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Private and Confidential

Yang Khang (MTK Studio), Maiden, North Carolina- Section 333 Exemption Petition

11-12-2005

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam, 

I, Yang Khang (MTK Studio), 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, Yang 

Khang (MTK Studio), an owner and operator of small unmanned aircraft, be exempted 

from the Federal Aviation Regulations (“FARs”) listed below, therefore I may operate my 

small ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated 

airspace by the Federal Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, Yang Khang (MTK Studio), will 

primarily use my professionally built DJI Inspire 1 and DJI S1000 UAS equipped with 

camera for the following applications: Closed-Set Film operations on Film and Television 

Productions, as well as Aerial Videography/Cinematography for safety enhance films 

and commercials; augmentation of real estate listing videos; and the creation of visual

and topography layout videos for search and rescue (SAR) missions for state and local 

agency’s education, agricultural inspections, building, and constructions zone 

inspections.

My, Yang Khang (MTK Studio)’s, exemption request would permit the operation of ultra 

lightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of 

community and government use videos, permissible within property boundaries for 

individual homeowners and within in tightly controlled, limited airspaces predetermined 

in areas away from the general public, airports, heliports and vehicular traffic. Currently, 

similar lightweight, remote controlled UAS's are legally operated by unmonitored 

amateur hobbyists with no safety plan or controls in place to prevent catastrophe. 

Furthermore, it is my intent to assist future FAA safety protocols and regulations 

exclusive to lightweight UAS's for specific video and photography usage by sharing 
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information with the FAA as I, Yang Khang (MTK Studio), record flight data and other 

pertinent information gained through permitted flight operations. 

In addition, granting my, Yang Khang (MTK Studio)’s, exemption request will comply 

with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only 

integrate UAS's into the national airspace system, but to “...establish requirements for 

the safe operation of such aircraft systems [UAS's] in the national airspace system” 

under Section 333(c) of the Reform Act specific to the use of UAS's for real 

estate/Realtor purposes, educational videos, Search and Rescue, land/trusts 

inspections, agricultural field monitoring, film/video productions, closed-set motion 

picture film operations and television, and structure inspections, to aid state and local 

agency’s. 

Further I, Yang Khang (MTK Studio), will conduct my operations in compliance with the 

protocols described herein or as otherwise established by the FAA. 

For the reasons stated below, I, Yang Khang (MTK Studio), respectfully 

request the grant of an exemption allowing me to operate ultra lightweight, remote 

controlled UAS’s to aid academic community awareness, to benefit/stimulate attraction 

to the metro Maiden/Hickory, North Carolina and to enhance personal and public video 

feeds. A grant that will ultimately allow UAS’s to play a more positive role in our local 

community by increasing employment opportunities, heightening security measures and 

decreasing government expenditures by reducing the need for heavier manned aircraft, 

containing costly, combustible fuel- a potential public hazard in and of itself. 

I. Contact Information:

Yang Khang

MTK Studio

Maiden, NC 28650

Business: (828) 469-8056

Cellular: (828) 358-9308

MTKSutdioofNC@yahoo.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which 

Yang Khang (MTK Studio) Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 
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III. The Extent of relief Yang Khang (MTK Studio) Seeks and the 

Reason He Seeks Such Relief: 

I, Yang Khang (MTK Studio) submit this application in accordance with the Reform Act, 

112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to 

prevent me, Yang Khang (MTK Studio), contemplated commercial cinematic, academic 

and other flight operations within the national airspace system. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public’s interest to do so. My, Yang Khang (MTK 

Studio)’s, ultra lightweight UAS meets the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of my ultra light weight UAS is 

expressly contemplated by the Reform Act. I would like to operate my ultra lightweight 

UAS prior to the time period by which the Reform Act requires the FAA to promulgate 

rules governing such craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all related UAS 

aerial video and photography. The Reform Act guides the Secretary in determining the 

types of UAS's that may operate safely in our national airspace system. Considerations 

include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS 

will be operated near airports or heavily populated areas; and, Whether the UAS will be 

operated by line of sight. 112 P.L. 95 § 333 (a). 

Each of these items reflect in favor of an exemption for me, Yang Khang (MTK Studio). 

My UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. My 

UAS’s are equipped with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Vertical speed indicator

6) Course deviation indicator

7) GPS location

8) Radio magnetic indicator 

9) Flight Path indicator

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTH (Return To Home) 

13) Auto landing technology. 

Each UAS weighing less than thirty (35) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without gimbal (a camera stabilizer). I, Yang Khang (MTK 

Studio), considers safety as foremost with each flight. My small unmanned aircraft is 

designed to hover in place, circle in a specific place or loiter via GPS and can be 
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operated in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of 

financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems 

include a GPS mode that allows my UAS to hover/circle in place or land when radio 

controls are released. 

With three (2) modes to choose from, I will fly with the modes safest to complete the 

videos for aerial videography/photography and have the ability to choose the safest, 

most reliable and stable mode to prevent accident and hazard. When pilot 

communication from the radio control is lost, UAS is designed slowly descend to point of 

takeoff and or to land at point of launch after ascending to a pre-set altitude to ensure 

the UAS will clear any obstacles that may be between the takeoff point and the current 

position of the UAS. This failsafe altitude will not be set more than 200ft and is 

determined before each flight. 

I, Yang Khang (MTK Studio), will not operate my UAS near airports, hospitals nor police 

heliports, and do not operate near areas where general public is within fifty to one 

hundred (50-100) yards depending on location, conditions and weather. I am constantly 

on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to 

land/abort immediately to the nearest and safest ground point should a manned aircraft 

approach my location or I suspect manned aircraft may approach near my location. My 

UAS’s are capable of vertical and horizontal operations, and is flown only within my line 

of sight, as the remote control pilot. My UAS's are also flown with a second operator who 

aids in watching for any obstacles, including manned aircraft, within the flight zone of the 

UAS. Utilizing battery power rather than combustible fuels, flights generally last between 

three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) feet. (3 

)Smart Mode includes, position hold, self-leveling, altitude command, GPS, return home 

feature, and safety control to return home or land in the event of communication 

interruption between RC transmitter and UAS.

I, Yang Khang (MTK Studio), utilize a fresh fully charged battery with each flight 

as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) 

minutes as tested. I do not operate my UAS at or below manufacturer recommend 

minimum charge levels for operation; preferring to remain well within a safe operating 

range to insure adequate communication between radio control and UAS to eliminate 

potential for crash, loss of control or hazard. Reserve batteries are at hand with each 

exercise to insure replacement for sufficient safe level of operation. I do not believe in 

taking risk that may cause a crash, which could create hazard to the 

public/property/manned aircraft, and have no desire to lose an investment. I have 

clocked numerous practice flights in remote areas as a hobbyist simulating flights for 

future commercial use to gain familiarization with the characteristics of this specific 

UAS's performance under different temperature and weather conditions. I also practice 

computerized simulated flights to maintain adequate skills and response reflex time. All 

for the sake of safety. 
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I, Yang Khang (MTK Studio), am extremely cautious when operating of my 

UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the 

national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and 

weight of my UAS it falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UAS's into the 

national airspace system. Yang Khang (MTK Studio)’s UAS, used in hobby flight, has a 

demonstrable safety record and does not pose any threat to the general public or 

national security. 

IV. How Yang Khang (MTK Studio)’s Request Will Benefit the 

Public As A Whole: Aerial videography for geographical awareness, education, search 

and rescue, land management, structure inspections and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. For 

small budget companies, average homeowners and property owners the expense of 

such aerial videography is cost prohibitive. Only large companies and high end Realtors 

or luxury homeowners can afford to absorb such expense; depriving non-luxury owners 

and lower budget companies from a valuable marketing tool. Manned aircraft pose a 

threat to the public through potential catastrophic crash that the Maiden/Hickory

community has experienced in the past with military aircraft, medical helicopters, and 

news helicopters crashes within the city of Maiden/Hickory, North Carolina. Each 

resulting in loss of life. 

