Civic Mind Media LLC

5982 N Harcourt Drive

Coeur d’Alene, ID 83815

208-209-3274

carl@civicmindmedia.com

June 10, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR

61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14

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

Dear Sir or Madam:

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the

Reform Act) and 14 CFR Part 11, Civic Mind Media LLC hereby applies for an exemption

from the listed Federal Aviation Regulations (FARs) to allow commercial use of its Small 

Unmanned Aircraft Systems (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.

An exemption is being requested because (1) existing regulations will burden Civic Mind 

Media LLC (2) Civic Mind Media LLC can provide a level of safety that is equal (or greater

than in many cases) to those provided by existing rules, and (3) the request is in the public

interest. The FAA’s authority to issue exemptions from operating rules, and the Secretary’s

authority granted by Section 333 of P.L. 112-95, Special Rules for Certain Unmanned Aircraft

Systems, provide an opportunity to authorize certain SUAS operations in the National

Airspace System (NAS) prior to implementation of the SUAS rule. This incremental step will

allow Civic Mind Media LLC to safely and legally enter into the NAS.
June 10, 2015

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As described in detail below, the requested exemption would permit Civic Mind Media LLC

to operate SUASs 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 of those aircraft of similar size, weight, speed, and operating capability that have

been granted entry into the NAS via the rules in Academy of Model Aeronautics (AMA)

National Aircraft Safety Code.

1 Approval of this exemption would thereby greatly enhance

safety and fulfill the Secretary of Transportation’s (the Secretary) responsibilities to

“...establish requirements for the safe operation of such aircraft systems in the national 

airspace system” per Section 333 (c) of the Reform Act.

Civic Mind Media LLC is requesting exemption from the following 

regulations: 14 CFR Part 21, Subpart H

14 CFR 61.23 (a)

14 CFR 61.113 (a) and (b)

14 CFR 91.109

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.405 (a)

14 CFR 91.407 (a)(1)

14 CFR 91.409 (a)(1)

14 CFR 91.409 (a)(2)

14 CFR 91.417 (a) and (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 to consider whether

certain unmanned aircraft systems may operate safely in the 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, to the public, or pose a threat to national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an

unmanned aircraft system, as a result of its size, weight, speed, operational capability,

proximity to airports and populated areas, and operation within visual line of sight (VLOS)

does not create a hazard to users of the NAS or the public or pose a threat to national

1 See the attached “AmaSafetyCode.pdf” document.
June 10, 2015

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security, and (2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under 49 USC 44704 is required for the operation of civil (nongovernmental) UASs. Therefore, 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”.

2

Operation Overview

Civic Mind Media LLC’ SUASs are multirotors (quadcopters, hexcopters, tricopters) and EPO 

foam fixed wing aircraft weighing 5 or fewer lbs. (including payload). The multirotor SUASs

have the capability to hover and move in the vertical and horizontal planes simultaneously.

Fixed wing SUASs operate in a similar fashion as full scale fix wing aircraft. They will operate

only in visual line of slight (VLOS) and will operate only in tightly controlled and limited

airspace. They are capable of operating at speeds of up to 29 knots, but will be routinely

operated at much lower speeds. They will routinely be operated below 200 feet above ground

level (AGL), and never about 400 feet AGL.

Civic Mind Media LLC’ exemption request would permit its commercial operation of SUAS

for aerial photography, aerial mapping and videography in tightly controlled and limited

airspace. Aerial photography, mapping and videography services will be offered to 

homeowners, realtors, home builders, developers, engineers, home contractors, and/or 

home inspectors for use in, but not limited to, real estate marketing and safer inspections

of home exteriors. All operations will be conducted on private property and with the written

and/or oral permission of the property owner(s). Operations will always be conducted in

areas that are clear of all people, except the pilot in command (PIC) and the PIC’s helper(s).

Such operations will ensure that the SUAS will “not create a hazard to users of the national 

airspace system or the public”.

3

Aircraft

Civic Mind Media LLC operates a 550 Hexacopter SUASs manufactured by AeroSky and a 

light weight EPO foam fixed wing aircraft both engineered for SUAS use by Carl Stearns 

using the ArduPilot autopilot systems designed by 3DRobotics.

4 5

2 Civic Mind Media LLC interprets this provision to place the duty on the Secretary to not 

only process applications for exemptions under section 333 of the Reform Act, but for the

Secretary to craft conditions for safe operations of SUAS, if it should be determined that the

conditions set forth herein do not fulfill the statutory requirements for approval.

