January 11, 2016 

Three Pines Productions, LLC 

121 Reservoir Road 

Wilsall, Montana 59086 

406-578-2321 

kent@3Qbn.tv 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 

and Part 11 of the Federal Aviation Regulations from 14 C.F.R 21(h); 14 C.P.R. 43.7; 14 C.P.R. 

43.11; 14 C.P.R. 45.11; 14 C.P.R. 45.27; 14 C.P.R. 45.29; 14 C.P.R. 91.7(a); 14 C.P.R. 91.9(b) 

(2); 14 C.P.R. 91.9(c); 14 C.P.R. 91.103(b)(2); 14 C.P.R. 91.105; 14 C.P.R. 91.113(b); 14 C.P.R. 

91.119(b) and (c); 14 C.P.R. 121; 14 C.P.R. 91.151; 14 C.P.R. 91.203(a) and (b); 14 C.P.R. 215; 14 

C.P.R. 91.403; 14 C.P.R. 405 (a) and (b); 14 C.P.R. 91.407; 14 C.P.R. 409; and 14 C.P.R. 91.417. 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 

C.P.R. Part 11, Three Pines Productions, LLC, an operator of Small Unmanned Aircraft Systems 

("sUAS") equipped to film and photograph aerial inspections, patrolling, photography and 

videography of residential and commercial real estate, electrical power lines, wind turbines and cell 

towers, pipelines; filmmaking, cinematography, wildlife and forestry monitoring, aerial surveying, 

construction site inspection and monitoring, public entity support operations, aerial imaging for 

safety, monitoring and comparing work efforts and completion percentages, and security of 

controlled environment of various sites, aerial video and live video feed to assist with search and 

rescue operations under the authority and support of local authority officials; public and private use 

including television, public events, cinematography live feed and live newsgathering, training, 

special events, research, risk management and assessment, motion picture production, surface 

mining, closed-set filming, and disaster and catastrophe events throughout the United States but 

primarily in the state of Montana, applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

):, ', ' 
Approval of exemptions for Three Pines Productions, LLC will allow commercial operations of 

sUASs in rural, remote, low density areas of the United States but primarily in the state of Montana, 

for the purpose of aerial inspections, patrolling, photography and videography of residential and 

commercial real estate, electrical power lines, wind turbines and cell towers, pipelines; filmmaking, 

cinematography, wildlife and forestry monitoring, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing 

work efforts and completion percentages, and security of controlled environment of various sites, 

aerial video and live video feed to assist with search and rescue operations under the authority and 

support of local authority officials; public and private use including television, public events, 

cinematography live feed and live newsgathering, training, special events, research, risk management 

and assessment, motion picture production, surface mining, closed-set filming, and disaster and 

catastrophe events. 

The pilot in command (PIC) is a certified commercial and instrument-rated twin-engine pilot with 

more than 6,500 hours of flight time, and has a second class medical certificate. The owner of the 

company is a student pilot and has flown sUAS aircraft for nearly 20 years. The requested exemption 

should be granted because the proposed operations of the Yuneec Q500 4K, a small UASs that 

weighs 60.0 oz, inclusive of battery and payload, conducted in the strict conditions outlined below, 

will provide an equivalent level of safety, as Congress intended, while still allowing commercial 

operations. The lightweight aircraft covered by the exemption are far safer than conventional 

operations conducted with manned helicopters and fixed-wing aircraft weighing thousands of 

pounds, containing highly flammable fuel, and operating in close proximity to the ground and 

people, as a similar UAS has been previously approved in Exemption No. 14227 Mr. Robert Crum. 

The seven factors Congress directed the FAA to consider when approving Section 333 exemption 

petitions - size, weight, speed, operational capability, proximity to airports, proximity to populated 

areas, and operation within visual line of sight - each support the request. In particular, the aircraft 

is small, and will operate at slow speeds, close to the ground, far from airports and in a low risk, low 

population environment. In addition, the substantial experience of the PIC weighs heavily in favor of 

granting the exemption. 

Pursuant to 14 C.F.R. 11.35, Three Pines Productions, LLC requests confidential treatment for certain 

information provided with this request for exemption. Specifically, Three Pines Productions, LLC 

requests that information contained in its user manual, operating procedures not be made public due 

to the proprietary information that the applicant has not and will not share with others. Additionally, 

Three Pines Productions, LLC requests that personal information related to the PIC not be made 

public in order to protect his identity. These documents are not available to the public and are 

protected from release under the Freedom of Information Act 5 U.S.C. 552. 

For your ease in reviewing this petition please refer to the table of contents which begins on page 

three. If we can provide any additional information to assist your understanding or review of this 

document, please do not hesitate to contact us at 406-578-2321 or email at kent@3pbn.tv. 

Thank you, 

/""" 

-~ 2[ '-:2..-;.::%:~-~-'4 ·~.... -~:::....- -~- " 

~~ - Kent Grabau 

President 

Three Pines Productions, LLC 
Table of Contents 

• Publishable Summary ..................................................................................................................... 5 

• Petitioner's Contact Information .................................................................................................... 6 

• Three Pines Productions LLC's Operations ................................................................................... 6 

• The sUAS .............................................................................................................................. 6 

• Flight Conditions ................................................................................................................... 7 

• Flight Operations ................................................................................................................... 7 

• Privacy ............................................................................................................................................ S 

• Aircraft and Equivalent Level of Safety ......................................................................................... 9 

• Public Interest and Safety ............................................................................................................... 1 0 

• Regulations from Which Exemption is Requested ......................................................................... 11 

• 14 C.F.R. 21(h): Airworthiness Certificates ................................................................................... 11 

• 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines,propellers, 

appliances, or component parts for return to service after maintenance, preventive maintenance, 

rebuilding, or alteration ................................................................................................................. 12 

• 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts 

91 and 125 and §§135.411(a)(1) and 135.419 ofthis chapter ........................................................ 12 

• 14 C.F.R. 45.11: Marking of products ............................................................................................ 13 

• 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft ......................................................... 13 

• 14 C.F.R. 45.29: Size ofmarks ....................................................................................................... 13 

• 14 C.F.R. 91.7(a): Civil aircraft airworthiness ............................................................................... 14 

• 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard requirements ................ .14 

• 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements ...................... 15 

• 14 C.F.R. 91.103(b)(2): Preflight action ......................................................................................... 15 

• 14 C.F.R. 91.105: Flight crewmembers at stations ......................................................................... 15 

• 14 C.F.R. 91.113(b ): Right-of-way rules: Except water operations ............................................... 16 

• 14 C.F.R. 91.119( c): Minimum safe altitudes: General.. ................................................................ 16 

• 14 C.F.R. 91.121: Altimeter Settings .............................................................................................. 17 

