# UAS Exemption for Buzz By 

# Drones LLC

AUGUST 20, 2015



### US Department ofTransportation Docket Management System 1200 New Jersey Ave., SE 3 Washington DC 20590



### The name, address and contact information ofthe Petitioner is: 

### BuzzByDrones LLC Lance Atkins, Pres. 83 Chapel Hill Rd Reading, P A 19608 CELL PHONE: 610.670.8193 Business Phone: 484.999.0986 Email; BuzzByDrones@gmail.com 

### (1st) LAtkins@DroneBuzzings.com

To whom it may concern:

Re: Exemption Request Pursuantto Public Law 112-95, Section 333 ofthe FAA Reform Act and Part 11 ofthe Code ofFederal Regulations from: 

### Regulations from which the exemntion is requested:

14 CFRPart21 subpart H 14 CFR91.131(b)(1) 14 C.F.R. 91.403(b & c) 14 CFR47.3(b)(2) 14 CFR91.131(d)(1)&(2) 14 CFR91.405 14 CFR47.31(c) 14 CFR91. 145 (b) 14 CFR91.407 14 CFR91 .9(b)(2) 14 CFR91.151 (a) 14 CFR91.409 14CFR91.7 (a) 14 CFR91.203(a &b)(2) 14 CFR91.417 14 CFR 103 14 CFR45.23 14 CFR91.119(d)(1) 14 CFR91.109(a) 14 CFR 61.113 (a & b) 14 CFR91.121 14 CFR 61.133

liP ageNote: 14 CFRPart 61 in its current form applies to mannedaircraft. 14 CFR 61.3 refers specifically toflight crew members who is defined in Part 1.1 as apilot,flight engineer, or flight navigatorassignedto duty "in an aircraft" duringflight time; therefore no exemptions from Part 61.3 is beingsought for as it is notapplicable at the time of this exemption request.

Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 (the "ReformAct") and 14 CFRPart 11, Buzz ByDrones LLC, operator ofa small UnmannedAircraft System (U AS), hereby applies for an exemption from the listed Federal Aviation Regulations ("F

### ARs") to allow commercial operation ofits UAS, so long as such operations are conductedwithin and underthe conditions outlinedherein or as may be established by the FAA as required by Section 333.

The exemption would permitBuzzBy Drones LLC, to operate a small UnmannedAircraft System (UAS) for the commercial purposes stated in DocketNo.: FAA-2015-0150; Notice No. 15-01, including aerial video andphotography over certain areas ofthe United States. Briefly described:



## •!• The ability to offertraining to persons individually orbelongingto bothprivate and/or public organizations thathave interests in the use and application ofa UAS for the purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons andproperty.


## •!• Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.


## •!• Aerial video and/or photography for public and/or private use including television, public events, cinematography andnews gathering.



## •!• Aerial inspection/photography ofresidential/commercial structures under contract with the owners or local government authority.


## •!• Aerial inspection/photography ofresidential/commercial utility infrastructure including butnot limitedto electrical power lines, wind turbines and cell towers.


## •!• Aerial video photography orproviding live video feed to assist with search and rescue operations in cases ofan emergency ornatural disaster only whenthe local authorities or governmenthas requested itby contract and/or donation.

2\Page· As described fully hereafter, the requested exemption would permitthe operation ofa UAS by Buzz By Drones LLC under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's and the FAA Administrator's responsibilities to "

....establish requirements for the safe operation ofsuch aircraft systems in the national airspace system. 

### Description and specifications ofUAS to be used by the Petitioner

DJI Phantom 3 Professional Type: Quad Rotor Copter Weight: (including batteryandpropellers) 2.8 pounds Diagonal size: (includingpropellers) 23.3 inches Max Speed: 35.8 mph (no wind) GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer Batteries Battery Capacity: 4480 mAh Remote Control Operating Frequency: 2.400GHz

- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 23 minutes Special Features: Return to Home (RTH) mode ifbattery life gets to lowpoint



### DJI INSPIRE 1 T600 Type: Quad Rotor Copter Weight: (including batteryandpropellers) 2935 grams (6.47 lbs) Dimensions: 438mm x 451mm x 301mm or 17.24in x 17.75in x 11.85in. Max Speed: 22.2n/sec = 49mph (no wind) GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer High Voltage Batteries Battery Capacity: 4500 mAh and -+ 5700 mAh Remote Control Operating Frequency: 2.400GHz

- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 18 minutes Special Features: Return to Home (RTH) mode ifbattery life gets to lowpoint



### DJI SlOOO+ Professional Spreading Wings Type: Octo- Rotor copter Weight: (including battery andpropellers) 4.4 Kg Diagonal size: (includingpropellers) 1045 mm Max Speed: not made for high speed GPS Mode: GPS/GLONASS Aircraft means ofpropulsion: Electric via Lithium Polymer Batteries Battery Capacity: 1 OOOmAh-2000 mAh Remote Control Operating Frequency: 2.400GHz

- 2.483GHz. Live Feed Frequency: 5.728GHz- 5.850GHz. Max Flight Time: Approximately 15 minutes 3jPage

### General Operatin2 Standards

The Petitioner, Buzz BYDrones LLC, will operate the UAS in line ofsight within a predetermined area owned and/operated by the property representative. Given the small size of the UAS andthe controlled environmentprovided, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including butnot limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly the Petitioner requests that the FAAgrantthe requested exemption with minimum delay.

Buzz By Drones, LLC will only operate its UAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public." Before an operation ofa UAS within 5NM ofan airport with a control tower, the control tower will be called to gain permissionto operate the UAS. The PIC will give the position, altitude and the times the UAS will be operated. The UAS will not be operated at an altitude ofover 500 feet AGL. Weatherminimums will be 3 miles visibility and a 1 000 foot ceiling. Before an operation ofa UAS within 5NM ofa non-tower controlled, airport operators will be notified and the PIC will give the right ofway to avoid flying in the proximity offull-scale aircraft. Atno time will the UAS be operated within the final approach course andthe takeoff

course ofany runway.

- Maximum flight time for each operational flight will be 15 minutes.

- Flights will be terminated at 25% battery powerreserve shouldthat occurpriorto the 15 minute limit.

- The UAS will be programmed so that itwill notbe operated at an altitude ofno more than 500 feet AGL and not more than 200 feet above an elevatedplatform from which filming is planned.

- Minimum crew for each operation will consist ofthe UAS Pilot, and Visual Observer.

- The UAS operatedby the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals).

- The UAS will operate at speeds ofno more than 25 knots, canhover, and can simultaneously move vertically and horizontally.

- Given the small size ofthe sUAS andthe restricted sterile environment within which they will operate, ourUAS operations adhere to the Reform Act's safety requirements.

The UAS, poweredby batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people onboard and will thereby reduce current risk levels andthereby enhance safety and diminish the likelihood of 41Page' death or serious bodily injury. With a small payload and maximum flight time ofonly 15 minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees.

The benefits ofreduced cost and improved quality ofpresentation from the UA will be valuable to and benefit many buyers and sellers ofreal property. Chartering full-sized helicopters for this purpose, have proven more costly than many potential clients are able to afford.
Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so.


### Pilot in Command and Observer Qualifications and Duties

In addition to these flight restrictions, Buzz By Drones LLC will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertainingto all aircraft operators but also in the unique aspects ofUAS flight. As set forth in the Operations Manual, Pilots will have experience not only in UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permittedto participate in commercial flights on behalfofBuzz By Drones LLC. Petitioner believes that this system will provide a higher level ofcompetency and proficiency for its pilots.

Pilot In Command Duties are:

The PIC is responsible for the safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but not limited to:

• Safe in-flight operations

• RiskMitigation to Persons and Property

• Airfield Suitability

The Visual Observers Duties are:

• The Observer must have the visual acuity to observe the UAS and be able to communicate clearly with the PIC.

• Warning the PIC ofany impending obstacles in the flight path ofthe UAS.

51Paoe "'• Warning the PIC ofany deviations in the planned flight path ofthe UAS.

• Warning the PIC should any unauthorized personnel appear in the area ofthe planned flight.

• The Observer will have the authority to order the PIC to terminate the flight should he feel the flight cannot be conducted safely.



### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent orhigher level ofsafety because operations will further enhance the safety ofpersons, property and also manned aircraft in the NAS. These limitations and conditions to which the Petitioner, hereafterreferred to as the operator, agrees to adhere to when conducting commercial operations underthe FAA issued exemption limitations, and as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS, as specifically designated and described in this petition, will weigh less than 55 lbs including payload. 2. The UA will be operated within visual line ofsight 

### (VLOS) at all times by the operator or visual observers. 

### (VOs). 3. The UA will remain close enough to the operator so that human vision unaided by any device other than corrective lenses will be used. 4. The UA will not be operated overpersons not directly involved in the operation unless those persons remain under a covered structure. 5. The UA will only be operated during sunlight 

### (official sunrise to sunset in operation area) unless specific authorization from the FAA is granted prior to operations. 6. The operator may use VOs for certain operations and will ensure each VO is trained on procedures listed in the operators FOM. 7. The UA will not be operated at a speed exceeding 87 knots 

### (100 milesper hour) using ground speed 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 bythe aircraft manufacturer. 8. The UA will be operated at an altitude ofno more than 500 feet above ground level (AGL). Altitude will be measured in feet AGL. Ifan objectto be inspected, such as an antenna, exceeds 500 feet AGL, the operator will limit the flight to within 200 feet higher than the structure being photographed. The operator will notify the FAA and local authorities ofthe proposed planto include date, time, location and height ofthe objectto be inspectedpriorto operations. The UA will be flown in a safe manner in close proximity to the object as to not 61Pageinterfere with traffic in the NAS. 9. The UA will not be operated unless visibility is greater than day requirements listed in 14 CFR91.155 for the Class ofairspace at the operator's ground station, on location. 10. The UA will not be operated in Class A airspace 

### (18,000feet andabove). 11.The operator will receive ATC permission prior to operations in Class B, C, D and E

mrspace. 12. The operator will ensure that any VOs, ifused, will only monitor one UA at any given time. 13.The operator will not allow operations from a moving vehicle or aircraft, except for watercraft onthe water. 14. The operator will not conduct any careless or reckless operations. A flight will be terminated immediately as possible ifthe safety ofthe operation cannot be maintained. 15. Priorto each flight, the operator will conduct a pre-flight inspection and determine that 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. Ifthe inspection reveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has beenperformed, logged and the UAS is found to be in a condition for safe flight. 16.The operator will not operate any UA ifa physical or mental condition would preventthe safe operation ofthat aircraft. 17.When using aVO orVOs, the operator and VO must be able to communicate at all times. Radio communications or communication assisting devices may be used. Electronic messaging ortexting will not be permitted during flight operations. Daisy-chaining ofVOs for the purpose ofexpanding the operations area will notbe permitted. 18. The operator will be responsible to see and avoid all other users ofthe NAS in which the UAS is operating. 19.The holder ofthis exemption will be responsible to ensure its aircraft are properly registered in accordance with 14 CFRPart 47, and have identification (N-Number) markings in accordance with 14 CFRPart 45 Subpart C. Markings mustbe large as practicable. 20.The UAS operator will be designated before the flight and cannot transfer his orher designation for the duration ofthe flight unless a medical duress or unforeseen emergency is preventing safe operation ofthe UAS. In which case the VO, who has been deemed qualified and trained in the operation ofthe UAS, will operate the controls to land the UA in a predetermined "emergency plan" set forth by the operator who was granted this exemption. The holder ofthis exemption must ensure that VOs, ifused, can perform the duties required ofaVO. 21.Documents for UAS operations and maintenance will be made available to the FAAupon request. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the FOM, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in the FOM. The operator may update or revise its operating documents. Itis the operator's responsibility to track such revisions and present revised documents to the FAA or any law enforcement official upon request. Ifthe operator determines that any update or revision

7JPagewould affect the basis upon which the FAA granted an exemption, then the operatormust petition for an amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operating documents.

22. Any UAS thathas undergone maintenance or alterations that affect UAS operations or flight characteristics, e.g. replacement ofa flight critical component, must undergo an operational check flight priorto conducting further operations under this exemption. Operational check flights may onlybe conductedby a qualified operator familiar with the specific UAS being checked and mustremain 500 feet from any persons unless they remain under a covered structure. (NPRM wording) The operational check flight mustbe conducted in such a
manner so as to not pose an undue hazard to persons and property.

