Garrett Backstrom

7001 Rindge Ave Playa Del Rey, 

 California 90293

GBackstrom95@yahoo.com

719-502-6268 Cell Phone

US Department of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or Madam:

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

reform act) and CFR Part 11; I Garrett Backstrom, owner and operator of Small 

Unmanned Aircraft Systems (UAS’s) request to be exempted from the Federal Aviation 

Regulations (FAR) listed below so that I, Garrett Backstrom may operate UASs 

commercially in airspace regulated by the FAA, as long as such operations are 

conducted within and under the conditions outlined herein or as maybe established by 

the FAA as required by Section 333. 

 I Garrett Backstrom am currently enrolled in the top film school in America. I 

also have been a actor for 5 years in L.A. and have experience being on full scale sets. 

I am requesting exemption from regulations listed below to perform aerial 

photography of Real Estate and Landscape. All operations will be performed with the 

public’s safety and right to privacy safeguarded at all times. 

 Garrett Backstrom’s UASs is a rotorcraft weighing less than 55 pounds including 

payload (The DJI Phantom 3 Professional Quad Copter). It operates at a speed of less 

than 50 knots and has the capability to hover and move in the vertical and horizontal 

plane simultaneously. It has an auto return to launch point when the battery power is 

under 25%. The UAS will operate within the line of sight within a protected flight 

area as described below and at 200 feet AGL or less with an observer located close at 

hand as to make voice communication possible. These operations will not create a 

hazard to users of the nation airspace, public nor the environment.

 I, Garrett Backstrom, respectfully request the grant of an exception to the 

following specific sections of the Title 14 Code of Federal regulations allowing it to 

operate lightweight UASs for commercial use,
 14 CFR 21, subpart H, 14 CFR 45. 23 (b) 14 CFR 91. 7 (a), 91.9 (b) (2) 91.103 

(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) & (b), 91.405(a), 91.407(a) (1), 

91.409 (a) & (b).

 I Garrett Backstrom submit this application in accordance with the reform Act, 

112 P.L.95 331-334, seeking relief from any currently applicable FAR’S operating to 

prevent Garrett Backstrom future commercial use of small UASs to operate in the 

national airspace system as described below. The reform Act section 332 provides for 

such integration of civil unmanned aircraft into integration of these UASs are 

expressly contemplated by the Reform Act I, Garrett Backstrom, would like to 

operate it’s light weight UASs prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such aircraft.

 The Reform Act directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in national airspace before 

completion of the rule making required under Section 332 of the reform Act. In 

making this determination, the Secretary of Transportation is required to determine 

which UASs do create a hazard to users of the national airspace system or the public 

or pose a threat to national security in light of the following.

 The UASs size, speed, weight and operational capability

 Operation of the UASs in close proximity to airports and populated areas

 Operation of the UASs within visual line of sight of the operator

 

DJI Phantom 3s are rotorcrafts weighing less than 55 lbs. and they operate at 

speeds less than 50 knots and have the capability to operate in the vertical and 

horizontal plane simultaneously. The UASs will operate only within the line of sight of 

the operator within the protected fight area and t 200 feet AGL or less. These will not 

present a hazard to the national airspace nor the public.

The very small nature of these UASs combined with the safe guards presented 

below, will allow for the safe operation greater than that envisioned by Congress for 

the FAA to establish and by exemption allow commercial operations of UASs to 

commence immediately. Also due to the size of UASs and the areas and altitudes they 

will operate approval of this exception presents no national security issues and 

absolutely minimal safety concerns which have been mitigated through our rigorous 

risk management process. Given the clear direction given in Section 333of the Reform 

Act, the authority contained in the Federal Aviation Act, as amended, the strong 
equivalent level of enhanced safety, reduced emissions utilizing UASs verses 

traditional aircraft as well as the economic impact of greatly reducing the cost of 

aerial photography thereby benefiting the greater public’s interest. Accordingly, the 

applicant request that the FAA grant the request exemption without delay.

