January 26, 2015 

Michale's Drone Photography, L.L.C. 

1850 Golden Gate Ave. 

Kingman, AZ 86401 

(928) 897-2631 

dronephotos@hotmail.com ; · .. 

U.S. Department of Transportation Docket 

Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the 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 of the 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 of a 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 of hours 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 

research being 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 amateur hobbyists with no safety plan or controls 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 

information gained through permitted flight operations which may be shared with the FAA through 

any required FAA reports to assist with the development of future FAA protocols and safety 

regulations. 

The use of Michael's Drone Photography's UAs for these purposes reduces the need to 

operate conventional aircraft, typically needed to perform these types of operations, 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 of aerial videography and photography, using Michael's 

Drone Photography's UAs, which will be operated under controlled conditions at an altitude of no 

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, if required by the FAA. As 

outlined below, the airspace in which Michael's Drone Photography's UAs will operate within will 

be disclosed to the FAA in advance to flight operation. Finally, Michael's Drone Photography's 

UAs will be used in lieu of comparatively hazardous operations now conducted with fixed wing 

and rotary conventional aircraft which should reassure the FAA that these operations will achieve 

at least an equivalent level or greater level of safety. 

In the interest of economic efficiency and public safety, Michael's Drone Photography 

hereby respectfully applies for an exemption from the listed F ARs to allow commercial operations 

of Michael's Drone Photography's UAs, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's ("Administrator") responsibilities under Section 333(c) of the 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) 897-2631 
As discussed above and more fully described below, the requested exemption would permit 

the operation of small, unmanned and relatively inexpensive UAs under controlled conditions in 

airspace that is limited and predetermined. Approval of this exemption would thereby enhance 

safety and fulfill the Administrator responsibilities to " ... establish requirements for the safe 

operation of such 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 

Exemption No. 11138. 

The name and address of the applicant is: 

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

1850 Golden Gate Ave. 

Kingman, AZ 86401 

(928) 897-2631 

REGULATIONS FROM WHICH THE 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) 

3 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to determine which types of UAs do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

• 

• 

• 

The UA's size, weight, speed, and operational capability; 

Operation of the UAs in close proximity to airports and populated areas; and 

Operation ofthe UAs within visual line of sight ("VLOS") ofthe operator . 

Reform Act§ 333 (a). 

Lastly, if the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system." Id. §333(c) (emphasis added). 1 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the 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 of a 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 ), equipment and any payload. They operate, under normal 

conditions at a ground speed of no more than thirty (30) knots and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. The UAs will operate only in line of 

sight and within safe. Such operations will insure that the UA will "not create a hazard to users 

of the national airspace system or the 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 of the UA, if it should be determined that the conditior,~s set forth herein do not fulfill 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) 897-2631 
Given the small size of the UAs involved and the restricted environment within which they 

will operate, Michael's Drone Photography falls squarely within that zone of safety (an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations ofUAs to commence immediately. Also due to the size of the UAs and the restricted 

areas in which the relevant UAs will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the 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 of the 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 law enforcement, for the services which are to be provided by Michael's Drone 

Photography. 

THE EXTENT AND BASIS OF THE RELIEF SOUGHT BY MICHAEL'S DRONE 

PHOTOGRAPHY 

Michael's Drone Photography submits this application in accordance with the Reform Act, 

112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating that presently 

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 in the public's interest to do so. Michael's Drone Photography's UAs meet 

the definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration 

of Michael's Drone Photography's ultralight weight UAs is expressly contemplated by the Reform 

Act. Michael's Drone Photography would like to operate its ultralight weight U As prior to the time 

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 of UAs that may operate safely in 

our national airspace system. These considerations include: weight, size, speed and overall 

capabilities of the UAs; whether the UAs will be operated near airports or heavily populated areas 

and; whether the UAs will be operated by line of sight.4 Each of these 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) 897-2631 
4 112 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 in place via GPS and operate in less than a 

24 knot (27 mph) wind. In order to increase safety plus stability and limit harm and financial loss 

of property, 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 

have three modes to choose from, Michael's Drone Photography utilizes the 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 descend to the point of takeoff. 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 and prepared to 

immediately abort and land the U A 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 

aircraft may approach the operating area of a Michael's Drone Photography UA. Michael's Drone 

Photography's UAs are capable of vertical and horizontal operations, and are flown only within 

my line of sight ofthe pilot. 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 of control or hazard. Fully charged reserve batteries 

are on hand with to insure replacement for a sufficiently safe level of operation. Michael's Drone 

Photography operates very conservatively and does believe in taking 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 of this specific UA's performance 

under different temperature and weather conditions. 

