Section 333 Exemption Petition

Mark W. Garza Excelsior Springs,

Missouri , 64024
Phone: 254

- 535

- 3329 Email: GarzaMW@yahoo.com

01/ 26/2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590

Re : Exemption Request Sectio n 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 14 CFR Part 21; 14 CFR 45.23 (b); 14 CFR 45.27 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405 (a); 8900.227 §16 (c) (4) and §16 (e) (1)

Dear Sir or Madam, I, M ark W. Garza , am writing pursu ant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, M ark
W. Garza , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed belo w so that I, M ark W. Garza , may operate my small ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, M ark W. Garza , will pr imarily use my professionally built ( DJU Inspire 1, DJU Phantom 3, AGRAS MG

- 1 , DJI Matrice 100 ) UAS equipped with cameras for the following applications: Closed

- Set Film Operations on Film and Television Productions, as well as aerial vide ography/cinematography to safely enhance films and commercials ; augmentation of real estate listing videos ; education, Aerial Data Collection to include agricultural inspections and building and construction zone inspections. Inspection on towers, poles, pipelines, power lines, cables , bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, and buildings. Golf Courses, Special Events, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Animal tracking, Forestry & logging, Insurance Assessments, Surveys, Mining, Traffic monitoring, and sporting events2

2 M ark W. Garza ’ s , exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of community and government use videos, permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in a reas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Fur thermore, it is my intent to assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific video and photography usage by sharing information with the FAA as I, M ark W. Garza , record flight data and other pertinent informati on gained through permitted flight operations.

In addition, granting my, M ark W. Garza ’ s , exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace syste m, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search a nd Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, closed

- set motion picture film operations and television, and structure inspections, to aid state and local agency’s. Further I, M ark W. Garza , will conduct my oper ations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below, I, M ark W. Garza

, respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’ s to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems . A grant that will ultimately allow UAS’s to play a more positive role in our local community by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel

- a potential public hazard in and of itself.

I. Contact Information:

M ark W. Garza

Excelsior Springs

, Missouri 64025
Phone: 254

- 535

- 3329 Email: garzamw@yahoo.com

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

M ark W. Garza Requests Exemption are: 14 CFR 21; 14 CFR 61.113 (a) & (b);

14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 14 CFR 417 (a) & (b). 14 CFR 45.23 (b) 14 CFR 45.27 (a) 14 CFR 91.7 (a)3

3 14 CFR 91.9 (b) (2)
14 CFR 91.103
14 CFR 91.105
14 CFR 91.109
14 CFR 91.119
14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 8900.227 §16 (c) (4) and §16 (e) (1)

III. The Extent of relief M ark W. Garza Seeks and the Reason He Seeks Such Relief: I, M ark W. Garza , submit this application in accordance with the Reform Act, 112 P.L. 95 §§

331

- 334, seeking relie f from any currently applicable FARs operating to prevent me M ark W.
Garza , contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil

u nmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, M ark W. Garza ’ s , ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of m y ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct exp erience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspac e system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a).

Ea ch of these items reflect in favor of an exemption for me, Mark W. Garza . My UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. My UAS’s are equipped with the following via video and data telemetry:

1) Altimeter 2) At titude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery Left with approximate time

. 11) Loiter and circle mode.4

4 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology.

Each UAS weighing less than thirty (35) pounds (far below the maximum 55 pound limit); Including camera(s) with or without gimbal (a camera stabilize r). I, Mark W. Garza , considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter via GPS and can be operated in winds up to 30.4 knots (35mph) wind. For safety, stability an d fear of financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released.

With three (3) modes to choose from, I will f ly with the modes safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is des igned to slowly descend to point of takeoff and or to land at point of launch after ascending to a pre

- set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the current position of the UAS. This failsafe altitud e will not be set more than 200ft and is determined before each flight.

I, Mark W. Garza , will not operate my UAS near airports, hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my loca tion or I suspect manned aircraft may approach near my location. My UAS’s are capable of vertical and horizontal operations, and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generally last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (15 0) feet. (3 )Smart Mode includes, position hold, self

- leveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption
between RC transmitter and UAS.

