Matthew R. Engel

Tree Top View Media

1866 Germany Rd.

Williamston, Michigan 48895

November 23, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

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

91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 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: 

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

and 14 C.F.R. Part 11, Tree Top View Media (“the applicant”), developer and operator of Small 

Unmanned Aircraft Systems (“sUASs”) equipped to conduct Real Estate, Marketing, 

Infrastructure and Construction Inspection and assist Business Operations, 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.

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, 3) controlled as to access, and 4) would provide safety enhancements 

to the already safe operations in the infrastructure and business operations 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.” 

Section 333(c) of the Reform Act.

The name and address of the applicant is: 

Tree Top View Media

Attn: Matthew R. Engel

Phone: (517) 285-0307

Email: mengel@treetopviewmedia.com 

Address: 1866 Germany Rd. Williamston, Michigan 48895
Regulations from which the exemption is requested: 

• 14 CFR Part 21 

• 14 C.F.R. 45.23(b) 

• 14 CFR 61.113 (a) & (b) 

• 14 C.F.R. 91.7 (a) 

• 14 CFR 91.9 (b) (2) 

• 14 C.F.R. 91.103 

• 14 C.F.R. 91.109 

• 14 C.F. R. 91.119 

• 14 C.F.R. 91.121 

• 14 CFR 91.151 (a) 

• 14 CFR 91.203 (a) & (b) 

• 14 CFR 91.405 (a) 

• 14 CFR 407 (a) (1) 

• 14 CFR 409 (a) (2) 

• 14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following:

• The UAS’s size, weight, speed, and operational capability;

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

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, which includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it 

should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.

 
finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14 CFR §91.203 (a) (1).

Tree Top View Media’s sUAS’s (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including 

payload. They operate under normal conditions at a speed of no more than 25 knots and have the 

capability to hover and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate only within the sterile area described in the • TREE 

TOP VIEW MEDIA - Attachment 1 - sUAS Operating Manual, attached as Appendix 2 

(hereinafter “the Manual”). Such operations insure that the sUAS does “not create a hazard to 

users of the national airspace system or the public.”2 Given the small size of the sUAS’s involved 

and the restricted sterile environment within which they will operate, the applicant falls squarely 

within that zone of safety (an equivalent level of safety) in which Congress envisioned that the 

FAA must, by exemption, allow commercial operations of sUASs to commence immediately. 

Also due to the size of the sUASs and the restricted areas in which the relevant sUAS’s will 

operate, approval of the application presents no national security issue. Given the clear direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions associated with allowing sUAS’s for Real Estate, Marketing, 

Infrastructure and Construction Inspection, and Business Operations, the granting of the 

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay.

Background Information

Tree Top View Media is in the business of consulting on video inspection of building and 

maintaining mission specific sUAS Real Estate, Marketing, Infrastructure and Construction 

Inspection, and Public Safety. Tree Top View Media’s clients look to us for safe operations of 

sUAS. We have developed specific safe UAV operational procedures. Increasingly, we have 

clients looking to operate sUAS for infrastructure and maintenance inspections, construction 

documentation, public safety, and business operations.

2 Reform Act Section 333 (b).

 
Operations performed by Tree Top View Media include: 

• Real Estate/Architecture

• Marketing

- Tourism

- Hotel/Resort

- Golf Course Management

• Aerial Data Collection

• Surveying and Mapping

• Agriculture Crop Management

• Agriculture Inspection

• Aerial Filmmaking and Photography

• Construction Site Inspections and Monitoring

• Industrial Surveying

• Manufacturing Inspection

• Construction Site Documentation

• Land Development

• Public Safety

As part of this, Tree Top View Media is requesting FAA Exemption for sUAS operations for 

safety, marketing, inspection and video capture usage.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

infrastructure, construction, and business operations conducted with conventional aircraft.

These limitations and conditions to which Tree Top View Media agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 

200 feet above an elevated platform from which flight is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer.

6. The sUAS pilot will be a specially trained staff member of Tree Top View Media

knowledgeable of the airspace within which the operation will take place and how that 

airspace fits into the NAS.
7. The sUAS Pilot will be the Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on site, 

that person can also be designated as PIC.

8. The sUAS will only operate within defined boundaries as outlined in the company 

Manual.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each 

mission. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office (FSDO).

