BAPCO

1

September 15, 2015

U.S. Department of Transportation,

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC, 205a90

RE: Petition for Exemption Pursuant to Section 333 of the Federal Aviation 

Administration Modernization and Reform Act of 2012 and Part 11 of the Federal 

Aviation Regulation to Operate Small Unmanned Aircraft Systems.

Summary for Publication in the Federal Registry

Dear Madam or Sir,

Bartlett Aerial Productions Company is seeking an exemption from the Federal Aviation 

Regulations (FARS) pursuant to Section 333 of the Federal Aviation Administration (FAA) 

Modernization and Reform Act (FMRA) of 2012 and 14 CFR Part 11. This request for 

exemption would enable Bartlett Aerial Productions Company to operate unmanned aircraft 

systems (UASs) within the National Airspace System (NAS) for commercial purposes. The 

commercial purposes anticipated by Bartlett Aerial Productions Company involve aerial data 

acquisitions, including without constraint to any aerial reconnaissance requested by clients 

within the private and public sectors.

The exemptions being requested pursuant to Section 333 of the FMRA and the FARs are as 

follows:

 Title 14 CFR Part 61.113(a) & (b) – Private pilot privileges and limitations: Pilots in 

command

 Title 14 CFR Part 91.7(a) - Civil aircraft airworthiness.

 Title 14 CFR Part 91.9(c) - Civil aircraft flight marking requirements

 Title 14 CFR Part 91.119 – Minimum safe altitudes: general

 Title 14 CFR Part 91.121 – Altimeter settings

 Title 14 CFR Part 91.151(b) – Fuel requirements for flight in VFR conditions

 Title 14 CFR Part 91.405(a) – Maintenance required

 Title 14 CFR Part 91.407(a)(1) - Operation after maintenance, preventive 

maintenance, rebuilding, or alteration

 Title 14 CFR Part 91.409 (a) – Inspections

 Title 14 CFR Part 91.417 (a) & (b) – Maintenance records

Bartlett Aerial Productions (BAPCO) was founded in the wild and wonderful state of West 

Virginia in 2014. Seeing the opportunities available, BAPCO has developed a vast portfolio 

of charitable and recreational flights that make us the reliable choice for aerial data 

acquisitions in the area. Once FAA exemption has been granted, BAPCO will be able to fully

engage in new opportunities that were otherwise noted as non-recreational.

Acquiring data via UAS will make (BAPCO) capable of composing a feasible solution all the 

while improving overall safety and reducing environmental impacts. These factors not only 
BAPCO’s Petition for Exemption

from Section 333 2

provide benefits to our clients, they also provide additional benefits to the public as well. 

UASs will enable BAPCO to explore additional markets beyond those described in the 

abovementioned executive summary while staying in compliance with the present and future 

regulations. Enhanced safety measures by using UASs will be recognized by the reduction of 

ground crews needed to gather the same data using traditional methods and reducing the 

payload and overall weight of the UAS in comparison to other manned aircraft systems. The 

welfare of the environment will be sustained since the UASs that will be used by BAPCO

will not emit carbon dioxide (CO2). Additionally, UASs will also reduce the amount of 

necessary commutes to proposed project locations as the aerial data can often be acquired in 

one visit, thereby reducing motor vehicle CO

2

emissions. 

BAPCO has established the proposed UASs to be used for commercial purposes. The 

proposed UASs and associated safety features and technical specifications described herein 

have been established as the minimum standards for which future UASs may be purchased. 

The said UASs to be used are the DJI Phantom 3 Professional, DJI Inspire 1, and the DJI 

Spreading Wings S1000+. Additional information pertaining to the UASs, operations, safety 

precautions, and supplementary information will be described herein.

Identity and Contact Information of the Petitioner:

Name: Brandon G. Bartlett, Bartlett Aerial Productions Company

Address: 17 Orchard Acres Drive

Morgantown, WV, 26508

Phone: 304-677-3366

Email: bbartlett316@gmail.com

Proposed UASs and Operation

To introduce brevity to the exemption process, BAPCO has listed the aforementioned UASs

in exemptions that have been previously granted by the FAA. A summary table and links to 

the respective manufacturer’s manuals describing various characteristics of the proposed 

UASs have also been included for detailed examination of proposed UAS safety features. 