I, Mark W. Garza , utilize a f resh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; prefe rring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for suffic ient safe level of operation. I do not believe in tak ing risk that may cause a crash that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a h obbyist simulating flights for future5

5 commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

I, Mark W. Garza , am extremely cautious when operating of my UAS/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 UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system Mark W. Garza’s

UA S, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How Mark W. Garza’s Request Will Benefit the Public as a Whole: Aerial videography for geographical awareness, educatio n, search and rescue, land management, structure inspections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies, average homeowners and property owners the expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense; depriving non

- luxury owners and lower budget companies from a valuable marketing tool. Use of the UAS in lieu o f a manned aircraft would also enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilit ate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that can not be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and f ertilizer and conservation of water as well as increased
crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photogra phic data for these purposes on a ‘for hire’ basis acting as an independent
contractor.

V. Reasons Why M ark W. Garza ’ s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: M ark W.
Garza ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, M ark W. Garza , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land and structured owners. For development in cooperation with the FAA. In addition I, M ark W. Garza , submit the following representations of enhancements to curre nt aerial videography and photography: My UAS’s weigh less than fifteen ( 15 ) pounds complete with an integrated ultra

- light weight camera ; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the

FAA Modernization and Reform Act of 2012); My UAS only operate for 3

- 30 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by line of sight; and have live video feed for a secondary pilo t to monitor video recording; I receive a live telemetry feed from my UAS during all flights which6

6 include remaining battery voltage, distance, altitude, and any anomalies that may occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz

- 2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz

- 5.875Ghz frequencies in accordance with CFR 47, Part 15.

My UAS’s have a GPS controlled flight controller

- a flight safety fe ature whereby it hovers or circles and then lands at the GPS takeoff point if communication with the remote control pilot is lost; I actively record and analyze flight data through the DJI Inspire 1, DJI phantom 3

, DJI
AGRAS MG

- 1 , DJI Matrice flight controller app to constantly u pdate and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, durin g which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger. My, M ark W. Garza ’ s , safety protocols provide a l evel of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness real est ate, structured inspections, land management and search and rescue. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra lightweight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the po tential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has been experimentally operated for familiarization/competency and wi ll continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certi ficates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my, M ark W. Garza ’s, UAS permits exemption from Part 21 because my UAS meets (an d 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 p ieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity7

7 to areas such as airports and dense populations. My, M ark W. Garza ’ s , current and projected
UAS's meet or exceed each of the elements.

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 inappli cable.

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 UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintai ning 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.

14 CFR 91.103: Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety o f flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual. These actions will provide an equivalent level of safety.

14 CFR 91.105: Flight crewmembers at stations This regulation defines the obligations of the flight crewmembers during takeoff and landing, and while en route. Th is part is not applicable due to the sUAS is not carrying any flight

c r ewmembers. Mark W. Garza will not operate the aircraft unless someone is at the controls at all times. Each flight will be manual, with the exception when the sUAS goes into emergency

m ode like return

- to

- home. This will achieve an equivalent level of safety to 14 CFR. 91.105, because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft but on the ground.

14 CFR 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. By design, sUASs and remotely piloted aircra ft 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 previously approved exemptions for aircraft without fully functional du al controls. 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, the ability to control the sUAS via radio signals from the controller, and by the size and speed of the aircraft.

14 C.F.R. § 91 .121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing”

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certific ations and registrations. They are inapplicable for the same reasons described above. The equivalent level8

8 of safety will be achieved by maintaining any such required certifications and registrations by

me, M ark W. Garza

.

14 CFR 45.23 (b): Marking of the Aircraft and 14 CFR 45.27 (a): Location of marks; nonfixed

- wing aircraft This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft t o be marked with letters between 2 inches and 6 inches high "limited," "restricted," "light

- sport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The equivalent level of safety will be provi ded by having the sUAS marked with the word "Experimental" will be placed one of the arms of the sUAS in compliance with45.29 (f) and on both sides of the UAS in compliance with 45.27 (a) where the pilot, observer and others working with the sUAS will see the identification of the sUAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A

.

