Sudesh Saroop

Private Pilot, Executive Vice President

PRiyaCOMM, LLC

48 Sutton Park Road

Poughkeepsie, NY 12603

(845) 849-2205

ssaroop@priyacomm.com

August 12, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

I am writing concerning the FAA Modernization and Reform Act of 2012 (the "Reform Act") and the

procedures contained in 14 C.F.R. 11. I am requesting that PRiyaCOMM, LLC, owned and operated by

Karen Dipnarine-Saroop be exempted from the Federal Aviation Regulations ("FARs") listed below so that 

Sudesh Saroop, Executive Vice President, PRiyaCOMM, LLC may operate its small unmanned 

aircraft/lightweight unmanned aircraft systems "UAS" in commercial airspace regulated by the Federal 

Aviation Administration ("FAA").

Primary uses will be low altitude aerial photography and video footage for educational, research, 

promotional, entertainment, and marketing purposes.

PRiyaCOMM, LLC and Sudesh Saroop have operated a UAS on many occasions, non-commercially,

without incident. Sudesh Saroop is also an FAA certified instrument-rated private pilot since 1999 and is 

fully aware of the relevant FARs and the national airspace system.

The UAS utilizes battery power, not combustible fuels. Flight time ranges between five and twenty

minutes. The UAS has GPS functionality to hover in place as well as a return to home function in case of

loss of contact with the radio. It has an audible and visual warning system and will start to descend slowly 

if battery power reaches 25%.

PRiyaCOMM, LLC's exemption request would permit its operation of lightweight, unmanned (piloted by

remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace. As stated 

earlier, Sudesh Saroop has UAS flight experience and is willing to abide and comply with the FAA's

current and forthcoming regulations. The UAS will only be operated with full GPS reception in order to 

maintain situational awareness using the displayed map and remain outside of pre-programmed No Fly 

Zones.

For the reasons stated below, PRiyaCOMM, LLC respectfully requests the grant of an exemption allowing 

Sudesh Saroop to operate lightweight, remote controlled UASs as the sole pilot on behalf of 

PRiyaCOMM, LLC.

1. Contact Information:

Mr. Sudesh Saroop

PRiyaCOMM, LLC

48 Sutton Park Road

Poughkeepsie, NY 12603
(845) 849-2205

e-mail: ssaroop@priyacomm.com

2. The Specific Sections of Title 14 of the Code of Federal Regulations from Which We Request

Exemption is:

14CFR 21:

14 C.F.R. 45.23 (b):

14 CFR 61m113 (a) & (b):

14 C.F.R. 91, et seq.:

14 CFR 407 (a) (1):

14 CFR 409 (a) (2):

14 CFR 417 (a) & (b).

U.S Dep't of Trans.

3. The Extent of Relief PRiyaCOMM, LLC Seeks and the Reason It Seeks Such Relief:

PRiyaCOMM, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating in cinematic, educational, promotional, 

research, entertainment, and marketing flight operations within the national airspace system. The Reform 

Act in Section 332 provides for such integration of civil unmanned aircraft systems into our National 

airspace system as it is in the public's interest to do so. Our lightweight UAS meets the definition of "small 

unmanned aircraft" as defined in Section 331 and therefore the integration of our lightweight UAS is 

expressly contemplated by the Reform Act. We would like to operate our lightweight UAS prior to the time 

period by which the Reform Act requires the FAA to promulgate rules governing such craft.

The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our 

national airspace system. Considerations include:

• The weight, size, speed and overall capabilities of the UAS:

• Whether the UAS will be operated near airports or populated areas: and,

• Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for PRiyaCOMM, LLC. Our 

UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs less than 

3 pounds, including battery and all equipment. This small unmanned aircraft is designed to primarily 

hover in place and operate at less than a 32 knot maximum speed. It is capable of vertical and horizontal 

operation but will operate only within the line of sight of the remote control pilot. In addition to the remote 

control pilot, we use a spotter, such that, at minimum, two PRiyaCOMM, LLC personnel govern the safe 

flight of the aircraft at all times.

Utilizing battery power and not combustible fuels, flights generally last between five and twenty minutes. 

We do not operate the UAS with less than twenty five percent battery capacity. Safety systems in place 

include a GPS/GLONASS mode that allows the UAS to stay outside No Fly Zones and to hover in place 

or return to takeoff location if communication with the radio control pilot is lost and then slowly descend 

the UAS at twenty five percent battery capacity. PRiyaCOMM, LLC does not operate the UAS near 

airports or near populated areas. To date, we have only operated the UAS in a non-commercial manner.

