Petition for Exemption filed under section 333

Petitioner: 

Eagle Eye Media Inc. 

1647 Bridgeview Circle Eagle Eye Media Inc.

Orlando, FL 32824

President: Frank B. Maldonado 

CEO: Jimmy Maldonado

EagleEyeMediaGroup@gmail.com

To: Secretary of Transportation/ FAA

Docket Operations, M-30; U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE, Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Dear Sir/ Madam:

Eagle Eye Media Inc. is petitioning for 333 exemption from the Federal Aviation Administration (FAA) for 

an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (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), 

and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption would 

allow Eagle Eye Media Inc. to operate the DJI PHANTOM 3 Professional quad-copter unmanned aircraft 

system (UAS) to conduct aerial videography and cinematography to enhance academic community 

awareness for those individuals and companies unfamiliar with the geographical layout of the state of 

Florida and produce real estate listing videos and photos.

We support our request with the following information:

Eagle Eye Media Inc. has provided the following information – contained in the petition and supporting 

documentation including: 1) Supplemental Response for Petition, 2) PHANTOM Flying Flow Chart V1.0 

(Simplified Version), PHANTOM 3 Professional Quick Start Manual v1.0, PHANTOM 3 Professional Safety 

Guidelines and Disclaimer Advanced Manual v.1.0, 3) PHANTOM 3 Professional Intelligent Flight Battery 

Safety Guidelines User Manual 4) restricted areas map, 5) personal protocols and controls, and 6) 

Safety/Flight Manual (all hereinafter referred to as operating documents).
Eagle Eye Media Inc. has organized the FAA petition into four sections: 1) the unmanned aircraft system 

(UAS), 2) the UAS Pilot in Command (PIC), 3) the UAS operating parameters and 4) Public Interest.

Unmanned Aircraft System

Eagle Eye Media states that we plan to operate a UAS, the DJI PHANTOM 3 PROFESSIONAL, which is 

comprised of an unmanned aircraft (UA or PHANTOM) and a transportable ground station.

The PHANTOM 3 PROFESSIONAL is a quad-copter with a maximum gross weight of about 3 pounds. It is 

equipped with four rotors that are driven by electric motors powered by a patented Intelligent Flight 

Battery which gives accurate and constant voltage communication to controls. The UA has built in 

integrated flight solutions such as GPS capabilities, GPS-Enabled Return to Home system which kicks in if 

communications are ever lost with the PHANTOM 3 PRO. The UA also has built in visual positioning 

system which stabilizes the UA for further flight safety in/outdoors. The UA has a maximum airspeed of 

31.1 knots. Phantom 3 Pro has a built in Sony EXMOR 4k camera which is built into the UAS and provides 

live 720p visual streaming to the control in real time and has a range of 1.25 miles which also 

demonstrates in real time system controls and flight information such as altitude, vertical/horizontal/ 

ascending/descending directly to monitor on the control. Camera and built in features are included in 

gross weight to his UA, and will operate the UA over various areas in Florida to enhance academic

community awareness and produce real estate listing videos and photos. All specifications found in the 

Quick Start Manual provided with petition. 

We also have obtained UAS insurance for commercial purposes and will provide proof of that with 

operational documentation.

Eagle Eye Media Inc. makes the following representations of operational enhancements which we will

abide by to ensure the exemption provides a level of safety at least equal to existing rules:

• We will only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; and

• We will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance.

Eagle Eye Media Inc. states that given the size, weight, speed, built in intelligence, and limited operating 

area of 1.25 miles ( which a spotter will be used at all times, using Celestron SkyMaster 20-100x70 Zoom

binoculars to keep within sight at all times for further safety) associated with the aircraft to be utilized 
by Eagle Eye Media Inc. an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 

91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted 

and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of 

P.L. 112-95 (Section 333).

Eagle Eye Media Inc. requests an exemption from § 45.23 Marking of the aircraft because the UA will 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, we state 

that two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. Regardless of this, Eagle Eye Media Inc. state that we will mark his UAS 

in the largest possible lettering by placing the word “EAGLEEYEMEDIAINC” and gold, blue, and silver 

stickers on its fuselage as required by § 45.29(f) so that we or anyone assisting as a spotter will see the 

markings. We will never fly in conditions deemed unfit to keep visual line of sight, this includes unfit 

wind conditions, cloudy weather deemed unfit to keep visual line of sight, rain, nor will we operate at 

altitudes lower than 20 feet relative to any object or persons. 

Eagle Eye Media Inc. states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 

91.417(a) and (b) Maintenance inspections may be required and should be granted since they only apply 

to aircraft with an airworthiness certificate. However, we will as a safety precaution always perform a 

preflight and post flight inspection of the UAS before each flight as outlined in the operating documents.

UAS Pilot in Command (PIC)

Driver’s License of PIC included substituting the need for current medical certificate.

