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 Regul ations (“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 qu adcopter 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, horizo ntal 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 whil e 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 vis ually 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 unde r 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 cont ract 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 owne rs 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 d onation 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 s afely 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") whe re 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 anexemption 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 Refo rm 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 Si ze, 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 contain s 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 contain s all of t he 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 establishe d 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 th e 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 ensu re 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 operation s 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). U ltralight 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 addi tion 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, a ircraft owners and operators to “have [the] aircraftinspected 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 c hapter. . . .” 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 nat ional 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