Hub City Bees Attn: Andrew Cooper 385 Royal OakDrive Spartanburg, SC 29302
U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 i.·:,i· 1 i C· ; '

Re: Exemption Request Pursuant to Section 333 ofthe FAA ReformAct and Part 11 ofthe FederalAviation Regulations from: 14 CFR 21 subpart H; 14 CFR45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR**91.9(b)(2~·** 14 CFR 91.103; 14 CFR91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 1 CFR91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) 1)and (2); 14 CFR91.417(a) and (b)

Dear Sir orMadam:
Pursuant to Section 333 ofthe FAA Modernization an ReformAct of2012 (the "Reform Act") and 14 CFRPart 11, Andrew Cooper, owner an operator ofan UnmannedAircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits UAS, o long as such operations are conducted within and underthe conditions outlined herein or as ay be established by the FAA as required by Section 333. This request for exemption s similar, ifnot identical, to many previously submitted requests that have received exe ption. Commercial operation ofanUAS, as described here· , which are equipped with camera(s) and sensors, would operate inthe following manner:
1. Aerial photography and/or video for public and/orprivate use including real estate, architecture, land surveying, events, tourism, engineering and otherrelated 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 ofresidential/commercial structures under contract withthe owners or local government authority.

. .... 4'

. - 4. Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limited to electrical power lines, wind**turbines~**..cell towers. s. Aerial video/photography orproviding live**vid~d** to emergency responders 6. Aerial collection of3d data and GPS data for latermodeling7. Aerial real-time survey ofenvironmental status and wildlife population in cooperation with local environmental organizations/researchers 8. Marketresearch and public demonstrations with explicitpermission ofany property owner and/or management and adherence with all relevant safety guidelines. 2

As described fully below, the requested exemption would permit the operation ofa UAS under controlled conditions inthe NationalAirspace 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 ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

....establishrequirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is· Hub City Bees Attn: Andrew Cooper Ph: 864-921-4742 Email:

-------- Address: 385 Royal Oak Drive, Spartanburg, SC 29302 Regulations from whichthe exemption is requested:
14 CFRPart 21 subpart H 14 CFR45.23 (b) 14 CFR61.3 14 CFR 61.113 (a) & (b) 14 CFR91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR91.103 14 CFR91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR91.417 (a) & (b)r· '-.

Hub City Bees will operate a variety ofUASs, including butnot limited to the DJI Inspire 1, DJI Phantom 3, 3DRobotics Solo, 3D Robotics Aero, 3DRobotics IRIS+, Parrot Bebop and ParrotAR Drone 2., will bepowered using lithium polymer batteries and controlled with a remote transmitter operating on2.4Ghz band. The applicant will operate the UAS in line of sight within a closed offand predetermined area owned and/ operated by the property representative. 3

Given the small size ofthe UAS and the controlled environmentprovided the proposed operations will adhere to the ReformAct's safety requirements

..Regarding tlle level ofsafety surrounding the proposed operations andthe public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. We have intentionto provide services, gratis, to local wildlife preservation organizations and researchers to survey flora and fauna. We have further intentionto provide free services to local arts organizations for various projects undertaken in the public interestAccordingly 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 tenpounds and more specifically, and will be qualified as a UAS. Vehicles that will be utilized are the DJI Inspire 

### 1, DJI Phantom 3, iDRobotics Solo, 3DRoboticsAero, 3DRobotics IRIS+, Parrot Bebop and ParrotARDrone 2 In the event a loss ofcommunications 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 ifcommunication is reestablished. However inthe case ofa GPS failure the craft will be able to be manually flown to a safe landing bythe pilot. The craft operates electrically, carries no flammable fuel, has anintegrated GPS pilot system, provides location information along with heightAGL, speed, battery life, has programmed no-fly zones for controlled airports, and provides direction oftravel distance from the pilot.
Flight Operations: Flight paths will be carefully selected in advance taking care to avoid crowds. Flights will end whenbattery 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 priorto flight and after flight. Any UAS unable to satisfy safety checklists will beremoved from service until the issue can beresolved. Granting this request would not adversely affect safety since operations would be in accordance with currentUAS rules. Additional Information:4
The applicant, Andrew Cooper, is an experienced hardware and software designer and has years ofexperience with robotics and remote control technology.
Section 333 Compliance and Appropriatenes: Based onthe size ofthe 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 ofthe FAA Modernization and Reform Act of2012 (including new interim policies)

er , Hub City Bees