Looga Productions, L.L.C. 413 N Eton St. Apt. 208 Birmingham, MI 48009 loogaproductions@gmail.com
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request Pu rsuant To Section 333 of the FAA Reform Act of 2012 To Whom It May Concern: Looga Productions LLC is a Michigan Limited Liability Company doing business as Looga Productions. We are writing pursuant to the FAA Modernization and Reform Act of 2012 (the Reform Act) and procedures contained in 14 C.F.R. 11, to request that Looga Productions, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FAR) listed below so that Looga Productions may operate its small unmanned aircraft systems ( UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). Looga Productions operates UASs under 55 pounds, all of wh ich are manufactured by 3DR, DJI, and Lilly Robotics Inc. all leaders in the UAS industry. The proposed aircraft models from 3DR are the solo and the X8

- M. The proposed aircraft from DJI include the Phantom

- 3 and the Inspire

- 1. The proposed model from Lilly Robotics Inc is the Lilly. All of the listed UASs have programmable return to home functions as well as programmable limitations for flight distance and altitude. All aircraft are GPS enabled with safety features such as altitude hold and return to home functions. Looga productions utilizes the owned UASs primarily for aerial videos of golf courses, ski resorts, and Real Estate marketing, though they may be used for cinematography uses such as television, water sports, precision agriculture, surveys, infrastructure inspection, and by first responders. Looga Productions operation of small UASs will prove key in p roviding imagery and video to resort developments in Michigan. We also hope that our video will be used by developers and investors by providing them with a broader picture to investors that cannot readily travel to the area in order to inspect current projects, allowing them to make key decisions anywhere in the world. These operations benefit the public by bringing revenue and jobs to the local economy. Looga Productions UASs are also highly cost efficient when compared to other types of aerial videograph y . Looga Productions exemption request would permit its operation of lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace under 400 feet. Predetermined, specifically marked areas of operation and corresponding enhancements to current safety controls will allow Looga Productions to operate within current safety parameters. Currently, amateurs with no flight experience, safety plan or controls in place to prevent catastrophe legally o perate similar lightweight, remote controlled UASs. It is only logical to allow Looga Productions experienced remote control pilots to operate similar lightweight UASs. This will act to further safetyprotocols specific to lightweight UASs as Looga Product ions researches flight data and other information

gained through permitted flight operations. Granting Looga Productions request comports with the Secretary of Transportation (FAA Administrators) responsibilities to not only integrate UASs into the nation al airspace system, but to establish requirements for the safe operation of such aircraft systems in the national airspace system under section 333(c) of the Reform Act. Further, Looga Productions will conduct its operations in compliance with the protocol s described herein or as otherwise established by the FAA. For the reasons stated in our petition, Looga Productions respectfully requests the grant of an exemption allowing it to operate lightweight, remote controlled UASs within the national airspace. The following links provide details on the specific UASs that Looga Productions plans to operate. 3DR Solo: https://3drobotics.com/solo

-gopro - drone

-specs 3DR X8

- M: https://store.3drobotics.com/products/x8

- m Phantom 3: http://www.dji.com/product/phantom

- 3/spec Inspire 1: http://www.dji.com/product/inspire

- 1/spec Lilly: https://www.lily.camera/tech

-specs/
If you require any additional information please do not hesitate to contact us at: loogaproductions@gmail.com Respectfully, Scott McCartney, Owner Raymond Warren, Owner Looga Productions, LLC loogaproductions@gmail.com (586) 242

- 3631Looga Productions, L.L.C. 413 N Eton St. Apt. 208 Birmingham, MI 48009 loogaproductions@gmail.com
October 13, 2015 US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590 

## Exemption Request Pursuant to Section 333 of the FAA Reform Act and **Part 11 of the Federal Aviation Regulations from: 14 CFR Part 21 Subpart H, 14 CFR**  **61.113 (a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119,**  **14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417**  To Whom It May Concern:
P ursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Looga Productions, an operator of Unmanned Aircraft Systems (UAS) for aerial photography and video of golf courses, ski resorts, Real Estate, m otion picture and television industry, precision agriculture, mapping and surveying, and infrastructure inspection, herby applies for an exemption from the Federal Aviation Regulations (FAR) to allow commercial operation of its UASs. Looga Productions, LLC’s requested exemption would permit the operation of small UASs under 55 pounds to conduct aerial video and photography under the operational control of an individual holding at least a sports pilots license; under direct control of a Pilot in Command (PI C); within Visual Line of Sight (VLOS); while utilizing a second person for the purpose of a Safety Observer. As established by the exemptions already granted by the FAA, approval of Looga Productions exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrators) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.The name and address of the applicant is as follows:

