Comment Information: ===============

General Comment: Bolin & Associates, LLC Request for Exemption/ rulemaking- under 

Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations
Brad R. Bolin

Bolin & Associates, LLC

PO Box 662

Baxter Springs, KS 66713

620-762-6282

info@bolintransportation.com

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam:

I am submitting this petition on my own, on the behalf of my company Bolin & 

Associates, LLC, (petitioner) without the assistance of legal counsel.

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

Act), and 14 C.F.R. Part 11, the petitioner which is owned and operated by Brad R. 

Bolin, a sole proprietor LLC, operating in the State of Kansas.

Bolin & Associates, LLC, wishes to apply for an exemption from the Federal Aviation 

Regulations (FAR) listed below to allow operation of our sUAS commercially in airspace 

regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333.

The requested exemption would permit the petitioner to pursue its commercial interests 

in providing services to companies interested in aerial data that can only be captured by 

using newly developed sUAS in the following areas:

 Industrial Applications

 Architecture

 Wildlife and Land Management Applications

 Commercial and Residential Applications

 UAV and UAS Flight, Payload and Maintenance Training

 Pipeline and Electrical Transmission Line

 Research and Development

 Surveying and 3D aerial mapping 
 Agriculture crop assessment and growth patterns 

 Golf course management 

 Insurance company claim assessment 

 Construction site and ecological impact assessment 

Additional necessary uses for the public good may include:

• Disaster Area Surveillance and Analysis

• Search and rescue as directed by local and State Authorities

The petitioner asserts that all sUAS flights that will occur over private or controlled 

access property will do so with the property owner’s consent and knowledge and that 

only people who have consented or otherwise have agreed to be in the area where 

flight activity is taking place. Petitioner’s PIC has had extensive flight time logged with 

sUAS devices. Our observers will attend ground school and will be taught the rules and 

regulations relevant to operating private aircraft under Visual Flight Rules (VFR) over 

civilian population areas as described and set forth in the Aeronautical Information 

Manual.

This petition’s content is similar to the exemption granted to Falcon Sky Cam 

Regulatory Docket No. FAA-2014-0884 in that petitioner will engage in aerial 

photography and videography of land, buildings, and insurance claims, by using remote 

controlled sUAS to observe and verify the condition of fields, crops, ecological impact, 

and financial losses due to destruction by fire and other natural disasters.

Petitioner has a sUAS equipped with cameras for aerial photography including video 

and still pictures and special lens adaptations to make them very accurate in the 3 D 

mapping activity. We have the ability to produce high-resolution photography of remote 

locations that would be difficult or dangerous to access otherwise. This will enhance and 

benefit our insurance and other aforementioned work activities.

Bolin & Associates, LLC exemption request would permit us to operate lightweight, 

unmanned (remotely controlled in line of sight) sUAS’s in tightly controlled and limited 

airspace. Predetermined, specifically marked areas of operation as well as Global 

Positioning Satellite (GPS) navigation maps which incorporate restricted, no fly zones 

and control zones of airports, will allow Bolin & Associates, LLC to operate within 

current safety parameters as well as the new ones being implemented.

From which the exemption is requested:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.205(b)
14 C.F.R. 91.215

14 C.F.R. (91.401-91.417)

Unmanned Aircraft System

sUASs are an ideal photographic platform compared to traditional aircraft because 

these smaller devices are less expensive, they produce less noise, and are more 

beneficial to the environment. The issue of safety is key sUAS are less likely to cause 

injury to the public and or property.

Bolin & Associate, LLC is petitioning for an exemption to enable our agency to operate 

the DJI Spreading wings S900, equipped with the DJI Advanced Stabilization Controller 

for Multi-Rotor Platforms (S900/S1000+)/ with the safety auto return home feature and 

the gimbal a DJI Zenmuse Z-15, a 3 axis gimbal and camera system.

