July 9, 2015

Exemption No. 11998

Regulatory Docket No. FAA–2015-0331

Mr. Michael Joseph Indovina VI

Mike Six Imaging 

8000 West Manchester Ave. #222

Playa Del Rey, CA 90293

Dear Mr. Indovina:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 31, 2015 you petitioned the Federal Aviation Administration (FAA) on 

behalf of Mike Six Imaging (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct commercial 

real estate and venue photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

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

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot 680 Pro hexa-copter.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mike Six Imaging is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Mike Six Imaging is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Tarot 680 hexacopter when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

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

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. 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 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All 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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

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

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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 UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Indovina 1

To	Whom	It	May	Concern:

I	am	a	Los	Angeles	native, active	Airline	Transport	Pilot,	CFI	and	aerial	

photographer	operating	under Mike	Six	Imaging.		This	letter	is	written	to	request	for	

an	exemption	to	Section	333	for	UAS	drone	filming	for	commercial	gain with	the	

intent	to	comply	with	all	existing	and	future	FAA	Regulations	under	the	National	

Airspace	System.

For	nearly	the	last	eight	years	I	have	flown as	a	full	time commercial	pilot	in	traffic	

watch,	flight	instruction and	part-135	on-demand	charter	operations and	operated	

Mike	Six	Aerial	Imaging	photography	business	and	hobby	on	the	side.		In	recent	

word	of	the	proposed	laws	regarding	UAS	drones	I	began	to	decide this	would	be	a	

perfect	addition	to	my	work,	given	my	training, extensive	knowledge	and	

background	in	this	area.	 Having flown	both	remotely	controlled	and	fixed	wing	

aircraft at	a	young	age gives me	a	strong	and	stable foundation	in	this industry	as	

my	performance	has	continued	to	develope	into	an	instinct.		Working in	the	system	

for	the	past	decade	in	combination with my	knowledge	of	the	airspace,	regulations

and	procedures	I feel that	I	would	be	an	ideal	candidate	and pilot	in	the	eyes	of	the	

FAA with UAS	drone	operations.			I	have	proven	myself	true	in	my	flight	career	to	

date,	I	have	logged	more	than	4,500	hours	total	time	and	hold	a	jet	PIC	rating,	with	

not	one	violation	of	regulations	or any incidents.

These recent	changes	for	usage	of	remotely	controlled	devices	for	film	and	

photography	create	an	advantage	to	many, including	myself,	who have	the	

background	in	remotely	controlled	aircraft	operations	whom also	hold a	pilot’s	

license and	current	medical	certificate.		I	wish	to	support	the	growth	of	this	industry	

by	maintaining	and	complying	within a	strongly	structured	business	plan and	FAA	

approval	in	combining	my	efforts	with	you	as	the	system	continues	to grow.

Design:

My	UAS	system	is	comprised	of	lightweight,	exceptionally strong	foldable	carbon	

fiber	frame	with six	brushless	motors	with	the	capability	of	generating	over	19lbs	of	

lift.		Affixed	within	are	GPS,	magnetic	compass, and	barometric	altitude	sensors	with

a	3-axis gyroscope to	maintain	stability	and	remotely	controlled	via	a	radio	

transmitter.		Permanently	mounted	below as	payload,	center-ship is	a	Sony	Nex-5	

small and	lightweight DSLR	camera	fixed	on	a	3-axis,	self-righted	camera	gimbal,

with	a	total	combined	weight	of	less	than 2	pounds.		The UAS ships’ only	purpose	is	

to	be	used	in	still/motion	framed	filming,	compliant	within Line	of	Sight	control,	

flight	altitudes	well	below	400	feet	above	ground	level	with	a total	combined	flight	

weight	of 8	pounds	including its twin	batteries.		Its	flight speeds	are	flown	very	

slow,	much	below	mandated	speeds	of	50kts, and	has	four	fail-safe	modes:	one	for	

radio	failure,	one	for	GPS	failures	and	2	for	battery	low	conditions.		
Indovina 2

To	date,	I	have	kept	an	extensive	flight	log	including	maintenance	performance tests,	

removal,	repair	& preventative	maintenance	with return	to	service descriptions	and	

have	logged	over	5	hours of	flight	time.		

