Hub City Bees

Attn: Andrew Cooper

385 Royal Oak Drive

Spartanburg, SC 29302 

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 and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 

61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 

CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

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

Act”) and 14 CFR Part 11, Andrew Cooper, operator of an Unmanned Aircraft System (UAS), 

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to 

allow commercial operation of its UAS, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by

Section 333. This request for exemption is similar, if not identical, to many previously

submitted requests that have received exemption. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would operate in the following manner: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, events, tourism, engineering and other related professional 

activities. 

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to emergency responders
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6. Aerial collection of 3d data and GPS data for later modeling 

7. Aerial real-time survey of environmental status and wildlife population in cooperation 

with local environmental organizations/researchers

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the National Airspace System that would be a) limited b) controlled c) 

predetermined and d) will provide safety enhancements to the already safe operations in the 

industry presently using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “....establish requirements for the safe operation of such aircraft systems in 

the national airspace system.” 

The name and address of the applicant is: 

Hub City Bees

Attn: Andrew Cooper

Ph: 864-921-4742

Email: hubcitybees@gmail.com

Address: 385 Royal Oak Drive, Spartanburg, SC 29302

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.3 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 
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Hub City Bees will operate a variety of UASs, including but not limited to the DJI Inspire 1, 

DJI Phantom 3, 3DRobotics Solo, 3DRobotics Aero, 3DRobotics IRIS+, Parrot Bebop and 

Parrot AR Drone 2., will be powered using lithium polymer batteries and controlled with a 

remote transmitter operating on 2.4Ghz band. The applicant will operate the UAS in line of 

sight within a closed off and predetermined area owned and/operated by the property 

representative. 

Given the small size of the UAS and the controlled environment provided the proposed 

operations will adhere to the Reform Act’s safety requirements..Regarding the level of safety 

surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. We have intention to provide services, gratis, to local 

wildlife preservation organizations and researchers to survey flora and fauna. We have further 

intention to provide free services to local arts organizations for various projects undertaken in 

the public interest Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay. 

UAS Description: 

I am asking for an exemption for a UAS up to 55 pounds because I forecast I will be using a 

craft that will be flown operationally, weighing less than ten pounds and more specifically, and 

will be qualified as a UAS. Vehicles that will be utilized are the DJI Inspire 1, DJI Phantom 3, 

3DRobotics Solo, 3DRobotics Aero, 3DRobotics IRIS+, Parrot Bebop and Parrot AR Drone 2

In the event a loss of communications occurs the craft will rise up vertically to a safe height 

before beginning an automatic return to home function. The control signal may be reconnected 

in flight and the pilot can take over safe operations again if communication is reestablished. 

However in the case of a GPS failure the craft will be able to be manually flown to a safe 

landing by the pilot. The craft operates electrically, carries no flammable fuel, has an integrated 

GPS pilot system, provides location information along with height AGL, speed, battery life, has 

programmed no-fly zones for controlled airports, and provides direction of travel distance from 

the pilot. 

Flight Operations: Flight paths will be carefully selected in advance taking care to avoid 

crowds. Flights will end when battery reserve reaches 20 percent. Operations will not occur 

under inclement conditions. In addition, preflight and post-flight checklists and UAS 

examinations will help detect any abnormalities prior to flight and after flight. Any UAS unable 

to satisfy safety checklists will be removed from service until the issue can be resolved. 

Granting this request would not adversely affect safety since operations would be in accordance 

with current UAS rules. 

Additional Information:
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The applicant, Andrew Cooper, is an experienced technology professional with experience in 

software and hardware design and development and has worked for numerous fortune 500 

corporations. Additionally the applicant has extensive experience with remote control 

technology and custom robotics. 

Section 333 Compliance and Appropriateness: Based on the size of the craft, experience of 

the pilot, and operational goals, this request appears to be well suited for approval using the 

current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 

(including new interim policies) 

Sincerely, 

Andrew Cooper , Hub City Bees