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 Baker, Managing Member of Flight 50 LLC for 

exemption from certain federal aviation regulations to operate 

unmanned aircraft systems 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 Modernization 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

1A - Specifically, F50 seeks to operate UAV for newsgathering, commercial 

production, 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 – Proposed Operations and Public Benefit Interests

2A - Flight 50 is a company that strives to provide safe, secure and 

technologically advanced aerial data collection services. 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 good. F50

seeks 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 themselves 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 valuable and usable data and 

information. Moreover, UAV’s can improve 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 

gathering 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 important data and other content. As 

discussed in more detail below, F50 is committed to the safe operation of its 

UAV, and will adhere to stringent operating conditions in conformity with 

past grants of exemption. These conditions ensure that F50 will operate 

safely in the national airspace, mitigate the risks of harming other aircraft or 

people or prope1ty on the ground, and present no threat to national security. 

Adhering to these parameters, F50 will be able to safely and effectively 
operate its UAV to the benefit of its business, crew, employees, 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. All 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 respects to previous petitions the 

FAA has granted, F50 requests that the FAA issue a summary grant of 

exemption 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 grants.

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 Parameters 

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 built UAV’s that enhance safety and adhere to FAA regulatory 

regulations and standards. All of which are below 55 pounds including 

payload.

2. The UAV will not be operated at a speed exceeding 87 knots (100 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 certificate, as well as an FAA airman 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 affects the safe operation of the UAV, the UAV will not be 

operated until the necessary maintenance 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 unpredicted obstacles or 

emergencies and will yield absolutely to all manned aviation activities. 

12. F50 will 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 of 

exemption. F50 respectfully requests that the FAA grant this petition to 

enhance F50’s ability to provide the benefit of services to public 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