My	plan	is	to	offer	a	creative	twist	to	my	photography	business	with the	usage	of	my	

personally	assembled	drone	to	capture	shots,	reducing	the	traffic	load	on	the	NAS	by	

splitting	events	between	the	use	of	aircraft	and	my	drone.		My	photos	are intended

primarily for	commercial	real	estate	and/or	personally	invited	events,	and	would	

not	in	any	way	adversely	affect	or	jeopardize anyone’s	safety.		I	plan	to provide	the

level	of	safety	standards	equal	to	what’s	required	under	FAR	parts	61	and	91.		My	

system	was	designed	with	safety	and	professionalism	in	mind,	and	shows	

throughout my	work performance.

Developmental,	Operational	History and	Limitations:

August	2014	design,	plan	and	construction	were all	carefully	considered	when	

piecing	together	this	system.		The	choice	of	6	power-plant	motors	over	4	added	an	

extra	edge	and	added	protection	from the	unexpected	event	of a	sudden,	in-flight	

power	or	rotor-blade	failure.		The	Flight	Controller	is	manufactured	by	APM (3dr	

robotics) a	vastly	tested	and	trusted	company	in	the	industry,	which	contains	an	

internal, 3-axis	gyroscope	for	ship	leveling	and a	barometric	altitude	sensor	which	

offers altitude	hold	operations.		The	GPS	antenna	and	on-board	compass	module	can	

be	used	for	position	logging,	position	hold,	GPS	guided,	and	return	to	launch	and/or	

failsafe	operations.		The	flight	controller	also	transmits	pitch	&	roll,	airspeed,	

altitude,	magnetic	heading,	battery	voltage,	and	GPS	latitude	&	longitudinal data	to	

the	ground	station	for	an	added	level	of	control.		Fixed	opposite	of	each	other	to	

counter-balance each	others weight	are	2	lipo	batteries	that	provide	up	to 20	

minutes	of	flight	between	swapping,	and	are	wired	in	parallel	to	cover	the	event	of	a	

sudden	loss	of	current from	each	other.		Redundancy	was	at	the	forefront	of	mind in	

the	design.

Numerous	test flights	of	the	3	flight	modes:	GPS	lock,	Return	to	Launch,	Altitude	

Hold;	and	failsafe	operations: loss	of	radio	control	signal	or	low	battery	voltage	

triggering	either	landing or	a	return	to	the	launch	position	and land	were all	

meticulously	and	cautiously	executed at	a	safe	and	controlled	field.		Each	flight	

session	begins	with	an	extensive	preflight	inspection	of	all	power	plants,	propellers

and	frame	structure,	flight	mode	conditions,	flight	data	read-out	display	and	flown	

only	after	all	have	been deemed	satisfactory	for	flight,	pursuant	to	14	CFR	section	

91.7(b).		A	wireless	connection	to	a	base	station,	a	separately	powered	Apple	laptop	

running	APM	software	that	provides	a	up-to-the-second	active	display	of	the	flight	

mode,	flight	attitude,	ship	altitude and airspeed,	latitude	&	longitude	position	and	

battery	voltage.		All	maintenance	and	repairs	have, and	always	will	be, performed	by	

myself	with	compatible	and/or	identical	parts,	logged	and	tested	prior	to	any	

subsequent	flight.		Again,	safety	is	a	key	principle	value.
Indovina 3

Radio	control	is	accomplished	via	a	2.4	GHz,	pre-bound	(singular	bonded)	signal	

with	frequency	hopping	technology	to	prevent	signal	interference	or	interruption.	 A	

933MHz	signal	is	established	between	ground	control	unit	(laptop	&	APM	software)	

and	APM	controller, operated	as	an	optional	unit	for	the displayed	flight	

information.		All	of	the UAS	RF signals	are	FCC	compliant.

The	PIC	of	this	drone	is	myself,	Michael	Joseph	Indovina	VI,	and	is directly	

responsible	for	the	operation	of	this	UAS.		I	am	an	ATP	Pilot	with	over	4,500	flight	

hours	and	hold	a	first	class	medical	certificate.		With	this UAS,	I	have	currently	

logged	49 flights,	and	accumulated	more	than	5	flight	hours.	 Medical	standards	for	

the	pilot	would	be	such	that	mimic	regulations	for	flight	in	aircraft	under	FAR	parts

61 & 91.	

