Spacecrafting,	Inc.

Owner:	Mike	McCaw

917	N.	5th Street

Minneapolis,	MN	55401

612-353-4073

U.S.	Department	of	Transportation

Federal	Aviation	Administration

January	13th,	2016

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

Federal	Aviation	Regulations	contained	in	14	CFR:	45.23(b),	91.103,	91.109,	91.119,	

91.121,	91.151(a),	91.203(a),	91.7(a),	91.9(b)(2),	91.405(a),	91.407(a)(1),	

91.409(a)(2),	91.417(a)(b).	

To	Whom	It	May	Concern:

Pursuant	to	Section	333	of	the	Federal	Aviation	Administration	(FAA)	

Modernization	and	Reform	Act	of 2012	(the	“Reform	Act”)	and	14	CFR	Part	11,	Mike	

McCaw,	owner	of	Spacecrafting Photography	&	Video	(Spacecrafting)	which	owns	

and	operates	an	Unmanned	Aircraft	System	(UAS),	hereby	applies

for	an	exemption	from	the	listed	Federal	Aviation	Regulations	(FARs)	to	allow	

commercial	operation	of its	UAS,	so	long	as	such	operations	are	conducted	within	

and	under	the	conditions	outlined	herein	or	as may	be	established	by	the	FAA	as	

required	by	Section	333.

Commercial	operation	of	an	UAS,	as	described	herein, would	operate	in	the	

following	manner:

- Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	

estate, architecture,	surveying,	engineering	and	other	related	professional	

activities.

- Aerial	video	and/or	photography	for	public	and/or	private	use	including	

television,	public events,	private	events,	cinematography	and	newsgathering.

Spacecrafting operates	a DJI	Inspire	1	(4)	blade	quad	copter weighing	6	pounds,	7.5	

ounces	(see	attached manual).	The	UAS	has	a	maximum	airspeed	of	40	miles	per	

hour	and	uses	a	remote	controller	operating	on	frequency	range	of	2.400-2.483	

GHZ.	The	Inspire	1	is	equipped with	built-in	ground	support technology	that	allows	
it	to	fly	utilizing	global	positioning	system	(GPS)	for	stability,	tracking,	safe	flight

mode	and	a	return-to-home	feature	in	the	event	of	loss	of	remote	control	signal	or	

critical	low	battery. All	flights	start	with	a	pre-flight	safety	check	and	all	flight	data	

are	recorded.	The	Inspire	1	is	equipped with	a	camera	that	sends	a	live	video	signal	

to	the	controller	allowing	the	person	in control	(PIC)	to	monitor	real-time	video.	

Flight	data,	speed	height,	distance,	battery	level	and	general aircraft	conditions	are	

also	displayed	during	operation.	The	Inspire	1	battery	has	a	flight	time	of	15-20

minutes	and	is,	therefore,	always	returned	to	original	takeoff	point and	always	

flown	utilizing	visual	line of	sight	(VLOS).	We	have	been	training	on	the	DJI	Inspire	

for	close	to	1	year and	have	become	proficient in	all	aspects	of	flight	and	safety	of	

this	UAS (see	technical	details	attached).	Our	request	for	exemption	would	allow	us	

to	offer	unique aerial	photography	and	videography	services	to	our	clients.

Petitioner/Operators

Steve	Huffman	went	through	the	Quadrocopter	FreeFly	ALTA	Hands-On	Multi-rotor	

Operation	&	Flight	Training program	and	has	been flying	sUAS	“quadcopters”	for	3

years	as	a	hobbyist	and	has	approximately	250 hours	of	total	sUAS	time.	

Branick	Weix	has	been	designing,	building,	and	flying	model	aircraft	for	over	10	

years	and	has	experience	in	structural	composites	and	small	electronics.		He	has	

been	an	avid	sUAS	user	over	the	last	three	years	in	platforms	such	as	the	DJI	

Phantom	2/2+,	DJI	Inspire	1,	and	3DR	Iris+.		For	the	platforms	in	which	we	are	

seeking	approval	he	has	over	120	hours	of	safe	flight	operations	in	adverse	

conditions	and	climates.		

