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B2 Aerial Video and Photography Owners: Christopher Brunsvold and Kyle Burgess 2360 Dodge Dr. Sparks, NV 89436

775-846-1038

U.S. Department of Transportation
Federal Aviation Administration

July 13, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 C FR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 9 1.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407( a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a ) and (b)

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Admin istration (FAA) Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Christoph er Brunsvold, owner of B2 Aerial Video and Photography (B2 Aerial) which owns and operates an Un manned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Reg ulations (FARs) to allow commercial operation of its UAS, so long as such operations are conducted wit hin and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, w hich are equipped with camera(s) and sensors, would operate in the following manner:

- Aerial photography and/or video for public and/or priva te use including real estate, architecture, surveying, engineering and other related professional activities.

- Aerial video and/or photography for public and/or priva te use including television, public events, private events, cinematography and news gathe ring.

- Aerial inspection/photography of residential/commerci al structures under contract with the owners or local government authority.

- Aerial inspection/photography or residential/commercia l utility infrastructure including but not limited to electrical power lines, wind turbines and c ell towers.2

- Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of emergency or natural disaster on ly when the local authorities or government has requested it by contract or donation.

B2 Aerial operates two DJI Inspire 1 (4) blade quad co pters weighing 6 pounds, 7.5 ounces (see attached manual). The UAS has a maximum airspeed of 40 miles per hour and uses a remote controller operating on frequency range of 2.400-2.483 GHZ. The Inspire 1 i s equipped with built-in ground support technology that allows it to fly utilizing global p ositioning system (GPS) for stability, tracking, safe flight
mode and a return-to-home feature in the event of lo ss of remote control signal or critical low battery. All flights start with a pre-flight safety check and all flight data are recorded. The Inspire 1 is equipped with a gimbal mounted camera that sends a live video signal to the controller allowing the person in control (PIC) to monitor real-time video. Flight data , speed height, distance, battery level and general aircraft conditions are also displayed during operation. The Inspire 1 battery has a flight time of 15-20 minutes and is, therefore, always returned to original t akeoff point and always flown utilizing visiual lin e of sight (VLOS). We have been training on the DJI In spire for seven months and have become proficient in all aspects of flight and safety of this UAS. Ou r request for exemption would allow us to offer unique aerial photography and videography services to our clie ntele.

UAS Safety Operating Parameters We will abide by the following additional operating conditions under this exemption, which ensures a level of safety during UAS flight including operating the UAS below 400 feed and within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from the owner/controller of any vessels, vehicles and structures when operations may b e conducted closer than 500 feet to any such vessels, vehicles or structures. We will conduct a sa fety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard. Other safety operating parameters include:

- Operate the UAS for 15-20 minutes per flight.

- Land UAS prior to the manufacturers recommended minimu m level of battery power.

- Operate the UAS during daylight hours only within VLOS

.

- Utilize the UAS’ GPS flight safety feature whereby i t hovers and then slowly lands if communication with the PIC is lost or battery become s critically low.

- Always obtain all necessary permissions prior to operati on.

- Have procedures in place to abort flights in the even t of safety breaches or potential danger.

- Review weather reports prior to flight and never operate UAS in unsafe conditions, high wind, low clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly co ntrolled, are away from power lines, elevated lights, airports and densely populated areas

.

- Also conduct extensive preflight inspections and prot ocols during which safety carries primary importance.3

The PIC will also have a minimum of five hours logge d on this craft and 10 hours minimum flying UAS quad copters under varying conditions and environments and will follow all safety protocol of B2 Aerial as well as guidelines of 14 CFR §61.51(b) having th e ability to safely operate the UAS in a manner consistent with the operating documents, including e vasive and emergency maneuvers and maintaining appropriate distances from people.

Specific Exemptions Requested Given the size, weight, speed and limited operating area associated with the UAS, we feel an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificat es) and 14 CFR 91.203(a) and (b) (certifications required), subject to certain conditions and limitatio ns, is warranted and meets the requirements for an equivalent level of safety under 14 CFR Part 11 and S ection 333 of P.L. 112-95 (Section 333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS will not have a cabin, cockpit or pilot station on which to mark cert ain words or phrases. Further, the two-inch lettering is difficult to place on such a small aircraft with d imensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS i n the largest possible lettering by placing the word “Experimental” on its fuselage as required by 14 C FR 45.29(f) so that anyone will see the markings.

We request an exemption from 14 CFR 61.113(a) and (b ) Private Pilot Privileges and Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots or passengers nor property. The Risks attendant to the operation of the UAS is far less than the risk levels inherent in the commercial activities outline d in 14 CFR §61. The operation and limitations in the flight operation manual (FOM) will equate to the saf e operations of the UAS.

