### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 1 April 21, 2015

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

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Matthew Q. Bellamy, Jr. , am writing pursuant to the FAA Modernizati on and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Matthew Q. Bellamy, Jr., an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Mat thew Q. Bellamy, Jr., m ay operate my small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Matthew Q. Bellamy, Jr., am a small business owner with in the State

of Florida ; experienced in flying hobby type helicopters for recreational purposes and certificated airplane and helicopter pilot . I have added a hobby grade quad

- copter UAS (Phantom 2 Vision+) to my inventory equipped with an attached camera with intent for aerial videography/cinematography to augment real estate list ings, land development, events

, promotional videos ; following exemption and approval by the FAA.

My, Matthew Q. Bellamy, Jr 's, exemption request would permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace.

Predetermined in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate

li sting videos/photos. Currently, unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe legally operate similar lightweight, remote controlled

UAS’s in the Na tional Airspace System

.

I, Matthew Q. Bellamy, Jr., have personally instilled safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightwe ight UAS's specific to real estate video and photography usage as I, Matthew Q. Bellamy, Jr., record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future p rotocol and safety regulation s

.

Granting my, Matthew Q. Bellamy, Jr ’s, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate

UAS's into the , but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the ” under Section 333(c) of the Reform Act specific to the use of UAS's for real

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 2 estate, photography and videography purposes

. Further I, Matthew Q. Bellamy, Jr., will conduct my operations in compl iance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Matthew Q. Bellamy, Jr., respectfully request the grant of an exemption all owing me to operate ultra light weight, remote controlled UAS’s to enhance real estate listing videos for homeowners who cannot afford expensive mann ed aircraft. This will promote local economic growth through increased employm ent and increased tax base. This will keep public safety in mind by keeping heavier manned aircr aft conta ining combustible

fuel that poses potential public hazard.

I. Contact Information:

Matthew Q. Bellamy, Jr., Owner Aerial 360 Imaging

135 Jenkins Street

Suite 105B

- #201 St. Augustine, FL 32086 Office: (904) 910

- 5309

Email: mbellamy@aerial360imaging.com or aerial360imaging@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Matthew Q. Bellamy, Jr Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a ) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Matthew Q. Bellamy, Jr seeks and the Reason He Seeks Such

Relief:

I, Matthew Q. Bellamy, Jr., submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent

me, Matthew Q. Bellamy, Jr., contemplated commercial cinematic, academic and other flight operations within the National Airspace System . The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our National Airspace System as it is in the public’s interest to do so. My, Matthew Q. Bellamy, Jr ’s, ultra light weigh t UAS meets

the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I

would like to operate my ultra light weight UAS prior to the time per iod by which the Reform Act requires the FAA to promulgate rules governing such craft.

Thereby, providing direct experience and valuable information for formal regulation that can

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 3 be administered uniformly to all real estate related UAS aerial video and p hotography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in

our National Airspace System . Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operat ed near airports or heavily populated areas; and, w hether the UAS will be operated by line of sight. Each of these items

reflects in favor of an exemption for me, Matthew Q. Bellamy, Jr . My UAS utilizes four (4)

counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) p ounds (far below the

maximum 55

- pound limit); including camera with gimbal.

I, Matthew Q. Bellamy, Jr., consider safety as foremost with eac h flight. My small

- unmanned aircraft is designed to hover in place via GPS and operate in less than a 24

- knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazar d. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50

- 100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may

ap proach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight (LOS) of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (3) to seven (7) minutes, with an altitude under one hundred fifty (150) feet. I, Matthew Q. Bellamy, Jr., utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is
up to twenty

- five (25 ) minutes . I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for cras h, loss of control or hazard. Reserve batteries are at hand with

each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, which could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain

familiarization with the char acteristics of this specific UAS's performance under different temperature and weather conditions.