3 Reform Act Section 333 (b)
June 10, 2015

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The 550 Hexacopter has six prop driven motors that provide excellent lift and provide a 

measure of safety over common 4 motor units such as the DJI Phantom. A Hexacopter will 

remain controllable if a motor becomes disabled while a DJI Phantom will crash immediately. 

Light weight EPO Fixed Wing aircraft is electric prop powered and will glide in the event of a 

power failure. Both aircraft are controlled via 16 channel 2.4ghz radio system that also 

provides telemetry back to the operator on the condition of the aircraft. 

The 550 Hexacopter is about 1.5 feet in diameter in size. The EPO Fixed Wing is has a 59 inch 

wing spanand a 3 foot length. Both aircraft have a maximum ascent speed of 11 knots and a

maximum flight speed of 29 knots. While operating within VLOS, the remote control has a

range of 2,624 feet. The total weight (including the payload) is less than 5 lbs.

The 550 Hexacopter and EPO Fixed Wing are equipped with an ArduPilot flight control

system designed by 3DRobotics. This provides for incredible ease of use and stability. Pilots

can control the aircrafts movements in many directions – including pitch (forward and

backward), roll (left and right), elevator (up and down), and yaw (turn left or right). The

flight control system can also provide Intelligent Orientation Control (IOC), failsafe, battery 

level warnings, and show the aircraft’s current heading, direction, and approximate distance

from home on the on-screen radar. The built- in GPS system aids in stabilizing the aircraft

and automatically and safely returns it back to its home point in any case where

communication between the remote control and aircraft are lost.

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric

altimeter that measures both attitude (ATTI) and altitude. The inertial measurement tells

the aircraft how it’s tilted. And the gyros tell it if it’s rotating in any particular direction.

The Ardupilots compass read geomagnetic information and assist the Global Positioning

System (GPS) to accurately calculate the position and height of the aircraft. The vertical 

accuracy is +/- 2.6 ft. The horizontal accuracy is +/- 8.2 ft.

4 Ardupilot by 3DRobotics – Multirotor Reference: http://copter.ardupilot.com –

5 Ardupilot by 3DRobotics – Fixed Wing: http://plane.ardupilot.com
June 10, 2015

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Such highly advanced capabilities along with the redundancy provided by the Hexacopters

6 motor configuration and the ability for the Fixed Wing Aircraft to glide will ensure that

the SUASs can be safely operated and “not create a hazard to users of the national

airspace system or the public.”

6

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace

system in the world and to minimize the risk to the NAS or to persons and property on the

ground, Civic Mind Media LLC agrees to be bound by the following limitations and

conditions when conducting commercial operations under an FAA issued exemption:

A. For the purposes of ensuring SUASs will be operated within the standards that the

FAA has allowed in the AMA National Model Aircraft Safety Code :

7 8

1. SUASs will not be flown:

a. In a careless or reckless manner.

b. At a location where SUAS activities are prohibited.

2. SUAS pilots will:

a. Yield the right of way to all human-carrying aircraft.

b. See and avoid all aircraft using a spotter.

c. Not fly higher than 400 feet above ground level.

d. Not interfere with operations and traffic patterns at any airport, heliport

or seaplane base except where there is a mixed use agreement.

e. Not exceed a takeoff weight of 55 pounds (including payload).

6 Reform Act Section 333 (b)

7 AMA Document #540-D
June 10, 2015

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a. Ensure the aircraft is identified by affixing the owner’s contact

information to the outside of the SUAS.

b. Not operate SUASs while under the influence of alcohol or while using any

drug that could adversely affect the PIC’s ability to safely control the

model.

c. Not operate SUASs carrying pyrotechnic devices that explode or burn, or

any device which propels a projectile or drops any object that creates a

hazard to persons or property.

2. SUASs will not be flown unless:

a. The aircraft, control system and pilot skills have successfully

demonstrated all maneuvers intended or anticipated prior to the specific

event.

3. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or

structures and shall avoid endangerment of life and property of others.

4. A successful radio equipment ground-range check in accordance with

manufacturer’s recommendations will be completed before the first flight of a

new or repaired model aircraft.

5. SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC).

6. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25

feet to any individual, except for the PIC and the PIC's helper(s) located at the

8 AMA Documents #922 and #923
June 10, 2015

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takeoff site.

