United States of America Department of Transportation 

Federal Aviation Administration 

Federal Docket Management System 

Washington, D.C. 

James C. Hollenbeck 

Hollenbeck Pest Control & Environmental Inc 

273 Quassaick ave 

New Windsor NY 12553 

james@hollenbeckpestcontrol.com 

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RE: Petition of Hollenbeck Pest Control Aerial Photography and Inspections for Exemption 

Pursuant to section 333 ofthe FAA Reform Act. 

Attn: To whom it may concern 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Hollenbeck Pest Control, operator of Small Unmanned 

Aircraft Systems (sUASs) equipped to conduct aerial photography and videography, 

hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to 

allow commercial operation of its sUASs, so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.1 

The proposed exemption, if granted, would allow Hollenbeck Pest Control & 

Environmental Inc to conduct commercial operations of small, unmanned aircraft systems 

("UAS") meeting or exceeding all of the operational and safety requirements Congress has 

set forth in Section 333. 

Hollenbeck Pest Control plans to exploit the capabilities of Unmanned Aerial Systems to offer a 

multitude of services, including: 

• Aerial surveying 

• Creating own Commercial Advertising 

• Structural Inspections 

• Real Estate Photography 

• Aerial film making and photography 

• Construction site inspections and monitoring 

• Wildlife and forestry monitoring 

• Educational and research operations 

• Producing training videos 

Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft 

Systems", provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the NAS. Section 333(a) states that the FAA "shall determine if certain unmanned 

aircraft systems may operate safely in the national airspace system before completion of the 
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(comprehensive) plan and rule making required by section 332(b)(1) of this Act or the guidance 

required by section 334 of this Act." In Section 332(b) (1), Congress made it clear that Section 

333 provides a mechanism for "expedited operation authorization" if several factors are met. 

Petitioner meets all requirements to permit FAA approval of commercial UAS operations. 

The Petitioner Requests Relief from the Following: 

Regulations from which the exemption is requested: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 (b) 

• 14 C.F.R. 61.113(a) and (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b) (2) 

• 14 C.F.R. 91.105 

• 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) & (b) 

• 14 C.F.R. 91.205 (b) 

• 14 C.F.R. 91.215 

• 14C.F.R. (91.401-91.417) 

Unmanned Aircraft System 

sUA V s are oftentimes seen as superior to helicopters due to the smaller devices cheaper 

equipment and personnel cost, reduced noise and as such, a much smaller environmental impact 

which promotes public safety. 

We are petitioning for exemption to enable Hollenbeck Pest Control to operate a Yuneec Q500 

4k that will be equipped with a three-axis gimbal and use High-Def cameras. This sUA V has a 

built-in capability to limit the height it flies above the ground, to limit the radius of the distance it 

flies from the operator and to exclude it from Class B, C, and D airspace including a no-fly zone 

feature. The Yuneec Q500 also has the fail safe function of"Home Mode", which means when 

the communication between the Main Controller and the transmitter is disconnected or the 

battery falls below a set voltage, the U AS will return to within 20 feet of its takeoff location and 

land safely. The Yuneec Q500 is rated for 25 minute flight times. 

The above specifications meet with the Model Aircraft Operating Standards as set below: 

• Hollenbeck Pest Control will only operate its sUAS in line of sight of a pilot and/or 

observer and will operate at sites that are a 'sufficient distance' from populated areas 

within the sterile area described in the FOPM. Such operations will insure that the sUAS 

will "not create a hazard to users of the national airspace system or the public." 

• When flying sUA V within 5 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. 
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• Maximum flight time for each operational flight will be 20 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 25 

minute limit. 

• The sUAV will be programmed so that it will not be operated at an altitude ofno more 

than 400 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal) . 

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the sUAS and the restricted sterile environment within which they 

will operate, our sUAS operations adhere to the Reform Act's safety requirements. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 25 

minutes, this platform offers little or no risk to national security. Low level oblique photos and 

video from several angles are far more effective than ground based imagery for displaying the 

characteristics of large, complex properties with several buildings· and large trees. The benefits 

of reduced cost and improved quality of presentation from the UA will be valuable to and benefit 

many buyers and sellers of real estate property. Additionally, we request that we be allowed to 

use our system to benefit first responders nearby who might require assistance, including fire 

fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this 

application as we do so. 

a) No flight will be made with a Gross weight exceeding 55 pounds; 

b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

airspeed of no more than 25 knots and no further than 118th NM from the PIC; 

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation. 

d) Operations over private property will be made only with the owner's permission 

e) All required permits will be obtained from state and local government prior to operation; 

f) Hollenbeck Pest Control, will not be operate over densely populated areas; 

g) Hollenbeck Pest Control will not be operating over any open-air assembly of people; 

h) Hollenbeck Pest Control, will not be operating over heavily tracked roads; 

i) Hollenbeck Pest Control, will not be operating within 5 NM of an airport or heliport 

without prior permission. 

We respectfully request exemption under Section 333 to enable Hollenbeck Pest Control, to 

operate efficient, limited, low-risk commercial sUA V operations for the activities stated 

respecting at all times the space and privacy of citizens and property while keeping our skies 

safe. 
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Safety and Benefits of the UAS 

Hollenbeck Pest Control will be using the UAS in a variety of applications that generally require 

expensive full-size manned aircraft and or ladders needed to complete. Small, light, unmanned 

aerial vehicles offer myriad benefits over the use of full-sized manned aircraft for Structural 

inspections, advanced agriculture, film and still photography, just to name a few. Replacing 

significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying 

no passengers or crew creates a much greater margin of safety for the pilots and crew. By 

granting Hollenbeck Pest Control requested exemptions, the FAA will help drive development of 

safe and successful commercial UAS operations and will advance the public knowledge base for 

such operations. Hollenbeck Pest Control is committed to promoting the UAS research efforts of 

policymakers including the FAA, NASA, DOD and DARPA by sharing data from its 

commercial UAS operations and serving as a resource for future UAS research operations. Thus, 

the FAA has good cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the SUAs which our company would use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of 

sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles 

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities, 

unless the air traffic control authorities (ATC) have been notified and have authorized each flight 

within a radius of this distance. All our SUAs have proven capability for controlled flight. They 

are devices offered for general sale on the market around the world and have often been used as 

Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, 

about Section 332, Public Law 112 -95, 2014, have already provided you with the assurances on 

the airworthiness of SUAs such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and Hollenbeck 

Pest Control should be permitted to conduct small UAS operations in accordance with its 

manuals and all other operating parameters deemed necessary and appropriate by the FAA. The 

submission of this application and its contents is the best demonstration that indeed it is possible 

to pursue the authorization process so that some SUAs may be used for legitimate commercial 

activities and under reasonably safe conditions. 

Sincerely, 

Owner