• 14 C.F.R. 91.151 : Fuel requirements for flight in VFR conditions ................................................ 1 7 

• 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required ............................................... 18 

• 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use ........................ 19 

• 14 C.F.R. 91.403: General. ............................................................................................................. 20 

• 14 C.F.R. 91.405 (a) and (d): Maintenance Required ..................................................................... 20 

• 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or 

alteration ......................................................................................................................................... 21 

• 14 C.F.R. 91.409: Inspections ........................................................................................................ 21 

• 14 C.F.R. 91.417: Maintenance records ......................................................................................... 21 

P< I Kl•\ 116. \41 il-,all. ,\i I W086 ; , ': -f:Jf>. :- -x.2J"~ I 
Exhibit List 

Exhibit 1: Yuneec Q500 4K Manual.. ....................................................................... Submitted Separately 

Exhibit 2: Yuneec Q500 4K- Specs ........................................................................................................ 21 

Exhibit 3: Yuneec Q500 4K Camera Gimbal- Specs ............................................................................. 21 

Exhibit 4: Yuneec Q500 4K Ground Control- Specs ............................................................................. 22 

Exhibit 5: YPP Flight Operations Manual ................................................................ Submitted Separately 

Exhibit 6: Memorandum from Mark W. Bury, Assistant Chief Counsel for Int'l Law, Legislation and 

Regulations, Fed. Aviation Admin., to John Duncan, Dir., Flight Standards Serv. (Aug. 8, 

2014) ........................................................................................................................................................ 24 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
Additional documents have been submitted to the FAA 

confidentially and are not available to the public. 

• Publishable Summary 

Pursuant to 14 C.F.R. Part 11, the following swnmary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 

14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 

C.P.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b) 

and (c); 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 

91.403; 14 C.F.R. 405 (a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 

91.417. 

Approval of exemptions for Three Pines Productions LLC will allow commercial operations of 

sUASs in rural, remote, low density areas throughout the United States but primarily in the State of 

Montana, for the purpose of aerial inspections, patrolling, photography and videography of 

residential and commercial real estate, electrical power lines, wind turbines and cell towers, 

pipelines; filmmaking, cinematography, wildlife and forestry monitoring, aerial surveying, 

construction site inspection and monitoring, public entity support operations, aerial imaging 

for safety, monitoring and comparing work efforts and completion percentages, and security of 

controlled environment of various sites, aerial video and live video feed to assist with search 

and rescue operations under the authority and support of local authority officials; public and 

private use including television, public events, cinematography live feed and live 

newsgathering, training, special events, research, risk management and assessment, motion 

picture production, surface mining, closed-set filming, and disaster and .catastrophe events. The 

pilot in command (PIC) is a certified commercial and instrument-rated helicopter pilot with 

more than 6,1 00 hours of flight time, and has a second class medical certificate. The requested 

exemption should be granted because proposed operation of the Yuneec Q500 4K, a small 

UASs weighing 60 ounces, ip.clusive of battery and payload, conducted in the strict conditions 

outlined below, will provide an equivalent level of safety, as Congress intended, while still 

allowing commercial operations. The lightweight aircraft covered by the exemption are far 

safer than conventional operations conducted with helicopters and fixed-wing aircraft 

operating in close proximity to the ground and people. The seven factors Congress directed the 

FAA to consider when approving Section 333 exemption petitions - size, weight, speed, 

operational capability, proximity to airports, proximity to populated areas, and operation 

within visual line of sight - each support the request. In particular, the aircraft are small, and 

will operate at slow speeds, close to the ground, far from airports and in a low risk, low 

population environment. In addition, the substantial experience of the PIC weighs heavily in 

favor of granting the·exemption. 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
• Petitioner's Contact Information 

Three Pines Productions LLC 

PO Box 116 

Wilsall, MT 59086 

Tel: 406-578-2321 

Email: kent@3pbn.tv 

• Three Pines Productions LLC's Operations 

• ThesUAS 

The requested exemption will permit the operation of the Yuneec Q500 4K. The Q500 4K is a 

small, unmanned multirotor aircraft, weighing 60 ounces inclusive of batteries, the propellers, and 

technical payload. This rotorcraft can operate at a speed up to 29 knots, but Three Pines Productions 

LLC ("Three Pines Productions) will limit the speed to no more than 20 knots. The FAA has 

previously granted Exemption No. 14227 Mr. Robert Crum, allowing commercial flight of a member 

of the Yuneec Q500 family. 

The sUAS will have the following specifications: Airframe: 

Yuneec Q500 4K 

FLIGHT TIME: Up to 25 Minutes 

DIMENSIONS: 8.27 in (210mm) x 16.54 in (420mm) 

DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm) 

PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm) 

WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g) 

MAXIMUM TAKEOFF WEIGHT WITH CG03: 60.0 oz (1700g) 

BATTERY: 5400mAh 3S 11.1V LiPo (included) 

CHARGER: 3S 11.1 V LiPo DC Balancing Smart Charger with AC Adapter (included) 

TRANSMITTER: 10-channel2.4GHz with 5.8GHz video downlink (included) 

MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground Level 

(Adjustable via the Q500 GUI) 

MAXIMUM ROTATION RATE: 65°/s 

MAXIMUM ROLL ANGLE: 35° 

RADIO CONTROL FREQUENCY BAND: 2.4GHz 

MAXIMUM CLIMB RATE: 2m/s 

MAXIMUM DESCENT RATE: 3m/s 

Please refer to Exhibits 1- 5 for further information about the sUAS and transmitter. 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
• Flight Conditions 

The sUAS will be flown in airspace under 400 feet above ground level ("AGL") and under 

controlled conditions. The majority of flights will take place under 100 feet AGL. Three Pines 

Productions's operations will occur in rural, remote, low density areas throughout the United States but 

primarily in the State ofMontana. Three Pines Productions will avoid congested and densely populated 

areas and will work with local Flight Standard District Offices to determine safe areas to fly in. Three 

Pines Productions will only operate its sUAS in VMC, visual meteorological conditions: no less than 

500 feet below and no less than 2,000 feet horizontally from a cloud or when visibility at least 3 

statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every 

operation, and will only operate when it is determined that no undue hazards are present. 

• Flight Operations 

Three Pines Productions's flight operations require that the sUAS will always be in the line of 

sight of both a PIC and a monitor specialist, who will also act as the visual observer (VO). Flights 

will be at altitudes of no more than 400 feet AGL, and at speeds less than 20 knots. Despite the 400 

ft. AGL limit, most flights will take place at an altitude of no more than 100ft. AGL. 

