Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

1 Jonathan Bain Bain Property Inspection, Inc.

611 Kastle Road Lexington, KY 40502 (859) 268-0262 bainpropertyinspection@gmail.com Kentucky Licensed Home Inspector No. 2058

Federal Aviation Administration Small UAS Certifica te of Registration No. FA33MFLPHW

January 2nd, 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Ac t of the Federal Aviation Regulations from 14 C. F. R. 45.23(b); 14 C.F.R. § § 61.23(a) a nd (c); 61.101(e)(4) and (5); 61.315(a); C.F.R. Par t 21; C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91. 103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)& (b)

Dear Sir or Madam:

I, Jonathan Bain, have been the owner of Bain Prope rty Inspection, Inc. since 1998, and I have been licensed to perform home inspections in the State o f Kentucky since 2003, when licensing became required by law. My company performs inspections of houses and buildings for both potential buyers, and current owners. I am writing pursuant t o the FAA Modernization and Reform Act of 2012, and the procedures contained within 14 C.F.R. 11, to request that I, Jonathan Bain, an owner of small, unmanned aircraft, be exempted from the F ederal Aviation Regulations ("FARs") listed below so that I, Jonathan Bain, may operate my ligh tweight, unmanned-aircraft-systems ("UASs") commercially in airspace regulated by the Federal A viation Administration ("FAA"). As described herein I, Jonathan Bain, am a licensed home inspect or within the state of Kentucky. My license number is HI-2058. I am experienced in flying hobby helicopters for recreational purposes. I currently own a DJI Phantom-3 Professional quadcopt er, as well as a DJI Phantom 2 Vision, and a 3DR Solo. I intend to use the quadcopters to photog raph and videograph roofs, and other features of buildings and houses, to provide my clients with enhanced knowledge about the conditions of the buildings and houses, typically prior to purchase, that could not be provided otherwise, following exemption and approval by the FAA. Depending upon s izes and configurations, roofs can be exceedingly expensive to repair or replace. I am se eking an FAA Exemption so that I can provide information about roofs, and other high portions of houses and buildings, that could otherwise only be observed utilizing tall ladders that would place myself in danger, or by utilizing a manned aircraf t, which would prove cost prohibitive. Should the FAA grant my exemption, I could provide better service to my clients, and potentially save them th ousands, or even tens of thousands, of dollars by providing a greater degree of information about the conditions of houses and buildings they either own, or plan to purchase.Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

2 I have flown small, radio-controlled helicopters fo r approximately five years without any adverse incidents. I am committed to safety and the well-be ing of the public on each and every flight. My, Jonathan Bain’s, exemption request would permit the operation of unmanned, but piloted by a remote-control receiver, UAS(s) in tightly controll ed and limited airspace. These flights would occur predominantly in areas away from the general public , airports, heliports, and vehicular traffic, to provide photos of roofs and other aspects of houses and buildings that otherwise could not be observed, for inspection clients of mine. At presen t, similar lightweight, remote-controlled UASs are legally operated by unmonitored, amateur hobbyists with no safety plans or controls in place to prevent catastrophe. I, Jonathan Bain, will operate any UAS with the utmost regard for the safety and maintenance procedures included in all applicab le UAS manufacturer's instructions and operating manuals to avoid and prevent public hazar ds, as well as manned-aircraft hazards and catastrophes. This will serve to enhance safety pro tocols exclusive to UASs specific to real-estate inspection videography-and-photography usage as I, Jonathan Bain, record flight data and other information gained through permitted flight-operati ons to share with the FAA through any required FAA reports to assist with any and all future proto col and safety regulations.

Granting my, Jonathan Bain's, request comports with the Secretary of Transportation's (FAA Administrator's) responsibilities and authority to not only integrate UASs into the national airspace system, but to " . . . establish requirements for t he safe operation of such aircraft systems (UASs) i n the national airspace system," under Section 333(c) of the Reform Act specific to the use of UASs for real-estate/realtor purposes. Further I, Jonath an Bain, will conduct my operations in compliance with the protocols described herein, or as otherwis e established by the FAA.

For the reasons stated below, I, Jonathan Bain, res pectfully request the grant of an exemption allowing me to operate remote-controlled UASs to pr ovide community awareness regarding UASs, and to provide my clients with higher levels of inf ormation about the houses or buildings they either own, or have under consideration to purchase. These houses and buildings typically are valued from between fifty-thousand dollars ($50,000.00) to over one million dollars ($1,000,000.00). I will be providing a valuable service by operating a UAS to provide a higher degree of information about the houses or buildings. Another benefit is, I will be able to provide aerial views of the houses and buildings that would not be possible without hiring a much more expensive, manned aircraft.