23.The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

24.The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

25.The holder ofthis exemption will follow manufacturers safety bulletins for eachUAS operatedunder this exemption.

26. The holder ofthis exemption will ensure that each operator is 17 years or older, a US citizen and has a state issued driver's license.

27.The holder ofthis exemption will require that its operators demonstrate the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated inthis petition, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. Qualification flight hours and currency may be logged in a manner consistent with 14 CFR61.51(b). Flights for the purposes oftraining the operator's and VOs (training, proficiency, and experience building) and determining the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated, will be permitted. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-building flights will be conducted 500 feet from any persons that are not intended to be part ofsuchtraining operations unless those persons remain under a covered structure.

28. The operator will use UAS that have safety features allowing itto return to a preset location ifit loses communications with its ground station. The operatorwill setthis pre--determined location within the private or controlled access property as to minimize any possible contact with objects.

81Page· 29.The operator is prohibited from beginning a flight 

### (considering windand forecast weather conditions) unless there is enough available power for the UAto conductthe intended operation and to operate after that with at least 25% energy reserves or with the reserve power recommended by the manufacturer, whichever is greater. The operator will perform training tests, in a designated training area as prescribed herein, to assess the true energy characteristics ofthe specific UAS battery system to determine the power. Said energy tests will deem the "safety" operating procedure for actual emergencies and useful flight time.

30.The exemption holder will ensure that operators and VOs have a copy ofthis exemption, the FOM and applicable aircraft registrations located at the ground station during operations. These documents will be made available to the Administrator or any law enforcement official upon request.

31.All operations shall be conducted over private or controlled access property with permission from the property owner/controller or authorized representative.

32.The exemption holder will be responsible to report to the FAA any small UAS operation that results in: 

### (1) any injury to a person; or (2) damage to property otherthan the small unmanned aircraft. The report would have to be made within 10 days ofthe operation that resulted in injury or damage to property. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov. Current NTSB accident reporting is required when

... 1) Any person suffers death or serious injury. 2) Any UAS with max gross takeoffweight exceeding 300 pounds sustains substantial damage.
Operations for closed-set motion picture and television filming and production include the following limitations:

33.The operator must have a motionpicture and television operations manual (MPTOM) in his/her possession. 34.At least 3 days before aerial filming, the operator ofthe UAS must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofproposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO. The plan ofactivities must include at least the following: a.Dates and times for all flights; b. Name and phone number ofthe operator for the UAS aerial filming;

c. Name and phone number ofthe person responsible for the on-scene operation of the UAS d. Make, model, and serial or N-Number ofUAS to be used;

e. A statement that the operatorhas obtained permission from property owners and/or local officials to conductthe filming production event;

91Pagef. A list ofthose who gave permission, mustbe made available to the inspectorupon request; g. Signature ofoperator orrepresentative; h. A description ofthe flight activity, including maps ordiagrams ofany area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 35. Flight operations maybe conducted over/nearparticipatingpersons consentingto be involved and necessary for the filming production, as specified inthe operator's MPTOM.



### Regulations from which the exemption is requested:

14 CFRPart 21, Subpart Hand 14 CFR §91.203(a)(l)&(b): Airworthiness Certificates SubpartH, entitledAirworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by 14 CFR91 .203(a)(1 ). Given the size and limited operating area associated withthe aircraftto be utilizedbythe Petitioner, an exemption from Part 21 SubpartH meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe "AReform Actboth authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, andproximityto airports andpopulated areas ofthe particularUAS. in all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with

an airworthiness certificate withoutthe restrictions and conditions proposed.
The UAS to be operatedhereunder is less than 55 lbs. fully loaded, carries neither a pilotnor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitoredbyboththe operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posedby the UAS, due to its size, speed ofoperation, location of operation, nearly silent operation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load.


### 14 CFR47.3(b)(2) and 14 CFR 47.31(c) and 14 CFR 91.203(a){2): Registration reguired This regulation states inpart: Noperson may operate an aircraftthat is eligible for registration under 49 U.S.C. 44101- 44104 unless the aircraft is carrying aboard the temporary authorization requiredby §47.31(c). Part 91 .203(a)(2) reads similar. The Petitionerwill be operating small

lOIPage· UAS. Placing registration paperworkinside the UAwill be impractical. An equivalent level of safety canbe achieved by the Petitioner ensuringthat all temporary orpermanentregistration paperwork for the UAS being operated is located on site at the ground station as stated in item #30 inthis document.