Each with combustible fuel that exploded and burned on impact. Police helicopters have 

made emergency hard landings within city limits. My, Yang Khang (MTK Studio) 's, UAS 

poses no such threat since size and lack of combustible fuel alleviates any potential 

threat to the public. Congress has already proclaimed that it is in the public’s interest to 

integrate commercially flown UAS's into the national airspace system, hence the passing 

of the Reform Act. Granting my, Yang Khang (MTK Studio)’s, exemption request furthers 

the public interest through academic/visual awareness of the geographical benefits in 

and around the metro Maiden/Hickory area. My ultra light weight UAS is battery powered 

and creates no emissions that can harm the environment. The consequence of my ultra 

light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; 

which are heavy, contain combustible fuel and can cause catastrophic devastation to the 

public. The public’s interest is furthered by minimizing ecological and crash threat by 

permitting aerial video/photo capture through my battery operated ultra lightweight 

UAS's. Permitting me, Yang Khang (MTK Studio), to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially furthers 

the economic impact for the metro Maiden and surrounding community for companies 

looking to relocate or build around the Maiden metro area as well as individuals looking 

to relocate for career advancement through academic and geographical awareness. 

Both of which serve as a stimulus to the community. 

V. Reasons Why Yang Khang (MTK Studio)’s Exemption
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Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At 

Least Equal To Existing Rule: My, Yang Khang (MTK Studio)’s, exemption will not 

adversely affect safety. Quite the contrary, for the reasons stated permitting me, Yang 

Khang (MTK Studio), to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow me to contribute to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for Realtors, 

land and structured owners. For development in cooperation with the FAA. In addition I,

Yang Khang (MTK Studio), submit the following representations of enhancements to 

current aerial videography and photography: My UAS’s weigh less than ten (10) pounds 

complete with an integrated ultra-light weight camera; I operate my UAS below 300 feet 

(well within the 400 foot permissible ceiling set by the FAA Modernization and Reform 

Act of 2012); My UAS only operate for 3-30 minutes per flight; I land my UAS prior to 

manufacturer recommended minimum level of battery power; I pilot my UAS through 

remote control only by line of sight; and have live video feed for a secondary pilot to 

monitor video recording; I receive a live telemetry feed from my UAS during all flights 

which include remaining battery voltage, distance, altitude, and any anomalies that may 

occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz 

frequencies in accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz-5.875Ghz frequencies in accordance with 

CFR 47, Part 15.

My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it 

hovers or circles and then lands at the GPS takeoff point if communication with the 

remote control pilot is lost; I actively record and analyze flight data through the DJI 

Inspire 1 and DJI 1000 flight controller app to constantly update and enhance safety 

protocols; I only operate in reasonably safe environment that are strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas; I conduct 

extensive preflight inspections and protocol, during which safety carries primary 

importance; I always obtain all necessary permissions prior to operation; and, I have 

procedures in place to abort flights in the event of safety breaches or potential danger. 

My, Yang Khang (MTK Studio)’s safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of commercial 

UAS into our national airspace system, helicopters are the primary means of aerial video 

and photography for community awareness real estate, structured inspections, land 

management and search and rescue. While the safety record of such helicopters is 

remarkably astounding, there has been local incident involving loss of life as well as 

extensive property damage; it is far safer to operate a battery powered ultra lightweight 

UAS. First, the potential loss of life is diminished because UAS's carry no people on 

board and I only operate my UAS in specific areas away from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. Third, the small size and extreme maneuverability of my UAS allow 

me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its 
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small size and weight, even when close enough to capture amazing images, my UAS 

need not be so close to the objects they are focused on through the technology and use 

of post editing software allowing pan and zoom. Accordingly, my UAS has been 

experimentally operated for familiarization/competency and will continue to operate at 

and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). 

The size, weight and enclosed operational area of my, Yang Khang (MTK Studio), UAS 

permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration 

of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. My, Yang Khang (MTK Studio)’s, current and projected UAS's meet 

or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

manual delineating areas of where safety can be defined. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS 

“geofencing” 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining any such required certifications 

and registrations by me, Yang Khang (MTK Studio). 

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My UAS can be marked 

with the appropriate “N” number once this “N” number has been given.
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C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 

C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I,

Yang Khang (MTK Studio). The sUAS Pilot in Command must possess at least a sport 

pilot certificate and a driver's license. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot 

certificate as outlined in 14 C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe 

altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower 

altitudes in certain conditions. My UAS will never operate at an altitude greater than 

300fclose AGL; safely below the standard of 400 AGL. I, Yang Khang (MTK Studio), will 

however operate my UAS in safe areas away from public and traffic, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. Given 

the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of 

safety will be achieved.

