October 28, 2015

To: US Department of Transportation From: Michael Silvestri, President

Docket Management System Long Island Drone Media, Inc.

1200 New Jersey Ave, SE 46 Pershing Ave.

Washington, DC 20590 Babylon, NY 11702

(Submitted electronically to the Federal Phone: 631-219-2779

Docket Management System-FDM) Email: lidronemedia@gmail.com

Re: Request for Exemption to Section 333 of the FAA Reform Act and 14 CFR Part 11

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), and

14 C.F.R. Part 11, Michael Silvestri, owner of Long Island Drone Media, Inc. (“LIDM”), a professional

media company 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 and limitations set

forth in this Petition or as may be established by the FAA as required by Section 333.

LIDM requests that the FAA review this petition pursuant to its “summary grant” process as the FAA

has already granted exemptions similar in all material respects to this petition. See FAA Grant of

Exception Nos. 11062, 11109, 11112, and 11213. The reasons stated by the FAA in granting the

exemptions listed above also apply to this petition, and the grant of this petition is in the public interest.

Regulations for Which Exemption is Requested

LIDM requests exemption from the following regulations:

• 14 C.F.R Part 21, Subpart H;

• 14 C.F.R Part 27;

• 14 C.F.R § 45.23(b);

• 14 C.F.R. § 45.27(a);

• 14 C.F.R § 61.113;

• 14 C.F.R § 91.7(a);

• 14 C.F.R § 91.9(b)(2);

• 14 C.F.R § 91.9(c);

• 14 C.F.R § 91.103;

• 14 C.F.R § 91.109(a);

• 14 C.F.R § 91.119;

• 14 C.F.R § 91.121;

• 14 C.F.R § 91.151(a) & (b)

• 14 C.F.R § 91.203 (a) & (b);

• 14 C.F.R § 91.405(a);

• 14 C.F.R § 91.407(a)(l);

• 14 C.F.R § 91.409(a)(2);

• 14 C.F.R § 91.417 (a) & (b).
Statutory Authority for Requested Exemptions

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress

has directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the

national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to

permit operation of an unmanned aircraft system (“UAS”) where it does not create a hazard to users of

the national airspace system (“NAS”) or the public or pose a threat to national security based on the

following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant

exemptions from the agency’s safety regulations and minimum standards when the Administrator

decides a requested exemption is in the public interest. See 49 U.S.C. §§106(f), 44701-44716, et seq. A

party requesting an exemption must explain the reasons why the exemption: (1) would benefit the

public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at

least equal to the existing rules. 14 C.F.R. § 11.81.

Description of Long Island Drone Media, Inc. Services

Commercial operation of a UAS, as described herein, which are equipped with camera(s) and sensors,

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 news gathering.

• Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

• Aerial inspection/photography or residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers.

• Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

 LIDM UAS Equipment - DJI Phantom 3

LIDM will use the Phantom 3 as the aircraft it will provide its services. The Phantom 3 is shown in

Figure 1 below. The FAA has already approved the Phantom 3 for commercial use in FAA Exemption

No. 11696 (FAA Docket No. FAA-2015-0746). 

Figure 1 – DJI Phantom 3

The Phantom 3 is more fully described in the Phantom 3 User Manual.
LIDM Proposed Operations Demonstrate an Equivalent Level of Safety

LIDM proposes to operate within the limitations and performance specifications listed in this

application and in the Manuals. These limitations provide for at least an equivalent, or higher, level of

safety for operations under the current regulatory structure because the proposed operations are safer

than conventional operations using helicopters or fixed wing aircraft which carry an operator and

flammable fuel. The proposed flight operations are similar in all material respects to operations already

approved by the FAA and are therefore subject to the FAA’s “summary grant” process.

The proposed operations do not create any hazard to users of the national airspace system or pose a

threat to national security. The aircraft are battery operated with a maximum flight time of less than 23

minutes. The vehicles weigh less than 55 pounds. The vehicles will be operated at or below 400 feet

AGL within the visual line of sight of the pilot in command. LIDM operations will be over private or

controlled access property with the permission of the owner/controller or authorized agent.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The proposed

UAS carry no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is

eliminated. Compared to manned aircraft, the UAS being operated by the petitioner reduces the risk to

participating persons in close proximity to the aircraft due to the limited size, weight, operating

conditions, and design safety features.