Flight	operations	would	include	myself,	a	camera	operator	and	a minimum	of	one	

flight	observer	to	aid	and	assist with flight operations.		Both	assistants	will	obtain	

qualifications	of	ground	instruction	and	a	satisfactory	demonstration	of	knowledge	

and	performance prior	to any service.		The	observer’s	primary	objective	will	be	to

notify	of	any	aircraft	in	the	proximity	to	cease	flight	activities,	and	most	importantly	

for	population	control	to	maintain	a	clear	area	in	the	flight	environment.		A	

quarantined	area	will	be	used	for	drone	departures	&	arrivals,	including	all	flight	

paths,	which	will	be	segregated	from	any	interference	as	an	added	safety	barrier.		

All	flight	operations	will	be	controlled	within	close proximity	of	the	UAS,	within	

visual	line-of-sight	(VLOS)	as	mandated	by	Section	333(b)(1).

Flight	times	are not	to	exceed	15 minutes or	operated	below	a	battery	voltage	of	

15.3, equating	to landing sooner	than	80%	of	the	total	available	capacity	and/or	

with	a	minimum	of	20%	battery	charge	(6	minutes	of	flight time	remaining as	a	

reserve.)		Flights	are	never	to	be	conducted	over	people	or	a	crowd,	and	operated at	

a	minimum	safe	altitude	over	objects	or	property	as	not	to	create	a	collision	hazard.		

Flight	altitudes	will	never	be	conducted	above	400	feet	Above	Ground	Level.		Speeds	

operated	will	be	very	slow if	not	stationary,	much	slower	than	already	limited	and	

approved	UAS	ships	at	50 knots.			Flights	will	be	conducted	daylight	conditions	

(sunrise	to	sunset.)		Operations	will	be	limited	to	wind conditions	at	or	below 15	

knots	of	velocity	and	will	at	all	times	maintain	clear	of	clouds.		Operations	in	visible	

moisture will	be	strictly	prohibited.		Any	flight	to	be	conducted	within	5	statute

miles	of	a	controlled	airport	will	require approval	from	the	controlling	agency	prior	

to	any	flight	operations.

Safety	Risks	and	Hazards:

As	with	any	aircraft,	the	primary	safety	risks	and	hazards	with	this	UAS	are	with the	

moving	propellers,	injury	from	falling	objects	and	a	fire	hazard	from	the	electronics.		

Contact	with	the	propeller	while	it	is	in	motion	could	cause	serious	injuries	and	

could	require	hospitalization.	 Camera,	sensors	and	other	objects	fixed	to	the	ship	

necessary	for	flight	will	be	permanently	mounted	by	metallic	screws	and	in	some	
Indovina 4

cases adhesive	tape	and	zip-tie	straps	to	prevent being	dislodged from	the	ship	and	

onto	persons	or	property below.		A	minimal	fire	hazard	could	arise	from	an	

unexpected	crash	and	contact	with	electrical	wire	or	components.		By	carrying	a	

class	AB&C	Halon	fire	extinguisher	and	a	first-aid	kit,	fire	and	injury	risks	could	be	

minimized	and	contained	should	these	events occur.		Flight	operations	would	be	

tailored	to	meet	the	need	to	prepare,	prevent	and	reduce the	risk	of	these	injuries or	

events for	each	flight	by maintaining	a	clear	and	unobstructed	area	below	the	ship	

while	it	is	in	flight.

In	Conclusion:

With	my	declaration of	purpose and	stated	limitations	within	this	document,	I	

submit	to	you	this formal request	for	a	written exemption	of	Section	333 for	Mike	

Six	Imaging.		In	the	event	that	this	letter	does	not	satisfy	the	requirements	for	an	

exemption	I	respectfully	request	any	information	or	correspondence	so	that	I	may	

provide	to	you	any	omitted	material.		Again,	it	is	with	my	utmost	desire	to	comply	

within	your authorization, any	and	all	limitations	placed	by	you to	minimize the

potential	risks,	hazards	and/or	unnecessary	congestion	to	the	National	Airspace	

System	where	applicable,	and	eliminate	any	imposed	threats	to	any	person	or	

property	to	the	uninvolved.		My longstanding	support in the	growing	aviation	

industry	will	continue	to	build	my	reputation	of safety,	performance	and	reliability	

in	the	face	of	the	FAA	and	the	public	for	the growing	NAS	structure	at	the	forefront	

of	today’s	technology	and	changing	times	with	my	operations.

Michael	Joseph	Indovina	VI

ATP	CFI	MEI		3146873

VI@mikesix.com

www.mikesix.com

8000	West	Manchester	Ave.	#222

Playa	Del	Rey,	CA	90293

805-455-9041