January 16, 2016
United States Department ofTransportation Docket Management System 1200 NewJersey Ave., SE WestBuilding Ground Floor Room W12-140 Washington, DC 20590

Re: Exemption Request PursuantTo Section 333 ofthe FAA Reform Actof2012

Dear Sir or Madam:

I am writing pursuant tothe FAA Modernization and Reform Actof2012 (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 ownerand operatorofsmall unmanned aircraft be exempted from the Federal Aviation Regulations ("FARs") listed**~below** sothat Michael 

### L. Prindle (dba: Garuda Video Productions) mayoperate asmaJI!Jnmanned**aircraft/lightw~ght** unmanned aircraft systems ("UAS") commercially in airspace (NAS) regulated bythe Federal Aviation Administration ("FAA").
Primary uses forthis sUAS will be lowaltitude 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 othergathering ofdata by instruments aboard the UA. Additional eventualuse may include buying, developing, modifying, installing, and/or testing of"obstacle detection 

### & avoidance systems" confined to controlled and approved areas while adheringto FAA regulations and guidelines forsuch activities, and after properauthorization and registration by the FAA forsuch procedures. This UAS mayalso be used for hobbyist and recreational type activities and operations.

The contracting entities (clients) may include: clients requiring photos and/orvideo footage forwebsites or internet media sites, aerial inspection services for local government agencies, private entities, land developers, architectural firms, real estate agencies, surveyors, advertising agencies, or otherappropriate commercial entities

- to include but not limited to

- approved and authorized aerial inspections of pipelines, power lines, disaster areas, windturbines, agricultural surveys, real estate property, 30topography mapping, and/orsearch/inspection/survey missions requested and authorized by appropriate authorities.

The sUAS is described as asmall, light-weight, quadcoptercommercially 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 motorsfor no pollution orcarbon footprint

.. carries no crew orpassengers, carries no frammablefuel, weighs under 5 pounds, has several onboard monitoring and failsafe systems, and has GPS/autopilot features with audible and visual warning systems which alertthe operator/PIC/VO as to status and condition ofthe 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 safetyfeatures should give the FAA confidence and good cause to find the UAS operation granted bythis exemption to be in the public interest.

The petitioner/operator/PIC ofthis 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 himselfqualified 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 ofoperations 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

### &motorserial nbrs: Nbr of Motors/Model#s/Max Output UAS Builtfor Land/Sea Operation: Potential payloads: Maximum horizontal ground speed: Maximum vertical climb speed: Maxtotal airframe launch weight: Operational Flight Rules: N614QP (affixed to rear outboard motorarms) 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 TerryAve North, Seattle, WA 98109, USA DJI TechnologyCo. Ltd. Phantom 3 Professional P76DCH24A26620 UAS

- Multi-rotorQuadcopter 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-sightfor Operator/PIC/VO

Aircraftdrawing and dimensionsFor the reasons described in this petition, Michael L. Prindle, dba: Garuda Video Productions, respectfully requests the grant ofan exemption allowingthe operation in NAS ofthe described UAS and protocol described in this petition, and while ultimatelyfollowing all rules and restrictions set forth bythe FAA grant pursuantto 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 ofTitle 14 ofthe Code of Federal Regulations from Which the Exemption is being requested: 14CFR 21: 14 C.F.R. 45.23 (b); 14CFR 61.113 (a) 

### & (b); 14C.F.R. 91, etseq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) {2); 14CFR 417 (a) 

### & (b); U.S Dept ofTrans. (and any othersubsequent and relevant code to allowthe petitionerto operate a UAVto perform aerial data collection as described in the above description)



### 3. The Extent of Reliefthat 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 otherflight operations within the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our National airspace system as it is in the public's interestto do so. The lightweight UAS meetsthe definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration ofthis lightweight UAS is expressly contemplated by the Reform Act. Iwould like to operate the aforementioned lightweight UAS priortothe time period by which the Reform Act requires the FAA to promulgate the final rules governingsuch UAS aircraft.



### 4. How.this RequE!st and WaiverGrantWill Benefitthe Public as aWhole: Grantingthis exemption request furthersthe public interest. Congress has already pronounced that it is in the public's interestto integrate commercially flown UASs intothe national airspace system, hence the passing ofthe Reform Act. First, the reduction ofthe air pollution and carbon footprint by using electric aircraftfor commercial and public service operations serves to protectthe environment. Secondly, it has been shown that UASs can be used to perform many comparable operations that formally required large manned aircraftto collect aerial data to achieve a particulargoal.

