January 11, 2016 ThreePines Productions, LLC 121 ReservoirRoad Wilsall, Montana 59086 406-578-2321 kent@3Qbn.tv
U.S. Department of Transportation DocketManagement System 1200NewJerseyAve S.E. Washington, D.C. 20590 Re: Request for Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe 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 SirorMadam: Pursuant to Section 333 oftheFAA Modernization and ReformAct of2012 (the ReformAct) 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 ofresidential 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 oflocal 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 ofthe United States but primarily in the state ofMontana, 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 ofthe 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 ofbattery 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 ofsight

- 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 ofthe PIC weighs heavily in favor of granting the exemption. Pursuantto 14 C.F.R. 11.35, Three PinesProductions, 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 ofInformationAct 5 U.S.C. 552. For your ease in reviewing this petition please refer to the table ofcontents which begins on page three. Ifwe can provide any additional information to assist your understanding or review ofthis document, please do not hesitate to contact us at 406-578-2321 or email at kent@3pbn.tv. Thankyou,

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

# - Kent Grabau President Three Pines Productions, LLCTableofContents
• Publishable Summary
.....................................................................................................................5
• Petitioner's ContactInformation
....................................................................................................6
• Three Pines Productions LLC's Operations
...................................................................................6
• The sUAS
..............................................................................................................................6 • Flight Conditions
...................................................................................................................7 • Flight Operations
...................................................................................................................7 • Privacy
............................................................................................................................................S
• Aircraft and EquivalentLevel ofSafety
.........................................................................................9
• Public Interestand 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, aircraftengines,propellers, appliances, orcomponentpartsfor returnto service aftermaintenance, preventivemaintenance, rebuilding, oralteration
.................................................................................................................12 • 14 C.F.R. 43.11: Content, form, and disposition ofrecords for inspections conductedunderparts 91 and 125 and §§135.411(a)(1) and 135.419ofthis chapter
........................................................12 • 14 C.F.R. 45.11: Marking ofproducts
............................................................................................13 • 14 C.F.R. 45.27: Locationofmarks; 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 placardrequirements
.................14 • 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placardrequirements
......................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: Exceptwater 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 inVFRconditions
................................................1 7 • 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certificationsrequired
...............................................18 • 14 C.F.R. 91.215:ATC TransponderandAltitude 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: Operationafter 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"~** IExhibit List Exhibit 1: Yuneec Q500 4KManual..
....................................................................... Submitted Separately Exhibit 2: Yuneec Q500 4K- Specs
........................................................................................................21 Exhibit 3: Yuneec Q500 4KCameraGimbal- Specs
.............................................................................21 Exhibit 4: Yuneec Q500 4K Ground Control- Specs
.............................................................................22 Exhibit 5: YPPFlight OperationsManual
................................................................Submitted Separately Exhibit 6: Memorandum from MarkW. 

### Bury, Assistant ChiefCounsel for Int'lLaw, Legislation and Regulations, Fed. AviationAdmin., to JohnDuncan, Dir., Flight Standards Serv. (Aug. 8, 2014)
........................................................................................................................................................24

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

### Additional documentshavebeensubmittedto the FAA confidentiallyand are notavailable to the public.

• Publishable Summary Pursuantto 14 C.F.R. Part 11, the following swnmary is provided for publication inthe Federal Register, should itbe determined thatpublication 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 ofexemptions for Three Pines Productions LLC will allow commercial operations of sUASs in rural, remote, low density areas throughoutthe United States butprimarily inthe 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 completionpercentages, and security of controlled environment ofvarious 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 

# acertified commercial and instrument-rated helicopter pilot with more than 6,100 hours offlight 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 ofbattery and payload, conducted inthe 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 ofsight

- 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 ofthe PIC weighs heavily in favor ofgranting the·exemption.

