Date: October 28, 2015

The Producers’Group INC.

280 Huali Street suite 202

Honolulu, Hawaii 96813

Office: 808 255 7988

Email: Haleytom@AOL.com

Mr. Thomas M. Haley, President, CEO

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from:

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. 91.103

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. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14

C.F.R. Part 11, The Producers’ Group Inc (TPGI) hereby applying for an exemption from the

listed Federal Aviation Regulations (" FARs") and any other necessary to allow operation of

Small Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography for the

motion picture and television industry for scripted closed set filming, hereby applies for an

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation

of its 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.

Description of Petitioner

The Producers’ Group Inc. is a whole owned corporation in the State of Hawaii the purpose of

which is the production of motion pictures, television commercial and educational videos.

Use of sUASs: TPGI wants to use the sUASs in the production of feature films, high quality

commercials and educational Videos. Experience or Qualifications of sUASs Operator:

Thomas M. Haley is a licensed (private pilot). Producers group has been around for 25 years,

originally started by my father Bill Haley. TPGI has hands on experience in the production of
feature films and commercial for national television. Mr. Haley is a union member certificate

#3030715 and is in good standing of local 600 (Los Angles) and 665 (Hawaii).

Tech Specs Make:

TPGI will operate the DJI Inspire 1 Pro, Model T600, with a total weight of 2935g or 6.47lbs.

The dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85 inches. Under

still air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or

25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane

simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6-cell

4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI

1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controller with an

operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an operating

frequency of 5.728GHz – 5.850GHz. http://www.dji.com/product/inspire-1/spec

Maintenance Program

TPGI in-house and out Source maintenance program. In house maintenance will be sustained by

an inventory of manufacture produced parts and manuals. Out sourced maintenance will be

performed by the manufacture of the sUASs. 

TPGI will maintain all appropriate safety training, and technical advancements in field of sUASs

flight as a way to provide my clients with the best and most current techniques while ensuring all

safety rules are followed. An up-to date library of FAA Rules and Safety manuals and all

technical material from manufactures of the sUASs.

Community Benefit

By making the UAV available to:

Government agencies extremely beneficial for emergency first responders, energy industries, and

the film cultural industry: this technology will keep human lives safe by providing a proven

product that has been tested to meet the highest safety standards for the use by government and

non-government entities. Industry will have a local resource on how to operate cameras and how

to conduct operations safely and responsibly. In addition, the use of cutting edge cameras and

GPS guidance equipment will provide a superior level of safety.

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

3) Controlled as to access

4) Would provide safety enhancements to the already safe operations in the film and television

industry presently using conventional aircraft.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation's (the FAA Administrator's) responsibilities to "... establish requirements for the

safe operation of such aircraft systems in the national airspace system." Section 333(c) of the

Reform Act.
Regulations from which the 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. 91.103

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. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (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 of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (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 sUASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following:

• The sUAS's size, weight, speed, and operational capability;

• Operation of the sUAS in close proximity to airports and populated areas; and

• Operation of the sUAS within visual line of sight of the operator.

Reform Act§333(a) lastly, 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.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40 101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14

CFR §91.203 (a)(1).

TPGI sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, under normal 

conditions at a speed of no more than 50 knots and have the capability to hover, and move in the vertical 
and horizontal plane simultaneously. They will operate only in line of sight and will operate only within 

the approved locations. 

1. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace 

system or the public.

2. Given the small size of the sUASs involved and the restricted sterile environment within which they 

will operate, the applicant falls squarely within that zone of safety (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 the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs for movie and television operations, the grant of the requested 

exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant 

the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the current regulatory structure because the 

proposed operations represent a safety enhancement to the already safe movie and television filming 

operations conducted with conventional aircraft.

These limitations and conditions to which TPGI agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 

25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and the Camera 

Operator.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot's certificate and/or third class 

medical, or US Driver's License. The observer will hold at least a third class medical.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who 

possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person 

can also be designated as PIC.

8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. The Manual 

requires the establishment of a "Security Perimeter" for the flight operations area.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production 

activities. It will be mandatory that all personnel who will be performing duties within the boundaries of 

the safety perimeter be present for this briefing.
10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate Flight Standards District Office.

11. The operator will obtain the consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced 

to 30 feet based upon an equivalent level of safety determination, as required by the Manual. With the 

advanced permission of the relevant FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed 

shoot as required by the Exemption.

