January 26, 2015 Michale's Drone Photography, L.L.C. 1850 Golden Gate Ave.

Kingman, AZ 86401 (928) 897-2631 dronephotos@hotmail.com ; ·

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U.S. Department ofTransportation Docket Management System 1200 NewJersey Avenue SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 13 C.F.R. 61.133(a); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). Dear Sir(s)/Madam(s): Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Michael's Drone Photography, L.L.C., an Arizona limited liability company, the operator ofa DJI Phantom 1 ("UA"), seeks an exemption from the Federal Aviation Regulations ("FARs") as listed and discussed below. Michael's Drone Photography's team has flown its UAs, for recreational purposes, for hundreds ofhours without incident. Michael's Drone Photography's UAs are equipped to take aerial videography and photography to enhance awareness for those individuals and companies unfamiliar with the geographical layout of certain areas and augment real estate listings and promote the use of certain real estate properties which provides an enhancement to academic researchbeing performed in certain geographical areas ("purpose"). Michael's Drone Photography's exemption request will permit the operation of comparatively inexpensive UAs in tightly controlled, predetermined and limited airspace. This airspace will include areas away from general public, airports, heliports and vehicular traffic for 1
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631

### community videos, and within property boundaries for real estate listing videos and photos. Currently, similar lightweight, remote controlled UAs are legally operated by unmonitored and untrained amateurhobbyists withno safetyplan orcontrols in place to prevent catastrophic events. Michael's Drone Photography has safety protocols and controls in place to avoid and prevent public hazards as well as preventing the interference with manned aircraft which could cause a hazard or catastrophe. This acts to enhance safety protocols unique to Michael's Drone Photography's lightweight UAs being utilized specifically for real estate videography and photography. Michael's Drone Photography hope to be able to record flight data and other informationgainedthroughpermittedflight operationswhichmaybe sharedwiththe FAAthrough any required FAA reports to assist with the development of future FAA protocols and safety regulations. The use ofMichael's Drone Photography's UAs for these purposes reduces the need to operate conventional aircraft, typically needed to perform these types ofoperations, provides an economic benefit to the business consumer as the Michael's Drone Photography UAs provides higher quality imagery at a fraction of the cost of aerial videography and photography using conventional aircraft. These savings result in not only enhanced efficiency and productivity for the affected activities but added environmental and safety benefits to the public at large. As described more fully below, Michael's Drone Photography's requested exemption would authorize commercial operations ofaerial videography and photography, using Michael's Drone Photography'sUAs, which will be operatedunder controlled conditions at an altitude ofno greater than three hundred (300) feet AGL in airspace that is limited in scope and will have automated control features. Michael's Drone Photography's UAs will also be operated by an individual who has passed an FAA approved ground training exam, ifrequired by the FAA. As outlinedbelow,the airspace inwhichMichael'sDronePhotography'sUAs will operate withinwill be disclosed to the FAA in advance to flight operation. Finally, Michael's Drone Photography's UAs will be used in lieu ofcomparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft which shouldreassure the FAA that these operations will achieve at least an equivalent level or greater level ofsafety. In the interest of economic efficiency and public safety, Michael's Drone Photography hereby respectfully applies for anexemptionfrom the listed FARs to allowcommercial operations ofMichael'sDrone Photography'sUAs, so long as suchoperations are conductedwithinandunder the conditions outlined herein or as may be established by the FAA as required by Section 333. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's ("Administrator") 

### responsibilities under Section 333(c) ofthe Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system." 2
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631As discussed above and more fully describedbelow, therequestedexemptionwouldpermit the operation ofsmall, unmanned and relatively inexpensive UAs under controlled conditions in airspace that is limited and predetermined. Approval ofthis exemption would thereby enhance safety and fulfill the Administrator responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Please see Section 333(c) of the Reform Act. Additionally, the FAA has already granted a previous exemption which is essentially identical to the exemption being sought by Michael's Drone Photography. Please see FAA ExemptionNo. 11138. The name and address ofthe applicant is: Michael's Drone Photography, L.L.C. 1850 Golden Gate Ave. Kingman, AZ 86401 (928) 897-2631



### REGULATIONS FROMWHICHTHE EXEMPTION IS REQUESTED 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 13 C.F.R. 61.133(a) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.405(a) 14 C.F.R. 91.407(a)(1) 14 C.F.R. 91.409(a)(2) 14 C.F.R. 91.417(a) & (b)
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Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completionofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUAs do not create ahazard to users ofthe NAS orthe public orpose a threatto national security in light ofthe following:



### • • 

### • The UA's size, weight, speed, and operational capability; Operation ofthe UAs in close proximityto airports and populated areas; and Operation oftheUAs within visual line ofsight 

### ("VLOS") ofthe operator
. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft inthe national airspace system." Id. §333(c) (emphasis added). 1
The FederalAviationAct expressly grants the FAAthe authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act; that includes UAs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Michael's Drone Photography's UAs are rotorcraft weighing less than five (5) pounds (2.26796 Kg) including energy source(s), equipmentandanypayload. They operate, undernormal conditions at a ground speed ofno more than thirty (30) knots and have the capability to hover, and move in the vertical andhorizontal plane simultaneously. The UAs will operate only inline of sight and within safe. Such operations will insure that the UA will "not create a hazard to users ofthe national airspace system orthe public."3

