05/22/2015 BUNGEE LLC. Attn: Charles Gilman PO Box 334 Danville, VT. 05828 802
- 535
-4749 Charliegilman@me.com

TO: Federal Aviation Administration US Department of Transportation Docket Management System 1200 New Jersey Ave. S.E Washington, DC . 20590 Re: Exemption Request Section 333 of the FAA Reform Act Pursuant to section 333 of the FAA Modernization and Reform act of 2012 (The Reform Act), and 14 C.F.R. Part 11, BUNGEE LLC , herby seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to allow BUNGEE LLC to operate Small Unmanned Aircraft Systems ( UAS ) commercially in airspace regulated by the Federal Aviation Administration (FAA) under the conditions and limitations set forth in thi s petition. The requested exemption would permit BUNGEE LLC to operate small, unmanned aircraft system ( UAS ) for the purpose of providing an aerial photography and survey service to Municipalities, Utilities & P rivate consumers. The areas of use will inclu de both photo and video in the Utilities, Communications industry, real estate industry, surveying industry, construction industry, agricultural industry. The UAS will be operated in airspace that is 1) limited 2) predetermined 3) would provide added safe ty enhancements to the already safe operations in the industry presently using conventional aircraft. system” Exemption request to section 333 of the FAA Reform Act Plan 11 Specific to UAS operations. 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 6 1
. 113(a) & (b); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109: 14 CFR 91.119(c);14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.401(a)(1) & (2); 14 CFR 91.417(a) 7 (b).Dea r Sir or Madam:

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related profess ional activities.
 Aerial video and/or photography of for public and/or private use including television, public events, cinematography and news gatherings.
 Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.
 Aerial inspection/photography of residential/commercial utility infrastructure included but not limited to electrical power lines, wind turbines and cell towers.
 Aerial video/photography or providing live video feed to assist w ith rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract and/or donation.
 The ability to offer training to persons or individuals belonging to both private and/or public o rganizations that have interests in the use and application of UAS for the purpose of the safe operation of a UAS to enhance the safety of national aerospace system (NAS) as well as for protection of the persons and property. As described fully below, and to be used as FOM (exibit#1) , the requested exemption s would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements such as limited exposu re to flight crew, climbing crews, weight of vehicles, speeds of usage, non use of volatile fuels, ect
. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportations (the FAA administrators) responsibilities to “....es tablish requirements for the safe operation of such aircraft systems in the national airspace system.
**AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The primary vehicle to be used will be the DJI Phantom 2 Vision+ and or DJI Inspire1. While vehicles may be upg raded as new technological and safety advanced occur the bar for operation and safety will be set by DJI Phantom 2 Vision + and any new vehicles or versions will exceed the current safety and operational standards. No vehicle operated by BUNGEE LLC will be modified from the manufacturers design unless specifically directed by the same manufacturer. The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the flight operations manual include:

# Exhibit #1

 The UAS will w eigh less than 55 lbs
 The UAS will have a maximum operating speed of no more than 100 mph
 Flights will be operated within line of sight of the pilot in command and/or visual observer
 Maximum flight time for each operational flight will be 30 minutes. Flig hts will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first
 Flights will be operated at altitude of no more than 200feet above ground level and no more than 200 feet above an equivalent platform from which filmin g is planned
.  UAS will NOT operate.
 5 nautical miles (NM) from an airport having an operational control tower; or
 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or
 2 NM from an airport without a published instrument flight procedure or an operational tower; or  2 NM from a heliport with a published instrument flight procedure  Minimum crew for each operation will consist of the UAS pilot (PIC) , the visual observer (VO) and may include but not limited to a cam era operator  The UAS pilot will be designated pilot in command and hold a private pilot’s license along with a Current State Drivers License . If the PIC feels another operator to be qualified with the necessary skills to be pilot in command and possesses a private pilot’s license along with , Current credentials, that person may be designated PIC provided they have a minimum of 20 hours of flight time with the UAS.
 A briefing will be performed regarding the planned UAS operations prior to each day’s flig ht consisting of all days production activities
 All flights will occur under visual flight rules meteorological conditions ( V FR only).
 The operator will obtain verbal/written consent of all persons involved with the planned operations and ensure only conse nting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advance permission of the FFDO, operations at close r range may be approved.
 The PIC and VO will have been trained in operation of UAS and receive up

-to - date information for the particular UAS to be operated.
 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.
 Written and/o r verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.
 If the UAS loses communications with the remote controller or losses GPS sig nal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.
 The UAS will have the capability to abort a flight and return to designated landing area in case of unpredicted obstacles, we ather, or emergencies.
 VO or PIC instructed to switch UAS to automatically return home in event either are incapacitated.**https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/**

