Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

June 11, 2015

Russell M. Squire

1087 Stoneridge, Suite 2-A

Bozeman, MT 59718

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 

119.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2) and 91.417 (a) & (b).

Dear U.S. Department of Transportation,

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

C.F.R. Part 11, I, Russell M. Squire, owner and operator of a small Unmanned Aircraft System equipped 

to conduct aerial videos and photos of real estate listings, hereby apply for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of my small Unmanned Aircraft System, so 

long as such operation is conducted within and under the conditions outlined herein or as may be 

established by the FAA as required in Section 333.

My name is Russell M. Squire and I am the owner of Sly Dog Production, PLLC, a State of Montana 

registered professional limited liability company which services the real estate industry in Montana, 

experienced in flying hobby quad-copters for recreational purposes. I have also completed 35 hours of 

private pilot training through Sunbird aviation located at Gallatin Field in Belgrade, Montana. I, Russell 

M. Squire, have filmed with ESPN, OLN (Out Door Life Network), Dick Barrymore Productions; I have 

further shot still photos with Esquire and Men’s Journal.

I have a DJI Phantom 3 Professional quad copter with the intention of creating aerial cinematography to 

assist individuals and companies unfamiliar with the geographic layout of Bozeman, Montana and 

Gallatin County, Montana and to help improve real estate listing presentations for agents following 

exemption and approval by the FAA. This will serve to augment the academic research experience for 

the Bozeman area. I further intend to add a second DJI Phantom 3 Professional quad-copter1to our 

company’s inventory in the future with identical safety features and capabilities.

I have flown small ultra-light unmanned aerial systems for four years that are piloted by remote control 

without incident. Recent technological developments by DJI Company now make these devices safer 

than ever before as well as more stable and easier to fly. I am committed to safety with each flight and

 
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

use a strict pre-flight checklist and protocol. My, Russell M. Squire’s, exemption request would permit 

the operation of ultra-light weight, unmanned (piloted by remote control) vehicle in tightly controlled 

and limited airspace2. These areas would be predetermined and away from the general public, airports, 

heliports and vehicular, as well as pedestrian, traffic for community videos and inside property 

boundaries for individual homeowner real estate listing videos and photos.

I, Russell M. Squire, have personally created safety protocols and pre-flight checklist plan to be used in 

all flights whether for recreational or commercial purposes as the same procedures should apply to all 

UAS. These procedures are intended to avoid and prevent public hazard, as well as unmanned aircraft 

hazards. This will act to further enhance safety protocols3exclusive to lightweight UAS’s specific to real 

estate video and photography. Our DJI Phantom 3 Professional quad-copter further records all flight 

data and other information obtained through permitted flight operations to share with the FAA through 

any required FAA reporting to assist with future protocol and safety regulations.

 

1

– Appendix A – DJI Phantom 3 Professional quad-copter Operator Manual

2

– Appendix B - Bozeman, Montana 5 mile airport radius maps

3

– Appendix C – Personal Protocols and Controls
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

Granting my, Russell M. Squire’s, request comports with the Secretary of Transportation’s (FAA 

Administrators) responsibilities and authority to not only integrate UAS’s into the national airspace 

system, 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 

residential commercial photography, video productions and use by real estate professionals. 

Furthermore, I, Russell M. Squire, will conduct my operations in compliance with the protocols 

described herein or as otherwise mandated by the FAA.

For the reasons stated below I, Russell M. Squire, respectfully request the grant of an exemption 

allowing me to operate ultra light weight, remote controlled UAS’s for academic community awareness 

to benefit/stimulate attraction to the Bozeman, Montana and Gallatin County areas and to enhance real 

estate listing videos for homeowners who cannot afford expensive manned aircraft for the same 

purpose. These activities will promote local economic growth through increased employment and 

increased tax base. Both with public safety in mind by keeping heavier manned aircraft containing

combustible fuel that poses potential public hazard. If I can provide any additional information to assist 

your understanding or review of this document, please do not hesitate to contact me at 406-425-2742 

or via email at rustysquire7@gmail.com.

