Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 1 of 10

May 5, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE Washington, DC 20590

Subj: Petition for Exemption to Operate the DJI Phantom 2 Vision+ V3.0 Quad-Copter 

Unmanned Aerial System for Commercial Aerial Photography and Videography Purposes

Dear Sir or Madam:

I, Michael Sliter, owner of Hotwire Productions.net, LLC., am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that Hotwire Productions.net, LLC, a multimedia, photography and videography business, 

be exempted from the Federal Aviation Regulations (“FARs”) listed below so that we may operate 

a small ultra-lightweight unmanned aircraft system (“sUAS”) commercially in airspace regulated 

by the Federal Aviation Administration (“FAA”). 

As described herein I, Michael Sliter, am chief photographer / videographer at Hotwire 

Productions.net, LLC., which has acquired a DJI Phantom 2 Vision+ "V3.0" Quadcopter with FPV 

HD Video Camera with intent to operate it for commercial aerial photography / videography 

following exemption and approval by the FAA. 

I am well acquainted with the risks that come with the privilege of operating an aircraft in the 

United States, but also with the opportunities available via new unmanned flight technology. I 

have made numerous flights as a hobbyist and have accumulated more than twenty hours (20) of 

logged flight time with the unmanned aircraft that is the subject of this Petition. I would like to 

combine the benefits of an unmanned aviation platform with my existing profession as a web 

developer, photographer and videographer to further the opportunities for safe, cost-effective 

aerial imaging services for the public at large. I, Michael Sliter, will serve as chief pilot at Hotwire 

Productions.net, LLC. for the proposed use of the sUAS. 

Exemption request would permit operation of ultra-light weight, unmanned (piloted by remote 

control) and comparatively inexpensive sUAS(s) in tightly controlled and limited airspace 

photographing or videographing within property boundaries of individual property owners with 

their permission.

Appendix A – Hotwire Productions.net, LLC Operating Procedures

Attachment B – DJI Phantom 2 Vision+ (User Manual V1.8)
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 2 of 10

I. Contact Information: 

Michael Sliter, 

Hotwire Productions.net, LLC.

PO Box 339

1313 Somerset Road

London, Kentucky 40743-0339

Phone: 606-682-6799

Email: michael@hotwireproductions.net

Website: www.hotwireproductions.net

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Hotwire 

Productions.net, LLC Requests Exemption are: 

14 C.F.R. Part 21 subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 14 C.F.R. 91.7(a); 91.9(b) 

(2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b) 

III. The Extent of relief Hotwire Productions.net, LLC seeks and the Reason He Seeks Such Relief: 

I, Michael Sliter, submit this petition in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating to prevent Hotwire Productions.net, 

LLC’s contemplated commercial use of an sUAS for photographic and videographic use within 

the national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do 

so. Hotwire Productions.net, LLC’s ultra-lightweight sUAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of my ultralightweight sUAS is expressly contemplated by the Reform Act. 

The Reform Act guides the Secretary in determining the types of sUASs that may operate safely 

in our national airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the sUASs; whether the sUAS will be operated near airports or heavily populated 

areas; and, whether the sUAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of 

these items reflect in favor of an exemption for Hotwire Productions.net, LLC. My sUAS utilizes 

four (4) counter-rotating propellers for balance, control and stability. My sUAS is equipped with 

GPS and auto return safety technology. My sUAS weighs less than five (5) pounds (far below the 

maximum 55 pound limit); including camera with gimbal. I, Michael Sliter, consider safety the 

utmost importance with every flight. My small unmanned aircraft is designed to hover in place 

via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability and fear of 

financial loss I will not fly in winds exceeding 12 knot (13 mph). Built in safety systems include a 

GPS mode that allows my sUAS to hover in place when radio controls are released. When pilot 

communication is lost, the sUAS is designed to slowly descend to the point of take-off. Hotwire 

Productions.net, LLC will not operate sUAS near airports, Hospitals nor Police heliports, and will 

not operate near areas where general public is within thirty to one hundred (30-100) yards 

depending on location, conditions and weather. We utilize a crew of two (2), a pilot (“PIC”), and 

a spotter who are constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) 
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 3 of 10

and prepared to land / abort immediately to the nearest and safest ground point should a 

manned aircraft approach the area of operation. 