Because this petition is similar in all material as pects to previously-granted Section 333 petitions, I request expedited approval pursuant to the FAA’s su mmary grant process.

I. Applicant Information:

Jonathan Bain

611 Kastle Road Lexington, KY 40502 (859) 268-0262 bainpropertyinspection@gmail.com

II. The Specific Sections of Title 14 of the Federal R egulations From Which Jonathan Bain Requests Exemptions are:

14 C.F.R. 21;Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

3 14 C.F.R. 61.23 (a) and (c);

14 C.F.R. 61.101(e)(4);

14 C.F.R. 61.315(a):

14 C.F.R. 45.23 (b);

14 C.F.R. 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 C.F.R. 407 (a) (1);

14 C.F.R. 409 (a) (2); and,

14 C.F.R. 417 (a) & (b).

I also ask the FAA to exempt me from any other rule s the FAA deems necessary, to operate unmanned aircraft systems for aerial inspections an d data collection.

III. The Extent of Relief Jonathan Bain seeks and the Reason He Seeks Such Relief:

I, Jonathan Bain, submit this application in accord ance with the Reform Act, 112 P.L. 95 §§ 331- 334, seeking relief from any currently applicable F ARs operating to prevent me, Jonathan Bain, from performing commercial, academic, and other flight o perations within the national airspace system. The Reform Act in Section 332 provides for such int egration of civil, unmanned aircraft systems into our national airspace system as it is in the p ublic’s interest to do so. My, Jonathan Bain’s, UAS

meets the definition of “small unmanned aircraft” a s defined in Section 331, and therefore the integration of my UAS is expressly contemplated by the Reform Act. I would like to operate my UAS prior to the time period by which the Reform Ac t requires the FAA to promulgate rules governing such craft. Thereby, providing direct exp erience and valuable information for formal regulation that can be administered uniformly to al l real-estate-related UAS aerial photography and videography. The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our national airspace system. Con siderations include: The weight, size, speed, and overall capabilities of the UASs, and whether the U AS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Jonathan Bain. My UASs utilize four (4) counter-rotating propellers for balance, c ontrol, and stability. My UAS is equipped with GPS and auto-return safety technology, and it weigh s less than five (5) pounds (far below the maximum fifty-five (55) pound limit); including the cameras and gimbals.

I, Jonathan Bain, practice safety first and foremos t on every flight. My unmanned aircraft is designed to hover in place with the assistance of GPS satell ites, and operate in less than a twenty-four (24) knot, or fifteen (15) mile-per-hour wind. In the in terest of safety, stability, and cognizance of financial loss, I do not fly in winds exceeding six teen (16) knots-per-hour, or ten (10) miles-perhour. My UASs have inherent safety systems in place that include a GPS mode that allows my UAS to hover in place when radio controls are not manip ulated. I would only use the GPS mode while photographing or videographing houses and buildings . This GPS mode provides the maximumJonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

4 degree of safety, reliability, and stability for a UAS, and it significantly reduces the possibility o f

accident or hazard. Should the UAS ever lose its si gnal between itself and its controller, the UAS is designed and programmed to slowly descend to the pr ecise location from which it ascended off the ground. I do not operate my UAS near airports, hosp itals, or heliports, and I don’t operate my UAS when the general public is within fifty to one-hund red (50-100) yards depending upon location, governing instances and conditions, and weather. I continually monitor the sky around me for any and all manned aircraft—police, medical, and other helicopters—and prepare to immediately abort my flight and land at the nearest and safest ground -point should a manned aircraft approach my location, or if I suspect a manned aircraft may app roach my location. My UAS is capable of vertical and horizontal movement, and it is only flown withi n the line of sight of me, the remote-control pilot, and my visual observer. Utilizing battery po wer, rather than combustible fuels, flights typical ly last between four (4) and ten (10) minutes, and I u nfailingly land when the battery is at or above thirty percent (30%) of its capacity. My flights wo uld normally be at altitudes of one hundred (100) feet or less. I, Jonathan Bain, utilize a fresh, fu lly-charged battery for every flight as a safety precaution, despite each battery’s ability to provi de fifteen (15) to twenty (20) minutes of flight ti me. I do not operate my UAS at or below the manufacture r-recommended minimum-charge levels for operation. Rather, I remain well within a safe oper ating range to insure adequate communication

between the radio-controller and the UAS to elimina te the potentials for crashes, loss of control, and any other potential hazards. I maintain reserve bat teries at all times should replacement be necessary for safe operation of the UAS. I do not take risks that could result in crashes, or that would create a hazard for public property, people, or manned aircr aft. I have logged hundreds (100s) of hours of practice flights in remote areas as a hobbyist, sim ulating flights for future commercial use. This has provided me with familiarity with the characteristi cs of my specific UAS’s performance when operated under disparate temperature- and weather c onditions. I also have logged, and continue to do so, computerized flight-simulations to make cert ain my skills and response-reflex time remain well honed. All of this has been performed in the i nterest of safety.

