UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

1200 New Jersey Avenue, SE., Room W12-140,

West Building Ground Floor, 

WASHINGTON, DC 20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

MAURICE KEALOHA SALLAVE

GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer 

SOP Standard Operating Procedures

sUASs Small Unmanned Aircraft Systems

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing

The name and address of the applicant are:
Maurice Kealoha Sallave

8575 Independence Ave. #8, 

Canoga Park, Ca. 91304 

1(310)948-5871 

msallave@toastedmango.com

To whom it may concern: 

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

and 14 C.F.R. Part 11, Maurice Sallave, operator of Small Unmanned Aircraft Systems 

(“sUASs”) equipped to conduct aerial photography and videography, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 

of its sUASs, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) 

limited 2) predetermined and 3)controlled. The proposed exemption, if granted, would allow 

Maurice Sallave to conduct commercial operations of sUASs meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333.

Maurice Sallave is currently obtaining a business that includes aerial film and photography for 

the business name Toasted Mango Media. The objective of Toasted Mango Media will be to 

provide services that aims focus around aerial site inspections, land surveying, agricultural, 

advertising, and marketing. Mr. Sallave, who resides in Canoga Park, Ca. has been in the rc 

community for the past 7 years and is also a skilled web developer/designer/videographer for 

the past 12 years. Before working as a web developer he was working for the coin-operated 

industry assembling vending, arcade, and bill changing machines that required an analytical and 

mechanical skillset.

Maurice Sallave plans to use the capabilities of sUASs to offer a multitude of services, including:

● Aerial surveying of local water supply to the community 

● Event Photography/Videography 

● Agriculture and Livestock monitoring 

● Real Estate Photography and presentation 

● Aerial filmmaking and photography 

● 3d environment mapping

● various types of construction inspections which includes power lines, cell towers, and 

agriculture systems.

Construction site inspections and monitoring Statutory Authority Section 333, titled “Special 

Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited 

FAA authorization of safe civil Unmanned Aircraft Systems (UAS) operations in the National 
Airspace System (“NAS”). Section 333(a) states that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before 

completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act 

or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it 

clear that Section 333 provides a mechanism for “expedited operation authorization” if several 

factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations.

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (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. 91.121Page 3 

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)

sUASs are oftentimes seen as superior to helicopters due to the lesser cost of equipment, the 

reduction of personnel needed to operate equipment, reduced noise levels and zero emissions 

into the environment. In addition to providing cost savings and having little to no impact on the 

environment, sUASs provide enhanced safety. These factors are beneficial for, and in the best 

interest of, the public. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay.

Mr. Sallave is requesting an exemption to operate a DJI Inspire 1 sUAS that is upgraded to 

latest version firmware, equipped with a 3 axis Zenmuse camera gimbal, which uses a High-Def 

video camera that can capture up to 4K (4096x2160p) video and 12M pixel photos. This sUAS 

has a built-in capability to limit 1) the height it flies above the ground and 2) the radius of the 

distance it flies from the operator. The aircraft weight is 2935 grams or 6.47 pounds with battery, 

which is the total gross weight. 

Mr. Sallave is also requesting an exemption to operate a DJI Phantom 3 professional that has a 

maximum gross weight of approximately 2 pounds 11 ounces, a length of 16 inches width of 16 

inches, height of 8 inches, and a maximum speed of approximately 29 knots. This sUAS has 

the same features as the Inspire 1, but is lighter at 1280 grams or 2.82 pounds with battery.
Both DJI Phantom 3 and Inspire 1 have an intelligent flight battery and a failsafe function. If the 

battery runs low or control system has been disconnected, the built in failsafe function turns on, 

of the autopilot system, and Returns to Home and will land When the communication between 

the Main Controller and the transmitter is disconnected, the outputs of all command sticks from 

controller will go to the center position. If the GPS signal is good enough, the system will 

automatically trigger the failsafe function. Please refer to attachments - (inspire_1.pdf, 

inspire_2.pdf, and inspire_3.pdf), on the DJI Inspire 1, and attachments (phantom3pro_1.pdf 

and phantom3pro_2.pdf), for the Phantom 3 Professional, Instruction Manual, for the 

performance limitations and flight operations. 