Our sUAS is capable of vertical and horizontal operations, and is flown only within line of sight of 

the PIC. Utilizing battery power rather than combustible fuels, flights generally last between ten 

(10) to fifteen (15) minutes, with an altitude under two hundred (200) feet. Hotwire 

Productions.net, LLC will utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is twenty (20) to twenty-five (25) minutes as 

tested. Hotwire Productions.net, LLC will not operate sUAS at or below the manufacturer 

recommend minimum charge levels for operation; preferring to remain well within a safe 

operating range to insure adequate communication between radio control and sUAS to eliminate 

potential for crash, loss of control or hazards. Reserve batteries are at hand with each mission to 

insure replacement for sufficient safe level of operation. We do not take any risks that may cause 

a crash, which could create hazards to the public / property / manned aircraft, and we have no 

desire to lose or damage our investment. I have completed dozens of practice flights in remote 

areas on private property as hobbyists simulating flights for future commercial use to gain 

familiarization with the characteristics of this specific sUAS’s performance under different 

temperature and weather conditions. 

I, Michael Sliter, will be Hotwire Productions.net LLC’s chief pilot. I am extremely cautious when 

operating our sUAS / ultra-lightweight unmanned aircraft and will not “create a hazard to users 

of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and 

weight of my sUAS it falls well within Congress’s contemplated safety zone when it promulgated 

the Reform Act and the corresponding directive to integrate sUASs into the national airspace 

system. My Phantom 2 sUAS, used in hobby flight, has a demonstrated safety record and does 

not pose any threat to the general public. 

IV. How Hotwire Productions.net, LLC’s Request Will Benefit the Public As A Whole: 

Hotwire Productions.net, LLC is a small business serving customers in need of professional 

quality web design, photography and videography. We are interested in providing aerial 

photography and videography services to realtors, private property owners and business owners 

located in South-Eastern Kentucky. For many, the expense of aerial photography and 

videography using manned aircraft is cost prohibitive. The advent of sUAS’s used in this business 

environment, and their ability to produce unique images will not only help our small business 

compete with larger businesses, but also provide our realtor customers with their own new 

business value, thus promoting commerce and economic development. Permitting Hotwire 

Productions.net, LLC to immediately fly within national air space furthers economic growth in 

our South-Eastern Kentucky area, and provides a definite benefit to the Realtors and 

property/business owners looking to use aerial photography and videography, both of which 

increase commerce and serve as a benefit and stimulus to the area economy and community. 
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 4 of 10

V. Reasons Why Hotwire Productions.net, LLC’s Exemption Will Not Adversely Affect Safety or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Hotwire Productions.net, LLC has the utmost respect for everyone’s safety and comfort. As it 

concerns to sUAS operations:

1. Our sUAS (DJI Phantom 2 Vision+ "V3.0" Quadcopter with FPV HD Video Camera) weighs 

less than 5 pounds; 

2. Each mission will consist of a crew of 2: one PIC and one spotter;

3. The PIC will have a minimum of 20 logged flights and 20 total hours in the make and 

model of the operating sUAS, including at least 3 flights in the last 90 days;

4. We only operate our sUAS below 200 feet in day VFR conditions (well within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act of 2012);

5. We will not operate the sUAS in Class A, B, C, or D airspace without written approval from 

the FAA;

6. We will not operate within 3 nautical miles of the geographic center of a nontowered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted 

in accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management will be made available to the Administrator upon request;

7. During operation of the sUAS, signs will be posted warning the public that: “Caution: 

Small Unmanned Aircraft Operation in Progress”;

8. If any unauthorized person moves within 200 feet of the operating sUAS, the mission will 

be aborted immediately;

9. Our sUAS only operates for ten (10) to fifteen (15) minutes per flight, severely limiting 

the exposure of any safety concerns towards the public or property;

10. We pilot our sUAS through remote control only by visual line of sight, keeping the sUAS 

within 500 feet of the operator at all times;

11. Our sUAS has GPS controlled failsafe, a flight safety feature whereby it hovers and then 

slowly lands if communication with the remote control pilot is lost;

12. We log flight data and other sources of information to constantly update and enhance 

safety protocols; 

13. Before each flight we assess the environment and we only proceed to operate in 

reasonably safe environments that are controlled, are away from power lines, elevated 

lights, airports and actively populated areas;

14. We conduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance;

15. We always obtain all necessary permissions prior to operation; and we have procedures 

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

VI. A Summary: The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 5 of 10

1. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a)(1). The size, weight and enclosed operational area Hotwire 

Productions.net, LLC’s sUAS permits exemption from Part 21 because our sUAS 

meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt sUASs 

from the airworthiness certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Hotwire Productions.net, LLC’s sUAS meets or exceeds each of the 

elements.

