Lynne M. Un d raitis Saddle Up Productions 184 High Road Kalispell, Montana 59901

(406) 249

- 3322 lynne@saddleupproductions. com

12/29/15 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE
Was hington, DC 20590

E xemption Request Section 333 of the FAA Reform Act

To Whom It May Concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Saddle Up Productions , a licensed business in the State of Montana , h ereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) for commercial applications in airspace that is governed by the Federal Aviation Administration (FAA ). All flight operations will be conducted under the conditions and boundaries outlined herein or as establi shed by the FAA in accordance with Section 333.

The exemptions, as requested by Saddle Up Productions , would permit the provision of commercial services to customers th at are in need of aerial data capture (photography and videography) from a sUAS. Saddle Up Productions requests these exemptions in order to perform commercial flights in the following areas :

 S urveying

 A griculture

 I nspection

 Real E state

 Construction

 S earch and R escue A ssistance

 S pecial E vents

All flights will be conducted over private or controlled access property with the consent and knowledge of the property owner or controlling party. All fli ght operations will maintain a 500

- foot buffer from all nonparticipating persons, vessels , vehicles, and structures unless sufficient barriers are in place to protect nonparticipating persons from undue ha rm. Flight operations will only be operated near vessels, vehicles, and structures where the property owner/controller has granted perm ission and a safety assessment has been made.

All of Saddle Up Productions flight operations will be conducted by pilots that hold either an airline transport, commercial, private, recreational, or sport pilot certificate with appropriate medical certi ficates

. All visual observers (VO) w ill be trained to perform their required duties before flight operations begin.

Saddle Up Productions has demonst rated the ability to safely and effectively fly the sUAS DJI Phantom 3 which will be used for all co mmercial and private purposes. Saddle Up Productions complies with local ordinances and laws regarding the operation of sUAS, and adheres to all weather and envir onmental restrictions or limitations in reference to the operations of sUAS.
All flights will occur in ordinance with any state or local laws regarding privacy.Saddle Up Productions is seeking the exemption and will comply with all of the rules, guidelines, limitations, and

future legislation set forth by the FAA. Saddle Up Productions agree s to operate the UAS in the manner described, and for the purposes described.

The following contains a list of regulations from which Saddle Up Productions is seeking exemption, and a complete list of responsibilities Saddle Up Productions assume s as operator; it also contains information regarding the aircraft, public benefit and safety features

.

Regulations from which an exemption is requested:

14 CFR 61.113(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)
14 CFR Subpart E (91.401

– 91.417)

EXEMPTIO N REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Saddle Up Productions requests an exemption from the following regulations as well as any additional regulations found by the FAA to be necessary for safe and efficient UAS flight operations.

14 CFR 61.113(a), P rivate pilot privileges and limitations: Pilot in command This regulation states that no person holding a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that pe rson, for compensation or hire, act as pilot in command of an aircraft.

Saddle Up Productions believe s that a PIC that hold s either an airline transport, commercial, private, recreational, or sport pilot certificate with appropriate medical certi ficates has sufficient skill s and knowledge to complete operations, especially after completing a sUAS knowledge and training course. We do no t think that a commercial pilot license will significantly improve a PIC ’ s performance while operating a s UAV. Therefore, we ask for an exemption from 14 CFR 61.113(a) in order to operate commercially with the minimum of an airline transport, commercial, private, recreational, or sport pilot certificate with appropriate medical certificates.

14 CFR 91.7(a) Civil aircraft airworthiness As a s UAS will not require an airworthiness certificate, we believe that this regulation is not applicable. Therefore, we request exemption from this regulation.

14 CFR 91.119(c) Minimum safe altitudes This regula tion states that no person may operate an aircraft below 500 feet above the surface as well as within 500 feet of any person, vessel, vehicle, or structure.

Saddle Up Productions believes that, because of the nature of most UAS operations, an exemption is required in order to allow operation closer than 500 feet to vessels, vehicles, or structures as long as permission is granted from the owning/controlling parties and an assessment is made to assure that people and property are safe from undue harm. Saddle Up Productions also request that opera tions be allowed over congested areas as long as the operations stay within the following standards:

 Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and structures unless:



### a. Barriers or structures are present that suf ficiently protect nonparticipating persons from
d ebris in the event of an accident. 

### b. Participating persons are made aware of the dangers of the UAS operation and the safety

p recautions that have been put into place.c. The aircraft is operated near vesse l s , vehicles, or structures only where the property owner/controller has granted permission and the PIC has made a safety assessment in regard to the close operation to these objects. d. Operations near the PIC or VO do not present an undue hazard to the PI C or VO per 91.119(a).

e. All operations will be conducted over private or controlled

- access property with prior permission from the property owner/controller or authorized representative.

