CAVU AEROMEDIA, INC. 

5847 La Gorce Circle 

Lake Worth, FL 33463 

561-880-5381 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

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

and 14 C.F.R. Part 11, CAVU AEROMEDIA, INC., an operator of Small Unmanned Aircraft 

Systems ("sUAS"), hereby applies for an exemption from the Federal Aviation Regulations 

("FARs"), identified below, to allow commercial operation of sUAS. 

The proposed operations include aerial photography and videography for:

• Real Estate and Yacht Sales,

• Advertising

• Land Survey

• Tower Inspection

• Motion Picture and Television

As described below, the requested exemption would permit the operation of small UAS under 

controlled conditions. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation's (the FAA Administrator's) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 

Section 333(c) of the Reform Act. 

 
The name and address of the applicant is: 

 Name: CAVU AeroMedia, Inc. 

 Attn: Mark Mangold 

 Email: mmangold@cavuaeromedia.com 

 Address: 5847 La Gorce Circle 

 Lake Worth, FL 33463 

 Phone: 561-880-5381 

Regulations from which the exemption is requested: 

21, Subpart H 

61.113(a) & (b) 

91.103 

91.119(c) 

91.121 

91.151(a) 

91.203(a) & (b) 

91.405(a) 

91.407(a)(1) 

91.409 (a)(1) & (2) 

91.417(a)&(b) 

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 rule-making 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 UAS's size' weight, speed and operational capability 

• Operation of the UAS in the close proximity to airports and populated areas 

• Operation of the UAS within visual line of sight of the 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." I d. §333(c). 

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, and UASs 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) ofthis 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). 

Such operations will insure that the UAS will not create a hazard to users of the national 

airspace system or the public. Given the small size of CAVU AEROMEDIA, INC. UASs and the 

environment within which they will operate, CAVU AEROMEDIA, INC. UAS operations adhere to 

the Reform Act's safety requirements. Additionally, approval of this application presents no 

national security issues. Based on the substantial level of safety surrounding the proposed 

operations, and the significant public benefit (enhanced safety), reduction in environmental 

impacts (reduced emissions and noise), the grant of the requested exemption is in the public 

interest. Accordingly, CAVU AEROMEDIA, INC. respectfully requests that the FAA grant the 

requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The following UASs are submitted for exemption from the regulations above for operations of 

CAVU AEROMEDIA, INC. 

• DJI Phantom 3 

• DJI Inspire 1 

Both the Phantom 3 and the Inspire 1 are highly successful consumer grade UAS Quadcopters 

designed to carry a high definition (HD) camera powered by four electric motors. It utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is controlled 

primarily through an FCC certified radio control (RC) unit. Real time video and telemetry 

information is transmitted back to a ground control station allowing the operator and/or PIC to 
monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, 

and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. 

Altitude can be limited by the on board flight controller system and maximum altitude can be 

preprogrammed by the PIC. The flight controller/tablet will warn the pilot via telemetry and 

external lighting cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state. 

All UAS operations conducted by CAVU AEROMEDIA, INC.will: 

• Weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). 

• Operate at speeds of no more than 50 knots, can hover, and can simultaneously move 

vertically and horizontally. 

• Only operate its UAS in line of sight of the operator (PIC). 

• Limit each operational flight to 30 minutes or less. Flights will be terminated at 25% battery 

power reserve should that occur prior to the 30 minute limit. 

• Operated at an altitude of no more than 400 feet AGL. 

• Be operated by a FAA licensed airman with at least a private pilot's certificate and third 

class medical. 

• Be operated at a lateral distance of at least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not 

signed a waiver in advance of the operation. 

• The UAS will only operate within a confined "Sterile Area" of the flight operations area. 

• Have the capability to return to a pre-determined location if the UAS loses communications 

or loses its GPS signal. 

• PIC will commence flight operations only after completing a thorough preflight inspection of 

the UAS in accordance with UAS operator manuals specific to the UAS. 

• Have the ability to communicate if needed by Radio or Phone. Operators (PIC) during all 

UAS operation have the local Flight Standards District Offices (FSDO) and the closest 

airport control towers phone number and frequency. 

• Observer and PIC will at all times be able to communicate by voice. 

