August 5, 2015

Exemption No. 12349

Regulatory Docket No. FAA–2015–1027

Mr. Dacoda J. Bartels

811 Albertsons Parkway

Broussard, LA 70518

Dear Mr. Bartels:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 10, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. You requested to operate an unmanned aircraft system (UAS) to conduct 

photography and videography operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI S1000 Premium.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 
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Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Dacoda Bartels is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Dacoda Bartels is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S1000 

Premium when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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 
U.S. DOT 

April10, 2015 

Page2 

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. 
U.S. DOT 

April10, 2015 

Page 3 

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. 
U.S. DOT 

April10, 2015 

Page4 

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. 
U.S. DOT 

April10, 2015 

Page 5 

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. 
U.S. DOT 

April10, 2015 

Page 6 

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