 The following will be considered as the binding limitation on operations 

of Garrett Backstrom, 

1. Flights will only occur in the day time hours, 

2. Flights will be operated in the line of sight of the operator (PIC) and 

observer, (VSO)

3. Flights will be terminated at any time weather and wind deteriorate to 

“unsafe for flight” by manufacturers recommendations. 

4. The UASs will weigh less than 55 lbs. 

5. Flights will be operated at 200 Feet AGL or less. 

6. Crew will be at a minimum of Operator (PIC) and an Observer and /or 

Camera operator (VSO). 

7. Operator and crew will remain in contact during the flight operation. 

8. The UASs operator will perform a check of the flight area and make certain 

of the safety of all persons in the area.

9. Consent will be obtained from all persons within the video capabilities of 

the units to further reduce the chance of violating anyone’s privacy.

10.All required FAA clearances, will be obtained and distances from airports 

strictly observed. 

11.All UASs will have the capability to return automatically to the operator in a 

safe manner, with the auto return function checked and working. 

12.When operated in conjunction with fishing vessels in the gulf, a chase boat 

will be assigned to operate the UASs at a safe distance from the main fishing 

boat. 

13.Flights will only operate during VFR conditions.

14.UASs have a function on the control to tell the operator the distance from 

the operator and the battery power remaining. 
15.The Flight team will communicate by voice, and if needed the use of two 

way radios if the area or terrain is too big to clearly hear the voice of all 

team members. 

16.UASs will be used to video private outings and functions, boating, jet skiing, 

kayaking, fishing trips in the gulf area and sporting events at a safe 

distance. 

17.When operating over or near water the UASs will be equipped with flotation 

devices so that recovery can be made as to prevent lithium battery exposure 

to the water table

14 CFR Part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

 Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, 

weight, and defines area of operations for Garrett Backstrom’s UASs permits 

exemption from Part 21 because they meet an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 USC4470(f) and Section 

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from 

the airworthiness certificates in consideration of weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. Garrett Backstrom’s 

UASs meets or exceeds each of these elements. 

As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” 

COA for flights at or under 200 AGL to any UASs operator with a section 333 

exemption.

14CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Because the UASs in unmanned and will not carry a pilot or passengers, the proposed 

operations can achieve a high level of safety of operation without the required pilot 

license.

14 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and 

registrations. These are inapplicable for the same reasons stated above.

14 CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will applicable in the form contemplated by FAR’s 

this regulation is inapplicable.

14 CFR 91.9 (b) (2) civil Aircraft Flight Manual in Aircraft
14 CFR 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UASs this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining such certifications and 

registrations at 

Drone ProShots

The FAA has previously issued exemptions to this regulation in Exemptions No’s 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil 

aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. 

Drone ProShots will only operate its UASs at or below 200 AGL. They will be operated 

on a will defined AOR that has been carefully reviewed for hazards and minimizes the 

presence of any persons not essential for these operations. Flights will only be over 

private property that the owner has consented and all persons within this video area 

also give consent for this filming. Compared to flight operations of conventional and 

traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 

500AGL with flammable fuel UASs operations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the 

service of aerial photography will greatly enhance safety by reducing the overall risk 

associated with traditional aircraft. Traditional aerial photography requires large 

aircraft with flammable fuel to fly in close proximity of populated areas and people in 

general. AGL the risk of injury of people on the ground or the crew has been reduced 

or almost erased. The granting of the use of these small UASs by Garrett Backstrom 

will give potential sellers of Real Estate of competitive edge in the market place.

Granting Garrett Backstrom the above exemption will allow for the expansion of UASs 

systems into the future for the safe conduct of free enterprise and the enjoyment of 

the masses.

I, Garrett Backstrom, respectfully requests the FAA grant its exception without delay. 

The FAA has the authority to issue the exemption sought by Garrett Backstrom 

pursuant to the Federal Aviation Act, 85 P.I. 726 (1958) as amended (the ACT).

Sincerely,

Garrett Backstrom

Drone ProShots