January 16, 2016 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

I am writing pursuant to the FAA Modernization and Reform Actof 2012 (the "Reform Act") and the procedures 

contained in 14 C.F.R. 11, to request that Garuda Video Productions, owned and operated by Michael Prindle and as 

owner and operator of small unmanned aircraft be exempted from the Federal Aviation Regulations ("FARs") listed 

~below so that Michael L. Prindle (dba: Garuda Video Productions) may operate a smaJI!Jnmanned aircraft/lightw~ght 

unmanned aircraft systems ("UAS") commercially in airspace (NAS) regulated by the Federal Aviation Administration 

("FAA"). 

Primary uses for this sUAS will be low altitude aerial photography and videography. The intended use ofthis sUAS is for 

aerial data collection to include any remote sensing and measuring by an instrument(s) aboard the UA. This collection 

may include imagery by photography, video, infrared means, electronic measurement (precision survey, RF analysis, 30 

virtual imaging, etc), chemical measurement (particulate measurement, etc), or any other gathering of data by 

instruments aboard the UA. Additional eventual use may include buying, developing, modifying, installing, and/or 

testing of "obstacle detection & avoidance systems" confined to controlled and approved areas while adhering to FAA 

regulations and guidelines for such activities, and after proper authorization and registration by the FAA for such 

procedures. This UAS may also be used for hobbyist and recreational type activities and operations. 

The contracting entities (clients) may include: clients requiring photos and/or video footage for websites or internet 

media sites, aerial inspection services for local government agencies, private entities, land developers, architectural 

firms, real estate agencies, surveyors, advertising agencies, or other appropriate commercial entities - to include but 

not limited to - approved and authorized aerial inspections of pipelines, power lines, disaster areas, wind turbines, 

agricultural surveys, real estate property, 30 topography mapping, and/or search/inspection/survey missions requested 

and authorized by appropriate authorities. 

The sUAS is described as a small, light-weight, quadcopter commercially manufactured by DJI Technology Co. Ltd. and 

named DJI Phantom 3 Professional. Flight times range between ten (10) and twenty-five (25) minutes. The UA has_ 

electric motors for no pollution or carbon footprint .. carries no crew or passengers, carries no frammable fuel, weighs 

under 5 pounds, has several onboard monitoring and failsafe systems, and has GPS/autopilot features with audible and 

visual warning systems which alert the operator/PIC/VO as to status and condition of the battery reserve and no-fly 

zones. Whenever the RC signal is lost between the UA and controller radio, the UA auto-climbs to a preset attitude, 

above trees and structures, and returns to its home launch site. These several tested and proven safety features should 

give the FAA confidence and good cause to find the UAS operation granted by this exemption to be in the public 

interest. 

The petitioner/operator/PIC of this small UA, Michael Prindle, is an experienced FAA certified airman (#1762005) 

familiar with FAA regulations and also versed in UAS guidelines and "best practice" procedures. The petitioner/PIC 

believes himself qualified to safely operate this UAS in NAS while complying with all rules and regulations set forth by 

the FAA and any other local governing authorities- ensuring the safety of operations conducted as described above. 

NOTICE: PLEASE TAKE TIME TO GIVE SPECIAL CONSIDERATION ITEM#6 BELOW WHEN EVALUATING THIS REQUEST 

FOR EXEMPTION. THANK YOU. 
The Owner ID and UAS specifications summary is listed below: 

UAS SPECIFICATIONS/DESCRIPTION SUMMARY: 

U.S. Identification: 

Name of Petitioner/Owner/PIC: 

Owner/Pilot's FAA certifications: 

Organization memberships: 

Purchase Information: 

Retailer seller identifiers: 

UAS Airframe Manufacturer: 

UA Model name: 

Serial number: 

A/C Classification: 

Type motor/engine Installed: 

Motor Mfr & motor serial nbrs: 

Nbr of Motors/Model#s/Max Output 

UAS Built for Land/Sea Operation: 

Potential payloads: 

Maximum horizontal ground speed: 

Maximum vertical climb speed: 

Max total airframe launch weight: 

Operational Flight Rules: 

N614QP (affixed to rear outboard motor arms) 

Michael L. Prindle, dba: Garuda Video Productions 

Airmen Cert# 1762005 

AMA# 1089080 

Purchased on Amazon 10-19-15; delivered by UPS on 10-23-15 

Amazon.com, 4040 Terry Ave North, Seattle, WA 98109, USA 

DJI Technology Co. Ltd. 

