July 16, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption request pursuant to Section 333 of the FM Reform Act and specified parts under 14 CFR, 

the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 {the "Reform Act") and 14 CFR 

Part 11, Kalamazoo Drone Imagery, LLC, an "operator" of Unmanned Aircraft Systems {"UAS") for aerial 

photography and videography, hereby applies for an exemption (see list of exemptions below) from the 

listed Federal Aviation Regulations {"FARs") to allow commercial operation of its UAS platforms in the 

National Airspace System ("NAS"). 

This application is submitted by: 

Company: Kalamazoo Drone Imagery, LLC 

Owner/ Operators: Joshua S. Iocca, Oavid Frew, Brian Austin 

Phone: 269·598·3300 

Address: 4021 E. Hillandale Or. 

Kalamazoo, M149008 

Email: kzoodroneimagery@gmail.com 

The following are the sections of 14 CFR from which we seek an exemption: 

14 C.F.R. 21 14 C.F.R. 91.9{b)(2) 14 C.F.R. 91.203 {a) and (b) 

14 C.F.R. 45.23(b) 14 C.F.R. 91.103 14 C.F .R. 91.205 

14 C.F.R. 61.113{a) and {b) 14 C.F.R. 91.119 14 C.F.R. 91.215 

14 C.F.R.61.133(a) and (b) 14 C.F.R. 91.121 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) 

14 C.F.R. 91.7(a) 14 C.F.R. 91.151(a) (2); 417(a) & {b) 

The extent of relief we seek and the reason w e seek the relief: 

Commercial operation of a small UAS, as described herein, which are equipped with camera{s) and 

sensors, would operate in the following manner: 

• Aerial photography and/or video for public and/or private use including real estate, architecture, 

land surveying, engineering and other related professional activities. 

• Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

• 

• 

• 

Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers. 

Aerial video/photography or providing live video feed to assist with search and rescue operations 

in cases of an emergency or natural disaster only when the local authorities or government has 

requested it by contract or donation. 
As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. 

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." 

How our request would benefit the public as a whole: 

Granting Kalamazoo Drone Imagery, LLC our request for exemption will allow for local services such as 

real estate and marketing, and will allow growth for the local economy. There is a shortage of certified 

individual(s) and companies that provide aerial photography and videos in the area, thus driving up the 

cost for such services- making it cost prohibited. The UAS platform for Kalamazoo Drone Imagery, LLC 

provides a safe and cost effective method for the local economy to showcase its greatest assets. 

Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule: 

The high standards and regards to safety of Kalamazoo Drone Imagery, LLC will provide the benchmark for 

local competition and will drive for safer options to a much-needed service in this geographical area. The 

selected UAS platform has many safety measures in place that will significantly lower the risk of safety 

related incidents- from the heightened operator awareness to the engineered safety features. 

The operating limitations proposed by Kalamazoo Drone Imagery, LLC provide for a higher level of safety 

because UAS operations further enhance safety of aerial photography operations over using conventional 

aircraft. 

These limitations and conditions to which Kalamazoo Drone Imagery, LLC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

Operator Awareness 

o Pre-flight Checklist 

• Ensure that you are using only genuine parts and that all parts are in mint 

condition. 

• Ensure the remote controller, Intelligent Flight Battery, and mobile device are 

fully charged. 

• Ensure that there is no foreign object stuck to the camera lens, t he micro-SD 

card has been inserted into 

• The camera, and the gimbal can rotate freely before powering it on. 

• Ensure the propellers are securely mounted on to the motors, and the motors 

can start and function normally. 

• Follow the on-screen instructions to calibrate the compass. 

• Ensure the DJI Pilot app and aircraft's firmware have been upgraded to the 

latest version. 

• Ensure that your flight area is outside the No-Fly Zones and flight conditions are 

suitable for flying the aircraft. 

• Be sure t hat you are NOT flying under the influence of alcohol, drugs or any 

substance that may impair your cognitive abilities. 

• Be familiar with the selected flight mode and understand all safety functions 

and warnings. 

Be sure to observe all local regulations, obtain appropriate authorizations, and 

understand the risks. 

o Fly the aircraft only within line of sight; p.ilot in command (PIC) and/or visual observer 

(VO) 

• The PIC and VO will be able to communicate by voice, radio, and/or text at all 

times. 
• 

o Respective airports will be contacted if operating within 5 miles of an airport to be 

granted permission to enter air space. 

o Submission to the controller's safety warnings and alarms. (Such as power warnings, 

calibration needs and connection errors) 

o Flights will be operated at an altitude of no more than 400ft. above ground level. 

o Under still air tbe maximum speed is no more than 3Smph with a cruising speed of 

25m ph. 

The DJI Phantom 3 Professional's Engineered Safety Features: (The following is from the Phantom 

3 Professional User Manual) 

o Maximum Speed of 35m ph 

o Weight of< 31bs. 

o Maximum flight altitude limit capability. 

o Maximum flight range limit capability. 