13. Pilot and observer will have been trained in operation of UAS generally and received up to- date 

information on the particular UAS to be operated as required the Manual.

14. Observer and pilot will at all times be able to communicate verbally.

15. Written and/or oral permission from the relevant property holders will be obtained.

16. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a)(1)

Subpart H, entitled Airworthiness Certificates, 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 the Applicant, an exemption from Part21 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 U.S.C.§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 UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as 

set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator, pursuant to the Manual's requirements, and under the 

requirements and in compliance with local public safety requirements, to provide security for the area of 

operation as is now done with conventional filming. The FAA will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with motion 

picture and television production, provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
14 C.F .R. § 45.23 {b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

placed. Given the size of the sUAV, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the 

UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command Sections 61.113 

(a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot or 

passengers, the proposed operations can achieve the equivalent level of safety of current operations by 

requiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's 

license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the 

sUAS is remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the job contract. The level 

of safety provided by the requirements included in the job contract exceeds that provided by a single 

individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated

with the operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with 

a private pilot as the PIC exceeds the present level of safety achieved by 14 C.P.R. §61.113 (a) &(b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, an 

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point 

where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will 

be needed. An equivalent level of safety will be provided as set forth in the Manual. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 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. See Exemption 

Nos.5778K & 9862A. 

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.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption

is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may 

be needed to allow such operations. As set forth herein, except for the limited conditions stated in the

Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a restricted 

area with security perimeter, where buildings and people will not be exposed to operations without their 

pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations as set forth in flight plan. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein 

and the lack of flammable fuel, any risk associated with these operations is far less than those presently

presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, 
the low-altitude operations of the sUAS will ensure separation between these small-UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

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, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) 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 40 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS'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.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners 

or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, limiting sUAS flights to 10minutes would greatly reduce the 

utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 

25% of battery power whichever happens first. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate....

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of 

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs and 

is operated without an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS.
An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them; to the extent they are applicable to 

the sUAS. The P AA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 9816A, and 10700.

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

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 Part43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight 

and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure 

that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. 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.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. Filming will be of people who have also consented to being filmed or otherwise have 

agreed to be in the area where filming will take place. 

Set forth below are pictures of aerial filming conducted in day environment, as flown today in highly 

populated and/or urban areas, with turbine powered helicopters. The grant of this exemption request will 

provide improved safety in both day and night operations.

Summary

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

TPGI seeks an exemption from the following Regulations: 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. 91.103

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. 91.405 (a)

14 C.F.R. 407 (a) (1)
14 C.F.R. aoe @)(2)

14 C.F.R. ar7 @) &,(b)

TPGI to operate Inspire 1 pro sUAS for aerial photography for the motion picture and television indusfry

for scripted closed set filming and sUAS aerial services. This authorization will be used to provide

support services for photography, film and movie production in a safe environment and in full compliance

with federal guidelines. If an exernption is granted to TPGI will have a unique opportunity offer education

to change the present and an innovative approach to the future. Along with this, brings a chance to share

information that will educate and elevate the State of Hawaii and neighboring states across the sea to

become more respectfrrl and responsible operators, hobby enthusiasts and future professional

entrepreneurs of UAS. By granting TPGI request for exemption will also enhance safety and reduce

current risk levels as TPGI will operate at lower altitudes and in controlled airspace.

In closing TPGI has strong ties to his community and the ability to keep its citizens informed about the

product and its potential services. This offers a unique role to affect positive change. . . if exemption is

granted. By his relationship with UAS's and the continued sharing of cutting edge techniques and

extraordinary safeguards in place, the likelihood of death or serious bodily injury are significantly

reduced.

Drone Services Hawaii LLC Exemption#12675 helped educate and developed Petition for exemption for

TPGI the end document usor. This step was initiated after Alaska UAS interest group annual meeting

2015. This action is a new way forward to ensure a higher level of Safety. Sharing data across exemption

holders will be the way to move forward in solving sUASs integration into the NAS.

TPGI respectfully requests that the FAA grants its exemption request wilhout delay. The FAA has the

authority to issue the exemption sought by TPGI pursuant to the Federal Aviation Act, 85 P.L.726

(1958), as amended (the uAct').

Sincerely,

Mr. Thomas M. Haley, President, CEO

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