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

### • Petitioner'sContactInformation Three Pines Productions LLC PO Box 116 Wilsall, MT 59086 Tel: 406-578-2321 Email: kent@3pbn.tv



### • ThreePines ProductionsLLC's Operations

• ThesUAS The requested exemption will permitthe operation ofthe Yuneec Q500 4K. The Q500 4Kis a small, unmanned multirotor aircraft, weighing 60 ounces inclusive ofbatteries, the propellers, and technical payload. This rotorcraft can operate ata speed upto 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 ofa member ofthe Yuneec Q500 family. The sUAS will have the following specifications: Airframe: Yuneec Q500 4K FLIGHTTIME: Up to 25 Minutes DIMENSIONS: 8.27 in (210mm) x 16.54 in (420mm) DIAGONALMOTORTO MOTORDISTANCE: 20 in (510mm) PROPELLER/MAIN ROTORDIAMETER: 13.0 in (330mm) WEIGHTWITHOUTBATTERYAND PAYLOAD: 40.0 oz(1130g) MAXIMUMTAKEOFF WEIGHTWITH CG03: 60.0 oz (1700g) BATTERY: 5400mAh 3S 11.1VLiPo (included) CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger withAC Adapter (included) TRANSMITTER: 10-channel2.4GHzwith 5.8GHzvideo downlink (included) MAXIMUM FLYING ALTITUDE: Default400 FeetAbove Ground Level (Adjustable viathe Q500 GUI) MAXIMUM ROTATION RATE: 65°/s MAXIMUM ROLLANGLE: 35° RADIO CONTROLFREQUENCYBAND: 2.4GHz MAXIMUM CLIMB RATE: 2m/s MAXIMUM DESCENTRATE: 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 inrural, remote, low density areas throughoutthe United States but primarilyinthe 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 

### inVMC, 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 ofthe risk ofevery operation, andwill only operate when it is determined that noundue hazards arepresent.

• Flight Operations ThreePines Productions's flight operationsrequire thatthe sUAS will always be inthe line of sight ofboth a PIC and a monitor specialist, who will also act as the visual observer (VO). Flights will be at altitudes ofno more than 400 feet AGL, and at speeds less than 20 knots. Despite the 400 ft. AGLlimit, mostflights will takeplace at an altitude ofno 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 ofexperience with RC aircraft, and has thousands ofhours flying sUAS as a hobbyist, and is a studentpilot with 36hours offlight time inCessna 182 aircraft. The week of an operation, the flight crew will file a flight plan with the local FSDO and contactATC. 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 safetybriefmg withthe property owners. Operations will not take place in congested ordensely populated areas, and the PIC will work with the local FSDO when planning operations. The flight crew will obtain all aeronautical and weatherdata information. Priorto departing for an operation, the flight crewwill brieflyturn onthe sUAS toensure that everythingis connected andthatthe 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 willthen setouttraffic cones to designatethe aircraft's "home area," which will beapproximately 20 feet indiameter, to markthe sUAS take-offand landing zone.Note: Ifthe 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 ofthe 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 ofsafety to operations. Other than this automated feature ofthe Yuneec Q500 4K, the PIC will always fly the sUAS manually. The PIC and VO have tested the sUAS in a variety ofweather 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 ofan 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 ifand when it is safe for the sUAS to returnto the home location. During flights, the PIC and the VO will be standing nextto 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 ofthe flight. Flights will be limited to 18 minutes, which is 75% ofthe total battery life ofthe Yuneec Q500 4K. Once the sUAS has landed, the PIC will conduct a post-flight checklist as set out in Appendix D ofthe Operations Manual.

• Privacy There is little concern that the proposed flights will cause invasions ofprivacy because all flights will occur property owner's priorknowledge and consent. The only people and/or property to be filmed will have requested and hired Three Pines Productions for the express purpose offilming and photographing the people and/orproperty 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 orphotographed, except in cases where they are trespassing upon or damaging customerproperty, orinterfering withthe applicant's orits customers' operations

PO Box 116. \\> iIsail, tv! I .'i9086 1.:1: 406-578-21

**~I**• Aircraft and Equivalent Level ofSafety 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 ofsafety 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 ofbattery and payload.

• Flights will be operated within line ofsight ofa pilot andVO.

• Maximum total flight time for each operational flight will be 75% ofbattery 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 ofno more than 400 feetAGL. Despite this limitation, the majority offlights are anticipated to operate atno more than 100 feetAGL.

• Minimum crew for each operationwill consist ofthe sUAS PIC andVO.

