Maksim V. Gudakov

7010 Mountain View Rd.

Taylors, SC 29687

(425) 387-7699

mgudakov@gmail.com

Dear Sir or Madam: 

This petition is being submitted on my behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Maksim V. Gudakov , a freelance videographer, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft 

System (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 Section 333. 

The requested exemption would permit Maksim V. Gudakov to pursue his commercial interests in 

providing services to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, 

Land Management/Surveying, and Special Events. Maksim Gudakov states that all sUAS flights will 

occur over private or controlled access property and will do so with the property owner's consent and 

knowledge and that only people who have consented or otherwise have agreed to be within the UAS’ 

radius during filming and photography applications.

Maksim Gudakov has demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 3 and 

Dji Inspire which will be used for all commercial and private purposes. Maksim Gudakov complies with 

local ordinances and laws regarding the operation of sUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Maksim Gudakov, am seeking the exemption because I am committed to complying with all of the rules, 

guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the 

manner that I have described, and for the purposes that I have described. Without the exemption request 

granted, I would be unable to safely and effectively run my business, and it is my intention to comply with 

the FAA and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and 

safety features, and similar petitions requests granted.

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 
14 C.F.R. 91.7(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 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 and the DJI Inspire 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 4 limitations in this exemption and the procedures 

outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. 

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. 5 

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 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. 6 

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 (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.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 

11109, 11112, and 11213
Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform due 

to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. 

Maksim Gudakov is petitioning for an exemption to operate a DJI Phantom 3 with a built-in stabilized HD camera 

and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the 

radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D 

airspace including a no-fly zone feature. 

The DJI Phantom 3 and well as the DJI Inspire also has a failsafe function that is triggered in the event 

communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will return to 

its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land 

manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that are 

`sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will ensure 

that the sUAS will "not create a hazard to users of the national airspace system or the public." 

• When flying the sUAS within three (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 operation 

will be 30 minutes. 

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the 

sUAS. 

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more 

than 200 feet above an elevated platform from which videography is planned. 

• Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator. 

• The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current FAA 

medical certificate. 

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and 

stabilized gimbal). 

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and 

horizontally. 

• Given the small size of the sUAS and the restricted sterile environment within which it will operate, True Cinema 

Entertainment’s operations adhere to the Reform Act's safety requirements.