U.S. Department of Transportation, Docket Operations. 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

March 25th, 2015 

Re: Exemption Request Section 333 of the FAA Reform Act 

U.S. Department of Transportation, 

~- ---l-am-submitting-this-petition-on-my-own, or~-the-behalf-of-my-com~JaRy bodoGir~ema; 

LLC. without the aid of legal council. Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, LodoCinema, LLC 

which is owned and operated by Michael Hering, a sole proprietor, operating in the State 

of Colorado. LodoCinema, LLC who has been shooting video in the state for the last 8 

years and operating Small Unmanned Aircraft Systems for less than a year, wishes to 

apply for an exemption from the Federal Aviation Regulations (FAR) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the 

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

Section333. The requested exemption would permit LodoCinema, LLC to pursue its 

commercial interests in providing services to companies interested in aerial data that 

can only be captured by using newly developed sUAS in residential and public areas 

including but not limited to surveying, Real Estate aerial mapping, Agriculture crop 

assessment and growth patterns, Golf course management, Insurance company claim 

assessment, Special events, construction site and ecological-impact assessment 

----- -~bodoCir~ema, LLC asserts that-al!-sUAS-f!ights-that-will-occur-over-private-or-controlled 

access property will do so with the property owner's consent and knowledge and that 

only people who have consented or otherwise have agreed to be in the area wher~ 

flight activity is taking place. Additionally, I am a private pilot with 1 00 hours of flight time 

logged and am the sole operator of the sUAS we own and operate. Our observers will 

attend ground school to be taught the rules and regulation as they pertain to operating 

private aircraft under Visual Flight Rules (VFR) over civilian population areas as 

described and set fourth in the Aeronautical Information Manual. 

The substance of this request is essentially the same as that granted to Falcon Sky 

Cam Requlatorv Docket No. FAA-2014-0884 in that LodoCinema, LLC is enqaqed in 

aerial photography of land, buildings, and insurance claims, by using remote controlled 

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suA-=> to see tne conamon OT T1e1as, crops, ecoiogicai impact, and financiai iosses do to 

destruction by fire and other natural disasters, without the need to drive over or climb on 

the property being so assessed. LodoCinema, LLC has equipped each of our sUAS 

aircraft GoPro cameras for aerial photoQraphy includinQ video and still pictures and 

special lens adaptations to make them very accurate in the 3 D mapping activity. By 

doing so we have the ability to produce high-resolution photography of remote locations 

that would be difficult or dangerous to reach on foot. This would be especially 

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exemption request would permit us to operate lightweight, unmanned (remotely 

controlled in line of sight) sUAS's in tightly controlled and limited airspace. 

Predetermined, specifically marked areas of operation as well as Global Positioning 

•~~-~~-_§atellite (§PS) na~igatioo !!lC!PS ~bich incorgorate restricted,.noJty~_4_0fJ~_s__an<;t,,G.Qr)tcoJ:=- ~-~-­

zones of airports, will allow LodoCinema, LLC to operate within current safety 

parameters as well as the new ones being implemented. 

The Extent of Relief LodoCinema, LLC Seeks and Its Justification for Such Relief: 

Regulation from LodoCinema, LLC request exemption: 14 C.F.R. 61.113(a) and (b) 14 

C.F.R. 91. ?(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 

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Unmanned Aircraft System sUASs are seen as a better photographic platform to 

helicopters because these smaller devices are less expensive, they produce less noise, 

and they have much less environmental impact and are less likely to cause injury to the 

public and or property. 

I am petitioning for exemption to enable LodoCinema, LLC to operate IRIS+, systems, 

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has a built in capacity to limit the height it flies above the ground, to limit the radius of 

the distance it flies from the operator and to exclude it for Class 8, C, and D airspace 

including No Fly Restricted Zones. The IRSI also has the failsafe feature of the Naza-M 

autopilot system which means when the communication between the main controller 

~- -and-the trarismitte-(is -los( the IRIS- will return to the home starting point and 1~md-safefy:~ ~~ ,__ 

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below: 

• The petitioner will only operate its sUAS in line of sight of a pilot/observer and will 

operate at sites tnat are sumcient distance from popuiated areas witnin tne steriie area 

described in the FOPM. Such operations will insure that the sUAS will not create a 

hazard to users of the national airspace or the public. 

• When flyinQ sUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full scale aircraft. 

• Maximum flight time for each operational flight will be 30 minutes. 
• Flights will be terminated at 25% battery power reserve should that occur prior to the 

30 minute limit. 

• The sUAS will be programmed so it will not be operated at an altitude of no more than 

4oo feet AGL, and not more than 200 feet above a fixed platform from which 

operations are conducted. 

• The minimum crew for each operation will consist of the sUAS pilot and the Visual 

Observer. 

• The sUAS will weigh less than 55 pounds including its payload of camera and gimbal. 

• The sUAS will fly no more than 50 knots and can hover plus move horizontally and 

vertically. 

• Given the small size of the sUAS, and the restricted airspace within which it will 

operate, I believe our sUA~ oR_eration.s_wiiLc.QmpJy_wi.tb_bothJhe_spi~itand-tbe.rules.-:-:-:------ - ---- ---- - _ _... -· intended by the Reform Act safety requirements. 

I respectfully request exemption under Section 333 to enable LodoCinema, LLC to 

operate efficient, limited, lowrisk commercial sUAS operations for the activities stated, 

respecting at all times, the space and privacy of citizens and property as we keep our 

skies safe. 

Sincere!, 

Michael Hering 

LodoCinema, LLC 

450 w 14th ave 40243 

Denver, CO 80204 

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