In the area ofemergency 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 ofwind turbines, power lines, agricultural crops, architectural structures, and pipelines, as well as topography mapping, land surveying, and emergency surveillances

- reduce manpowerand machinery requirements, and diminishesthe 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 oflightweight UAS is negligible when compared tothe conventional full size helicopter, notwithstandingthe statistically noteworthysafety record offull 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 asmall UAS crash under unforeseen circumstances, resulting in no risk offuel igniting afterthe crash.

Whenever aerial data collection is necessary, there are obvious advantages forthe good ofthe 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 threatto persons and property by implementing UASs to performfunctions 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 impactthe quality ofpersohallife, natural " environment, public safety, and asustainable ecological infrastructure.
lastly, with the introduction of UASs intothe marketplace, great strides in the development ofadvanced avionics and aerial electronics have resulted not onlyforthe UAS industry but also lends itselfto 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 meetwith tragedy. The degree oflife and property at risk is much differentwhen comparing a small UAS to a large multi-ton manned aircraft when both are serving thesame purpose orfunction.



# s. Reasons Whythis Requested Exemption Will NotAdverselyAffect Safety or Howthe Exemption Will Provide a Level ofSafetyat Least Equal tothe Existing Rule:

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

The following is a bulleJ Jist ofthe 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 UnmannedAircraft (Airworthiness): UA is equipped with red and green navigation lights as well as awhite LED strobe light. UA has integrated software that always prevents its operation within 

### 15 miles ofthe White House in Washington, DC. UA has an integrated safety procedure in which the PIC is able to immediatelystall all motors instantlyforcing itto freefall tothe ground in the event an unavoidable collision course wouldjeopardize the safety ofpersons or property. UA has an integrated failsafe system onboard in which, ifthe remote control signal is lostfor any reason, the UA will automaticallyascend 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 thatthe onboard "intelligent"flight battery is running a lowcharge so itcan be returned to its launch sight safely without incident.

- UA has aflight mode that allows itto use both GPS positioning and ultrasonic sensors detecting proximityto ground surfaces to ensure its safe operation with only minimal PIC remote control input. Should the PIC inadvertently release the RC controljoysticks on the remote controller radio transmitter, the UA will come to astationary hoverand remain there unaffected by wind, untilthe PIC resumes control.

- UA is equipped with aGPS/Compass system that corrects forsevere drifting in strongwind 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 onboard that now utilizes the Russian GLONASS satellites in addition tothe customary U.S. satellites used in the older GPS systems. This addition feature enhances the integrityand efficacy ofthe GPS and autopilot systems ofthe aircraft, thus improvingsafety and reliability duringflights. UA is equipped with an onboard/under-body LED lighting system and an on-screen display on the monitoring device
on the ground that continuously indicates tothe Operator/PIC/VOthe status ofthe flight mode as well as early warning alerts for conditions possibly involving safety.

- UA has a programmable protocol that allows the Operator/PICto preset altitude ceiling limitations to automatically remain within FAA restrictions to 400 feetAGL. UAS is equipped with a8-inch display monitor mobile device (Samsung Tab-S tablet) that attaches tothe Operator/ PIC's handheld remote controller radio in orderto monitorflight status, flight modes, compass direction of travel, altitude, batterycharge level, Google map position, number ofsatellite locks, etc. -all ofwhich continuously keep the Operator/PIC/VO advised ofthe condition, status, and progress ofthe flight operations realtime. UA is equipped with an onboard 3-axis stabilization gimbal and 720 Hi-Defcamera in combination with the abovementioned 8-inch display monitor- allowingforthe PIC/VO to not only monitorthe flight status, but also visually monitorall possible hindrances, obstructions, orassess safety situations in a94-degree field ofvision to augment and enhance the Operator/PIC/VO's VLOS observations, situational awareness, and detect possible safety issues developing in realtime duringflight. UAS has integrated navigation capability ofdownloading and storing aerial Google topography Maps ofthe precise
areas ofoperation so thatthe Operator/PIC can monitorthe location and progress ofthe UA's position in flight realtime (see Appendixfor photo example ofground position display).