2. 14 C.F.R. 91.7(a) 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.

3. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the sUASs, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

4. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our sUAS 

utilizes electronic global positioning systems with a barometric sensor, and 

altitude information will be provided to the pilot via a digitally encoded telemetric 

datalink to a real-time display.

5. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. Hotwire Productions.net, LLC requests exemption 

from this FAR insofar as it mandates issuance of an airworthiness certificate, for 

the reasons stated in my request for an exemption under 14 CFR Part 21, Subpart 

H.

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My sUASs are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark 

certain words or phrases. Further, two-inch lettering is difficult to place on such small 

aircraft with dimensions smaller that minimal lettering requirement. Hotwire 

Productions.net, LLC requests an exemption from this part. The FAA has previously issued 
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 6 of 10

exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), the petitioner requests an exemption that would allow him to operate 

the Subject UAS for compensation or hire as part of his aerial photography business for 

the reasons articulated in In re Trudeau, FAA Exemption No. 11138, and In re Astraeus, 

FAA Exemption No. 11062. Hotwire Productions.net, LLC will operate the sUAS over 

property where the owner or owner's representative has requested that the operation 

occur. Furthermore, since I meet the knowledge base and skill level for operating an UAS, 

I request an exemption from the requirement that I hold a commercial pilot certificate 

and anything other than a Third Class Medical certificate. 

D. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Our sUAS will never 

operate at an altitude greater than 200 feet AGL, only in safe areas away from the public 

and traffic. Given the small size and weight of the sUAS, its maneuverability and speed 

profile, we can achieve an equivalent level of safety.

E. 14 CFR § 91.151(a) requires a thirty (30) minute fuel reserve for flight in VFR conditions. 

Since maximum flight time is limited to battery capacity, and is less than 30 minutes for 

our sUAS, we will operate our sUAS for no longer than ten (10) to fifteen (15) minutes on 

a full charge. A full charge would allow for a flight time of at least twenty (20) minutes, 

providing a 25% to 50% safety margin. The FAA has previously issued exemptions for 

manned aircraft to operate at less than the minimums prescribed in 14 CFR § 91.151(a), 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief 

has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight 

Rules (VFR) conditions.

F. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The 

above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] 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. . . .” 

To comply with this regulation, the PIC, before each mission, will check the 

manufacturers’ internet service pages, and ensure applicable software and hardware is 

up to date as required, and ensure compliance with any safety bulletins posted. In 

addition, the Operators Manual as provided by the sUAS manufacturer will be revised to 

include specific operating procedures and limitations to comply with the exemptions 

sought as described in section V (see appendix A). The revised Operators Manual will be 

in possession of the crew during operation of the sUAS, and must be made available to 

the Administrator or any law enforcement official upon request. 

 
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 7 of 10

 

 

In summary, Hotwire Productions.net, LLC seeks an exemption from the following Regulations: 

14 C.F.R. 21, subpart H; 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. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a);14 C.F.R. § 

91.407 (a)(1); 14 C.F.R. §91.409 (a)(2); and, 14 C.F.R. § 91.417(a) & (b) to commercially operate 

Hotwire Productions.net, LLC’s small, ultra-lightweight, unmanned aerial vehicle (sUAS) in aerial 

photography and videography operations. Hotwire Productions.net, LLC will utilize safety 

protocols and the implementation of flight operating procedures that exceeds currently 

accepted means and methods for safe flight. Hotwire Productions.net, LLC’s operation of the 

sUAS, weighing less than 5 pounds and travelling at low speeds within limited controlled areas 

will provide an equivalent level of safety as that achieved under current FARs. Accordingly 

Hotwire Productions.net, LLC respectfully requests that the FAA grant our exemption request. 

Conclusion 

I would like to thank the FAA for considering this request. Please do not hesitate to contact me 

should there be a need for additional information. I look forward to working with the FAA in its 

determination, and to being a part of the discussion as the FAA considers how to expand and 

control commercial UAV use in the United States.

