**07/16/2015**

U.S. Department of Transportation Washington DC 20590

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 CFR 45.2 3(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(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 FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Baesel Media Group, Inc. of 730 Texana Drive, Prosper TX 75078, operator of an Unmanned Aircraft System (UAS), here by applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as
requ ired by Section 333.

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

1. Aerial photography and/or video for public and/or private use including real estate, archite cture, land surveying, engineering and other related professional activities.
2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.
3. Aerial inspection/photography of residenti al/commercial structures under contract with the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.
5. Aeri al video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or
donation.
6. The ability to offer trainin g to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safet y enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....esta blish requirements for the safe operation of such aircraft systems in the national airspace system.” 469.296.8822 eric@baeselmedia.comRegulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)
14 CFR 91.103
14 CFR 91.109 14 CFR 91.119 (c)
14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

Equipment to be operated is the 3DRobotics Solo:

Flight time: 25 m inutes; 20 minutes with payload Range: .5 miles (.8 km) Max speed: 55 mph (89 km/h) Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode Max descent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode Max payload: 420 g Max altitude: 400 ft per FAA regulation, user adjustable (122 m) Motors: 880 kV Propellers: 10′′ diameter 4.5′′ pitch self

- tightening (24 cm diameter 144 cm pitch); glass

- reinforced nylon Autopilot: Pixhawk 2 Software: APM:Copter Communication: 3DR Link secure WiFi network Frequency: 2.4 GHz Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor

- to

- motor Flight battery: Lithium polymer 5200 mAh 14.8 Vdc Battery charge time: ~1. 5 hours Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion App requirements: iOS 8.0 or later / Android 4.3 or later

Baesel Media Group, Inc. will operate the UAS in line of sight within a closed off and predetermined area o wned and/operated by the property representative. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements.The approval of this application presen ts no national security issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operati ons will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption
as set forth in the Flight Operations Manual (FOM) include :

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed of no more than 35mph.

• Flights will be operated within line of sight of the Pilot in Command (PI C) and/or Visual Observer (VO).

• Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 25% battery power reserve or 20 minutes of fligh t time whichever occurs first.

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist o f the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.

• The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary certifications currently being approved by the FAA administrati on for commercial use.

• A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ production activities.

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only

.

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport

.

• If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and ot her pertinent information.

• The operator will file FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation.

• The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 fe et based upon an equivalent level of safety determination, as required under the FOM. With the advanced permission of the FSDO, operations a t closer range may be approved.

• The PIC and VO will have been trained in operation of UAS and receive up

- to

- date i nformation for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

• Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other app ropriate governmental agencies.

• If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated locat ion and land autonomously.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthines s Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria
demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate witho ut the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a sec ured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will
have advan ce notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, applicatio n of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substa ntial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or exper imental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "l ight

- sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental”

c an be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its fuselage a s required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. An equivalent level of safety can be achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The operation and limitations set fort h in the FOM will equate to the safe operation of the
UAS.

14 C.F.R. §91.7(a) : Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will
be no airworthiness certific ate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of saf ety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no abilit y or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight m anual at the ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F .R. § 91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the manufacturer FOM in the pre

- flight inspection section, including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F .R. §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloo n) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a

contro l box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraf t and for flight instruction in experimental aircraft. The equivalent leve l of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.14 C.F.R. §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil ai rcraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein,
the UAS wil l never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the stru cture. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected ind ividuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is
far l ess than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the
low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must compl y with Section 91.119.

14 C.F .R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check li st and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a) Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginnin g “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that
for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to a pproximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applica nt believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility
for whi ch the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to it s planned landing zone from anywhere in its limited operating area.1 4 C.F.R. §91.203 (a) and (b) Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them; to the extent they are applicable to the UAS.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equ ivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar
with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in
accordance with the UAS Manufactu rer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed.

Additional Information

The applicant, Baesel Media Group, Inc. , and t he primary pilot, Eric Baesel , has an in

- depth understanding of the capabilities and safety concerns involve d in using this technology as an asset to the community. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s UAS.

Sincerely,

Eric Baesel
Owner Baesel Media Group, Inc.