Our operation of this small unmanned aircraft will not "create a hazard to users of the national airspace

system or the public." 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, combined with

its operation in cordoned off and well-controlled areas, this falls within Congress's contemplated safety

zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the

national airspace system. Indeed, our UAS will not pose any threat to the general public or national

security.

The FAA has the authority to issue the exemption sought by PRiyaCOMM, LLC pursuant to the Federal

Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").
4. How this Request Will Benefit the Public As A Whole:

Granting this exemption request will benefit the public by promoting education, research, and promotional 

ideas within the community. Presently, it is cost prohibitive for local businesses to obtain aerial images 

and videos of properties and events by renting or hiring a commercial aircraft and photographer. Thus, we 

aim to offer a competitive advantage to small businesses and non-profit organizations in documenting 

and/or promoting their products and work. One of our prime goals is to showcase the natural beauty of 

our environment to increase the appreciation of our parks, lakes, rivers, and mountain by the public 

thereby encouraging eco-tourism and attendance at State parks and the preservation of our natural 

resources.

PRiyaCOMM, LLC would also like to use UASs for cinematic and entertainment purposes. The videos 

and imagery captured would be put together in films that offer entertainment to the general public

audience. Progression of the arts and sciences has been fundamental to our society since its inclusion in

the United States Constitution. Congress mandated the integration of UASs into our national airspace

system, in part, to achieve progression in this noteworthy and inevitable field. Permitting PRiyaCOMM, 

LLC to immediately fly within the United States furthers these goals.

5. Reasons Why PRiyaCOMM, LLC Exemption Will Not Adversely Affect Safety or How the Exemption Will 

Provide a level of Safety At Least Equal to Existing Rule:

This exemption will not adversely affect safety. Since PRiyaCOMM, LLC has experience with flying UASs,

we are quite aware of (and follow) FAA safety protocols and airspace guidelines. PRiyaCOMM, LLC’s 

UAS will be piloted by an experienced FAA Private Pilot.

In addition we submit the following to represent the safety techniques we uphold when flying our UAS:

• Our UAS weighs less than 3 pounds complete with all mounted equipment and battery:

• We only operate our UAS below 400 feet. This limit is voluntarily programmed into the UAS for the 

safety of the public:

• Our UAS only operates for 5-20 minutes per flight:

• We land our UAS when it reaches 25% battery power:

• Our remote control pilot operates the UAS by line of sight:

• Our remote control pilot has video backup and GPS locator should he somehow lose sight of the UAS:

• We staff each flight with a remote control pilot and spotter with communication systems enabling real 

time communication between them:

• Our UAS has GPS flight modes whereby it hovers, returns to takeoff position and then slowly lands if 

communication with the remote control pilot is lost or battery power is below 25%:

• We will actively monitor the position of the UAS on pre-loaded maps to remain outside of restricted 

zones

• We actively analyze electronic flight data and other sources of information to constantly update and 

enhance safety protocols:

• We conduct briefings prior to flight during which safety carries primary importance:

• We have procedures in place to abort flights in the event of safety breaches or potential danger.

It is important to note that absent the integration of commercial UASs into our national airspace system, 

helicopters and manned airplanes are the primary means of aerial motion picture and promotional 

imagery. While the safety record of such aircrafts is remarkably astounding, it is far safer to operate a 

battery powered lightweight UAS. The potential loss of life is diminished because UASs carry no people 

on board and PRiyaCOMM, LLC only operates them in specific areas away from mass populations. There 

is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. The small 

size and extreme maneuverability of our UAS allows our remote control pilot to avoid hazards. Given their 

small size and weight, even when close enough to capture amazing images, our UAS needs not be so 

close to the objects it is focused on. Accordingly, our UAS has operated and will continue to operate at 

and above current safety levels.

6. Summary:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness certificates and Manuals.
14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of

necessary airworthiness certificates in relation to FAR§ 91.203(a)(1). The size, weight and enclosed

operational area of PRiyaCOMM, LLC UAS permits exemption from Part 21 because PRiyaCOMM's UAS

meets an equivalent level of safety pursuant to Section333 of the Reform Act. The FAA is authorized to

exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)

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

airworthiness certificate requirement in consideration of the weight, size speed, maneuverability and

proximity to areas such as airports and dense populations. PRiyaCOMM, LLC UAS meets or exceeds 

each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R § 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 a manual at the flight operations center. The FAA has previously issued 

exemptions to their regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167,

10167A, 10602, 10700 and 32827.

