April 10, 2015 

U. S. Department of Transportation Docket 

Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Dacoda J. Bartels 

811 Albertsons Pkwy, Suite C 

Broussard, LA 70518 

Phone: (504) 458-4665 

Email: dacoda.aerobotics@gmail.com 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 

91.121; 91.151 (a); 91.405(a); 91.407(a)(1 ); 91.409 (a)(1) and (2); 91.417(a) and (b). 

Dear Sir or Madam: 

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

Act")and 14 C.F.R. Part 11, Dacoda Bartels, an operator of Unmanned Aircraft Systems 

("UASs") for aerial photography and videography, hereby applies for an exemption from the 

Federal Aviation Regulations ("FARs") to allow commercial operation of his UASs. 

Dacoda Bartels, an FAA licensed Commercial Rotorcraft Pilot with Instrument rating 

(Certificate# 3364961)'s requested exemption would permit the operation of small, unmanned 

UAS under controlled and "sterile" conditions that are limited, predetermined, and provide 

greater safety in connection with aircraft operations. As established by the exemptions already 

granted by the FAA, approval of Dacoda Bartels's exemption would enhance safety and fulfill 

the Secretary of Transportation's (the FAA Administrator's) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 

Section 333(c) of the Reform Act. · 

The name and address of the applicant is: 

Dacoda Bartels 

Phone: 504-458-4665 

Email: dacoda.aerobotics@gmail.com 

Address: 811 Albertsons Pkwy, Suite C Broussard, LA 70518 
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April10, 2015 

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Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 

14 C.F.R. 91.103 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151(a) 

14 CFR 91.405(a) 

14 CFR 407(a)(1) 

14 CFR 409(a)(2) 

14 CFR 417(a) and (b) 

UASs operated by Dacoda Bartels weigh less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and 

can simultaneously move vertically and horizontally. Dacoda Bartels will only operate his UASs 

in line of sight, below 400 feet, and will operate only with land owner's permission while in 

constant contact of the authority of that airspace via cell phone and handheld VHF radio. Such 

operations will insure that the UAS will "not create a hazard to users of the national airspace 

system or the public." 

Given the small size of Dacoda Bartels's UASs and the restricted sterile environment 

within which they will operate, Dacoda Bartels's UAS operations adhere to the Reform Act's 

safety requirements. Additionally, due to the size of the UASs and the limited areas in which 

they will operate, approval of this application presents no national security issues. Based on the 

level of safety surrounding the proposed operations, and the significant public benefit (enhanced 

safety), reduction in environmental impacts (reduced emissions and noise), the grant of the 

requested exemption is in the public interest. Accordingly, Dacoda Bartels respectfully requests 

that the FAA grant the requested exemption without delay. 

Aircraft and Equivalent Level Of Safety 

The operating limitations proposed by Dacoda Bartels provide for at least an equivalent 

or higher level of safety because operations further enhance safety of photography and 

videography using conventional aircraft. 

The limitations and conditions include: 

D The UASs will weigh less than 55 pounds 

D Flights will be operated within line of sight of a pilot and/or observer. 

D Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 

D Flights will be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet 

above an elevated platform from which filming is planned. 
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April10, 2015 

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D Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer I Camera 

Operator. 

D A UAS pilot will be an FAA licensed airman with at least a private pilot's certificate and 

third class medical. 

D A UAS Pilot will be Pilot in Command (PIC). 

D The UAS will only operate within a confined "Sterile Area". 

D A briefing will be conducted for planned UAS operations prior to each day's flight. All 

personnel performing duties within the boundaries of the safety perimeter are 

required to attend. 

D The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office ("FSDO"). 

D The operator will obtain consent of all persons involved in the video and/or photo and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation. 

This radius may be reduced to 30 feet based upon an equivalent level of safety 

determination. With the advanced permission of the FSDO, operations at closer range can be 

approved. 

D The Pilot and observer must be trained in UAS operations and have received current 

information on the particular UAS to be operated. 

D The Observer and pilot will at all times be able to communicate by voice and/or text. There will 

also be a handheld VHF radio to be used at all times to monitor air traffic. 

D Written and/or oral permission from the relevant property holders will be obtained. 