The PIC has the following licenses and certifications: ATP (Airplane Multi-Engine Land) 

Pilot, Commercial (Airplane Single·Engine Land) Pilot, CFII (Certified Flight Instructor Intrument), 

AGI (Advanced Ground Instructor), is type rated in the BE-1900, and has a second class medical 

certificate. The VO has over 20 years of experience with RC aircraft, and has thousands of hours 

flying sUAS as a hobbyist, and is a student pilot with 36 hours of flight time in Cessna 182 aircraft. 

The week of an operation, the flight crew will file a flight plan with the local FSDO and 

contact ATC. The day before an operation, the flight crew will visit and inspect for safety the area in 

which operations will take place. The flight crew will also contact any neighbors to notify them of 

the filming. The sUAS will only fly over land which it has permission from the landowner or 

landowner's agent to fly above. The notification will consist of, at minimum, the time, place, and 

type of VAS operation being conducted. The flight crew will also have letters to leave in mailboxes 

and front doors, informing neighbors of the planned sUAS operations. The flight crew will also 

conduct a safety briefmg with the property owners. 

Operations will not take place in congested or densely populated areas, and the PIC will work 

with the local FSDO when planning operations. The flight crew will obtain all aeronautical and 

weather data information. 

Prior to departing for an operation, the flight crew will briefly turn on the sUAS to ensure that 

everything is connected and that the sUAS is in operational condition. 

Upon arrival at a location for filming or photography, the flight crew will conduct an aerial 

and ground preflight inspection. This inspection is listed in the Three Pines Productions Operations 

Manual. 

The flight crew will then set out traffic cones to designate the aircraft's "home area," which 

will be approximately 20 feet in diameter, to mark the sUAS take-off and landing zone. 
Note: If the radio control link is broken during flight, the autopilot system will recognize this 

broken control link and cause the sUAS to automatically return to the home area as recorded by the 

GPS instrumentation. 

The flight crew will conduct a physical inspection of the aircraft as set out in the Operations 

Manual. 

The PIC will then conduct a pre-flight inspection as outlined in the Operations Manual. 

The geo-fence is a virtual 'barrier' that will keep TYPHOON from traveling further than 300 

feet from the pilot. Should the pilot lose orientation, during the flight, the pilot may activate 'Home' 

mode which will cause the Q500 to fly in a straight line to the pilot and land. 

The Yuneec Q500 4K also has "no fly zones" programmed into it, which will prevent flights 

in restricted zones. Although Three Pines Productions will take every precaution to avoid flying in 

airspace other than class G airspace, the preprogrammed "no fly zones" will add an additional level 

of safety to operations. 

Other than this automated feature of the Yuneec Q500 4K, the PIC will always fly the sUAS 

manually. The PIC and VO have tested the sUAS in a variety of weather conditions, including on 

overcast days and in winds up to 25 knots. The PIC and VO will not fly the sUAS in heavy 

rainstorms, due to decreased visibility and the potential for water damage to the sUAS. The PIC and 

VO have also practiced emergency bailout procedures by having the sUAS return to home. In the 

event of an emergency, the PIC will release the joysticks. This will make the sUAS automatically 

hover in place and maintain its position and altitude, and the PIC and VO can determine if and when 

it is safe for the sUAS to return to the home location. 

During flights, the PIC and the VO will be standing next to each other, in oral communication 

at all times at the ground station. The VO will observe the telemetry data on a hand-held monitor and 

will monitor the images from the camera The VO will direct the PIC if he wishes to capture a 

different angle on the camera. The camera will be filming or taking still images at intervals during 

the entirety of the flight. 

Flights will be limited to 18 minutes, which is 75% of the total battery life of the Yuneec 

Q500 4K. Once the sUAS has landed, the PIC will conduct a post-flight checklist as set out in 

Appendix D of the Operations Manual. 

• Privacy 

There is little concern that the proposed flights will cause invasions of privacy because all 

flights will occur property owner's prior knowledge and consent. The only people and/or property to 

be filmed will have requested and hired Three Pines Productions for the express purpose of filming 

and photographing the people and/or property with the sUAS. 

No attempt will be made to identify any individuals filmed or photographed during the flights who 

have not consented to be filmed or photographed, except in cases where they are trespassing upon or 

damaging customer property, or interfering with the applicant's or its customers' operations 

PO Box 116. \\> i I sail, tv! I .'i9086 1.:1: 406-5 78-21 ~I 
• Aircraft and Equivalent Level of Safety 

Three Pines Productions proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These limitations 

provide for at least an equivalent or higher level of safety to operations under the current regulatory 

structure. 

These limitations and conditions to which Three Pines Productions agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

• The sUAS will weigh significantly less than fifty (50) lbs. The Yuneec Q500 4K weighs 60 

ounces, inclusive of battery and payload. 

• Flights will be operated within line of sight of a pilot and VO. 

• Maximum total flight time for each operational flight will be 75% of battery life. Flights will be 

terminated once the battery reaches a 25% level. This data will be available through telemetry 

data submitted to the transmitter and monitor. 

• The sUAS will remain clear and yield the right of way to all other manned operations and 

activities at all times. 

• Flights will be operated at an altitude of no more than 400 feet AGL. Despite this limitation, the 

majority of flights are anticipated to operate at no more than 100 feet AGL. 

• Minimum crew for each operation will consist of the sUAS PIC and VO. 

• A briefing will be conducted in regard to the planned sUAS operations prior to each dais 

activities. It will be mandatory that all personnel who will be performing duties in connection 

with the operations be present for this briefing. 

• The operator will obtain a FAA UAS Civil COA prior to conducting any operations under this 

grant of exemption. 

• The operator will request a Notice to Airman (NOT AM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. 

• At least three days before scheduled filming, the operator of the sUAS will submit a written 

Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. 

• The PIC is a certified commercial and instrument-rated airplane pilot with more than 6,500 

hours of flight time, and has a second class medical certificate. 

• The PIC and VO have practiced the Yuneec Q500 4K for approximately 60 minutes a day, 

every day, for 90 days, translating to 90 hours of flight on this model. Practice flights have been 

in a variety of weather conditions, including in winds up to 25 knots and on overcast days. 

Practice flights have also included using the Yuneec Q500 4K's return-to-home feature. 

I 1<.,) 
• The PIC and VO will at all times be able to communicate by voice and be stationed next to 

each other at the ground station. 

• Written and/or oral permission from the landowner or authorized agent, of the land over which 

the sUAS will be flying. 

• All required permissions and permits will be obtained from territorial~ state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

• The sUAS will have the capability to abort a flight in case of unexpected obstacles or 

emergencies. The PIC and VO have practiced the emergency failsafe procedures. 

• If the multirotor and its controller disconnects during flight, the system's failsafe protection will 

come to the rescue and the multirotor will return to home and land automatically, rather than 

flying off uncontrollably or landing at an unknown location. 