The petitioner’s aircraft have the capability to operate safely after experiencing certain inflight failures,

as specified in the Manuals. The aircraft are also able to respond to a lost-link or low battery event with

a pre-coordinated, predictable, automated flight maneuver.

Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will operate, the

procedures listed below, and pilot certification requirements, LIDM's proposed operations would “not

create a hazard to users of the national airspace system or the public or pose a threat to national

security.” Reform Act Section 333(b)(1).

1. The aircraft weigh less than 55 pounds.

2. Each aircraft will be identified by serial number, registered with the FAA, and have

identification (N-Number) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and confirmed for

accuracy by PIC.

5. The PIC will ensure that before each flight, there is enough available power for the UAS to

conduct the intended operation and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer if greater.

6. The aircraft will be operated during daylight and in VFR conditions.

7. Flights will not exceed 400 feet AGL.

8. Flights will be operated at a lateral distance of at least 500 feet from any persons or property not

associated with the operation who have not given prior permission.

9. Flights will be limited to a groundspeed of 40 mph.

10. Minimum crew for each flight will consist of a PIC and an Observer.

11. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot

certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S.

driver’s license issued by a state or the Federal Government. The PIC will also meet the flight

review requirements specified in 14 CFR § 61.56.
12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as

well as contact information for the PIC.

13. The flight operations will yield the right of way to other manned aircraft operations.

14. All persons who are not involved with LIDM's operations will be required to be at least 500 feet

from flight operations.

15. The aircraft will only operate over private or controlled access property with the permission of

the owner/controller or authorized representative.

16. The UAS will not operate within 5 nautical miles of an airport unless a letter of agreement is

obtained.

17. All required permissions and permits will be obtained from territory, state, county or city

jurisdictions prior to flight.

18. Prior to commencing operations, LIDM will obtain a Certificate of Waiver or Authorization

(COA) from the FAA.

19. If the aircraft loses communications, it will have the capability to return to a pre-determined

location within the operational area and land.

20. If the aircraft loses its GPS signal it will have the capability of being flown manually to a

predetermined location within the operational area and land.

21. The flight will be aborted in case of unpredicted obstacles or emergencies.

22. UAS operations will be conducted within the parameters of the Manuals.

Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are more fully documented in the

attached Manuals.

SPECIFIC FAR EXEMPTIONS REQUESTED

LIDM seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for

purposes of conducting the requested operations. Listed below are (1) the specific FAR sections for

which exemption is sought, and (2) the operating procedures and safeguards that LIDM has established

which will ensure a level of safety better than or equal to the rules from which exemption is sought. See

14 C.F.R. §11.81 (e).

14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft

normally used for the same application. These criteria are met with this petition, and therefore no

exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-0352 at 13-14, 22. If,

however, the FAA determines that there are some characteristics of the UASs that fail to meet the

requirements of the Reform Act, an exemption is requested. Equivalent Level of Safety: The UASs are

safe when taking into account their size, weight, speed, and operational capability. They weigh less

than 55 pounds and will be flown at speeds less than 100 miles per hour, and in visual line of sight of

the operator. The UASs do not carry pilots, passengers, explosive materials, or flammable liquid fuels.

The UASs will be operated within the parameters of their respective Manuals. The proposed operations

will be at least as safe as, or safer than, conventional rotorcraft or fixed wing aircraft operating with an

airworthiness certificate without the restrictions and conditions proposed here.
14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal

category rotorcraft. To the extent the UASs would otherwise require certification under Part 27, LIDM

seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the

request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states: When marks include only the Roman capital letter

“N” and the registration number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display on that aircraft near

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6

inches high, the words “limited,” “restricted,” “light-sport, “experimental,” or “provisional,” as

applicable. 

14 C.F.R. § 45.27(a) states: Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 

14 C.F.R. § 91.9(c) states: No person may operate a U.S.-registered civil aircraft unless that aircraft is

identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was

warranted provided that the aircraft “have identification (N-Number) markings in accordance with 14

CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 11062,

Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety: LIDM will mark all UASs with their N-Number in a prominent spot on the

fuselage with markings that are as large as practicable. 

