1 

November, 01 2015 

Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: BumpWorks, LLC 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS, FEDERAL AVIATION REGULATION PART 103 

ULTRALIGHT VEHICLES, SOURCE: Docket No. 21631, 47 FR 38776, Sept. 2, 1982 

§103.1 Applicability. 

(a) is used or intended to be used for manned operation in the air by a single occupant; 

(b) Is used or intended to be used for recreation or sport purposes only; 

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Brian M Bailey 

Co-Owner 

BumpWorks, LLC

131 Cheeseman Rd. 

Portersville, PA 16051 

724-368-2070 

bmb@bumpworks.com

 
2 

TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................4 

BASIS FOR PETITION.........................................................................................................5 

NAME AND ADDRESS OF PETITIONER.........................................................................11

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BUMPWORKS, LLC 

SEEKS EXEMPTION............................................................................................................11 

THE EXTENT OF RELIEF BUMPWORKS, LLC SEEKS AND THE REASON 

BUMPWORKS, LLC SEEKS THE RELIEF...................................................................... 11 

THE REASONS WHY GRANTING THE BUMPWORKS’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST ..........................................................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION TO BUMPWORKS, LLC WOULD 

NOT ADVERSELY AFFECT SAFETY..............................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................21 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE ALTEK MEDIA GROUP’S REQUEST..................................................21 

CONCLUSION.....................................................................................................................22 
3 

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
4 

SUMMARY

BumpWorks, LLC seeks exemption from the requirements of 14 C.F.R §§ §103.1 Applicability. 

(a) is used or intended to be used for manned operation in the air by a single occupant; 

(b) Is used or intended to be used for recreation or sport purposes only; 

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit BumpWorks, LLC to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography of construction sites, residential and commercial real estate, civil landscapes and 

events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

BumpWorks, LLC has for over 8 years provided their clients (which include private sector 

businesses and non-profits, along with local state and federal agencies) with expertise, knowledge 

and training using advanced technologies and solutions. The objective of BumpWorks, LLC and 

our Unmanned Aircraft System aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting

• UAS construction, repair and flight worthiness awareness

• Economic development 

• Aerial video and photography

• Special event coverage

• Private and governmental training 

BACKGROUND

Unmanned Aircraft Systems: UAS

BumpWorks, LLC seeks an exemption to operate UAS system for compensation or hire within the 

NAS. The UAS is an Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The UAS will not exceed a maximum gross weight of 

55lb. A maximum airspeed of 55 knots and a maximum flying height of 500'. 

The UAS that will be operated by BumpWorks, LLC will be flown according to: 

 
5 

BASIS FOR PETITION

Petitioner, BumpWorks, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate UAS in the National Airspace System (NAS), and for an exemption from 

the requirements of 14 C.F.R §§ 103.1 (a) & (b). Under Sec. 103.5 Waivers. No person may 

conduct operations that require a deviation from this part except under a written waiver issued by 

the Administrator. 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, BumpWorks, LLC operation of UAS aircraft meets certain 

conditions of FAR 103 

 Sec. 103.1 Applicability. 

This part prescribes rules governing the operation of ultralight vehicles in the United States. For 

the purposes of this part, an ultralight vehicle is a vehicle that: 

 (c) Does not have any U.S. or foreign airworthiness certificate; and 

 (d) If unpowered, weighs less than 155 pounds; or 

 (e) If powered: 

(1) Weighs less than 254 pounds empty weight, excluding floats and safety devices which 

are intended for deployment in a potentially catastrophic situation; 

 (2) Has a fuel capacity not exceeding 5 U.S. gallons; 

(3) Is not capable of more than 55 knots calibrated airspeed at full power in level flight; 

and 

 (4) Has a power-off stall speed which does not exceed 24 knots calibrated airspeed. 

Sec. 103.3 Inspection requirements. 

(a) Any person operating an ultralight vehicle under this part shall, upon request, allow the 

Administrator, or his designee, to inspect the vehicle to determine the applicability of this part. 

(b) The pilot or operator of an ultralight vehicle must, upon request of the Administrator, 

furnish satisfactory evidence that the vehicle is subject only to the provisions of this part. 

Sec. 103.7 Certification and registration. 

(a) Notwithstanding any other section pertaining to certification of aircraft or their parts or 

equipment, ultralight vehicles and their component parts and equipment are not required to 

meet the airworthiness certification standards specified for aircraft or to have certificates of 

airworthiness. 