We request an exemption from 14 CFR 91.7(a) which pro hibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenanc e inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety prec aution, we will perform a preflight inspection of the UAS before each flight as outlined in the attach ed operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft, however, since there are no pilots or passengers on boa rd the aircraft, and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/fli ght manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight In struction: Simulated Instrument Flight and Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is being use d for flight instruction unless that aircraft has fully f unctioning dual controls. Although the DJI Inspire 1 is capable of dual/linked controls, we will be operating with a single remote controller.4

We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of civil aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “pr oviding a level of safety at least equivalent to or
below those in relation to minimum safe altitudes.” Given the size, weight and maneuverability and speed of the UAS, an equivalent or higher level of sa fety will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the UAS
utilizes electronic GPS with a barometric sensor. We r equest an exemption from 14 CFR 91.151(a) Fuel Requirements for Flight in visual flight rules (VFR) c onditions. The UAS is 100 percent electric and two low battery alerts are issued – per the operating docu ments, the UAS will be landed at the first alert. Also, our flights will last only 15-20 minutes each and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless, considering wind an forecast weather conditions, there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UAS wit h 30 percent battery power remaining.

Summary We will comply with all of the following conditions and limitations should this grant of exemption be provided:

1. Operations will be limited to the following aircraft described in the operating documents which is a quad-rotor aircraft weighing less than seven poun ds: DJI Inspire 1 Aircraft System.

2. The UAS will not be flown at an indicated airspeed e xceeding 40 mph.
3. The UAS will be operated at an altitude of no more th an 400 feet AGL, as indicated by the procedures specified in the operating documents.

4. The UAS will be operated within VLOS of the PIC at a ll times.

5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS of the
VO at all times. The VO and PIC will be able to com municate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform t he functions prescribed in the operating
documents.
6. The operating documents will be accessible during the UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.

7. Prior to each flight, the PIC will inspect the UAS t o ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the saf e operation of the UAS, the UAS will not be operated until the necessary maintenance has been perf ormed and the UAS is found to be in a condition for safe flight. The Ground Control Stati on will be included in the preflight inspection. All maintenance and alterations will be properly docu ments in the aircraft records.
8. Any UAS maintenance or alterations that affect the UA S operation or flight characteristics, e.g. replacement of a flight critical component, will unde rgo a functional test flight. The PIC who conducts the functional test flight will make an en try into the aircraft records.5

9. The pre-flight inspection section in the operating do cuments will account for all discrepancies, i.e. inoperable components, items or equipment not al ready covered in the relevant sections of the operating documents.
10. We will follow the UAS manufacturer’s aircraft/componen t, maintenance, overhaul, replacement, inspection and life limit requirements.

11. We will carry out maintenance, inspections and record -keeping requirements, in accordance with the operating documents. Maintenance, inspectio n and alterations will be noted in the aircraft records, including total flight hours, descripti on of work accomplished and the signature of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer S afety Bulletins.

13. An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in
which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar opera tions), the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b) , a minimum of five hours as an UAS pilot operating the make and model of the UAS to be used i n operations.
16. The PIC will not operate the UAS for the purpose of ae rial videography/cinematography and augmenting real estate listing videos (or similar opera tions), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51 (b), the ability to safely operate the UAS in a manner consistent with the operating documents, i ncluding evasive and emergency maneuvers and maintaining appropriate distances from pe ople, vessels, vehicles and structures.

17. UAS operations will not be conducted during night hou rs, as defined in 14 CFR 1.1 All operations will be conducted under visual meteorological conditi ons (VMC).

18. The UAS will not operate within five nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart.
19. The UAS will not be operated less than 500 feet belo w or less than 2,000 feet horizontally from a cloud or when visibility is less than three statute miles from the PIC.

20. If a UAS loses communications or loses its GPS signa l, it will return to a predetermined location within the planned operating area and land or be recov ered in accordance with the operating
documents.

21. The PIC will abort a flight in the event of unpredict ed obstacles or emergencies in accordance with the operating documents.

22. The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is enough power to fly at a normal cruising speed to the intended landing point and land the UAS with 30 percent battery power remaining.

23. Before conducting operations, the radio frequency spec trum used for operation and control of the UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

24. The documents required under 14 CFR 91.9 and 14 CFR 9 1.203 would be available to the PIC at the Ground Control Station of the UAS at any time t he UAS is operating. These documents will be made available to the Administrator or any law enfo rcement official upon request.6

25. The UAS will remain clear and yield the right of way t o all manned aviation operations and
activities at all times.

26. The UAS will not be operated by the PIC from any mov ing device or vehicle.

27. The UAS will not be operated over congested or densely populated areas unless contracted out
to do events.

28. Flight operations will be conducted at least 500 fee t from all nonparticipating persons, vessels,
vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. We will ensure that nonparticipating persons remain under such protection. If a situation a rises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediately.
b. The aircraft is operated near vessels, vehicles or struct ures where the owner/controller of such vessels, vehicles or structures has granted per mission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

c. Operations near to the PIC, VO, operator trainees or ess ential persons do not present an undue hazard to those persons per 14 CFR 91.119(a).

29. All operations will be conducted over private or contro lled-access property with permission from the land owner/controller or authorized representat ive. Permission from land owner/controller or authorized representative will be o btained for each flight to be conducted.

30. Any incident, accident or flight operation that transg resses the lateral or vertical boundaries of the operational area as defined by the applicable cert ificate of authorization (COA) will be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (N TSB) per instructions contained on the
NTSB website: www.ntsb.gov

.

On behalf of B2 Aerial Video and Photography, I would like to thank you for your consideration in granting this exemption.

Signed,

Christopher Brunsvold B2 Aerial Video and Photography