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

Inspections.1, 2, Manual

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] 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. . . .”These 

Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Yang Khang (MTK Studio)'s, UAS. However, as a safety 

precaution I inspect my UAS before and after each flight. 

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 

91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of my UAS permits exemption from Part 21 because my,

Yang Khang (MTK Studio)’s, UAS meets an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the 

operation of an aircraft without an airworthiness certificate. As no such certificate will be 

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 
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equivalent level of safety will be achieved by maintaining a manual. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software 

updates and curative measures for any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. In summary, Yang Khang (MTK Studio) seeks an 

exemption from the following Regulations:14 C.F.R. 21, subpart H; 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. § 

91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 

91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to 

commercially operate my, Yang Khang (MTK Studio) 's, small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness, education, 

structural inspection land management, search and rescue and real estate operations, 

and to develop economic platforms for the aforementioned to enhance the experience of 

those seeking to relocate, rebuild, reevaluate and to find in the metro Maiden/Hickory, 

North Carolina area. 

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy 

source(s) and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operator's manual. All altitudes reported to ATC must be in feet AGL.

4. The UAS 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 state driver’s license.

5. All operations must utilize a visual observer (VO). 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.
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6. If a discrepancy exists between these limitations and any procedure outlined 

elsewhere in this operations manual, the conditions and limitations herein take 

precedence and must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition 

for safe flight. 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. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records.

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 in accordance with the 

operator's manual. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. When 

unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the 

operator's manual. At a minimum, the following must be included in the operator's 

manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Power plant (motors)

d. Propellers

e. Electronic speed 

controller 

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)
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j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at 

least a current state driver’s license. 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/her pilot certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent 

with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a 

UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS 

type (single blade or multirotor). Prior documented flight experience that was 

obtained in compliance with applicable regulations may satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under 

this grant of exemption to accomplish the required flight cycles and flight time. 

During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered non-participants, and the PIC must 

operate the UAS with appropriate distance from non-participants in accordance 

with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations under the exemption and three take-offs 

and three landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and landing currency flights can be conducted under this grant 

of exemption to accomplish the required flight time and 90 day currency. During 

training, proficiency, experience-building, and take-off and landing currency flights, all 

persons not essential for flight operations are considered non-participants, and the 

PIC must operate the UAS with appropriate distance from non-participants in 

accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and 

visual observer (VO) must have successfully completed a qualification process, as 

outlined in the operator’s manual. As this is a requirement stipulated by the operator, 
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the test must be developed and implemented by a qualified person designated at the 

sole discretion of the operator. A record of completion of this qualification process 

must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -

qualified pilot must be successfully completed and documented. This documentation 

must be available for review upon request by the Administrator. Because the 

knowledge and airmanship test qualifications have been developed by the operator, 

and there are no established practical test standards that support a jurisdictional FAA 

FSDO evaluation and approval of company designated examiners, the petitioner will 

conduct these tests in accordance with the operator’s manual.

15. The UAS may not be operated directly over any person, except authorized and 

consenting production personnel, below an altitude that is hazardous to persons or 

property on the surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has 

safety mitigations for authorized and consenting production personnel. At all times, 

those persons must be essential to the closed-set film operations. Because these 

procedures are specific to participating persons, no further FSDO or Aviation Safety 

Inspector (ASI) approval is necessary for reductions to the distances specified in the 

petitioner’s manuals. This is consistent with the manned aircraft procedures described 

in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and 

Television Filming.

17. Regarding distance from non-participating persons, the operator must ensure that 

no persons are allowed within 500 feet of the area except those consenting to be 

involved and necessary for the filming production. This provision may be reduced to 

no less than 200 feet if it would not adversely affect safety and the Administrator has 

approved it. For example, an equivalent level of safety may be determined by an 

aviation safety inspector’s evaluation of the filming production area to note terrain 

features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the 
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event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, 

S1.18. If the UAS loses communications or loses its GPS signal, the UA must return 

to a pre-determined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant 

of exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to 

the operation.

