Bruce Barnard Jr 341 Hilltop Drive GulfShores, AL. 36542 barnard.bruce.75@gmail.com

US Department ofTransportation, Docket Operations West Building Ground Floor Room W-12-140 1200 NewJerseyAvenue, SE Washington D.C. 2059

Dear Sir or Madam,

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (The Reform Act) and CFR Part II:
I, Bruce Barnard Jr, ownerand operatorofa Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that I, Bruce Barnard Jr, may operate UASs commercially in airspace regulated bythe FAA, as long as such operations are conducted within and underthe conditions outlined herein or as maybe established by the FAA as required by S,ection 333.

. I, Bruce Barnard Jr,, am requesting exemption from regulations listed below to perform aerial photography and videography of Real Estate and Landscape. All operationswill be'performed with the public's safety and rightto privacy safeguarded at all times.

Bruce Barnard Jr's UASs is aYuneec Q-500 Typhoon 4K weighing less than 55 lbs. including payload (CG03 camera). Itoperates ata speed of less than 40 knots and has the capability to hover and
movethevertical and horizontal plane simultaneously. It has an auto return to launch pointwhen battery power is under25%. The UASs will operate only within the line ofsight ofthe operatorwithin a protected flight area and at 200 feet AGL or less. These operations will notcreate a hazard to users of the National Airspace, Public, northe Environment.

I, Bruce Barnard Jr, respectfully request the grant ofan exemption to the following specific sections oftheTitle 14Code of Federal Regulations allowing meto operate lightweight UASs for commercial use,
14CFR 21, subpart H, 14 CFR 45.23 (b) 14CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119,**~1.121,** 91.151, (a), 91.203 (a) 

### & (b), 91.405 (a), 91.409 (a) (1), 91.409 (a) 

### & (b). 14 CFR 61.113 (a) 

### & (b).I, Bruce Barnard Jr, submitthis application in accordance with the Reform Act, 112 P.L. 95 331- 335, seeking relieffrom any currently applicable FAR's operating to prevent Bruce Barnard Jr's future commercial use ofsmall UASs to operate in the National Airspace System as described below. The Reform Act Section 332 provides for such integration ofcivil unmanned aircraft into our national airspace system as it is in the public's interestto do so. Bruce Barnard Jr's UAS meetsthe definition of "Small Unmanned Aircraft'' as defined in Section 331 and thereforthe integration ofthese UAS's are expressly contemplated by the Reform Act.
The very small nature ofthe UAS combined with the safe guards presented below will allow for the safe operation greaterthan that envisioned by Congress forthe FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also, due to the issue of UASs and the
areas and altitudes theywill operate approval ofthis exemption presents no national security issues and absolutely minimal safety concerns. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level ofenhanced safety, reduced emissions utilizing UAS's versus traditional aircraft as well as the economic impactof greatly reducing the cost ofaerial photographythereby benefitting the greater public's interest. Accordingly, the applicant requests thatthe FAA grant exemption ofthe requested without delay.
The following will be considered as binding limitations ofoperationsfor Bruce Barnard Jr's UAS: 1.) Flights will only occur during daylight hours. 2.) Flights will be operated in the line ofsight ofthe operator (PIC) and the observer (VSO). 3.} Flights will be terminated at any time ifweather and wind deteriorateto "unsafe forflight" by manufacturers recommendations (which are rain and/orwind that exceed 12mph/19kph.) 4.} The UAS weighs less than 55 lbs. 5.) Flights will be conducted/operated at 200ftACL or less. 6.} Crew will be operator and observer on all flight operations. 7.) Operator and Observer will remain in contact duringthe flight operation. 8.) The UAS operatorwill perform a check ofthe flight area and make certain ofthe safety ofall persons in the area. 9.} Consent will be obtained from all persons within the video capabilities ofthe unitto further reduce the chance ofviolating anyone's privacy. 10.}AII required FAA clearances will be obtained and distances from airports strictly observed. 11.}My UAS will return to home automatically in a safe mannerwith the home function activated 12.)When operated in conjunction with fishing vessels in the Gulf, a chase boatwill be used to operate the UAS at a safe distance from the main boat. 13.)Flights will only operate in VFR conditions. 14.}UAS has telemetry on the control to tell operator, batteryvolts, airspeed, the distance from operator, GPS position. 15.)Fiightteam will communicate by voice ofby using 2 way radios ifarea is too big to hear voice.16.)UAS will be used tovideo private outings and functions from a safe distance. 17.)When operating overor nearwaterthe UAS will be equipped with flotation devices so that recovery can be made to prevent lithium battery exposure to the watertable.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7 (a), 91.203 (a) (1). Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement ofnecessary certificates in relation to FAR 91.203 (a) (1). The size, weight, and defined area ofoperationsfor Bruce Barnard Jr's UAS flights permits exemption from Part 21 because they meet an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Bruce Barnard Jr's UAS meets orexceeds each ofthese elements.
14CFR 91.203 (a 

### & b) provides for carrying ofcivil aircraft certifications and registrations. These are inapplicable forthe same reason as stated above.

14 CFR 91.9 (b) (2). Civil Aircraft Flight manual in Aircraft. As there are no pilots or passengers, and given the size ofthe UAS this regulation is applicable.

14 CFR 91.7 (a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in theform contemplated by FARs this regulation is inapplicable.
14 CFR 61.113 (a) and (b): Private Pilot Privileges and Limitations Pilot in Command. Because the UAS is unmanned and will notcarry a pilot or passengers, the proposed operations can achieve a high level of safety ofoperation withoutthe required pilot license.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation ofcivil aircraft. It allows helicopters to be operated at loweraltitudes in certain conditions. I will only operate the UAS at or below 200 AGL. Flights will only be over private propertythatthe owner has consented to and all persons within the video/ picture area also give consent forfilming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 55lbs, operating below 500 AGL with flammable fuel. UAS operations present afar smaller risk to the public. Approval ofthese 333 exemptions allowing commercial operations ofsmall UASs in the service ofaerial photography will greatly enhance safety by reducing the overall risks associated with traditional aircraft. Traditional aerial photography requires large aircraftwith flammable fuel to fly in close proximityof populated areas and people in general. With the use ofsmall UAS of55lbs or less, battery operated and flying below 200ftAGL the risk of injuryofpeople on the ground orthe crew has been reduced or erased. The granting ofthe use ofsmall UASs by Bruce Barnard Jr will give potential sellers of Real Estate
a competitive edge in the market place.Granting Bruce Barnard Jr the above exemption will allow forthe expansion of UAS systems into the future for safe conduct offree enterprise and the enjoyment ofthe masses. I, Bruce Barnard Jr, respectfully request that the FAA grantthis exemption without delay. The FAA has the authorityto issue the exemption sought by Bruce Barnard Jr pursuant to the Federal Aviation Act, 85 P.l. 726 (1958) as amended (The Act.)

Sincerely,

Bruce Barnard Jr.