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U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590

December 1, 2015

Dear FAA UAS Exemption Review Team,

I, Gregory C. Inglett, company owner and UAS pilot is in pursuant of exemptions that would grant legal 

and safe entry into the National Airspace Systems (NAS) under section 333 of the FAA Modernization 

and Reforms act of 2012 and the procedures within 14 C.F.R. 11, (Public Law 112-95 FEB). In the matter 

of the petition for Midwest Aerial Productions LLC. (M.A.P.) requests exemption from the Federal 

Aviation Regulations Title 14 of the code of federal regulations sections listed below and any additional 

regulations as required by the FAA that is deemed necessary in order to conduct commercial unmanned 

aircraft system operations: 45.23(b), 61.113(a)(b), 91.7(a), 91.9(b)(2), 91.119(c), 91.121, 91.151(a)(1), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a)(b). 

The exemption will permit Midwest Aerial Productions LLC. to operate an Unmanned Aircraft Systems 

(UAS) for commercial purposes. The requested exemptions above would allow safe and professional 

services, to the state of Michigan and surrounding states in the U.S.A. The exemptions would allow for 

both public and private operation of small unmanned aircraft systems for:

 Aerial real estate photography/videography

 Aerial event filming 

 Aerial construction development photography/videography

 Aerial residential and commercial property photography/videography

 Aerial agriculture photography/videography

 Aerial location scouting and safety inspection 

 Film production

 Search assist 

Terms of Reference:

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air.

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, 

equipment and services, airports or landing areas; aeronautical charts, information and services; 

rules, regulations and procedures, technical information, and manpower and material.

3. Operational Control: with respect to a flight, means the exercise of authority over initiating, 

conducting or terminating a flight

4. Pilot in Command (PIC): the person who has final authority and responsibility for the operation 

and safety of the flight; has been designated as PIC before or during the flight; and hold the 

appropriate category class and type-rating, if appropriate, for the conduct of the flight
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5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct human 

intervention from within or on the aircraft

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, including

communication links and the components that control the unmanned aircraft, are required for 

the pilot in command to operate safely and efficiently in the national airspace system. 

7. UAS Certification of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity. 

8. Visual Line of Sight (VLOS): unaided visual contact between a pilot in command and an 

unmanned aircraft sufficient to maintain safe operational control of the aircraft, know it 

location, and be able to scan the airspace in which it is operating to see and avoid other air 

traffic or objects aloft or on the ground. 

9. Global Positioning System (GPS)

10. Above Ground Level (AGL)

11. Area of Interest (AOI)

12. Code of Federal Regulations (CFR)

13. Federal Aviation Regulation (FAR)

14. Vertical Takeoff and Landing (VTOL) 

15. Ground Control Station (GCS)

16. Intelligent Orientation Control (IOC)

Before establishing Midwest Aerial Production, the petitioner previously worked at Western Michigan 

College of Aviation as a photographer/videographer and web design. The petitioner has been in the 

photography and videography industry for over 10 years and is dedicated to the safety of all operations. 

MAP is devoted to set an example by legally entering the NAS for all businesses and operators alike.

Granting entry will advance the public interest while and help stimulate the economy in a safe and 

effective manner. In efforts to do this the petitioner is requesting to operate legitimately and in 

compliance with all regulations set forth by the FAA.

The first UAS that M.A.P. seeks an exemption to operate is the DJI Phantom 1. The UAS has a vertical 

takeoff and landing (VTOL), global positioning system (GPS), and a ground control station (GCS) utilizing 

an electronic tablet or smart phone. The total weight of the UA is less than 1200 grams and the diagonal 

distance (motor center to motor center) is 350.00 mm. The maximum flight velocity is 10 m/s operating 

with a LiPo 200 mA battery. The UAS has two flight control modes, including position hold and has 

intelligent orientation control (IOC). Built into the UAS is a failsafe and auto go home/landing should an 

emergency landing be needed or loss of contact with the GCS. The DJI Phantom 1 UA that will be 

operated by M.A.P. 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 unless an exemption is required as described below. 

The second UAS that M.A.P. seeks an exemption to operate is the DJI Phantom 3 Professional/Advanced.

The UAS has a vertical takeoff and landing (VTOL), global positioning system (GPS), and a ground control 

station (GCS) utilizing an electronic tablet or smart phone. The UAS utilizes the DJI Lightbridge 

communication software to control the UAS which allows to monitoring of the battery life. This allows 
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the pilot in command (PIC) to prearrange landing once the battery is below 25%.The total weight of the 

UA is less than 1300 grams and the diagonal distance (including propellers) is 590.00 mm. The maximum 

flight velocity is 16 m/s operating with a LiPo 2s 6000 mA battery. The UAS has auto-takeoff to a preset 

height, a failsafe, and auto go home/landing should an emergency landing be needed or loss of contact 

with the GCS. The DJI Phantom 3 UA that will be operated by M.A.P. 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 unless an 

exemption is required as described below. 