• 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 withthe operations be present for this briefing.
• The operator will obtain a FAA UAS Civil COAprior to conducting any operations under this grant ofexemption.

• The operator will request a Noticeto Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours priorto the operation.

• At least three days before scheduled filming, the operator ofthe sUAS will submit a written Plan ofActivities to the local FSDO withjurisdictionoverthe area ofproposed filming.

• The PIC is a certified commercial and instrument-rated airplane pilot with more than 6,500 hours offlight 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 offlight onthis model. Practice flights have been in a variety ofweather conditions, including in winds up to 25 knots and on overcast days. Practice flights have also included using the Yuneec Q500 4K'sreturn-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, ofthe 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, orotherappropriate 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.

• Ifthe multirotor and its controllerdisconnects 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 offuncontrollably or landing at an unknown location.

• Becausethe PIC is a licensed commercial pilot, he has been subjectto the security screening by the Department ofHomeland Security. Additionally, the sUAS that will 

### be used, a Yuneec Q500 4K weighs 60 ounces, inclusive ofbattery and payload.Approval ofcommercial flights as outlined inthispetitionpresent no national security issue. Satisfaction ofthe criteria provided in Section 33 3 ofthe Reform Act of2012--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 ofapplicant's sUAS pursuant to Three Pines Productions'srules ofoperation appendedhereto.

• PublicInterestand Safety Use ofthe 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 offueL 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 ofa [sUAS] for the proposed operation." Exhibit 10 at 11-12. As inthe cited exemption, Three Pines Productions will use a Yuneec Q500 4Kweighingjust 60 ounces, inclusive ofbattery 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: 406-578-2321assessment priorto eachoperation, and will only operatewhenthere are no undue risks. The small weight, 60 ounces, is less than the size envisioned in Section 334(c)(2)(C) ofthe FAA Modernization and Reform Act of 2012, which allows government agencies "to operate unmanned aircraft weighing4.4pounds or less, ifoperated-

• withinthe line ofsight ofthe operator; • less than 400 feet above the ground; • during daylight conditions; • within Class G airspace; and • outside of5 statute miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities." Congress's determination that government agencies shouldbe allowedto operate such aircraft inthese situations, withno further restrictions on location, population density, orpilotexperience 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 ofthis 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 sUAS 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 lowheight 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 ofsafety pursuant to Section 333 based on the small size, light weight, relatively slow speed, and use in controlled environments onprivate land, as described previously inthispetition. Eguivalentlevel ofsafety: Three Pines Productions'sproposed exemption meets the requirements for an equivalentlevel ofsafety ofthis section, pursuantto Section 333, based on the following factors: • Small size: the Yuneec Q500 4Khas a diagonal length of565 millimeters, 22.2 inches. • Lightweight: 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 beterminated when 25% ofthebattery life remains. The Yuneec Q500 4K cantravel 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 notifyATC and the local FSDO priorto operations, as described previously. • Proximity to populated areas Three Pines Productions will avoid the yellow congested PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321areas 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 inthese specifically designated carve-out areas. • Operation within visual line ofsight: The PIC will always fly the sUAS within its line ofsight. • Location: Three Pines Productions will operate in areas with lowpopulation densityto take photographs and video. • Altitude: no more than 400 feet AGL, but the majority offlights are anticipated at no more than 100 feetAGL. • Restricted area in which the sUAS will be operated: as described above, prior to the day offilming, the flight crew will visit with neighbors to inform them ofthe 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 ofthe PIC: the PIC has a commercial fixed wing license with an IFRrating, withmore than 6,500 hours offlight 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 partprovides, inter alia, that the holder ofa 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 4Kto meet an equivalent level ofsafety ofthis section. Equivalent level of safety: The nature of the sUAS is that of a model aircraft, and the operators ofThree Pines Productions who will maintain and when necessary repair the sUAS will conduct inspections and maintenance based onmaintenance guidelines provided by the manufacturer ofthe sUAS, Yuneec. See Exhibits 1-5. The capabilities ofthese operators to maintain and repair the sUAS will be listed in the operator's manual and meet the requirements for an equivalent level of safetypursuant to Section 333 for the type ofsUAS, its intended use, andthe operating environment.
• 14 C.F.R. 43.11: Content, form, and disposition ofrecords for inspections conducted underparts 91 and 125 and §§135.41l(a)(1) and 135.419 ofthis 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 nothave room for placards to be placed in oron it and no inspections for sUAS have been certified by FAA atthe present time. Equivalent level ofsafety: Three Pines Productions will keep log books ofall 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 controlstation," datedAugust 8, 2014. See Exhibit 8. This request provides an equivalent level ofsafety 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 ofan emergency, rather than with the sUAS which could be up to 1,000 meters from the operator.