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. The operator must develop procedures to document and maintain a record of 

the UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures must be added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria 

must be added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to 

include the following requirement: The preflight inspection must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UAS must comply with the Federal Communications 
14

Commission (FCC) or other appropriate government oversight agency 

requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by 

this exemption must submit a written Plan of Activities to the local FSDO with 

jurisdiction over the area of proposed filming. The 3-day notification may be 

waived with the concurrence of the FSDO. The plan of activities must include at 

least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS 

filming production under this grant of exemption

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS.

d. Make, model and serial or N-number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the 

filming production event 

f. A statement that the operator has obtained permission from 

property owners and/or local officials to conduct the filming 

production event; the list of those who gave permission must be 

made available to the inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any 

area, city, town, county, and/or state over which filming will be 

conducted and the altitudes essential to accomplish the operation

29. The 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.

30. The UAS must remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultra light

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

31. 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.
15

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS 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.

34. The UAS may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UAS may not operate within 5 miles of the geographic center 

of a non-towered airport as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport’s management is obtained, and 

the operation is conducted in accordance with a NOTAM as required by the 

operator’s COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA must 

be reported to the Federal Aviation Administration’s (FAA) 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. Further flight operations may not be conducted until the 

incident, accident, or transgression is reviewed by AFS-80 and authorization to 

resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting 

my, Yang Khang (MTK Studio)’s, request for exemption will reduce current risk levels 

and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is 

smaller, lighter and more maneuverable than conventional video and photographic 

aircraft with much less flight time. Further, I operate at lower altitudes and in controlled 

airspace eliminating potential public risk flying to and from established airfields. I, Yang 

Khang (MTK Studio) have been informally analyzing and recording flight information and 

will compile safety protocols and the implementation of a flight operations manual for 

usage that exceeds currently accepted means and methods for safe flight. Formal 

collection of information shared with the FAA will enhance the FAA's internal efforts to 

establish protocols for complying with the FAA Modernization and Reform Act of 2012. 

There are no personnel on board my, Yang Khang (MTK Studio)’s, UAS and therefore 

the likelihood of death or serious bodily injury is significantly diminished. My, Yang 

Khang (MTK Studio)’s, operation of my UAS, weighing less than forty (40) pounds and 

traveling at lower speeds within limited areas low to the ground will provide an equivalent 

level of safety as that achieved under current FARs. Accordingly I, Yang Khang (MTK 

Studio), respectfully request that the FAA grant my exemption request and am willing to 
16

cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the 

general public at large. 

Respectfully submitted, 

Yang Khang

MTK Studio

Maiden, NC 28650
17

Appendix A

List of Aircraft

1. DJI Inspire 1

The operation of the DJI INSPIRE 1 system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The DJI INSPIRE ONE flight in a 4 motor quadcopter setup. ,

3. Payload 

I. The DJI INSPIRE ONE flies it’s own light-weight integrated camera. 

II. Maximum All-up weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of 

cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for 

signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. 

Replace as necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace 

as necessary. 

No. Make and Model Description of 

Aircraft

Serial No. Registration 

No.

1 DJI Inspire 1 Electric powered with 

4 rotors, Small 

unmanned Multirotor 

Helicopter

FCC: SS3-

WM6101410

Pending 

1 DJI S1000 Electric powered with 

8 rotors, Small 

unmanned Multirotor 

Helicopter

Pending
18

3. Remove flight controllers and visually inspect and check for damage. Replace as 

necessary and/or chips. Replace if propeller is questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and perform a 

minimum of 15 test flights before conducting commercial work.

Appendix B

2. DJI S1000

The operation of the DJI S1000 multirotor system are as follows (the flight controller 

operation manual is NOT explained in this manual but can be found in Appendix E, 

Section 1).

1. Build Materials

I. Carbon Fiber

II. ABS Plastic

III. Stainless Steel Hardware

2. Motor Configuration

I. S1000 configuration utilizing 8 motors (DJI 4114 Pro Motors in a octagon 

shape which is powered by the 8 DJI 40A motor controllers. The motors are 

configured with 1 motor per arm. We have tested this situation and can confirm it 

works as described.

II. In this configuration the DJI S1000 can handle up to four (2) motors failing and still be 

able to fly.