- UAS has integrated failsafe software which will disable the UAS from taking offand also limitthe UAS system from flying within specific GPS preset no-fly zones.**---~** 

### UAS hasflightlogging software that records and stores flightdata. UAS complies with Part 15 ofFCC Rules; it also complies with the limits for aClass Bdigital 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 limitfor civil UAs underthe commercial COA for UAS Operators/PICwho hold an FAA Airman Certification (pilot's License); and 

### 2) thatthe "Hobbyist/Recreational" operators category is granted a "blanket" ruling ofa400-footAGL limitation. It seems to me unfairand impractical in terms ofsafety thatthe "letter ofthe law" FAA ruling seems to contradictthe intended "spirit" ofthe rulingwhich is focused on provisions aimed primarilyat safety in the NAS. Itseems difficultto rationalize that the civil/commercial UASs flown by licensed pilots like myself holding an airman certification are limited to the 200' blanket exemption, whilethe hobbyist pilotwithout an FAA pilot's license enjoys the freedom to fly at400 feet.

### As a 

### pilot, I am authorized tofly asingle-engine, fixed-wing land passenger aircraft in Class-G (and others) airspace at 1,200-feet. Yet while using the same aviation knowledge, FARs, safetyskills, and situational awareness I have accrued and nowautomatically applyto myflying procedures for UASs- Iseem 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, betterjudgment, more knowledge of FARs, more familiaritywith weather criteria, ground school training, FAA flight procedures, more conscious ofa high safety standard ofpractice, 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. Ithinkthatthe maximum AGL altitude for licensed pilots with UAS experience should at least be equal to (orgreaterthan) the maximum altitude granted to hobbyists automaticallyvia 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

- ifanother aircraftwere flying in the general vicinity ofa400' UA, 

### the UAS pilotcould reduce the altitude from 400'to 300' in a matterofseconds to avoid any safetythreatto the approaching aircraft. At 400' the human eye has avery wide field ofvision around the UA aircraft he is operating. And therefore allowing the detection an approaching aircraft in ample time to reduce the UA's altitude quicklyto avoid any threatto the approaching aircraft. This same situation occurs when curious raptors (eagles, hawks, etc) approach the UA on occasion. Merely byvertically descending the UA quickly avoids anythreat ofcollision orattack 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 of2015, the FAA published proposals including a ceiling limitof500' AGL. Therefore, a 500-foot ceiling obviouslywas not beyond the realm ofpossibility for UAs atthattime in the FAA's view. And in terms of

### safety, itseems that a licensed pilot with UAS experience is betterable to avoid compromising safety situations at 400' than a hobbyist pilot operating atthe "blanket" max of 400 feet.

For these reasons, among others, I respectfully request being granted an allowance tofly my registered UAS at altitudes up to 400 feetAGL, which in my 

### case, would be on an occasional basis and lasting less than a minute,

-**posingver-y-~ittlethreatt&**

### the safety ether aircraft. In myoperation; itwould**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 astationary hover at400 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 ofanother aircraft approachingthe proximity ofthe UA in less than 60 seconds. 

### Also, a super-bright LED strobe (white) has been added to the bottom ofairframe as aextra precaution for alerting approaching aircraft. 

### Strobes attract attention.

And forthe sake offairness to othercertified pilots, I respectfully request thatthe "blanket" 200-foot COA ruling currently attached to 333 Exemption recipients be amended immediatelyto allow certified pilots with a333 Exemption also be automaticallygranted the "blanket" 400-foot limitation currently enjoyed by hobbyists and recreational UAS operators having no pilot's license. Itrustyou can appreciate the equity is making such an amendmentto the present 200' COA blanket. Itseems to be discrimination in the wrong direction for safety sake. Thankyou foryour consideration in this recommendation.

### GENERAL REQUESTJUSTIFICATIONS
Regarding the Unmanned Aircraft PIC:

The petitioner/owner/PIC, (Michael Prindle, dba: Garuda Video Productions), has held an FAA Airmen Certification for
overfortyyears. The petitioner is familiar with all aspects aviation 

### safety, airportfacilities and restrictions, and is trained/experienced in aviation flight rules and regulations. Petitioner is qualified to read aeronautical charts, assess weatherconditions/development, and is familiar with the rules and regulations set forth bythe FAA regardingthe operation ofsUAS and UAS aircraft.

