1 November, 01 2015

Attn: U. S. Department of Transpor tation 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 R EQUIREMENTS OF TITLE 14 OF THE C ODE 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 us ed for manned operation in the air by a single occupant; (b) Is used or intended to be us ed for recreation or sport purp oses only;
CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS
PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATI ON 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.com2 TABLE OF CONTENTS

Page

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

SUMMARY........................................................

............................................................... ....4

INTRODUCTION AND INTERES TS 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 BU MPWORKS, 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 TH E

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 MEDI A GROUP’S REQUEST.......................... ........................21

CONCLUSION.....................................................

............................................................... .223 GLOSSARY OF ABBREVIATIONS

AGL A bove 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 Aviati on Administration

FAR Federal Aviati on Regulation

GCS Gr ound Control Station

GPS Global Positioni ng System
LOL Loss of Li nk NAS National Airsp ace System
NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization a nd Reform Act of 2012 (FMRA) SO Safety Observer SOP Standard Operati ng Procedures

UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules

VLOS Visual Line of Site VMC Visual Meteorological C onditions

VTOL Vertical Takeoff a nd Landing4 SUMMARY

BumpWorks, LLC seeks exemption from the requirements of 14 C.F. R §§ §103.1 Applicability. (a) is used or intended to be us ed for manned operation in the air by a single occupant; (b) Is used or intended to be us ed for recreation or sport purp oses 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) fo r the commercial purpose of co nducting aerial video and photography of construction sites, residential and commercial r eal 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 (whi ch include private sector businesses and non-profits, along with local state and federal agencies) with expertise, knowledge and training using advanced tec hnologies and solutions. The obj ective of BumpWorks, LLC and our Unmanned Aircraft System aeria l operations is to provide a more affordable, high-quality production system for a variety of governmental, commercial, pu blic, and residential uses, specifically targeting

• UAS construction, repair and fli ght 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 com pensation 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 exce ed a maximum gross weight of 55lb. A maximum airspeed of 55 knots and a maximum flying heigh t of 500'.

The UAS that will be operated by B umpWorks, LLC will be flown a ccording to:5 BASIS FOR PETITION

Petitioner, BumpWorks, LLC, pursu ant to the provisions of the F ederal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Mode rnization and Reform Act of 201 2 (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 d eviation from this part exce pt under a written waiver issued by

the Administrator.

In consideration of the speed, weight, size, and limited operat ing area associated with the unmanned aircraft and its operati on, BumpWorks, LLC operation o f UAS aircraft meets certain

conditions of FAR 103

Sec. 103.1 Applicability.

This part prescribes rules gove rning the operation of ultraligh t vehicles in the United States. For the purposes of this part, an ultr alight vehicle is a vehicle t hat:

(c) Does not have any U.S. or f oreign airworthiness certifi cate; and (d) If unpowered, wei ghs less than 155 pounds; or (e) If powered: (1) Weighs less than 254 pounds e mpty weight, excluding floats and safety devices which are intended for deployment in a potentially catastrophic situa tion; (2) Has a fuel capacity not exceeding 5 U.S. gallons; (3) Is not capable of more th an 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 ultrali ght vehicle under this part shall, upon request, allow the Administrator, or his designee, t o inspect the vehicle to deter mine the applicability of this part. (b) The pilot or operator of an ultralight vehicle must, upon r equest of the Administrator, furnish satisfactory evidence th at the vehicle is subject only to the provisions of this part.

Sec. 103.7 Certification and registration.

(a) Notwithstanding any other se ction pertaining to certificati on of aircraft or their parts or equipment, ultralight vehicles and their component parts and eq uipment are not required to
meet the airworthiness certifi cation standards specified for ai rcraft or to have certificates of
airworthiness. (b) Notwithstanding any other se ction pertaining to airman cert ification, operato rs of ultralight vehicles are not required t o meet any aeronautical knowledge, a ge, or experience requirements to operate those vehicles or t o have airman or medical certific ates.6 (c) Notwithstanding any other se ction pertaining to registratio n and marking of aircraft, ultralight vehicles are not requ ired to be registered or to bea r markings of any type.

Subpart B--Operating Rules

Sec. 103.9 Hazardous operations.