I. Contact Information:

Russell M. Squire

Sly Dog Production, PLLC

1087 Stoneridge, Suite 2-A

Bozeman, MT 59718

Mobile: (406) 425-2742

Email: rustysquire7@gmail.com

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

Which Russell M. Squire Requests Exemption is:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

III. The Extent of relief Russell M. Squire seeks and the Reasons For Seeking The 

Relied:

I, Russell M. Squire, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating to prevent me, Russell M. Squire, 

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 unmanned aircraft systems 

into our national airspace system as it is in the public’s interest to do so. My, Russell M. Squire’s, ultra 

light weight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and

therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I 

would like to operate my ultra light weight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and 

valuable information for formal regulation that can be administered uniformly to all real estate 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 airspace 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). Each of 

these items reflects in favor of an exemption for me, Russell M. Squire. My UAS utilizes four (4) counterrotating propellers for balance, control and stability and has integrated GPS sensors with ground sensors 

to further safety considerations. My UAS is equipped with GPS and auto return to home safety

technology. Weighing less than four (4) pounds (far below the maximum 55 pound limit); with all 

equipment attached.

I, Russell M. Squire, consider safety as a foremost concern with each flight. My small unmanned

aircraft is designed to hover in place via GPS and operate in less than a 24 knot (27.61 mph) wind. For 

safety, stability and fear of financial loss I will not fly in winds exceeding 15 knots (17.26 mph). Built in 

safety systems include a GPS mode that allows my UAS to hover in place when radio controls are 

released. With three modes to choose from, I utilize the Fail Safe Mode4for aerial video and 

photography. We further set the UAS’s altitude governance at 200 feet meaning that it cannot exceed 

this altitude above ground level (AGL). This is the safest, most reliable and stable mode to prevent 

accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take 

off using an automated return to home feature. I do 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 location or I suspect manned aircraft may 

approach near my location. My UAS is capable of vertical and horizontal operations, and are flown only 

within my line of sight of me, as the remote control pilot. Utilizing battery power rather than

combustible fuels, flights generally last between five (5) to ten (10) minutes, with an altitude under two 

hundred (200) feet. I, Russell M. Squire, utilize a fully charged battery for every flight as an added

safety precaution and we have two spare batteries fully charged as back-ups. Furthermore the UAS 

 

4

- Fail Safe Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return to 

home feature and safety control to return home or land in the event of communication interruption between the 

Remote Control Transmitter and the UAS. See Appendix A – Operator Manual for DJI Phantom 3 Professional
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

offers pre-sets to alert us when the battery has discharged to 30%, so there is plenty of time to land 

prior to the batteries expiration. The complete flight time for each battery is between 20 and 23 minutes

with the 30% level generally reached within 16 minutes of the commencement of flight operations.

I, Russell M. Squire, do not operate my UAS at or below manufacture recommend minimum charge 

levels for operation; preferring 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 sufficient safe level 

of operation. I do not believe in taking 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 hundreds of 

hours of practice flights and have filmed numerous subject properties as a hobbyist simulating flights for 

future 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 and regularly train on the flight simulator to keep my 

skills sharp.

I, Russell M. Squire, 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. Russell M. Squire’s UAS, used in hobby flight, has a demonstrable safety

record with over 200 flight hours logged, receives regular maintenance and does not pose any threat to 

the general public or national security.

IV. How Russell M. Squire’s Request Will Benefit the Public As A Whole:

Aerial video for geographical awareness and for real estate marketing has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget real estate companies and 

average homeowners the expense of such aerial video is cost prohibitive. Only large companies and 

high-end Realtors or luxury homeowners can afford to absorb such expense. This has deprived nonluxury homeowners and Realtors with less disposable income from a valuable marketing tool. Manned 

aircraft pose a threat to the public because of combustible fuels, a threat that our UAS does not have 

because it uses no combustible fuel but rather a simple lithium-ion rechargeable battery. If we travel on 

commercial airlines with our UAS then we carry on all lithium ion batteries per TSA regulations.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's 

into the national airspace system, hence the passing of the Reform Act. Granting my, Russell M. Squire’s, 

exemption request furthers the public interest through academic/visual awareness of the geographical 

benefits in and around the Bozeman, Montana area. My ultra light weight UAS is battery powered

and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible 

fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video 

and photo capture through my battery operated ultra light weight UAS's. Permitting me, Russell M. 
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

Squire, to immediately fly within national air space furthers economic growth. Granting my exemption 

request substantially furthers the economic impact for the Bozeman community for companies looking 

to relocate or build in the Bozeman area as well as individuals looking to relocate for career

advancement through academic and geographical awareness, both of which serve as an economic

stimulus to the community. 