The third UAS that M.A.P. seeks an exemption to operate is the DJI Inspire 1. The UAS has a vertical 

takeoff and landing (VTOL), global positioning system (GPS), and a ground control station (GCS) utilizing 

an electronic tablet or smart phone. The use of two remotes can be utilized for increased safety. The 

UAS utilizes the DJI Lightbridge communication software to control the UAS which allows monitoring of 

the battery life. This allows the pilot in command (PIC) to prearrange landing once the battery is below 

25%. The total weight of the UA is less than 3000 grams and the diagonal distance is 559.00 mm to 

581.00 mm. The maximum flight velocity is 22 m/s operating with a LiPo 2s 6000 mA battery. The UAS 

has auto-takeoff to a preset height, a failsafe, and auto go home/landing should an emergency landing 

be needed or loss of contact with the GCS. The DJI Inspire 1 UA that will be operated by M.A.P. 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 unless an exemption is required as described below. 

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21, Subpart H – Airworthiness Certificates

Subpart H details the procedural requirements for the issue of airworthiness certificates. 

An exemption for Part 21 Subpart H is required due to the size and limited operating area associated 

with the aircraft. Under the Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt any aircraft from an airworthiness certificate taking in consideration 

the UAS operational capability, weight, size, speed, and proximity to airports and other populated areas. 

The UAS is less than 55 lbs. and is operated without an onboard pilot or passengers. The level of safety 

will be achieved by tightly controlling the operations of the UAS in reference to the criteria mentioned 

above. Due to the size and limited operating area associated with the aircraft an exemption from Part 21 

Subpart H meets the requirement of an equivalent level of safety under Part 11 and Section 333 or the 

Reform Act. The UAS is operated without an onboard pilot or crew and also carries no explosive 

materials or flammable liquids fuels.
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14 C.F.R. 45.23 (b) Display of marks; general

(b) 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,” “lightsport,” “experimental,” or “provisional,” as applicable.

An exemption may be needed as the UAS does not have an entrance to the cabin, cockpit, or pilot 

station on which the word “Experimental” can be placed. In compliance with 45.29(f), the word 

“Experimental” will be place on the fuselage as an alternative, providing equivalent level of safety. 

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

(a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, 

act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, 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. 

Midwest Aerial Productions seek an exemption from this rule. The UAS is controlled from the ground 

and does not carry a pilot or passengers. The equivalent level of safety will be obtained since risks 

associated of the UAS operation are mitigated as there is no living thing on board the UAS. 

14 C.F.R. 91.7 - Civil aircraft airworthiness

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

The UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Given the size of the aircraft and that the aircraft does not carry passengers or crew, the PIC will 

determine the equivalent level of safety prior to every flight by determining that the aircraft is in a 

condition for safe flight. 

14 C.F.R. 91.9 (b) (2) – Civil aircraft flight manual, marking, and placard requirements.

No person may operate a civil aircraft without complying with the operating limitations specified in the 

approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by 

the certificating authority of the country of registry.

(b) No person may operate a U.S.-registered civil aircraft--

(2) For which an Airplane or Rotorcraft Flight Manual is not required by Sec. 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.
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The UAS, at no point, will weigh more than 55 lbs. The UAS is operated without an onboard pilot so 

there is no ability to carry a flight manual. To achieve the equivalent level of safety the pilot flying the 

UAS will have immediate access to it on ground. 

14 C.F.R. 91.119 (c) Minimum safe altitudes: General. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.

The petitioner requests exemption from Section 91.119 (c) as the equivalent level of safety will be 

achieved given the UAS size, weight, speeds and limited operating time and area. No flight will be 

conducted without advance notice and permission from the property owner and all individuals involved. 

The UAS operated under GPS lock and the low-altitude operations will ensure appropriate distance 

between the UAS operated and the operations of a conventional aircraft that also complies with section 

91.119. In an emergency the UAS will land either by control of the operator or by the return-to-home 

feature of the UAS. 

14 C.F.R. 91.121 Altimeter settings.

Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the 

case may be, by reference to an altimeter that is set..... 

The UAS will not have a typical barometric altimeter onboard. The UAS will be provided to the PIC via 

Global Positioning System (GPS) equipment. An equivalent level of safety will be achieved, equivalent to 

Section 91.121 by the operator and will maintain a visual line of site, at or below 400 feet AGL 

14 C.F.R. 91.151 (a) (1) Fuel requirements for flight in VFR conditions.

(a)No person may begin 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.

Currently the UAS battery provides approximately 30 minutes of power flight times. Given the 

limitations of the UAS and the predetermined flight routes, an equivalent level of safety will be 

maintained by operating the UAS in a tightly controlled area. The operators will prepare to land when 

the battery percentage falls below 25%. As stated above in an emergency the UAS will return-to-home 

should loss of contact occur or the battery becomes low. 
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14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) (2); 417 (a) (b) - Maintenance Inspections.

Each owner or operator of an aircraft 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....

All maintenance and repairs will be accomplished by utilizing the manual for the UAS. Given that the 

above sections and Part 43 apply to an aircraft with an airworthiness certificate these sections will not 

apply for Midwest Aerial Productions. Pre and post flight checks will be conducted and if any 

deficiencies are found the UAS will not be operated until repairs are conducted in accordance to the UAS 

manual. 

Thank you for your time and consideration. 

Sincerely,

Gregory Inglett

Midwest Aerial Production

4610 Dunhill Terrace

Kalamazoo, MI 49006