Michael's Drone Photography is extremely cautious when operating of its UAs and will 

not "create a hazard to users of the national airspace system or the public."6 Given the small size 

and weight of Michael's Drone Photography's UAs, they fall well within Congress's contemplated 

safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAs 

6 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
into 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 1 User 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 of manned fixed wing 

aircraft and helicopters. The challenge for smaller real estate companies and average landowners 

is that the expense related to manned videography and photography is cost prohibitive. Typically, 

only large businesses, large high end real estate companies and high net worth landowners are able 

to absorb such an enormous expense. This deprives non-luxury landowners and small revenue real 

estate companies from the enjoying the benefit of this valuable marketing and promotional tool. 

Manned aircraft pose a clear threat to the general public through potential catastrophic crashes that 

may occur. There are many documented events where a manned aircraft has crashed into populated 

areas with the size and combustibility of these manned aircraft causing large propetiy damage, 

human injuries and loss of life. Michael's Drone Photography's UAs pose no such threat since 

size and lack of combustible fuel alleviates any of these potential threat to the public. 

With the passage of the 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 

of the exemption request by Michael's Drone Photography furthers the public interest through 

academic and visual awareness of the geographical benefits of certain 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 harm the environment. In the unlikely event of a Michael's Drone Photography UA crash, 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) 897-2631 
Granting Michael's Drone Photography's exemption request substantially furthers the economic 

impact for any community and for companies looking to relocate or build in a certain community 

as well as individuals looking to relocate to a community for career advancement through academic 

and geographical awareness provided by Michael's Drone Photography. In the end, the granting 

of this exemption to Michael's Drone Photography will serve as a benefit and stimulus to any 

community. 

MICHAEL'S DRONE PHOTOGRAPHY'S EXEMPTION WILL NOT ADVERSELY 

AFFECT 

SAFETY AND WILL PROVIDE A LEVEL OF SAFETY AT 

LEAST EQUAL TO EXISTING FAA STANDARDS 

Michael's Drone Photography's exemption will not adversely affect safety, as it will in fact 

enhance safety. Michael's Drone Photography's ability to log significant, controlled and monitored 

flight time in FAA controlled airspace will allow Michael's Drone Photography to contribute to 

the innovation and implementation of new, 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 of enhancements to 

current aerial videography and photography: 

• Michael's Drone Photography's UAs weigh less than 5 pounds (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 ofbattery power; 

.Michael's Drone Photography's pilots operate the UAs through Visual Line of Sight only; 

• Michael's Drone Photography's UAs have a GPS flight safety feature whereby the UA 

hovers and then slowly lands if communication with the pilot is lost; 

2 National Association of Realtors, 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 prior to the operation its UAs and; 

• Michael's Drone Photography has established safety procedures in place to abort flights in 

the event of safety 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 of commercial 

UAs into our national airspace system, manned fixed wing airplanes and helicopters are the 

primary means of aerial videography and photography for community awareness and real estate 

uses. While the safety record of such helicopters is outstanding, there have been incidents involving 

loss of life as well as extensive property damage due to crashes of these manned aircraft and it is 

far safer and less expensive to operate a battery powered Michael's Drone Photography's ultralight 

UAs to accomplish the same task. The potential for loss of life 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 EQUIVALENT LEVEL 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 of safety to operations under the 

current regulatory structure because the proposed operations represent a safety enhancement to the 

operations conducted with conventional aircraft. The FAA has noted in past exemptions that 

"Conventional aerial video operations, using jet or piston-powered aircraft present risks associated 

with aircraft that weigh in the neighborhood of 5,000 to 7,000 pounds or more, carry large 

quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and from the 

survey location. Please see FAA Exemption 11110. 

9 

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 prior to the fifteen (15) minute limit. 

3. Flights will be operated at an altitude of no more than three hundred (300) feet AGL. 

4. Minimum crew for each operation will consist ofthe UA Pilot and a Visual Observer 

("VO"). 

5. The UAs will only operate within a safe area. 

6. A briefing will be conducted with regard to the planned UA operations prior to flight 

operations. It will be mandatory that all personnel who will be performing duties 

with regard to the flight operations be present for this briefing. 

7. The Pilot and VO will have been trained 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. If the UA loses communications or loses its GPS signal, the UA will return to the 

launch site of the 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 of airworthiness 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 exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for 

an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

10 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
and proximity to airports and populated areas of the 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 or rotorcraft) 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 nor passenger, 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 of operation as is now done with conventional aerial videography and photography. Lastly, 

application of these same criteria demonstrates that there is no credible threat to 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 regulation requires: 

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. 

Even though the UAs will have no airworthiness certificate, an exemption may be needed 

as the U As will have no entrance to the cabin, cockpit or pilot station on which the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," may be placed. Given the size of the 

UAs, two-inch lettering will be impossible. The word "experimental," or any other term as is so 

required, will be placed on the fuselage of the UAs in compliance with §45.29 (t). 