14 C.F.R. § 61.113: Private Pilot Privile ges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, M ark W. Garza , The sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. The
PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the

op eration of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 300f close AGL; safely below the standard of 400 AGL. I, M ark W. Garza

, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety wi ll be achieved.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to operations in sterile and controlled environments as outlined in the Manual, and has a limited range and flight time which require an exemption from 14 CFR 91.151 (a).The battery powering the sUAS provides approximately 25 minutes of powered flight.
To meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS flights would not be
p ossible to perform. Given the limitations on the sUAS's proposed flight area and the locat ion of its proposed operations within a predetermined area, a longer time frame for flight in daylight is reasonable. Mark W. Garza believes that an exemption from 14 CFR 91.151 (a) falls within the scope of prior exemptions. See Exemption 11191 (allowing Singer’s Creation to operate without compliance with FAR 91.151 (a)). Operating the sUAS, 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 r eserve fuel, does not engender the type of risks that Section
91.151 (a) was intended to alleviate given the size and speed of the sUAS. The sUAS calculates battery reserve in real time. The sUAS has two levels of low battery capacity warning that are presented on the monitoring system. The first appears when the9

9 battery has less than 30% power and the second appears when it has less than 15% power. The sUAS will return to its ground station with at least 15% battery po wer reserve should that occur prior to the 25 minute flight time. An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 15% of battery po wer (as determined by the onboard monitoring system and the pilot), 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

e xemptions have be en granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and 11191.

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

Manual

. The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribe d 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. . . .”These Regulations only apply to aircraft with an airworthin ess certificate. They will not, therefore, apply to my, M ark W.
Garza ’ s , UAS. However, as a safety precaution I inspect my UAS before and after each flight.

8900.227 Paragraph 16 (c) (4) PIC Medical. and Paragraph 16 (e) (1) Observer Medical. This policy provides that both the PIC and observer must have a valid FAA second class medical certificate issued under part 67 in order to perform as a pilot or observer. Requiring the crew to meet the same medical requirements as commercial pilot carrying passengers in a large aircraft is an unnecessary burde n. We propose that the minimum medical requirements be vision corrected to 20/20 and a valid, state

- issued driver's license. The risk of both the PIC and observer becoming incapacitated at the same time and suddenly is very low. Further, since the sUAS is operating close to the ground, it could be brought in for landing in a very short time if incapacitation was suspected. Finally, the sUAS's that will be operated are equipped with an automatic return to home feature which would provide a final level of safety. We feel this would provide an equivalent level of safety

.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91:

Airworth iness Certificates, Manuals and The Like. 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 opera tional area of my UAS permits exemption from Part 21 because my, M ark W. Garza ’ s , UAS meets 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 un der 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 UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 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. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of10

10 the UAS's, this Regulation is inapplicable. An equivalent level of safet y will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures fo r any damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, M ark W. Garza seeks an exemption from the following Regulations: 14 CFR 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR §§ 61.113 (a) & (b); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 14 CFR Part 21; 14 CFR 45.23 (b); 14 CFR 45.27 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405 (a); 8900.227 §16 (c) (4) and §16 (e) (1) to commercially operate my, M ark W. Garza ’ s , small unmanned vehicle/lightweight unmanned aircraft vehicle for Closed

- Set Film Operations on Film and Television Productions, as well as aerial vide ography/cinematography to safely enhance films and commercials ; augmentation of real estate listing videos ; education, Aerial Data Collection to include agricultural inspections and building and construction zone inspections. Inspection on towers, poles, pipelines, power lines, cables , bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, and buildings. Golf Courses, Special Events, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Animal tracking, Forestry & logging, Insurance Assessments, Surveys, Mining, Traffic monitoring, and sporting events

.

F. Additional FAA Required Operating Conditions and L imitations

When not covered elsewhere in this Operations Manual, the following conditions and

limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s)

and equipment

2. The UA may not be flown at a speed exceed ing a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level
(AGL), as indicated by the procedures specified in the operator's manual. All

altitudes reported to ATC must be in feet AGL.

4. The UAS 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 state driver’s license.11

11 5. All operations must utilize a visual observer (VO). 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.

6. If a discrepancy exists between these limit ations and any procedure outlined elsewhere

in this operations manual, the conditions and limitations herein take precedence and

must be followed.
7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe

flight. If th e 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. The Ground

Control Station, if utilized, must be included in the preflight inspection. All

maintenance and alterations must be properly documented in the aircraft records.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or flight characterist ics, 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.

9. The ope rator must follow the manufacturer's UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft
maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must b e established and identified in the operator's manual. At a minimum,

the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed contro ller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator12

12 10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a
current state driver’s license. 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/her pilot

certificate.