Phantom 3 Professional 

P76DCH24A26620 

UAS - Multi-rotor Quadcopter 

Brushless electric lift motors 

DJI (no published serial nbrs) 

Four (4) - model# DJI 2312/960KV - max output Unknown 

Land 

camera/gimbal, water pontoons; obstacle detection & avoidance systems. 

35mph (16meters/sec) 

llmph (Smeters/sec) 

5 lbs. (including OEM camera; new white navigation strobe; tracking module) 

VFR; visual line-of-sight for Operator/PIC/VO 

Aircraft drawing and dimensions 
For the reasons described in this petition, Michael L. Prindle, dba: Garuda Video Productions, respectfully requests the 

grant of an exemption allowing the operation in NAS of the described UAS and protocol described in this petition, and 

while ultimately following all rules and restrictions set forth by the FAA grant pursuant to the Exemption. 

1. Contact Information: 

Michael L. Prindle 

5334 Lakecrest Road 

Caledonia, IL 61011 

Tel.: (815) 713-0911 

email: garuda_video_productions@hotmail.com 

2. The Specific Sections of Title 14 of the Code of Federal Regulations from Which the Exemption is being 

requested: 

14CFR 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); 

14 CFR 417 (a) & (b); 

U.S Dept ofTrans. 

(and any other subsequent and relevant code to allow the petitioner to operate a UAV to perform aerial data 

collection as described in the above description) 

3. The Extent of Relief that Michael L. Prindle (dba: Garuda Video Productions) Seeks and the Reasons He 

Seeks Such Relief: 

Garuda Video Productions submits this application in accordance with the Reform Act, 112 P.L. 95§§ 331-334, seeking 

relieffrom any currently applicable FARs operating in cinematic, research, 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. The lightweight UAS meets the definition of 

"small unmanned aircraft" as defined in Section 331 and therefore the integration of this lightweight UAS is expressly 

contemplated by the Reform Act. I would like to operate the aforementioned lightweight UAS prior to the time period 

by which the Reform Act requires the FAA to promulgate the final rules governing such UAS aircraft. 

4. How. this RequE!st and Waiver Grant Will Benefit the Public as a Whole: 

Granting this exemption request furthers the public interest. Congress has already pronounced that it is in the public's 

interest to integrate commercially flown UASs into the national airspace system, hence the passing of the Reform Act. 

First, the reduction of the air pollution and carbon footprint by using electric aircraft for commercial and public service 

operations serves to protect the environment. Secondly, it has been shown that UASs can be used to perform many 

comparable operations that formally required large manned aircraft to collect aerial data to achieve a particular goal. 

In the area of emergency response missions, UASs can be deployed faster and at a much smaller expense than manned 

fix-wing aircraft and helicopters when only aerial observations and data collect are required. Likewise with data 

collection by movie studios, real estate facilities, architectural firms, etc. For example, using UASs for inspections of wind 

turbines, power lines, agricultural crops, architectural structures, and pipelines, as well as topography mapping, land 

surveying, and emergency surveillances - reduce manpower and machinery requirements, and diminishes the risk of 

human dangers while conducting such inspections using human inspectors and large expensive aircraft that burn 

expensive fuel that pollutes the environment. 
The impact of lightweight UAS is negligible when compared to the conventional full size helicopter, notwithstanding the 

statistically noteworthy safety record of full size helicopters used in motion picture aerial filming. The public's interest is 

furthered by minimizing ecological and crash impacts by permitting photo and video capture through lightweight UAS 

and the minimal environmental damage that occurs should a small UAS crash under unforeseen circumstances, resulting 

in no risk of fuel igniting after the crash. 

