Bruce Barnard Jr 

341 Hilltop Drive 

Gulf Shores, AL. 36542 

barnard.bruce. 75@gmail.com 

US Department of Transportation, Docket Operations 

West Building Ground Floor Room W-12-140 

1200 New Jersey Avenue, SE 

Washington D.C. 2059 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 

CFR Part II: 

I, Bruce Barnard Jr, owner and operator of a 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 air space regulated by the FAA, as long as such operations are conducted 

within and under the 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 operations will be' performed with the 

public's safety and right to privacy safeguarded at all times. 

Bruce Barnard Jr's UASs is a Yuneec Q-500 Typhoon 4K weighing less than 55 lbs. including 

payload (CG03 camera). It operates at a speed of less than 40 knots and has the capability to hover and 

move the vertical and horizontal plane simultaneously. It has an auto return to launch point when 

battery power is under 25%. The UASs will operate only within the line of sight of the operator within a 

protected flight area and at 200 feet AGL or less. These operations will not create a hazard to users of 

the National Airspace, Public, nor the Environment. 

I, Bruce Barnard Jr, respectfully request the grant of an exemption to the following specific 

sections of the Title 14 Code of Federal Regulations allowing me to operate light weight UASs for 

commercial use, 

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 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, submit this 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 of small UASs to operate in the National Airspace System as described below. The 

Reform Act Section 332 provides for such integration of civil unmanned aircraft into our national 

airspace system as it is in the public's interest to do so. Bruce Barnard Jr's UAS meets the definition of 

"Small Unmanned Aircraft'' as defined in Section 331 and therefor the integration of these UAS's are 

expressly contemplated by the Reform Act. 

The very small nature of the UAS combined with the safe guards presented below will allow for 

the safe operation greater than that envisioned by Congress for the 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 they will operate approval of this exemption presents no national security issues and 

absolutely minimal safety concerns. Given the clear direction given in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced 

safety, reduced emissions utilizing UAS's versus traditional aircraft as well as the economic impact of 

greatly reducing the cost of aerial photography thereby benefitting the greater public's interest. 

Accordingly, the applicant requests that the FAA grant exemption of the requested without delay. 

The following will be considered as binding limitations of operations for Bruce Barnard Jr's UAS: 

1.) Flights will only occur during daylight hours. 

2.) Flights will be operated in the line of sight of the operator (PIC) and the observer (VSO). 

3.} Flights will be terminated at any time if weather and wind deteriorate to "unsafe for flight" 

by manufacturers recommendations (which are rain and/or wind that exceed 

12mph/19kph.) 

4.} The UAS weighs less than 55 lbs. 

5.) Flights will be conducted/ operated at 200ft ACL or less. 

6.} Crew will be operator and observer on all flight operations. 

7.) Operator and Observer will remain in contact during the flight operation. 

8.) The UAS operator will perform a check of the flight area and make certain of the safety of all 

persons in the area. 

9.} Consent will be obtained from all persons within the video capabilities of the unit to further 

reduce the chance of violating 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 manner with the home function 

activated 

12.)When operated in conjunction with fishing vessels in the Gulf, a chase boat will 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, battery volts, airspeed, the distance from 

operator, GPS position. 

15.)Fiight team will communicate by voice of by using 2 way radios if area is too big to hear 

voice. 
16.)UAS will be used to video private outings and functions from a safe distance. 

17.)When operating over or near water the UAS will be equipped with flotation devices so that 

recovery can be made to prevent lithium battery exposure to the water table. 

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 of necessary 

certificates in relation to FAR 91.203 (a) (1). The size, weight, and defined area of operations for Bruce 

Barnard Jr's UAS flights permits exemption from Part 21 because they meet an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Bruce Barnard Jr's UAS meets or exceeds each of these 

elements. 

14 CFR 91.203 (a & b) provides for carrying of civil aircraft certifications and registrations. These are 

inapplicable for the 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 of the UAS this regulation is applicable. 

14 CFR 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 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 not carry a pilot or passengers, the proposed operations can achieve a high level of 

safety of operation without the required pilot license. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. I will only operate the UAS at or 

below 200 AGL. Flights will only be over private property that the owner has consented to and all 

persons within the video/ picture area also give consent for filming. 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 a far smaller risk to the public. 

Approval of these 333 exemptions allowing commercial operations of small UASs in the service of aerial 

photography will greatly enhance safety by reducing the overall risks associated with traditional aircraft. 

Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of 

populated areas and people in general. With the use of small UAS of 55lbs or less, battery operated and 

flying below 200ft AGL the risk of injury of people on the ground or the crew has been reduced or 

erased. The granting of the use of small 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 for the expansion of UAS systems into the 

future for safe conduct offree enterprise and the enjoyment of the masses. 

I, Bruce Barnard Jr, respectfully request that the FAA grant this exemption without delay. The FAA has 

the authority to 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.