1 Michael's Drone Photography interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation ofthe UA, if it should be determined that the**conditior,~s** set forth herein do notfulfill the statutory requirements for approval. 3 Reform Act Section 333 (b). 4
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631Giventhe small size ofthe UAs involved and the restricted environment withinwhichthey will operate, Michael's Drone Photography falls squarely withinthat zone ofsafety (an equivalent level ofsafety) inwhichCongress envisionedthatthe FAAmust, byexemption, allowcommercial operations ofUAs to commence immediately. Also due to the size ofthe UAs and the restricted areas in which the relevant UAs will operate, approval ofthe application presents no national security issue. Giventhe clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAs for aerial videography and photography operations, the grant ofthe requested exemptions is in the public interest. Additionally, there is economic efficiency created with the use of Michael's Drone Photography's UAs as the typical cost to perform aerial videography and photography with helicopters and airplanes heavily multiplies the cost to business consumers and government agencies, including lawenforcement, for the services whichare to beprovidedbyMichael'sDrone Photography. THEEXTENT AND BASIS OFTHE RELIEF SOUGHTBYMICHAEL'S DRONE PHOTOGRAPHY Michael's Drone Photography submits this application in accordance withthe Reform Act, 112P.L. 95 §§ 331-334, seekingrelieffrom any currentlyapplicable FARs operatingthatpresently prevents Michael's Drone Photography from contemplated commercial video-graphic, photographic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is inthe public's interest to do so. Michael's Drone Photography's UAs meet the definition of"smallunmanned aircraft" as defined in Section 331 and therefore the integration ofMichael'sDrone Photography'sultralightweightUAs is expressly contemplatedbythe Reform Act. Michael'sDronePhotographywouldliketo operateits ultralightweightUAspriortothetime period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UA aerial videography and photography. The Reform Act guides the Administrator in determining the types ofUAs that may operate safely in our national airspace system. These considerations include: weight, size, speed and overall capabilities ofthe UAs; whetherthe UAs will be operated near airports orheavily populated areas and; whether the UAs will be operated by line of sight.4 Each ofthese items is favorable to the grant of an exemption to Michael's Drone Photography. Michael's Drone Photography's UAs utilize four (4) counter-rotating propellers for balance, control and stability. Michael's Drone Photography's UAs are equipped with GPS and auto return safety technology. Michael's Drone Photography's UAs weigh less than five (5) pounds including camera and gimbal assembly. 5
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-26314 112 P.L. 95 § 333 (a). Michael's Drone Photography puts safety first when considering any UA flight. Michael's Drone Photography's small UAs are designed to hover inplace viaGPS and operate in less than a 24 knot (27 mph) wind. In orderto increase safety plus stability and limit harm and financial loss ofproperty, Michael's Drone Photography will not fly its UAs in winds exceeding 15 knots (17 mph). Michael's Drone Photography's established safety systems include a GPS mode that allows its UAs to hover in place when radio controls are released. Michael's Drone Photography's UAs havethree modesto choosefrom, Michael'sDronePhotographyutilizesthe Intelligent Orientation Control (IOC) Flight (with GPS & compass module)5 for aerial videography and photography. This mode is the safest, most reliable and stable mode to prevent accidents and being a hazard to others. When pilot communication is lost, Michael's Drone Photography's UAs are designed to return then slowly descendto the point oftakeoff. Michael's Drone Photography does not operate its UAs near airports, hospitals, police heliports or news channel heliports. Michael's Drone Photography does not operate its UAs in areas where general public is within fifty (50) to one hundred (100) yards depending on location, conditions and weather. Michael's Drone Photography's pilots and observers are constantly on alert for any manned aircraft andpreparedto immediately abort and land the UA at the nearest and safest ground point in the event a manned aircraft approaches or the Michael's Drone Photography pilot or observer suspects a manned aircraftmay approachthe operating area ofaMichael'sDrone PhotographyUA. Michael'sDrone Photography's UAs are capable ofvertical and horizontal operations, and are flown only within my line ofsight ofthepilot. Michael's Drone Photography's UA flights generally last fifteen (15) minutes with an altitude under three hundred (300) and utilize battery power rather than combustible fuels. Michael's Drone Photography does not operate its UAs below the manufacturer's recommended minimum charge levels for operation preferring to remain well within a safe operating range to insure adequate communication between radio control and the UAs to eliminate potential for crashes, loss ofcontrol or hazard. Fully charged reserve batteries are on hand with to insure replacement for a sufficiently safe level ofoperation. Michael's Drone Photography operates very conservatively and does believe intaking risks that may cause a crash or that could create hazard to the public, property and manned aircraft. Michael's Drone Photography's pilots have logged numerous practice flights in order to simulate flights for future commercial use to gain familiarization with the characteristics ofthis specific UA's performance under different temperature and weather conditions. Michael's Drone Photography is extremely cautious when operating ofits UAs and will not "create a hazard to users ofthe national airspace system orthe public."6 Given the small size andweight ofMichael's Drone Photography'sUAs, theyfall well withinCongress's contemplated safety zone when itpromulgated the Reform Act and the corresponding directive to integrate UAs 6
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631into the national airspace system. Michael's Drone Photography's UAs, utilized in hobby flight, has a demonstrable safety record and do not pose any threat to the general public or national security.

5 Intelligent Orientation Control (IOC) Flight (with GPS & compass module) includes safe circle for

operation, position hold, self-leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. See Exhibit "1"

- Phantom 1User Manual. 6 112 P.L. 95 § 333 (b).

MICHAEL'S DRONE PHOTOGRAPHY'S REQUEST WILL BENEFIT THE PUBLIC AT LARGE Aerial videography and photography for geographical awareness and for real estate marketing and promotion has been around for a long time through the use ofmanned fixed wing aircraft and helicopters. The challenge for smallerreal estate companies and average landowners is that the expense related to manned videography and photography is costprohibitive. Typically, only large businesses, large high endreal estate companies and highnetworthlandowners are able to absorb such an enormous expense. This deprives non-luxury landowners and small revenue real estate companies from the enjoying the benefit ofthis valuable marketing and promotional tool. Manned aircraftpose a clearthreatto the general public throughpotential catastrophic crashesthat may occur. There are manydocumentedeventswhere amanned aircrafthas crashedintopopulated areas with the size and combustibility ofthese manned aircraft causing large propetiy damage, human injuries and loss oflife. Michael's Drone Photography's UAs pose no such threat since size and lack ofcombustible fuel alleviates any ofthese potential threatto the public. With the passage ofthe Reform Act, Congress has already proclaimed that it is in the public's interest to integrate commercially flown UAs into the national airspace system. The grant ofthe exemption request by Michael'sDrone Photography furthers the public interest through academic and visual awareness ofthe geographicalbenefits ofcertain areas and by making this cost effective alternative available to small real estate companies and the average landowner. Michael's Drone Photography's ultralight UAs are battery powered and create no emissions that may harmthe environment. Inthe unlikely eventofa Michael's Drone PhotographyUAcrash, the consequence is far less than a full size helicopter or fixed wing aircraft, which are heavy and contain combustible fuel, crashing and causing catastrophic devastation to the public. The public's interest is furthered as Michael's Drone Photography minimizes ecological and crash threat by permitting aerial videography and photography captured through Michael's Drone Photography's battery operated ultralight UA's. Permitting Michael's Drone Photography to immediately fly within national air space furthers not only public safety but economic growth. 7
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631Granting Michael's Drone Photography's exemption request substantially furthers the economic impact for any community and for companies looking to relocate orbuild in a certain community as well as individuals lookingtorelocateto acommunityfor careeradvancementthrough academic and geographical awareness provided by Michael's Drone Photography. In the end, the granting ofthis exemption to Michael's Drone Photography will serve as a benefit and stimulus to any community.