7. Under no circumstances may a pilot or other person touch a SUAS in flight while

it is still under power, except to divert it from striking an individual.

8. The PIC of the SUAS shall:

a. Maintain control during the entire flight, maintaining visual contact

without enhancement other than by corrective lenses prescribed for the

pilot.

b. Fly using the assistance of a camera or First-Person View (FPV) only in

accordance with the procedures outlined in AMA Document #550

using a spotter.

c. Fly using the assistance of autopilot or stabilization system only in

accordance with the procedures outlined in AMA Document #560.

9. The flying area must be clear of all utility wires or poles and an SUAV will not be

flown closer than 50 feet to any above-ground electric utility lines.

10. The flying area must be clear before the engine is started, except for PIC and the

PIC's helper(s).

B. In addition to the above rules outlined by the AMA National Model Aircraft Safety

Code and in an effort to enhance the safety offered by the already safe operations

mentioned above, Civic Mind Media LLC also agrees to be bound by the following

limitations and conditions:

1. Flights will be operated within VLOS of the PIC.

2. Maximum total flight time for each operational flight will be 25 minutes. Flights

will be terminated at 25% battery power reserve should that occur prior to the

25 minute limit.

3. The SUAS will only operate in tightly controlled and limited airspace.
June 10, 2015

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4. A briefing will be conducted in regard to the planned SUAS operations prior to

each flight. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS and

received up-to-date information on the particular SUAS to be operated.

6. The pilot and the PIC's helper(s) will at all times be able to communicate by

voice.

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have

capability to return to a pre-determined location within the security perimeter

and safely land.

8. The SUAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

9. All flights will be conducted on private property and with the written and/or oral 

permission of the property owner(s).

10. Flights will always be conducted in areas that are clear of all people, except for

the PIC and the PIC's helper(s).

11. All flights will be conducted outdoors in visual meteorological conditions (VMC)

and never during severe weather conditions.

12. Flights will not occur in weather conditions that prevent the PIC from operating

within visual line-of-sight (VLOS) at all times or in weather conditions that

dramatically affect the UAS’s flight (e.g. high winds).

13. If an operation occurs in an area where people could inadvertently enter the

area, an operational border will be established with traffic cones. If it’s not

feasible to use traffic cones due to interference with the

photography/videography, the PIC's helper(s) will be responsible for keeping a

safe perimeter around the operation. The operation will cease immediately and

be rescheduled if it’s impossible to establish a safe perimeter around the
June 10, 2015

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operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensive

preventative maintenance plan can be followed, as described in the

“Preventative Maintenance” section below.

The operation of SUASs, weighing less than 5 lbs., conducted in the strict conditions as

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

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 tightly

controlled environment. As a result, they offer a much safer way to capture aerial 

photography, mapping and videography. Furthermore, the proposed operations represent a

safety enhancement to the already safe operations that have been granted by the FAA for

the establishment of the AMA National Model Aircraft Safety Code.

Preflight Action Plan

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a

condition for safe flight. This plan will be improved as needed in order to ensure all known

safety precautions and/or safety precautions suggested by the manufacturer are being

accounted for.

A. Pre-flight Inspection

1. Check that the remote control, and flight battery are all fully charged.

2. Verify that the flight battery is not swollen or damaged in any way. Clean the

contact needles and pads if necessary.
June 10, 2015

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3. Turn the motor shaft(s) with your fingers and verify they are smooth without

excessive play or binding.

4. Verify that the propeller(s) are mounted correctly. Each propeller should spin

all the way down onto the motor shaft.

5. Run finger along the edge of edge blade to check for any rough edges.

6. Flex both side of the propellers’ blades to check for hairline cracks where the

blades connect in the center of the propeller.

7. Verify that the landing gear is secure (not cracked/broken/loose).

8. Verify that the Micro-SD card has been inserted and formatted.

9. Verify that the damping absorbers are not broken and/or worn.

10. Remove the Gimbal guard and camera lens cap.

11. Verify that the camera is secure and clean. Inspect the camera ribbon cables

for tears and/or signs of wear.

B. Power Up

1. Verify that S1 and S2 are in the top position on the remote control.

2. Power on the equipment in the following sequential order:

a. Remote Control (2.4ghz flight control)

b. Insert and attach the flight battery(s).

