Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 

C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.109;119.121; 91.151(a); 91.405(a); 91.407(a) (1); 91.409(a) 

(2); 91.417(a)&(b) 

To whom it may concern,

I, Jeff Bake, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures 

contained within 14 C.F.R. 11, to request that I, Jeff Bake, an owner and operator of small unmanned 

aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I may operate 

a small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the 

Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations & Policies. 

I. Contact Information:

Jeff Bake

2362 State Route 151 Mingo Junction, OH 43938 

Phone: 740-512-4533

Email: jeff@imadstudios.com

II. Information regarding the UAS Specifically, the UAS is: An ultra lightweight battery operated 4-motor 

rotorcraft in the form of a quadcopter that takes off and lands vertically, with the following equipment: 

• An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a groundbased transmitter/controller; 

• An integrated on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• An on-board telemetry system that delivers flight data from the on-board flight computer to the 

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site; 

• A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above;

The Ground Station Includes: 

• A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and 

who controls the UAS while in the air; 

• A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in 

flight; 

• A radio receiver receiving live video and flight data from the onboard camera and computer 

projects it all together onto a screen for the PIC to view during flight; 

• A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UAS 

while in flight.
III. Proposed Operations:

I, Jeff Bake, intend to use UASs in two areas. First, I seek an exemption to perform video filming 

and photographing by air for public and private use. Second, I will employ UAS’s to inspect land, 

residential commercial and industrial structures and property. Specifically, I will use UASs which are 

equipped with cameras and sensors, in order to engage in the following commercial:

(a) Video filming by air and photographing for public and private purposes, including: television, 

cinematography, advertising or promotions. Filming and Photography will only be conducted 

with permission and under contract with registered owners or with any local government 

authority and only when safe to do so.

(b) Video filming by air and photographing to support professional operations in engineering, land 

surveying and development, architecture, real estate and other related professional activities. 

Filming and Photography will only be conducted with permission and under contract with 

registered owners or with any local government authority and only when safe to do so. 

(c) Inspection by air of infrastructure such as bridges, highways, photovoltaic power stations, and 

pipelines. These inspections will only be done under contract and permission with any 

registered owners or with any local government authority and only when safe to do so. 

(d) Inspection by air of land and residential, commercial and industrial structures, only under 

contract and permission with any registered owners or with any local government authority and 

only when safe to do so. 

(e) Support provided to search and rescue operations and reconnaissance in cases of need, 

emergency or natural disasters only when government authorities have requested it by contract 

or donation and only when safe to do so.

IV. Relevant Statutory Authority:

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following 

considerations: 

• The UAS’s size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator. Additionally, the FAA 

Administrator has general authority to grant exemptions from the agency's safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the public 

interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) 

(permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716,et seq.). A party requesting an 
exemption must explain the reasons why the exemption: (1) would benefit the public as a 

whole, and (2) would not adversely affect safety (or how it would provide a level of safety at 

least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

V. These Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act:

The proposed operations in this Petition for Exemption qualify for expedited approval pursuant 

to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied. 

VI. Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability:

I, Jeff Bake, will employ the UAS for the operations specified in this Petition for exemption. 

• The UAS more than satisfies the weight limit of 55 pounds, with weights depending on the 

camera(s) employeed, all well under 10 pounds AUW.

• Flight speed will not exceed 25 miles per hour, and it will not be flown in controlled airspace or 

at an altitude that exceeds 400 feet AGL. 

• All flights will be flown in such a manner that they can be safely terminated with a reserve 

battery power of no less than 20% of the battery's maximum charge. 

• The UAS does not carry any flammable propellant or fuel. 

• The UAS has an integrated GPS system that calculates the UAS’s position and height and relays 

that information via a secure connection to the operator. 

• The UAS contains a failsafe mode if its connection to the remote control is lost, and this system 

permits the UAS to return to a predetermined location and land without injury or damage. 

VII. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual. DJI 

Naza M - V2 flight controller, operators manual contains all of the procedures and limitations necessary 

to successfully perform the operations specified in this Petition for Exemption. 

VIII. Public Interest:

The public interest will be served by granting Jeff Bake a Petition for Exemption. Congress has 

established a national policy that favors early integration of UASs into the NAS in controlled, safe 

working environments such as those proposed in this Petition. In addition, the public also has an interest 

in reducing the hazards associated with alternate methods of conducting similar operations. Currently 

operations are conducted using teams that physically climb onto structures using ladders, using low 

flying helicopters or aircraft, are extremely cost prohibitive or are simply not available by traditional 

means. By using UAS, exposure to physical hazards will be reduced by conducting the operation while 

remaining safely on the ground. Additionally, the intended uses of the UAS as outlined in this document 

have identifiable safety benefits that include reducing the danger and emissions associated with full size 

helicopters. UAS have no fuel to ignite or explode, no crew, add a greater degree of flexibility, 
supplement the current capabilities offered by manned aircraft, and public interest for a ground impact 

of a small lightweight UAS is further minimized from an ecological and safety standpoint.

IX. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 91.7(a) I, Jeff Bake, will 

ensure the UAS is in airworthy condition based on compliance with the operating documents prior to 

each flight. 

14 C.F.R. § 91.121 Relief is requested considering the limited altitude of proposed operations. 

B. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. § 61.113 (a), The FAA has previously declared that additional manned 

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

necessary for similarly proposed operations in previously issued exemptions to this regulation through 

Exemption Nos. 11062 and 11138. 

Pursuant to 14 C.F.R. § 61.113 (b), The stick and rudder controls of the typical aircraft one would 

be trained on to achieve a private pilots license are completely different than that of a small UAS. 

Additionally, the FAA does not require manned ultralight vehicle PICs to meet any aeronautical 

knowledge, age, or experience requirements or to have airman or medical certificates (as outlined in 14 

C.F.R. § 103). Ultralight vehicles can weigh more than 500 pounds than the UAS, can carry up to 5 

gallons of combustible fuel, and fly at speeds close to double that capable by the UAS. Due to these 

facts, I, Jeff Bake respectfully request that an 333 exception be granted and PIC license requirement be 

waived 

D. 14 C.F.R. 91.119 (c): Minimum Safe Altitudes. 

14 C.F.R. § 91.119 (c) I, Jeff Bake, will ensure that all persons and objects not essential to flight 

operations must remain 500 feet away from operations. In addition to visual monitoring of the area, a 

traffic cone and warning sign alerting persons in the area will be placed at the operation ground station. 

14 C.F.R. 91.151 (c): Fuel Requirements for Flight in VFR Conditions. 

14 C.F.R. 91.151 (c), I, Jeff Bake, will ensure that each individual flight will not begin unless there 

is enough power to fly to the first point of intended landing and land the UA with 30% battery power 

remaining. In addition, each individual flight will last no longer than 20 minutes, 5 minutes less than the 

manufacturer stated 25 minutes of flight time. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited 

Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft 
inspected as prescribed in subpart of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Jeff Bake’s, UAS. However, as a safety precaution I inspect my UAS per operating 

documents before and after each flight.

X. Conclusion:

This Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within visual line of sight and national security. Additionally, the Petition provides more than 

adequate justification for the grant of the requested exemptions to permit Jeff Bake to operate a UAS 

for the operations specified herein. Granting the exemption will benefit the public interest as a whole in 

several ways, including (1) significantly improving safety and reducing risk by alleviating human exposure 

to danger, and (2) improving the quality of services and decreasing operating costs compared with 

conventional flight operations. 

Thank you,

Jeff Bake