• Because the PIC is a licensed commercial pilot, he has been subject to the security screening by 

the Department of Homeland Security. Additionally, the sUAS that will be used, a Yuneec 

Q500 4K weighs 60 ounces, inclusive of battery and payload. Approval of commercial 

flights as outlined in this petition present no national security issue. 

Satisfaction of the criteria provided in Section 3 3 3 of the Reform Act of 20 12--size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual 

line of sight and national security provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant's sUAS pursuant to Three Pines 

Productions's rules of operation appended hereto. 

• Public Interest and Safety 

Use of the sUAS will increase ground safety by eliminating the need to have a manned, 

aircraft take the videos or photographs. As the FAA recognized in the Douglas Trudeau, Realtor® 

Exemption, No. 11138: 

"Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, 

are operated by an onboard pilot and may carry other onboard crewmembers, as well as 1 00 

gallons or more of fueL The petitioner's [sUAS] weighs less than 3 lbs. The pilot and crew 

will be remotely located from the aircraft. The limited weight reduces the potential for harm 

to persons or damage to property in the event of an incident or accident. The risk of an 

onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS] 

for the proposed operation." Exhibit 10 at 11-12. 

As in the cited exemption, Three Pines Productions will use a Yuneec Q500 4K weighing just 

60 ounces, inclusive of battery and payload. 

During Three Pines Productions's operations, the PIC and VO will similarly be safely on the 

ground, directing the Yuneec Q500 4K at altitudes no higher than 400 feet AGL. Three Pines 

Productions will not fly over congested or densely populated locations, and will work with local 

FSDO when planning operations. Three Pines Productions's flight crew will make a safety 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
assessment prior to each operation, and will only operate when there are no undue risks. 

The small weight, 60 ounces, is less than the size envisioned in Section 334(c)(2)(C) of the 

FAA Modernization and Reform Act of 2012, which allows government agencies "to operate 

unmanned aircraft weighing 4.4 pounds or less, if operated-

• within the line of sight of the operator; 

• less than 400 feet above the ground; 

• during daylight conditions; 

• within Class G airspace; and 

• outside of 5 statute miles from any airport, heliport, seaplane base, spaceport, or other 

location with aviation activities." 

Congress's determination that government agencies should be allowed to operate such aircraft 

in these situations, with no further restrictions on location, population density, or pilot experience and 

training, indicates that Congress did not believe that aircraft of this size and weight warranted 

additional attention. 

The PIC for Three Pines Productions is a professional commercial pilot, who flies a 

Beachcraft 1900. As the FAA recognized in Exemption No. 1162, manned aircraft of this size can 

pose a much greater threat to its occupants as well as to individuals on the ground. Additionally, a 

much greater space will be necessary for takeoff, landing, and operations than would be necessary 

for the 60 ounces sU AS that Three Pines Productions requests an exemption to use and may render 

filming an area impossible, due to the areas Three Pines Productions wishes to operate in, and the 

low height footage Three Pines Productions wishes to shoot. 

• Regulations from Which Exemption is Requested 

• 14 C.F.R. 2l(h): Airworthiness Certificates 

Three Pines Productions requests an exemption from 14 C.F.R. 21(h). This exemption meets 

the requirements for an equivalent level of safety pursuant to Section 333 based on the small size, 

light weight, relatively slow speed, and use in controlled environments on private land, as described 

previously in this petition. 

Eguivalent level of safety: Three Pines Productions's proposed exemption meets the 

requirements for an equivalent level of safety of this section, pursuant to Section 333, based on 

the following factors: 

• Small size: the Yuneec Q500 4K has a diagonal length of 565 millimeters, 22.2 inches. 

• Light weight: 60 ounces. 

• Relatively slow speed: the PIC will limit the sUAS's speed to 20 knots (23 miles per 

hour). 

• Operational capacity: currently, the Yuneec Q500 4K can operate for 25 minutes. 

Flights will be terminated when 25% ofthe battery life remains. The Yuneec Q500 4K 

can travel no more than 1,000 meters, 3280.84 feet, from the receiver. 

• Proximity to airports: Three Pines Productions will only operate in Class G airspace, 

and will notify ATC and the local FSDO prior to operations, as described previously. 

• Proximity to populated areas Three Pines Productions will avoid the yellow congested 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
areas in Sectional Aeronautical Charts, and work with the local Flight Standards 

District Offices to determine which areas to avoid during flights. Local FSDO may 

carve out areas indicated as yellow in the sectional chart and allow Three Pines 

Productions to fly in these specifically designated carve-out areas. 

• Operation within visual line of sight: The PIC will always fly the sUAS within its line 

of sight. 

• Location: Three Pines Productions will operate in areas with low population densityto 

take photographs and video. 

• Altitude: no more than 400 feet AGL, but the majority of flights are anticipated at no 

more than 100 feet AGL. 

• Restricted area in which the sUAS will be operated: as described above, prior to the 

day of filming, the flight crew will visit with neighbors to inform them of the filming 

over the consenting landowner's property. During filming, which will occur in rural 

areas, the flight crew will set out cones to mark the "home area" for the sUAS, and 

will monitor the area to make sure no one comes into the flight area. Should any 

nonparticipating individual enter the flight area, operations will immediately cease. 

See Exhibit 1 0 at 19. 

• Substantial experience of the PIC: the PIC has a commercial fixed wing license with 

an IFR rating, with more than 6,500 hours of flight time in manned aircraft. 

• 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, 

propellers, appliances, or component parts for return to service after maintenance, 

preventive maintenance, rebuilding, or alteration. 

Three Pines Productions requests an exemption from 14 C.F.R. 43.7. This part provides, inter 

alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, 

airframe, aircraft engine, propeller, appliance, or component part for return to service. As described 

previously, Three Pines Productions's flight crew will be capable to repair and maintain the Yuneec 

Q500 4K to meet an equivalent level of safety ofthis section. 

Equivalent level of safety: The nature of the sUAS is that of a model aircraft, and the 

operators of Three Pines Productions who will maintain and when necessary repair the sUAS will 

conduct inspections and maintenance based on maintenance guidelines provided by the manufacturer 

of the sUAS, Yuneec. See Exhibits 1-5. The capabilities of these operators to maintain and repair the 

sUAS will be listed in the operator's manual and meet the requirements for an equivalent level of 

safety pursuant to Section 333 for the type of sUAS, its intended use, and the operating environment. 

• 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted 

under parts 91 and 125 and §§135.41l(a)(1) and 135.419 of this chapter. 

Three Pines Productions requests an exemption from 14 C.F.R. 43 .11. This part provides, 

inter alia, that maintenance record entries be maintained and for the listing of discrepancies and 

placards by inspectors. The sUAS, due to its small size, does not have room for placards to be placed 

in or on it and no inspections for sUAS have been certified by FAA at the present time. 