11. Prior to operations conducte d for the purpose of motion picture filming (or similar
operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single

blade or multirotor). Prior documented flight experience that was obtained in compliance

with applicable regulations may satisfy this requirement. Training, proficiency, and

experience

- buildin g flights can also be conducted under this grant of exemption to

accomplish the required flight cycles and flight time. During training, proficiency, and

experience

- building flights, all persons not essential for flight operations are considered

non

- partic ipants, and the PIC must operate the UAS with appropriate distance from non

participants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14
CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS

to be utilized for operations under the exemption and three take

- offs and three landings in the

preceding 90 days. Training , proficiency, experience

- building, and take

- off and landing

currency flights can be conducted under this grant of exemption to accomplish the required

flight time and 90 day currency. During training, proficiency, experience

- building, and take

- off

and lan ding currency flights, all persons not essential for flight operations are considered non

participants, and the PIC must operate the UAS with appropriate distance from non

- participants

in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual

observer (VO) must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test must be

developed and imp lemented by a qualified person designated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and made

available to the Administrator upon request.13

13 14. Prior to operations conducted for the purpo se of motion picture filming (or similar

operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot

must be successfully completed and documented. This documentation must be available for

review upon request by the Admin istrator. Because the knowledge and airmanship test

qualifications have been developed by the operator, and there are no established practical

test standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, th e petitioner will conduct these tests in accordance with the operator’s

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting

production personnel, below an altitude that is hazardous to persons or property on the surface
in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety

mitigations for authorized and consenting production personnel. At all times, those persons

must be essential t o the closed

- set film operations. Because these procedures are specific to
participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is

necessary for reductions to the distances specified in the petitioner’s manuals. This is

consis tent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1
Issue a Certificate of Waiver for Motion Picture and Television Filming

.

17. Regarding distance from non

- participating persons, the operator must ensure that no

persons are allowed within 500 feet of the area except those consenting to be involved and

necessary for the filming production. This provision may be reduced to no less than 200 feet

if it would not adversely affect safety and the Administrator has approved it. For example, an
equivalent level of safety may be determined by an aviation safety inspector’s evaluation of

the filming production area to note terrain features, obstructions, buildings, safety barriers,
etc. Such barriers may protect non

- participating person s (observers, the public, news media,

etc.) from debris in the event of an accident. This is also consistent with the same FAA Order
8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA

must return to a pre

- determined loc ation within the security perimeter and land or be

recovered in accordance with the operator’s manual.14

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

determined location within the security perimeter and land or be recovered in accordance

with the operator’s manual.

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

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or
Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will a lso require the operator to request a Notice to Airman
(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation.

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. The operator must develop procedures to document and maintain a record of the UAS

ma intenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the UAS. These procedures must be

added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the

f ollowing requirement: The preflight inspection must account for all discrepancies, i.e.

inoperable components, items, or equipment, not covered in the relevant preflight

inspection sections of the operator’s manual.

27. Before conducting operations, the ra dio frequency spectrum used for operation and

control of the UAS must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of t he UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction15

15 over the area of proposed filming. The 3

- day notification may be waived with the

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming

production under this grant of exemption

c. Name and phone number of the person responsible for the on

- scene operation

of the UAS.

d. Make, model and serial or N

- number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming

production event

f. A statement that the operator has obtained permission from property

owners and/or local o fficials to conduct the filming production event; the

list of those who gave permission must be made available to the

inspector upon request.

g. Signature of exemption

- holder or representative

h. A description of the flight activity, including maps or diagrams of any area,
city, town, county, and/or state over which filming will be conducted and the

altitudes essential to accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC

at the ground cont rol 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.
30. The UAS 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.).

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

operations must be conduc ted under visual meteorological conditions (VMC). Flights
under special visual flight rules (SVFR) are not authorized.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS 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.16

16 34. The UAS may not operate in Class B, C, or D airspace without written approval from the
FAA. The UAS may not operate within 5 miles of the geog raphic center of a non

- towered

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 must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical

boundaries of the operational area as def ined by the applicable COA must be reported to

the Federal Aviation Administration’s (FAA) 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. Further flight operations may
not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my,
Mark W. Garza ’ s , request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flyin g to and from established airfields. I, Mark W. Garza , have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Mark W. Ga rza ’ s , UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Mark W. Garza ’ s , operation of my UAS, weighing less than forty (40) pounds and traveling at lower speeds within limited areas low to the ground will pro vide an equivalent level of safety as that achieved under current FARs. Accordingly I, Mark W. Garza , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircr aft, and the general public at large.