BAPCO is seeking an exemption to operate the DJI Phantom 3 Professional UAS. The 

Phantom 3 Professional has been listed as the prescribed UAS in a number of exemptions 

granted by the FAA. Said exemptions include: Exemption Nos. 12727, 12706, and 12691.

Information regarding the DJI Phantom 3 Professional can be found in Table 1 and/or within 

the manufacturer’s manuals by following the links below.

DJI Phantom 3 Professional User Manual:

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en.

pdf

DJI Phantom 3 Professional Safety Guidelines:

http://download.djiinnovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf

BAPCO is seeking an exemption to operate the DJI Inspire 1 UAS. The Inspire 1 has been 

listed as the prescribed UAS in a number of exemptions granted by the FAA. Said 

exemptions include: Exemption Nos. 12846, 12835, and 12759. Information regarding the 
BAPCO’s Petition for Exemption

from Section 333 3

DJI Inspire 1 can be found in Table 1 and/or within the manufacturer’s manuals by following 

the links below.

DJI Inspire 1 User Manual:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

DJI Inspire 1 Safety Guidelines:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf

DJI Inspire 1 Maintenance Manual:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf

BAPCO is seeking an exemption to operate the DJI Spreading Wings S1000+ UAS. The 

S1000+ has been listed as the prescribed UAS in a number of exemptions granted by the 

FAA. Said exemptions include: Exemption Nos. 12721 and 12706. Information regarding the 

DJI Spreading Wings S1000+ can be found in Table 1 and/or within the manufacturer’s 

manual by following the link below.

DJI Spreading Wings S1000+ User Manual:

http://download.djiinnovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

Table 1 - UAS Information

UAS Name DJI Phantom 3 

Professional

DJI Inspire 1 DJI Spreading 

Wings S1000+

Maximum gross weight 2.8 lbs. 6.5 lbs. 24 lbs.

Maximum dimension 24 in. 18 in. 41 in.

Maximum air speed 35 mph 46 mph 56 mph

Power Source 6000 mAh 5700 mAh 20000 mAh

Max flight time 23 minutes 18 minutes 15 minutes

Maximum Radio link range 1.24 miles 1.24 miles 1.24 miles

BAPCO will operate within the limitations listed herein which comply with equivalent or 

greater safety measures under the current regulatory framework. Said conditions and 

limitations agreed upon by BAPCO to conduct commercial operations under an exemption 

issued by the FAA comprise of the following.

1. Proposed UASs with equivalent or greater safety features shall weight less than 55 

pounds including payload.

2. Operations for the purposes of closed-set motion picture and television filming will 

not be performed.

3. The UA will be operated below speeds of 100 miles per hour. Either groundspeed 

and/or calibrated airspeed will be used to confirm speeds are restricted to less than 

100 miles per hour.

4. The UA will be operated at an altitude of no more than 400 feet above ground level 

(AGL) and will be reported in feet AGL.
BAPCO’s Petition for Exemption

from Section 333 4

5. The UAS will always be operated within visual line of sight (VLOS) of the pilot in 

command (PIC)

6. Operations may utilize a visual observer (VO) when available. The UA will always 

be operated within visual line of sight (VLOS) of the PIC and VO. The VO and PIC 

will always maintain verbal communication during operations. The PIC will be 

designated prior to flight and will remain the PIC for the duration of the flight. The 

PIC will ensure the VO can perform the duties required of the VO.

7. The operating documents will be accessible during UAS operations and made 

available to the Administrator upon request. Any revisions will be presented to the 

Administrator or any law enforcement official upon request.

8. Any UAS that undergoes maintenance or alterations which affect the UAS operation 

or flight characteristics will undergo a functional test flight prior to conducting 

further operations. The functional test flight will only be conducted by the PIC with a 

VO (if available) and will remain at least 500 feet from other people and will be 

conducted in a manner as to not pose a hazard to property and people.

9. The operator will maintain and inspect the UAS to ensure it is in safe operating 

condition.

10. Pre-flight inspections will be conducted to confirm the UAS is in safe operating 

condition prior to each flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the UA will undergo the necessary maintenance required to 

render the UAS in a safe operating condition.

11. The operator will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection and life limit requirements for the aircraft and aircraft 

components.

12. Each UAS operation must comply with all manufacturer safety bulletins.

13. The PIC will hold a valid United States (US) driver’s license issued by a state.

14. The PIC will not allow any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS is to be operated 

under the aforementioned exemption request. PIC qualification flight hours and 

currency will be logged.