14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as PRiyaCOMM, LLC utilizes 

electronic global positioning systems and internal gyroscopes to provide spatial coordination.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations.

They are inapplicable for the same reasons described above. The equivalent level of safety will be

achieved by maintaining such certifications and registrations at PRiyaCOMM, LLC.

B. 14 C.F.R § 45.23: Marking of the Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications.

PRiyaCOMM's UAS is, by definition, unmanned. It therefore does not have a cabin, cockpit or pilot station 

on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small 

aircraft. Regardless, PRiyaCOMM, LLC will mark its UAS in the largest possible lettering by placing the 

word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. § 45.29(f) so that the pilot, technician, 

spotter and others working with the UAS will see the markings. The FAA has previously issued 

exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: 

PIC. Pursuant to 14 C.F.R.§§ 61.113 (a) & (b) private pilots are limited to non-commercial operations. 

PRiyaCOMM, LLC can achieve an equivalent level of safety as achieved by current regulations because 

PRiyaCOMM, LLC UAS does not carry any pilots or passengers. Furthermore, PRiyaCOMM, LLC uses 

the wisdom of a certified FAA Private Pilot at all times. The risks attendant to the operation of 

PRiyaCOMM UAS is far less than the risk levels inherent in the commercial activities outlined in 14 

C.F.R.§ 61, et seq. Thus, allowing PRiyaCOMM, LLC to operate its UAS with a Private pilot as the pilot in 

control will exceed current safety levels in relation to 14 C.F.R. § 61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be

operated at lower altitudes in certain conditions. PRiyaCOMM, LLC will never operate at an altitude

greater than 400 AGL. Given the size, weight, maneuverability and speed of PRiyaCOMM, LLC UAS, an

equivalent level of safety will be achieved.

E. 14 C.F.R. 91.405 (a) (2); 417 (a) & (b): Maintenance Inspections.

The above cited Regulations require, amongst other things, aircraft owners and operators to "have aircraft 

inspected as prescribed in subpart E of this part and shall between required inspection, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this

chapter .... " These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will 

not apply to PRiyaCOMM, LLC should its requested exemption be granted. PRiyaCOMM, LLC conducts a 
maintenance program that involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.

F. Summary

PRiyaCOMM, LLC and Sudesh Saroop seek an exemption from the following Regulations: 14 C.F.R. 21,

subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R § 91.9 (b)(2); 

14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; C.F.R. § 91.151 (a); 

14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 

(a)(2);14 C.F.R. § 91.409 (a)(2);and 14 C.F.R.§§ 91.417 (a) & (b) to commercially operate its lightweight 

unmanned aircraft in educational, promotional, research, and motion picture or photography operations.

Granting PRiyaCOMM, LLC’s request for exemption will reduce current risk levels and thereby enhance

safety. Currently aerial promotional and motion picture image filming rely primarily on the use of larger

aircraft running combustible fuel. PRiyaCOMM aircraft does not contain potentially explosive fuel, is

smaller, lighter and more maneuverable than conventional aircraft. PRiyaCOMM, LLC’s UAS operates at

lower altitudes and in controlled airspace. There are no people on board PRiyaCOMM's UAS and

therefore the likelihood of death or serious bodily injury is significantly limited. PRiyaCOMM, LLC’s

operation of its UAS, weighing less than 3 pounds and travelling at speeds lower than 32 knots, will 

provide at least an equivalent level of safety as that achieved under current FARs.

Accordingly, PRiyaCOMM, LLC respectfully requests that the FAA grant its exemption request without

delay. The FAA has the authority to issue the exemption sought by PRiyaCOMM, LLC pursuant to the

Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act").

In closing, PRiyaCOMM, LLC would like to state that by granting PRiyaCOMM, LLC the exemption the 

FAA would be helping a small business accomplish at least three things that would benefit the general

public: 1) provide a cost-effective service to local small businesses and non-profits, 2) promote the 

appreciation and preservation of our natural resources, and 3) entertainment and educational value for all 

public audiences.

Respectfully submitted,

Sudesh Saroop

Executive Vice President

PRiyaCOMM, LLC

48 Sutton Park Road

Poughkeepsie, NY 12603