Michael D Crider

Michael Crider Aerial Photography

6141 Eagle Point Lane

Frisco, TX 75034

June 16, 2015

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the FederalAviation

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14

CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Michael D

Crider, operator of small Unmanned Aerial Systems (UAS), hereby applies for an exemption from the listed

Federal Aviation Regulations to allow commercial operation of a small UAS, 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.

Commercial operation small UAS, as described herein, which are equipped with cameras and sensors,would

operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land

Surveying, engineering and other related professional activities.

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

cinematography.

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

local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue operationsin

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

it by contract or donation.

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

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

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

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 systemsin

the national airspace system.”

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The name, phone, email and address of the applicant:

Name: Michael D. Crider

Phone: (509) 209-1438

Email: jetstar737@gmail.com

Address: 6141 Eagle Point Lane, Frisco, TX 75034 USA

Regulations from which the exemption isrequested:

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

The small UAS’s I will be using are multi-rotor craft weighing no more than 55lbs. including payload. Under

normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and have the ability hover and

move along a vertical and horizontal plane simultaneously. They will operate in line of sight only and bythe

exempted person or other fully qualified designated pilot obeying all other local and federal laws.

Given the small size of the small UAS and the controlled environment provided the proposed operationswill

adhere to the Reform Act’s safety requirements. The approval of this application presents no national

security issues. Regarding the level of safety surrounding the proposed operations and the publicbenefit,

reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of

the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the

requested exemption with minimum delay. 

Qualifications of Michael D. Crider, CEO and Chief Pilot of Michael Crider Aerial Photography. 

Airline Transport Pilot Certificate Number 2089380

Airplane Multiengine Land

Rotorcraft Helicopter

B-737, BH-222, CE-500, L-1329

Total Time 20,200 hours

Current in the B-737 300, 500, 700, 800

RC aircraft 400 hours
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operationswill

further enhance the safety of the persons and/or property over using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS will weigh less than 55 lbs.

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

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25%

battery power reserve or 30 minutes of flight time whichever occursfirst.

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more

than 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), theVisual

Observer (VO) when needed and may include but not limited to a Camera Operator.

6. The small UAS pilot will be Michael D. Crider or possibly another designated and trained FAA rated

commercial pilot.

7. A briefing will be performed regarding the planned small UAS operations prior to each day’sflight

consisting of all the days’ production activities.

8. The PIC will obtain verbal/written consent of all persons involved with the planned operation and ensure

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

be reduced to 30 feet based upon an equivalent level of safety determination, as required under the

FOM. With the advanced permission or direction of the FSDO, operations at closer range may be

approved.

9. The PIC and VO will have been trained in operation of small UAS and receive up-to-date information for

the particular small UAS to be operated and will be able to show upon request their competent ability to

operate the small UAS and/or Camera.

10. The PIC and VO will be able to communicate by voice at alltimes.

11. Written and/or verbal permission and permits will be obtained from territorial, state, county or city

jurisdictions, including law enforcement, fire or other appropriate governmental agencies when needed.

12. If the small UAS loses communications or loses GPS signal, the small UAS will have the capability to

return to a pre-determined location within a designated location and land autonomously.

13. The small UAS will have the capability to abort a flight in case of unpredicted obstacles, weather,or

emergencies.

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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 issuanceof

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 meetsthe

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 exemptaircraft

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 small UAS. In all cases, an analysis of

these criteria demonstrates that the small 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 conventionalaircraft

(fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions andconditions

proposed.

The small UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot norpassenger,

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and

monitored by both the operator and under the requirements and in compliance with local public safety

requirements. These safety enhancements 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 nationalsecurity

posed by the small UAS, due to its size, speed of operation, location of operation, lack of explosive materialsor

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

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

The regulation requires: When marks include only the Roman capital letter "N" and the registration numberis

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 pilotstation,

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 small UAS will have no airworthiness certificate, an exemption may be needed as the smallUAS

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed.

Given the size of the small UAS, two-inch lettering will be impossible. The word “Experimental” will be placedon

the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having thesmall

UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the

small UAS will see the identification of the small UAS as “Experimental.”

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

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 FAAregulatory

standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use ofsafety

checklists prior to each flight an equivalent level of safety will beprovided.

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 small UAS, 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 roomor

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keepingthe

flight manual at the ground control point where the pilot flying the small UAS will have immediate access toit.

14 C.F.R. § 91.103: PreflightAction.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed.The

OPERATOR will take all actions including reviewing weather, flight battery requirements, landing and takeoff

distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: FlightInstruction.

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. Small UAS and remotelypiloted

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 forflight

instruction in experimental aircraft. 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.

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14 C.F.R. §91.119: Minimum SafeAltitudes.