15. UAS operations will only be conducted during the day. Every operation will be 

conducted under visual meteorological conditions (VMC), not under special visual 

flight rules (SVFR).

16. The UA will not be operated within five nautical miles of an airport or an airport 

reference point (ARP).

17. The UA will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than three statute miles from the 

PIC.

18. In the case the UAS loses communications or loses its GPS signal, the UA will be 

returned to a pre-determined location within the private or controlled-access property.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC will only operate the UA if there is enough available power or reserve power 

for at least five minutes of flight. This is in consideration of the wind and forecast 

weather conditions.

21. In the case necessary of a COA, all operations will be conducted in accordance with 

an Air Traffic Organization Certificate of Waiver or Authorization (ATO) (COA).

22. All and/or any aircraft markings will be as large as practicable.

23. The required documents or any documents used by the operator to ensure safe 

operation and flight of the UAS will be made available to the PIC at the ground 

control station of the UAS any time the aircraft is operated to the Administrator or 

any law enforcement official
BAPCO’s Petition for Exemption

from Section 333 5

24. The UA will always remain clear and give way to all manned aviation operations and 

activities.

25. The UAS will not be operated by the PIC from any moving vehicle or device.

26. All flight operations will assessed by the PIC to determine the risks of operating 

close to objects and what, if any, hazards can be identified. Once the assessment has 

been made the PIC will 

27. All operations will be conducted over private or controlled –access property with 

permission (for each flight) from the property owner/ controller or authorized 

representative.

28. Any incident or flight operation that passes beyond the operational boundaries as 

defined by the applicable COA will be reported to the FAA’s UAS Integration Office 

within 24 hours. Any incident will be reported to the National Transportation Safety 

Board (NTSB) in accordance with the NTSB’s instructions.

Operator Credentials

BAPCO’s proposed PIC has demonstrated proficiency in safe operation of the UAS. The PIC

has flown innumerable successful flights in variable weather conditions and environments as

a hobbyist similar to the proposed operations within this exemption request. The experience 

gained by BAPCO’s proposed PIC has assured the safe operations of UASs within the NAS 

based on current regulations. Possessing a private, recreational, or sporter pilot certificate, 

though obliging, is a superfluous requirement that does not warrant a UAS pilot of their 

ability to operate safely within the NAS. BAPCO will take the necessary steps to satisfy any 

future protocols implemented by the FAA that require the PIC’s on staff to acquire and 

furnish certifications that are applicable to safe operation of UASs.

Operator Training

BAPCO is predicting a lush marketing future for the integration of UASs in the NAS. With 

such expansion will require additional PIC’s and VO’s for prospective operations. To 

promote safe operations, BAPCO will require adequate training standards before any 

commercial operations are performed by introductory PIC’s and VO’s. Introductory PIC’s

and VO’s must have accumulated and logged at least 25 hours as a rotorcraft and/or

multirotor pilot. Once he/she has achieved this, the introductory PIC’s and VO’s will be 

accompanied on their first three commercial operations by an experienced PIC to ensure 

overall safety and flight standards and maintained and implemented.

Public Interest and Safety

Upon approval of the current petition for exemption, BAPCO will be able to provide aerial 

data acquisitions to our clients and the public in a safe, effective, and economical manner. 

The use of UASs will increase safety by reducing the need for ground crews. This removal of 

a majority of ground crews will thwart the opportunities of encountering hazards that are 

typically encountered on a day to day basis.

In addition to the removal of ground crews, data acquired via UASs will prove to be a more 

effective practice with respect to time and cost. Today’s available UAS technology is capable 

of achieving equivalent or superior accuracies meanwhile reducing the time taken by a 

ground crew to complete similar tasks, thus facilitating overall faster project turnover and 

cost reduction. Faster project turnover will also enable BAPCO to serve more clients at a 

greater capacity, thus promoting economic growth.
BAPCO’s Petition for Exemption

from Section 333 6

Certain projects soon to be encountered by BAPCO may have required aerial data 

acquisitions from large manned aircraft. The use of UASs will ultimately replace manned 

aircraft and reduce the space occupied from the NAS, thus providing a safe, cost effective 

solution to traditional methods. Furthermore, manned aircraft is carrying a large payload, 

requires the use of flammable fuel sources, travels at a high rate of speed, and emits a loud 

sound. UAS’ infinitesimal payload, electronic power source, reduced air speed, and quiet 

rotors promote safety within the NAS and to the public when utilized within the limitations 

specified in this exemption. Finally UASs do not use fossil fuels to power the aircraft, do not 

emit CO2, and have virtually no effect on the environment with respect to global warming.