• If you fl y out of the limit, you can still control the Phantom 3, but cannot fly it 

any farther. If tl1e Phantom 3 flie s out of the max radius in Ready to Fly (nonGPS) mode, it will fly back within range automatically. 

• If the Phantom 3 fl ies out of Lhe max radius in Ready to Fly (non-GPS) mode, it 

will fl y back within range automatically. 

• The software prohibit<; flight in "no-fly zones" . Motors will not start and 

warning will notify pilot that take off is prohibited. 

o Return to Home (RTH) function - brings the aircraft to the last recorded home point. 

• Smart RTH - button on controller to bring aircraft horne 

• Low Battery RTH- the RTH fea ture is automatically triggered when the D.H 

Intelligent Flight Battery is depleted to a point that may affect the safe return of 

the aircraft. 

• Failsafe RTH - the RTH feature is automatically activated if the remote 

controller signal is lost for more than 3 seconds. 

o Vision Positioning System (VPS) 

• With the use of ultrasound and image data, the aircraft is able to maintain its 

current position. This will allow for the aircraft to hover in place more precisely 

where a GPS signal is not available. 

o DJI Intelligent Flight Battery Functions 

• Battery level display 

• Battery life display 

• DJI Phantom 3 Professional (same UAS as in Granted Exception No. 11911) 

o General Features 

• Ready to fly 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

3-axis camera stabilization 

Precision flight and stable hovering 

GPS/GLONASS positioning & auto return home 

Onscreen real-time flight parameters 

High Definition 4k Camera 

Camera tilt control 

Film straight down 

Supports Adobe DNG RAW 

Adobe lens profile support 

Camera parameter settings 

Album synchronization 

FAA no-fly zones locked out via installed software 

o Transmitter 

Operating Frequency: 2.400 GHz - 2.483 GHz 

• Communication Distance (open area): CE: 2000m; FCC: 2000m 

• Receiver Sensitivity (1%PER): -lOldBm +/- 2dBm 
• 

• 

• o Camera 

Transmitter Power: CE: 16dBm; FCC: 20dBm 

Working Voltage: 1.2A@ 7.4V 

Battery: 6000 mAh liPo 2s 

• Operating Environment Temperature: 0°( -40°( 

• Max Resolution: 4096 x 2162p @ 24/25fps 

• Sensor size: 1/2.3" 

• HD Recording: 4k p 24/25fps I 720p 60fps 

o DJI V ision App 

System Requirement of Mobile Device: iOS version 6.0 or above/ Android 

system version 4.0 or above 

• Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod 

Touch4, iPod Touch5; 

Given the specifications of the UAS platform, engineered safety features and operator awareness 

check list, the approval of this application presents no national security issues. Regarding the 

impact to the public and the safety protocols in-place, Kalamazoo Drone Imagery, LLC requests 

your approval with minimum delay. 

Explanations of Requested Exemptions 

• 14 C.F.R. 21: Certification Procedures for Products and Parts. 

o This regulation is designed for manned aircraft. It is not suitable for the UAS 

Platform of Kalamazoo Drone Imagery, LLC. This regulation is designed for 

manned aircraft. It is not suitable for off-the-shelf or production UAS. All parts 

come from the manufacturer. Substantive replacement pa rts (i.e. motors, 

propeller blades, radio transmitters, etc.) also come from the manufacturer or 

an authorized vendor with approved after-market components and will ensure 

correct equipment is used to replace substantive parts of the UAS craft. 

• 14 C.F.R. 45.23(b): Display of Marks; general. 

o Even though the UAS will have no airworthiness certificate, an exemption will 

be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the word "Experimental" can be placed. Given the size of the 

UAS, two-inch lettering will be impossible. The word "Experimental" will be 

placed on the fuselage in compliance with §45.29 (f). The equivalent level of 

safety will be provided by having the UAS marked on its fuselage as required by 

45.29 (f) where the pilot, observer and others working with the UAS wi ll see the 

identification of the UAS as "Experimental." 

• 14 C.F.R.61.113(a) and (b): Private pilot privileges and limitations: Pilot in command. 

o Kalamazoo Drone Imagery, LLC can achieve an equivalent level of safety as 

achieved by current regulations because our UAS does not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote 

control piloting skills. The risks attended to the operation of my UAS is far less 

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

61, et seq. Thus, allowing us to operate our UAS to meet and exceed current 

safety levels in relation to 14 C.F.R. 61.113 (a) & (b). 

• 14 C.F.R.61.133(a) and (b): Commercial pilot privileges and limitations. 

o Kalamazoo Drone Imagery, LLC can achieve an equivalent level of safety as 

achieved by current regulations because our small UAS does not carry any 

pilots or passengers. Further, while helpful, a pilot license will not ensure 

remote control piloting skills. The risks attended to the operation of my small 
UAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 C.F.R. 61, et seq. Thus, allowing us to operate our small UAS to meet and 

exceed current safety levels in relation to 14 C.F.R. 61.133 (a) & (b). 