Respectfully submitted,

Mark W. Garza 15804 Saddle Dr, Excelsior Springs, MO 6402417

17 10



## Appendix A

List of Aircraft

No. Make and Model Description Serial No. Registration
No.
1 DJI Inspire 1 Electric p owered, 4 rotor, small unmanned multirotor helicopter Not Yet Purchased 

### Pending

2 DJI Phantom 3 Electric powered, 4 rotor small unmanned multirotor helicopter Not Yet Purchased 

### Pending

3 DJI AGRAS MG

- 1 

### Electric powered, 8 rotor, small

unmann ed multirotor helicopter Not Yet Purchased 

### Pending

DJI Matrice 100 

### Electric p owered, 4 rotor, small

unmanned multirotor helicopter Not Yet Purchased 

### Pending

1. DJI INSPIRE 1

T he operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials
I. Plastic

II. Aluminum

2. Motor Configuration I. The DJI INSPIRE ONE flight in a 4 motor quadcopter s etup. ,

3. Payload

I. The DJI INSPIRE ONE flies it’s own light

- weight integrated camera.

II. Maximum All

- up weight

- 6lbs

4. Maintaining the DJI INSPIRE ONE I. Before each flight: 1. Check all hardware to ensure it is securely tightened.
2. Check that the mot or is level and locked in place.18

18 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 5. Check all navigational ligh ting to ensure it is properly working.

II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor controllers and visually inspect and check for damage. Replace as necess ary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.
5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.



## Appendix B

2. DJI Phantom 3 The operation of the DJI Phantom 3 system is as follows.

1. Build Materials

I. P lastic
II. Aluminum

2. Motor Configuration I. The Phantom 3 flight in a 4 motor quadcopter setup. ,

3. Payload I. The Phantom 3 it’s own integrated camera.

II. Maximum All

- up Weight

- 4lbs

4. Maintaining the Phantom 3 I. Before each flight:
1. Check al l hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 4. Check all wiring to motors, motor controllers, batteries , and flight controller for signs of 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor cont rollers and visually inspect and check for damage. Replace as necessary.19

19 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks , and/or loose/cold solder connections. Fix before flying. 5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.



## Appendix C

3. AGRAS MG

- 1
The operation of the DJI AGRAS MG

- 1 multirotor system are as follows (the flight controller operation manual is NOT explained in this manual but can be found in Appendix E , Section 1).

1. Build Materials
I. Carbon Fiber
II. ABS Plastic
III. Stainless Steel Har dware

2. Motor Configuration

I. X8 configuration utilizing 8 motors ( DJI KV 130 rpm/ V ) The motors are configured with 2 motors per arm, one top and one bottom spinning in a counter

- rotating dire ction. UAV is n ot equipped with camera but does not need one as its use will be only visual line of sight and no

more than 15ft above top of tallest planted crop

.

II. In this configuration the AGRAS MG

- 1 can handle up to four (4) motors failing and still be able to fly.

3. Payload
I. The AGRAS MG

- 1 will carry 10kg of either pesticide or fertilizer for crop II. 3 Flight modes Smart Mode, Assisted Mode & Manual Mode, according to terrain and specific

needs

I II. Maximum All

- up Weight

- 34lbs

4. Maintaining the AGRAS MG

- 1 I. Before each flight: II. After 45 hours of flight

1. Check all hardware to ensure it is securely tightened. 2. Check that all motors are level and locked in place. 3. Check all propellers to ensure they are tight and there are no visible signs of c racks, stress, and/or chips. Replace if any propeller is questionable. 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.
5. Chec k all navigational lighting to ensure it is properly working.20

20 6. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 7. Remove motor controllers and visually inspect and check for damage. Replace as

necessary. 8 . Remove flight controllers and visually inspect and check for damage. Replace as necessary. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.