3. Watch the ArduPilot startup sequence for abnormal indications. The blue LED

stop flashing and go solid after 10 to 60 seconds to indicate a sufficient GPS 

satellite fix (6+ satelites) and has marked the home point (for use by the

failsafe feature).
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C. Ready to Fly

1. Verify that the remote control antenna is perpendicular to the ground

(pointing skyward). Do not point top of antenna at the aircraft.

2. Verify that the blue LED is still solid and still connected to 6+ satellites.

3. Verify GPS condition, flight mode and flight controller status using the 

telemetry system.

4. Arm the SUAS using the button on the aircraft.

Hexacopter - start the motor(s) by pushing the throttle/yaw stick down and to 

the right.

Fixed Wing – verify proper direction of all control surfaces (ailerons, elevator, 

rudder) before starting motor. Start the motor(s) by pushing the throttle/rudder

stick (left control stick) down and to the right.

5. Verify that the motor(s) are functioning normally, are not making any

unusual noises, and are all spinning at the same speed.

6. Verify that the area is still clear of obstructions, people, power lines, etc.

7. Take off

Hexacopter - hover at about 6-8 feet above the takeoff point to verify that the

SUAS has a solid GPS lock. If any abnormalities are noticed (drifting, flying in

circles, etc.), land immediately and repeat the “Pre-flight Inspection” and

“Power Up” sequences.

Fixed Wing – Launch aircraft and maintain a proper angle of ascent to gain at 

least 30 feet of altitude and test for GPS stability.

8. Verify that the hexacopter holds a steady position while yawing 360 degrees.

9. Verify that the hexacopter SUAS response appropriately to all controls –

yaw left/right, pitch forward/backward, roll left/right, and throttle

up/down. (Fixed wing verify control surfaces on the ground before 

launch).
June 10, 2015

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Preventative Maintenance

A comprehensive preventative maintenance plan will be followed in order to ensure the

SUAS’s software is up-to-date, the batteries are in good health, and the aircraft itself is

always ready for safe flight9.

Pilot in Command (PIC) Qualifications

The PIC does not hold an airman certificate or medical certification. Since the SUAS’s are 

similar in size, weight, speed, and operating capability as those currently allowed to be

flown for hobby/recreation, holding the PIC to those same set of standards will allow for an

equivalent level of safety. Additionally, the PIC is a trained and experienced model aircraft 

pilot, builder and designer that has participated in the hobby for the past 10 years building and 

flying various types of model aircraft such as helicopters, aerobatic planes, gasoline driven 

model aircraft and electric aircraft.

The PIC is a computer programmer by profession. Since the SUAS’s are controlled by highly

advanced computer systems and runs on software that must be configured, updated, and

maintained, computer proficiency is a must to ensure the SUAS is ready to be safely

operated in the NAS.

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed

wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating

at 400 feet AGL or lower, within strictly controlled pre-approved airspace. Since there are 

no standards for either private or commercial SUAS pilot certificates, knowledge of airspace

regulations and dexterity in the control and operation of the SUAS acquired from actual 

operation of the aircraft will be the most important factors in establishing an equivalent

level of safety.

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strong

equivalent level of safety, a reduction in environmental impacts, and are free from the

harmful emissions associated with the manned aircraft that are currently used for aerial 

photography, mapping and videography. Due to the size of the SUAS and the tightly

controlled and limited airspace in which the SUAS will operate, approval of this application

presents no risk to the public. Furthermore, the public will be able to legally acquire aerial

photography and videography to help in, but not limited to, advertising homes for sale,
June 10, 2015

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advertising uninhabited home lots, use of photos and video as an aid when researching 

homes for sale on the market, or safely accessing high and/or awkward areas of a home’s

exterior to assess damage that needs to be repaired.

Privacy

Since the areas being photographed or filmed will be on private property, accessed only

after given written and/or oral consent by the property owner(s), and clear of all people,

except for the PIC and the PIC's helper(s), approval of this application presents no risk to

the public privacy.

National Security

Due to the size of the SUAS and the tightly controlled and limited airspace in which the

SUAS will operate, approval of this application presents no risk to national security.

Requested Exemptions

Civic Mind Media LLC requests exemption from the following regulations since it’s not 

possible to fully comply with them, and since attempting to follow them for the purposes of

operating a SUAS would be a burden:

Airworthiness Certificates

14 CFR Part 21, Subpart H

Subpart H 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 Civic Mind Media LLC, 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

USC 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 SUAS. In all cases, an analysis of these criteria

demonstrates that the SUAS operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed, will be at least as safe,
June 10, 2015

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or safer, than a conventional aircraft operating with an airworthiness certificate

without the restrictions and conditions proposed.