### 14 CFR91 .9(b)(2): Civil Aircraft FlightManual in the Aircraft Section 91.9(b)(2) provides: No person may operate a U.S.- registered civil aircraft (2) For which an Airplane orRotorcraft FlightManual is not required by §21.5 ofthis chapter, unless there is available inthe aircraft a current approved airplane orRotorcraft FlightManual, approved manual material, markings, and placards, or any combinationthereof. The UAS, given its size and configurationhas no ability orplace to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, butbecause there is no room or capacity to carry such

an item onthe aircraft. The equivalent level ofsafety will be maintained by keeping the UAS flight manual atthe ground station where the UAS operator will have immediate access to it.



### 14 CFR91.109(a): Flight Instruction Section 91.109(a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The Petitionerwill be operating small UAS that it do nothave fully functional dual controls. Flight control is accomplished through the use ofa control boxtransmitterthat communicates withthe aircraft viaradio communications. The equivalent level ofsafety is providedby the fact that neither a pilotnorpassengers will be carried inthe aircraft and by the size and speed ofthe aircraft. Flight instruction is accomplishedby handing the transmitter betweenthe instructor and trainee or bythe use ofa buddy box system instruction will also be accomplished in accordance with item #27 inthis document.



### 14 CFR91.119(d)(l): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91 .119(d)(1) allows helicopters to be operated at less than the minimums prescribed, providedthe person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is similarto a helicopter andthe exemptionrequests authority to operate at altitudes up to 500 AGL, ornot more than 200 above a structure from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 500 AGL withthe exceptionthat in circumstances where the UAS is used to survey orphotograph a structure whose height exceeds 500 feet AGL, the UAS will not be operated more than 200 feet above the highestpoint onthe structure in accordance with procedures outlined in item #8 ofthis document.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well

as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner orlocal officials. Because ofthe advance notice to the property owner and participants inthe filming activity, all affected individuals will be aware ofthe planned flight ll!Page· operations. Comparedto flight operations with aircraft orrotorcraft weighting far more thanthe maximum 55lbs. proposed herein andthe lack offlammable fuel, noise and any risk associated with these operations is far less thanthose presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations of the UAS will ensure separationbetween these UAS operations and the operations ofconventional aircraftthatmust; comply with Section 91 .119. The procedures outlined inthis document prohibit flight over persons not involved in operations unless they remain under a covered structure.
14 CFR91.121: Altimeter Settings This regulation requires each person operating an aircraftto maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the small UAS does nothave a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

### An equivalent level ofsafety will be achievedbythe operator, pursuantto the safety check list and live flight data monitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. Flights will be conducted 500 feet above that read out orwithin 200 feet above the highestpoint ofthe structure being filmed as outlined in item #8 ofthis document

14 CFR45.23: Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed

onlimited, restricted or light-sport category aircraft orexperimental orprovisionally certificated aircraft, the operatormust also display onthat aircraft near each entrance to the cabin, cockpit,

orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Eventhough the UAS will have no airworthiness certificate, an exemptionmay be needed as the UAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can be placed. Giventhe size ofthe UAS, two inch lettering will be impossible. The word "Experimental" will be placed onthe fuselage in compliance with §45.29 

### (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 

### (t) where the pilot, observer and others working withthe UAS will see the identification ofthe UAS as "Experimental

14 CFR91.103: Preftight Action. This regulation requires eachpilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft

an exemption will be needed. The PIC will take all actions as stated in the FOMin Section 4 underNormal Procedures including butnot limitedto reviewing weather, flight battery requirements, landing andtakeoffdistances and aircraftperformance databefore initiation of flight. Beforethe aircrafttakes flight, a home GPS location will be set for any reasonthe aircraft becomes disoriented in flight, and return safely to home.

