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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 333 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 

Colorado Springs, CO 80923

Hangar Bravo 7, LLC is a Limited Liability Company formed under the State laws of 

Colorado on or about January 1, 2007 with Douglas Edward Ringering as 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 photography & videography, mapping, 

aerial inspections, data collection, augmented real estate listings, commercial videos 

and other work related to aerial photography in the NAS. Hangar Bravo 7, LLC does not 

intend to use for closed set filming. Flight operations will utilize the off the shelf DJI 

family of unmanned aircraft. Conduct of UA operations 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 that 
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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 heightvelocity 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 carry 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 helicopter 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 requested.

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)
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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 inspection 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

representative.

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 conduct 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 participating 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 installed 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 

persons or property becomes compromised.

15.Will terminate 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 prescribed by the applicable 

COA, relief is needed from Section 91.119 (c). By following these operating 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 operation for which we seek exemption. The UA will be flown via a 

combination of RC control and tablet GCS. This UA type is a GPS equipped, 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 GPS, and low battery as 

outlined in the respective Operation Manuals. The UA display visual and emit an audible 

low battery alerts at which time the UA will automatically engage the landing sequence. 
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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 area 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 practicable 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 according to operations 

manual and prudent judgment as previously outlined to determine the integrity and 

safety of the UA and associated equipment. 

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

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

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

this would be inappropriate. The UAS are too small to carry the operating documents so 

an equivalent 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 aerial photography & videography, mapping, power 

line surveillance, agricultural crop surveillance, aerial inspections, data collection, 

augmented real estate listings, commercial videos and other work related to aerial 

photography will ultimately be in the public interest. These operations, when executed 

with prudence, will exceed the current level of safety as the regulations from which 

exemption is sought. UA operations will allow greater access to commercial aerial 

services that were not previously economically feasible for many firms. This will provide 

a much needed economic uplift to the community and hence the public. UA operations 

are associated with less risk of collateral damage to persons and property while limiting 

disruptive noise pollution associated with low altitude aviation operations.
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Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and 

Reform Act of 2012”, Hangar Bravo 7, LLC, hereby applies for authorization to conduct

commercial unmanned aerial systems (UAS) operations for the purposes of aerial 

photography & videography, mapping, aerial inspections, data collection, augmented 

real estate listings, commercial videos and other work related to aerial photography 

listings Rules for which exemption is sought:

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, 

Douglas Edward Ringering

Owner, Hangar Bravo 7, LLC