December 1,2015

Michael P Palleschi

16 Clarence Place

Staten Island , NY 10306

(917)­686­0999

mpalleschi514@gmail.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services.

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

and 14 C.F.R. Part 11, Michael P Palleschi , a freelance videographer, hereby applies for an

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our

Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal

Aviation Administration (FAA) so long as such operations are conducted with 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 and 3. Controlled. The proposed exemption, if granted, would allow

Brian Johnson to conduct commercial operations of small, unmanned aircraft systems ("UAS")

meeting or exceeding all of the operational and safety requirements Congress has set forth in

Section 333.

The requested exemption would permit Michael P Palleschi to pursue his commercial interests

in providing services to clients using a small advanced sUAV in the following areas: Real Estate,

Marketing, Land Management/Surveying,Aerial surveying ,Remote sensing,Agricultural support,

Aerial filmmaking and photography,Construction site inspections and monitoring, Wildlife and

forestry monitoring, Educational and research operations and Special Events. Michael Palleschi

states that all sUAS flights will occur over private or controlled access property and will do so

with the property owner's consent and knowledge and that only people who have consented or

otherwise have agreed to be within the UAS’ radius during filming and photography applications.

Michael Palleschi has demonstrated the ability to safely and effectively fly the sUAS DJI

Phantom 3 which will be used for all commercial and private purposes. Michael Palleschi

complies with local ordinances and laws regarding the operation of sUAS, and adheres to all

weather and environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.
I, Michael Palleschi, am seeking the exemption because I am committed to complying with all of

the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate

the sUAS in the manner that I have described, and for the purposes that I have described.

Without the exemption request granted, I would be unable to safely and effectively run my

business, and it is my intention to comply with the FAA and obtain an exemption of the following

regulations.

The following contains my list of regulations from which I am seeking exemption, and a

complete list of responsibilities I assume as operator; it also contains information regarding the

aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 ­ 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will

require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed­set motion picture and television filming are not

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine compliance

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than

the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL).

Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than corrective

lenses, as specified on the PIC’s FAA­issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual
line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be

able to communicate verbally at all times; electronic messaging or texting is not permitted during

flight operations. The PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the VO can perform the

duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter

referred to as the operating documents. The operating documents must be accessible during

UAS operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and 4 limitations in this exemption and the procedures outlined in the

operating documents, the conditions and limitations herein take precedence and must be

followed. Otherwise, the operator must follow the procedures as outlined in its operating

documents. The operator may update or revise its operating documents. It is the operator’s

responsibility to track such revisions and present updated and revised documents to the

Administrator or any law enforcement official upon request. The operator must also present

updated and revised documents if it petitions for extension or amendment to this grant of

exemption. If the operator determines that any update or revision would affect the basis upon

which the FAA granted this exemption, then the operator must petition for an amendment to its

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions

arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional

test flight prior to conducting further operations under this exemption. Functional test flights may

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The

functional test flight must be conducted in such a manner so as to not pose an undue hazard to

persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre­flight inspection and determine the UAS is in

a condition for safe flight. The pre­flight inspection must account for all potential discrepancies,

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that

affects the safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a condition for safe

flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also
meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is

rated on his or her pilot certificate. 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under this

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training

the operator’s PICs and VOs (training, proficiency, and experience­building) and determining

the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption are permitted under the terms of this exemption. However,

training operations may only be conducted during dedicated training sessions. During training,

proficiency, and experience­building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights under

special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an

ARP, the center of the airport symbol as denoted on the current FAA­published aeronautical

chart, unless a letter of agreement with that airport’s management is obtained or otherwise

permitted by a COA issued to the exemption holder. The letter of agreement with the airport

management must be made available to the Administrator or any law enforcement official upon

request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre­determined location within the private or controlled­access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather

conditions) there is enough available power for the UA to conduct the intended operation and to

operate after that for at least five minutes or with the reserve power recommended by the

manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations

shall be conducted in accordance with an ATO­issued COA. The exemption holder may apply

for a new or amended COA if it intends to conduct operations that cannot be conducted under

the terms of the attached COA. 6

22. All aircraft operated in accordance with this exemption must be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the
Ground Control Station of the UAS any time the aircraft is operating. These documents must be

made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at

all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently

protect nonparticipating persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such protection. If a situation

arises where nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately in a manner ensuring the safety of nonparticipating

persons; and b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not present an undue

hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating

persons under this exemption.

27. All operations shall be conducted over private or controlled­access property with permission

from the property owner/controller or authorized representative. Permission from property

owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the operational area as defined by the applicable COA must be reported to the FAA's UAS

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of

Exemption Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video

gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced

noise and as such, a much smaller environmental impact which promotes public safety.

Michael Palleschi is petitioning for an exemption to operate a DJI Phantom 3 with a built­in

stabilized HD camera and GPS safety features which limit its ability to limit the height it flies

above ground level (AGL), to limit the radius of the distance it flies from the operator and to

exclude it from operations within designated Class B, C and D airspace including a no­fly zone

feature.

The DJI Phantom 3 has a failsafe function that is triggered in the event communication is lost

between the sUAS and the main controller transmitter.At that time, the sUAS will return to its
point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight

and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

• The petitioner will only operate its sUAS in line­of­sight of a pilot and/or observer and will

operate at sites that are `sufficient distance' from populated areas within the sterile area

described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to

users of the national airspace system or the public."

• When flying the sUAS within three (3) miles of an airport, airport operators will be notified and

the operator will give the right­of­way to avoid flying in the proximity of full­scale aircraft.