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

LIDM seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for

compensation or hire and would also require a second class medical certificate. The purpose of Part 61

is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be

operating, as well as requiring certifications if the pilot is carrying passengers or cargo for hire. 

While the UAS will be operated as part of a commercial operation, they carry neither passengers nor

cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the

unique characteristics of UAS operation outside of controlled airspace did not warrant the additional

cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and a class

II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot

covers the same fundamental principles as a private pilot.

The FAA has also granted exemptions allowing operations by people who hold an airline transport,

commercial, private, recreational, or sport pilot certificate with a current FAA airman medical

certificate or a valid U.S. driver’s license issued by a state or the Federal Government. The PIC must

also meet the flight review requirements specified in 14 CFR §61.56. See FAA Exemption No. 11374.

LIDM will ensure the PIC will meet the requirements listed in the above paragraph. LIDM will also

ensure the PIC will have completed the manufacturers’ training guidelines outlined in the Manuals. The

FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety
factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through

UAS-specific flight cycles, flight time, and specific make and model experience, culminating in

verification through testing.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 18. The

proposed operations can achieve an equivalent level of safety by requiring the knowledge and

experience in the UAS operations described above.

The restrictions LIDM has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352 and those listed in the FAA’s

“summary grant” process. 

 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

LIDM seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy

condition to be operated. The FAA has stated that no exemption is required to the extent that the

requirements of Part 21 are waived or found inapplicable. Accordingly, LIDM requests that the

requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of

Exemption No. 11062, p. 19.

 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 91.203(a) and (b):

Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft -

...

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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...

(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.

LIDM does not request an exemption from this section but instead notifies the FAA that, in accordance

with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual,

registration certificate and other documentation will be kept at the control station with the PIC during

flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method

constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19-20,

and Grant of Exemption No. 8607.
 14 C.F.R. § 91.103: Preflight Action

LIDM seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with

specific information before each flight, including information contained in the FAA-approved Flight

Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all

actions including reviewing weather, flight battery requirements, landing and takeoff distances and

aircraft performance data before initiation of flight. Under these circumstances, the FAA has stated that

no exemption is required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the

extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the Manuals.

The PIC will take all required preflight actions - including performing all required checklists and

reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft

performance data, and contingency landing areas - before initiation of flight. The Manuals will be kept

at the ground station with the operator at all times.

 14 C.F.R. § 91.109(a): Flight Instruction

LIDM seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 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.” UASs and remotely piloted aircraft, by their design, do not have

functional dual controls. Instead, flight control is accomplished through the use of the Ground Control

Station (GCS) that communicates with the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on board the aircraft

and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given

the size and speed of the UAS, an equivalent level of safe training can still be achieved without dual

controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance

away in the event that the aircraft experiences any difficulties during flight instruction. In addition,

LIDM will conduct flight training at a remote facility away from population centers. These training

flights will comply with the provisions in the Manuals. Accordingly, LIDM’s proposed method of

operation provides superior levels of safety.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

LIDM requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c).

Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person,

vessel, vehicle, or structure. The Manuals provide for LIDM operations at least 500 feet from persons

and structures not involved in the operations. The FAA has already determined that relief from Section

91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those

imposed by LIDM. See Grant of Exemption No. 11062, p. 20-21. 

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing aircraft

weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel,

any risk associated with these operations is far less than those that presently exist with conventional

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as

well as the locations where it is operated . In order to avoid any risk to aircraft, flight operations will be

restricted to 400 feet AGL or below. Other aircraft are already prohibited from operating closer than

500 from structures where LIDM proposes to operate. This is airspace where other aircraft do not

normally operate. As set forth in the Manuals and herein, the UAS will be operated in the remote sites,

away from persons or structures not involved in the operation. All persons who are not involved with

LIDM operations will be required to be at least 500 feet from flight operations. This will pose no risk to
the public because other aircraft are not operating in these areas.