I, Jonathan Bain, am exceedingly cautious when oper ating my UAS, which is a lightweight,

unmanned aircraft. I will not “create a hazard to u sers of the national airspace system or the public. ” 112 P.L. 95 § 333 (b). Given the small size and wei ght of my UAS, it falls well within Congress’s contemplated safety-zone when it promulgated the Re form Act and the corresponding directive to integrate UASs into the national airspace system. J onathan Bain’s UAS, used during hobby flights, has a demonstrable safety record, and does not pose any threat to the general public or national security.

IV. How Jonathan Bain’s Request Will Benefit the Pub lic As A Whole:

Aerial videography and photography for real-estate inspections have been available for years by using manned, fixed-wing aircraft and helicopters. For most people who are purchasing a home or commercial building, however, the cost of hiring a manned aircraft is prohibitive. Very few people, and very few businesses, could afford to absorb suc h expenses. This deprives typical buyers of houses and commercial buildings of the benefit to l earn more about the conditions of the properties they have under consideration to purchase. It also deprives current owners of a house or building from knowing as much as is possible regarding the c onditions of their houses or buildings. Utilizing manned aircraft to perform house or building inspec tions poses a threat to the public due to the potential of catastrophic crashes, which have occur red in the past. The crashes of manned aircraft have resulted in losses of life and damage to prope rty. When the manned aircraft crashed, they contained combustible fuel that exploded and create d fires on impact. People have been injured, andJonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

5 property has been damaged. My, Jonathan Bain’s, UAS poses no such threat since its small size, and lack of combustible fuel, alleviate any potential t hreat to the public.

Congress has proclaimed that it is in the public’s interest to integrate commercially-flown UASs into the national airspace system, hence the passage of the Reform Act. Granting my, Jonathan Bain’s, exemption-request furthers the public interest thro ugh knowledge and visual awareness of properties that are either owned, or under consideration to pu rchase, by my clients. My lightweight UAS is battery powered, and it creates no emissions that c an harm the environment. The possibility of my lightweight UAS crashing is far less than that of a full-size helicopter or fixed-wing aircraft, both of which are heavy, and contain combustible fuel, and which can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ec ological threats and crash threats by permitting aerial photographic and videographic inspections us ing my battery-operated UAS. Permitting me, Jonathan Bain, to immediately fly within national a irspace furthers economic growth through the purchases of houses and buildings. This will stimul ate my community’s economy, as well as the national community when I provide services for clie nts who do not reside in my home state of Kentucky.

V. Reasons Why Jonathan Bain’s Exemption Will Not Adver sely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equ al to the Existing Rule:

My, Jonathan Bain’s, exemption will not adversely a ffect safety. Quite the contrary, for the reasons stated permitting me, Jonathan Bain, to log more fl ight time in FAA controlled airspace will allow me to contribute to the innovation and implementati on of new and novel safety protocols for Property Inspectors and Home Inspectors that can be developed in cooperation with the FAA. In addition, I, Jonathan Bain, submit the following re presentations of enhancements to current aerial videography and photography for property inspection s and home inspections:

a) My UAS weighs less than five (5) pounds. b) I only operate my UAS below two hundred (200) feet, which is well within the four hundred (400) foot permissible ceiling established by the F AA Modernization and Reform Act of

2012. c) My UAS only operates for twenty minutes per flight. I land my UAS prior to the manufacturer’s recommended minimum-level of battery power. I pilot my UAS with a remote controller, and always keep the UAS within m y line of sight. d) My UAS has a GPS flight-safety feature which allows it to hover in place, and then slowly land if communication with the remote-control pilot is lost. e) I actively analyze flight data and other sources of information to constantly review and improve safety protocols. f) I only operate my UAS in reasonably-safe environmen ts that are strictly controlled, that are safe distances from electrical power-lines and data antennae, elevated light fixtures, airports, and actively-populated areas. I conduct extensive p re-flight inspections and protocols, during which the safety of individuals and property are he ld to utmost importance. g) I always obtain all necessary permissions prior to operation, and I have procedures in place to abort flights should safety breaches or potentia l dangers occur.Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

6 My, Jonathan Bain’s, safety protocols provide a lev el of safety equal to, or exceeding, existing rules

. It is important to note that absent the integration of commercial UASs into our national airspace system, helicopters are the primary means by which to provide aerial photography and videography for knowledge regarding house and building inspecti ons. While the safety records of these helicopters is remarkable, there have been incident s in which loss of life and extensive property damage have occurred. It is far safer to operate a battery-powered, lightweight UAS to inspect buildings and houses.