Equivalent level of safety: Three Pines Productions will keep log books of all maintenance 

and repairs at the ground station, as envisioned in the FAA Memorandum subject, "Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft's control 
station," dated August 8, 2014. See Exhibit 8. This request provides an equivalent level of safety as 

14 C.F.R. 43.11 because the documentation will be at the ground station with the PIC, where it will 

be useable in case of an emergency, rather than with the sUAS which could be up to 1,000 meters 

from the operator. 

• 14 C.F.R. 45.11: Marking of products. 

Three Pines Productions requests an exemption from 14 C.F.R. 45.11. This part provides, 

inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or 

propellers with an approved fireproof identification plate. The sUAS, due to its small size, does not 

have room for frreproof placards to be placed in it. Any required placards could become hazardous, 

due to the additional weight and strain placed on the sUAS. Any additional weight or placards on the 

60ounce sUAS could create a risk, due to the very small size and nature ofthe Yuneec Q500 4K. 

Equivalent level of safety: Three Pines Productions's PIC and VO will keep information 

related to the Yuneec Q500 4K, including the user manual, at the ground control station and affix its 

N-Number, once obtained from the FAA Registration Office, on the "arms" of the sUAS as large as 

practicably possible. This exemption provides an equivalent level of safety to 14 C.P.R. 45.11 

because the relevant documentation containing the serial number will be at the ground station with 

the PIC, where it will be useable in case of an emergency, rather than with the sUAS. In addition, the 

fuselage is marked with "Yuneec," the manufacturer of the sUAS. 

• 14 C.F.R. 45.27: Location of marks; nonfu.ed-wing aircraft 

Three Pines Productions requests an exemption from 14 C.P.R. 45.27. This part provides, 

inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The sUAS, due to its 

small size, does not have a cabin, fuselage, boom or tail to display the marks required by §45.23. 

Equivalent level of safety: Once Three Pines Productions receives its N-Number, it will 

display these marks on the "arms" of the aircraft as large as practicably possible. This exemption 

provides an equivalent level of safety to 14 C.P.R. 45.27 because the sUAS will be registered with 

the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Three 

Pines Productions. 

• 14 C.F.R. 45.29: Size of marks 

Three Pines Productions requests an exemption from 14 C.P.R. 45.27. This part provides, 

inter alia, at subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. The 

sUAS, due to its small size, does not have any surface area large enough to display marks anywhere 

near 12 inches high. 

Equivalent level of safety: Three Pines Productions will affix its registration number as large 

as practicably possible on its "arms" once it obtains the N-Number. This exemption provides an 

equivalent level of safety to 14 C.P.R. 45.29 because the sUAS will be registered with the FAA 

Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Three Pines 

Productions. 

PO Box !!.6. MT 59056 
• 14 C.F.R. 91.7(a): Civil aircraft airworthiness. 

The FAA has previously stated that no exemption is required for a member of the Yuneec 

Q500 4K family. Exhibit 8 at 17. Three Pines Productions requests the same determination to be 

made for its Yuneec Q500 4K. 

Alternatively, Three Pines Productions requests an exemption from 14 C.F.R. 91.7(a). The 

regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft should this exemption be granted, no 

standard will exist for determining airworthiness. 

Equivalent level of safety: Three Pines Productions will keep the YUneec Q500 4K's 

maintenance and safety information at the ground station, where it will be readily accessible to the 

PIC and VO before, during, and after operations. This exemption provides an equivalent level of 

safety as 14 C.F.R. 91. 7(a) because the PIC will be able to make the determination of whether the 

sUAS is in an airworthy mechanical and electrical condition, in accordance with 14 C.F.R. 91.7(b). 

• 14 C.F.R. 91.9(b)(l): Civil aircraft flight manual, marking, and placard 

requirements. 

T4fee Pines Productions requests an exemption from 14 C.F.R. 91.9(b )(2). This part provides: 

"(b) No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof." 

First, there does not currently exist a method of approving manuals for sUAS. Second, given 

the size and configuration of the sUAS, there is no space to carry such a flight manual on the 

aircraft. In addition, carrying the manual on the aircraft would be pointless, since there is no pilot or 

other person on board who could read or use it. On August 8, 2014, the FAA issued a 

memorandum entitled "Interpretation regarding whether certain required documents may be kept at 

an unmanned aircraft's control station." This document stated, in part "maintaining these documents 

at the pilot's control station would meet the intent of the rule as the pilot would be able to produce 

the documents for his or her own information or to an FAA inspector." See Exhibit 9. 

Equivalent level of safety: Three Pines Productions will keep its flight manual at the ground 

station, where both the PIC and VO can access it. An equivalent level of safety to 14 C.F.R. 91.9(b) 

(2) is provided because the intent of this rule - the pilot having access to this material during flight -

is met. 

• 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements. 

Three Pines Productions requests an exemption from 14 C.F.R. 91.9(c). This part provides: 

"(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter." 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
As stated above, Three Pines Productions will obtain an N-Number from the FAA 

Registration Office and the sUAS, due to its small size, does not have room to contain fireproof 

placard or to display aircraft marks in a conventional size. However, once Three Pines Productions 

obtains anN-Number, it will place the number on the "arms" ofthe aircraft as large as practicably 

possible. 

Equivalent level of safety: Three Pines Productions will obtain its N-Number from the FAA 

Registration Office and affix it to the "arms" of the aircraft as large as practicably possible. An 

equivalent level of safety to 14 C.F.R. 91.9(c) is met because the sUAS will be registered with the 

FAA and identifiable in the event of an incident. 

• 14 C.F.R. 91.103(b)(2): Preflight action. 

Three Pines Productions requests an exemption from 14 C.F.R. 91.103(b)(2) to the extent that 

is applicable. This part provides: 

"Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include-... (b) For 

any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: ... (2) For civil aircraft other than those specified in 

paragraph (b )(1) of this section, other reliable information appropriate to the aircraft, 

relating to aircraft performance under expected values of airport elevation and runway 

slope, aircraft gross weight, and wind and temperature." 

Three Pines Productions's PIC in fact will, before beginning a flight, become familiar with all 

available information concerning that flight, including the aircraft performance under expected 

elevations, the gross weight of the aircraft (which will be no more than 60 ounces), and the wind and 

temperature. As the flights of the sUAS will not be at airports the information required of Part 

91.103(b)(2) does not apply. 

Equivalent level of safety: Three Pines Productions shall perform preflight operations as 

outlined previously in this petition, and flights will not be at airports. An equivalent level of safety 

to 14 

C.F.R. 91.1 03(b )(2) will be met because the PIC will become familiar with the conditions prior to the 

flight, including the aircraft performance under expected elevations, the gross weight of the aircraft 

(which will be no more than 60 ounces), and the wind and temperature. 