121 Page

### · 14 CFR91.145: Management ofaircraft operations in the vicinity ofaerial demonstrations and managing events states: ofthis section, the FAAconsiders the following factors: (1) Areawhere the event will be held. (2) Effectflight restrictions will have onknown aircraft operations. (3) Any existing ATC airspace traffic managementrestrictions. (4) Estimated duration ofthe event. (5) Degree ofpublic interest. (6) Number ofspectators. (7) Provisions for spectator safety. (8) Number andtypes ofparticipating aircraft. (9) Use ofmixedhigh and lowperformance aircraft. (10) Impact onnon-participating aircraft. (11) Weather minimums. (12) Emergency procedures that will be in effect. Note: If

### Buzz By Drones LLC intends to use a UAS to cover sporting events from outside the activity, coordination will be completedby contacting the FSDOpriorto the eventto ascertain the presence ofany other unmanned activities. Flight activity will be conductedbased on safety and with particular attention to the avoidance ofoverflight oflarge concentrations ofpeople. However, specific relieffrom this regulation is still necessary to ensure compliance with FARs.



### 14 CFR 61.113 (a) and (b): Private Pilot Privileges and 

### Limitations and 61.133 Commercial pilot privileges and limitations.

Pilot in Command. Pursuantto 14 CFR61.113 (a) & (b), no person who holds a private pilot certificate may act as
a pilot in command ofan aircraftthat is carrying passengers orproperty for compensation or hire. 

### Buzz By Drones LLC may achieve an equivalent level ofsafety as achievedby current Regulations because the applicant's UAS do not carry any pilots orpassengers norproperty. The risks inherentto the operation ofUAS is far less than the risk levels inherent inthe commercial activities outlined in 14 CFR 61.


### Buzz By Drones LLC seeks exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure thatthe skill and competency of any PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers orcargo for hire. Inthis case, while the UASs will be operated as part ofa commercial operation, it carries neitherpassengers nor cargo. Inthe Grant ofExemption in FAADocketNo. FAA-2014-03 52, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did notwarrant the additional cost and restrictions incumbent withrequiring the PIC to have a commercial pilot certificate and/or class II medical certificate.

131PageThe restrictions 

### BuzzBy Drones LLC placed on its UAS flight operations manual is to meet or exceedthe restrictions similarly imposed onAstraeus Aerial in FAADocketNo. FAA-2014- 0352. 

### Buzz By Drones LLC will operate away from persons andproperty not involved in the operation, and flights will be conducted using VLOS at 500' AGL or below. A NOT AM will be issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated withthe applicable FSDO.


### 14 CFR91.131 (b)(l): Pilot requirements for Class B airspace This regulation states that no person may operate a civil aircraft within a Class B airspace unless thatperson is a private pilot, recreational pilot, sport pilot or is a studentpilotthat meets requirements of§61.94 or §61.95 ofthis chapter. An exemption from this regulation may be required. An equivalent level ofsafety will be achievedby operating the small UAS at altitudes listed in the limitation section ofthis document. The UAwill notbe landing or departing from airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a controlled environment within VLOS. The UAS operator will require ATC permission priorto conducting operations and will give right ofway to any manned aircraft.



### 14 CFR 91 .131(d)(l) and (2): Equipment reguirements for Class B airspace The regulation states thatno person may operate an aircraft in Class B airspace unless it is equipped with a transponder and after January 1, 2020 an ADS-Bout system. An exemption may be required. Dueto the size, weight and payload capacity ofthe small UAS, installing these systems is notpractical. An equivalent level ofsafety will be achieved by operating the small UAS at altitudes listed in the limitations section ofthis document. The UAS will not be landing or departing from airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a controlled environment within VLOS. The UAS operator will require ATC permissionprior to conducting operations and will give right ofway to any manned aircraft. Note: If

### Buzz By Drones LLC is conducting an exposition or contracted for filming purposes at an airport that would require landing or departing in Class B airspace. 

### Buzz By Drones LLC will seek and acquire the properpermits thru the FAA, local authorities, and any other necessary agency. A detailed proposed plan would include date, time, location and purpose of needed area to complete the planned operations. The UA will be flown in a safe manner as to not interfere with traffic in the NAS.