UAS	Safety	Operating	Parameters

We	will	abide	by	the	following	additional	operating	conditions	under	this	

exemption,	which	ensures	a level	of	safety	during	UAS	flight	including	operating	the	

UAS	below	400	feet and	within	a	radius	of	1,000 feet	from	PIC	always	maintaining	

VLOS	and	obtaining	permission	from	the	owner/controller	of	any vessels,	vehicles	

and	structures	when	operations	may	be	conducted	closer	than	500	feet	to	any	such

vessels,	vehicles	or	structures.	We	will	conduct	a	safety	assessment	of	the	risk	of	

operating	closer	to those	objects	and	determine	that	it	does	not	present	an	undue	

hazard.	Other	safety	operating parameters	include:

- Operate	the	UAS	for	15-20	minutes	per	flight.

- Land	UAS	prior	to	the	manufacturers	recommended	minimum	level	of	

battery	power.

- Operate	the	UAS	during	daylight	hours	only	within	VLOS.

- Utilize	the	UAS’	GPS	flight	safety	feature	whereby	it	hovers	and	then	slowly	

lands	if communication	with	the	PIC	is	lost	or	battery	becomes	critically	low.

- Always	obtain	all	necessary	permissions	prior	to	operation.

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

potential	danger.

- Review	weather	reports	prior	to	flight	and	never	operate	UAS	in	unsafe	

conditions,	high	wind, low	clouds	or	conditions	that	hinder	visibility.
- Only	operate	in	safe	environments	that	are	strictly	controlled,	are	away	from	

power	lines, elevated	lights,	airports	and	densely	populated	areas.

- Also	conduct	extensive	preflight	inspections	and	protocols	during	which	

safety	carries	primary importance.	

The	PIC	will	also	have	a	minimum	of	five	hours	logged	on	this	craft	and	10	hours	

minimum	flying	UAS quad	copters	under	varying	conditions	and	environments	and	

will	follow	all	guidelines	of	14	CFR	§61.51(b)	having	the	ability	to	safely	operate	the	

UAS	in	a	manner consistent	with	the	operating	documents,	including	evasive	and	

emergency	maneuvers	and	maintaining appropriate	distances	from	people.

Specific	Exemptions	Requested

Given	the	size,	weight,	speed	and	limited	operating	area	associated	with	the	UAS,	we	

feel	an	exemption from	14	CFR	Part	21,	Subpart	H	(Airworthiness	Certificates)	and	

14	CFR	91.203(a)	and	(b)	(certifications required),	subject	to	certain	conditions	and	

limitations,	is	warranted	and	meets	the	requirements	for	an equivalent	level	of	

safety	under	14	CFR	Part	11	and	Section	333	of	P.L.	112-95	(Section	333).

We	request	an	exemption	from	14	CFR	45.23	Marking	of	the	Aircraft	because	the	

UAS	will	not	have	a cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	words	or	

phrases.	Further,	the	two-inch	lettering is	difficult	to	place	on	such	a	small	aircraft	

with	dimensions	smaller	than	the	minimal	lettering requirement.	Regardless	of	this,	

we	can	mark	the	UAS	in	the	largest	possible	lettering	by	placing	the word	

“Experimental”	on	its	fuselage	as	required	by	14	CFR	45.29(f)	so	that	anyone will	

see	the	markings.

We	request	an	exemption	from	14	CFR	61.113(a)	and	(b)	Private	Pilot	Privileges	

and	Limitations:	Pilot	in Command.	The	applicant’s	UAS	do	not	carry	any	pilots	or	

passengers	nor	property.	The	Risks	attendant to	the	operation	of	the	UAS	is	far	less	

than	the	risk	levels	inherent	in	the	commercial	activities	outlined in	14	CFR	§61.	The	

operation	and	limitations	in	the	flight	operation	manual	(FOM)	will	equate	to	the	

safe operations	of	the	UAS.

