Gerald W. Lempicki

Bear Swamp Power Company, LLC. 370 River Road Florida, MA 01247 (UPS and FedEx delivery only, no USPS) December 29, 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W1 2 - 140 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Mr. Duncan: This letter constitutes a petition for exemptions in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. I , Gerald W. Lempicki, representing Bear Swamp Power Company , intend to us e small unmanned aircraft systems ( S UAS) for the purposes of aerial photography, video capture, surveying, inspectio ns, data collection, S UAS/UAV operational training, and demonstration of S UAS/UAV capabilities. Bear Swamp Power Company (BSPC) owns and op erates hydroelectric generation facilities with associated civil structures and distribution equipment. I seek relief from the following:  14 CFR Section 61.23 (a) and (c): M edical certificate requirement o I request exemption so as to not require the operator to hold a medical certificate.  14 CFR Section 61.101 (e)(4) and (5): Recreational pilot limitations o I request exemption so as to allow a recreational pilot certificate holder to operate the UAS for compensation or hire, a nd in furth erance of a bus iness.  14 CFR Section 61.113(a): P rivate pilot limitations o I request exemption so as to allow a private pilot certificate holder to operate the UAS for compensation or hire, and in furtherance of a business.  14 CFR Section 61.315(a): S port pilot limitation s o I request exemption so as to allow a sport pilot certificate holder to operate the UAS for compensation or hire, and in furtherance of a business. 14 CFR Section 91.7(a): Civil aircraft airworthiness o I request exemption so as to allow the operator to determine airworthiness based on a preflight inspection incorporating manufacturer’s recommendations.  14 CFR Section 91.119(c): Minimum safe altitude s o I request exemption so as to allow operation of the UAS from the surface up to 400’ AGL.  14 CFR Section 9 1.121: Altimeter settings o I request exemption so as to allow operation with existing UAS flight controller technology, be it GPS derived or pressure sensor derived altitude.  14 CFR Section 91.151(a)(1): Fuel requirements o I request exemption so as to allow UAS operation by maintaining a reasonable reserve power supply in order to complete the mission in the event of unforeseen winds/occurrences.  14 CFR Section 91.405(a): Maintenance require d o I request exemption so as to allow operation of the UAS given preflight and post flight inspections based on manufacturer recommendations and operator experience.  14 CFR Section 91.407(a): Operation after m aintenance , etc. o I request exemption so as to allow operation of the UAS based on following manufacturer’ s recommended maintenance procedures.  14 CFR Sect ion 91.409(a)(1)(2): Inspections o I request exception from annual inspection and airworthiness certificate requirements so as to allow operation of the UAS based on preflight inspections and proper maintenance according to the manufacturer.  14 CFR Section 91.417(a)(b): Maintenance records o I request exemption from 14 CFR Section 91.417(a) and (b) as written. I will maintain operational and inspection logs to satisfy my safety and operating requirements.Bear Swamp Power Company intends to use the following S UAS, to be selected based

on the work that is to be performed :  3DR Solo  DJI Inspire 1  DJI Phantom 3 Pro  DJI F550  DJI S900  DJI S1000  Birdseyeview Aerobotics Firefly6  Action Drone AD - 1  Action Drone AD -2  senseFly Exom All of the above are electric powered and meet the weight requirements of a small unmanned aircraft system. For convenience, the manuals and specifications are hyperlinked above. As shown by numerous previously granted S UAS exemptions , commercial operations of SUAS will enhance safety by reducing exposure to risk. The use of SUAS would eliminate some of the risk associated with technicians working at height, over water, and in close proximity to energized equipment. Conventional aircraft are much larger than SUAS , and are inherently more dangerous due to the volume of fuel on board. SUAS generate less noise and have less environmental impact. A high level of safety will be maintained by following the SUAS manufacturer’s recommended operating proced ures, my Operations Manual, and my checklist procedures . In addition, the operator will adhere to all terms, conditions, and limitations of the exemptions granted. The result of this action would contribute to the overall integrity of our infrastructure and to the reliability of our operations

.In summary, Bear Swamp Power Company seeks exemption from the following rules:

14 CFR Section 61.23 (a) and (c), 14 CFR Section 61.101 (e)(4) and (5), 14 CFR Section 61.113(a), 14 CFR Section 61.315(a), 14 CFR Section 91.7(a), 14 CFR Section 91.119(c), 14 CFR Section 91.121, 14 CFR Section 91.151(a)(1 ), 14 CFR Section 91.405(a) , 14 CFR Section 91.407(a ), 14 CFR Section 91.409(a)(1) and (2) , and 14 CFR Section 91.417(a) and (b)

. I do not believe the request for exemption of the above rules would set a precedent; upon review of the FAA’s Authorizations Granted via Section 333 Exemptions it is apparent that there have been many previously approved exemptions for similar purposes. Confidential and proprietary documents will be emailed separately. If you require any additional information, please contact me here

. Sincerely,

Gerald W. Lempicki