### United States ofAmerica Department ofTransportation Federal Aviation Administration Federal Docket Management System Washington, D.C. James C. Hollenbeck Hollenbeck Pest Control & 

### Environmental Inc 273 Quassaick ave New WindsorNY 12553 james@hollenbeckpestcontrol.com Page 1

RE: Petition ofHollenbeck Pest Control Aerial Photography and Inspections for Exemption Pursuant to section 333 oftheFAA Reform Act. Attn: To whom it may concern Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, HollenbeckPest Control, operatorofSmall Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography andvideography, hereby applies for an exemption from the listed FederalAviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by theFAA as required bySection 333.1 The proposed exemption,ifgranted,would allow HollenbeckPest Control & 

### EnvironmentalInc to conductcommercial operations ofsmall, unmanned aircraftsystems ("UAS") meeting orexceeding all ofthe operational and safety requirements Congress has setforth in Section 333. Hollenbeck Pest Control plans to exploitthe capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, 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 StatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthePage 2 (comprehensive) plan and rule making required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b) (1), Congress made it clearthat Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitionermeets all requirements to permit FAA approval ofcommercial UAS operations. 

### The PetitionerRequests Relieffrom 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)



### UnmannedAircraft System sUA Vs are oftentimes seen as superiorto helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotespublic safety. We are petitioning for exemptionto enable HollenbeckPest Control to operate a Yuneec Q500 4kthat will be equipped with a three-axis gimbal and use High-Defcameras. This sUAV has a built-in capability to limitthe height it flies above the ground, to limit the radius ofthe 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 communicationbetweenthe Main Controller and the transmitter is disconnected orthe battery falls below a set voltage, the UAS will return to within 20 feet ofits takeofflocation and land safely. The Yuneec Q500 is rated for 25 minute flight times. 

### The above specifications meetwiththeModel Aircraft OperatingStandards as setbelow:

• Hollenbeck Pest Control will only operate its sUAS inline ofsight ofa 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. Suchoperations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." • When flying sUAV within 5 miles ofan airport, airport operators will be notified and the operator will give the right ofway to avoid flying inthe proximity offull-scale aircraft.Page 3

• Maximum flight time for each operational flight will be 20 minutes. • Flights will be terminated at 25%battery powerreserve 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 elevatedplatform from which filming is planned. • Minimum crew for each operation will consist ofthe 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 ofno more than 50 knots, canhover, and can simultaneously move vertically and horizontally. • Given the small size ofthe sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safetyrequirements. The UA, poweredby batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will therebyreduce currentrisk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time ofonly 25 minutes, this platform offers little or no risk to national security. Low level obliquephotos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complex properties with several buildings· and large trees. The benefits ofreduced cost and improved quality ofpresentation from the UA will be valuable to and benefit many buyers and sellers ofreal 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, thepolice, the sheriff, et al., while remaining subjectto all limitations cited inthis 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 ofno more than 25 knots and no further than 118thNM from the PIC; c) All operations mustutilize a visual observer (VO). The VO and PIC mustbe able to communicate by voice at all times during a flight operation. d) Operations overprivateproperty will be made only withthe owner'spermission e) All required permits will be obtained from state and local governmentpriorto 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 ofpeople; h) Hollenbeck Pest Control, will not be operating overheavily tracked roads; i) Hollenbeck Pest Control, will notbe operating within 5NM ofan airport orheliport without priorpermission. We respectfully request exemptionunder Section 333 to enable Hollenbeck Pest Control, to operate efficient, limited, low-risk commercial sUAV operations for the activities stated respecting at all times the space and privacy ofcitizens and property while keeping our skies safe.Page 4 Safety and Benefits ofthe UAS Hollenbeck Pest Control will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft and orladders needed to complete. Small, light, unmanned aerial vehicles offermyriad benefits overthe use offull-sized manned aircraft for Structural inspections, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers orcrewcreates a much greatermargin ofsafety 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 datafrom 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 Aspointed out in this application, all the SUAs which ourcompanywould use, under authorization by the US DOT-FAA, are small, light-weight devices operated within the line of sight ofthe 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 ofthis distance. All our SUAs have proven capability for controlled flight. They are devices offered for general sale onthe market around the world and have oftenbeenused as Model Aircraft in the USA. We are certainthat the studies conducted until nowby the FAA, about Section 332, Public Law 112 -95, 2014, have already provided you withthe assurances on the airworthiness ofSUAs such as ours. Forthe foregoing reasons, the exemptions requested herein should be granted and Hollenbeck Pest Control should be permittedto conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA. The submission ofthis 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