First, the potential loss of life is greatly dimini shed because UASs carry no people on board, and I can only operate my UAS in specific areas, aw ay from mass populations.

Second, there is no combustible fuel onboard a UAS, and because of this, the potential for fires or explosions is greatly diminished.

Third, the small size and extreme maneuverability o f my UAS allows me to remotely pilot the UAS away from, and avoid, hazards quickly and s afely.

Lastly, given its small size and weight, even when close enough to capture images and videos, my UAS does not need to be terribly close t o the objects they are focused on due to technology, and the ability to utilize post-editing software that allows for panning and zooming.

Accordingly, my UAS has been experimentally operate d for familiarization and competency, and will continue to operate at, and above, current safety l evels and standards.

VI. A Summary the FAA May Publish in the Federal Re gister

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certif icates, Manuals, and Similar Issues

14 C.F.R. 21, Subpart H, entitled Airworthiness Cer tificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight, and enclosed operational area of my, Jonath an Bain’s, UAS permits exemption from Part 21 because my UAS meets, and exceeds, an equivalent le vel of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraf t from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 ( f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuv erability, and proximity to areas such as airports and dense populations. My, Jonathan Bain’s, current and projected UASs meet or exceed each of

these elements.

14 C.F.R. 91.7 (a) prohibits the operation of an ai rcraft without an airworthiness certificate. As no such certificate will be applicable in the form con templated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft fligh t manual in the aircraft. As there are no on-board pilots or passengers, and given the size of the UAS s, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a s afety/flight manual delineating areas of whereJonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

7 safety can be defined. The FAA has previously issue d exemptions to this regulation in Exemption

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10 167, 0167A, 10602, 10700, and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global-positioning-systems with a barometric sensor

.

14 C.F.R § 91.203 (a) and (b) provide for the carry ing of civil aircraft certifications and registrati ons. They are inapplicable for the same reasons outlined above. The equivalent level of safety will be achieved by maintaining any such required certifica tions and registrations by me, Jonathan Bain.

B. 14 C.F.R § 45.23: Marking the aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specific ations. My UASs are, by definition, unmanned. They therefor e do not have a cabin, cockpit, or pilot station on which to mark certain words or phrases. Furtherm ore, two-inch lettering is difficult to place on

such small aircrafts with dimensions smaller than t he minimal lettering requirement. I, Jonathan Bain, will mark on my UASs, my FAA Small UAS Regist ration Certificate Number, which is FA33MFLPHW on my UASs fuselages, as required by 14 C.F.R. §45.29 (f) so that I, the pilot, or anyone assisting me as a spotter with the UAS will see the markings.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Li mitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) and (b), privat e pilots are limited to non-commercial operations. I, Jonathan Bain, can achieve an equivalent level o f safety as achieved by current Regulations because my UAS does not carry any pilots or passeng ers. Furthermore, while helpful, a pilot’s license will not ensure remote-control piloting ski lls. The risks attended to the operation of my UAS

is far less than the risk levels inherent in the co mmercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Jonathan Bain, to operate my UAS to meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) and (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for th e operation of a civil aircraft. It allows helicopt ers to be operated at lower altitudes in certain condit ions. My UAS will never operate at an altitude greater than 200 feet above ground level; which is safely below the standard of 400 feet above ground level. I, Jonathan Bain, will however operat e my UAS in safe areas away from the public and traffic, providing a level of safety at least equiv alent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability, and speed of my UAS, an equivalent or higher level of safety will be achieved.

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

10 Appendix E—Safety/Flight Manual

The above-cited Regulations require, among other th ings, aircraft owners and operators to “have (the) aircraft inspected as prescribed in sub-part E 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 ....”Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

8 These Regulations only apply to aircraft with an ai rworthiness certificate. They will not, therefore, apply to my, Jonathan Bain’s, UAS. However, as a sa fety precaution, I inspect my UAS before and after each and every flight.