MICHAEL'S DRONEPHOTOGRAPHY'S EXEMPTIONWILL NOT ADVERSELY AFFECT SAFETYAND WILL PROVIDE A LEVEL OF SAFETYAT LEASTEQUAL TOEXISTING FAA STANDARDS Michael's Drone Photography's exemptionwill not adversely affect safety, as itwill infact enhance safety. Michael'sDrone Photography's abilityto log significant, controlledandmonitored flight time in FAA controlled airspace will allow Michael's Drone Photography to contribute to the innovation and implementation ofnew, novel and undiscovered safety protocols for realtors that may be embraced by the NAR2 through consistent and ongoing cooperation with the FAA. Additionally, the FAA may utilize the new safety protocols for the use ofUAs in FAA controlled airspace for all industries. Michael's Drone Photography submits the following representations ofenhancements to current aerial videography and photography:

• Michael's Drone Photography's UAs weigh less than 5pounds (2.26796 Kg) complete with the camera and gimbal assembly; • Michael's Drone Photography will only operate its UAs below three hundred (300) feet which is well within the four hundred (400) feet ceiling having been established by the Reform Act of2012; .Michael's Drone Photography's UAs only operate for fifteen (15) minutes per flight; • Michael's Drone Photography lands its UAs prior to manufacturer's recommended minimum level ofbatterypower; .Michael's Drone Photography's pilots operate the UAs through Visual Line ofSight only; • Michael's Drone Photography's UAs have a GPS flight safety feature whereby the UA hovers and then slowly lands ifcommunication withthe pilot is lost;

2National Association ofRealtors, http://www.realtor.org/ 8
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631

### • Michael's Drone Photography actively analyzes its flight data and other sources of information to constantly update and enhance its safety protocols; • Michael's Drone Photography only operates in reasonably safe environments which are strictly controlled and away from power lines, elevated lights, airports and actively populated areas; • Michael's Drone Photography conducts extensive pre-flight inspections and protocol to ensure safety remains the primary concern; • Michael's Drone Photography always obtains all necessary permissions from the FAA and landowners priorto the operation its UAs and; • Michael's Drone Photography has established safety procedures in place to abort flights in the event ofsafety breaches or any potential danger. Michael's Drone Photography's safety protocols provide a level of safety equal to or exceeding existing FAA rules. It 

### is important to note that absent the integration ofcommercial UAs into our national airspace system, manned fixed wing airplanes and helicopters are the primary means ofaerial videography and photography for community awareness and real estate uses. Whilethe safetyrecord ofsuchhelicopters is outstanding,therehavebeenincidents involving loss oflife as well as extensive property damage due to crashes ofthese manned aircraft and it is far saferand less expensiveto operate abatterypoweredMichael'sDrone Photography'sultralight UAs to accomplish the same task. The potential for loss oflife is great diminished with a UA as Michael's Drone Photography's UAs carry no people or fuel on board and the UAs are also very small and versatile which allows Michael's Drone Photography to avoid hazards quickly and safely. Accordingly, Michael's Drone Photography respectfully requests that the FAA grant the requested exemption without delay. AIRCRAFT AND EQUIVALENTLEVEL OF SAFETY Michael's Drone Photography proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations underthe currentregulatory structurebecausethe proposed operationsrepresent a safety enhancementto the operations conducted with conventional aircraft. The FAA has noted in past exemptions that "Conventional aerial video operations, usingjetorpiston-powered aircraftpresentrisks associated with aircraft that weigh in the neighborhood of 5,000 to 7,000 pounds or more, carry large quantities offuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the survey location. Please see FAA Exemption 11110.

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Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: {928) 897-2631

### These limitations and conditions to which Michael's Drone Photography agrees to be bound when conducting all operations under an FAA issued exemption include: 1. The UAs will weigh less than five (5) pounds (2.26796 Kg). 2. Maximum total flight time for each operational flight will be fifteen (15) minutes. Flights will be terminated at thirty percent (30%) battery power reserve should that occur priorto the fifteen (15) minute limit. 3. Flights will be operated at an altitude ofno more than three hundred (300) feet AGL. 4. Minimum crew for each operationwill consist oftheUA Pilot and a Visual Observer ("VO"). 

### 5. The UAs will only operate within a safe area. 6. Abriefing will be conducted withregard to the planned UA operations priorto flight operations. It 

### will be mandatory that all personnel who will be performing duties withregard to the flight operations be present for this briefing. 7. The Pilot and VO will have beentrained in operation ofUAs generally and received up-to-date information on the particular UA to be operated and the UA will be operated in conformity with Michael's Drone Photography's protocols. 8. The PILOT and VO will at all times be able to communicate via voice communication. 9. Written and/or oral permission from the relevant property holder(s), or their authorized representative(s), will be obtained. 10. All reqpired permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 11. Ifthe UA loses communications or loses its GPS signal, the UA will return to the launch site ofthe UA, or another more appropriate site, and land. 12. The UA will have the capability to abort a flight in case ofunpredicted obstacles or emergencies. 14 C.F.R. PART 21, SUBPART H:

AIRWORTHINESS CERTIFICATES 14 C.F.R. §91.203 (A) (1) 

### Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). 