Whenever aerial data collection is necessary, there are obvious advantages for the good of the public and environment 

by using UASs when possible and appropriate. Noise pollution is exponentially improved by using UASs verses large 

manned aircraft. Much less expense outlays are required to build or utilize existing launch sites for UASs than with large 

airports and infrastructures for manned aircraft- involving many applications that are faster, more convenient, les 

expensive, more practical, utilizing less resources, and reducing the potential safety threat to persons and property by 

implementing UASs to perform functions previously conducted by large, expensive, resource draining, air-polluting 

conventional aircraft. Although large conventional aircraft will always have their role in application requiring large 

aircraft, we must remain open-minded regarding the practical use of UASs in certain applications which serve to benefit 

the society, environment, and scarce resources - and not adversely impact the quality of persohallife, natural " 

environment, public safety, and a sustainable ecological infrastructure. 

lastly, with the introduction of UASs into the marketplace, great strides in the development of advanced avionics and 

aerial electronics have resulted not only for the UAS industry but also lends itself to enhancing technological 

developments in the manned aircraft industry. For example, the increasing research in the UAS genre has enlisted many 

more engineers and scientists to develop more sophisticated detection and avoidance systems for both UAS builders as 

well as the established manned aircraft industry. The more engineers, the more advancement and innovation in these 

safety and life-saving systems. And ultimately, as the military establishment is discovering, using UASs in certain 

applications can forgo the risk ofthreatening a human pilot's life and collateral damage to life and property on the 

ground should an aircraft meet with tragedy. The degree of life and property at risk is much different when comparing a 

small UAS to a large multi-ton manned aircraft when both are serving the same purpose or function. 

s. Reasons Why this Requested Exemption Will Not Adversely Affect Safety or How the Exemption Will 

Provide a Level of Safety at Least Equal to the Existing Rule: 

(CRITERIA FOR MAKING SAFETY EVALUATION- COMPLIANCE STATEMENTS FOR OPERATIONAL LIMITATION OF PART 107): 

The following is a bulleJ Jist of the favorable features and safety mechanisms integrated ittthe UAS orprotoco1lJ1ilized 

during the operation ofthe UAS in the functions and uses ofthe UAS as outlined above. 

Regarding the Unmanned Aircraft (Airworthiness): 

UA is equipped with red and green navigation lights as well as a white LED strobe light. 

UA has integrated software that always prevents its operation within 15 miles of the White House in Washington, DC. 

UA has an integrated safety procedure in which the PIC is able to immediately stall all motors instantly forcing it to 

freefall to the ground in the event an unavoidable collision course would jeopardize the safety of persons or 

property. 

UA has an integrated failsafe system on board in which, if the remote control signal is lost for any reason, the UA will 

automatically ascend to an attitude above trees and structures, and safely returns home to its original launch 

site safely without incident. 
- UA is equipped with both visual and audible alert mechanism that warns the Operator/ PIC that the on board 

"intelligent" flight battery is running a low charge so it can be returned to its launch sight safely without 

incident. 

- UA has a flight mode that allows it to use both GPS positioning and ultrasonic sensors detecting proximity to ground 

surfaces to ensure its safe operation with only minimal PIC remote control input. Should the PIC inadvertently 

release the RC control joysticks on the remote controller radio transmitter, the UA will come to a stationary 

hover and remain there unaffected by wind, until the PIC resumes control. 

- UA is equipped with a GPS/Compass system that corrects for severe drifting in strong wind gusts, which signals an 

alert and then brings the aircraft to to a higher altitude to gain enough GPS satellite "locks" to resume stability 

and mitigate drifting. 

UA has an advanced GPS system on board that now utilizes the Russian GLONASS satellites in addition to the 

customary U.S. satellites used in the older GPS systems. This addition feature enhances the integrity and 

efficacy of the GPS and autopilot systems ofthe aircraft, thus improving safety and reliability during flights. 

UA is equipped with an on board/under-body LED lighting system and an on-screen display on the monitoring device 

on the ground that continuously indicates to the Operator/PIC/VO the status of the flight mode as well as early 

warning alerts for conditions possibly involving safety. 

- UA has a programmable protocol that allows the Operator/PIC to preset altitude ceiling limitations to automatically 

remain within FAA restrictions to 400 feet AGL. 

UAS is equipped with a 8-inch display monitor mobile device (Samsung Tab-S tablet) that attaches to the Operator/ 

PIC's handheld remote controller radio in order to monitor flight status, flight modes, compass direction of 

travel, altitude, battery charge level, Google map position, number of satellite locks, etc. -all of which 

continuously keep the Operator/PIC/VO advised of the condition, status, and progress of the flight operations 

realtime. 