### • 14 C.F.R. 45.11: Markingofproducts. 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 fireproofidentification plate. The sUAS, due to its small size, does not have room for frreproofplacards to be placed in it. Any required placards could become hazardous, due to the additional weight and strain placed onthe sUAS. Any additional weight orplacards onthe 60ounce sUAS could create arisk, due to the very small size and nature oftheYuneec 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" ofthe 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 ofan emergency, rather than with the sUAS. In addition, the fuselage is marked with "Yuneec,"the manufacturer ofthe sUAS.


### • 14 C.F.R. 45.27: Location ofmarks; 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 ofthe cabin, fuselage, boom, or tail the marks required by §45.23. The sUAS, due to its small size, doesnot have a cabin, fuselage, boom ortail to displaythe 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" ofthe aircraft as large as practicably possible. This exemption provides an equivalent level ofsafety to 14 C.P.R. 45.27 because the sUAS will be registered with the FAA Aircraft Registration Branch. In the event ofincident, the sUAS will be traceable to Three Pines Productions.



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

### Equivalentlevel ofsafety: Three Pines Productions will affix its registrationnumber 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 ofthe Yuneec Q500 4K family. Exhibit 8 at 17. Three Pines Productions requests the same determination to be made for itsYuneec Q5004K. 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 standardwill 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 ofwhether 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 exemptionfrom 14 C.F.R. 91.9(b)(2). Thispart provides: "(b) Noperson may operate a U.S.-registered civil aircraft
... (2) Forwhich anAirplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 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 ofapproving 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 onthe 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 ofthe rule as the pilot would be able to produce the documents for his orher owninformationorto an FAAinspector." See Exhibit 9. Equivalentlevel ofsafety: Three Pines Productions will keep its flight manual atthe ground station, where both the PIC and VO can access it. An equivalent level ofsafety to 14 C.F.R. 91.9(b) (2) is provided because the intent ofthis rule

- thepilothaving access to this material during flight

- is met.
• 14 C.F.R. 91.9(c): Civil aircraftflight manual, marking, and placardrequirements. 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 withpart45 ofthischapter."

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321As 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 ofsafety: Three Pines Productions will obtain itsN-Number from the FAA Registration Office and affix it to the "arms" of the aircraft 

### as large 

### as practicably possible. An equivalent level ofsafety to 14 C.F.R. 91.9(c) is met because the sUAS will be registered with the FAAand identifiable inthe event ofan 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 extentthat is applicable. Thispartprovides: "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) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values ofairport elevation and runway slope, aircraft gross weight, andwind and temperature." Three Pines Productions's PIC infact will, before beginning a flight, become familiar with 

### all available information concerning that flight, including the aircraft performance under expected elevations, the gross weight ofthe 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 ofsafety to 14 C.F.R. 91.103(b)(2) will bemetbecause the PIC will become familiar with the conditionspriorto the flight, including the aircraft performance under expected elevations, the gross weight ofthe aircraft (which will be no more than 60 ounces), and the wind andtemperature.
• 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 carryingno 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 ofsafety 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 notbe onthe aircraft butonthe ground.



### ro**Bm~!** IG.• 14 C.F.R. 91.113(b): Right-of-way rules: Exceptwateroperations. 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 higherthan400 feetAGL. This partprovides: "(b): General. When weather conditions permit, regardless ofwhether 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 ofthis section gives another aircraft the right-of-way, the pilot shall give way to that aircraft andmaynotpass over, under, orahead ofitunless well clear." For example, ifanother aircraft is operating overhead at 10,000 feet AGL there is no danger posed to that other aircraft ifthe 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 ofsight, the PIC will be able to give right ofway to that aircraft. Equivalent level ofsafety: 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 offlights 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 anequivalent 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 otherpilot.