(b) Notwithstanding any other section pertaining to airman certification, operators of ultralight 

vehicles are not required to meet any aeronautical knowledge, age, or experience requirements 

to operate those vehicles or to have airman or medical certificates. 
6 

(c) Notwithstanding any other section pertaining to registration and marking of aircraft, 

ultralight vehicles are not required to be registered or to bear markings of any type. 

 Subpart B--Operating Rules 

 Sec. 103.9 Hazardous operations. 

(a) No person may operate any ultralight vehicle in a manner that creates a hazard to other 

persons or property. 

(b) No person may allow an object to be dropped from an ultralight vehicle if such action 

creates a hazard to other persons or property. 

 Sec. 103.11 Daylight operations. 

(a) No person may operate an ultralight vehicle except between the hours of sunrise and 

sunset. 

(b) Notwithstanding paragraph (a) of this section, ultralight vehicles may be operated during 

the twilight periods 30 minutes before official sunrise and 30 minutes after official sunset or, 

in Alaska, during the period of civil twilight as defined in the Air Almanac, if: 

(1) The vehicle is equipped with an operating anti-collision light visible for at least 3 statute 

miles; and 

 (2) All operations are conducted in uncontrolled airspace. 

 Sec. 103.13 Operation near aircraft; right-of-way rules. 

(a) Each person operating an ultralight vehicle shall maintain vigilance so as to see and avoid 

aircraft and shall yield the right-of-way to all aircraft. 

(b) No person may operate an ultralight vehicle in a manner that creates a collision hazard 

with respect to any aircraft. 

 (c) Powered ultralights shall yield the right-of-way to unpowered ultralights. 

 Sec. 103.15 Operations over congested areas. 

No person may operate an ultralight vehicle over any congested area of a city, town, or 

settlement, or over any open air assembly of persons. 

 Sec. 103.17 Operations in certain airspace. 

No person may operate an ultralight vehicle within Class A, Class B, Class C, or Class D 

airspace or within the lateral boundaries of the surface area of Class E airspace designated for 

an airport unless that person has prior authorization from the ATC facility having jurisdiction 

over that airspace. 
7 

EFFECTIVE DATE NOTE: Amdt. 103-4, 56 FR 65662, Dec. 17, 1991, revised Sec. 103.17 

effective September 16, 1993. The text of Sec. 130.17 in effect until September 16, 1993 reads 

as follows: 

 Sec. 103.17 Operations in certain airspace. 

 No person may operate an ultralight vehicle within an airport traffic area, control zone, airport 

radar service area, terminal control area, or positive control area unless that person has prior 

authorization from the air traffic control facility having jurisdiction over that airspace. 

 [Doc. No. 23708, 50 FR 9259, Mar. 6, 1985] 

 56 FR 65638, No. 242, Dec. 17, 1991 

SUMMARY: This final rule amends the Federal Aviation Regulations (FAR) to adopt certain 

recommendations of the National Airspace Review (NAR) concerning changes to regulations 

and procedures in regard to airspace classifications. These changes are intended to: (1) 

Simplify airspace designations; (2) achieve international commonality of airspace designations; 

(3) increase standardization of equipment requirements for operations in various classifications 

of airspace; (4) describe appropriate pilot certificate requirements, visual flight rules (VFR) 

visibility and distance from cloud rules, and air traffic services offered in each class of 

airspace; and (5) satisfy the responsibilities of the United States as a member of the 

International Civil Aviation Organization (ICAO). The final rule also amends the requirement 

for minimum distance from clouds in certain airspace areas and the requirements for 

communications with air traffic control (ATC) in certain airspace areas; eliminates airport 

radar service areas (ARSAs), control zones, and terminal control areas (TCAs) as airspace 

classifications; and eliminates the term "airport traffic area." The FAA believes simplified 

airspace classifications will reduce existing airspace complexity and thereby enhance safety. 

EFFECTIVE DATE: These regulations become effective September 16, 1993, except that Secs. 

11.61(c), 91.215(d), 71.601, 71.603, 71.605, 71.607, and 71.609 and Part 75 become effective 

December 12, 1991, and except that amendatory instruction number 20, Sec. 71.1, is effective as 

of December 17, 1991 through September 15, 1993, and that Secs. 71.11 and 71.19 become 

effective October 15, 1992. The incorporation by reference of FAA Order 7400.7 in Sec. 71.1 

(amendatory instruction number 20) is approved by the Director of the Federal Register as of 

December 17, 1991, through September 15, 1993. The incorporation by reference of FAA Order 

7400.9 in Sec. 71.1 (amendatory instruction number 24) is approved by the Director of the 

Federal Register as of September 16, 1993 through September 15, 1994. 