The equivalent level of safety 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 of the UAs as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 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) 897-2631 
AND 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 of the particular UA. Michael's Drone 

Photography's UAs have various built-in technical capabilities that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application including a 

fly back to launch point to terminate the flight. Since hobbyists are not required to have a pilot 

license, Michael's Drone Photography requests exemption for the need of the pilot to be licensed 

as a pilot by the FAA. 

• Detection of lost GPS or of insufficient satellites initiates an immediate return to launch 

location. 

• Low power on the 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 of the 

UAs should only be required to hold a private pilot's license and not a commercial pilot's license. 

Michael's Drone Photography notes that the FAA has found that safety factors permitted 

operation of UAs 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 pilot requirements for commercial operations. 

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of Michael's Drone Photography's UAs without a commercial pilot's license, 

under the conditions set forth herein. 

The risks associated with the operation of Michael's Drone Photography's UAs (given its 

size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level 

of risk associated with private pilot operations or commercial operations contemplated by Part 61 

with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAs as set 

forth above meets or exceeds the present level of safety provided under 14 C.P.R. § 61.113(a) & 

12 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
(b) and does not rise to the level of requiring 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 aircraft that carries the pilot and passengers, the UAs are remotely controlled with no 

living thing on board. The area of operation is controlled and restricted, 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 of the UAs are so diminished from 

the level of risk associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the UAs as requested with a private pilot as the PILOT exceeds the present 

level of safety achieved by 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 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given 

the size of the aircraft and the requirements for maintenance and use of safety 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 person may operate a U.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 on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. 

13 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
The equivalent level of safety will be maintained by keeping at the ground control point 

where the pilot flying the UAs will have immediate access to it. The FAA has issued the 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: PREFLIGHT ACTION 

This regulation requires each pilot in command to take certain actions before flight to insure 

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. An equivalent level of safety will be provided. The PILOT will take 

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

and aircraft performance data before initiation of flight. 

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 and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft 

via radio communications. The FAA has approved exemptions for flight training without fully 

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

Please see FAA Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided as 

neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. 

As this exemption is for UAs that are a helicopter and the exemption requests 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 

security perimeter, where buildings and people will not be exposed to operations without their preobtained consent. 

14 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
The equivalent level of safety will be achieved given the size, weight, speed of the UAs as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner(s), or their 

authorized representative(s), all affected individuals will be aware of the planned flight operations. 

When one compares the flight operations proposed herein with aircraft or rotorcraft weighing far 

in excess of the less than five ( 5) pounds (2.26796 Kg) and the lack of flammable 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 of the UAs will ensure separation between these small UAs operations and the 

operations of conventional 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 of the 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 of safety will 

be achieved by the operator, confirming the altitude of the launch site shown on the 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 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." 

Michael's Drone Photography believes that an equivalent level of safety can be achieved by 

limiting flights to fifteen (15) minutes or thirty percent (30%) of battery power whichever happens 

first. This restriction would be more than adequate to return the UAs to their planned landing 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 CERTIFICATION AND REGISTRATION 

The regulation provides in pertinent part: 

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 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. 

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 on the UA. 

An equivalent level of safety 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 of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Michael's Drone Photography. Maintenance will be accomplished 

by the operator pursuant to the flight manual and operating handboo. An equivalent level of safety 

will be achieved because these small U As are very limited in size and will carry a small payload 

and operate only in restricted areas for limited periods of time. If mechanical 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 

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

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 it be 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.R 45.23(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) in its operations. 

Approval of exemptions allowing commercial operations of UAs in the purposes outlined 

above (or similar operations) will enhance safety by reducing risk. Conventional aerial 

videography and photography operations, using jet or piston power aircraft, operate at extremely 

low altitudes just feet from the object being photographed and often in extreme proximity to people 

and structures; and present the risks associated with vehicles that weigh in the neighborhood of 

four thousand ( 4,000) pounds, carrying large amounts of jet A or other fuel (one hundred and forty 

(140) gallons for jet helicopters). Such aircraft must fly to and from the site's location. In contrast, 

a UA weighing less than five (5) pounds (2.26796 Kg) pounds and powered by batteries eliminates 

virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The 

UA is carried to the site ofthe purposes outlined above (or similar operations) and not flown 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 of small 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 

grant of the exemptions requested herein, including exempting Michael's Drone Photography from 

the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate 

at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than 

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, or their authorized representative, prior consent and knowledge. The aerial videography 

and photography will be of structures and property whose owner, or authorized representative, 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) 897-2631 
where aerial videography and photography will take place. The grant of this exemption request 

will provide improved safety in all operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012- size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual 

line of sight and national security- provide more than adequate justification for the granting of the 

requested exemptions allowing commercial operation of Michael's Drone Photography's UAs. 