UA is equipped with an on board 3-axis stabilization gimbal and 720 Hi-Def camera in combination with the abovementioned 8-inch display monitor- allowing for the PIC/VO to not only monitor the flight status, but also 

visually monitor all possible hindrances, obstructions, or assess safety situations in a 94-degree field of vision to 

augment and enhance the Operator/PIC/VO's VLOS observations, situational awareness, and detect possible 

safety issues developing in realtime during flight. 

UAS has integrated navigation capability of downloading and storing aerial Google topography Maps of the precise 

areas of operation so that the Operator/PIC can monitor the location and progress of the UA's position in flight 

realtime (see Appendix for photo example of ground position display). 

- UAS has integrated failsafe software which will disable the UAS from taking off and also limit the UAS system from 

flying within specific GPS preset no-fly zones. 

---~ UAS hasflightlogging software that records and stores flight data. 

UAS complies with Part 15 of FCC Rules; it also complies with the limits for a Class B digital device, pursuant to Part 

15 of FCC Rules. 

6. Respectfully Request for Exemption from the "blanket" 200 foot Maximum Altitude AGL: 

In reviewing the latest FAA proposals and interim regulations, I noticed: 1) The FAA has granted a "blanket 200-foot 

max altitude (AGL) COA limit for civil UAs under the commercial COA for UAS Operators/PIC who hold an FAA 

Airman Certification (pilot's License); and 2) that the "Hobbyist/Recreational" operators category is granted a 

"blanket" ruling of a 400-foot AGL limitation. It seems to me unfair and impractical in terms of safety that the 

"letter of the law" FAA ruling seems to contradict the intended "spirit" of the ruling which is focused on provisions 

aimed primarily at safety in the NAS. It seems difficult to rationalize that the civil/commercial UASs flown by 

licensed pilots like myself holding an airman certification are limited to the 200' blanket exemption, while the 

hobbyist pilot without an FAA pilot's license enjoys the freedom to fly at 400 feet. 
As a pilot, I am authorized to fly a single-engine, fixed-wing land passenger aircraft in Class-G (and others) airspace 

at 1,200-feet. Yet while using the same aviation knowledge, FARs, safety skills, and situational awareness I have 

accrued and now automatically apply to my flying procedures for UASs- I seem denied the authorization to fly at 

400 feet like the UAS hobbyists with no FAA pilot's license/experience. Can you see the practical contradiction in 

this ruling? 

I contend that it is likely that an experienced pilot holding an airman certification and also happens to be 

experienced in flying UAS aircraft - has significantly more practical skill, better judgment, more knowledge of 

FARs, more familiarity with weather criteria, ground school training, FAA flight procedures, more conscious of a 

high safety standard of practice, and perhaps more importantly has much better "situational awareness" ingrained 

in his psyche - rendering him much better prepared to handle situations that arise involving safety. I think that the 

maximum AGL altitude for licensed pilots with UAS experience should at least be equal to (or greater than) the 

maximum altitude granted to hobbyists automatically via a 400' COA blanket. 

And since the licensed pilot/operator always has visual contact with the UA and is trained in practicing situational 

awareness as usual - if another aircraft were flying in the general vicinity of a 400' UA, the UAS pilot could reduce 

the altitude from 400' to 300' in a matter of seconds to avoid any safety threat to the approaching aircraft. At 400' 

the human eye has a very wide field of vision around the UA aircraft he is operating. And therefore allowing the 

detection an approaching aircraft in ample time to reduce the UA's altitude quickly to avoid any threat to the 

approaching aircraft. This same situation occurs when curious raptors (eagles, hawks, etc) approach the UA on 

occasion. Merely by vertically descending the UA quickly avoids any threat of collision or attack by the raptor by 

simply outmaneuvering the approaching bird. And the larger the manned aircraft in the vicinity, the more it can be 

detected earlier and easier than a nearby bird being the same size as the UA. 

The 400' request seems reasonable for licensed pilots since back in February of 2015, the FAA published proposals 

including a ceiling limit of 500' AGL. Therefore, a 500-foot ceiling obviously was not beyond the realm of possibility 

for UAs at that time in the FAA's view. And in terms of safety, it seems that a licensed pilot with UAS experience is 

better able to avoid compromising safety situations at 400' than a hobbyist pilot operating at the "blanket" max of 

400 feet. 