Sec. 103.19 Operations in prohibited or restricted areas. 

No person may operate an ultralight vehicle in prohibited or restricted areas unless that person 

has permission from the using or controlling agency, as appropriate. 

Sec. 103.20 Flight restrictions in the proximity of certain areas designated by notice to airmen. 
8 

No person may operate an ultralight vehicle in areas designated in a Notice to Airmen under Sec. 

91.143 or Sec. 91.141 of this chapter, unless authorized by ATC. 

[Doc. No. 24454, 50 FR 4969, Feb. 5, 1985, as amended by Amdt. 103-3, 54 FR 34331, Aug. 18, 

1989] 

 Effective Date Note: At 54 FR 34331, August 18, 1989, Sec. 103.20 was amended by changing 

the cross reference "Sec. 91.102 or Sec. 91.104" to read "Sec. 91.143 or Sec. 91.141", effective 

August 18, 1990. 

Sec. 103.21 Visual reference with the surface. 

 No person may operate an ultralight vehicle except by visual reference with the surface. 

Sec. 103.23 Flight visibility and cloud clearance requirements. 

No person may operate an ultralight vehicle when the flight visibility or distance from clouds is 

less than that in the table found below. All operations in Class A, Class B, Class C, and Class D 

airspace or Class E airspace designated for an airport must receive prior ATC authorization as 

required in Sec. 103.17 of this part. 

 Flight 

 Airspace visibility Distance from clouds 

 Class A Not applicable Not Applicable. 

 Class B 3 statute miles Clear of Clouds. 

 Class C 3 statute miles 500 feet below. 

 1,000 feet above. 

 2,000 feet horizontal. 

 Class D 3 statute miles 500 feet below. 

 1,000 feet above. 

 2,000 feet horizontal. 

 Class E: 

 Less than 10,000 feet MSL 3 statute miles 500 feet below. 

 1,000 feet above. 

 2,000 feet horizontal. 

 At or above 10,000 feet MSL 5 statute miles 1,000 feet below. 

 1,000 feet above. 

 1 statute mile 

horizontal. 

 Class G: 

 1,200 feet or less above the 

 surface (regardless of MSL 

 altitude) 1 statute mile Clear of clouds. 

 More than 1,200 feet above the 

 surface but less than 10,000 

 feet MSL 1 statute mile 500 feet below. 

 1,000 feet above. 

 2,000 feet horizontal. 

 More than 1,200 feet above the 

 surface and at or above 10,000 

 feet MSL 5 statute miles 1,000 feet below. 

 1,000 feet above. 

 1 statute mile 
9 

EFFECTIVE DATE NOTE: Amdt. 103-4, 56 FR 65662, Dec. 17, 1991, revised Sec. 103.23 

effective September 16, 1993. The text of Sec. 103.23 in effect until September 16, 1993 reads 

as follows: 

 Sec. 103.23 Flight visibility and cloud clearance requirements. 

No person may operate an ultralight vehicle when the flight visibility or distance from clouds 

is less than that in the following table, as appropriate: 

 Minimum 

 flight 

 visibility 

 Flight altitudes /1/ Minimum distance from clouds 

 1,200 feet or less above the 

 surface regardless of MSL 

 altitude: 

 (1) Within controlled airspace 3 500 feet below, 1,000 feet 

 above, 2,000 feet 

horizontal. 

 (2) Outside controlled 1 Clear of clouds. 

 airspace 

 More than 1,200 feet above the 

 surface but less than 10,000 

 feet MSL: 

 (1) Within controlled airspace 3 500 feet below, 1,000 feet 

 above, 2,000 feet 

horizontal. 

 (2) Outside controlled 1 500 feet below, 1,000 feet 

 airspace above, 2,000 feet 

horizontal. 

 More than 1,200 feet above the 5 1,000 feet below, 1,000 feet 

 surface and at or above 10,000 above, 1 statute mile 

 feet MSL horizontal. 

 /1/ Statute miles. 

 

 ******************************************************************* 

 56 FR 65638, No. 242, Dec. 17, 1991 

SUMMARY: This final rule amends the Federal Aviation Regulations (FAR) to adopt certain 

recommendations of the National Airspace Review (NAR) concerning changes to regulations 

and procedures in regard to airspace classifications. These changes are intended to: (1) Simplify 

airspace designations; (2) achieve international commonality of airspace designations; (3) 

increase standardization of equipment requirements for operations in various classifications of 

airspace; (4) describe appropriate pilot certificate requirements, visual flight rules (VFR) 

visibility and distance from cloud rules, and air traffic services offered in each class of airspace; 

and (5) satisfy the responsibilities of the United States as a member of the International Civil 
10 

Aviation Organization (ICAO). The final rule also amends the requirement for minimum 

distance from clouds in certain airspace areas and the requirements for communications with air 

traffic control (ATC) in certain airspace areas; eliminates airport radar service areas (ARSAs), 

control zones, and terminal control areas (TCAs) as airspace classifications; and eliminates the 

term "airport traffic area." The FAA believes simplified airspace classifications will reduce 

existing airspace complexity and thereby enhance safety. 