 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the

elevation of the departure airport. The UASs proposed here use both barometric pressure sensors and

GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption

is required to the extent that the UAS does not have a barometric altimeter setting. The altitude of the

UAS is monitored by the PIC on the ground control station and by the visual observer.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be achieved if the

aircraft will be operated at or below 400 feet AGL and within visual line-of sight in addition to GPS

based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p.

20-21. As the attached Manuals indicate, the UAS will be operated at or below 400 feet AGL and

otherwise comply with the limitations in the Grant of Exemption No. 11062.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

LIDM requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR

conditions. Section 91.151 states:

(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.

Here, the technological limitations on the UAS battery power means that no meaningful flight

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery powered

with a maximum flight time of less than 25 minutes. The PIC will ensure that before each flight, there

is enough available power for the UAS to conduct the intended operation and to operate after that for at

least five minutes or with the reserve power recommended by the manufacturer if greater.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if the

UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated with at least

25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-22. The FAA’s

“summary grant” process provides that the PIC is prohibited from beginning a flight unless there is

enough available power to conduct the intended operation and to operate after that for at least five

minutes or with the reserve power recommended by the manufacturer if greater. See FAA Exemption

No. 11374 (FAA Docket No. 2015-0091 at p. 5). The limitations here provide that the PIC will ensure

that before each flight, there is enough available power for the UAS to conduct the intended operation

and to operate after that for at least five minutes or with the reserve power recommended by the

manufacturer if greater.

 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

LIDM seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. §

91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that
each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in subpart E of

this part and shall between required inspections ... have discrepancies repaired as prescribed in part 43

of this chapter”). An exemption from these regulations is needed because Part 43 and these sections

only apply to aircraft with an airworthiness certificate, which the UAS proposed here will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance and

inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul,

replacement, and preflight inspection requirements. See Exemption No. 11062 (FAA Docket No. 2014-

0352, at p. 14-15) and Exemption No. 11374 (FAA Docket No. 2015-0091, at p. 4). LIDM will follow

the UAS manufacturer’s maintenance requirements. Flights will not be conducted unless a flight

operations checklist is performed that includes all of the aircraft’s components.

Public Interest

Granting LIDM'S petition for exemption furthers the public interest. National policy set by Congress

favors early integration of UAS into the NAS in controlled, safe working environments such as

proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing

UAS to operate safely in the NAS before completion of the rulemaking required under Section 332 of

the Reform Act. Moreover, use of UAS will promote the efficient use of resources. The use of the UAS

propped here will also decrease safety-related incidents involving traditional aircraft. The public has an

interest in promoting science and technology education and in reducing the hazards and emissions

associated with alternate use of helicopters and small airplanes to conduct similar operations.

Privacy

All flights will occur over private or controlled access property with the owner’s consent. All flights

will be conducted in accordance with any federal, state or local laws regarding privacy.

Summary for Federal Register

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

LIDM seeks an exemption from the following rules for aeronautical and UAS training and education of

middle and high school students: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b);

14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R §91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c);

14 C.F.R § 91.103; 14 C.F.R § 91.109(a);14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a)

& (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R §

91.409(a)(2); 14 C.F.R §91.417 (a) & (b).

The exemption will promote science and technology education and training while enhancing safety by

reducing risk to the operator, the general public and property owners from the substantial hazards

associated with performing equivalent training and education using traditional conventional aircraft and

rotorcraft. LIDM requests that the FAA grant this petition using the “summary grant” process such that

publication in the Federal Register is not required. This petition would not set a precedent, and any

delay in acting on this petition would be detrimental to the petitioner.

ATTACHMENTS

Available online at http://www.dji.com/products=

Attachment 1: Phantom 3 User Manual
CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, operating

capabilities, proximity to airports and populated areas, operation within visual line of sight, and

national security considerations - provides more than adequate justification for the grant of the

requested exemptions to permit LIDM to operate the UASs proposed here. Furthermore, this petition

warrants review by the FAA under the “summary grant” process for immediate approval.

If you have any questions or need any additional information, please contact the undersigned at

631.219.2779 or lidronemedia@gmail.com.

Respectively Submitted,

Michael Silvestri

Long Island Drone Media, Inc.