January 5, 2016

Mark Mondello

2118 Foster Ave.

Ventura, Ca. 93001

Mobile: (714) 7944164

Email: Mark.Mondello@Verizon.net

Federal Aviation Administration:

I, Mark Mondello am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that I, Mark Mondello, owner and operator of 

small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below 

so that I, Mark Mondello may operate a small ultra-light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in accordance 

with FAA UAS Regulations & Policies.

We would like to formally submit for an exemption from the following Section 333 regulations: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a),

14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14

C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1)

and (2), 14 C.F.R. 91.417(a) and (b). to operate the multiple DJI products. This UAS will be 

equipped with a detachable camera and will be transported in proper storage. This proposed 
exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial 

videography/ photography as a service to the public/ business interests. 

As found in exemption No. 11138 (Trudeau), the FAA recently approved similar use of a DJI 

Phantom 2 UAS. The DJI products were selected because it has proven reliable flying capabilities 

managed by gyro stabilized flight, ground detection, GPS aided navigation, a compass, blinking 

LEDs, failsafe mode for returning home.

This will act to further safety protocols exclusive to lightweight UAS’s specific to video and

photography usage as I, Mark Mondello record flight data and other information gained through 

permitted flight operations to share with the FAA through any required FAA reports to assist with 

future protocol and safety regulations.

Specific section or sections of 14 CFR which we seek relief and the reason we seek relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the aircrafts to be utilized by

Mark Mondello, an exemption from Part 21 meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the reform Act. 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 conventional aircraft 

operating with an airworthiness certificate without restrictions and conditions proposed.

14 C.F.R. 45.23: Display of marks: general

The UA does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain 

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

dimensions smaller than the minimal lettering requirement.
14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a commercially 

certified pilot would not correlate to the airmanship skills necessary for similarly proposed operations 

in previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation is 

inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board 

this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

I, Mark Mondello will ensure that UAS do not operate any higher than 400 feet at ground level. I will 

not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper 

height analysis as to avoid collisions.

14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS. An equivalent level of safety will be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that we will fly are powered by electricity, using lithium polymer batteries that currently 

have a flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the 

batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, 

Mark Mondello however will always fly safely while having the manuals.

14 C.F.R. 91.405(a): Maintenance Required,
14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or

alteration,

14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. However I, Mark Mondello will perform preflight inspections of the 

UAS before each flight as outlined in the operating documents. I Mark Mondello will also follow 

manufacturer recommendations from said operating documents.

Public Interest

Aerial photography and videography as an available service to the public allows for a cheaper 

method to capturing imagery than its alternative. Its alternative being aircraft and helicopters. They

are expensive, create lots of noise, and are much more threatening due to size and combustible fuel.

I, Mark Mondello would gladly offer my services upon request and with proper coordination to any 

official search and rescue or emergency services organization to benefit the public.

Also as mentioned in the Trudeau exemption, exemption No.11138:

““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are 

operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or 

more of fuel. The petitioner’s [UAS] weighs less than 3 lbs. The pilot and crew will be remotely 

located from the aircraft. The limited weight reduces the potential for harm to persons or damage to 

property in the event of an incident or accident. The risk of an onboard pilot and crew during an 

incident or accident is eliminated with the use of a [sUAS] for the proposed operation.”

Summary

I, Mark Mondello am seeking exemption from the following rules:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R.
91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R.

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and

(2), 14 C.F.R. 91.417(a) and (b)

With the exemptions of the mentioned rules I, Mark Mondello will be seeking to make

Our drone photography/videography services available to the public. 

By not using combustible fuel, flying at safe heights and strictly following the usage 

recommendations from DJI.

These include but are not limited to:

● Flying the following UAS Safely

● DJI Products

● Flying below 400 feet

● Proper visual inspection of UAS before flights

● Keeping mentioned UAS in visual sight at all times when in operation

● Using an observer to assist if needed

● Remain well clear of and do not interfere with manned aircraft operations, and avoid other aircraft 

and obstacles at all times

● Not intentionally fly over unprotected persons or moving vehicles

● Contact the airport or control tower before flying within 5 miles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensure the operating environment is safe

● Not flying over sensitive infrastructure or property such as power stations, water treatment 

facilities, correctional facilities, etc.

● Check and follow all local laws and ordinances before flying over private property
● Do not conduct surveillance or photograph persons in areas where there is an expectation of 

privacy without the individual's permission.

Respectfully,

Mark Mondello

2118 Foster Ave.

Ventura, Ca. 93001

Mobile: (714) 7944164

Email: Mark.Mondello@Verizon.net