• 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 belowthe following altitudes
... (c) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, or structure." Three Pines Productions will notoperate the sUAS any higherthan400 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 ofoperations 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**78-2321The 400 feetAGL maximum will provide an equivalent level ofsafety 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 ofand larger than Three Pines Productions's Yuneec Q500 4K could fly up to 400 feetAGL.

• 14 C.F.R. 91.121: AltimeterSettings 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 ofthe 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, ofout ofan 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 orout ofan airport. Equivalentlevel ofsafety: Therequestedexemptionprovides anequivalentlevel ofsafety 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 atall 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 ofsight ofthe PIC. The FAA has previously grantedthis exemption for similarproposed operations. SeeExhibit 10.

• 14C.F.R. 91.151: Fuelrequirementsfor flight inVFR conditions. The sUAS Three Pines Productions will fly is powered by electricity, using lithium polymer batteries that currently have a flight limit ofapproximately no more than 25 minutes. (See Exhibits 1 and 1 0). Therefore, due to the limitations ofthe 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 asthat ofa manned aircraft complying with Part 91.151. Operation ofan sUAS with less than 30 minutes ofreserve fuel does not engenderthe 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 ofreserve capacityofthe batteries. Three Pines Productions will limit flights to 75% ofbattery 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 oftime 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 beforereaching 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 batterypowerhasbeenused.

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321Applicantbelievesthat an exemption from 14 CFR §91.15l(a) is consistent with the scope of similar exemptions already granted to otheroperations. Exhibit 10. Equivalent level ofsafetv: Three Pines Productions will limit flights 75% ofbattery power. The proposed exemption meets an equivalent level ofsafety to 14 C.F.R. 91.151 because, given the limitations onThree Pines Productions's proposed operations and the location ofthose operations, a reduced minimumpowerreserve for flight in daylightVFRconditions 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. SeeExhibit 10 at 17. Alternatively, Three Pines Productions requests an exemption from 14 C.F.R. 91.203(a) and (b). This sectionprovides inpart: "(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within itthe following:
• An appropriate and currentairworthiness certificate
...
• Aneffective U.S. registration certificate issued to its owner... (b) Noperson may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin orcockpitentrance so thatit is legible topassengers orcrew." First, there are currently no procedures in effect for providing airworthiness certificates for sUAS. However, as a condition to the approval ofexemption, Three Pines Productions will display its N-Number, once received, onthe sUAS, andthe operatorwill 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 ofsafety as a manned aircraft with an airworthiness certificate. Because ofthe use ofGPS with the sUAS, the operator will set the initial location offlight takeoff("home position") and ifthe 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 offan 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 standinginthe way ofthe 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 ofthese same criteriademonstrates 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 orflammable liquid fuels, and inability to carry a substantial payload.

PO Box 116, Wilsall, MT 59086 Tel: 406-578-2321In the restricted environment and under the conditions proposed, operation ofthe 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 whenplanning 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 ofoperation. The FAA will have advance notice ofall 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 ofsafety to 14 C.F.R. 91.203(a) and (b) because ofthe small size ofthe sUAS and the operational limits set out above.

• 14 C.F.R. 91.215: ATC TransponderandAltitude ReportingEquipment andUse 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 radarbeacon transponder. There are presently no known commercially available ATC transponders that meet the payload requirements ofa sUAS and are available at reasonable cost. However, because the sUASs used by Three Pines Productions will not be flying into ornear airports, and will fly no higher than 400 feet AGL, there is very low risk ofcollision 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 knownto 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 ofcollision 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 describedpreviously in this petition. Three Pines Productions also give right ofway to any manned aircraftthat 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 ofsafety pursuant to Section 333 based on the small size, light weight, relatively slow speed, and use in controlled rural environments onprivate, secured land, as describedpreviously 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 ofmaintenance to the sUAS, and these records will be available to the PIC and VO before, during, and after operations ofthe 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 ofall 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 ofpassengers, 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 ofthe sUAS, there is no roomto place the placard. Despite the requested exemption from subparts (a) and (d) of this section, Three Pines Productions will follow subparts (b) and (c) ofthis subpart. Equivalent level ofsafety: 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 sufficientto ensure that safety is not adversely affected.