**section333_public_guidance.pdf As of March**  **23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below 200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less**  **than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR ) conditions**  **and within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports.**  **In seeking authorization, petitioners will require exemptions from regulations with**  **which they cannot fully comply. The table be**  **low provides guidance regarding regulations from which a petitioner may**  **require exemption. However, some proposed operations may require**  **exemption from regulations not listed here, while others may not require**  **exemption from all regulations listed here.**  **14 CFR PART**  **Part 21 Airworthiness Certification 21, Subpart H**  **Certification procedures for products and parts, Airworthiness Certificates**  **91.103(b)(2) Preflight action**  **91.105 Flight crewmembers at stations**  **91.109 Flight instruction**  **91.119 Minimum safe altitudes**  **91.121 Altimeter settings**  **91.151 Fuel requirements for flights in VFR**  **conditions 91.405**  **Maintenance required 91.407**  **Operation after maintenance 91.409**  **Inspections 91.417**  **Maintenance 14 C.F.R. Part 21, Subpart H: Airworthiness**  **C ertificates 14 C.F.R. Sec 91.203(a)(1)** 

**The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no explosive** **materials or flammable liquid fuels*, and operates in within a se****cured and pre -** **determined designated area**  **, at altitudes not to exceed 200**  **ft ALT or speeds in access of 100 MPH**  **. 14 C.F.R. Sec 91.105 Flight crew members at station**  **Exemption may be required, the PIC may not leave his station nor shall VO leave station . In event that PIC**  **or VO become incapacitated, UAS**  **is to automatically return to designated landing area, as**  **outlined in FOM 14 CFR Sec 91.109**  **Flight Instruction (D ual Controls)**  **Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has fully functioning dual controls.**  **UAS and Remote controlled aircraft by design do not have dual controls, to**  **do so on a radio controlled airc raft would lower the ability to safely operate the UAS. This section**  **cannot reasonably apply 14 C.F.R. Sec 45.23(b). Marking of the Aircraft**  **Although exemption from said section cannot benefit nor exceed current stipulations, physical limitations of UAV**  **a re reality, such as cabin**  **s, letter size, ect. The**  **UAV will operate under my control with registration lettering**  **sized to fit fuselage in compliance of said section 45.23(b) under**  **conditions and or limitations dee**  **med mandatory by FAA**  **. I and my colleges must be held responsible for compliancy** **, on behalf**  **of Public’s safety**  **and shared air space , as well as**  **its need**  **to indentify and**  **Enforce the accountability and of this grow ing**  **industry. 14 C.F.R. Sec 61.113(a) and (b): Private Pilot**  **Privileges and Limitations: Pilot in Command By current regulations because the applicants UA** **S does not carry passengers, or property. The use of**  **UAS is far less dangerous (weight, speed, Fuel)**  **than the inherent usage of commercial activities outlined in 1**  **4 CFR. 16**  **. The pilot in command shall have a current Private**  **pilots license**  **as well as a Current state drivers licsence**  **which will equal if not exceed**  **safety regulations outlined in 14 CFR**  **16 .113.(a) & (b).** 

**14 C.F.R. Sec. 91.103: Preflight Action :**  **Exempt ion**  **is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC**  **will take all actions as stated in FOM, under normal procedures included but not limited to review of weather, examination of batteries for flight time analysis** **, landing and takeoff distances as well as flight and aircraft performance in flight.** **14 C.F.R. Sec 91.119; Minimum Safe Altitudes**

**Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then minimums prescribed, providing the person operating helicopter complies with any route with and or**  **altitudes prescribed for Helicopter’s by FAA. Being that UA V is of Helicopters standards and operation**  **a request for exemption to operate at altitude’s not to exceed 2**  **00 AGL or not more than 200 ft above any elevated platform from which take off is necessary to achieved filming. In the event of such**  **particular fl ight plan, property owners, filming crews and other personnel would all be briefed as to**  **safety and conduct procedures during flight. FOB or ATC having jurisdiction in such area would have notification and briefing as mandated.**  **14 C.F.R. Sec 91.121 Altime ter Settings**  **The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UA** **S has no**  **barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied.**  **Per a pre flight check list and live flight data monitoring, the altitude of launch site will be predetermined and therefore calculated into the UA** **S -**  **GPS indicator before flight. 14**  **C.F.R. Sec 91 .151(a): Fuel Requirements for Flight in VFR Co**  **Fuel requirements for flight. The maximum flight time under ideal conditions is 30 minutes with the current manufacturers battery pack. The proposed rule under**  **this exemption would require**  **the UA** **S to retur**  **n to its point of launch if its battery reaches less than 25% provides a higher standard of safety when applied to**  **UA S**  **. 1**  **4 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections Referring to maintenance, preventive maintenance,**  **and alterations to the UA S**  **. The operator will provide minor maintenance and inspection to the UA** **S , documented as outlined in the operational**  **and safety guidelines. Given the size and simplicity of the UA S**  **combined with the operational and safety guidelines**  **outlined in this petition the operator can maintain or exceed the required level of safety.** 
**Sincerely Charles Gilman**  **BUNGEE, LLC**