V. Reasons Why Russell M. Squire’s Exemption Will Not Adversely Affect Safety Or How The 

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

My, Russell M. Squire’s, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated permitting me, Russell M. Squire, 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, as of yet, undeveloped safety protocols for Realtors or marketing companies that can be embraced 

by the NAR5, and GAR6for development in cooperation with the FAA. In addition I, Russell M. Squire, 

submit the following representations of enhancements to current aerial video and photography for real 

estate: 

I. My UAS weighs less than 4 pounds complete with a small ultra light weight high quality 4K 

resolution camera; 

II. 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); 

III. my UAS only operates for 10 to 17 minutes per flight (23 minutes would be at maximum 

battery capacity and we land when 30% capacity remains under all circumstances); 

IV. I land my UAS prior to manufacturer recommended minimum level of battery power;

V. I pilot my UAS through remote control only by line of sight; 

VI. My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost;

VII. My UAS has ground sensors to prevent fast landings; 

VIII. I actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols; 

IX. I only operate in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; 

X. I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance; I carry out initial research of the area to ensure it does not fall within any 

restricted areas and review weather forecasts and other pertinent information to ensure 

safe flight operations; 

XI. 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. 

 

5

- National Association of Realtor (NAR) http://www.realtor.org/

6

- Gallatin Association of Realtors (GAR) http://www.gallatinrealtors.com/
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

My, Russell M. Squire’s, safety protocols provide a level 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 and real 

estate tours. While the safety record of such helicopters is remarkable, there have been incidents 

involving loss of life; it is far safer to operate a battery powered ultra light weight UAS.

 First, the potential loss of life is diminished because UAS's carry no people onboard and I only 

operate my UAS in specific areas away from mass populations.

 Second, there is no fuel on board a UAS and thus the potential 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.

 Finally, 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 without the risk of creating those effects while 

flying.

Accordingly, my UAS has been experimentally operated for familiarity and will continue to operate at 

and above current safety levels.

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

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

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

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of my, Russell M. Squire’s, UAS permits exemption from 

Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 

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

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

Act. Both pieces of legislation permit the FAA to exempt 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, Russell M. Squire’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 

inapplicable.

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 maintaining a safety/flight manual delineating 

areas of where safety can be defined.7The FAA has previously issued exemptions to this 

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

10602, 10700 and 32827. 

 

7

 - Appendix D Flight/Safety Manual
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor. 

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

registrations. They are inapplicable for the same reasons described above. The equivalent level 

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

me, Russell M. Squire.

B. 14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft with dimensions smaller that minimal lettering 

requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone 

assisting me as a spotter with the UAV will see the markings. The FAA has previously issued 

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

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

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Russell M. Squire, can achieve an equivalent level of safety as achieved by current 

Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills. The risks attendant to the operation of 

my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 

61, et seq. Thus, allowing me, Russell M. Squire, to operate my UAS meet and exceed current 

safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

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

to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude 

greater than 300 AGL; safely below the standard of 400 AGL. I, Russell M. Squire, 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 will be achieved. 

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

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

operators to “have [the] aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of this chapter. . . .”
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

to my, Russell M. Squire's, UAS. However, as a safety precaution I inspect my UAS before and after each 

flight.

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

Airworthiness Certificates, Manuals and the Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed 

operational area of my UAS permits exemption from Part 21 because my,Russell M. Squire’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 under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 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 of the UAS's, this Regulation is inapplicable. An equivalent level 

of safety 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 for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved.

In summary, Russell M. Squire seeks an exemption from the following Regulations:

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

91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 

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

Russell M. Squire's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community

Awareness and real estate operations to develop economic platforms for real estate to enhance the 

experience of those seeking to relocate to the Bozeman and Gallatin County areas. Currently, area 

awareness and real estate aerial video and photography rely primarily on the use of larger aircraft 

running on combustible fuel, posing greater potential risk to the public. Granting my, Russell M. Squire’s,

request for exemption will reduce current risk levels and thereby enhance safety.

My UAS craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional real estate video and photographic aircraft with much less flight time. Further, I operate at 

lower altitudes and in controlled airspace eliminating potential public risk flying to and from established 

air fields. I, Russell M. Squire, have private pilot training and have been informally analyzing flight

information and will compile safety protocols and the implementation of a flight operations manual for 

real estate 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 passengers on board my, 
Russell M. Squire, Sly Dog Production, PLLC, Bozeman, MT – Section 333 Exemption Petition

Russell M. Squire’s, UAS and therefore the likelihood of death or serious bodily injury is significantly 

diminished. My, Russell M. Squire’s, operation of my UAS, weighing less than 4 pounds and travelling at 

lower speeds within limited areas will provide an equivalent level of safety as that achieved under 

current FARs. Accordingly I, Russell M. Squire, respectfully request that the FAA grant my exemption 

request and am willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large.

Respectfully,

Russell M. Squire, President

Sly Dog Production, PLLC.

1087 Stoneridge, Suite 2-A

Bozeman, MT 59718

Tel. 406-425-2742