(a) No person may operate any ultralight vehicle in a manner th at creates a hazard to other persons or property. (b) No person may allow an objec t to be dropped from an ultrali ght vehicle if such action
creates a hazard to other persons or property.

Sec. 103.11 Daylight operations.

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

sunset. (b) Notwithstanding paragraph (a) of this section, ultralight v ehicles 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 c ivil twilight as defined in th e Air Almanac, if: (1) The vehicle is equipped wit h an operating anti-collision li ght visible for at least 3 statute miles; and (2) All operations are conducted in uncontrolled airspace.

Sec. 103.13 Operation near aircr aft; right-of-way rules.

(a) Each person operating an ultral ight 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 ultra light vehicle in a manner tha t creates a collision hazard with respect to any aircraft. (c) Powered ultralights sha ll yield the right-of-way to unp owered ultralights.

Sec. 103.15 Operations over congested areas.

No person may operate an ultrali ght 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, Cla ss B, Class C, or Class D airspace or within the lateral boundaries of the surface area o f 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, r evised 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 ultralig ht vehicle within an airpo rt traffic area, control zone, airport radar service area, terminal c ontrol area, or positive control area unless that person has prior
authorization from the air traffi c control facility having juri sdiction 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 t he Federal Aviation Regulation s (FAR) to adopt certain recommendations of the National Airspace Review (NAR) concernin g changes to regulations and procedures in regard to airsp ace classifications. These cha nges are intended to: (1) Simplify airspace designations; (2) achieve international commo nality of airspace designations; (3) increase standardization of e quipment requirements for oper ations in various classifications of airspace; (4) describe appropriate pilot certificate require ments, visual flight rules (VFR) visibility and distance from cl oud rules, and air traffic servi ces offered in each class of airspace; and (5) satisfy the r esponsibilities of the United St ates as a member of the International Civil Aviation Org anization (ICAO). The final rul e also amends the requirement for minimum distance from clouds in certain airspace areas and the requirements for
communications with air traffic c ontrol (ATC) in certain airspa ce areas; eliminates airport radar service areas (ARSAs), cont rol zones, and terminal contro l areas (TCAs) as airspace classifications; and eliminates t he term "airport traffic area. " The FAA believes simplified airspace classifications will reduce existing airspace complexi ty and thereby enhance safety.

EFFECTIVE DATE: These regulati ons 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 numbe r 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 i ncorporation by reference of F AA 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 incorporatio n by reference of FAA Order 7400.9 in Sec. 71.1 (amendatory instruction number 24) is appro ved by the Director of the Federal Register as of September 16, 1993 through September 15, 1994.

Sec. 103.19 Operations in prohibite d or restricted areas.

No person may operate an ultralight vehicle in prohibited or re stricted areas unless that person has permission from the using or controlling agency, as appropr iate.

Sec. 103.20 Flight restrictions in t he proximity of certain are as 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 ultrali ght vehicle except by visual reference with the surface.

Sec. 103.23 Flight visibility and c loud clearance requirement s.

No person may operate an ultralight vehicle when the flight vis ibility or distance from clouds is
less than that in the table f ound below. All operations in Clas s A, Class B, Class C, and Class D airspace or Class E airspace desi gnated for an airport must rec eive 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 mile9 EFFECTIVE DATE NOTE: Amdt. 103-4, 56 FR 65662, Dec. 17, 1991, r evised 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 c loud clearance requirement s.

No person may operate an ultralight vehicle when the flight vis ibility or distance from clouds
is less than that in the fol lowing 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 t he Federal Aviation Regulation s (FAR) to adopt certain recommendations of the National Airspace Review (NAR) concernin g changes to regulations and procedures in regard to airsp ace classifications. These cha nges are intended to: (1) Simplify airspace designations; (2) achie ve international commonality of airspace designations; (3) increase standardization of equi pment requirements for operatio ns in various cla ssifications of airspace; (4) describe appropria te pilot certificate requiremen ts, visual flight rules (VFR) visibility and distance from cl oud rules, and air traffic servi ces offered in each class of airspace; and (5) satisfy the res ponsibilities of the United States as a member of the International Civil10 Aviation Organization (ICAO). The f inal rule also amends the re quirement for minimum distance from clouds in certain airspace areas and the requirem ents for communications with air traffic control (ATC) in certa in airspace areas; eliminates air port radar service areas (ARSAs), control zones, and terminal control areas (TCAs) as airspace cl assifications; and eliminates the term "airport traffic area." T he FAA believes simplified airspa ce classifications will reduce existing airspace complexity and thereby enhance safety.