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness. 

o The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will 

exist for determining airworthiness. 

o Given the size of the aircraft for maintenance and use of safety checklists prior 

to each flight an equivalent level of safety will be provided. 

• 14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

o The need to have an aircraft manual on board does not apply. UAS aircraft 

information manuals will be kept by the operator. 

• 14 C.F.R. 91.103: Preflight action. 

o This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals 

will not be provided for the aircraft an exemption will be needed. The PIC will 

take all actions as stated in the manufacturer FOM in the pre-flight inspection 

section, including but not limited to reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight. 

• 14 C.F.R. 91.119: Minimum Safe Altitudes. 

o Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 {d) allows helicopters to be operated at less than the minimums 

prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is 

for a UAS that is a helicopter and the exemption requests authority to operate 

at altitudes up to 400 AGL, or not more than 200 above an elevated platform 

from which filming is planned, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 

AGL with the exception that in circumstances where the UAS is used to survey 

or photograph a structure whose height exceeds 400 feet AGL, the UAS will not 

be operated more than 200 feet above the highest point on the structure. It 

will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their preobtained consent. 

• 14 C.F.R. 91.121: 

o 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. 
o 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 for at 

least 30 minutes ... " 

o The battery powering the OJI Phantom 3 Professional UAS provides 

approximately 20 minutes of powered flight. Operations would be impossible 

to conduct in order to meet the 30-minute reserve requirement in 14 CFR 

91.151. Given the limitations on the UAS's proposed flight area, its proposed 

flight time, and proposed operations within a predetermined location, 14 CFR 

91.151 is inapplicable. Furthermore, operating the UASs in a tightly controlled 

area where only people, property owners, and/or official representatives will 

be allowed, less than 30 minutes of reserve fuel does not endanger the type of 

risk that 91.151 was intended to address. 

o The owner/operator of Kalamazoo Drone Imagery, LLC affirms that safety can 

be achieved by limiting flights to end with a 25% battery reserve as indicated 

on the PIC's controller mounted monitor. This restriction would be more than 

adequate to return the UAS to its predetermined landing area. 

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

o The UAS fully loaded weighs 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 UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will have immediate access to them; to the 

extent they are applicable to the UAS. 

• 14 C.F.R. 91.205: Powered civil aircraft with standard category U.S. airworthiness 

certificates: Instrument and equipment requirements. 

o Section 91.205 pertains to cockpit instruments for manned aircraft occupied by 

at least one pilot. This is not applicable to UAS. However, to ensure an 

equivalent level of safety and information, transmitted telemetry will be sent 

to the PIC and displayed on a video screen indicating various parameters 

including, but not limited to, GPS altitude, GPS signal, battery power remaining, 

time in flight, UAS ground speed, etc. 

• 14 C.F.R. 91.215: ATC transponder and altitude reporting equipment and use. 

o The UAS craft will have insufficient useful load and power supply to operate a 

transponder. Furthermore, operations offered by the blanket COA will occur 

below ATC radar coverage. To ensure an equivalent level of safety, when 

operations exist near a public airport, the operator will notify the local airport 

or ATC facility to advise them of the operation. If operations exist in an area not 

covered by the blanket COA, then a specific COA for that operation will be 

obtained by the local FSDO and specific case-by-case coordination with ATC will 

be made for the UAS flight. 

• 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a} (2); 417(a) & (b): Maintenance Inspections. 

o 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. 
o Given that these section and Part 43 apply only to aircraft with an 

airwort hiness certificate, these sections will not apply to the applicants. 

Maintenance will be accomplished by the operator pursuant to the flight 

manual and operating handbook. An equivalent level of safety will be achieved 

because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period of time. 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 of any 

maintenance performed. Moreover, 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. 

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

inspections will be performed in accordance with the UAS Manufacturer's User 

Manual. As provided in the Flight Operating Manual, the operator will ensure 

that the UAS is in working order prior to initiating flight and perform required 

maintenance needed. 

In summary, Kalamazoo Drone Imagery, LLC seeks exemptions from the regulations stated above to 

commercially operate our small UAS in aerial photography, real estate operation, videography and other 

opportunities which may present itself. 

Granting Kalamazoo Drone Imagery, LLC's request for exemption will reduce current risk levels and 

thereby enhance safety. Our UAS aircraft does not contain potentially explosive fuel, is smaller, lighter 

and more maneuverable than conventional real estate video and photographic aircraft with much less 

flight time. Furthermore, we operate at lower altitudes and in controlled airspace eliminating potential 

public risk flying to and from established airfields. 

Sincerely, 

Joshua S. Iocca 

David ~ Frew 

Brian 

~AL Austin 

Kalamazoo Drone Imagery, LLC 

4021 E. Hillandale Dr. 

Kalamazoo, Ml 49008 

kzoodroneimagery@gmail.com 

269-598-3300