• 14 C.F.R. 91.407: Operation aftermaintenance, 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 ofthis 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 ofsafety pursuant to Section 333 for both the type ofsUAS, its intended use, and the rural operating environment. Additionally, due to the small size ofthe sUAS, there is no room to place inspectionplacards.

PO Box 116, V. iball, \1 r 59086 lei: 406-578-2321Therefore, 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 ofthe battery cycle and repairs needed onthe body orthe propellers ofthe Yuneec Q500 4K. Equivalent level ofsafety: The proposed exemption will meet an equivalent level ofsafety 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 ofmanned aircraft significantly larger and capable ofsignificantly longer flights than is sUAS. Three Pines Productions's pre-flight and post-flight inspections meet or exceed the level ofsafety 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 ofthe 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 anairworthiness certificate, this Section is inapplicable. Equivalent level ofsafety: The requested exemption will meet an equivalent level ofsafety 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.

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### Exibit 6: Memorandum from MarkW. Bury,Assistant ChiefCounsel for Int'lLaw, Legislation andRegulations, Fed.AviationAdmin.,to JohnDuncan,Dir.,Flight StandardsServ. (Aug. 8, 2014) 

# Federal Aviation Administration 

# Memorandum Date: August 8, 2014 To: John Duncan, Director, Flight Standards Service,AFS-1 From: MarkW. Bury, Assistant ChiefCounsel 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 atan unmanned aircraft's control station. This memorandum addresses whetherthe pilotofanunmanned aircraft may keep airworthiness certificates, aircraft manuals, and aircraft registration certificates atthe unmanned aircraft's ground control station and satisfy the regulatory requirements ofsections 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 broughtto ourattention because ofthe impracticality ofplacingthese documents on a small aircraft with no pilot onboard. As discussed below, we find thatthe intent ofthese regulations is met ifthepilotofthe unmanned aircraft has access tothese documents atthe control station from which he orshe is operatingthe aircraft. Section 91.9(b) prohibits operation ofU.S.-registeredcivil aircraft unless "there is available in the aircraft" anAirplane orRotorcraft FlightManual orothermaterial, markings andplacards. The FAA statedthatthepurpose ofthis rule is to "insure thatthe information is readily available tothe pilot" for use during operations. See 40Fed. Reg. 24665 (June 9, 1975), 37Fed. Reg. 20022 (Sept. 23, 1972). The text ofthe rule and preambleto subsequentrevisions ofthe rule confirmthe intentthatthe pilot is to have access tothe material during flight. Accordingly, we find thatthe intent ofthe rule is met ifthe information is maintained atthe pilot's control station such that it is available to the pilot. Section 91.203(a) prohibits operation ofa 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 atthe cabin orcockpitentrance sothat it is legible to passengers orcrew." Similarly, sections 47.3(b)(2) and 47.3l(c) allow an applicantfor aircraft registration to any "inthe aircraft" the second copy ofthe registration application as temporary authority to operate withoutregistration. These documents demonstrate thatthe aircraft is appropriately certificated and registered, oris inthe process ofbeing registered.Additionally, the FAAhaspreviously addressed the requirement to displaythe airworthiness certificate and found that the regulation permitsdisplaying the certificate so that it is only legible to the flight creweven ifnot legible to passengers. See Legal Interpretationto LeonardA. Ceruzzi, from Donald P. Byrne,ActingAssistant ChiefCounsel, Regulations and Enforcement Division (Aug. 7, 1990).Accordingly, we find thatmaintaining these documents at the pilot's control station would meetthe intentofthe rule as the pilot would be able toproduce the documents for his orherown information orto an FAA inspector. We note thatthismemorandum is to be narrowly construedtounmanned aircraft systems and is not intendedto apply to operation ofmanned aircraft oroptionallypiloted aircraft with a piloton board.