### Given the size and limited operating area associated with the aircraft to be utilized by Michael's Drone Photography, an exemptionfrom Part 21 SubpartHmeetsthe requirements ofan equivalentlevel ofsafetyunder Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 

### and Section 333 ofthe Reform Actboth authorize the FAAto exempt aircraft from therequirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, 10
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631and proximity to airports and populated areas ofthe particular UA. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAs to be operated hereunder is less than five (5) pounds (2.26796 Kg) fully loaded, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, and under the requirements and in compliance with local public safety requirements, to provide security for the area ofoperation as is now done with conventional aerial videography and photography. Lastly, application ofthese same criteria demonstrates that there is no credible threatto national security posed by the UAs, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (B). MARKING OF THE AIRCRAFT The regulationrequires: Whenmarks include only the Roman capital letter "N" andthe registration number is displayed on limited, restricted orlight-sport category aircraft orexperimental 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. Even though the UAs will have no airworthiness certificate, an exemption may be needed as theUAs will haveno entranceto the cabin, cockpitorpilot stationonwhichthe words "limited," "restricted," "light-sport," "experimental," or "provisional," may be placed. Given the size ofthe UAs, two-inch lettering will be impossible. The word "experimental," or any other term as is so required, will be placed onthe fuselage ofthe UAs in compliance with §45.29 

### (t). The equivalent level ofsafety will be provided by having the UAs marked on its fuselage as required by §45.29 

### (t) where the pilot, observer and others working with the UAs will see the identification ofthe UAs as "Experimental."The FAAhas issuedthe following exemptions to this regulation to ExemptionsNos. 10700, 8738, 10167 and 10167A. 14 C.F.R. § 61.113(A) & (B); 61.133(A): PRIVATE PILOT PRIVILEGES ANDLIMITATIONS; PILOT IN COMMAND; COMMERCIAL PILOT PRIVILEGES 11
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: {928) 897-2631AND LIMITATIONS: PILOT IN COMMAND Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UA in this case is remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft for compensation or hire. Michael's Drone Photography respectfully proposes that operator requirements should take into account the characteristics ofthe particularUA. Michael's Drone Photography's UAs have various built-intechnical capabilitiesthat strictlylimitthe potential for operation outside ofthe operating conditions set forth in the exemption application including a fly back to launchpointto terminate the flight. Since hobbyists are not required to have a pilot license, Michael's Drone Photographyrequests exemptionfor the need ofthepilotto be licensed as apilotby the FAA.

• Detection oflost GPS or ofinsufficient satellites initiates an immediate return to launch location. • Lowpower onthe aircraft triggers escalating alarms at 30% and 15% levels. • The aircraft weighs less than five (5) pounds (2.26796 Kg), fully loaded. Given these safety features, Michael's Drone Photography proposes that operators ofthe UAs should only be required to hold aprivate pilot's license and not a commercial pilot's license. Michael's Drone Photography notes that the FAA has found that safetyfactors permitted operation ofUAs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are present. Please see Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilotrequirements for commercial operations. Given these conditions and restrictions, an equivalent level ofsafety will be provided by allowing operation ofMichael'sDrone Photography's UAs without a commercial pilot's license, underthe conditions set forth herein. The risks associated with the operation ofMichael's Drone Photography's UAs (given its size, speed, operational capabilities, and lackofcombustible fuel) are so diminishedfrom the level ofrisk associated withprivate pilot operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations ofthe UAs as set forth above meets or exceeds the present level ofsafety provided under 14 C.P.R. § 61.113(a) &
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Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631(b) and does not rise to the level ofrequiring a commercial pilot to operate the aircraft under §61.133(a). Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAs will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PILOT operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate these small UAs. Unlike a conventional aircraftthat carriesthe pilot andpassengers, the UAs are remotely controlled withno livingthing onboard. The area ofoperationis controlled andrestricted, and all flights are planned and coordinated in advance. The level of safety provided by Michael's Drone Photography's exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe UAs are so diminished from the level ofrisk associatedwithcommercial operations contemplatedbyPart 61 when drafted, that allowing operations ofthe UAs as requested with aprivatepilot as the PILOT exceeds the present level ofsafety achievedby 14 C.P.R. §61.113 (a) & (b). 14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemptionbe granted, no FAAregulatory standardwill existfor determining airworthiness. Given the size ofthe aircraft and the requirements for maintenance and use ofsafety check lists prior to each flight. 14 C.F.R. § 91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT Section 91.9 (b) (2) provides: No personmay operate 

## aU.S. registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAs, given their size and configuration has no ability or place to carry such a flight manual onthe aircraft, not only because there is no pilotonboard, butbecausethere is no room or capacity to carry such an item onthe aircraft.

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Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631The equivalent level of safety will be maintained by keeping at the ground control point where thepilot flying the UAs will have immediate access to it. The FAAhas issuedthe following exemptions to this regulation: Please see FAA Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,32827, and 10700. 

### 14 C.F.R. § 91.103: PREFLIGHTACTION Thisregulationrequires eachpilotincommandto take certainactionsbeforeflightto insure the safetyofflight. As FAAapprovedrotorcraftflight manuals will notbeprovidedforthe aircraft an exemptionwillbeneeded. Anequivalentlevel ofsafetywill beprovided. ThePILOTwilltake all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance databefore initiation offlight. 

### 14 C.F.R. §91.109: FLIGHT INSTRUCTION Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAs andremotelypilotedaircraft,bytheir designdo nothavefully functional dual controls. Flight control is accomplishedthroughtheuse ofa controlboxthatcommunicates withthe aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. Please see FAA Exemption Nos. 5778K & 9862A. The equivalent level ofsafety is provided as neither apilotnorpassengerswillbe carriedinthe aircraft andbythe size and speed ofthe aircraft. 