DISCUSSION OF EXCEPTIONS REQUESTED 

14 C.F.R. § 21, Subpart H: Airworthiness Certificates 

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 the Sky Eye, 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, 

and proximity to airports and populated areas of the particular UAS. Our small UAS will be 

operated at low speed in a controlled environment, at least five miles from an airport and more 

than three miles from any city or densely populated area. An analysis of these criteria 

demonstrates that the UAS 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 helicopter) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, pursuant to the Manual's 

requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is currently done on active 

construction sites. The FAA will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with 

motion picture and television production, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. 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 ability 

to carry a substantial external load. 

14 C.F.R. § 61.113{a) and (b): Private Pilot Privileges and limitations: Pilot in Command

 Sections 61.113 (a) and {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 PIC operating the 
 aircraft to have a private pilot's license rather than a commercial pilot's license to 

 operate a small UAS. 

Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based 

Operator. The operational area is controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety exceeds that provided by a single individual holding 

a commercial pilot's certificate operating a conventional aircraft. The risks associated with the 

use of a UAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 allowing UAS use by a private pilot as the PIC exceeds the present 

level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the 

 safety of flight. 

As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, including 

reviewing weather, flight battery requirements, Notices to Airmen (NOT AM), landing and takeoff 

distances, and aircraft performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, 

in pertinent part, that: 

 " ... except when necessary for takeoff or landing, no person may operate an aircraft 

 below the following altitudes: ..... 

 (b) Over other than congested areas. An altitude of 500 feet above the surface, 

 except over open water or sparsely populated areas. In those cases, the aircraft 

 may not be operated closer than 500 feet to any person, vessel, vehicle, or 

 structure." 

Because CAVU AEROMEDIA, INC. requests authority to operate at altitudes only up to 400 

AGL, an exemption is needed to allow such operations. 

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 UAS 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, 

pursuant to the safety check list and live flight data monitoring, 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 far at least 

 30 minutes; or (2} At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 

30 minute reserve requirement in 14 CFR §91.151, sUASflights would be limiting factor. Given 

the limitations on the UAS on exemption may be needed. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

 The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate o 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 weigh is no more than 55 lbs and is operated without an on board pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the UASs. An equivalent level of safety will be achieved by keeping these documents at 
the ground control point where the controller (PIC) of the UAS will have immediate access to 

them, to the extent they are applicable to the UAS. 

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 the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook. An equivalent level of safety will be 

achieved because these UAS are very limited in size and will carry a small payload. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log book of any maintenance performed as 

well as track all flight hours. 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. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft 

Operations Manual. As provided in the Operations Manual, the operator will ensure that the 

UAS is in working order prior to initiating flight and perform required maintenance needed. 

SUMMARY FOR PUBLICATION 

CAVU AEROMEDIA, INC. seeks an exemption from the following rules: 

14 CFR 61.113(a) & (b); 91.103;91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 

(a)(1) and (2); 91.417(a) &(b). To operate commercially a small unmanned vehicle (55 lbs or 

less) 

To operate commercially small unmanned vehicle (55 lbs or less) in yacht photography, land 

surveying, real estate photography, motion picture and television industry and tower inspections. 

Approval of exemptions allowing UASs commercial operations in the areas list above will 
enhance safety by reducing risk. A UAS weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board traditional aircraft performing the same function. The UAS 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 conducted in the strict conditions outlined above, will provide an 

equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. 

These UASs operate at very slow speeds, close to the ground, 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 or controlled areas with the property owner's prior 

consent and knowledge. Filming will be only of people who have given their consent or 

otherwise have agreed to be in the area where filming will take place. Satisfaction of the criteria 

provided in Section 333 of the Reform Act of 2012 (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 to grant CAVU AEROMEDIA, INC. requested 

exemption. 

CAVU AEROMEDIA INC. seeks only relief from the regulations requested. Otherwise, all other 

rules of Federal Aviation Regulations will strictly adhered to including pilot currency and medical 

requirements as well as preflight planning. CAVU intends on conducting operations with Safety 

as our first priority. Our goal is to safely provide aerial photography and videography for real 

estate and yacht sales, advertising, land survey, tower inspection and motion picture 

and television industries while providing a low cost alternative to conventional aerial 

photography practices and lowering operational risks to the public.

If you have any questions or concerns, please feel free to contact me at 561-880-5381

Sincerely,

Mark Mangold

CAVU AeroMedia, Inc.