## Appendix D

4

. Matri ce 100

1. Build Materials
I. Carbon Fiber
II. ABS Plastic

III. Stainless Steel Har dware

2. Motor Configuration

I. The Matrice 100 flight in a 4 motor quadcopter setup

3. Payload

I. Matrice 100 has it’s own integrated camera. Maximum All

- up Weight

- 4lbs

3. Maintaining the Phantom 3

I. Before each flight:
1. Check al l hardware to ensure it is securely tightened. 2. Check that the motor is level and locked in place. 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 4. Check all wiring to motors, motor controllers, batteries , and flight controller for signs of 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary. 2. Remove motor cont rollers and visually inspect and check for damage. Replace as necessary. 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. and/or chips. Replace if propeller is questionable. 4. Check for cuts, fraying, cracks , and/or loose/cold solder connections. Fix before flying. 5. Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.21

21 Personal Protocols/Controls/Flight Manual
Protocols and Controls

Mark W. Garza, Excelsior Springs, Missouri

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safet y protocols and controls must be implemented through pre

‐ flight preparation and during flight. Pre

‐ Flight Protocol:

Check batteries with voltage meter to insure fully charged and ready for use.

Inspect batteries for damage or leakage that may affect pr oper operation.

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or unmanageable/uncontrolled flight.

Check all GPS and Telemetry connections prior to flight.

Check weather forecasts for wind advisory or other conditions that my impact flight.

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated

e levation of flight, and any other pertinent information.

Inspect flight area for Vicinity of public safety helipads/heliports Vicinity of medical helipads/heliports Vicinity of light poles vicinity or utility wires Vicinity of trees flocks of birds th at may cause interference and potential flight impact Vicinity of any elevated obstructions that may pose potential flight hazard Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may attract viewers optiona l point of control for best visual site of UAS while in flight Emergency landing areas

Takeoff and landing

Inspect area for best and safest point of takeoff and landing22

22 If in a subdivision or area that is within 150 feet of a residential street, post warning Sign(s)/stand(s) "Attention Aerial Photography In Progress

‐ Remain Back 150 Feet "

Flight Protocol: takeoff and land from same location ( have alternate landing areas in case of emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficient to acquire desired results remained prepared for emergency landing at all times pay attention to flight time

– warning meter for low voltage.

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut down propulsion immediately following landing

– priority of disconnecting batteries

Post flight:

1. a) Disconnect batte ry to prevent accidental activation of propulsion system

2. b) Secure UAS in a safe location

c) Remove all warning signs from public access areas Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

Ma nned aircraft is heard or seen in vicinity of flight There is a public gathering within established safety boundary wanting to observe flight Pilot is being distracted from focusing on flight and safety Sudden change in weather (wind bursts)
Sudden inc rease in vehicular traffic in vicinity of flight Birds enter into proximity of flight Any sudden unsafe event that can cause collision, distraction or interruption of control

Safety for public on the ground as well as manned aircraft above is an essent ial and utmost consideration for aerial videos and photography.

Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.

Date:____________________ Location:___________________________________

________________

pre

‐ flight Inspection:23

23 o Yes o No

Comment: _________________________________________________

Elements

Proximity to airport: _________________ (see attached map pinpointing approximate location of flight)

Airport notified: No Ye s

Date:_______________ Time: ______________

Phone Number: _______________________ Contact Name:___________________________________

Nearest major intersection:

______________________________________________________________

Proximity to medium traff ic road:

_________________________________________________________

Proximity to heavily traveled roadway road:

_________________________________________________

Proximity to congested population:

________________________________________________________

Approx. Takeoff Time : GMT:

Weather Good Fair Poor Comment :

Visibility Good Fair Poor Comment :

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment :

Appro x. Landing Time: GMT: Estimated Elevation Ground level: Safety Concerns:
Additional Comments:

sea level:24

24 

## Appendix
'E '

Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and illustrated parts catalogs . These manuals may be attached to the docket when submitted. Information regarding design, aircraft performance, fail

- safe features, operating limitations, normal and emergency procedures, and maintenance and inspection procedures is contained within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1.0 / V2.0/Pro
2. Inspire 1 Maintenance Manual v1.0 /v2.0/Pro
3. Intelligent Flight Battery Safety Guidelines v1.4 4. Inspire 1 Safety Guidelines 5. Phantom 3 Professional Manual V1 .0 6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)
7. Matrice 100 Manual 8. Matrice 100 Safety Guidelines 9. AG RAS

- M1 Ma nual
10

. AGRAS

- M1 Safety Guidelines

For more information or questions about this manual please contact:

Mark W. Garza

15804 Saddle Dr , Excelsior Springs, MO

254

- 535

- 3329