Mikka Pineda

dba Flying Piggy

1808 San Pablo Ave, Unit C

Berkeley, CA 94702

321-337-8350

mikkasoft@gmail.com

October 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave

SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 

Title 14 CFR 21 subpart H; 

Title 14 CFR 45.23(b); 

Title 14 CFR 61.113(a); 

Title 14 CFR 91.7(a); 

Title 14 CFR 91.9(b)(2); 

Title 14 CFR 91.103;

Title 14 CFR 91.109; 

Title 14 CFR 91.119; 

Title 14 CFR 91.121; 

Title 14 CFR 91.151(a); 

Title 14 CFR 91.203 (a) and (b); 

Title 14 CFR 91.405 (a); 

Title 14 CFR 91.407 (a) (1);

Title 14 CFR 91.409 (a)(1) and (2); 

Title 14 CFR 91.417

Dear Sir or Madam:

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

Act”) and 14 C.F.R. Part 11, Flying Piggy, operator of Unmanned Aircraft Systems 

(“UASs”) for aerial photography and videography, hereby applies for an exemption from 

the Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs to 

obtain aerial images (including video) for use in marketing, research and entertainment.

Flying Piggy’s operation of small UASs, described herein, will benefit the public by

providing a safer and more affordable means of obtaining aerial images than previously 

available through helicopters and airplanes. Flying Piggy’s UASs will pose no threat to 

the public given their small size and weight, lack of combustible fuel and their safe and 

responsible operation.
Flying Piggy’s requested exemption would permit the operation of small UAS in 

controlled conditions in the NAS that are 1) limited, 2) predetermined, 3) subject to 

controlled access, and 4) provide safety enhancements over conventional aircraft. 

UASs that will be operated by Flying Piggy are multi-rotor aircraft that weigh less than 

55 pounds, including payload (i.e. camera, lens, and gimbal). They are no more than 1 

meter in diameter. They operate at speeds of no more than 40 mph, can hover, and can 

simultaneously move vertically and horizontally. They have a maximum flight time of 35 

minutes. They will not carry a pilot or passengers. They are remotely controlled by a 

ground-based operator using a 2.4GHz radio controller that complies with part 15 of the 

FCC Rules. They are powered by lithium-polymer battery and do not carry flammable 

fuel or explosive materials.

Flying Piggy will operate UASs according to these safety precautions:

1. Flights will be conducted at an altitude of no more than 200 feet AGL to ensure 

separation between UAS and conventional aircraft.

2. Flights will be conducted during daytime Visual Flight Rules conditions.

3. UAS will weigh less than 55 pounds.

4. UAS will fly within visual line of sight (VLOS) of the pilot in command (PIC) and/or 

visual observer (VO).

5. Flying Piggy will not operate in restricted airspaces where the FAA prohibits UAS 

operations.

6. Flying Piggy will maintain certain distances away from airports or heliports: 5 

nautical miles (NM) from an airport having an operational control tower; or 3 NM 

from an airport with a published instrument flight procedure, but not an 

operational tower; or 2 NM from an airport without a published instrument flight 

procedure or an operational tower; or 2 NM from a heliport with a published 

instrument flight procedure

7. Flying Piggy will obtain consent of all persons involved in the filming and ensure

that only consenting persons will be allowed within 100 feet of the flight

operation. 

8. The PIC and VO must be trained in UAS operations and have received

current information on the particular UAS to be operated.

9. The PIC and VO will at all times be able to communicate verbally.

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

obtained.

11.Flights will be terminated at 25% battery power reserve in order to leave enough 

power to return the UAS to its pre-determined landing zone.

12.If the UAS loses communications or loses its GPS signal, the UAS will have the

capability to return to a pre-determined location and slowly land.

13.The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

14.Flying Piggy will conduct extensive preflight inspections and protocols, during 

which safety carries primary importance.
15.The operator will ensure that the UAS is in working order prior to flight and 

perform any required maintenance.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security) provide adequate justification 

to grant Flying Piggy’s requested exemption, allowing for Flying Piggy’s UAS 

commercial operations.

If you have any questions or need any additional information, please contact the 

undersigned at 321-337-8350 or mikkanthrope@gmail.com.

Sincerely yours,

Mikka Pineda

Director, Flying Piggy