• 14 C.F.R. 91.105: Flight crewmembers at stations. 

Three Pines Productions requests an exemption from 14 C.F.R. 91.105 since this part is not 

applicable due to the sUAS carrying no flight crewmembers. 

Equivalent leyel of safety: Three Pines Productions will not operate the aircraft unless 

someone is at the controls at all times, and each flight will be manually flown, with the exception of 

the Ytmeec Q500 4K's automated safety features. This will provide an equivalent level of safety to 14 

C.F.R. 91.105 because the flight crew will be at their stations at all times during the flight. The 

stations will not be on the aircraft but on the ground. 

ro Bm~! IG. 
• 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations. 

Three Pines Productions requests an exemption from 14 C.F.R. 113(b) to the extent that it 

applies to overhead aircraft operating at or above 500 feet AGL as the sUAS will be operating no 

higher than 400 feetAGL. This part provides: 

"(b): General. When weather conditions permit, regardless of whether an operation is 

conducted under instrument flight rules or visual flight rules, vigilance shall be 

maintained by each person operating an aircraft so as to see and avoid other aircraft. 

When a rule of this section gives another aircraft the right-of-way, the pilot shall give 

way to that aircraft and may not pass over, under, or ahead of it unless well clear." 

For example, if another aircraft is operating overhead at 10,000 feet AGL there is no danger 

posed to that other aircraft if the sUAS is operating under it or ahead of it at or beneath 400 feet 

AGL. Despite this, should another aircraft enter the area in which Three Pines Productions is 

operating, because the flight will be within his line of sight, the PIC will be able to give right of way 

to that aircraft. 

Equivalent level of safety: Three Pines Productions will operate its sUAS to see and avoid 

and give way to other aircraft that should enter airspace at or below 400 feet AGL, and will give 

right-of-way to manned aircraft. All flights will be in class G airspace and the majority of flights will 

be at no more than 100 feet AGL, which will create a very slim chance that Three Pines 

Productions's operations will interfere with a manned aircraft's flight. This will provide an equivalent 

level of safety to 14 C.F.R. 91.113(b) because the sUAS has significantly greater mobility than a 

much larger, manned aircraft. As a result, the PIC will be able to react and respond much more 

quickly than the other pilot. 

• 14 C.F.R. 91.119(e): Minimum safe altitudes: General. 

Three Pines Productions requests an exemption from 14 C.F.R. 91.119 subpart (c). This 

regulation provides: 

"Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes ... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure." 

Three Pines Productions will not operate the sUAS any higher than 400 feetAGL. 

Equivalent level of safety: Three Pines Productions will operate the sUAS no higher than 

400 feet AGL, and it is anticipated that the majority of operations will be no higher than 100 feet 

AGL. Three Pines Productions will not operate in congested areas, and will work with the local 

FSDO when planning operations. Three Pines Productions's flight crew will make a safety 

assessment prior to each operation, and only operate after it determines that there is no undue hazard 

present. Exhibit 8 at 19. 

PO Box 116. \\ Ilsall. \II 59086 ld: ~06-5 78-2321 
The 400 feet AGL maximum will provide an equivalent level of safety to 14 C.F.R. 91.119( c) 

because, since 1981 with AC 91·57, this height has been an operating standard for model aircraft. 

Additionally, in Section 334(c)(2)(C), Congress determined that sUAS operated by public agencies 

flying sUAS the size of and larger than Three Pines Productions's Yuneec Q500 4K could fly up to 

400 feetAGL. 

• 14 C.F.R. 91.121: Altimeter Settings 

Three Pines Productions requests an exemption from 14 C.F.R. 91.121. This Part provides 

guidelines for altimeter use in maintaining the cruising altitude or flight level of the aircraft. Three 

Pines Productions is not requesting a general exemption from the requirement that its sUAS have an 

Altimeter. The Yuneec Q500 4K's flight controller will have an internal measurement unit ("IMU"). 

The IMU has a built-in internal sensor and a barometric altimeter that measures both attitude and 

altitude. See Exhibit 1, Appendix B, page 5. Rather, Three Pines Productions requests an exemption 

from the requirement to set its altimeter to a station along the route, of out of an airport, because the 

Yuneec Q500 4K is not traveling point-to-point and is limited in the distance it can travel from the 

PIC. Additionally, Three Pines Productions will not be flying into or out of an airport. 

Equivalent level of safety: The requested exemption provides an equivalent level of safety to 

14 C.F.R 91.121 because Three Pines Productions will not operate the sUAS above 400 feet AGL in 

a sustained cruising flight mode such as a manned aircraft will typically fly. The PIC will at all times 

be controlling the maximum height of the sUAS through the telemetry features of the Yuneec 

controller. Additionally, the sUAS will be operated within the line of sight of the PIC. The FAA has 

previously granted this exemption for similar proposed operations. See Exhibit 10. 

• 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. 

The sUAS Three Pines Productions will fly is powered by electricity, using lithium polymer 

batteries that currently have a flight limit of approximately no more than 25 minutes. (See Exhibits 1 

and 1 0). Therefore, due to the limitations of the batteries, it is currently impossible to comply with 

Part 91.151. However, the sUAS will be operated in a manner with at least the equivalent level of 

safety as that of a manned aircraft complying with Part 91.151. 

Operation of an sUAS with less than 30 minutes of reserve fuel does not engender the type of 

risks that Section 91.151(a) was intended to alleviate. During the entire flight, the PIC will always 

have a visual line of sight of the sUAS and the VO will be monitoring the battery life via the 

telemetry display on the laptop at the ground station. The sUAS will always have enough power to 

land safely, given the minimum level of reserve capacity of the batteries. 

Three Pines Productions will limit flights to 7 5% of battery capacity. With the battery Three 

Pines Productions currently uses, the 75% point occurs at 18 minutes, leaving 7 minutes for the 

sUAS to reach the planned landing zone. This amount of time will be more than sufficient for the 

PIC to safely return to and land in the "home area." As battery power increases, the number of 

minutes the sUAS can operate before reaching the 75% mark will also increase. As new batteries are 

obtained and put into use, Three Pines Productions will continue to terminate flights after 75% of 

battery power has been used. 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
Applicant believes that an exemption from 14 CFR §91.15l(a) is consistent with the scope of 

similar exemptions already granted to other operations. Exhibit 10. 

Equivalent level of safetv: Three Pines Productions will limit flights 75% of battery power. 

The proposed exemption meets an equivalent level of safety to 14 C.F.R. 91.151 because, given the 

limitations on Three Pines Productions's proposed operations and the location of those operations, a 

reduced minimum power reserve for flight in daylight VFR conditions is reasonable. 

• 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required. 

The FAA has previously determined that exemption from 14 C.F.R. 91.203(a) and (b) is not 

necessary. See Exhibit 10 at 17. 