Maximum flight time for each operation will be 30 minutes.

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time

to safely land the sUAS.

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet

AGL, and not more than 200 feet above an elevated platform from which videography is

planned. • Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS

observer, and the camera operator.

• The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate

and a current FAA medical certificate.

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e.

camera, lens, and stabilized gimbal).

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously

move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which it will

operate, True Cinema Entertainment’s operations adhere to the Reform Act's safety

requirements.

Conclusion

As pointed out in this application, all the SUAs which I would use, under authorization by the

US DOT­FAA, are small, light­weight devices operated within the line of sight of the

Pilot­in­Command (PIC), less than 400 feet above the ground and outside 5 miles from any

airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the

air traffic control authorities (ATC) have been notified and have authorized each flight within a

radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general

sale on the market around the world and have often been used as Model Aircraft in the USA.

We a re certain that the studies conducted until now by the FAA, about Section 332, Public Law

112 ­95, 2014, have already provided you with the assurances on the airworthiness of SUAs

such as ours.
For the foregoing reasons, the exemptions requested herein should be granted and Michael P

Palleschi should be permitted to conduct small UAS operations in accordance with its manuals

and all other operating parameters deemed necessary and appropriate by the FAA. The

submission of this application and its contents is the best demonstration that indeed it is

possible to pursue the authorization process so that some SUAs may be used for legitimate

commercial activities and under reasonably safe conditions.

I respectfully request exemption under Section 333 to enable Michael P Palleschi to operate

efficient, limited, low­risk commercial sUAV operations for the activities stated respecting at all

times the space and privacy of citizens and property whilst keeping our skies safe.

Sincerely,

Michael P Palleschi
EXEMPTION REQUESTS

Michael P Palleschi requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we

request an experimental certificate be issued for the DJI Inspire 1 under either or both of the

following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show

compliance with the airworthiness regulations including flights to show compliance for issuance

of type and supplemental type certificates, flights to substantiate major design changes, and

flights to show compliance with the function and reliability requirements of the regulations. Since

the experimental certificate can be used for commercial purposes such as market surveys, sales

demonstrations, and customer crew training, we would expect that an experimental certificate

would permit our commercial purpose as well. The aircraft will not carry persons or property, will

not carry fuel, and will only fly under strict operational requirements.

Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we

propose that the UA will be at least as safe, if not safer, than a conventionally certificated

aircraft performing the same mission. If an experimental airworthiness certificate is not

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H.

and the requirement for airworthiness certificate in general. Citing the equivalent level of safety

outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or

pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be

placed, and may not have a registration number assigned to it by the FAA. We propose to

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on

the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer)
and others in the vicinity of the aircraft while it is preparing for launch will be able to see the

designation. Additionally, we feel that the permanent placard discussed in the previous

paragraph will provide the aircraft's registration information at the ground station. Finally, we will

display at the ground station a high contrast flag or banner that contains the words "Unmanned

Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within

3/4 NM of the ground station, the

banner should be visible to anyone that observes the aircraft and chooses to investigate its

point of origin.

14 CFR 61.113 Private pilot privileges and limitations Pilot in Command and 61.133 Commercial

pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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. Our proposed operations require that the PIC

must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot

carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even

though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no

such certificate will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight

manual information is available to the aircrew while operating the aircraft. We request an

exemption to this requirement since the aircraft is not only too small to carry documentation, the

documentation would not be available to the crew during flight operations. To obtain an

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved

sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is

in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls." The sUAS System ground

based control station consists of a small hand­held radio transmitter and while it does not offer a

second set of "controls", both the student and instructor can, and will, operate the single set of

controls simultaneously. With both student and instructor having "hands­on" the controls during
flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of

safety. ∙

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated

areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or

structure. Since the typical mission of the sUAS would be photography or survey of persons,

vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items

listed. Operations will only be flown over property or persons where permission has been

obtained and careful pre­planned has been performed. The aircraft will be operated at a low

altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or

property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard

to persons, vehicles and structures is minimal compared to manned aircraft, which should be

considered in granting the exemption. ∙

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter

setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio

from the sUAS on­board computer to the d1splay screen held by the PIC, providing a constantly

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day­VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy

reserve as a safety buffer for delays to landing. The sUAV is battery operated and the maximum

duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the

aircraft will never fly more than 1/8 NM from the point of intended landing, a full battery charge

at launch will ensure that we meet the reserve energy requirement of this paragraph. We

request an exemption to the word "fuel" and ask for an equivalent interpretation with the word

"energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned

to the aircraft and a registration certificate must be aboard the aircraft. Additionally,

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds,

the sUAS is too small to carry documentation, does not have an entrance, and is not capable of
carrying passengers or crew. To obtain an equivalent level of safety and∙ meet the intent of

91.203, we propose that documents deemed

appropriate for this aircraft by the FAA will be located with the crew at the ground control station

and available for inspection upon request. In order to identify the aircraft, we propose that the

information found on airworthiness and registration certificates be permanently affixed to the

aircraft via placard containing the following information plus the word "EXPERIMENTAL" to

satisfy the requirement of

14 CFR 45.23.

14 CFR Subpart E (91.401­ 91.417)­ Maintenance, Preventive Maintenance, Alterations.

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43. 7" after maintenance and inspection. It is our intention that the PIC perform maintenance

and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in

addition conduct detailed inspections after every two hours of flight. Maintenance performed by

the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections

and updating software and firmware for the on­board computer. The manufacturer or their

designated repair facility will perform all other maintenance. The PIC will document work

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity

of the aircraft, the PIC can ensure an equivalent level of safety.