### 14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthehelicoptercomplieswithanyroute oraltitudesprescribedforhelicoptersbytheFAA. As this exemption is for UAs that are a helicopter and the exemptionrequests authority to operate at altitudes up to three hundred (300) feet AGL, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions, the UAs will never operate at higher than three hundred (300) feet AGL. It will however be operated in a restricted area with securityperimeter, wherebuildings andpeople will notbe exposedto operations withouttheirpreobtained consent.

14
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAs as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner(s), ortheir authorizedrepresentative(s), all affected individuals will be aware ofthe plannedflight operations. When one compares the flight operations proposed herein with aircraft orrotorcraft weighing far in excess ofthe less than five (5) pounds (2.26796 Kg) and the lack offlammable fuel, any risk associated with these proposed operations is far less than those presently presented with conventional aircraft operating at or below five hundred (500) feet AGL. In addition, the lowaltitude operations ofthe UAs will ensure separation between these small UAs operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 ALTIMETER SETTINGS This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UA may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight.

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS Section 91.151 (a) prohibits an individual from beginning "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 ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30minutes; or (2) Atnight, to fly afterthat for at least45 minutes." Michael's Drone Photography believes that an equivalent level of safety can be achieved by limiting flights to fifteen (15) minutes orthirtypercent (30%) ofbatterypowerwhicheverhappens first. This restriction wouldbe morethan adequate to returnthe UAsto theirplannedlanding zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203 (A) AND (B): CARRYING CIVIL AIRCRAFT CERTIFICATIONAND REGISTRATION The regulation provides inpertinentpart: 15
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within 

### itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No personmayoperate a civil aircraftunless the airworthiness certificaterequired 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. The UAs fully loaded weight is no greater than five (5) pounds (2.26796 Kg) and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them onthe UA. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UA will have immediate access to them to the extent they are applicable to the UA. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (A); 407 {A) (1); 409 (A) (2); 417(A) & (B): MAINTENANCE INSPECTIONS These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter

...," and others shall inspect ormaintainthe aircraft in compliance withPart 43. Giventhatthese section and Part43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to Michael's Drone Photography. Maintenance will be accomplished by the operatorpursuantto the flight manual and operatinghandboo. Anequivalentlevel ofsafety will be achieved because these small UAs are very limited in size and will carry a small payload and operate only in restricted areas for limitedperiods oftime. Ifmechanical issues arise the UAs may land immediately and will be operating from no higher than three-hundred (300) feet AGL. The operator will ensure that the UAs are in working order prior to initiating flight, perform requiredmaintenance, andkeep a log ofanymaintenance performed. Moreover, the operatoris the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. 16
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631

### ********* Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should itbe determined that publication is needed: Michael's Drone Photography seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle weighing less than fifty-five (55) pounds (25 Kg) inits operations. Approval ofexemptions allowing commercial operations ofUAs in the purposes outlined above (or similar operations) will enhance safety by reducing risk. Conventional aerial videography and photography operations, usingjet or piston power aircraft, operate at extremely lowaltitudesjustfeet from the objectbeingphotographed andoften inextremeproximitytopeople and structures; and present the risks associated with vehicles that weigh in the neighborhood of four thousand ( 4,000) pounds, carrying large amounts of jetA orotherfuel (one hundred and forty (140) gallons forjethelicopters). Suchaircraftmust fly to andfrom the site'slocation. Incontrast, a UA weighing less thanfive (5) pounds (2.26796 Kg) pounds andpoweredbybatteries eliminates virtually all ofthatrisk given the reduced mass and lack ofcombustible fuel carried onboard. The UA is carriedto the site ofthepurposes outlined above (or similar operations) and notflown to the site. The UA will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofsmall UAs, weighing less than five (5) pounds (2.26796 Kg), conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grantofthe exemptionsrequestedherein, including exemptingMichael'sDronePhotographyfrom therequirements ofPart21 and allowingcommercial operations. These lightweightaircraftoperate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. PRIVACY All flights will occur over private, controlled or approved property with the property owner's, ortheir authorizedrepresentative, prior consent andknowledge. The aerial videography andphotography will be ofstructures and property whose owner, or authorizedrepresentative, has consented to the aerial videography and photography or otherwise have agreed to be in the area
17
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: {928) 897-2631where aerial videography and photography will take place. The grant ofthis exemption request will provide improved safety in all operations. Satisfactionofthe criteriaprovidedin Section 333 oftheReformAct of2012- size, weight, speed, operating capabilities,proximityto airports andpopulated areas and operationwithinvisual line ofsight and national security-provide more than adequatejustificationfor the granting ofthe requested exemptions allowing commercial operation ofMichael's Drone Photography's UAs. SUMMARY OF MICHAEL'S DRONE PHOTOGRAPHY'S REQUEST FORAN FAA EXEMPTION 1. Michael's Drone Photography's UAs must weigh less than five (5) pounds (2.26796 Kg), including energy source(s) and equipment. Operations authorizedbythe grant ofan exemption are limited to the following aircraft: Michael's Drone Photography's UA aircraft variant, bearing serial #PH645210898 onward as additional UAs are utilized byMichael's Drone Photography provided the additional UAs are ofthe same or similar specifications as the UA bearing serial# PH645210898. Any proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 2. Michael'sDronePhotography'sUAsmaynotbeflown ataground speedexceeding thirty (30) knots. 3. Michael's Drone Photography's flights must be operated at an altitude ofno more than three hundred (300) feet above ground level (AGL), as indicated by the procedures. All altitudes reported to ATC must be in feet AGL. 4. Michael's Drone Photography's UAs must be operated within the VLOS ofthe PILOT at all times. This requires the PILOTto be able to use humanvisionunaided by any device other than corrective lenses. 5. All Michael's Drone Photography operations must utilize aVO. The VO may be used to satisfy the VLOS requirement as long as the PILOT always maintains VLOS capability. The VO and PILOT must be able to communicate verbally at all times. 6. Priorto each flight the PILOTmust inspectthe UAto ensure it is ina conditionfor safe flight. Ifthe inspectionreveals a conditionthataffectsthe safe operation ofthe UA,the aircraft is prohibited from operating until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight. A Ground Control Station, ifutilized, must be included
18
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 7. Any UA that has undergone maintenance or alterations that affect the UA's operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PILOT who conductsthe functional testflight mustmake an entryinthe UA's aircraft records ofthe flight.



