Mikka Pineda

d ba Flying Piggy

1808 San Pablo Ave, Unit C Berkeley, CA 94702

321

- 337

- 8350

mikka soft @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 2 1 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, Flyin g Pigg y

, operator of Unmanned Aircraft Systems (“UASs”) for aerial photography and videography

, hereby applies for an exemption fr om the Federal Aviation Regulations (“FARs” ) to allow c om mercia l operati on of its UASs to obtain aerial images (including video) fo r use in marketing, research and entertainment

.

Flying Piggy ’ s ope ration o f small UAS s , described her e in, will benefit the public by providing a safer and more affordable means of obtaining aerial images than previously

available thr ough helicopters and airplanes. Flying Piggy ’ s UASs will pose no thre at to the p ublic given the ir small size and weight

, lack of combustible fuel and thei r safe and
responsible operation

.Flying Piggy ’ s requested exemption would permit the operati on of small UAS in

controlled conditions in the NAS that are 1) limited, 2 ) predetermined, 3 ) subje ct t o 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, incl uding payload (i.e. camera, lens, and gimbal). They are n o more than 1

meter in diameter. They operate at speeds of no more than 4 0 mph, can hover, and can simultaneously move vertically and horizontally. They have a maximum flight time of 35

minutes. They will not carry a pil ot 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 l ithium

- polymer batter y 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

visua l obs erver (VO)

. 5. Flying Piggy wi ll not operate in restricted air spaces 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 w ith 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 b e 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, duri ng which safety carries primary importance.15. T he 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 Re form 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 UA S
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