We	request	an	exemption	from	14	CFR	91.7(a) which	prohibits	the	operation	of	an	

aircraft	without	an airworthiness	certificate,	since	there	is	currently	no	certificate	

applicable	to	our	operation,	this regulation	is	inapplicable.	We	request	an	exemption	

from	14	CFR	91.405(a),	14	CFR	91.407(a)(1),	14 CFR 91.409(a)2)	and	14	CFR	

91.417(a)	and	(b)	Maintenance	inspections	since	they	only	apply	to	aircraft	with an	

airworthiness	certificate.	However,	as	a	safety	precaution,	we	will	perform	a	

preflight	inspection	of the	UAS	before	each	flight	as	outlined	in	the	attached	

operating	documents.

We	request	an	exemption	from	14	CFR	91.9(b)(2)	which	requires	an	aircraft	FOM	in	

the	aircraft, however,	since	there	are	no	pilots	or	passengers	on	board	the	aircraft,	

and	given	its	size,	this	regulation is	inapplicable.	We	believe	an	equivalent	level	of	
safety	will	be	achieved	by	maintaining	a	safety/flight manual	with	the	UAS	ground	

station.

We	request	an	exemption	from	14	CFR	91.109	Flight	Instruction:	Simulated	

Instrument	Flight	and Certain	Flight	Tests.	This	section	states	that	no	person	shall	

operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	being	used	for	flight	

instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	

The	Inspire	1/T600	like	almost	all	sUAS	aircraft	by	their	design	do	not	have	fully	

functional	dial	controls.	Flight	control	is	accomplished	through	the	use	of	a	control	

box	that	communicates	with	the	aircraft	via	a	2.4	GHz	radio	communications	link.	

The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional	dual	

controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	

See	exemption	notes	5778K	and	9862A.	The	equivalent	level	of	safety	provided	by	

the	fact	that	neither	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	training	

would	be	conducted	at	an	FAA	approved	training	site,	operating	under	a	COA.

We	request	an	exemption	from	14	CFR	91.119(c)	which	prescribes	safe	altitudes	for	

the	operation	of civil	aircraft,	but	allows	helicopters	to	be	operated	at	lower	

altitudes	in	certain	conditions.	We	will	not operate	our	UAS	above	the	altitude	of	

400	feet	above	ground	level	(AGL)	and	will	also	only	operate	in safe	areas	away	

from	the	public	and	traffic,	thus	“providing	a	level	of	safety	at	least	equivalent	to	or

below	those	in	relation	to	minimum	safe	altitudes.”	Given	the	size,	weight	and	

maneuverability	and speed	of	the	UAS,	an	equivalent	or	higher	level	of	safety	will	be	

achieved.

We	request	an	exemption	from	14	CFR	91.121	Altimeter	Settings,	as	it	is	

inapplicable since	the	UAS utilizes	electronic	GPS	with	a	barometric	sensor.	We	

request	an	exemption	from	14	CFR	91.151(a)	Fuel Requirements	for	Flight	in	visual	

flight	rules	(VFR)	conditions.	The	UAS	is	100	percent	electric	and	two low	battery	

alerts	are	issued	– per the	operating	documents,	the	UAS	will	be	landed	at	the	first	

alert. Also,	our	flights	will	last	only	15-20	minutes	each	and	the	UAS	has	an	

automated	function,	which	results in	immediate	landing	when	a	low	battery	is	

detected.	The	PIC	will	not	begin	a	flight	unless,	considering wind	an	forecast	

weather	conditions,	there	is	enough	power	to	fly to	the	first	point	of	intended	

landing and,	assuming	normal	cruising	speed,	land	the	UAS	with	30	percent	battery	

power	remaining.

Summary

We	will	comply	with	all	of	the	following	conditions	and	limitations	should	this	grant	

of	exemption	be provided:

1.	Operations	will	be	limited	to	the	following	aircraft	described	in	the	operating	

documents	which is	a	quad-rotor	aircraft	weighing	less	than	seven	pounds:	DJI	

Inspire	1	Aircraft	System.