14 CFR 91.121 Altimeter settings Saddle Up Productions UAS do es not utilize a stan dard barometric altimeter, we request exemption from 91.121 to the extent necessary to comply with applicable conditions and limitations. The altimeter reading for our UAS is calculated by GPS. The accurate and continuous readings that we receive from this GPS system allow us to operate below set minimums at all times.

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions This regulation states that no pe rson may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and, after that, fly for an additional 30 minutes. This regulation is intended to create a safe flying environment by creating sufficient fuel reserves. Therefore, Saddle Up Productions does not request an exemption from this regulation but, instead, request that the term “ fuel ” be changed

to “ battery power. ” Saddle Up Productions also request s that our battery power reserve for our UAS operations be 25 %.

Saddle Up Productions UA S has capabilities that allow the PIC to monitor battery power levels as well as a return to land feature that will engage when battery levels reach a critical level, therefore returning the UAS automatically to the point of takeoff.

14 CFR Subpart E (91.4 01

– 91.417) Saddle Up Productions requests an exemption from the stringent maintenance regulations that are designed to increase the safety of the flying environment by ensuring adequate inspections and servicing of aircraft. We are requesting exemptio n from these regulations because we believe that, due to the simplicity and the ease of repair, general and preventive maintenance can be performed by the PIC. The PIC is required to make a thorough preflight inspection before each operation. In the case o f a discovery of faulty equipment, most replacement and repair can simply be done on site as long as repairs are of an airworthy manner. Major repair will still have to be performed by a licensed repair facility which will be logged in the UAS records.

Saddle Up Productions believes that our comprehensive preflight inspection, the simplicity of the UAS itself, the nature of the UAS ’ s operations, and the fact that no passengers are on board the aircraft make our operations eligible for exemption from CFR Subpart E (91.401

– 91. 417).

SADDLE UP PRODUCTIONS , ASSUME S THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 29 knots. The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 29 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL). Altitude must be reported in feet AGL.5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be

able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and c onduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents will be accessible during UAS operations and made available to the Ad ministrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrato r or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basi s upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents

.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics,

e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exe mption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. T he oper ator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight i nspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary mainte nance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either airline transport, commercial, private, recreational, or sport pilot certificate with appropriate medical certificates

.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive andemergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are consider ed nonparticipants, and the PIC must operate
the UA S with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be

conducted under vis ual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are
not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol
as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exempti on holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA S must return to a pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA S to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be
conducted in accordanc e with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 6

22. All aircraft operated in accordance with this exemption must be identifie d by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operati on and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA S must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducte d at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator mu st ensure that nonparticipating persons remainunder such protection. If a situation arises where nonparticipating persons leave such protection and are within

500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects
and determin ed that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the la teral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructi ons contained on the NTSB Web site: www.ntsb.gov

.



### PUBLIC BENEFIT AND SAFTEY

U nmanned Aircraft Sys tem sUAVs are often seen as superior to helicopters as an aerial video and photography due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller

e nvironmental impact which promotes public safety. With these technological advances Saddle Up Productions will
enhance economic growth by showcasing our breathtaking community

.

Saddle Up Productions is petitioning for an exemption to operate a DJI Phantom 3 with a built

- in stabilized HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit
the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

- fly zone feature.

The DJI Phantom 3 also has a failsafe function that is triggered in the event com munication is lost betwe en the UAS
and the main controller transmitter. At that time, the UAS will return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Oper ating Standards as set below:

Saddle Up Productions will only operate its UAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are `sufficient distance' from populated areas wi thin the sterile area described. Such operation s will ensure that
the UAS will "not create a hazard to users of the national airspace system or the public."



### The UA may not operate within 5 nautical miles of an airport reference point unless a letter of agreement with that airport ’ s management is obtained. Maximum flight time for each operation will be 25 minutes.

Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the

UAS.

The UAS will be prog rammed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 200 feet above an elevated platform fro m which videography is planned.

The UAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).The UAS will operate at speeds of no more than 29 knots, can hover, and can simultaneously move vertically and

horizontally.

Saddle Up Productions is confident that the knowledge of the PIC, along with the strict safety standards set by Saddle Up Productions , the FAA, and the phy sical safety properties of the UAS, will allow safe and efficient operations.

Saddle Up Productions hereby requests exemption under Section 333 in order to pursue commercial UAV applications with the intent to provide customers w ith the safe, high quality digital medi a (videography and photography).

Sincerely,

Lynne M Undraitis Saddle Up Productions 184 High Road Kalispell, Montana 59901