3. Payload 

I. The DJI S1000 will carry the Zenmuse Z15-5D III 3 axis camera gimbal. 

II. The cameras that will be flown on the DJI S1000 include, but are not limited to, 

Canon 5DMKII, 

III. Maximum All-up Weight- 34lbs

4. Maintaining the DJI 1000

I. Before each flight:

II. After 25 hours of flight

1. Check all hardware to ensure it is securely tightened.

2. Check that all motors are level and locked in place.

3. Check all propellers to ensure they are tight and there are no visible signs of cracks, 

stress, and/or chips. Replace if any propeller is questionable. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check all navigational lighting to ensure it is properly working.

6. Remove and check all motors and motor mounts for signs of wear and tear. Replace 

as necessary.
19

7. Remove motor controllers and visually inspect and check for damage. Replace as 

necessary.

8. Remove flight controllers and visually inspect and check for damage. Replace as 

necessary. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work. 

Appendix D 

Personal Protocols/Controls/Flight Manual 

Protocols and Controls 

Yang Khang (MTK Studio), Maiden, North Carolina

Safety for public on the ground as well as manned aircraft above is an essential and 

utmost consideration for aerial videos and photography. As such, safety protocols and 

controls must be implemented through pre‐flight preparation and during flight. 

Pre‐Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion 

or unmanageable/uncontrolled flight. 

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight 

paths of possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, 

estimated elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight 

impact Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewers optional point of control for best visual site of 

UAS while in flight 
20

Emergency landing areas 

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 

If in a subdivision or area that is within 150 feet of a residential street, post 

warning Sign(s)/stand(s) "Attention Aerial Photography In Progress ‐ Remain 

Back 150 Feet " 

Flight Protocol: takeoff and land from same location (have alternate landing areas in 

case of emergencies) remain alert to birds, sound or aircraft, curious public, and 

approaching vehicles do not allow anyone to engage in conversation or distract the 

remote control pilot restrict flight to minimal elevation sufficient to acquire desired results 

remained prepared for emergency landing at all times pay attention to flight time –

warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and 

shut down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. a) Disconnect battery to prevent accidental activation of propulsion system 

2. b) Secure UAS in a safe location 

c) Remove all warning signs from public access areas Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to 

observe flight Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of 

control
21

Safety for public on the ground as well as manned aircraft above is an essential and 

utmost consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Date:____________________ 

Location:___________________________________________________ 

Pre‐Flight Inspection: 

Circle one: Yes No 

Comment: _________________________________________________ 

Elements 

Proximity to airport: _________________ (see attached map pinpointing approximate 

location of flight) 

Airport notified: No Yes 

Date: _______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

________________________________________________________________ 

Proximity to medium traffic road: 

________________________________________________________________

Proximity to heavily traveled roadway road: 

________________________________________________________________ 

Proximity to congested population: 

________________________________________________________________ 

Approx. Takeoff Time: UTC Eastern Time: 

Weather: Good Fair Poor 
22

Visibility: Good Fair Poor 

Wind Speed __ _ _ mph ___ Gusts/MPH __ _Avg/MPH 

Comment: ______________________________________________________

Approx. Landing Time: UTC: ______________

Estimated Elevation Ground level: ____________

Safety Concerns: _________________________________________________

Additional Comments: _____________________________________________

_______________________________________________________________

_______________________________________________________________

Appendix 'D'

 Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, 

and illustrated parts catalogs. These manuals may be attached to the docket when 

submitted. Information regarding design, aircraft performance, fail-safe features, 

operating limitations, normal and emergency procedures, and maintenance and 

inspection procedures is contained within the manuals and supplemental information 

documents listed below:

1. DJI Inspire Manual V1.0

2. Inspire 1 Maintenance Manual v1.0

3. Intelligent Flight Battery Safety Guidelines v1.4

4. Inspire 1 Safety Guidelines

5. DJI S1000 Professional Manual V1.0

6. DJI S1000 Maintenance Manual

7. DJI S1000 Flight Battery Safety Guidelines

8. DJI S1000 Safety Guidelines

For more information or questions about this manual please contact:

Yang Khang

MTK Studio

Maiden, NC 28650

Business: (828) 469-8056

Cellular: (828) 358-9308

MTKSutdioofNC@yahoo.com