For these reasons, among others, I respectfully request being granted an allowance to fly my registered UAS at 

altitudes up to 400 feet AGL, which in my case, would be on an occasional basis and lasting less than a minute, 

- posingver-y-~ittlethreatt& the safety ether aircraft. In my operation; it would imrolve·as~endingto 40€Heet,-~ --~-­

conducting a slow 360-degree pan during a stationary hover, and immediately descending to less than 200 feet. 

The UA would perform a stationary hover at 400 feet for less than a minute. The pilot/operator's standard protocol 

of visually scanning the surrounding sky before climbing to 400' would eliminate any possibility of another aircraft 

approaching the proximity of the UA in less than 60 seconds. Also, a super-bright LED strobe (white) has been 

added to the bottom of airframe as a extra precaution for alerting approaching aircraft. Strobes attract attention. 

And for the sake of fairness to other certified pilots, I respectfully request that the "blanket" 200-foot COA ruling 

currently attached to 333 Exemption recipients be amended immediately to allow certified pilots with a 333 

Exemption also be automatically granted the "blanket" 400-foot limitation currently enjoyed by hobbyists and 

recreational UAS operators having no pilot's license. I trust you can appreciate the equity is making such an 

amendment to the present 200' COA blanket. It seems to be discrimination in the wrong direction for safety sake. 

Thank you for your consideration in this recommendation. 
GENERAL REQUEST JUSTIFICATIONS 

Regarding the Unmanned Aircraft PIC: 

The petitioner/owner/PIC, (Michael Prindle, dba: Garuda Video Productions), has held an FAA Airmen Certification for 

over forty years. The petitioner is familiar with all aspects aviation safety, airport facilities and restrictions, and is 

trained/experienced in aviation flight rules and regulations. Petitioner is qualified to read aeronautical charts, assess 

weather conditions/development, and is familiar with the rules and regulations set forth by the FAA regarding the 

operation of sUAS and UAS aircraft. 

The petitioner also has experience building large-scale multirotor UASs from scratch (not kits), and therefore is familiar 

with the mechanics, electronics, and structure of UA airframes - and therefore is experienced to better understand and 

practice the critical pre-flight check points to assess accurately if the aircraft is worthy of flight for each operation/flight. 

The petitioner holds an Illinois drivers license, airmen's certificate, and an AMA membership. 

Regarding the Operation of the Unmanned Aircraft: 

The Petitioner/PIC states that during the private pilot training (Airmen Certification# 1762005), the aspect of safety that 

was emphasized most by the flight training staff was "Situational Awareness." The skill of maintaining awareness and 

anticipating a problem or threat in a timely fashion, and quickly responding to emergencies in an appropriate manner is 

absolutely paramount to maintaining safety at all times. 

For that reason, the petitioner/PIC considers himself skilled and prepared to address all aspects of safety in the flying of 

all UAs in the NAS. Previous experience affords the Petitioner/PIC the ability to plan well ahead and conduct flights with 

the utmost care and caution. There will always be a thorough plan and pre-flight procedure to include checking up-todate sectional maps, ensure that aircraft and associated equipment are in top working order, and always be sensitive to 

weather conditions, human activity on the ground, and air traffic situations whenever scheduling a project involving UAS 

flights in a particular area. 

The petitioner's pilot training, federal law enforcement training, and practical experience all contribute to his ability and 

skills in conducting a variety of UAS flights in a variety of situations. The petitioner strives always not to allow deadlines 

or financial gains to cloud his decisions and judgment when accepting civil/commercial assignments and choosing the 

times and places for best conducting missi()ns in whichsafet')' pr~vails ap_gve all_oth~ consid~r(lti()QS_,_ 

- Manufacturer's advertised weight is 3 pounds; max payload launch in all operations will always be less than 55 lbs. 

- VLOS and VFR operation will prevail always; even though a FPV monitor is active in order to monitor and record 

flight data, battery charge remaining, compass bearing, and flight status. During more complex operations, a 

trained VO will be employed to ensure greater safety and to assist with detection and avoidance protocol. 

UA will not be operated over (above) any persons, animals, or vehicles (unless authorized by appropriate authorities 

during a search/rescue operations under approved supervision by local authorities. 