Looga Productions Att: Scott McCartney PH #: 917

-656

-3730 Email: loogaproductions@gmail.com Address: 413 N Eton, Apt 208, Birmingham, MI 48009 Regulations from which the exemption is requested: 

## 14 CFR Part 21 Subpart H, 14 CFR 61.113 (a) and (b), 14 CFR 91.103, 14 CFR **91.109, 14 CFR 91.119,**  **14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417**  UASs operated by Looga Productions weigh less than 55 lbs, in cluding the camera, sensors, and gimbal. They operate at a speed of less than 50 knots, can hover, and simultaneously move vertically and horizontally. Looga Productions will only operate the UASs in the line of sight and below 400 feet AGL. Looga Product ions will utilize a safety observer to insure that the UAS will “not create a hazard to users of the national airspace or the public.” Looga Production small size UASs and the safety considerations of the UASs ensure that our proposal adheres to the Refo rms Act’s safety requirements. Based on the level of safety surrounding the proposed operations and the significant public benefits such as: Marketing and development of real estate, public awareness, reduction in environmental impacts due to more traditio nal methods of filming, and an increase to local revenue, the grant of this petition is in the public’s interest. Accordingly, Looga Productions, respectfully requests that the FAA grant the requested exemption.Aircraft and Equivalent Level of Safety

The operating limitations proposed by Looga Productions provide for at least an equivalent or higher level of safety because operations further enhance safety of real estate, infrastructure inspection, movie, and television filming using conventional aircraft. Looga Productions proposed limitations and conditions include:

 The UASs will weigh less than 50 lbs
 Flights will be operated within the visual line of sight of a pilot and/or observer
 Flights will be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned
 Minimum crew for each operation will consist of the UAS Pilot and a visual observer
 All UAS pilots will undergo in

- house training before operating a ny UAS for commercial use.
 A briefing will be conducted for planned UAS operations prior to each day’s flight. All persons involved in the operations are required to attend
 The operator will obtain consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 50 feet of the flight operation
 The operator will submit a written plan of activities to the FSDO three days prior to any operations and proposed filming
 All required permissions and permits will be obtai ned from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies
 If the UAS loses communications or loses GPS signal, the UAS will have the capability to return to a pre - determine d location and land. **14 CFR Part 21, Subpart H: Airworthiness Certificates** Given the size and limited operating area associated with the UASs to be utilized by Looga Productions, this meets the requirements of an equivalent level of safety under part 11 a nd Section 333 of the Reform Act. The Federal Aviation Act (49 USC § 44701 (f)) and section 333 of the Reform Act both authorize the FAA to exempt the UASs from the requirement for an air worthiness certificate, upon consideration of size, weight, speed, o perational capability, and proximity to airports and populated areas of the particular UASs. In all cases, an analysis of these criteria demonstrates that a UAS operated without an air worthiness certificate, in a restricted environment and under the condi tions proposed will be at least as safe, or safer, than a conventional aircraft operating with an air worthiness certificate without the restrictions and conditions proposed.**14 CFR § 61.113 (a) and (b): Private Pilot Privileges and Limitation:** Pilot in Command sections 61.113 (a) and (b) limit private pilots to non commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve an equivalent level of safety of current operations by requiring all o perations to be supervised by an individual holding a private pilot’s license rather than requiring that individual to hold a commercial pilot’s license to operator a small UAS. Unlike conventional manned aircraft, a ground based operator remotely controls a UAS. The operational area is limited, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s license operating a conventional aircraft. The risks associated w ith the use of the UAS are far lower from those associated with commercial operations contemplated by Part 61. Allowing operational control of a UAS by a private pilot exceeds the present level of safety sought by 14 CFR §61.113 (a) and (b) **14 CFR § 91.10 3: Preflight Action**  Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of the flight. As FAA approved rotorcraft manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, airspace, NOTAMS, TFRs flight battery requirements, landing and take off distances, and performance data before commencement of flight. Additionally all UASs will be checked for security of attached components prior to every flight. **14 CFR § 91.109: Flight Instruction** Section 91.109 states, “No person may operate a civil aircraft (except manned free balloon) that is being used for flight instruction unless that aircraft has fully functio ning dual controls.” The proposed UASs will be operated utilizing an autopilot to maintain controlled flight, and all UASs are programmed to return to a level altitude and hover when the controls are returned to a neutral position. Because of these built i n safety features, dual control is not necessary in order to maintain an equivalent level of safety proposed by section 91.109 during training. All training will be conducted in a controlled environment as to not cause undue harm or damage to persons or property.**14 CFR § 91.119: Minimum Safe Altitudes**