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 withany

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a small UAS that is ahelicopter

and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an

elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set 

forth herein, the small UAS will never operate at higher than 400 AGL with the exception that incircumstances

where the small UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, thesmall

UAS will not be operated more than 100' above the highest point on the structure. It will however be operated

in a restricted area with security perimeter, where buildings and people will not be exposed tooperations

without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight,speed

of the small 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 participantsin

the filming activity, all affected individuals will be aware of the planned flight operations. Compared toflight

operations with aircraft or rotorcraft weighting 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 presentedwith

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the small UAS

will ensure separation between these small- UAS operations and the operations of conventional aircraftthat

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 small UAS may not have a barometric altimeter, but instead a GPS altitude readout,

an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant tothe

safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

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

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 ofintended

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 small UAS provides approximately30

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UASflights

would be limited to approximately 10 minutes in length. Given the limitations on the small UAS’s proposedflight

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

daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR§91.151(a)

falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area whereonly

people and property owners or official representatives who have signed waivers will be allowed, with lessthan

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 small UAS flights to 10 minutes wouldgreatly

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reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level ofsafety

can be achieved by limiting flights to 30 minutes or 25% of battery power— whichever happens first.This

restriction would be more than adequate to return the small UAS to its planned landing zone from anywherein

its limited operating area.

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 itthe

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 cockpitentrance

so that it is legible to passengers or crew.

The small 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 smallUAS.

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

pilot flying the small UAS will have immediate access to them; to the extent they are applicable to the smallUAS.

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 thissection,

have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the

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

airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the

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

because these small UASs are very limited in size and will carry a small payload and operate only inrestricted

areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be

operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order

prior to initiating flight, perform required maintenance, and keep a log of any maintenanceperformed.

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraftin

an airworthy condition to provide the equivalent level ofsafety.

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

accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual(AOM).

As provided in the FOM, the operator will ensure that the small UAS is in working order prior to initiatingflight

and perform required maintenance needed.

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Small UAS Information

Small UAS’s to be used are as follows but not limited to providing they are within the scope of theexemption

granted by the FAA:

1. 3D Robotics Solo Quad Copter

• Weight (Battery & Propellers Included) –3.3 lbs.

• Autopilot: 3DR Pixhawk2

• Flight Code: ArduPilot Copter

• Control: 3DR Solo Controller

• Wireless Link: 3DR Link 1.0

• Frequency: 2.4 GHz

• Maximum altitude: 328 ft. (100 m)

• Range: .5 miles

• Payload capacity: 1.1 lbs (500 g)

• Cruise speed 5.7 mph

• Maximum speed: 55 mph

• Maximum climb rate 11 mph ( 5.0 m/s)

• Maximum descent rate: 5.5 mph (2.5 m/s)

• Headwind limitation: 25 mph

• Crosswind limitation 25 mph

• Estimated flight time 25 min

• Camera Gimbal 3DR Solo smart gimbal

• Camera GoPro 4

• Safety features: 

o Return to Launch with loss of control link or low battery

o GPS controlled auto takeoff and auto land

o GPS limited maximum altitude (set to 300 feet)

o GPS programmable fence

o Preflight automatic systems check, magnetic interference, gyro calibration, GPS lock, 

Battery voltage check.

• Solo Flight Battery: 4s 5300mah.

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2. Alware Cyclone X8 Octocopter

• Frame: Made of 3K carbon fiber

• Diagonal Wheelbase: 900mm.

• Frame Arm Length (with Motor Mount): 455mm

• Frame Weight (With Retract System, Motor, ESC, Props) 3385g

• Retractable Landing Gear

• 8 High Efficiency Motors

• High Efficiency Carbon Props 14x4.7 inch

• Maximum Takeoff Weight: 19 lbs. (8.6kg)

• 3 Axis Gimbal for Sony NEX 5n Camera

• Power Battery: 6s Lipo (9000mAh-20000mAh 20C min

• Autopilot 3DR Pixhawk

• Flight Code: ArduPilot Copter

• Wireless Link: FrSky Taranis 

• Frequency 2.4Ghz

• Range 1 mile

• Telemetry link: 3DR 900 mhz

• Safety Features:

o Return to Launch with loss of control link or low battery

o GPS auto hover (loiter mode)

o GPS limited maximum altitude (set to 300 feet)

o GPS programmable fence

o Telemetry systems for system health, Battery voltage, Battery mAh used, link quality, GPS

status, all with voice warnings.

o X8 octocopter configuration which allows safe landing with motor or prop failure

• Cruise speed: 5mph

• Maximum speed: 30mph

• Maximum climb rate: 11mph

• Maximum descent rate: 5mph

• Wind limitations: 30mph

• Estimated Flight Time: 15min

Conclusion

Thank you for the consideration of these exemptions.

Sincerely,

Michael Crider

CEO Michael Crider Aerial Photography

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