VII. Request for Summary Grant

Because this petition is similar in material respec ts to previous petitions the FAA has granted, I, Jonathan Bain, request that the FAA issue a summary grant of exemption pursuant to the agency’s expedited summary grant process. Specifically, the public and safety benefits my operations will achieve are materially similar to Grants of Exempti on the FAA has already issued. I, Jonathan Bain, will adhere to a series of operating parameters tha t will offer the same level of safety as the conditions the FAA currently requires in its summar y grants.

VIII Operating Parameters

I, Jonathan Bain, will adhere to the following oper ating parameters when operating UASs pursuant to a grant of the requested exemption.

1) Operations will be conducted using the DJI Phantom 2 Vision, 3DR Solo, and the DJI

Phantom 3 Professional. 2) The UAS will not be operated at a speed exceeding 8 7 knots (100 miles per hour), at an altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet below or 2,000 feet horiz ontally from a cloud. All operations will be conducted during the day under visual meteorologica l 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 and a vi sual observer, and the UAS will remain within the visual line of sight of the pilot and th e observer at all times. The pilot will maintain visual line-of-sight capability and the ab ility to communicate verbally with the visual

observer at all times. 5) I, Jonathan Bain’s, operating documents will be acc essible during UAS operations and made available to the Administrator upon request. 6) Prior to each flight, the pilot in command will con duct a pre-flight inspection and determine the UAS is in a condition for safe flight. If the i nspection reveals a condition that affects the safe operation of the UAS, the UAS will not be oper ated until the necessary maintenance has been performed and the UAS is found to be in a cond ition for safe flight. 7) I, Jonathan Bain, will follow the UAS manufacturer’ s maintenance, overhaul, replacement, inspection, and life-limit requirements, as well as safety bulletins, for the aircraft and aircraft

components. 8) The pilot in command will abort the flight in the e vent of unpredicted obstacles or emergencies, and will yield to all manned aviation activities.

A Summary

The FAA may Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness

Certificates, Manuals and The Like. 14 C.F.R. 21, S ubpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary air worthiness certificates in relation to FAR § 91.203(a)(1). The size, weight, and enclosed operat ional area of my UAS permits exemption fromJonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

9 Part 21 because my, Jonathan Bain’s, UAS meets an e quivalent level of safety pursuant to Section

333 of the Reform Act. The FAA is authorized to exe mpt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 ( f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuv erability, and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of these elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an a irworthiness certificate. As no such certificate wi ll be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the a ircraft. As there are no pilots or passengers, and given the size of the UASs, this Regulation is inap plicable. An equivalent level of safety will be achieved by maintaining. The FAA has previously iss ued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167. Furthermore, I maintain a maintenance schedule that includes regular firmware updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In Summary, Jonathan Bain seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H: 14 C.F.R. 45.23(b); 14 C.F .R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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. §§ 91.203( a) and (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. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & ( b) to commercially operate my, Jonathan Bain’s, small, unmanned aircraft for community awareness and real estate operations, and to develop economic platforms for real estate inspections to enhance the experiences of people and businesses buying hou ses and commercial buildings. Currently, real estate videography and photography rely primarily o n the use of larger aircraft that burn combustible fuels, which pose potential risks to the public. Gr anting my, Jonathan Bain’s, request for exemption will reduce current risk levels and thereby enhance and further safety. My UAS crafts do not contain potentially-explosive fuel. They are smaller, light er, and more maneuverable than conventional realestate videographic and photographic aircraft with much shorter flight times. Furthermore, I operate at lower altitudes, and in controlled airspace, eli minating potential public risks flying to and from established air fields. I, Jonathan Bain, have been informally analyzing flight information, and will compile safety protocols, and the implementation of a flight-operations manual, for real-estate usage that exceeds currently accepted means and methods f or safe flight. Formal collection of information

shared with the FAA will enhance the FAA’s internal efforts to establish protocols for complying

with the FAA Modernization and Reform Act of 2012. There are no personnel on my, Jonathan Bain’s, UAS, and therefore the likelihood of death or seriously bodily-injury is significantly diminished. My, Jonathan Bain’s, operation of my UA S, weighing less than five pounds, and travelling at lower speeds within limited areas, wi ll provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Jonatha n Bain, respectfully request that the FAA grant my exemption request. I am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large

,Jonathan Bain, Real Estate Inspector, Lexington, KY —Section 333 Exemption Petition

10 Respectfully Submitted,

Jonathan Bain Bain Property Inspection, Inc.

611 Kastle Road Lexington, KY 40502 (859) 268-0262 bainpropertyinspection@gmail.com Kentucky Licensed Home Inspector No. 2058

Federal Aviation Administration Small UAS Certifica te of Registration No. FA33MFLPHW