### 8. Michael's Drone Photography must follow the manufacturer's UA aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified. At a minimum, requirements for the following may be included in protocols and controls to be established by Michael's Drone Photography:

a. Actuators/Servos; b. Transmission (single rotor); c. Powerplant (motors); d. Propellers; e. Electronic speed controller; f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control; 1. Ground control station (ifused); and 

### J. Any other components as determined by Michael's Drone Photography. 10. Prior to operations conducted for the purposes outlined above (or similar operations), the PILOT musthave accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum oftwenty-five (25) hours oftotal time as a UArotorcraft pilot (single blade ormulti-rotor) and atleastten (10)hours logged as aUApilotwithmulti-rotorUAwhichis similar to the UA to be utilized pursuant to this exemption. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-buildingflights must be conductedunder an exemptionto accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, allpersonsnotessentialfor flight operationsare considerednonparticipants, andthePILOT must operate the UAwith appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119.
19
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: {928) 897-263111. Prior to operations conducted for the purposes outlined above (or similar operations), the PILOT musthave accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51(b), a minimum offive (5) hours as a UA pilot operating the make and model ofUAs to be utilized for operations under the exemption and three (3) take-offs and three (3) landings in the preceding ninety (90) days.**Training~** proficiency, experience-building, and take-offand landing currency flights can be conducted under the grant ofexemptionto accomplish the required flight time and ninety (90) day currency. Duringtraining, proficiency, experience-building, and take-off and landing currency flights all persons not essential for flight operations are considered nonparticipants, and the PILOT must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 12. Michael's Drone Photography shall not permit the PILOT to operate the UAS for the purpose ofaerial videography or photography (or similar operations), unless the PILOT has demonstrated and logged inamannerconsistentwith 14 CFR61.51(b), the abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 13. The UA may not be operated directly over any person, except authorized and consenting personnel and persons, below an altitude that is hazardous to persons or property on the surface in the event ofa UA's failure or an emergency. 14. At all times, those persons must be essential to the purposes outlined above (or similar operations). Because these procedures are specific to participating persons, no further FSDO or aviation safety inspector approval is necessary for reductions to the distances specified in Michael's Drone Photography's manuals. 15. Michael's Drone Photography's flight operations must 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 UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PILOT has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does notpresent anundue hazard, and; 20
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631

### c. Operations nearer to the PILOT, VO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 16. Ifthe UAs lose communications or loses its GPS signal, the UAs must return to a pre-determined location within the securityperimeter and land orbe recovered. 17. The UAs must abortthe flight inthe event ofunpredictedobstacles oremergencies. 18. Each UA operation must be completed within fifteen (15) minutes flight time or with thirtypercent (30%) batterypowerremaining, whichever occurs first. 19. Michael's Drone Photography must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations underthis grant ofexemption. This COA will also require Michael's Drone Photographyto request aNotice to Airman (NOTAM) not more than seventy-two (72) hours in advance, but not less than fortyeight (48) hours priorto the operation. 20. All aircraft operated in accordance withthis exemptionmustbe identifiedby serial number, registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings mustbe as large as practicable. 21. Michael'sDrone Photographyhas developedprocedures to document and maintain a record of the UA's maintenance, preventative maintenance, alterations, status of replacement/overhaul componentparts, and the total time in service ofthe UAs. 22. Each UA operated under this exemptionmust comply with all manufacturer Safety Bulletins. 23. The preflight inspection section in Michael's Drone Photography's Confidential Protocols and Controls Exhibit includes the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered inthe relevant preflight inspection. 24. Before conducting operations, the radio frequency spectrumused for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 25. The documents required under 14 CFR §§ 91.9 and 91.203 mustbe available to the PILOT atthe Ground Control Station, ifutilized, ofthe UA at anytime the UAis operating. These 21
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631documents must be made available to the Administrator or any law enforcement official upon request. 26. Michael's Drone Photography's UAs must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 27. Michael'sDronePhotography'sUA operations maynotbe conducted duringnight, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 28. Michael's Drone Photography's UAs may notbe operated bythe PILOT from any moving device or vehicle. 29. Michael's Drone Photography's UAs may not be operated less than five-hundred (500) feet beloworlessthantwo-thousand (2,000) feet horizontally from a cloudorwhenvisibility is less than three (3) statute miles from the PILOT. 30. Michael's Drone Photography's UA may not operate in Class B, C, or D airspace without written approval from the FAA. TheUAmay not operate within five (5) nautical miles of the geographic centerofa non-towered airport as denoted ona currentFAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, andthe operation is conductedinaccordance with aNOT AM as requiredbytheMichael'sDronePhotography's COA. The letter ofagreement withthe airport managementmustbe made available to the Administrator upon request. 31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational areaas definedbytheapplicable COAmustbereportedtotheFAA's UA Integration Office (AFS-80) withintwenty-four (24) hours. Accidents mustbe reportedto the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 32. Michael's Drone Photography's UAs, the UA's PILOT, and the UA's operations must comply with all applicableparts of 14 CFRincluding, butnotlimitedto, parts 45, 47, 61, and 91. As mentioned above, the FAA has already granted a previous exemption which is essentially identical to the exemption being sought by Michael's Drone Photography in this petition for an exemption. Please see FAA ExemptionNo. 11138.
22
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631Therefore, Michael'sDronePhotographyrespectfullyrequeststheFAAgrantanexemption pursuant to its application as outlined above. Sincerely,

# ~N~~';~'\~~

-Dannette J. Myers,

### ~J

Manager Michael's Drone Photography, L.L.C.