Medical certificates

14 CFR 61.23 (a)

This regulation requires pilots of manned aircraft to hold a medical certificate. Since

risks associated with the operation of the proposed SUAS are so diminished from the

level of risk associated with any manned aircraft; the SUAS is of a size, weight, 

speed, and operational capabilities which makes it much safer than any manned

aircraft; since operations will occur in tightly controlled and limited airspace; and

considering that all operations will be on private property that is clear of all people,

obtaining and maintaining a medical certificate would not improve the safety of the

operation. In the very rare case of a mishap, the SUAS being flown will pose

significantly less of a threat than manned helicopters and fixed wing aircraft because

the SUASs are a fraction of the size, a fraction of the weight, will be flown at a

fraction of the speed, carry no flammable fuel, and carry no crew or passengers.

Private pilot privileges and limitations: Pilot in command

14 CFR 61.113 (a) and (b)

These regulations limit private pilots to non-commercial operations. Because the

SUAS will not carry a pilot or passengers; due to the SUAS’s size, weight, speed, and

operational capabilities; and since operations will occur in tightly controlled and

limited airspace, the proposed operations can achieve the equivalent level of safety

of current operations that currently require a commercial pilot’s license.

Furthermore, since there are no standards for either private or commercial SUAS

pilot certificates, knowledge of airspace regulations and dexterity in the control and

operation of the SUAS acquired from actual operation of the aircraft will be the most

important factors in establishing an equivalent level of safety. It cannot be assumed

that a commercial pilot, approved to operate a manned helicopter or fixed wing

aircraft, has the skill or ability to safely operate an unmanned aerial vehicle,

operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace.

Flightinstruction

14 CFR 91.109
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This regulation 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. 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.

Altimetersettings

14 CFR 91.121

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 by confirming the altitude of the launch site shown on the GPS altitude

indicator before flight.

Fuel Requirements for Flight in VFR Conditions

14 CFR 91.151 (a)

This regulation 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 25 minutes of powered

flight. That would make it impossible to meet the 30 minute reserve requirement.

Given the limitations on the SUAS’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.
June 10, 2015

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An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25%

of battery power (whichever occurs first). This restriction would be more than

adequate to return the SUAS to its planned landing zone from anywhere in its 

limited operating area.

Maintenance Inspections

14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2);

14 CFR 91.417 (a) and (b)

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. Maintenance will be accomplished by the

operator pursuant to the aforementioned Phantom user manual and guide. An

equivalent level of safety will be achieved because these small SUASs are very

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

limited periods of time. If mechanical issues arise, the SUAS can land immediately

and will be operating from no higher than 400 feet AGL. As outlined in the

aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in

working order prior to initiating flight and perform maintenance as required.

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.

In accordance with 14 CFR Part 11, the following summary is provided for publication in the

Federal Register:

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart

H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14

CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14

CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55

lbs. or less) in order to safely and legally capture aerial photography, mapping and
June 10, 2015

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videography for use by homeowners, realtors, home builders, developer, 

engineers, architects, home contractors, and/or home inspectors.

The operation of SUASs conducted in the strict conditions outlined above, will provide an

equivalent and/or greater 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 existing operations

conducted with helicopters operating in close proximity to the ground, people, or other

buildings in the vicinity.

Given the small size of the SUASs involved, the slow speed at which they must be operated

in order to capture photos and videos, and the restricted environment within which they

will operate, the SUAS’s demonstrate that they can be operated within 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 SUASs will operate, approval of this application

presents no threat to national security. Given the clear direction in Section 333 of the

Reform Act, the authority contained in the Federal Aviation Act, the strong equivalent level 

of safety surrounding the proposed operations, the significant public benefit – including

enhanced safety, reduction in environmental impacts, no emissions, ability to legally obtain

aerial photography and videography services – the grant of the requested exemptions is in

the public interest. Accordingly, Civic Mind Media LLC respectfully requests that the FAA

grant the requested exemption.

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

operating capability, proximity to airports and populated areas, operation within the visual 

line of sight, public safety, and national security – provide more than adequate justification
June 10, 2015

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to grant Civic Mind Media LLC the requested exemption, allowing for commercial operations

as described herewith.

Sincerely,

Carl Stearns

Founder, Civic Mind Media LLC