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Douglas E. Ringering
Hangar Bravo 7, LLC

5522 Cassina Drive
Colorado Springs, CO 80923

December 31, 2015

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

RE: Exemption Request Pursuant to Section 3 33 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Hangar Bravo 7, LLC is submitting this Petition for Section 333 Exemption of the FAA

Modernization and Reform Act of 2012 (“FMRA”).

Applicant Information:

The name of the applicant: Douglas Edward Ringering

The primary contact for this application is:

Douglas Edward Ringering Hangar Bravo 7, LLC

5522 Cassina Drive

Colora do Springs, CO 80923

Hangar Bravo 7, LLC is a Limited Liability Company formed under the State laws of Colorado on or about January 1, 200 7 w i t h Douglas Edward Ringering a s the owner of the business. Pursuant to Section 333 of the FMRA, Hangar Bravo 7 LLC , hereby requests a determination by the Secretary of Transportation authorizing commercial operations of UAS for the purposes of aerial phot ography & videography, mapping

, aerial inspections, data collection, augmented real estate listings, commercial vid eos and other work related to aerial photog raphy in the NAS. Hangar Bravo 7, LLC does not intend to use for closed set filming. Flight oper ations will utilize the off the shelf DJI family of unmanned aircraft. Conduct of UA operatio ns will be with respect to FMRA Section 333(c) and the UAS “Blanket COA”.

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. The attached documentation includes detailed exemption requests thatPage 2 of 5

demonstrate how these exemptions are in the public interest and will maintain at least an equal level of safety to existing regulations. Authorizing Hangar Bravo 7, LLC to conduct commercial UAS operations will result in less disruptive, safer, and more cost

effective solutions than manned aviation equivalents due to the low altitude environment, given the size, speed and inherent risk of traditional commercial helicopter operations. These commercial operations often occur in the unsafe areas of the height

velocity diagram requiring special precision and skill. Hangar Bravo, LLC will conduct the commercial UAS operation in a manner that will meet, and in many cases exceed, the current level of safety of commercial helicopter operations. UA that are less than 10 lbs., have a low noise signature, and ca rry no volatile fuel, will limit collateral damage in the event of catastrophic failure. The low expense of operation compared to cost prohibitive manned aviation alternatives allows a greater economic benefit to

businesses. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for these commercial purposes benefit the public interest in the following ways:

1. Reduces the collateral damage risks to life and property associated with low

altitude helic opter operations in undesirable portions of the height

- velocity envelope.

2. Increased economic wellbeing to local businesses via cost reductions.

3. Enabling aerial business solutions to be available to a larger market

Exemptions from the following regulations is r equested

. 14 C.F.R. Part 21 Subpart H

14 C.F.R. § 45.23(b)

14 C.F.R. § 91.7(a)

14 C.F.R. 91.9(b)

14 C.F.R. § 91.103

14 C.F.R. § 91.109(a)

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.215(b)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.409(a)(2)

14 C.F.R. § 91.417(a) & (b)Page 3 of 5

For each flight, Hangar Bravo 7, LLC:

1. Will contact the controlling air traffic organization to issue a NOTAM (when appropriate)

. 2. Will conduct a comprehensive worksite insp ection and analysis, identifying limits

of customer property or authorized access areas.

3. Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

4. Will operate in those areas only with the consent of the landowner or designated

re presentative.

5. Will identify potential obstructions or other hazards to safe operation.

6. Will clear the area of personnel or bystanders that are non

- essential to the operation, maintaining at a minimum, 500 feet away from non

- participating

persons.

7. Will cond uct a preflight safety briefing to Visual Observer (VO) and participating

persons.

8. Will at all times yield to manned air traffic.

9. Will operate within VLOS of both PIC and VO during daylight hours only.

10. Will maintain voice communications with VO and partici pating persons.

11. Will operate under visual flight rules, in visual meteorological conditions, for the airspace in which the flight is conducted.

12. Will not exceed the maximum altitude as defined in the COA under which flight authorized, as determined by the i nstalled GPS.

13. Will keep operating documents, manuals, authorizations and exemptions in a

binder co

- located with the GCS.