2.	The	UAS	will	not	be	flown	at	an	indicated	airspeed	exceeding	40	mph.

3.	The	UAS	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL,	as	indicated	

by	the procedures	specified	in	the	operating	documents.
4.	The	UAS	will	be	operated	within	VLOS	of	the	PIC	at	all	times.

5.	All	operations	may	utilize	a	visual	observer	(VO.	The	UAS	will	be	operated	within	

the	VLOS	of	the VO	at	all	times.	The	VO	and	PIC	will	be	able	to	communicate	verbally	

at	all	times.	The	PIC	will	be designated	before the	flight	and	will	not	transfer	his	or	

her	designation	for	the	duration	of	the flight.	The	PIC	will	ensure	that	the	VO	can	

perform	the	functions	prescribed	in	the	operating documents.

6.	The	operating	documents	will	be	accessible	during	the	UAS	operations	and	made	

available	to the	Administrator	upon	request.	Any	revisions	to	the	operating	

documents	will	be	presented	to the	Administrator	upon	request.

7.	Prior	to	each	flight,	the	PIC	will	inspect	the	UAS	to	ensure	it	is	in	a	condition	for	

safe	flight.	If	the inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	

UAS,	the	UAS	will	not	be operated	until	the	necessary	maintenance	has	been	

performed	and	the	UAS	is	found	to	be	in	a condition	for	safe	flight.	The	Ground	

Control	Station	will	be	included	in	the	preflight	inspection.

All	maintenance	and	alterations	will	be	properly	documents	in	the	aircraft	records.

8.	Any	UAS	maintenance	or	alterations	that	affect	the	UAS	operation	or	flight	

characteristics,	e.g. replacement	of	a	flight	critical	component,	will	undergo	a	

functional	test	flight.	The	PIC	who conducts	the	functional	test	flight	will	make	an	

entry	into	the	aircraft	records.	

9.	The	pre-flight	inspection	section	in	the	operating	documents	will	account	for	all	

discrepancies, i.e.	inoperable	components,	items	or	equipment	not	already	covered	

in	the	relevant	sections	of the	operating	documents.

10.	We	will	follow	the	UAS	manufacturer’s	aircraft/component,	maintenance,	

overhaul, replacement,	inspection	and	life	limit	requirements.

11.	We	will	carry	out	maintenance,	inspections	and	record-keeping	requirements,	in	

accordance with	the	operating	documents.	Maintenance,	inspection	and	alterations	

will	be	noted	in	the aircraft	records,	including	total	flight	hours,	description	of	work	

accomplished and	the	signature of	the	authorized	person	returning	the	UAS	to	

service.

12.	Each	UAS	operated	will	comply	with	all	manufacturer	Safety	Bulletins.

13.	An	authorized	person	will	make	an	entry	in	the	aircraft	record	of	the	corrective	

action	taken against	discrepancies	discovered	between	inspections.

14.	The	PIC	will	also	meet	the	flight	review	requirements	specified	in	14	CFR	61.56	

in	an	aircraft	in which	the	PIC	is	rated	on.

15.	Prior	to	operations	conducted	for	the	purpose	of	aerial	

videography/cinematography	and augmenting	real	estate	listing	videos	(or	similar	

operations),	the	PIC	will	have	accumulated	and logged,	in	a	manner	consistent	with	

14	CFR	61.51(b),	a	minimum	of	five	hours	as	an	UAS	pilot operating	the	make	and	

model	of	the	UAS	to	be	used	in	operations.

16.	The	PIC	will	not	operate	the	UAS	for	the	purpose	of	aerial	

videography/cinematography	and augmenting	real	estate	listing	videos	(or	similar	

operations),	unless	the	PIC	has	demonstrated and	logged	in	a	manner	consistent	

with	14	CFR	61.51(b),	the ability	to	safely	operate	the	UAS	in a	manner	consistent	

with	the	operating	documents,	including	evasive	and	emergency maneuvers	and	

maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures.
17.	UAS	operations	will	not	be	conducted	during	night	hours,	as	defined	in	14	CFR	

1.1	All	operations will	be	conducted	under	visual	meteorological	conditions	(VMC).

18.	The	UAS	will	not	operate	within	five	nautical	miles	of	an	airport	reference	point	

as	denoted	on	a current	FAA-published	aeronautical	chart.