23
Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 Phone: (928) 897-2631Index INDEX

........................................................................................................................2 

### vanced anu A1 s:lF1WAA::AND DRJVffiiNSfAUAllON

.................................................................. 3 A2 CDNRGUR'\llON AND RA'v1WARJ:'& s:lFlWAREUPGRADE

..................................... 3 ViA A3lJNKINGTHE-mANSV11TTERAND RBJ3Vffi

............................................................ 4 2013.03.22 Revision A4 Q-IANGNGTHECDNTffil MODEOFTHE11R'\NSV11Tlffi

......................................... 5 A511R'\NSV11TTERC'AUBR'\llON

................................................................................. 7 A6 MOUNTCl\IV1 ER'\AND C'AM ER'\ FR'\fvlE.

................................................................ 8 A71NTBJJGENTORJENTA110N CDN1ROL(IOC) FUGHT(WITH GPS &COMPASS MODULE)

.................................................................................................................................. 9 AS MAINTENANCE.

.................................................................................................... 11

I I 21

## A 1 Software and Driver Installation Make sure to use the**NAZA~M** assistant software of 2.0 version (or above 2.0) to c.:ury 0\J!**fuTnv.'o;·~~ ~1pgraaa**  and parameter configuration. DO NOT use the NAZA·M assistant software bellow 2.0 vers1<.:Hl

1.

2. 3. 4. Please download the driver IDJI Driver Installed and NAZA-M assistant software from the PHANTOM j page of DJI website (http://www.dji-innovations.comlproductslphantomldownloadsn. 

# I

Connect the PHANTOM and the PC via the USB cable, power on the PHANTOM system. I Run the IDJI Driver**lnstalle~.** and follow the instructions strictly to finish installation. 

# J

Run the assistant software Installer, and**~~~~~~ons strictly~~~~---** 



## A2 Configuration and Firmware& Software Upgrade

1. Power on your computer. Make sure the computer is**conne~~;~·;~~-;;~·;~~~7~~~e~;~t** time**~;::~ ~**  use. 2. Switch on the transmitter first, then power on the aircraft. Connect the aircraft to the PC with the 1 USB cable. DO NOT breakthe connection until configuration or upgrade is finished. 3. Please refer to the "Assembly &Configuration->Step3n section of NAZA·M Quick Start Guide to get the detail of assistant software usage. 4. Refer to the "Appendix-> Firmware & Assistant Software Upgrade" section of NAZA-M Quick Start Guide to get the detail of assistant software usage. 5. If Manual Mode is required, please select "Manual" from the drop down list of Basic->RC->Control Mode Switch in the assistant software. Refer to the "Flying Test-> Step 1 Control Mode Knowledge" section ofNAZA-M Quick Start Guide to get the detail about the Manual Mode.

3 I 

## A3 Linking the Transmitter and Receiver The linking of the transmitter to the receiver of the PHANTOM was carried out before they left the factory. If necessary you can link the transmitter to the receiver as follows, for example you replace the transmitter. The default receiver type is PPM.

DO NOr use the PHr\NTOM transrmtter**treceiv~1r)** wlth the third party remote control equipment.

Please remove the housing by referring to the section of AS Maintenance -> Remove the Housing. 2. Locate the receiver module according to the following figure. 3. After powering on the aircraft and the transmitter, if the LED indicator ofthe receiver on the control board is lit solid red. this means the receiver currently has no connection with any transmitter. 4. Press down the link button for more than two seconds until the LED indicator blinks, then release the button. Cl 5. Push the throttle stickto the lowest position and turn on the transmitter. Then ifthe LED indicator of fhe receiver turns off, the link between the transmitter and the receiver has succeeded. (Linking operation can be done only when the LED indicator ofthe transmitter changes to blinking red .)D

transmitter can 1 enter the linking mode, please check that the throttle stick lies in the lowest

u YOLI can use your RIC system normally only after the linking is done successfully.o

Receiver Module

LinK Buttc>nr>···-·--

41

## A4 Changing the Control Mode ofthe Transmitter You can changethe operation mode ofthetransmitter according to the following procedures if necessary( The operation mode of Mode1 and Mode2 are shown as below.) Make sure to carry out the A5 Transmitter Calibration, 1f U1e Cmwol**rvhxl~;~** of the T1lm::>n11t!er ::> ct<.:mgr:u Mode1: 1111 Throttle, it cannot hold the central position when released. ft11 Roll, it can return to the central position when released.**~** Pitch, it can return to the central position when released. IE) Yaw, it can return to the central position when released.

Model2: {gThrottle, it cannot hold the central position when released. 00 Roll, it can return to the central position when released. iml Pitch, it can return to the central position when released.**~Yaw,** it can return to the central position when released. 1. Remove the right Throttle Ratchet plate and the Ratchet Nut. Assemble the Ratchet Nut to the Nut Hole

Location, and fix the Throttle Ratchet onto the Ratchet Nut and the Screw Hole Location. Adjust the
screw height ofthe Throttle Supportto change the tension, so as to give you the required operating feel. 2. Remove the left Centering Unit and the Centering Spring. Assemble them to the corresponding position

ofthe Right part (Close to the middle location ofthe transmitter). Then adjust the height ofthe Adjusting Screw, so as to give you the required operating feel. (Note: Be careful not to excessively tension the spring when moving and fixing, to avoid damage.) 3. Exchange the connectors of Channel 2( AIN2) and Channel 3 (AIN3). (Note: Take care about the

connector direction.) D Mode2 NO. Name Screw Hole Location

Centering Unit Adjusting Screw

Ratchet Nut Throttle Ratchet

3rd Channel 2nd Channel Centering Spring Nut Hole Loc tion

s I The following figure shows the successful change oftransmitter mode to Mode 1. Mode1

61

## A5Transmitter Calibration If the control mode of the transmitter is changed or calibration has not been carried out for a long time, transmitter calibration is necessary.