SUMMARY OF MICHAEL'S DRONE PHOTOGRAPHY'S REQUEST FOR AN 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 authorized by the grant of an 

exemption are limited to the following aircraft: Michael's Drone Photography's UA aircraft 

variant, bearing serial #PH645210898 onward as additional UAs are utilized by Michael's Drone 

Photography provided the additional UAs are of the same or similar specifications as the UA 

bearing serial# PH645210898. Any proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant. 

2. Michael's Drone Photography's UAs may not be flown at a ground speed exceeding 

thirty (30) knots. 

3. Michael's Drone Photography's flights must be operated at an altitude of no 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 of the 

PILOT at all times. This requires the PILOT to be able to use human vision unaided 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. Prior to each flight the PILOT must inspect the UA to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 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, if utilized, must be included 

18 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
in 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 of a flight critical component, must undergo a 

functional test flight. The PILOT who conducts the functional test flight must make an entry in the 

UA's aircraft records of the 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. Power plant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

1. Ground control station (if used); 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 must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51(b), a minimum of twenty-five (25) hours of total time as a UA rotorcraft pilot (single blade 

or multi-rotor) and at least ten (1 0) hours logged as a UA pilot with multi -rotor U A which is 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-building flights must be conducted under an exemption to accomplish 

the required flight cycles and flight time. During training, proficiency, and experience-building 

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. 

19 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: {928) 897-2631 
11. Prior to operations conducted for the purposes outlined above (or similar 

operations), the PILOT must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51(b), a minimum of five (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-off and landing 

currency flights can be conducted under the grant of exemption to accomplish the required flight 

time and ninety (90) day currency. During training, 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 of aerial videography or photography (or similar operations), unless the PILOT has 

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

the UAS in a manner consistent with 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 of a 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 of an 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 of the UA, flight operations must cease immediately and/or; 

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

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

and the PILOT has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue 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 security perimeter and land or be recovered. 

17. The UAs must abort the flight in the event ofunpredicted obstacles or emergencies. 

18. Each UA operation must be completed within fifteen (15) minutes flight time or 

with thirty percent (30%) battery power remaining, whichever occurs first. 

19. Michael's Drone Photography must obtain an Air Traffic Organization (ATO) 

issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this 

grant of exemption. This COA will also require Michael's Drone Photography to request a Notice 

to Airman (NOT AM) not more than seventy-two (72) hours in advance, but not less than fortyeight ( 48) hours prior to the operation. 

20. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

21. Michael's Drone Photography has developed procedures to document and maintain 

a record of the UA's maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAs. 

22. Each UA operated under this exemption must 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 in the 

relevant preflight inspection. 

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

control of the 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 must be available to the 

PILOT at the Ground Control Station, if utilized, of the UA at any time the UA is operating. These 

21 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
documents 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 of way 

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's Drone Photography's UA operations may not be conducted during night, 

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 not be operated by the PILOT from any 

moving device or vehicle. 

29. Michael's Drone Photography's UAs may not be operated less than five-hundred 

(500) feet below or less than two-thousand (2,000) feet horizontally from a cloud or when visibility 

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. The UA may not operate within five (5) nautical miles of 

the geographic center of a non-towered airport as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport's management is obtained, and the operation is 

conducted in accordance with a NOT AM as required by the Michael's Drone Photography's COA. 

The letter of agreement with the airport management must be made available to the Administrator 

upon request. 

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

boundaries of the operational area as defined by the applicable COA must be reported to the FAA's 

UA Integration Office (AFS-80) within twenty-four (24) hours. Accidents must be reported to 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 applicable parts of 14 CFR including, but not limited to, 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 Exemption No. 11138. 

22 

Michael's Drone Photography, 1850 Golden Gate Avenue, Kingman, Arizona 86401 

Phone: (928) 897-2631 
Therefore, Michael's Drone Photography respectfully requests the FAA grant an exemption 

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) 897-2631 
Index 

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 MOUNT Cl\IV1 ER'\ AND C'AM ER'\ FR'\fvl E. ................................................................ 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 break the 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 of NAZA-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 of the 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 stick to the lowest position and turn on the transmitter. Then if the 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 of the 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 of the Transmitter 

You can change the operation mode of the transmitter 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 of the Throttle Support to 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 

of the Right part (Close to the middle location of the transmitter). Then adjust the height of the 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 of transmitter mode to Mode 1. 

Mode1 

61 
A5 Transmitter 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\ A TTl 

"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 of the 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 

A 6 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 or fire. 

J_,_ --.., 

ri\r.:; 1 

s I 
A 7 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 

Before You 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 is the 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 

If you use the IOC function, please keep the Forward Direction of Course Lock Flying and the home point of 

Home Lock Flying in mind at any time. 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 seconds after 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 Fl Y!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 lock modes. 

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 of the 10m range around home 

point, and then flip the switch S2 to HL position to fly in home lock when all the requirements are 

met. If you 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 of the 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