### 14 CFR 91.403 (b) and (c); 91.405; 91.407; 91.409; 91.417: Maintenance and Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintainthe aircraft in accordance with Part 43. Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft

141 Page· operating in common carriage underprovisions ofPart 121 or 135. These sections will not apply to the Petitioner who will be operating a small UAS. An equivalent level ofsafety will be achieved as the UAS will be maintained in accordance with the UAS manufacturer's instructions and limitations listed inthe operator's FOM. The small UAS will carry a small payload and operate in a controlled area for a limitedperiod oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 500 feet AGL, withoutpriorFAA authorization. The operator will ensure thatthe UAS is in working order priorto initiating flight, perform required andpreventative maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

14 CFR 91.151: Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane underVFR conditions unless 

### (considering windand forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed. (1) Duringthe day, to fly after that for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes."

The battery poweringthe UAS provides approximately 30 minutes ofpoweredflight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations onthe UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight ortwilight VFRconditions is reasonable.
Applicantbelievesthat an exemption from 14 CFR §91.151(a) falls withinthe scope ofprior exemptions. Operating the UAS, in a tightly controlled area where only people and property

owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engenderthe type ofrisks that Section 91 .15l(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.
Applicant believesthat an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% ofbattery power whichever happens first. This restriction wouldbe more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating

area. 14 CFR 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issuedunder §91 .715 is displayed

15JPage• at the cabin orcockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboardpilot. As such, there is no ability orplace to carry certification and registration documents orto display them onthe UAS.

An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilotflying the UAS will have immediate access to them, to the extentthey are applicable to the UAS. Again, ifpilot forgets documents, all documents canbe achieved viathe DJI PilotApp.

14 CFR 91.403(b) and (c); 91.405; 91.407; 91.409; 91.417: Maintenance and Inspections. These regulations require that an aircraft operator or owner "shallhave that aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect ormaintain the aircraft in accordance with Part 43. Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft operating in common carriage underprovisions ofPart 121 or 135. These sections will not apply to the Petitioner who will be operating a small UAS. An equivalent level ofsafety will be achieved as the UAS will be maintained in accordance with the UAS manufacturer's instructions and limitations listed inthe operator's FOM. The small UAS will carry a small payload and operate in a controlled area for a limitedperiod oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 500 feet AGL, withoutpriorFAA authorization. The operator will ensure thatthe UAS is in working order priorto initiating flight, perform required andpreventative maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

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### · Safety and Benefits ofthe UAS Buzz By Drones LLC will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad benefits overthe use offull-sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafety for the pilots and

crew. By granting Buzz By Drones LLC's requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. Buzz By Drones LLC is committed to promotingthe UAS research efforts ofpolicymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.



### Conclusion As pointed out in this application, all the SUAs which our company would use, under authorization bythe US DOT-FAA, are small, light-weight devices operated within the line of sight ofthe Pilot-in-Command (PIC), less than 500 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, Spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.
All our SUAs have proven capability for controlled flight. They are devices offered for general sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112-95,2014, have already provided you with the assurances onthe airworthiness ofSUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Buzz By Drones LLC should be permittedto conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions.

171PageAdditional Information

The Petitioner, Lance Atkins, is and was Executive Director of Fiberbenders Inti., a pole vaulting camp and campus for the teaching ofpole vaulting skills and safety (30 years

... from 1985-2015). Fiberbenders, has producedmore than 250 state champions and 15 National Champs, plus heaps ofstate andnational medalists. In addition, to beingthe Director of Fiberbenders, he was Director ofFuture Champions Track and Field Camps from 1985 to 2006 where thousands ofteenagers from around the country and world were taught to better athletes in the event oftheir choice.

He was onthe safety board for the USA Track & Field Association (the governing bodyofUSA Track & Field) with Chairman Jan Johnson in charge ofpole vault safety and certification and therefore is quite knowledgeable about Safley Prevention andprotectiontoproperty and human lives. His expertise ofsafety inthe athletics industry wouldbe helpful inteaching others about UAS safety and operations.

He has had a long term love for RC devices and therefore possess RC skills such as model building, repairing, maintaining and flying experience.

Satisfaction ofcriteriaprovided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe Petitioner's UAS.

y submitted,

# ~ ce Atkins, President BuzzByDrones LLC BuzzByDrones.com

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