 EFFECTIVE DATE: These regulations become effective September 16, 1993, except that 

Secs. 11.61(c), 91.215(d), 71.601, 71.603, 71.605, 71.607, and 71.609 and Part 75 become 

effective December 12, 1991, and except that amendatory instruction number 20, Sec. 71.1, is 

effective as of December 17, 1991 through September 15, 1993, and that Secs. 71.11 and 71.19 

become effective October 15, 1992. The incorporation by reference of FAA Order 7400.7 in Sec. 

71.1 (amendatory instruction number 20) is approved by the Director of the Federal Register as 

of December 17, 1991, through September 15, 1993. The incorporation by reference of FAA 

Order 7400.9 in Sec. 71.1 (amendatory instruction number 24) is approved by the Director of the 

Federal Register as of September 16, 1993 through September 15, 1994. 

BumpWorks, LLC submits that the requested relief from certain requirements is proper since an 

equivalent level of safety will be ensured. BumpWorks, LLC will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the operating documents as specified by the 

equipment manufacture. 
11 

In accordance with 14 C.F.R. § 11.81, BumpWorks, LLC provides the following information in 

support of its petition for exemption: 

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Brian Bailey 

Co-Owner 

BumpWorks, LLC 

131 Cheeseman Rd. 

Portersville, PA 16051 

724-368-2070 

bmb@bumpworks.com 

Extent Of Relief BumpWorks, LLC Seeks And The Reason BumpWorks, LLC Seeks Relief 

From Section 103.1(a) & (b). 

Relief from Section 14 C.F.R §§ §103.1 Applicability. 

This relief is requested since the limitations set forth in Section 103.1(a) and (b) state that (a) is 

used or intended to be used for manned operation in the air by a single occupant; (b) Is used or intended to 

be used for recreation or sport purposes only; 

Relief from Section 103.1(a) used for UA “Unmanned Aircraft” operation and (b) is requested to 

conduct the proposed UAS “Unmanned Aircraft System” flight operations for compensation or 

hire. 

As set forth more fully below, BumpWorks, LLC submits that a level of safety will be maintained 

because no PIC will be allowed to operate the UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate either UAS in a manner 

consistent with the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.

Further, BumpWorks, LLC submits that all flights of the UAS, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to BumpWorks, LLC business; and (2) will not 

carry passengers or property for compensation or hire. 
12 

1.The Public Will Benefit From Decreased Congestion Of The NAS.

UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. UAS do not require an airport 

to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The UAS. 

Conducting aerial acquisitions with the UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial video and still photography flight operations. By using battery power and electric motors, 

the UAS produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial 

video and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise 

pollution, as the UAS are propelled by battery powered electric motors, rather than an internal 

combustion engine. 

By using the UAS to perform aerial acquisitions, the substantial risk to life and property in the air 

and on the ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, UAS (weighing less than 55 pounds at their maximum gross weight 

has less physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing approximately 

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 

180 gallons). 

3. Performing Aerial Video and Photography Operations with the UAS Will Benefit the 

Economy. 

In addition to being safe and efficient, the UAS used by BumpWorks, LLC are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

UAS will allow United States based companies, like BumpWorks, LLC, to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation 
13 

fuels, U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. 

By operating the UAS, companies such as BumpWorks, LLC, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to invest 

in research and development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

BumpWorks, LLC proposed operation of the UAS will not implicate any privacy issues. 

Specifically, UAS will be operated only in compliance with operating documents which requires 

property owner involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations 

 
14 

The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How 

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The 

Rule From Which BumpWorks, LLC Seeks Exemption. 

1. Reasons Why the UAS Meet The Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, BumpWorks, LLC operation of the UAS meet the conditions 

of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 103.7. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 

of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, BumpWorks, LLC submits that the UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the UAS; (b) the 

specific operating limitations. 
15 

a. Specifications of the UAS Demonstrate Its Safe Characteristics.

The UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight, speed, and operational capability. 

The UAS Global Positioning Modes Enable he UAS to Remain within a Defined 

Operational Area. 