The DJI Phantom 3 professional and Inspire 1 that will be operated by Maurice Sallave will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 

47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. 

A pre-flight inspection will be performed by the PIC in accordance with the factory instruction 

manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make 

sure that the compass, gyro and acceleration values are within specs, positive GPS locks are 

secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in.

The sUAS will be maintained in accordance with the manufacturer’s instruction manual and only 

manufacturer's authorized replacement parts will be used.

FCC Information

The DJI Inspire 1 and Phantom 3 Professional transmitter used for controlling the sUAS 

complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) 

This device may not cause harmful interference, and (2) this device must accept any 

interference received, including interference that may cause undesired operation.

The DJI Inspire1 and Phantom 3 Professional radio transmitter used for controlling the sUAS is 

wireless technology which has been tested and found to be compliant with the applicable 

regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance

When operating the DJI Inspire 1 or Phantom 3 Pro transmitter, the PIC will maintain a 

separation distance of at least 5 cm between his body (excluding fingers, hands, wrists, ankles 

and feet) and the antenna to meet RF exposure safety requirements as determined by FCC 

regulations.

Pilot in Command and Observer Qualifications and Duties
The PIC will maintain at least a Light Sport Pilot Certificate and a current State issued drivers 

license, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the type of 

UAS utilized in operations.

The PIC will have at least 100 hours total time and at least 30 hours flying Radio Controlled 

Model Aircraft, of which, 10 hours will be flying sUASs. 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include 

all preflight preparation and inspection, in flight operation, post flight requirements, and all 

procedures including but not limited to: 

● Safe in flight operations 

● Risk evaluation 

● Current weather conditions for safe flight

The Observer must have the visual acuity to observe the sUAS and be able to communicate 

clearly with the PIC. The Observers duties are: 

● Warning the PIC of any impending obstacles in the flight path of the sUAS. 

● Warning the PIC of any deviations in the planned flight path of the sUAS. 

● Warning the PIC should any unauthorized personnel appear in the area of the planned 

flight.

The Observer will have the authority to order the PIC to terminate the flight should he feel the 

flight cannot be conducted safely.

General Operating Standards

● Maurice Sallave will only operate its sUAS in line of sight of a pilot and/or observer and 

will operate at sites that are a 'sufficient distance' from populated areas. Such operations 

will insure that the sUAS will "not create a hazard to users of the national airspace 

system or the public."

● Before an operation of a sUAS within 5NM of an airport with a control tower, the control 

tower will be called to gain permission to operate the sUAS. The PIC will give the 

position, altitude and the times the sUAV will be operated. The sUAS will not be 

operated at an altitude of over 200 feet AGL. Weather minimums will be 3 miles visibility 

and a 1000 foot ceiling.

● Before an operation of a sUAS within 5NM of a non-tower controlled, airport operators 

will be notified and the PIC will give the right of way to avoid flying in the proximity of 

fullscale aircraft. At no time will the sUAS be operated within the final approach course 

and the takeoff course of any runway. The sUAV will not be operated at an altitude of 

over 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

● Maximum flight time for each operational flight will be 18 minutes. 
● Flights will be terminated at 30% battery power reserve should that occur prior to the 18 

minute limit.

● The sUAV will be programmed so that it will not be operated at an altitude of no more 

than 200 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned. 

● Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

● The sUAV operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, gimbals, and battery).

● The sUAS will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally.

● Given the small size of the sUAV and the restricted sterile environment within which they 

will operate, our sUAV operations adhere to the Reform Act's safety requirements.

The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel. The sUAS operates at lower altitudes with no people on board and 

will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 20 minutes, this 

offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. The benefits of reduced cost and improved quality of presentation 

from the sUAS over manned aircraft will be valuable to and benefit many buyers and sellers of 

real property, farmers and ranchers, and local city officials to monitor our local water supply.

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

who might require assistance, including fire fighters, police, sheriff, etc., all while remaining 

subject to all limitations cited below:

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 200 ft AGL, at an 

airspeed of no more than 25 knots and no further than 1600 ft, or 0.263 NM from the PIC; 

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the 

property owner;

(e) All required permits will be obtained from state and local government prior to operation;

(f) Maurice Sallave will not be operated over densely populated areas; 
(g) Maurice Sallave will not be operating over any open-air assembly of people; 

(h) Maurice Sallave will not be operating over heavily trafficked roads;

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Maurice Sallave requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DJI Inspire1 and Phantom 3 Professional 

under either or both of the following provisions: 21.191 Experimental certificates. Experimental 

certificates are issued for the following purposes:

(a) Research and development.

Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new 

aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations.

Conducting flight tests and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show compliance with 

the function and reliability requirements of the regulations. Since the experimental certificate can 

be used for commercial purposes such as market surveys, sales demonstrations, and customer 

crew training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only 

fly under strict operational requirements. Combined with the UAS's light weight, being 

constructed primarily of carbon fiber and plastic, we propose that the UAS will be at least as 

safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, then we request an 

exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in 

general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on 

the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) 

and others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground station. Finally, we will 
display at the ground station a high contrast flag or banner that contains the words "Unmanned 

Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 

0.263 NM of the ground station, the banner should be visible to anyone that observes the 

aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in 

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. Our proposed operations require that the PIC 

must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and since 

the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 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 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 

sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is 

in, or preparing for, flight, and ready for presentation for any governing official upon request.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 is 

capable of duel/linked controls, Maurice Sallave will be operating with a single remote controller.

91.119 Minimum safe altitudes:

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures 

it would be necessary to operate closer than 500 feet to the items listed. Operations will only be 

flown over property or persons where permission has been obtained and careful preplanned 

flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power 

unit fails, an emergency landing without undue hazard to persons or property on the surface. 

Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles 
and structures is minimal compared to manned aircraft, which should be considered in granting 

the exemption. 

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. The sUAS will always fly below 200 feet AGL and 

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio 

from the sUAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAV is battery operated and the maximum 

duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the 

aircraft will never fly more than 0.263 NM from the point of intended landing, a full battery 

charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We 

request an exemption to the word "fuel" and ask for an equivalent interpretation with the word 

"energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47 

pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not 

capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the 

intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will 

be with the crew at the ground control station and available for inspection upon request. In order 

to identify the aircraft, we propose that the information found on airworthiness and 9 registration 

certificates be permanently affixed to the aircraft via placard containing the following information 

plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The 

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition 

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC 

is limited to repairing small cracks, replacing a propeller, checking electrical connections and 
updating software and firmware for the on-board computer. All other maintenance will be 

performed by the manufacturer or their designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity 

of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

Mr. Sallave will be using the UAS in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient 

and safer benefits over the use of full-sized manned aircraft for aerial photography, advanced 

agriculture monitoring, film and still photography, real estate marketing, and water supply 

monitoring. Due to drought conditions in the area over the past few years, this would greatly 

supply safer, faster, and more efficient information to our local officials who need this 

information about the lake levels and our water supply.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS 

carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. 

By granting Maurice Sallave’s requested exemptions, the FAA will help drive development of 

safe and successful commercial UAS operations and will advance the public knowledge base 

for such operations. Maurice Sallave is committed to promoting the UAS research efforts of 

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial 

UAS operations and serving as a resource for future UAS research operations. Thus, the FAA 

has good cause to grant this Petition. 

Conclusion

As pointed out in this application, the DJI Inspire1 and DJI Phantom 3 Professional which 

Maurice Sallave would use, under authorization by the US DOT-FAA, is a small, light-weight 

device operated within the line of sight of the Pilot-in-Command (PIC), less than 200 feet above 

the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other 

location with aviation activities, unless the air traffic control authorities (ATC) have been notified 

and have authorized each flight within a radius of this distance.

The DJI Inspire1 and DJI Phantom 3 Professional have been proven capable for controlled 

flight. It is a UAS offered for general sale on the market around the world and have often been 

used as Model Aircraft in the USA. We are certain that the studies conducted until now by the 

FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the 

assurances on the airworthiness of sUAS. 

For the foregoing reasons, the exemptions requested herein should be granted and Mr. Maurice 

Sallave should be permitted to conduct small UAS operations in accordance with its manuals 

and all other operating parameters deemed necessary and appropriate by the FAA. 

The submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some sUAS may be used for legitimate 

commercial activities and under reasonably safe conditions.
Signed,

Maurice Sallave 

Toastedmango Media