unmanned aircraft and will not "create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 § 

### 333 (b). Given the small size and weight ofmy UAS, itfalls 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 notpose any threatto the general public or national security.

IV. HowMichael Joseph Indovina's RequestWill Benefitthe Public As AWhole:


### Aerial videography for geographical survey, real estate marketing, and for the theatrical film industryhas been around for quite some time through manned fixed wing aircraft and rotorcraft. For small budgetreal estate companies and average homeowners the expense ofsuch aerial videography is costprohibitive. Only large companies and high end Realtors orluxury homeowners can afford to absorb such an expense, which deprives non-luxury homeowners and lowerbudget Realtors from a valuable marketingtool. Manned aircraft pose a threatto the public through potential catastrophic crash thatthe aviation communityhas experienced numerouslywith airspace and ground terrain congestion, nearly each situation causes combustible fuel to ignite on impact and often results in subsequentloss of life. Manned aircraft operations have had to make emergencylandings 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 ofcombustible fuel alleviates anypotential threatto the public, and is much easierto maneuver to a safe landing under conditions any manned aircraft can obtain. Congress has alreadyproclaimed thatit is in the public's interestto integrate

MichaelJoseph Indovina VI, ATP-CFl-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 5 of 10Michael 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 interestthrough reducing potential threats ofmanned aircraft incidences. Furthermore, mylightweight UAS is batterypowered and creates no emissions that can harmthe environment. The consequence ofmylightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are extremelyheavy, contain many gallons combustible fuel and can cause catastrophic devastation to the public. Minimizing ecological and crash threats furthers the public's interestby permitting aerial videojphoto capturing through the use ofbattery operated, lightweight UAS's. Permitting me, Michael Joseph Indovina, to immediatelyfly within the NAS continues economic growth. Granting my exemption requestwill substantially further the economic impact for the greater Los Angeles community for companies looking to relocate orbuild in the area as well as individuals looking to survey properties. Both ofwhich serve as a stimulus to the community, and national economy.

V. Reasons Why Michael Joseph Indovina's Exemption Will NotAdversely Affect Safetyand/ orHow The Exemption Will Provide a Level ofSafetyAt Least Equal To Existing Rule: My, Michael Joseph Indovina's, exemption will not adversely affect safety, and itis with my utmost desire to complywithin 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 propertyto the uninvolved. By permittingthis exemption, you will allow the logging ofmore flight time in NAS, communication with the FAA, and allow me to continue to contribute with mylongstanding supportin the growing aviation industry. This would further build my reputation ofsafety, performance and reliability in the face ofthe FAA, and myATP oath ofgood moral character, to the public for the growing NAS structure atthe forefront oftoday's technology and changingtimes with my operations development in cooperation with the FAA.

In addition I, Michael Joseph Indovina, submitthe following representations for the exemption ofSection 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 setbythe FAA Modernization and Reform Act of 2012); My UAS only operates for 5-10 minutes per flight, orwithin 80% charged level; Iland my UAS priorto manufacturer recommended minimum of20% battery charge, 6 minutes oftested flight time remaining as reserves; I pilot my UAS through remote control only byvisual line-of-sight;

Michael Joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 6 of 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition

• My UAS has GPS a flight safety feature wherebyitreturns to launch position or hovers and then slowlylands ifcommunication betweenthe UAS and the Pilot In Command is lost;

. • I actively analyze flight data and other sources ofinformation to constantly update and enhance safety protocols;
• I only operate in reasonably safe environmentthatis strictly controlled, away from powerlines, elevated lights, airports and actively populated areas; • I conduct extensive pre-flight inspections and protocol, during which safety carries primaryimportance 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 priorto operation; and have procedures in place to abortflights in the event ofsafety breaches or potential danger.
My, Michael Joseph Indovina's, safety protocols provide a level ofsafety equal to or exceeding existing rules. Itis importantto note that absentthe integration of commercial UAS into the NAS, helicopters and otherfixed wing aircraft are the primary means ofaerial video and photographyfor aerial survey /photo 

## Icinematography. While the safetyrecord ofsuch aircraft are remarkably astounding, therehas been a plethora ofincidents involving loss oflife as well as extensive propertydamage; it is far safer to operate a batterypowered, lightweight UAS. First, the potential loss oflife 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 ofmy 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. SummaryThe 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 ofnecessary 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 equivalentlevel ofsafetypursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirementunderboth theAct ( 49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces oflegislation permitthe FAA to exempt UAS's from the airworthiness certificate requirementin consideration ofthe weight, size, speed, maneuverabilityand proximityto 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

Michael Joseph IndovinaVI,ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 7 of 10Michael 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 ofthese elements.