I, Matthew Q. Bellamy, Jr ’s, am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft and will not “c reate a hazard to users of t he National A irspace

S ystem or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directi ve to integrate UAS's into the National Airspace System

. Matthew Q. Bellamy, Jr ’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 4 IV. How Matthew Q. Bellamy, Jr ’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has been around

for a long time through manned fixed

- wing aircraft and helicopters. For small budget real estate companies and average homeowners

, the expense of such aerial videography is cost prohibitive . Only large companies and high

- end Realtors or luxury homeowners can afford to absorb such expense. Depriving non

- luxury homeowners and lower budget Realtors from a valuable marketing tool. My, Ma tthew Q. Bellamy, Jr 's, UAS pose no t hreat since size and

lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially

flown UAS's into the National A irspace System , hence the passing of the Reform Act. Granting my, Matthew Q. Bellamy, Jr ’s, exemption request furthers the public interest through academic/visual awareness of the geo graphical benefits in and around St. Augustine, Florida, the Nations Olde st City. My ultra light weight UAS is battery powered and creates no

emissions that can harm the environment. Th e consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain

combu stible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by

, minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting

me, Ma tthew Q. Bellamy, Jr., to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the St. Augustine community for companies looking to relocate or build in the Northeast Florida area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Matthew Q. Bellamy, Jr ’s Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing

Rule:

My, Matthew Q. Bellamy, Jr ’s, exemption will not adversely affect safety. Quite the
contrary, for the reasons stated permitting me, Matthew Q. Bellamy, Jr.

, to log more flight

time in FAA controlled airspace, with communication with the FAA, will allow me to

contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for other individuals and development in coope ration with the FAA. In addition I, Matthew Q. Bellamy, Jr., submit the following representations of enhancements to current aerial videography and photography for r eal estate and other opportunities , which may present itself :

My UAS weighs less than 5 pounds co mplete with a small ultra light weight high quality

built

- in camera; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate for 3

- 7 minutes per fl ight; I will land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remo te control only by visual line of sight (VLOS) ; My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if

communic ation with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 5 lights, airports and actively populated areas; I conduct extensive pre

- flight inspections and protocol, during which safety carries prim ary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger.

My, Matthew Q. Bellamy, Jr ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial

UA S i nto our , helicopters are the primary means of aerial video and photography for community awareness and real estate.

First, the potential loss of life is diminished because UAS's carry no peo ple on board and I only operate my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.

Accordingl y, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certifi cates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, Matthew Q. Bellamy, Jr ’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act.

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certifica te requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations.

My, Matthew Q. Bellamy, Jr ’s, current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) pr ohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined

.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others

.

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 6 14 C.F.R. § 91.121 regarding altimeter settings are inapplicable in so far as my UAS utili zes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent

lev el of safety will be achieved by maintaining any such required certifications and registrations by me, Matthew Q. Bellamy, Jr

.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft

with dimensions s maller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter wi th the UAV will see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. I, Matthew Q. Bellamy, Jr., can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Matthew Q. Bellamy, Jr., to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be op erated at lower altitudes in certain conditions. My UAS will never operate at a n altitude greater than 200 AGL, safely

below the standard of 400 AGL.

I, Matthew Q. Bellamy, Jr., will however operate my UAS in safe areas away from public and traffic, prov iding a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1 ); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspection s, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Matthe w Q. Bellamy, Jr 's, UAS. However, as a safety precaution I inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R.

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 7 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21 , Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 bec ause my, Matthew Q. Bellamy, Jr ’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Sec tion 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 1 4 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Matthew Q. Bellamy, Jr

., seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (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. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Matthew Q. Bellamy, Jr’s , small unmanned vehicle/lightweight unmanned aircraft vehicle in community

aware ness, real estate operations and other opportunities which may present itself. Currently,

area awarenes s and real estate aerial videography/photography relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public.

Granting my, Matthew Q. Bellamy, Jr ’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS air craft do es not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight time. Further, I operate at lower altitu des and in controlled airspace eliminating potential public risk flying to and from established airfields.

I, Matthew Q. Bellamy, Jr., have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal collection of

information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modern ization and Reform Act of 2012.

There are no personnel on board my, Matthew Q. Bellamy, Jr ’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Matthew Q. Bellamy, Jr ’s, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly

### Aerial	360	Imaging,	St.	Augustine,	FL

– Section	333	Exemption	Petition 8 I, Matthew Q. Bellamy, Jr. , respectfully request that the FAA grant my exemption request

and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Matthew Q. Bellamy, Jr., Owner Low Altitude Aerial Solutions, LLC

d.b.a. Aerial 360 Imaging

135 Jenki ns Street

Suite 105B

- #205 St. Augustine, Florida 32086

Attached: Preflight Form and Checklist