19.	The	UAS	will	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally	from	a cloud	or	when	visibility	is	less	than	three	statute	miles	from	the	

PIC.

20.	If	a	UAS	loses	communications	or	loses	its	GPS	signal,	it	will	return	to	a	

predetermined	location within	the	planned	operating	area	and	land	or	be	recovered	

in	accordance	with	the	operating documents.

21.	The	PIC	will	abort	a	flight	in	the	event	of	unpredicted	obstacles	or	emergencies	

in	accordance with	the	operating	documents.

22.	The	PIC	will	not	begin	a	flight	unless,	considering	wind	and	forecast	weather	

conditions,	there	is enough	power	to	fly	at	a	normal	cruising	speed	to	the	intended	

landing	point	and	land	the	UAS with	30	percent	battery	power	remaining.

23.	Before conducting	operations,	the	radio	frequency	spectrum	used	for	operation	

and	control	of the	UAS	will	comply	with	the	Federal	Communications	Commission	

(FCC)	or	other	appropriate government	oversight	agency	requirements.

24.	The	documents	required	under	14	CFR	91.9	and	14	CFR	91.203	would	be	

available	to	the	PIC	at the	Ground	Control	Station	of	the	UAS	at	any	time	the	UAS	is	

operating.	These	documents	will be	made	available	to	the	Administrator	or	any	law	

enforcement	official	upon	request.	

25.	The	UAS	will	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	

operations	and activities	at	all	times.

26.	The	UAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.

27.	The	UAS	will	not	be	operated	over	congested	or	densely	populated	areas	unless	

contracted	out to	do	events.

28.	Flight	operations	will	be	conducted	at	least	500	feet	from	all	nonparticipating	

persons,	vessels, vehicles	and	structures	unless:

a.	Barriers	or	structures	are	present	that	sufficiently	protect	nonparticipating	

persons	from the	UAS	and/or	debris	in	the	event	of	an	accident.	We	will	ensure	that	

nonparticipating persons	remain	under	such	protection.	If	a	situation	arises	where	

nonparticipating persons	leave	such	protection	and	are	within	500	feet	of	the	UAS,	

flight	operations	must cease	immediately.

b.	The	aircraft	is	operated	near	vessels,	vehicles	or	structures	where	the	

owner/controller of	such	vessels,	vehicles	or	structures	has	granted	permission	and	

the	PIC	has	made	a safety	assessment	of	the	risk	of	operating	closer	to	those	objects	

and	determined	that	it does	not	present	an	undue	hazard.

c.	Operations	near	to	the	PIC,	VO,	operator	trainees	or	essential	persons	do	not	

present	an undue	hazard	to	those	persons	per	14	CFR	91.119(a).

29.	All	operations	will	be	conducted	over	private	or	controlled-access	property	with	

permission from	the	land	owner/controller	or	authorized	representative.	

Permission	from	land owner/controller	or	authorized	representative	will	be	

obtained	for	each	flight	to	be	conducted.

30.	Any	incident, accident	or	flight	operation	that	transgresses	the	lateral	or	vertical	

boundaries	of the	operational	area	as	defined	by	the	applicable	certificate	of	
authorization	(COA)	will	be reported	to	the	FAA’s	UAS	Integration	Office	(AFS-80)	

within	24	hours.	Accidents	will	be reported	to	the	National	Transportation	Safety	

Board	(NTSB)	per	instructions	contained	on	the NTSB	website:	www.ntsb.gov.

Closing

Spacecrafting	Photography	& Video	is	committed	to	safe	flight	practices,	while	

integrating	safe	sUAS	operations	to	the	National	Airspace	System	(NAS).	We	are	

confident	in	executing	commercial	sUAS	operations	that	are	safe,	and	provide	a	

service	to	the	public.	We would	like	to	thank	you	for your	consideration	in granting	

this	exemption.

Respectfully	submitted,

Mike	McCaw

Spacecrafting	Photography	&	Video