This sUAS has a built in capacity to limit the height it flies above the ground, to limit the 

radius of the distance it flies from the operator and to exclude it for Class B, C, and D 

airspace including No Fly Restricted Zones. The DJI Spreading Wings S900 also has 

the following safety features Enhanced Failsafe Features, Including Auto Return-toHome, Single-Motor Failure Protection and Two-Tier Low Voltage Protection. These 

safety features allow for the sUAS to safely return to its originating point should the 

signal be lost. 

The above specifications meet with the Model Aircraft Operating Standards as set 

below:

 The petitioner will only operate its sUAS in line of sight of a pilot/observer and will 

operate at sites that are sufficient distance from populated areas within the sterile 

area described in the FOPM. Such operations will insure that the sUAS will not 

create a hazard to users of the national airspace or the public.

 When flying sUAS within 3 miles of an airport, airport operators will be notified and 

the operator will give the right of way to avoid flying in the proximity of full scale 

aircraft.

 Maximum flight time for each operational flight will be 25 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 

30-minute limit. 

 The sUAS will be programmed so it will not be operated at an altitude of no more 

than 400 feet AGL, and not more than 200 feet above a fixed platform from which 

operations are conducted.

 The minimum crew for each operation will consist of the sUAS pilot and the 

observer.

 The sUAS will weigh less than 55 pounds including its payload of camera and 

gimbal.
 The sUAS will fly no more than 50 knots and can hover plus move horizontally and 

vertically.

 The small size of the sUAS, and the restricted airspace within which it will operate, 

our sUAS operations will comply with the rules intended by the Reform Act safety 

requirements.

 Maintenance of sUAS will be conducted as per manufacturer’s schedule 

As part of this request for exemption, Bolin & Associates, LLC ensures that all persons 

involved in aerial operations will have completed sUAS education and training including 

all applicable regulations and guidance documents.

I respectfully request exemption under Section 333 to enable Bolin & Associates, LLC to 

safely operate commercially sUAS in the aforementioned purposes.

Sincerely yours,

Brad R. Bolin

Bolin & Associates

PO Box 662

Baxter Springs, KS 66713

620-762-6282

info@bolintransportation.com

Enclosure: PIC Experience and sUAS Specifications
Enclosure

Current Pilot in Command Experience and Credentials

Terence Hulet

Maned Aircraft Operations

Graduated Oklahoma State University in May of 2008 with a Bachelor of Science 

Professional Pilot.

Current Ratings include Commercial Certificate SEL and MEL with Instrument, Certified 

Flight Instructor, Certified Instrument Instructor and Multi-Engine Instructor.

Total: 2035

Single Engine Land: 1720

Multi-Engine Land: 315

Dual Given: 1913

Prior UAV Operations and Experience

Air Vehicle Pilot on the RQ23A Tigershark UAV platform with 1200 hours logged on 

aerial reconnaissance missions for the Department of the Navy NAVAIR 4.1

Total UAV: 1237

UAV SPECS

Spreading Wings S900 Hexacopter UAV

FRAME

Diagonal Wheelbase 900mm

Frame Arm Length 358mm

Frame Arm Weight

(Including Motor, ESC, Propeller) 316g

Center Frame Diameter 272mm

Center Frame Weight (with Landing Gear Mounting Base, Servos) 1185g

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight (with Radiators) 35g
FLIGHT PARAMETERS

Takeoff Weight 4.7Kg ~ 8.2Kg

Total Weight 3.3Kg

Power Battery LiPo (6S、10000mAh~15000mAh、15C(Min))

Max Power Consumption 3000W

Hover Power Consumption 1000W (@6.8Kg Takeoff Weight)

Hover Time 18min (@12000mAh& 6.8Kg Takeoff Weight)

Working Environment Temperature -10 °C ~ +40 °C

MOTOR

Stator Size 41×14mm

KV 400rpm/V

Max Power 500W

Weight (with Cooling Fan) 158g

FOLDABLE PROPELLER (1552/1552R)

MATERIAL

High strength performance engineered plastics

Size 15×5.2inch

Weight 13g

GAIN VALUE SETTINGS

For A2 flight controller Basic: Roll 110%, Pitch 110%, Yaw 120%

Attitude: Roll 220%, Pitch 220%, Vertical 120%