B. 14 CFR § 45.23: Aircraft Markings. Applicable Codes ofFederal Regulation require aircraftto be marked according to certain specifications. My UAS is, by definition, unmanned. It therefore does nothave a cabin, cockpit orpilot station on which to mark certain words or phrases. Furthermore, two-inch letteringis difficult to impossible to place on such small aircraftwith dimensions smaller thatminimal lettering requirement. Regardless, I will markits UASs in the largestpossible letteringbyplacing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29 (f) so that Ithe Pilot In Command, or anyone assisting me as a spotter with the UAV will seethese markings. The FAA has previouslyissued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 CFR 91.7 Prohibits the operation ofan 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 aircraftflight manual in the aircraft. As there are no on board pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafetywill be achieved by maintaining a safety /flightprocedures form, delineating areas ofwhere 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 ofthe PIC shall determine all applicable information ofintended airports ofuse, and takeoff/landing performance data. Gross weightand atmospheric conditions pertaining to the changes ofdensity altitude and performance characteristics ofaircraftwould notbe applicable to the operation ofmy UAS.

14 CFR 91.119: Prescribes minimum Safe Altitudes. My UAS will never operate at an altitude greaterthan 200 Above Ground Level (AGL); safely well below the standard of400 AGL. I, Michael Joseph Indovina, will however, operate my UAS in safe areas awayfrom public and traffic, providing a level ofsafety atleast equivalentto or belowthose in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofmy UAS, an equivalent orhigher level ofsafetywill be achieved. This should not apply as the UAS does notfly atthese flight altitudes, and is it at all times in a position to make an emergency landing withoutundue hazard to persons or propertyon the surface.

6Appendix B - Safety Protocols and Flight Controls

- Flight Procedures Form Michael Joseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 8 of 10Michael 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 ratherthan to a standard datum plane.
14 CFR § 91.151 Requires excess fuel to be carried onboard the aircraft as a means ofreserves, based on daylight or night conditions. This UAS does not carryfuel and maximum flight times are less than what is required in this section. However, safetymeasures are in place regarding leaving a certain level ofcharge onboard to ensure adequate powerto complete flight operations.
14 CFR § 91.203 provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level ofsafetywill be achieved bymaintaining any such required certifications and registrations by me, Michael Joseph Indovina.
14 CFR § 91.205 Required instruments and equipmentlist. None ofthese items applyto the flight operations ofmy UAS.

14 CFR 91.405; 91.407; 91.409; 91.411,91.413 and 91.417: Maintenance Inspections. The above-cited regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis partand shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

..." These Regulations only applyto aircraftwith an airworthiness certificate. They will not, therefore, applyto my, Michael Joseph Indovina's, UAS. However, as a safetyprecaution Iinspect 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 ofpurpose and stated limitations within this document, I submitto you this formal requestfor exemption for me, Michael Joseph Indovina, to commercially operate my, Michael Joseph Indovina's, small unmanned vehicle/lightweightunmanned aircraft vehicle in video cinematic and real estate operations, and to enhancethe experience of those seekingto relocate or discover newvenues within the greater Los Angeles area. Currently, area awareness and real estate aerial videography /photography relies primarily on the use oflarger aircraftrunning on combustible fuel. Posing a highly potential risk to the public. Granting my, Michael Joseph Indovina's, request for exemptionwill reduce currentrisk levels and thereby enhance safety, with my planto offer a creative twistto my photographybusiness with the usage ofmy

Michaeljoseph Indovina VI, ATP-CFI-MEI, Mike Six Imaging, Los Angeles CA- Section 333 Exemption Petition Page 9 of 10Michael Joseph Indovina VI, ATP/CFI, Mike Six Imaging- Section 333 Exemption Petition personal UAS ratherthan fixed wing, manned aircraft. My UAS craft does not contain potentiallyexplosive fuel, is smaller, lighter and more maneuverablethan conventional, manned aircraft, significantly less pollutantand economically beneficial.
Further, I operate atlower altitudes and in tightly controlled airspace eliminating potential public risk from putting themselves into unnecessaryharm. Formal collection offlight data information is stored and can be shared with the FAA in hopes to enhancethe FAA's internal efforts in establishing protocols for complying with the FAA Modernization and Reform Act of2012. There are no personnel on board my, Michael Joseph Indovina's, UAS and therefore the likelihood ofdeath or serious bodily injury is significantly diminished. My, Michael Joseph Indovina's, operation ofmyUAS, weighing less than 10 pounds and travelling atvery slow speeds within limited areas will provide an equivalentlevel ofsafety as that achieved under current FARs. Accordingly I, Michael Joseph Indovina, respectfully request thatthe FAA grantmy exemption request and I am willing to cooperate in sharing information to benefitthe FAA, the safety ofmanned aircraft, and the general public atlarge.

Thankyou for your consideration.

Respectfully;

Michael Joseph Indovina VI ATP CFI MEl: 3146873 Mike Six Imaging 8000 West ManchesterAve. #222 Playa Del Rey, CA 90293 Phone: (805) 455-9041 Email: Vl@mikesix.com www.mikesix.com

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