14. Will immediately terminate flight, in the safest manner possible, when safety to

person s or property becomes compromised.

15. Will terminat e flight, in the safest manner possible, when unable to comply with

these limitations or any other limitations granted as part of this exemption.

In order to remain at an altitude at or below the attitude prescribe d by the applicable
COA, relief is needed from Section 91.119 (c). By following these oper ating standards,

the commercial operation will meet an equivalent level of safety to the regulation in which relief is sought.

Unmanned Aircraft System Hangar Bravo 7, LLC , Inc. seeks exemption to operate a DJI Professional type UAS. Other UAS types may be requested in future amendments. The DJI is the primary aircraft in our ope ration for which we seek exemption. The UA will be flown via a

combi nation of RC control and tablet GCS. This UA type is a GPS equ ipped, multirotor helicopter

. A quad

- copter type rotorcraft utilizing four motors. Lithium

- polymer batteries power the UA.

The UA also has several fail

- safes for loss of RC signal, loss of G PS, and low battery as

outlined in the respective Operation Manu als. The UA display visual and emit an audible low battery alerts at which time the UA will automatically engage the landing seq uence.Page 4 of 5

Based upon those safeguards, I request exemption from Section 91.151(b) Fuel requirements for flight in VFR conditions.

Given the size, weight, speed, and controlled operating ar ea associated with the UA to

be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) is requested.

Exemption is sought from § 45.23 Marking of the aircraft.

The UA will display the registration number in the largest pract icable lettering.

Hangar Bravo 7, LLC seeks to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will be conducted accord ing t o operations manual and prudent judgment as previously outlined to determine the integrity and safety of the UA and associat ed equipment.

Further, relief is required from 91.7(a), which prohibi ts the operation of an aircraft

without an airworthiness certificate and 91.9(b) (2) requiring a n approved flight manual

in the aircraft. The UA will not be operating with an airworthiness certi ficate therefore,

this would be inappropriate. The UAS are too small to carry the operating do cuments so an equivalen t amount of safety can be achieved through keeping the operating

documents and manuals at the GCS.

UAS Pilot in Command (PIC) All UAS operators utilized by Hangar Bravo 7, LLC, with the exception of UAS
observers, will hold a Commercial Pilot Certificate or higher. This will ensure proper knowledge of the National Airspace System and promote a safe operational

environment.

Public Interest Given the above stated evidence, procedures, and precautions operating UAS commercially for the purposes of aeria l photography & videography, ma pping, power
line surveillance, agricultural crop surveillance, aerial inspections, data collection, augmented real estate listi ngs, commercial videos and other work related to aerial photography will ultimately be in the pub lic interest. These operations, when executed with prudence, will exc eed the current level of safety as the regulations from which exemption is sought. UA operatio ns will allow greater access to commercial aerial services that were not previously economica ll y feasible for many firms. This will provide a much needed economic uplift to the com munity and hence the public. UA operations are associated with less risk of collateral damag e to persons and property while limiting disruptive noise pollution associate d with low altitude aviation operations.Page 5 of 5

Summary

Pursuant to Section 333 of PL 112

- 95 commonly known as the “FAA Modernizati on and

Reform Act of 2012”, Hangar Bravo 7, LLC , hereby applies for authorization to conduct commercial unmanned aerial syste ms (UAS) operations for the p urposes of aerial photography & videography, mapping, aerial inspections, data collection, augmented real estate listings, commercial v ideos and other work related to aerial photography listings Rules for which exemption is sou ght:

14 C.F.R. Part 21 Subpart H

14 C.F.R. § 45.23(b)

14 C.F.R. § 91.7(a)

14 C.F.R. 91.9(b)

14 C.F.R. § 91.103

14 C.F.R. § 91.109(a)

14 C.F.R. § 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.215(b)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.409(a)(2)

14 C.F.R. § 91.417(a) & (b)

Thank you for your prompt attention and consideration. Please do not hesitate to contact me directly with any questions or concerns at 918.230.8682

Sincerely,

Dougl as Edward Ringering Owner, Hangar Bravo 7, LLC