UA will be operated during daylight hours between official sunrise and sunset. 

PIC will always yield right-of-way to all other aircraft in proximity. 

UA has a maximum rated horizontal speed of 35mph in calm air. 

PIC will adhere to the maximum limitation of 400 feet AGL. (or FAA restriction granted by COA) 

UA will operate in weather conditions where visibility is at least three (3) miles from PIC. 

UA will not operate in Restricted airspace. 
- UA will not operate within 5 miles of an airport without permission from airport authorities and ATC. 

- When operating this UA, the Operator, PIC, and any accompanying VO will not operate any other UA simultaneously. 

Extreme caution, alertness, situational awareness, and safety mindedness will be conducted during all operations of 

this and other UAs while following all safety procedures and regulations set forth by the FAA. No reckless, 

careless, or neglectful operations or procedures will be practiced by the Operator, PIC, or VO. 

- When aVO is being used, that VO will be in close proximity to Operator/PIC to ensure timely communications. 

- Each time the UA is operated, the PIC will conduct a thorough pre-flight inspection to ensure the integrity of the 

electronic components, attachments are secured, critical screws/nuts are tight, props and motors are in good 

operating condition, autopilot and GPS functions are functioning properly, batteries are fully charged, and the 

failsafe features are fully functional. 

During all flight operations, the Operator/PIC and any VO will be of good physical health and mental state of mind 

that will not compromise the good skill and judgment of PIC/VO to perform the operations safety and accurately 

as planned, while always practicing situational awareness with a mindfulness toward safety for all persons and 

property in the air and on the ground. 

During all flight operations, the autopilot and GPS functionality will be monitored to ensure that if the remote control 

signal is lost for any reason, that the UA will automatically ascend to a safe attitude above trees and strudi..ir'es, 

and return home to its original launch site safely without incident. 

-All accidents or incidents will be recorded/logged in detail and available the FAA and local authorities upon request. 

PIC will routinely and carefully reviewed all current FAA regs and notices, all current AMA guidelines, sectional maps 

of the area of operation; and will acquire all necessary permissions from FAA facilities/ ATC/airport authorities 

prior to all flight operations. 

In summary, the petitioner/operator, Michael Prindle, will persist in the safe operation ofthe aforementioned UAS by 

conducting preflight inspections, routine periodic structural/electronics inspections, remaining up-to-date in current FAA 

rulings/regulations, comply with these regulations, and will check current weather conditions and area restriction prior 

to each flight operation. Furthermore, the petitioner/operator will conduct operations in compliance with the rules, 

regulations, and protocol described herein or as otherwise established by the FAA. 

Precedence of prior Exemptions granted bv having all material respects the same : 

The UAS aircraft described above (DJI Phantom 3 Professional) is in all material respects the same aircraft which has 

previously been cited as Exemption by the FAA and found to be in the public interest - according to Grants of 

Exemption Nbrs: 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, Inc (see Docket No. FAA2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see 

Docket No. FAA-2014-0642), 12389 to Drone Guys (see Docket No. FAA-2015-1260). --<::- ~-~ - ~ 

7. Summary: 

A. - 14 C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals. 

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 the 

petitioner's (Michael Prindle, dba: Garuda Video Productions) UAS permits exemption from Part 21 because petitioner's 

UAS meets an equivalent level of safety pursuant to Section333 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 UASs from the airworthiness certificate requirement in 

consideration of the weight, size speed, maneuverability and proximity to areas such as airports and dense populations. 

The petitioner's 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 UASs, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at 

the flight operations center. The FAA has previously issued exemptions to their regulation in Exemption Nos 8607, 8737, 

8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. 

14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as the petitioner's UAS utilizes electronic global 

positioning systems and internal compass/gyroscopes to provide spatial coordination. 

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 such 

certifications and registrations at Garuda Video Productions flight operations center. 

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. The petitioner's 

UAS is, by definition, unmanned. It therefore does 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 as the DJI Phantom Professional 

measuring less than sixteen (16} inches at its widest points and having a height of eight (8} inches. However, (Michael 

Prindle, dba: Garuda Video Productions) will mark the UAS in the largest possible lettering required by the Exemption 

grant by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so that the pilot, 

technician, spotter and others working with the UAS will see the markings. The FAA has previously issued exemptions to 

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

The registered "N-number" for this UA will be affixed to the airframe in the largest possible letters appropriate for the 

size of the airframe, and will display in a contrasting colorfor best visibility. 