As mentioned in the preceding paragraphs, safety improvements can be recognized by those 

who are in the air as well those who are on the ground. Reducing the size and payload of 

traditional aircraft, replacing flammable fuel sources with electronic sources, reducing air 

speed, removing humans from aerial and ground operations are, in summary, the major 

constituents in which positive safety improvements would be made.

Exemptions Requested Under Section 333

BAPCO is requesting for exemptions from the following regulations:

 Title 14 CFR Part 61.113(a) & (b) – Private pilot privileges and limitations: Pilots in 

command

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers 

or property for compensation or hire; nor may that person, for compensation or hire, act as 

pilot in command of an aircraft.; (b) A private pilot may, for compensation or hire, act as 

pilot in command of an aircraft in connection with any business or employment:

 Title 14 CFR Part 91.7(a) - Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

 Title 14 CFR Part 91.9(c) - Civil aircraft flight marking requirements

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

 Title 14 CFR Part 91.119 – Minimum safe altitudes: general

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. (b) Over congested 

areas. Over any congested area of a city, town, or settlement, or over any open air assembly 

of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above 

the surface, except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) 

Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface
BAPCO’s Petition for Exemption

from Section 333 7

 Title 14 CFR Part 91.121 – Altimeter settings

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating (1) 

Below 18,000 feet MSL or (2) At or above 18,000 feet MSL, to 29.92′′ Hg.

 Title 14 CFR Part 91.151(b) – Fuel requirements for flight in VFR conditions

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

 Title 14 CFR Part 91.405(a) – Maintenance required

Each owner or operator of an aircraft—(a) Shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter.

 Title 14 CFR Part 91.407(a)(1) - Operation after maintenance, preventive 

maintenance, rebuilding, or alteration

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless (1) It has been approved for return to service by 

a person authorized under §43.7 of this chapter.

 Title 14 CFR Part 91.409 (a) – Inspections

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had— (1) An annual inspection in 

accordance with part 43 of this chapter and has been approved for return to service by a 

person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter. No inspection performed 

under paragraph (b) of this section may be substituted for any inspection required by this 

paragraph unless it is performed by a person authorized to perform annual inspections and is 

entered as an “annual” inspection in the required maintenance records.

 Title 14 CFR Part 91.417 (a) & (b) – Maintenance records

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) 

of this section: (1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. (2) Records containing the following information: (i) The total time 

in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status 

of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time 

since last overhaul of all items installed on the aircraft which are required to be overhauled 

on a specified time basis. (iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under which the aircraft and its 

appliances are maintained. (v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of compliance, the AD or safety directive 

number and revision date. If the AD or safety directive involves recurring action, the time and 

date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this 
BAPCO’s Petition for Exemption

from Section 333 8

chapter for each major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. (b) The owner or operator shall retain the following records for 

the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 year after the work is 

performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a 

registered owner or operator under §43.11 of this chapter shall be retained until the defects 

are repaired and the aircraft is approved for return to service.

Reason for Relief and Action Taken

The reasons for relief and the proposed action taken is provided in the following pages:

 Title 14 CFR Part 61.113(a) & (b) – Private pilot privileges and limitations: Pilots in 

command

BAPCO is requesting relief from this CFR in order to conduct commercial operations. An 

equivalent level of safety will achieved by the UAS and PIC. Respectfully, the UAS’s 

proposed will not carry pilots, passengers, or heavy payloads and the PIC has established 

his/herself as a recreational pilot with several years and hours of flight experience. Moreover, 

a pilot’s license does not explicitly ensure safe operations of UASs within the NAS.

 Title 14 CFR Part 91.7(a) - Civil aircraft airworthiness.

Because BAPCO is proposing UASs that meet the requirements of Section 333, BAPCO will 

not require an airworthiness certificate. BAPCO will confirm that each UAS is in an 

airworthy condition based on the applicable operating documents prior to every flight 

operation.