Alternatively, Three Pines Productions requests an exemption from 14 C.F.R. 91.203(a) and 

(b). This section provides in part: 

"(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it 

has within it the following: 

• An appropriate and current airworthiness certificate ... 

• An effective U.S. registration certificate issued to its owner ... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under§ 91.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." 

First, there are currently no procedures in effect for providing airworthiness certificates for 

sUAS. However, as a condition to the approval of exemption, Three Pines Productions will display 

its N-Number, once received, on the sUAS, and the operator will have, at the ground station, the user 

manual for the Yuneec Q500 4K. 

Second, the sUAS Three Pines Productions will use the Yuneec Q500 4K, which has an 

equivalent level of safety as a manned aircraft with an airworthiness certificate. 

Because of the use of GPS with the sUAS, the operator will set the initial location of flight 

takeoff ("home position") and if the radio control link is broken, the autopilot system will recognize 

this broken control link and cause the sUAS to automatically return to the home position as recorded 

by the GPS instrumentation. Additionally, because the sUAS team will mark off an area with traffic 

cones that has a 20 ft. radius, approximately 30 ft. from the operators that will be used as the "home 

position" for the sUAS to return, no one will be standing in the way of the path. 

These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under Subpart 

H. Application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial payload. 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
In the restricted environment and under the conditions proposed, operation of the sUAS will 

be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate but without the restrictions and conditions proposed. Three Pines Productions will not 

accept assignments from clients that would take place in Class B, C, D, or E airspace. Three Pines 

Productions will avoid flying over congested and populated areas and will work with local FSDO to 

avoid these areas when planning operations. 

Equivalent level of safety: The sUAS to be operated hereunder is 60 ounces, inclusive of 

batteries and technical payload, carries neither a pilot nor passengers, and carries no explosive 

materials or flammable liquid fuels. The sUASs operating under this exemption will be tightly 

controlled and monitored by the operator and the observer, and in compliance with local public 

safety requirements, to provide security for the area of operation. The FAA will have advance notice 

of all operations because Three Pines Productions will notify both ATC and the local FSDO prior to 

operations, as described previously in this petition. Granting the proposed exemption will achieve an 

equivalent level of safety to 14 C.F.R. 91.203(a) and (b) because of the small size of the sUAS and 

the operational limits set out above. 

• 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use 

This section requires that installed Air Traffic Control (ATC) transponder equipment must 

meet specific performance and environmental requirements, and aircraft must be equipped with an 

operable coded radar beacon transponder. 

There are presently no known commercially available ATC transponders that meet the 

payload requirements of a sUAS and are available at reasonable cost. However, because the sUASs 

used by Three Pines Productions will not be flying into or near airports, and will fly no higher than 

400 feet AGL, there is very low risk of collision with any manned aircraft. In addition, because there 

will be no need to have contemporaneous communication with ATC Control, due to the short 

distances, short flight times, and restricted altitude the sUASs will operate within, Three Pines 

Productions requests an exemption from this section. Additionally, the sUAS is too small to contain 

ATC transponder equipment in any form factor that is known to be available commercially. 

Equivalent level of safety: An equivalent level of safety to 14 C.F.R. 91.215 will be met 

because Three Pines Productions will not fly its sUAS into or near airports, and all operations will be 

below 400 feet AGL, so there is very low risk of collision with any manned aircraft. Three Pines 

Productions will contact local ATC before operations to issue a NOTAM, and the local FSDO with 

its flight plan, as described previously in this petition. Three Pines Productions also give right of way 

to any manned aircraft that do appear. 

• 14 C.F.R. 91.403: General 

This section requires that the owner or operator of an aircraft is primarily responsible for 

maintaining that aircraft in an airworthy condition. Three Pines Productions will adhere to this 

requirement. However, this Section also limits maintenance to that "prescribed in this subpart and 

other applicable regulations, including part 43 of this chapter." Because of this limitation, and 

because of the exemptions under Part 43 requested above, Three Pines Productions requests an 

exemption from this Section. 
This exemption meets the requirements for an equivalent level of safety pursuant to Section 

333 based on the small size, light weight, relatively slow speed, and use in controlled rural 

environments on private, secured land, as described previously in this petition. 

Equivalent level of safety: To achieve an equivalent level of safety to 14 C.P.R. 91.403, 

Three Pines Productions will maintain its sUAS in an airworthy condition and adhere to all 

manufacturer requirements for inspecting and maintaining the Yuneec Q500 4K. Three Pines 

Productions will keep records of maintenance to the sUAS, and these records will be available to the 

PIC and VO before, during, and after operations of the sUAS. 

• 14 C.F.R. 91.405 (a) and (d): Maintenance Required 

This section requires that aircraft be inspected as prescribed by Section E, 14 C.P.R. 

§§91.401-91.421. As shown below, Three Pines Productions is applying for an exemption for these 

sections, due to the fact that its operators will inspect the sUAS prior to each flight and keep 

maintenance records of all parts that are replaced, in accordance with Yuneec's instructions. Because 

the Sections discussed below are concerned with manned aircraft, and as such have inspection 

requirements designed for the safety of passengers, they are inapplicable to Three Pines Productions. 

Three Pines Productions is also applying for an exemption to subpart (d) of this section, 

which requires a placard to be installed and references §43.11. As noted previously, Three Pines 

Productions requests an exemption to the placard requirement, because, due to the small size of the 

sUAS, there is no room to place the placard. 

Despite the requested exemption from subparts (a) and (d) of this section, Three Pines 

Productions will follow subparts (b) and (c) of this subpart. 

Equivalent level of safety: To achieve an equivalent level of safety to 14 C.P.R. 91.405(a) 

and (b), Three Pines Productions will keep logbooks detailing all maintenance and repairs to the 

sUAS. The logbooks will be available to the PIC and VO before, during, and after sUAS operation. 

Prior to conducting post-maintenance operations, the flight crew will conduct a test flight to ensure 

that the sUAS functions properly. The FAA has previously determined that following the 

manufacturer's requirements for maintenance, inspection, and record keeping are sufficient to ensure 

that safety is not adversely affected. 

• 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or 

alteration 

This section requires that any aircraft which "has undergone maintenance, preventative 

maintenance, rebuilding, or alteration unless ... [i]t has been approved for return to service by a 

person authorized under§ 43.7 of this chapter .... " 

However, Three Pines Productions has requested an exemption from §§ 43.7 and 43.11 as 

described previously. The capability of the operators to maintain and repair the sUAS meets the 

requirements for an equivalent level of safety pursuant to Section 333 for both the type of sUAS, its 

intended use, and the rural operating environment. Additionally, due to the small size of the sUAS, 

there is no room to place inspection placards. 