11. The operator will obtain the consent of all persons involved in the mission and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, and 

this radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required by the company manual. With the advanced permission of the 

relevant FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days before the 

proposed mission as required in the company manual. Items will include: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the sUAS mission conducted under 

this petition of exemption; 

c. Make, model, and serial or N-number of UAS to be used; 

d. Name and certificate number of sUAS PICs involved in the mission; 

e. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the mission; 

f. The list of those who gave permission made available to the inspector upon 

request; 

g. Signature of exemption-holder or representative; and 

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

town, county, and/or state over which the mission will be conducted and the 

altitudes essential to accomplish the operation.

13. Pilot and observer will have been trained in operation of sUAS generally and received 

up-to-date information on the particular sUAS to be operated as required in the company 

manual.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral permission from the relevant property holders will be obtained.

16. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

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

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

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

exemption will be tightly controlled and monitored by both the operator and observer, pursuant 

to the Manual’s policies, and under and in compliance with local public safety requirements, to 

provide security for the area of operation as is now done with conventional infrastructure and 

construction inspections and business operations. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil aircraft operated in 

connection with infrastructure and construction inspections and business operations, provide a 

greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible threat to national

security posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to a cabin, cockpit or pilot station on which the word “Experimental” 

can be placed. Given the size of the sUAS, 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 sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the 

identification of the UAS as “Experimental.” The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

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

(PIC).

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have specially trained 

staff operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, 

the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set forth in the 

Manual. The level of safety provided by the requirements included in the Manual exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a conventional 

aircraft. The risks associated with the operation of the sUAS are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested by specially trained staff as the PIC exceeds the present 

level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

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. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance and 

use of safety checklists prior to each flight, as set forth in the company manual, an equivalent 

level of safety will be provided.

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

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any 

combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.
The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

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

14 C.F.R. § 91.103: Preflight action 

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. An equivalent level of safety will be provided as set forth in the 

company Manual. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before initiation of 

flight.

14 C.F.R. §91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the 

fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of 

the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes 

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 sUAS 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 operation 

is planned, an exemption may be needed to allow such operations. As set forth herein, except for 

the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. 

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

people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the mission, all affected individuals will be aware of the planned flight operations 

as set forth in the company manual.
Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 

55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 

AGL in the infrastructure and construction inspections and business operations industry. In 

addition, the low-altitude operations of the sUAS will ensure separation between these small 

UAS operations and the operations of conventional aircraft that must comply with Section 

91.119.

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS 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 Manual and safety checklist, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes.” 

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

the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 20 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the 

exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating 

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it 

has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

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

them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook as referenced in the Manual (See Sections 

8.6 and 9). An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Manual, 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.
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 

(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 

(a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a 

small unmanned vehicle (55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commercial operations of sUASs in the real estate, marketing, 

infrastructure and construction inspection and business operations will enhance safety by 

reducing risk. Conventional infrastructure and construction inspections and business operations, 

using jet or piston power aircraft, operate at extremely low altitudes just feet from the 

infrastructure being inspected and in extreme proximity to people and structures; and present the 

risks associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large 

amounts of jet A or other fuel. Such aircraft must fly to and from the work location. In contrast, a 

sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the 

worksite and not flown. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy 

All flights will occur over private or controlled access property with the property owner’s prior 

consent and knowledge. Infrastructure and construction inspections and business operations will 

be performed for people who have also consented for work to be performed or otherwise have 

agreed to be in the area where UAS flight will take place.
Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s UAS in the 

infrastructure and construction inspections and business operations industry pursuant to the 

Manual appended hereto.

Sincerely, 

Matthew R. Engel

Owner

Tree Top View Media

Appendix 1

• DJI Phantom 2

o See Attached Document: 

 TREE TOP VIEW MEDIA - Attachment 2 - Phantom 2 User Manual 

v1_4.pdf

• DJI Phantom 3 Professional

o See Attached Document:

 TREE TOP VIEW MEDIA - Attachment 3 - Phantom 3 Professional User 

Manual v1_2.pdf

• DJI Inspire 1

o See Attached Documents:

 TREE TOP VIEW MEDIA - Attachment 4 - Inspire 1 User Manual 

v1_2.pdf

 TREE TOP VIEW MEDIA - Attachment 5 - Inspire 1 Safety 

Guidelines.pdf

 TREE TOP VIEW MEDIA – Attachment 6 - Inspire 1 Maintenance 

Manual V1_0.pdf

• 3DRobotics Solo

o See Attached Document:

 TREE TOP VIEW MEDIA - Attachment 7 - 3DR Solo User Manual

Appendix 2 Please see the attached Operating Manual:

• TREE TOP VIEW MEDIA - Attachment 1 - sUAS Operating Manual