EFFECTIVE DATE: These regulations become effective Septembe r 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 instruc tion number 20, Sec. 71.1, is effective as of December 17, 1991 through September 15, 1993, a nd that Secs. 71.11 and 71.19 become effective October 15, 1992. The incorporation by referen ce of FAA Order 7400.7 in Sec. 71.1 (amendatory instruction numbe r 20) is approved by the Dire ctor of the Federal Register as of December 17, 1991, through September 15, 1993. The incorpora tion by reference of FAA Order 7400.9 in Sec. 71.1 (amendato ry instruction number 24) is approved by the Dir ector of the Federal Register as of September 16, 1993 through September 15, 1994.

BumpWorks, LLC submits that the requested relief from certain r equirements is proper since an equivalent level of safety will be ensured. BumpWorks, LLC will use experienced personnel or technicians to perform maintena nce, 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 t he following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Pe titioner 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 Reas on 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 Sec tion 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 oper ations for compensation or

hire.

As set forth more fully below, BumpWorks, LLC submits that a le vel of safety will be maintained because no PIC will be allowed to operate the UAS unless that P IC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to sa fely operate either UAS in a manner consistent with the operations specifications as described in t his exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distanc es from people, vessels, vehicles

and structures.

Further, BumpWorks, LLC submits that all flights of the UAS, co nducted 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 propert y 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 eco nomical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By re ducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing th e use of a UAS would reduce the

amount of manned aircraft in the NAS, reduce noise and air poll ution, as well as inc rease the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operatin g in the NAS, congestion around airports caused by arriving and departing aircraft will be redu ced. UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft co nducting aerial video and photography missions would result in fewer aircraft that must b e handled by air traffic control during the ground, takeoff, depart ure, arrival, and landing pha ses of flight operations.

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

Conducting aerial acquisitions with the UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing th e levels of air and noise poll ution generated during traditional aerial video and still photogra phy flight operations. By using battery power and electric motors, the UAS produce no air pollution, and is the most viable enviro nmentally conscious alternative to the cabin class, six cylinder in ternal combustion engine aircra ft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallon s per hour of leaded aviation fuel. The UAS, while reducing the carbon footprint of aerial ac quisitions, 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 aer ial acquisitions, the substantia l risk to life and pr operty in the air and on the ground, which is usua lly associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside f rom the lack of flight crew members located onboard the aircraft, UAS (weighing less than 55 pounds at their maximum gross weight has less physical poten tial for collateral damage to life and p roperty 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 BumpWo rks, LLC are also an economical alternative to using manned airc raft to conduct similar aerial operations. As such, operation of the UAS will allow United States based companies, like BumpWorks, L LC, to remain competitive and contribute to growth of the U.S. economy. Specifically, wit h the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory acti ons phasing out leaded aviation13 fuels, U.S. owned and operated companies must adopt new and alt ernative technology in order to remain competitive. Operating the battery powered UAS is one su ch technology that not only allows companies greater operational flexibility compared to ma nned aircraft, but provides such flexibility without the high operati onal cost of a traditional manned aircraft.

By operating the UAS, companies such as BumpWorks, LLC, can rem ain competitive and profitable, and therefore, provide greater job stability to emp loyees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved f inancial 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 reven ues; 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 oper ating documents which requires property owner involvement as well as local law enforcement not ification, and in accordance with the Federal Aviation Regulations14 The Reasons Why Granting The Exemption Would Not Adversely Affe ct Safety, Or How The Exemption Would Provide A Lev el 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 Moderniza tion and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operat ing area associated with the unmanned aircraft and its operati on, BumpWorks, LLC operation o f the UAS meet the conditions of FMRA Section 333, and will not require an airworthiness cert ificate in accordance with 14

C.F.R. Part 103.7.

