11/14/2015

Brandon P ope BPope Productions

1080 5 th Avenue CT NW Hickory, NC 2860 1 (828) 320

- 1925 brandon@bpopeproductions.com

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

To Whom It May Concern:

I, Brandon Pope , am writing to request exemption from the following sections of Title 14, Code of Federal Regulations §§ in accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the
FAA Modernization and Reform Act of 2012

. 91.119(c ) , .91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)&(b).

I am requesting this exemption i n order to operate small unmanned aircraft system s (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the

purp oses of aerial photography/cinemtography , real estate marketing and surveys, and other flight requests that could be performed safely and more cost effectively with the use of sUAS at low altitude (below 200 feet) within the U.S. national airspace system as compared to a manned aircraft. Such requests will only be performed with the authorization and permission of clients or authorized agents of such clients. No pers ons will be included in any photo/video without their expressed written permission, which will be kept on file for audit at any time by the FAA.

## 2BPope Productions The following reasons for exemption of the above mentioned Federal Aviation Regulations (FAR) are being reques ted by myself, Brandon Pope

.
 91.119(c) As determined in the Ex emption 11138 (Douglas Trudeau)

- operations conducted closer than 500 feet to the ground may require that the UAS be operated closer than 500 feet to essential persons or objects that would not be possible without additional relief. The petitioner requests modification or exemption and clarification concerning the terms congested areas and densely populated. I am requesting a waiver for this condition to allow responsible operation with extre me safety in areas with housing and possible other structures.
 91.121 As determined in exemption 11138 (Douglas Trudeau)

- is nonapplicable

since the the sUAS does not use an altimeter but does utilize electronic GPS with a

barometric sensor for altitude hold and information.
 91.151(a) As discussed in exemption 11136 (Advanced Aviation Solutions LLC)

– prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including exemption numbers 2689, 10650, and 5745. Additi onally, similar UAS specific relief has been granted in exemption numbers 10673, 8811, and 10808 for daytime visual field of reference conditions (VFR). The UAS provides battery power measurement to the radio controller held by the person in control
(PIC). The UA batteries allow for apporoximately 20 minutes of flight. I have attached information on UASs that describe in more detail the specifics around battery management. They contain process and procedures for the PIC when battery

reaches a certain level. Understanding the limitations on proposed operations and location of said operations, the FAA found that reduced minimum power reserve for flight in daytime VFR conditions was reasonable.
 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 91.417(a) & (b) As di scussed in exemption 11138 (Douglas Trudeau)

– I, Brandon Pope , will personally inspect and ensure that each UAS is in top condition for safe flight in accordance with all documents pertaining to safe operation. The FAA found that adherence to the
petiti oners operating documents and the conditions and limitations specified, describing the requirements for maintenance and record keeping and inspection were sufficient to ensure that safety would not be adversely affected.

Description of UAS to be Operated under this Exemption

## 3BPope Productions The DJI Phantom 3 professional is manufactured by highly successf ul and safety oriented

compan y

. T he DJI Phant om 3 Professional is under 25 pounds a nd carr ies a 4K/UHD

camera . The advertised maximum speed is less than 15 miles per hour and is powered by

four electric motors with a distance of less than 18 inches. T he Phantom 3 Professinonal utililize gps and compass orientation for stable flight and the ability to know their position at all times. The gps on the UASs also do not allow for motors to be initializ ed within a designated No Fly Zone. Real time video that includes telemetry is visible by the PIC at all times. The PIC can measure battery level, GPS strength, altitude, distance from PIC, along with image from camera at all times. Both units have fail sa fe modes of operation for low battery, loss of gps or loss of signal. In these situations, the UAS will return to the point of

takeoff and motors wi ll automatically disengage. The UAS can be programmed to limit their

altitude and distance from PIC before flight. T he u nit is also limited to approximately 2 3 minutes per battery. The Phantom 3 Professional also ha s visible LED indicators that let the PIC know of any situation that the PIC might determine requires the UAS to return home. Most flights last less than 10 min utes and more information is available in the attachments that I have included with this application for exemption.

Ack nowledgment of FAA Safety Regula tions and Guidelines
I, Brandon Pope , have reviewed and retained a copy of all FAA regulations includi ng those regulations and guidelines based on the premise of safety. I find all regulations to be reasonable and I will not only meet, but do my best to exceed all safety regulations as set forth by the FAA. My main focus is safety and protection of all per sons and property that myself or my UAS comes in contact with. I have enclosed documents that include a preflight and postflight checklist, but I also have an additional checklist that I use before, during and after each flight. All moving parts of the UAS are inspected to ensure safety.

Request for Close Proximity Flight
I, Brandon Pope

, am also requesting to be allowed to o perate within 5 miles of an airport

similar to reference number 1

, providing that

“The UA may not operate in Class B, C, or D air space without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAA published aeronautical chart unless a letter of agreement with that airport’s manageme nt is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s

## 4BPope Productions COA. The letter of agreement with the airport management must be made available to the Administrator upon request.”

I have permission of the airport a dministrator or designated official. I will have written permission and a documented flight plan for each flight used in this manner. The before mentioned written permission and flight plan will be kept on file for audit at any time for

the FAA. Flight wit hin 5 miles of an airport is rare, but in the area I plan to operate, there are several small airports that allow UAS flight within 5 miles with permission as noted

above.

Other Interests I feel that this exemption will allow me not only the ability to gain financially for use at the request of different companies, but it will also allow me to help educate the public on the safe use of a UAS under proper legal guidelines and safety. I feel that this exemption will also allow me to perform tasks that not only could not be performed from the ground, but would also allow me to perform tasks that would normally put persons at risk to obtain the same information. Many of the structures I would be filming would be hazardous for an individual to access. The use of a UAS allows for safe visual inspection of not only property, but buildings and other structures as well. I can also use the UAS to participate in air shows and displays for no charge to show the many uses of this type of aircraft when performed under the proper legal guidelines. My services will also be offered to local organizations such as schools, fire department s , and police department s as long as such re qu ests fall under the rules of the exemption that I am requesting along with all other FAA guidelines. Operations for this petition will also enhance the economic growth of the area in which my company resides.

Summary
I, Brandon Pope , am requesting this exemption for the purposes of aerial photography and video of, not only real estate, but possibly land observation, inspection of construction equipment, towers, and other flight operations as requested by clients. I am requesting this exemption for the reasons noted above and spec ifically intended these items to be broad based on my business plan to extend operations to different areas based on requests by clients. Each request will be analyzed by myself, Brandon Pope , to validate that these requests can be done in a safe manner and in compliance with all FAA regulations. I also plan

## 5BPope Productions to use my business and myself as a mentor for other small business owners to educate and to assist them in starting their own business in accordance with all FAA regulations and laws. I

have seen seve ral advertisements of people offering these services, as specified above, but I have refrained from pursuing opportunities for commercial use of my UAS until I can properly be authorized by the FAA.

Documents Attached

1. DJI Phantom 3 Professional Safety Guidelines

References

1. FAA Exemption Number 11080, Regulatory Document Number FAA

- 2014

- 0355 in

the matter of the petition of Flying Cam INC

2. FAA Exemption Number 11136, Regulatory Document Number FAA

- 2014

- 0508 in the matter of the petition of Advanced Aviation Solutions LLC

3. FAA Exemption Number 11138, Regulatory Document Number FAA

- 2014

- 0481 in

the matt er of the petition of Douglas Trudeau

Thank you for your consideration of my petition for this exemption. I look forward to hearing from you soon . Please do not hesitate to reach out to me with any questions or if any additional information is needed.

Respectfully,

Brandon Pope

Owner BPope Productions