D All required permissions and permits will be obtained from territorial, state, county, or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

D If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and 

land. 

D The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 
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April10, 2015 

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14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have 

a private pilot's license rather than a commercial pilot's license to operate a small UAS. Unlike a 

conventional manned aircraft, a UAS is remotely controlled by a ground-based operator. The 

operational area is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single individual holding a commercial 

pilot's certificate operating a conventional aircraft. The risks associated with the use of a UAS 

are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level of safety 

sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, including 

review of weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

provides, in pertinent part, that: "except when necessary for takeoff or landing, no person may 

operate an aircraft below the following altitudes: ..... 

(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." Because Dacoda Bartels's 

requests authority to operate at altitudes only up to 400 AGL, and not more than 

200 above an elevated platform from which photography/ videography is planned, an exemption 

is needed to allow such operations. The UAS will never operate higher than 400 AGL. It will, 

however, be operated within a security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the permission of 

property owners or local officials. Because of the advance notice to the property owners and 

participants in the filming activity, all affected individuals will be informed of the planned flight 

operations. Compared to flight operations for manned aircraft and the lack of flammable fuel, 

any risk associated with the proposed UAS operations is far less than conventional aircraft 

operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure 

separation between a UAS and conventional aircraft. 
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14 C. F. R. §91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As a UAS may not have a barometric altimeter, but 

instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be 

achieved by the operator, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 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- (1) During the 

day, to fly after that for at least 30 minutes .... " 

The battery powering Dacoda Bartels UASs provides approximately 22 minutes of 

powered flight. The UAS will be unable to meet the 30-minute reserve requirement in 14 CFR 

§91.151. Given the limitations on the UAS's proposed flight area and its proposed operations 

within a predetermined location, a longer time frame for flight in daylight VFR conditions is 

reasonable. Furthermore, operating the UASs in a tightly controlled area where only people, 

property owners, or official representatives who have signed waivers will be allowed, less than 

30 minutes of reserve fuel does not engender the type of risk that §91.151 (a) was intended to 

address. 

Dacoda Bartels believes that safety can be achieved by limiting flights to 15 minutes or 

25% of battery power, whichever occurs first. This restriction would be more than adequate to 

return the UAS to its pre-determined landing zone from anywhere in its limited operating area. 

Dacoda Bartels is not seeking an exemption for night-time UAS operations. 

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

These regulations require that an aircraft operator or owner 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 ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Dacoda Bartels' operations. Maintenance will be 

accomplished by the operator. An equivalent level of safety will be achieved because the UASs 

are limited in size, will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise, the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order 

prior to flight, perform any required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the UAS and best suited to 

maintain it in an airworthy condition. 
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April10, 2015 

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Summary for Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Dacoda Bartels seeks an exemption from the following rules: 

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1 ); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a 

small unmanned vehicle (55 pounds or less) for photography and videography 

operations. 

As established by the UAS exemptions already granted by the FAA, allowing commercial 

operations of UASs for photo and video capture will enhance safety by reducing risk. 

Conventional photography and videography operations, using turbine aircraft, operate at low 

altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, and 

which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the photo/video 

location. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates 

virtually all of that risk given the small size and lack of combustible fuel. The UAS is carried, and 

not flown, to a photo set. In this regard, the UAS carries no passengers or crew and, therefore, 

will not expose them to the risks associated with manned flights. 

The operation of UASs conducted only by an FAA licensed full size aircraft pilot, creates 

a level of safety supporting the grant of the exemption requested herein. The UASs operate at 

slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer 

than conventional operations conducted with turbine helicopters flying near the ground and 

people. 

Privacy 

All flights will occur over private or controlled access areas with the property owner's 

prior consent and knowledge. PhotosNideos will be only of people who have given their 

consent or otherwise have agreed to be in the area where photography/videography will take 

place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security) provide more than adequate justification to grant 

Dacoda Bartels requested exemption, allowing for Dacoda Bartels's UAS commercial 

operations for photography and videography. 

Any questions or requests for additional information, please contact the undersigned at 

504-458-4665 or at dacoda.aerobotics@gmail.com 

Sincerely yours, ~. . . 

~~~~~-~ Dacoda J. Bartels