The UAS may be operated in both manual and global positioning flight modes. 

The UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the UAS will assume that the Control Link is lost and the will return 

to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. 

b. Flight Operations the UAS Is Limited To The Line Of Sight Of the Pilot in Command 

With A Safety Observer. 

The BumpWorks, LLC staff will be the only persons to act as a pilot in command (PIC) of the 

UAS. Additionally, a safety observer will assist him at all times during flight time. 

c. Flights UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, BumpWorks, LLC proposes to commercially operate the UAS for the 

special purpose of conducting aerial video and photography and training over certain areas of 

United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UAS weighing less than 55 pounds 

maximum gross weight.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video, photography, training and flight testing. 

3. The UAS may not be flown at an indicated airspeed exceeding 55 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a special 

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses. 

6. All operations must utilize a safety observer (SO). The SO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC 

must be able to communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and cannot 
16 

transfer his or her designation for the duration of the flight. The PIC must ensure that the 

SO can perform the functions prescribed in the operating documents. 

7. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted 

to operate the camera or other instruments. 

8. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for extension 

or amendment to the grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. 

10. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. 

11. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

12. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

13. The operator must carry out its maintenance, inspections, requirements, in accordance 

with the OEM operating documents. 

14. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

15. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 
17 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

16. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 103.11. 

All operations must be conducted under visual meteorological conditions (VMC). If flight 

at night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized. 

17. The UA may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

18. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

19. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining.

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

23. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 
18 

24. The UA must remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, 

and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

 28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

BumpWorks, submits that the level of safety established will be maintained because no PIC will 

be allowed to operate the UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency, that the PIC is able to safely operate the UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Considering BumpWorks, LLC proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of Ultralight pilot aeronautical knowledge requirements to those 

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary 

to safely operate the UAS, BumpWorks, LLC submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for BumpWorks, LLC specific proposed flight operations. 
19 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

BumpWorks, LLC will not allow any PIC to operate the UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the UAS training and currency requirements, 

that the PIC is able to safely operate the UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

BumpWorks, LLC proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS 

to be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and 

model time may be included in the 10 hours of multi-rotor time and the 10 hours may be 

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption 

No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner’s proposed operations. The FAA also finds that prior documented 

flight experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During 

training, proficiency, and experience-building flights the PIC is required to operate the UA 

with appropriate distances in accordance with 14 C.F.R 103.21. 

Accordingly, BumpWorks, LLC will ensure safe operations by not allowing any PIC to operate 

the UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 
20 

The level of safety will be maintained using the altitude information of the UAS, the information 

will be provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with BumpWorks, LLC operation of the UAS within visual 

line of sight, at or below 500 feet AGL, will ensure a level of safety. The altitude information will 

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 

initiation point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 (103.21) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 103.11 as a result of (1) the technical specifications of the UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

The BumpWorks, LLC will ensure that it will safely operate the UAS during daylight hours in 

VFR conditions.

Here, as in Exemption No. 11109, safety will be ensured as the UAS provide audible and visual 

warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the UAS will descend and land 

automatically. 

Likewise, the exemption sought will not adversely affect safety because BumpWorks, LLC will 

use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating documents. 

 
21 

A Summary That Can Be Published in the Federal Register, stating: The Rules from Which 

BumpWorks, LLC Seeks Exemption: 

BumpWorks, LLC seeks exemption from the requirements of 14 C.F.R Sections 

103.1(a)&(b)

A Brief Description Of The Nature Of The Exemption The ALTEK MEDIA GROUP Seeks: 

This exemption will permit BumpWorks, LLC to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video, photography and 

training over certain areas of the United States.

Additional Information, Views, Or Arguments Available to Support the BumpWorks, LLC’s 

Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate 

safely in the NAS. As such, The BumpWorks, LLC’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard 

to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, BumpWorks, LLC will operate the UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

 
22 

CONCLUSION

As set forth herein, BumpWorks, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the UAS commercially, without an airworthiness certificate, for the limited purpose 

of conducting aerial video, photography and training over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing BumpWorks, LLC to safely, efficiently, and economically operate the UAS 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, BumpWorks, LLC respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

103.1(a) & (b), and permit BumpWorks, LLC to operate the UAS commercially for the purpose 

of conducting aerial video and photography over certain areas of the United States. 

Dated: November 1, 2015 

Respectfully submitted,

Brian Bailey 

Co-Owner 

BumpWorks, LLC

131 Cheeseman Rd. 

Portersville, PA 16051 

724-368-2070 

bmb@bumpworks.com