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. The petitioner can 

achieve an equivalent level of safety as achieved by current regulations because the petitioner's UAS does not carry any 

pilots or passengers. Furthermore, while helpful, a pilot license will not ensure remote control piloting skills. The risks 

attendant to the operation of petitioner's UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R.§ 61, et seq. Thus, the petitioner (Michael Prindle, dba: Garuda Video Productions) requests relief by 

a waiver in order to allow petitioner to operate the above-described UAS in the prescribed areas of the NAS with an 

Airmen Certificate (#1762005} as the pilot in control (PIC) which will 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. The petitioner will not operate at an altitude greater than 500 AGL (or whatever the 

- currentFAA-i:feems-as an appropriat-e limitation based on the -qualifications set forth here).li1-certain-sit-~ations-:tf1e"a~e~~­

of flight operation at low altitudes may be cordoned off with perimeters for safety and security, providing a level of 

safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and 

speed of Phantom3 UAS, an equivalent level of safety will be achieved. 

E.- 14 C.F.R. 91.405 (a) (2): 417 (a) & (b): Maintenance Inspections. 

The above cited Regulations require, amongst other things, aircraft owners and operators to "have aircraft inspected as 

prescribed in subpart E of this part and shall between required inspection, except as provided in paragraph © of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter .... " 

These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will not apply to petitioner 

(Michael Prindle, dba: Garuda Video Productions) should this requested exemption be granted. petitioner (Michael 

Prindle, dba: Garuda Video Productions) routinely conducts an extensive maintenance program that includes regular 

software updates, restoration/repair measures for any damaged hardware, and meticulous pre-flight inspections. 

Therefore, an equivalent level of safety will be achieved. 
F.- Summary of Petition Request 

Petitioner (Michael Prindle, dba: Garuda Video Productions) requests 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; 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 the above described lightweight unmanned aircraft in aerial filmmaking, photography, or 

other data collection operations and to conduct its own research; to include the implementation of manufacturerapproved "detection and avoidance systems when compatible. Granting petitioner's (Michael Prindle, dba: Garuda 

Video Productions) request for exemption will reduce current risk levels and thereby enhance safety. Up until recently, 

commercial filming production companies conducting aerial image capture and aerial data collection relied primarily on 

the use of larger aircraft utilizing combustible fuel. This petitioner's aircraft does not contain potentially flammable 

liquid fuel, is smaller, lighter and more maneuverable than conventional motion picture company aircraft. Petitioner 

(Michael Prindle, dba: Garuda Video Productions) operates at lower altitudes and in controlled airspace. And has been 

analyzing flight data and other information in compiling up-to-date safety protocols and the implementation of a flight 

operations procedures that exceed currently accepted means and methods for safe flight. Since there are no people on 

board this UAS, there is no risk of death or serious bodily injury to pilot, crew, or passengers. The operation of this UAS, 

weighing less than 5 pounds and travelling at speeds lower than 40 mph in calm air and is limited to operations in 

specifically defined NAS, it routine operation will provide at least an equivalent level of safety as that achieved under 

current FARs. 

Accordingly, petitioner (Michael Prindle, dba: Garuda Video Productions) respectfully requests that the FAA grant its 

exemption request as soon as possible. The FAA has the authority to issue the exemption sought by petitioner pursuant 

to the Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act''}. 

In closing, I emphasize that the utmost care and attention will be devoted to safety and concern for the protection and 

welfare of persons and property in proximity to the operation of all UASs in my possession and remain current on FAA 

regulations, procedures, and follow "best practices" pertaining to the operation and maintenance of all UASs used in 

conducting the operations and uses described above. As a responsible, FAA certified airman, and experienced UAS pilot, 

I will strive to conduct operations in the safest way possible. Thank you for your time and consideration in this request. 

Respectfully, 

~~ Michael Prindle, 

dba: Garuda Video Productions 

Owner/Operator/PIC 

5334 Lakecrest Road 

Caledonia, IL 61011 

(815) 713-0911