January 5, 2016

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590 **Re: Petition from**  **John Bak er, Managi**  **ng Member of Flight 50 LLC for e**  **xemption from certain federal a**  **viation regulations to operate**  **unmanned aircraft s ys**  **tems for commercial purposes pursuant to Section 333 of**  **the FAA Modernization and Reform Act .**  Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernizatio n and Reform Act ("FMRA") , John Baker/Flight 50 LLC (" F50 ") hereby petitions the Federal Aviation Administration ("FAA") for exemption from ; 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.101(e)(4), & (5); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133 (a); 14 C.F.R. 61.23(a) & (c); 14 C.F.R 91.7(a) 14 C.F.R. 91.9(b)(2); 14C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2}; 14 C.F.R. 91.417(a) & (b) ; and any other rules the FAA deems necessary, to enable F50 to operate unmanned aircraft systems (" UAV ") for aerial data collection. **Section 1**  **- Purpose**  1 A

- Specifically, F50 seeks to operate UAV for newsgathering, commercial produ ction, facilities inspection, videography , photography , mapping, land surveying and data collection using models DJI Phantom 3 , Inspire, 3DR Solo and custom built UAV’s that enhance safety and adhere to FAA regulatory regulations and standards

. 1B

- Because this petition is similar in all material respects to previously granted Section 333 petitions, F50 requests expedited approval pursuant to the FAA's summary grant process.**Section 2**

**– P**  **roposed Operations and Public Benefit Interests**

2A

- Flight 50 is a company that strives to provide safe, sec ure and technologically advanced aerial data collection service s . UAV’s provide the a cost
- effective way for F50 to achieve their business objective while providing a safe and valuable service for the public and private go od

. F50 seek s to use UAV’s to conduct aerial data collection that will serve a variety of functions, including those listed in Section 1A. Grant of this petition will enable F50 to better serve its clients across the country, as F50 will be able to obtain permission to operate its business more safely, efficiently, and effectively than ever before. 2B

- Permitting F50 to use UAV’s will result in enhanced services for both public and private individuals and companies who would otherwise not have access to these services or would risk injury to them selves or others by performing them

unpermitted

. Through our services and geographic reach we can provide a perspective that footage taken from the ground cannot, enhancing our clients’ ability to gain valuabl e and usable data and information. Moreover, UAV’s can im prove the accuracy and depth of information that F50 can convey to clients during operations. Authorization to operate UAV’s will enable F50 to provide information and imagery that is otherwise unavailable given existing barriers, such as those created by environmental hazards. Using an UAV , F50 can ensure the safety of its crewmembers while also gatheri ng crucial information for its clients . Grant of this petition will also lead to better industry standards and practices as well as public safety. 2C

- In addition to fostering significant public interest benefits, F50’s operations will carry minimal risk. Using an UAV for this aforementioned purposes in Section 1A, will both eliminate the dangers associated with conducting these activities on foot or in larger manned aircraft and enable F50 to efficiently and quickly deliver im p ortant data and other content. As discussed in more detail be low, F50 is committed to the safe operation of its UAV , and will adhere to stringent operating conditions in c onformity with past grants of exemption. These conditions ensure that F50 will operate safely in the national airspace, mi tigate the risks of harming other aircraft or people or prope1ty on the groun d, and present no threat to national security. Adhering to these parameters, F50 will be able to safely and effectivelyoperate its UAV to the benefit of its business, crew, em ployees, bystanders and the general public. **Section 3**

**– The UAV/S**  3A

- Flight 50 requests an exemption to operate the DJI Phantom 3 , Inspire, 3DR Solo and custom built UAV’s that enhance safety and adhere to FAA regulatory regulations and standards . A ll of which are below 55 pounds including payload. Through the Section 333 exemption process, the FAA has authorized use of all UAV ’s for which exemption is requested herein

. **Section 4**

**– Request for Summary Grant**  Because this petition is similar in material resp ects to previous petitions the FAA has granted, F50 requests that the FAA issue a summary grant of exem ption pursuant to the agency's expedited summary grant process. Specifically, the public interest and safety benefits F50’s operations will achieve are materially similar to those recognized in Grants of Exemption to Nos. 14068 Imagination Aerials (see Docket No. FAA

- 2015

- 3679 ), 14080 to Birds Eye Aerial Video & Photography (see Docket No. FAA

- 2015

- 4529). F50 will adhere to a series of operating parameters that will offer the same or better level of safety as the conditions the FAA currently requires in its summary grant s. **Section 3 -**  **APPLICANT INFORMATION** The name and contact information of the applicant is : John Baker, Managing Member , Flight 50 LLC , 419 Bay Berry Place Encinitas, CA 92024 Regulations from which exemption is requested: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.101(e)(4), & (5); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133 (a); 14 C.F.R. 61.23(a) & (c); 14 C.F.R 91.7(a) 14 C.F.R. 91.9(b)(2); 14C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2}; 14 C.F.R. 91.417(a) & (b) ;**Section 5 -**  **Operating Par ameters** 

Flight 50 will adhere to the following operating parameters when operating UAV pursuant to a grant of the requested exemption: 1. Operations will be conducted using DJI Phantom 3 , Inspire, 3DR Solo and custom

bui lt UAV’s that enhance safety and adhere to FAA regulatory regulations and standards . A ll of which are below 55 pounds including payload. 2. The UAV will not be operated at a speed exceeding 87 k nots (1 00 miles per hour), at an altitude greater than 400 feet above ground level, or, when visibility is less than three ( 3 ) statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All operations will be conducted during the day under visual meteorological conditions. 3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization ("COA''). 4. All operations will use a pilot

- in

- command ("PIC") and a visual observer ("VO"), and the UAV will remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS capability and the ability to communicate verbally with the VO at all times. 5. The PIC will be required to hold and/or pursue certification and training classes in UAV flight or/and airline transport , commercial, private, recreational, or sport pilot ce rtificate, as well as an FAA air man medical certificate or a valid U.S. driver's license. 6. F50 will ensure prior to operation that the PIC has demonstrated the ability to safely operate the UAV in a manner consistent with how the UAV will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structure
. 7. UAV operating documents, manuals, instructions and replacement parts will be accessible during UAV operations and made available to the Administrator upon request.8. Prior to each flight, the PIC will conduct a pre

- flight inspection and

determine the UAV is in a condition for safe flight. If the inspection reveals a condition that affec ts the safe operation of the UAV, the UAV will not be operated until the necessary maintenanc e has been performed and the UAV is found to be in a condition for safe flight. 9. Any UAV that has undergone maintenance or alterations that affect the UAV operation or flight characteristics will undergo a functional test flight prior to conducting further operations under this exemption. 10. F50 will follow the UAV manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety bulletins, for the aircraft and aircraft components. 11. The PIC will abort the flight in the event of unpred icted obstacles or emergencies and will yield absolutely to all manned aviation activities. 12. F50 w ill register and mark its UAV. **Section 6 -**  **Conclusion** As demonstrated above, the UAV operations Flight 50 LLC has proposed in this petition for exemption will garner significant public benefits while presenting minimal safety risks to operator and public. The F50 petition satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous petitions the FAA has granted, meriting a summary grant o f exem ption. F50 respectfully requests that the FAA grant this pe tition to enhance F50’s ability to provide the benefit of services to publ ic and private individuals and businesses

. Please do not hesitate to contact Flight 50 and their Managing Director John Baker at 917

- 804

- 9635 or johnbaker79@gmail.com with any questions about this petition filing. Sincerely,
John Baker