Section 333 provides authority for a UAS to operate without air worthiness certification and sets forth requirements for consider ing whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specif ically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other re quirement of this su btitle, and not later than 180 days after the date of enactment of this Act, th e Secretary of Transportation shall determine if certain unmanned aircraft systems may operate sa fely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance require d by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Syst ems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft syst ems, if any, as a re sult 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 th e 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 syst ems 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 requi rements 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 chara cteristics of the UAS; (b) the specific operating limitations.15 a. Specifications of the UAS Demon strate Its Safe Characteristi cs.

The UAS does not create a hazar d to users of the NAS or the pub lic, or otherwise pose a threat to national security considering its size, weight, speed, and oper ational capability.

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

The UAS may be operated in both ma nual and global positioning f light modes.

The UAS Are Designed For Automatic Return To Home Point Or Hove r In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the UAS will assume that the Con trol Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will de scend to the takeoff position and

shutdown.

b. Flight Operations the UAS Is Li mited 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 p ilot in command (PIC) of the UAS. Additionally, a safety observer will assist him at all tim es during flight time.

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

In seeking this exemption, BumpW orks, LLC proposes to commercia lly operate the UAS for the special purpose of conducting aer ial video and photography and training over certain areas of United States, pursuant to the f ollowing specific operating lim itations.

1. Operations authorized by this grant of exemption will be lim ited to the following aircraft described in the operating docum ents, rotorcraft UAS weighing l ess than 55 pounds maximum gross weight.

2. UAS operations under this exemption will be limited to condu cting operations for the purpose of aerial video, photogra phy, training and flight testi ng.

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 f eet above ground level (AGL), as indicated by the procedures specified in the operatin g 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 m ay be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capab ility. The SO and PIC must be able to communicate verbally at all times. Electronic m essaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot16 transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions pr escribed in the operating docume nts.

7. The SO must not perform any other duties beyond assisting th e PIC with seeing and avoiding other air traffic and other ground based obstacles/obs tructions and is not permitted to operate the camera or other instruments.

8. The operating documents and the grant of exemption must be a ccessible during UAS operations and made available to the Administrator upon request . If a discrepancy exists between the conditions and limitations contained in the grant o f 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 documen ts. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated a nd revised documents to the Admi nistrator upon request. The operator must also presen t updated and revised documents if it petitions for extension or amendment to the grant of exe mption. If the operator determi nes 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 b e 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 m aintenance has been performed and the UAS is found to be in a condition for safe fl ight. The Ground Control

Station must be included i n 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 critica l component, must undergo a functional test flight.

11. The pre-flight inspection mu st account for all potential di screpancies, e.g. inoperable components, items, or equipment, not already covered in the rel evant sections of the operating documents.

12. The operator must follow the UAS manufacturer’s aircraft/co mponent, maintenance, overhaul, replacement, inspection, and life limit requirements.

13. The operator must carry out its maintenance, inspections, r equirements, 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 P IC meets the operator’s qualification criteria and demonstrates the ability to safely o perate the UAS in a manner17 consistent with how the UAS will be operated under the exemptio n, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. Flight s for the purposes of training t he operator’s PICs are permitted under the terms of the exemption. However, training o perations may only be conducted during dedicated train ing sessions. During training, proficiency, and experience-building flights, all persons not essential for flig ht operations are considered nonparticipants, and the PIC must operate the UA with appropria te distance from nonparticipants in accord ance with 14 C.F.R. § 91.119.

16. UAS operations may not be conducted during night, as define d in 14 C.F.R. § 103.11. All operations must be conducted under visual meteorological co nditions (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 sp ecial visual flight rules ( SVFR) are not authorized.

17. The UA may not operate within 5 nautical miles of an airpor t reference point as denoted on a current FAA-published aeronautical chart unless a letter o f agreement with that airport’s management is obtained, and the operation is conducte d in accordance with a NOTAM as required by the operator’s COA. The letter of agreemen t with the airport management must be made availa ble to the Administrator upon req uest.

18. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or whe n visibility is less than 3 sta tute 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 o bstacles or emergencies in accordance with the operating documents.

21. The PIC is prohibited from b eginning a flight unless (consi dering wind and forecast weather conditions) there is enough power to fly at normal crui sing speed to the intended landing point and land the UA w ith 25% battery power remaining.