The petitioneralso 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 ifthe aircraft is worthy offlight for each operation/flight. The petitioner holds an Illinois drivers 

### license, airmen's certificate, and an AMA membership.



### Regarding the Operation ofthe Unmanned Aircraft:

The Petitioner/PIC states that during the private pilottraining (Airmen Certification# 1762005), the aspect ofsafetythat
was emphasized most by the flight training staffwas "Situational Awareness." The skill ofmaintaining awareness and anticipating a problem orthreat in atimelyfashion, and quickly responding to emergencies in an appropriate manner is absolutely paramountto maintainingsafety at all times.

For that 

### reason, the petitioner/PIC considers himselfskilled and prepared to address all aspects ofsafety in the flying of all UAs in the NAS. Previous experience affordsthe Petitioner/PICthe abilityto plan well ahead and conductflights with the utmost care and caution. There will always be athorough plan and pre-flight procedureto 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 activityon the ground, and airtraffic situations whenever scheduling a project involving UAS flights in a particular area.

The petitioner's pilottraining, federal law enforcement training, and practical experience all contribute to his abilityand skills in conducting avariety of UAS flights in avariety ofsituations. The petitionerstrives always notto allow deadlines
orfinancial gains to cloud his decisions and judgment when accepting civil/commercial assignments and choosing the times andplaces 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 orderto 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 greatersafety and to assist with detection and avoidance protocol. UA will not be operated over (above) any persons, animals, orvehicles (unless authorized by appropriate authorities during asearch/rescue operations underapproved supervision by local authorities. UA will be operated during daylight hours between official sunrise and sunset. PIC will always yield right-of-wayto all otheraircraft in proximity. UA has a maximum rated horizontal speed of35mph in calm air. PIC will adhere tothe maximum limitation of400 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 ofan airport without permission from airport authorities and ATC.

- When operatingthis 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 whilefollowing all safety procedures and regulations set forth bythe FAA. No reckless, careless, or neglectful operations or procedures will be practiced bythe Operator, PIC, orVO.

- When aVO is being used, that VO 

### will be in close proximityto Operator/PICto ensure timely communications.

- Each time the UA is operated, the PIC will conduct athorough pre-flight inspection to ensure the integrity ofthe 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 fullyfunctional. During all flight operations, the Operator/PIC and any VO will be ofgood physical health and mental state ofmind that will not compromise the good skill andjudgment of PIC/VO to performthe operations safety and accurately
as planned, while always practicing situational awareness with a mindfulness toward safetyfor all persons and property in the air and on the ground. During all flight operations, the autopilot and GPS functionalitywill be monitoredto ensure that ifthe remote control signal is lostfor any reason, thatthe UA will automaticallyascend to a safe attitude above trees and strudi..ir'es, and return hometo 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 currentAMA guidelines, sectional maps ofthe area ofoperation; and will acquire all necessary permissions from FAA 

### facilities/ ATC/airport authorities priorto all flight operations. In summary, the petitioner/operator, Michael Prindle, will persist in the safe operation ofthe aforementioned UAS by conducting preflight inspections, routine periodicstructural/electronics inspections, remaining up-to-date in current FAA rulings/regulations, complywith these regulations, and will check current weather conditions and area restriction prior to each flight operation. Furthermore, the petitioner/operatorwill conduct operations in compliance with the rules, regulations, and protocol described herein oras 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 respectsthe same aircraftwhich has previously been cited as Exemption bythe FAA and found to be in the public interest

- accordingto Grants of Exemption Nbrs: 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to 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), 12389to Drone Guys (see Docket No. FAA-2015-1260).

--<::-**~-~** -**~**



### 7. Summary:

A.

- 14C.F.R. 21 and 14C>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 ofthe petitioner's (Michael Prindle, dba: Garuda Video Productions) UAS permits exemption from Part 21 because petitioner's UAS meets an equivalent level ofsafety pursuantto Section333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both the Act {49 U.S.C. § 44701 (f) and Section 333 ofthe Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration ofthe weight, size speed, maneuverabilityand proximityto areas such as airports and dense populations. The petitioner's UAS meets or exceeds each ofthe elements. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in theform contemplated bythe FARs, this Regulation is inapplicable.14 C.F.R 

### § 91.9(b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs, this Regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining a manual at theflight operations center. The FAA has previously issued exemptions totheir regulation in Exemption Nos 8607, 8737, 8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. 14C.F.R. 