Pitch( Mode1) /Throttle( Mode2j



## Yaw+t•

.**j~f~;E_,** Power**Switch---~--- ~~-"--·--·Control**  Mode SwJtch f {:)GPS 51 i**~:"i** A TTl \0\ ATTl "Joystick

Throttle( Mode11**/Pit~~(** Mode2)



### +.;• Roll

CL: Course Lock HL: Home Lock

1. Set the switch S2 at the OFF position, and the switch S1 at the GPS**position~** J 2. Push the Throttle stick to the top position, and push the Pitch stick to the top position. Keep the Pitch stick at the top position manually since it can return to the central position when released.O 3. Turn on the Power Switch ofthe transmitter, you should hear the indicator sound of**~oi-Di** Oi" from the transmitter repeatedly. Toggle the switch S2 to the CL position, you should hear an indicator sound of**~Di"** from the transmitter, in this case, the transmitter has entered the calibration mode. (During this period, the Throttle stick and the Pitch stick must be kept at the top position an the time.) 4. Release the Pitch stick and pull the Throttle stick to the central position. Toggle the switch S1 to the A TTl position; you should hear an indicator sound of uDi" from the transmitter. Then move all of the sticks throughout their complete range several times. After this, put the Throttle stick to the bottom position, and toggle the switch S2 to the HL position, you should hear an indicator sound of "Dr from the transmitter, in this case, the transmitter has been calibrated successfully.a

7 I 

## A6 Mount Camera and Camera Frame Please mount the Camera and Camera Frame if necessary. ( 1) Mount the Camera to the Camera Frame

( 2) Mount the Camera and Camera Frame to the aircraft MaKe sure to**ust~** the**de~iicated** cross screws of the type M3.0"6, since an over long screw wm puncture the battery l'ly**pf1Ssin~J** through the battery compartrwwt and coulcllead to explosion orfire.

J_,_ --.., ri\r.:; 1

s I

## A7 Intelligent Orientation Control {IOC) Flight [with GPS& compass module) Make sure to open the IOC function in the NAZA·M assistant software before using. Definition of Forward Direction: Quad -rotor will fly along this direction when you push the elevator stick. Graphic Description D-Nose direction**~Forward** direction • Home point

......... Over 10m from Home point BeforeYou Start Usually, the forward direction of a flying aircraft is the same as the nose direction. By using IOC, wherever the nose points, the forward direction has nothing to do with nose direction:
o In course lock flying, the forward direction isthe same as a recorded nose direction. See the following

figures (The red and blue arrows on the transmitter is corresponding to pitch and roll operations):**~.,..~ t,,~** **Lllft~,·J~** Usually o In home lock flying, the for.vard direction is the same as the direction from home point to aircraft. See the

following figures (The red and blue arrows on the transmitter is corresponding to pitch and roll operations): t**+-~fl,-** 

# 111(,.,./•

Uso.l!fy**-~orne-** point Method of Forward Direction & Home Point Recording Ifyou use the IOC function, please keep the Forward Direction of Course Lock Flying and the home point of Home Lock Flying in mind at anytime. There are two ways to record the forward direction and the home point:

Manually record method. Home Lock Flight Before takeoff, the current position of 30 secondsafter you power on the quad-rotor will be saved as home point when you

, quad-rotor.

SWitch the S2 between OFF and CL position quickly 3 to 5 times to record current nose direction as new forward direction after you power on the quad-rotor for 30s. push the throttle stick for the first time after 6 or more GPS satellites have been found.

. '.'
. " ,.. ' When 6 or more GPS satellites are found, you can toggle the S2 switch between CL and HL position quickly 3 to 5 times to record the current position of the quad-rotor as the new home point. (CL -> HL -> CL is one time.) 91 IOC Flying Test Realize an IOC flight by the following

During the STEP1: Record Course t Lock f£

Switch Rt:cmd kw'-''<l' Setting duection

Home Lock

Switch Record ;;:t.; t sw1tch S 1!O GPS or A TTl pos1t10n S:? to CL

Set switch S1 to GPS position and S2 to HL Setting home point ""'"'"'"""""'"""""'""-·"--"**··"-------~~"""'·--~e~~~~~,.~~~·** lOC FlY!NG NOTES I! I Set s\Vitch S2 Toggle switch S2 from to OFF position OFF to CL position 

# ,, '"··

## ...•

Set switch S2 Toggle switch S2 from to OFF position OFF to HL position**r~ED :;~link@** **~uick;; i;·;·cor~~~,~~;;;sfut**  LED will blink between@)andf> slowly to indicate the IOC mode only when MC is ready to fly in course lock or home lockmodes. o Home lock flying requires that 6 or more GPS satellites are found and the aircraft is further than 10m away from the home point. 0 Before you do the home lock flight, you have to fly the aircraft out ofthe 10m range around home point, and then flip the switch S2 to HL position to fly in home lockwhen all the requirements are met. Ifyou have already toggled the switch S2 to HL position when the aircraft is still in 10m range around home point, and this is the first time you are going to fly in home lock during the current flight, then if all the requirements are met, MC will change into home lock automatically when the aircraft flies out of the 1Om range around home point. When flying in Home Lock mode, if any of the following situations happen, then the system will quit Home Lock flying and automatically enter Course Lock flying. The aircraft will fly in Course Lock using the earlier foiWard direction. 1. The aircraft fly's within 10m range ofthe home point. 2. You toggle the control mode switch to the A TTl. Mode. 3. The GPS signal becomes bad (The GPS signal LED is blinking Red twice or three times). o When the aircraft is flying in home lock mode far away from you and the home point, please do not toggle the lOC switch many times quickly so as to avoid the change of home point without you intentionally knowing. i We suggest that you should know clearly whiCh fhght lock method you are gmng to fly, and you know 

## I the locked forward d1rect1on or home pmnt, before you sw1tch on IOC mode during the flight. 

# I' Cont1nuously spmnmg the a1rcratt 1n flight w1ll cause a yaw error. Jn this case, you can stop or slow L---**-~fll~**..**~~~g,** so as to**hav!!!~"~ght P!:;;rfo:;:r:;;m~an:;;c:.::•:..·** -------------' 101