US Department of Transportation

Federal Aviation Administration

800 Independece Ave, SW

Washington, DC 20591

Dear Exemption Manager,

In reference to docket number FAA-2015-1523. It has been brought to my attention that there has bene 

a request for additional information posted under ID FAA-2015-1523-0002. This letter requested the 

following additional information:

- The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

- The reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to that provided by the rule form which you seek 

exemption.

- Any additional information, views, or arguments available to support your request.

Section 1: The reasons why granting the request would be in the public interest and how it would 

benefit the public as a whole.

Granting this request for exemption would further communicate the importance of UAS safety 

throughout the general public. While many hobbyists do not have plans for safety nor do they know the 

rules of airspace governed by the FAA there is a need to grant exemptions to individuals, such as myself, 

who plan to strictly adhere to all rulemaking procedures set forth by the FAA and follow these rules. I 

plan to understand any and all rules as it pertains to the hobby and my particular aircraft. 

For example, an amateur photographer or videographer may be approached to take video or 

pictures for events such as sporting events, races, or simply for a new vantage point a business would 

like to show to the public without knowing the rulings for this procedures necessary for safe operation. I 

intend to operate my UAS in a safe manner as previously described in the original docket and promote 

the safe flying of a UAS for commercial use as I plan to use the UAS for monetary compensation for 

individuals or businesses looking to get pictures which include but are not limited to; pictures of their 

business, pictures of land, or pictures of any operations being performed. 

This operation also includes any videography that will be performed for compensation in order 

to promote a brand or survey operations such as a work zone or construction project with new products 

which companies seek to promote. This may also include aerial videography, which companies choose 

to promote action sports with the strict consideration of using my particular UAS and how it will 

operate.
Section 2: The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule form which you seek 

exemption.

Granting exemption would not adversely affect safety of individuals, wildlife or other structures. 

The UAS will remain clear of all objects and structures as well as persons by obtaining a minimum range 

of safety from the FAA or otherwise specifically requesting written consent for a person or structure to 

be within the safe operating range of the UAS. Additionally any necessary barriers or buffers will be in 

place in order to ensure safe operating distances are met by the UAS operator (Rocky Babcock). This 

does not include closed set filming or photography but will pertain to recreational areas or private land 

or public areas as requested by an individual or business.

As previously stated, recreational hobbyists that attempt to provide services like this may not 

have required documentation or the necessary pre-flight checklist as well as knowledge of the rules set 

forth by the FAA. In order to maximize safety all FAA rules will pertain to any and all UAS operations 

performed by myself via the DJI Inspire 1 aircraft. I seek to find the right rules and guidelines to safely 

operate the Inspire 1 in a manner appropriate for any weather conditions or terrain in order to provide

the safety of any standing structures or people in the surrounding area. 

Section 3: Any additional information, views, or arguments available to support your request.

As a recreational hobbyist of 5 years in the radio controlled industry, I have a working 

knowledge of various parts, systems, and necessary safety knowledge for the operation of the Inspire 1 

for commercial use. I began flying small helicopters and progressed to larger, acrobatic helicopters that 

I continue to use to this day. This began my interest in these hobbies and much of my personal life 

involves repairing, operating and troubleshooting various small to mid-size helicopters strictly for 

recreational use.

Upon receiving the gift of the DJI Inspire 1 I have been approached by various individuals 

interested in any services I may provide with the UAS but I have turned down all inquiries as they would 

not be considered recreational and would fall under the commercial use category.

As far as safety is concerned, I am currently a large part, in my professional career, in charge of 

the safety operations of my current company as well as my previous company. I have been in the safety

regulation side of daily operations of various companies coming on to 4 years now, and understand the 

importance of safety as it pertains to any commercial situation. I do possess a knowledge and 

inclination to act within safety guidelines as I understand how disastrous not following any particular 

procedure may be.

The primary reason for my request for exemption doe include safety. I have been approached 

to gather information, video and pictures of a traffic control work zone. There is a style of sheeting 

called ‘Diamond Grade’ sheeting for traffic drums seen in construction zones. The Michigan Department 

of Transportation is interested in making this sheeting, which is the highest reflectivity you can get for 

this type of product, a requirement for all road construction projects. The company that wants this 

information wants to show a work area where this sheeting is being used and draw comparisons to 

show how much more visible this sheeting is to motorists than current sheeting required by the MDOT. 
This is not something that will be provided by myself until I have the required exemption to do so. 

These operations would not include any flight over any passing vehicles but would be performed any 

required distance away from people, vehicles and other structures which the Inspire 1 could cause 

harm.

Additionally I have been approached to provide videography and photography services for 

companies in order to take pictures of their inventory contained in their outdoor, enclosed yard areas. 

With these particular instances in mind I would like to gain exemption in order to offer my services for 

compensation as requested by companies or individuals.

I do seek to be as safe as possible in my operations and do understand the rules of the airspace. 

I intend to be a hobbyist (currently) that exemplifies a working knowledge of commercial use of the UAS 

and provide services in a safe and professional manner while adhering to the rules of the FAA.

I thank you for your consideration and look forward to hearing back from you.

Sincerely,

Rocky Babcock