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes...(c) Over other congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any pe rson, vessel, vehicle, or structure.” Because Looga Productions requests authority to operate at altitudes only up to 400 AGL, and not more than 200 feet above an elevated platform from which filming is planned, an exemption is needed to allow such operat ions. The equivalent level of safety will be achieved given the size, weight, and speed of the UAs as well as the location where it is operated. All affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of combustible fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations of the UAS will ensure separation between a UAS and conventional aircraft. **14 CFR § 91.121: Altimeter Settings** Section 91.121 requires each person operating an aircraft to maintain a cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appro priate altimeter setting available before departure.” As UAS may not have a barometric altimeter, but instead reference GPS altitude, an exemption is needed. The operator will achieve an equivalent level of safety, confirming the altitude of the lau n ch sit e shown on the GPS altitude indicator before flight. **14 CFR § 91.151: Fuel Requirements for Flight in VFR Condition** Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes...” The battery powering the proposed UAS provides approximately 30 minutes of powered flight. Therefore the UAS cannot meet the 30

- minute reserve requirement in 14 CFR 91.151. In lieu of this requirement the UAS flights will be terminated at approximately 25% of battery power, this restriction would be more than adequate to return the UAS to its predetermined landing zone from anywhere in its limited operating range.**14 CFR §91.405: Maintenance Inspections**

These regulations require that an aircraft operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prescribed in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...” and others shall inspect or maintain the aircraft in compliance with part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Looga Productions operations. Maintenance will be performed by the operator in accordance with the ma nufactures recommended procedures. An equivalent level of safety will be achieved because UASs are limited in size, will carry a small payload, and operate only for limited periods of time. A preflight inspection will be performed prior to every flight to ensure no mechanical issues are present. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to flight and perform any required mai ntenance. Moreover, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition. **14 CFR § 91.407: Operation after Maintenance** Functional check flights will be conducted away from people or property after any maintenance has been accomplished on the UAS. The UAS may be returned to service once it has been determined safe for flight. **14 CFR § 91.409: Inspections** Due to the small size of the UASs that will be operated by Looga Productions and limited compon ents, we request that the UASs be exempt from regularly scheduled inspections. To meet an equivalent level of safety sought by 14 CFR 91.409, all UASs will be thoroughly inspected prior to flight. Since the UASs will have limited components, a thorough ins pection can be accomplished before each flight, eliminating the need for periodic, time based, or flight hour based inspections cycles. **14 CFR § 91.417: Maintenance Records** As previously described, the UASs proposed size and use significantly limits the a mount of maintenance required. The UASs that will be operated by Looga Productions are designed by the manufacturer for the average hobbyist to purchase and fly with minimal assembly, regular preventative maintenance is limited to security if attached components and proper storage of, and charging of batteries. As such, Looga Productions requests an exemption from maintaining maintenance records as prescribed by 14 CFR 91.417. however, in order to operate as safely as possible, Looga Productions will keep a running log of all maintenance performed on each UAS, and any anomalies noted during operation in order to diagnose and prevent problems with the UAS. **Summary for Publication** Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed. Looga Productions seeks an exemption from the following rules: 14 CFR Part 21, Subpart H, 14 CFR 61.113 (a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 1 4 CFR 91.151, 14 CFR91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.417 to operate commercially small unmanned vehicles

(55 pounds or less) for aerial photography and video for the real estate, motion pi cture, and television industry. As established by t he UAS exemptions already granted by the FAA, allowing commercial operations of UASs in the real estate and film industry will enhance safety by reducing risks. Conventional film operations, using turbine aircraft, operating at low altitudes present the ri sks associated with aircraft that weigh thousands of pounds and carry large amounts of fuel. Such aircraft must also fly to and from the film location. In contrast, a UAS weighing 55 pounds or less and powered by batteries virtually eliminates all of the r isk given the small size and lack of combustible fuel. The UAS is carried, not flown, to a filming location. In this regard, the UAS carries no passengers or crew, therefore will not expose anyone to the risks associated with man n ed flights . The operation of UASs conducted in accordance with this request will provide an equivalent level of safety supporting the grant of the exemption requested herein. The UASs operate at slow speeds, close to the ground, and within a limited range. As a result, they are far safer than conventional operations conducted with turbine helicopters carrying fuel and flying near the ground and people. Satisfaction of the criteria provided in Section 3332 of the Reform Act of 2012 (size, weight, speed, operating capabilities, proxi mity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Looga Productions requested exemption, allowing for Looga Productions UAS commercial operations for real estate, motion picture, television, precision agriculture, infrastructure inspection, golf course, and ski resort industries. Sincerely, Scott McCartney Co

- Owner Raymond Warren Co

- Owner Looga Productions LLC