 Title 14 CFR Part 91.9(c) - Civil aircraft flight marking requirements

Because there is not an established registration process for UASs, BAPCO is requesting relief 

from this CFR. Additionally, the small sizes of the UASs proposed do not provide sufficient 

room to place legible aircraft markings or fireproof placards. However, BAPCO is willing to 

place aircraft markings by an auxiliary method which may be confined to the available 

surface area on each UAS as to not hinder the visibility of the UAS.

 Title 14 CFR Part 91.119 – Minimum safe altitudes: general

Since the UASs in this exemption will be operating below 400 feet AGL, satisfaction of this 

CFR cannot be realized. BAPCO will achieve an equivalent level of safety by requesting the 

permission of the property owners prior to each flight operation. Said property owners will be 

informed of the proposed flight operations, flight paths, and plausible risks to persons or 

property on the ground. Given the small size and gross weight of the proposed UASs, such 

risks will be infinitesimal in comparison to large manned aircraft. Additionally, operations 

will not be conducted by BAPCO over congested areas.

 Title 14 CFR Part 91.121 – Altimeter settings

Because BAPCO will not have a typical barometric altimeter on board, BAPCO is requesting 

exemption by offering an alternative measure. BAPCO will acquire altitude information via 
BAPCO’s Petition for Exemption

from Section 333 9

Global Positioning System (GPS) equipment and radio communication telemetry, which will 

provide active data monitoring for each flight. Along with the operational limitations and 

conditions set forth by BAPCO, this altitude information will used to ensure a level of safety 

as required by Part 91.121.

 Title 14 CFR Part 91.151(b) – Fuel requirements for flight in VFR conditions

BAPCO has proposed UASs that will be able to safely operate within these parameters. Each 

UAS will be able to fly during daylight hours in VCM under VFR conditions with enough 

power to fly for a total duration of 15 minutes to the first point of intended landing and to fly 

after that for at least five minutes assuming normal cruising speed.

 Title 14 CFR Part 91.405(a) – Maintenance required

For the reason that this CFR applies to aircraft with an airworthiness certificate, BAPCO is 

requesting relief from this Part because an equivalent level of safety will be ensured. BAPCO

will use experienced technicians to perform maintenance and alterations, or on its 

UASs using methods prescribed in the operating documents. Furthermore, BAPCO will 

document and retain all maintenance records for its UASs.

 Title 14 CFR Part 91.407(a)(1) - Operation after maintenance, preventive 

maintenance, rebuilding, or alteration

For the reason that this CFR applies to aircraft with an airworthiness certificate, BAPCO is 

requesting relief from this Part because an equivalent level of safety will be ensured. BAPCO

will use experienced technicians to perform maintenance and alterations, or on its 

UASs using methods prescribed in the operating documents. Furthermore, BAPCO will 

document and retain all maintenance records for its UASs.

 Title 14 CFR Part 91.409 (a) – Inspections

For the reason that this CFR applies to aircraft with an airworthiness certificate, BAPCO is 

requesting relief from this Part because an equivalent level of safety will be ensured. BAPCO

will use experienced technicians to perform maintenance and alterations, or on its 

UASs using methods prescribed in the operating documents. Furthermore, BAPCO will 

document and retain all maintenance records for its UASs.

 Title 14 CFR Part 91.417 (a) & (b) – Maintenance records

For the reason that this CFR applies to aircraft with an airworthiness certificate, BAPCO is 

requesting relief from this Part because an equivalent level of safety will be ensured. BAPCO

will use experienced technicians to perform maintenance and alterations, or on its 

UASs using methods prescribed in the operating documents. Furthermore, BAPCO will 

document and retain all maintenance records for its UASs.

Conclusion

Bartlett Aerial Productions Company petitions for exemption from the FAR’s pursuant to 

Section 333 of the FMRA of 2012 to enable commercial operations of aerial data acquisitions 

within the private and public sectors. Upon approval of these exemptions, BAPCO will be 
BAPCO’s Petition for Exemption

from Section 333 10

able to provide benefits to the sectors previously mentioned which are justly in the public 

interest all the while improving safety within the NAS. Consider this exemption earnestly 

based on the information provided herein and approve the commercial operations of UAS’s in 

the NAS.

Truly,

Brandon G. Bartlett

Proprietor/Operator

Bartlett Aerial Productions Company