 Eagle Eye Media Inc. asserts that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however we can achieve an equivalent level of safety as achieved by

current regulations because the UAS does not carry any pilots or passengers. Further, he states 

that, while helpful, a pilot license will not ensure remote control piloting skills. We further 

indicate that the risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 

61.113 Private Pilot Privileges and Limitations: Pilot in command.

 Regarding UAS operational training, we have flown numerous practice flights in remote areas as 

hobbyist simulating flights for future commercial use to gain familiarization with the 

characteristics of the UAS’ performance under different temperature and weather conditions. 

We further state that we practice computerized simulated flights daily to maintain adequate 

skills and response reflex time. We have over 6 years of experience flying as hobbyist and are 

capable of flying nitro copters which are for the highly skilled and are much more complex than 

the PHANTOM 3 PROFESSIONAL. The (PIC) has had 6 months experience with the current 

PHANTOM 3 PRO model. 
In a supplemental request to the FAA, Eagle Eye Media Inc. requests consideration of a 120 day 

temporary airman certificate in accordance with § 63.13, to allow us time to obtain a private pilot 

certificate or to allow the FAA time to establish minimum UAS airman certification standards.

Public Interest

Eagle Eye Media is dedicated to the safety of the public first and foremost, we have acquired the latest 

and safest in DJI technology in the PHANTOM 3 PRO and will take every precaution as listed in this 

petition to provide the highest levels of safety. Eagle Eye Media Inc. will provide services to Realtors and 

other industry professionals to further the integration of technology into small business firms. We will 

also help those not familiar with certain geographic aspects of Florida to safely explore and advance 

scientific / academic research within our state. All while providing the highest standards of safety 

combining flight experience and the technology the DJI PHANTOM 3 PRO has already integrated. Eagle 

Eye Media Inc. states that aerial videography and photography for geographical familiarization and for 

real estate marketing purposes has been around for a long time through manned fixed wing aircraft and

helicopters. For small business owners though, the expenses have been cost-prohibiting. Granting this 

exemption would allow Eagle Eye Media Inc. to provide this service at a much lower cost. Eagle Eye 

Media Inc. indicates our small UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger aircraft. The petitioner also states that the operation of his 

UAS will minimize ecological damage and promote economic growth by providing information to 

companies looking to relocate or build in the Central Florida area.

UAS Operating Parameters

Eagle Eye Media Inc. will abide by the following additional operating conditions under this exemption:

We shall abide by all procedures contained in the operating documents and will actively analyze flight 

data and other sources of information to constantly update and enhance safety protocols

• operate our UAS below 300 feet and within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation

• operate our UAS for 5-8 minutes per flight;

• land UAS prior to the manufacturer’s recommended minimum level of battery power;

• operate UAS only within visual line of sight (VLOS);

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost;

• conduct all operations under our own personal and flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) 
• Contact respective airports if operations will be within 5 miles to advise them of estimated flight time, 

flight duration, elevation of flight and other pertinent information;

• Always obtain all necessary permissions before any operation; and

• have safety protocols in place to abort flights in the event of safety breaches or potential danger.

• operate in reasonably safe environment that are strictly controlled, are away from power lines, 

elevated lights, airports and actively populated areas away from public and traffic;

• We will not operate within the 4 mile proximity of any airport as required by FAA regulations. Included 

in the operations manual are the NO FLY ZONES listed by DJI which Eagle Eye Media states we will 

strictly adhere to. Florida is a flat geographical area for the most part, our goal to keep a direct line of 

sight will include the help of at least 1 spotter at all times (driver’s license substituted for medical 

certificate) who will use high powered binoculars to keep the UAS in sight at all times. Eagle Eye Media 

Inc. does not plan to fly above the 400ft restriction already set in place. The UAS has a failsafe which 

enables GPS to safely guide the UAS back to the pilot to regain full control if radio communications are 

ever lost. 

• Preflight safety risks assessment will be conducted prior to every UA flight. This will comprise of 

research done days in advanced of location to be flown, including weather conditions, highest point of 

trees and property, geographically familiarizing ourselves with the area using technologies such as 

google earth and google maps, making sure no powerlines are around, research of the population of the 

area through public records, are all part of the preflight safety risk assessment but is not limited to these 

processes. Preflight inspection on the UA and intelligent batteries as detailed in the operations manual 

are always conducted, as well as post flight.

Eagle Eye Media Inc. states that § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. Eagle Eye Media Inc. asserts that since there is currently no certificate applicable to our

operations, this regulation is inapplicable.

Eagle Eye Media Inc. also states that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board the aircraft and given its size, this regulation is

inapplicable. Eagle Eye Media Inc. further indicates an equivalent level of safety will be achieved by

maintaining a hand written flight log for all operations as well as flight manuals at ground station at all 

times.

Also for exemption from; Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must

include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service.

 Safety/flight manuals shall stay with the UAS ground station at all times.

 Proof of insurance will be provided upon receiving exemption.