PO Box 116, V. iball, \1 r 59086 lei: 406-578-2321 
Therefore, because Three Pines Productions has requested an exemption from 43.7 and 43.11, 

Three Pines Productions respectfully requests an exemption from 91.407. The PIC, who holds a 

commercial pilot's certificate, will conduct maintenance on the sUAS and keep logs of the battery 

cycle and repairs needed on the body or the propellers of the Yuneec Q500 4K. 

Equivalent level of safety: The proposed exemption will meet an equivalent level of safety 

to 14 C.P.R. 91.407 because Three Pines Productions will regularly inspect and maintain its sUASs 

in accordance with the Yuneec operator manual, and keep detailed inspection and maintenance 

records that will be available to the PIC and VO before, during, and after operations. Prior to 

conducting post- maintenance operations, Three Pines Productions will conduct a test flight to ensure 

that the sUAS functions properly. 

• 14 C.F.R. 91.409: Inspections 

This section lays out specific requirements for inspections of aircraft. Three Pines 

Productions respectfully requests an exemption from these requirements because they are intended to 

maintain the safety of manned aircraft significantly larger and capable of significantly longer flights 

than is sUAS. Three Pines Productions's pre-flight and post-flight inspections meet or exceed the 

level of safety achieved by adherence to 14 C.P.R. 91.409. 

Equivalent level of safety: As discussed above, Three Pines Productions has an inspection 

procedure that provides an equivalent level of safety to 14 C.P.R. 91.409. Before and after each 

flight, the flight crew will conduct an inspection of the sUAS as described previously. 

• 14 C.F.R. 91.417: Maintenance records 

Three Pines Productions respectfully requests an exemption from this Section, as it is only 

applicable for aircraft with an airworthiness certificate. Because Three Pines Productions will not 

have an airworthiness certificate, this Section is inapplicable. 

Equivalent level of safety: The requested exemption will meet an equivalent level of safety 

to 14 C.F.R. 91.417 because Three Pines Productions will keep detailed maintenance records on 

every part as it is replaced, including but not limited to propellers, batteries, and electrical 

components. The detailed maintenance records will be accessible to the PIC and the VO before, 

during, and after operations. 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
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Type 

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Contro11ransmissl!m Ranp (Optim11D> 

Conditions) 

Vtd.., Trmsmisston Range (Optimum 

Conditions) 

Fllgbt Systems Telemetry Data On s.:-n, 

Dbplay 

LED Baddlt LCD s.:-n 

Tactile {\'lhnti!lg) and Audible Feedback 

11Smm (4.Sinl 

STlO+ 

j 10 

Personal Ground Station 

I . 

Iii 

L ......... H•u••huuu! 

.18Smm C7.41nl 

242mm 

(9.51nl 

FOC Complionce: Up to SOOm (2624.67 ft) CE Complial!ce: Up to400m (1312.34 fl) Wamillg: You Mnstfcllmv Loa! Laws and Mllint!in VlSU>l 

Linr orsigbt or Airrotft at All Times 

I S.SGHz 

FCCCompfumce: Up to 600m (1968.5 ft) CE Compliallce: Up to 300m (9114.252 ft) Waming: You Must Follow Loa! Lm'!l atuiMailltain VlSU>l Line 

of Sigllt or Airln1\ at All Times 

Yes 

Boih-in Lll'o Battery Voltap/ Capadty 3;6V/5200mAil 18. 72'1\'h-

~------~--------------r·--------~------------~---------------------------------------------

s.:-n Resoluti!ln 854 x -480px 

Cam•ra s.ttiDgl 

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321 
Exibit 6: Memorandum from Mark W. Bury, Assistant Chief Counsel for Int'l Law, Legislation 

and Regulations, Fed. Aviation Admin., to John Duncan, Dir., Flight Standards Serv. (Aug. 8, 

2014) 

Federal Aviation Administration Memorandum 

Date: August 8, 2014 

To: John Duncan, Director, Flight Standards Service, AFS-1 

From: Mark W. Bury, Assistant Chief Counsel for International Law and Regulations, AGC-200 

Prepared by: Dean E. Griffith, Attorney, AGC-220 

Subject: Interpretation regarding whether certain required documents may be kept at an 

unmanned aircraft's control station. 

This memorandum addresses whether the pilot of an unmanned aircraft may keep airworthiness 

certificates, aircraft manuals, and aircraft registration certificates at the unmanned aircraft's 

ground control station and satisfy the regulatory requirements of sections 91. 9(b ), 91.203 (a) and 

(b), 47.3(b)(2), and 47.3l(c) ofTitle 14, Code ofFederal Regulations. This question has been 

brought to our attention because of the impracticality of placing these documents on a small 

aircraft with no pilot on board. As discussed below, we find that the intent of these regulations is 

met if the pilot of the unmanned aircraft has access to these documents at the control station from 

which he or she is operating the aircraft. 

Section 91.9(b) prohibits operation ofU.S.-registered civil aircraft unless "there is available in 

the aircraft" an Airplane or Rotorcraft Flight Manual or other material, markings and placards. 

The FAA stated that the purpose of this rule is to "insure that the information is readily available 

to the pilot" for use during operations. See 40 Fed. Reg. 24665 (June 9, 1975), 37 Fed. Reg. 

20022 (Sept. 23, 1972). The text of the rule and preamble to subsequent revisions of the rule 

confirm the intent that the pilot is to have access to the material during flight. Accordingly, we 

find that the intent of the rule is met if the information is maintained at the pilot's control station 

such that it is available to the pilot. 

Section 91.203( a) prohibits operation of a civil aircraft "unless it has within it" an appropriate 

and current airworthiness celiificate and the aircraft's registration certification. Section 

91.203 (b) requires that the airwOlihiness certificate be "displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew." Similarly, sections 47.3(b)(2) and 47.3l(c) allow an 

applicant for aircraft registration to any "in the aircraft" the second copy of the registration 

application as temporary authority to operate without registration. These documents demonstrate 

that the aircraft is appropriately certificated and registered, or is in the process of being 

registered. Additionally, the FAA has previously addressed the requirement to display the 

airworthiness certificate and found that the regulation permits displaying the certificate so that it 

is only legible to the flight crew even if not legible to passengers. See Legal Interpretation to 

Leonard A. Ceruzzi, from Donald P. Byrne, Acting Assistant Chief Counsel, Regulations and 

Enforcement Division (Aug. 7, 1990). Accordingly, we find that maintaining these documents at 

the pilot's control station would meet the intent of the rule as the pilot would be able to produce 

the documents for his or her own information or to an FAA inspector. 

We note that this memorandum is to be narrowly construed to unmanned aircraft systems and is 

not intended to apply to operation of manned aircraft or optionally piloted aircraft with a pilot on 

board.