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) p rior to conducting any operation s 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 C ommission (FCC) or other appropriate government ove rsight 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 t he PIC from any moving devi ce 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 oper ator must ensure that nonparticipating persons remain under such protection. If a sit uation arises where nonparticipating persons leave su ch protection and are within 5 00 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structure s where the owner/controller of such vessels, vehicles or structures has gr anted permission and the PIC has made a safety assessment of the risk of operating c loser to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essen tial persons do not present an undue hazard to those persons.

27. All operations shall be condu cted over private or controlle d-access property with permission from the land owner/controller or authorized represe ntative. Permission from

land owner/controller or authori zed representative will be obta ined for each flight to be

conducted.

28. Any incident, accident, or f light operation that transgres ses 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. Acci dents must be reported to the National Transportation Safety Board (NTSB) per instruct ions 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 mainta ining 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 aeronautic al 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 addi tional manned airmanship experience of a commercially cer tificated pilot would not corre late to the airmanship skills necessary for BumpWorks, LLC s pecific proposed flight operation s.19 The FAA has previously granted relief from Section 61.113(a) an d (b) specific to UAS, in circumstances similar, in all material respects, to those prese nted 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 cons istent with this exemption, including evasive and emergency maneuvers and maintaining appropriate dis tances 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 regu lations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducti ng operations for the purpose of motion picture filmi ng (or similar operations), the PIC must have accumulated and logged, in a manner consis tent with 14 CFR 61.51(b), 25 hou rs of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pi lot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must als o have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same m ake and model of UAS to be used for operations under the exemption. For clarificatio n, 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 addit ion to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the precedin g 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour req uirements 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 find s that prior documented flight experience that was obtai ned in compliance with applicab le regulations would satisfy this requirement. Training, proficiency, and experience-buildin g flights can also be conducted under the grant of exemption to accomplish the requir ed flight time. During training, proficiency, and experi ence-building flights the PIC is required to operate the UA with appropriate distances i n accordance with 14 C.F.R 103.21.

Accordingly, BumpWorks, LLC wil l ensure safe operations by not allowing any PIC to operate the UAS unless that PIC has demonstrated, by meeting minimum fl ight-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 mainta ining appropriate distances from people, vessels, vehicles and structures.20 The level of safety will be maintained using the altitude infor mation of the UAS, the information will be provided to the PIC via GPS equipment and a radio commu nications 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 operati on 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. P rior to each flight, a zero altitude initiation point is automatica lly established by the UAS at gro und 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 prese nted 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 s afety established by 14 C.F.R.

Section 103.11 as a res ult of (1) the techni cal specifications of the UAS; (2) the limitations on the proposed flight operations; and ( 3) the location of the propose d 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 bat tery voltage, the first warning occurring at approximately 33% r emaining battery power, and aga in at approximately 10% remaining battery power. At the c ritically low battery level, t he 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, statin g: The Rules from Which BumpWorks, LLC Seeks Exemption:

BumpWorks, LLC seeks exemption from th e requirements of 14 C.F.R Sections 103.1(a)&(b)

A Brief Description Of The Nature Of The Exemption The ALTEK ME DIA 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 Suppor t the BumpWorks, LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Ref orm Act of 2012 (FMRA) Section 333, which directs the Se cretary of Transportation to d etermine if certain UAS may operate safely in the NAS. As such, The BumpWorks, LLC’s request for ex emption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Par t 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering wh ether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat t o national security; and further, provides the authority for suc h UAS to operate without airworth iness certification.

As discussed in detail above, Bum pWorks, LLC will operate the U AS safely in the NAS, without creating a hazard to users of th e NAS, or the public, or otherw ise 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 Modernizati on and Reform Act of 2012 (FM RA), which will permit safe operation of the UAS commercially , without an airworthiness cer tificate, for the limited purpose of conducting aerial video, photogr aphy and training over certa in areas of the United States. By granting this Petition, the FAA Administrator will be fulfillin g 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 economicall y operate the UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the F AA
Modernization and Reform Act o f 2012, Section 333, BumpWorks, L LC 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 co mmercially for the purpose of conducting aerial video and phot ography over certain areas o f 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