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 Pursuant 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 which 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 providing 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 videography.

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 operate 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 safety 
protocols specific to lightweight UASs as Looga Productions 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 national 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 protocols 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) 242-3631
Looga 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:

Pursuant 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, motion 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 (PIC); 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, including 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 Productions 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 Reforms 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 traditional 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 any 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 obtained 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-determined 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 and 

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, operational 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 conditions 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 operations 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 with 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 § 91.103: 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 takeoff 

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 functioning 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 in 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 person, 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 operations.

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 

appropriate 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 launch site 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 forecast 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 manufactures 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 maintenance. 

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 

components, 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 inspection 

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 amount 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, 14 CFR 91.151, 14 CFR 
91.405, 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 picture, and television 

industry.

As established by the 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 risks 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 risk 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 manned 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, proximity 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