US Department Of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or Madam:

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

CFR Part 11; I, Michael A. Nosewicz., owner and operator of Small Unmanned Aircraft 

Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed 

below so that I, Michael A. Nosewicz may operate UASs commercially in airspace regulated by

the FAA., as long as such operations are conducted within and under the conditions outlined 

herein or as maybe established by the FAA as required by Section 333.

I, Michael A. Nosewicz. I am requesting exemption from regulations listed below to perform 

aerial photography and videography of Real Estate and Landscape. All operations will be 

performed with the public's safety and right to privacy safe guarded at all times.

Michael A. Nosewicz. UASs is a rotorcraft weighing less than 55 pounds including payload

(The DJI Phantom 3 Vision Quad Copter). It operates at a speed less than 50 knots and has the 

capability to hover and move in the vertical and horizontal plane simultaneously. It has an auto 

return to launch point when battery power is under 25%.The UAS will operate within the line of 

sight with in a protected flight area as described below and at 200 feet AGL or less with an 

observer located close at hand as to make voice communication possible. These operations will 

not create a hazard to users of the nation airspace, public nor the environment.

I, Michael A. Nosewicz., respectfully request the grant of an exception to the following specific

sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for 

commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b),

91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

I, Michael A. Nosewicz. submit this application in accordance with the Reform Act ,112 P.L.95

331-334, seeking relief from any currently applicable FAR'S operating to prevent Michael A. 

Nosewicz. future commercial use of small UASs to operate in the national airspace system as 

described below. The reform Act section 332 provides for such integration of civil unmanned 

aircraft into our national airspace system as it is in the public's interest to do so. 

Michael A. Nosewicz. UASs meet the definition of "small unmanned aircraft" as defined in

Section 331 and therefor the integration of these UASs are expressly contemplated by the 

Reform Act. 

I, Michael A. Nosewicz., would like to operate its light weight UASs prior to the time period by

which the Reform Act requires the FAA to promulgate rules governing such aircraft. The 

Reform Act directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in national airspace before completion of the rule making 

required under Section 332 of the reform Act. In making this determination, the Secretary of 
Transportation is required to determine which UASs do create a hazard to users of the national 

airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles "may operate safely

in National Airspace System, the secretary shall establish requirements for the safe

operation in national airspace.

DJI Phantom 3s are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 

knots and have the capability to operate in the vertical and horizontal plane simultaneously. The 

UASs will operate only within the line of sight of the operator within a protected flight area and 

at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very small nature of these UASs combined with the safe guards presented below, will allow 

for the safe operation greater than that envisioned by Congress for the FAA to establish and by

exemption allow commercial operations of UASs to commence immediately. Also due to the 

size of UASs and the areas and altitudes they will operate approval of this exception presents no 

national security issues and absolutely minimal safety concerns which have been mitigated 

through our rigorous risk management process. 

Given the clear direction, in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act as amended along with the strong level of enhanced safety, reduced 

emissions, utilizing UASs verses traditional aircraft. As well as the economic impact of greatly 

reducing the cost of aerial photography is thereby benefiting the greater public's interest. 

Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of 

Michael A. Nosewicz:

1. Flights will only occur in the daytime hours,

2. Flights will be operated in the line of sight of the operator( PIC) and Observer,(VSO)

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by 

manufacturers recommendations,

4. The UASs will weigh less that 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew will be at a minimum of operator( PIC) and an observer and/or camera operator(VSO),

7. Operator and crew will remain in contact during the flight operation,

8. The UASs operator will perform a check of the flight area and make certain of the safety of all 

persons in the area,

9. Consent will be obtained from all persons with in the video capabilities of the units to further 

reduce the chance of violating anyone's privacy.

10. All required FAA clearances, will be obtained and distances from airports strictly observed.

11. All UASs will have the capability to return automatically to the operator in a safe manner 

with the auto return function checked and working.
12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned 

to operate the UASs at a safe distance from the main fishing boat.

13. Flights will only operate in VFR conditions.

14. UASs have a function on the control to tell operator the distance away from the operator and 

its battery power remaining.

15. Flight team will communicate by voice and the use of two-way radio if the area is too big to 

hear voice from all team members.

16. UASs will be used to video private outings and functions, boating, jet skiing, kayaking,

fishing trips in the gulf area and sporting events from a safe distance.

17. When operating over or near water the UASs will be equipped with flotation device so that 

recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of 

operations for Michael A. Nosewicz's UASs flights permits exception from Part 21 because they

meet 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA 

to exempt UASs from airworthiness certificates in consideration of weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. 

Michael A. Nosewicz's USAs meets or exceeds each of these elements 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for 

flights at or under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Because the UAS’s in unmanned and will not carry a pilot or passengers, the proposed

operations can achieve a high level of safety of operation without the required pilot

license.

14 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and

registrations. These are inapplicable for the same reasons stated above.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by FAR's this regulation is 

inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UASs this regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining such certifications and

registrations at ME Drone Video LLC operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No's

8607,8737,8738,9299,9299A, 9565,9565B, 10167,10167A, 10602,10700 and 32827.
14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. ME Drone Video LLC 

will only operate its UASs at or below 200AGL. They will be operated on a will defined AOR 

that has been carefully reviewed for hazards and minimizes the presence of any persons not 

essential for these operations. Flights will only be over private property that the owner has 

consented and all persons within this video area also give consent for this filming. Compared to 

flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 

lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk 

to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service 

of aerial photography will greatly enhance safety by reducing the overall risk associated with 

traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to 

fly in close proximity of populated areas and people in general. With the use of small UASs of 

55 lbs. or less, battery operated and fling below 200 feet AGL the risk of injury of people on the 

ground or the crew has been reduced or almost erased. The granting of the use of these small 

UASs by Michael A. Nosewicz will give potential sellers of Real Estate a competitive edge in 

the market place. 

Granting Michael A. Nosewicz the above exemption will allow for the expansion of UAS 

systems into the future for the safe conduct of free enterprise and the enjoyment of the masses.

I, Michael A. Nosewicz respectfully requests the FAA grant its exception without delay. The 

FAA has the authority to issue the exemption sought by Michael A. Nosewicz, pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).