Respectfully submitted, 

Michael Sliter, Photographer / Videographer, Owner 

Hotwire Productions.net, LLC

PO Box 339

1313 Somerset Road

London, Kentucky 40743-0339

Phone: 606-682-6799

E-mail: michael@hotwireproductions.net
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 8 of 10

Appendix A – Hotwire Productions.net, LLC’s Operating Procedures 

Safety is our main concern. Owner and crew must be familiar with, and follow these operating 

procedures: 

1. Owner must:

a. Document all maintenance, alterations, and updates in the aircraft records.

b. Any maintenance or alterations that affect the sUAS operation or flight 

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

functional test flight in accordance with the operator’s manual. The PIC who 

conducts the functional test flight must make an entry in the UAS aircraft records 

of the flight.

2. Prior to each mission: 

a. The PIC must familiarize him/herself with all possible safety aspects of the 

mission. This includes but is not limited to:

i. Software versions required (manufacturers web site)

ii. Weather 

iii. Wind (less than 12 knots) 

iv. NOTAMS 

v. Proximity of airports or SUA

3. Prior to each flight: 

a. The PIC must inspect the sUAS and Ground Station to ensure they are in a 

condition for safe flight. 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. This includes but is not limited to:

i. Batteries (full sUAS battery required for each flight, check battery levels 

for transmitter and range extender) 

ii. Inspect propellers, motors, wings and lights

iii. The documents required under 14 CFR §91.9 and §91.203 must be 

available to the PIC at the Ground Control Station of the sUAS any time 

the aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

b. The PIC performs a safety assessment. This includes but is not limited to:

i. If operating within 3 miles of an uncontrolled airport, check that a letter of 

agreement that covers the current mission with the airport manager is 

available to the PIC, and that the operation is conducted under a current 

NOTAM.

ii. Inspect flight area for light poles, trees, utility wires, proximity to helipads, 

hospitals, schools, busy roadways, gatherings of people, SUA.

iii. The PIC provides a safety briefing to the spotter. An agreement is made 

under which conditions the flight must be aborted.
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 9 of 10

iv. Check placement of warning signs: “Caution: Small Unmanned Aircraft 

Operation in Progress” 

v. Identify take-off and landing area. 

c. The PIC performs pre-flight checks:

i. Check all controls neutral

ii. Turn on Power transmitter first, then on sUAS, and Range Extender

iii. Perform GPS alignment according to manufacturer’s operating manual

iv. If alignment successful, flight can start from a safe take-off point

v. Immediately after takeoff perform the following checks:

1. Hover 5-10 feet

2. Check data link 

3. Check video link 

4. Check altimeter 

5. Check GPS 

6. Check time 

d. During each flight: 

i. The sUAS may not be operated by the PIC from any moving device or 

vehicle. 

ii. The sUAS may not be operated at an altitude exceeding 200 feet AGL. 

iii. The sUAS may not be operated at night or at altitudes less than 500 feet 

below or less than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles. 

iv. The sUAS must remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, 

ultralight vehicles, parachute activities, parasailing activities, hang gliders, 

etc.).

v. Flight time is limited to maximum fifteen (15) minutes. 

vi. sUAS must remain within line of sight and within 500 feet of PIC.

e. Emergency during flight. This could include but is not limited to: 

i. Pilot distracted

ii. Spotter signals abort 

iii. Sudden change in weather or wind 

iv. Manned aircraft in the vicinity 

v. People getting within safety perimeter 

vi. Birds 

Immediately: 

i. Determine closest safe landing location to sUAS

ii. Land
Exemption Request

Michael Sliter, Hotwire Productions.net, LLC.

Page 10 of 10

f. After each flight: 

i. Check and log flight time and remaining battery level.

ii. Turn off power to sUAS first, then turn off power to transmitter and range 

extender.

iii. Inspect sUAS for any damage.

iv. Remove warning signs 

Attachment B – DJI Phantom 2 Vision+ (User Manual) 

The PDF version of the DJI Phantom 2 Vision+ User Manual exceeded the 10.5 MB file-size 

upload limit on the Regulations.gov website’s comments section. 

The full user manual can be downloaded directly from the manufacturer’s website in PDF format 

at the following URL:

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual

_v1.8_en.pdf