### § 91.121 regarding altimetersettings is inapplicable insofar as the petitioner's UAS utilizes electronic global positioning systems and internal compass/gyroscopes to provide spatial coordination. 14C.F.R. § 91.203 (a}) and (b) provides forthe carrying ofcivil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations at Garuda Video Productions flight operations center.

B.

- 14 C.F.R § 45.23: Markingofthe Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. The petitioner's UAS is, by definition, unmanned. Ittherefore does not have a cabin, cockpit or pilotstation on which to mark certain words or phrases. Further, two-inch lettering is difficultto place on such small aircraft as the DJI Phantom Professional measuring less than sixteen (16} inches at its widest points and having a height ofeight (8} inches. However, (Michael Prindle, dba: Garuda Video Productions) will markthe UAS in the largest possible lettering required bythe Exemption grant by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so thatthe pilot, technician, spotter and others workingwith 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" forthis UA will be affixed tothe airframe in the largest possible letters appropriate forthe size ofthe airframe, and will display in a contrasting colorfor best visibility.

C.- 14 C.F.R. § 61.113: Private PilotPrivileges and Limitations: PIC.

Pursuant to 14C.F.R.§§ 61.113 (a) 

### &(b) private pilots are limited to non-commercial operations. The petitioner can achieve an equivalent level ofsafety 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 attendanttothe operation of petitioner's UAS is far less than the risk levels inherent in the commercial activities outlined in 14C.F.R.§ 61, et seq. Thus, the petitioner (Michael Prindle, dba: Garuda Video Productions) requests relief by awaiver in orderto allow petitionerto operatethe above-described UAS in the prescribed areas ofthe 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 forthe operation ofcivil aircraft. It allows helicoptersto be operated at lower altitudes in certain conditions. The petitionerwill not operate atan altitudegreaterthan 500 AGL (orwhateverthe

- currentFAA-i:feems-as an appropriat-e limitation based on the-qualifications set

### forth

### here).li1-certain-sit-~ations-:tf1e"a~e~~­ offlight operation at low altitudes may be cordoned offwith perimeters for safety and security, providing a level of safety at least equivalent tothose in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of Phantom3 UAS, an equivalent level ofsafetywill be achieved.

E.- 14 C.F.R. 91.405 (a) (2): 417 (a) 

### & (b): Maintenance Inspections.

The above cited Regulations require, amongst otherthings, aircraft owners and operatorsto "have aircraft inspected as prescribed in subpart Eofthis part and shall between required inspection, except as provided in paragraph 

### © ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...." These Regulations onlyapplyto aircraft with an airworthiness certificate.Therefore, theywill not applyto 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 ofsafety 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; 14C.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); 14C.F.R. § 91.409 (a)(2);14 C.F.R. § 91.409 (a)(2);and 14C.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 ofmanufacturerapproved "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 primarilyon the use oflarger aircraft utilizing combustible fuel. This petitioner's aircraft does not contain potentiallyflammable 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 ofaflight operations procedures that exceed currently accepted means and methods forsafe flight. Since there are no people on board this UAS, there is no risk ofdeath orserious bodily injuryto pilot, crew, or passengers. The operation ofthis UAS, weighing less than 5 pounds and travelling at speeds lowerthan 40 mph in calm air and is limitedto operations in specifically defined NAS, it routine operation will provide at least an equivalent level ofsafety as that achieved under current FARs. Accordingly, petitioner (Michael Prindle, dba: Garuda Video Productions) respectfully requests thatthe FAA grant its exemption request as soon as possible. The FAA has the authorityto issue the exemption sought by petitioner pursuant tothe Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act''}.

In closing, I emphasize thatthe utmost care and attention will be devoted to safety and concern forthe protection and welfare of persons and property in proximitytothe operation ofall UASs in my possession and remain current on FAA regulations, procedures, and follow "best practices" pertainingtothe operation and maintenance ofall UASs used in conductingthe operations and uses described above. As a responsible, FAA certified airman, and experienced UAS pilot, Iwill strive to conduct operations in the safest way possible. Thankyou foryourtime and consideration in this request. Respectfully,

# ~~ Michael Prindle, dba: Garuda Video Productions Owner/Operator/PIC 5334 Lakecrest Road Caledonia, IL 61011 (815) 713-0911