January	14,	2016

U.S.	Department	of	Transportation

Docket	Operations

West	Building	Ground	Floor,	Room	W12-140

1200	New	Jersey	Avenue,	SE

Washington,	DC	20590

Ron	Morris

Bay	Technical	Solutions,	Inc.

203	Sea	Village	Lane

Kill	Devil	Hills,	NC	27948

baytechnicalsolutions@cox.net

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,	Petitioner	Ron	Morris	of	Bay	Technical	

Solutions,	Inc. (“BTS”),	an	owner	and	operator	of	small	unmanned	aircraft,	be	

exempted	from	the	Federal	Aviation	Regulations	(FAR’s)	listed	below	so	that	Bay	

Technical	Solutions,	Inc.	,	may	operate	its	small	unmanned	aircraft/lightweight	

unmanned	aircraft	systems	(UAS)	commercially	in	airspace	regulated	by the	Federal	

Aviation	Administration	(FAA);	as	long	as	such	operations	are	conducted	within	and	

under	the	conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	

required	by	Secion	333.	Commercial	operations	of	an	UAS,	as	described	herein,	

which	are	equipped	with	camera(s)	and	sensors,	would	provide	professional	

services	in	the	following	areas;

1. Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	

estate,	architecture,	land	surveying,	engineering,	commercial	construction	

site	evaluation	and	construction	management	and	other	related	professional	

activities.

2. Aerial	video	and/or	photography	for	public	and/or	private	use	including	

television,	public	events	cinematography	and	newsgathering.

3. Aerial	inspection/photography	of	residential/commercial	structures	under	

contract	with	the	owners	or	local	government	authority.

4. Aerial	inspection/photography	of	residential/commercial	utility	

infrastructure	including	but	not	limited	to	electrical	power	lines,	wind	

turbines	and	cell	towers.

5. Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	

and	rescue	operations	in	cases	of	an	emergency	or	natural	disaster	only	

when	the	local	authorities	or	government	has	requested	it	by	contract	or	

donation.

6. Training	to	persons	or	entities	individually	or	belonging	to	both	private	

and/or	public	organizations	to	increase	awareness	and	improve	safety	for	

current	and	future	UAS	operations	within	the	National	Air	Space	(NAS).
As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	

designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	

that	would	be;	A)	Limited	B)	Controlled	C)	Predetermined	and	D)	Safe.	Approval	of	

this	exemption	would	increase	public	awareness	of	UAS	operations	and	enhance	

safety	to	aid	in	fulfilling	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.”	

Our	Plan	is	to	operate	UAS,	DJI	PHANTOM	2,	DJI	PHANTOM	3,	3DR	SOLO,	Yuneec	

Q500 and	DJI	INSPIRE	1	which are	comprised	of	unmanned	aircraft	and	

transportable	ground	stations.	All are	referred	to	as	quad	copter	with	max	gross	

weights	under	55	lbs	each.	All are	equipped	with	four	rotors	that	are	driven	by	

electric	motors	powered	by	rechargeable	batteries.	

Regulations	from	which	exemption	is	requested:

14	CFR	61.23	(a)	and	(c)

14	CFR	61.101	(e)(4)	and	(5)

14	CFR	61.113	(a)

14	CFR	61.315	(a)

14	CFR	91.7	(a)

14	CFR	91.119	(c)

14	CFR	91.	121

14	CFR 91.	151	(a)(1)

14	CFR	91.405	(a)

14	CFR	91.407	(a)(1)

14	CFR	91.409	(a)(1)	and	(2)

14	CFR	91.417	(a)	and	(b)

Operating	Parameters:

Bay	Technical	Solutions	will	adhere	to	the	following	operating	parameters	when	

operating	UAs	pursuant	to	a	grant	of	the	requested	exemption;

1. Operations	will	be	conducted	using	the	DJI	PHNATOM	2	and	3	models,	DJI	

INSPIRE	1,	Yuneec	Q500	and	3DR	Solo.

2. The	UAS	will	not	be	operated	at	a	speed	exceeding	87	knots	(100	miles	per	

hour),	at	an	altitude	greater	than	400	feet	above	ground	level	or	when	

visibility	is	less	than	3	statute	miles,	less	than	500	feet	below	or	2,000	feet	

horizontally	from	clouds.	All	operations	will	be	conducted	during	daylight	

under	visual	flight	rules(VFR) and	conditions.

3. All	operations	will	be	conducted	in	accordance	with	a	Certificate	of	Waiver	

(COA)	authorization.

4. All	operations	will	use	Pilot	in	Command	(PIC)	and	visual	observer	(VO)	and	

the	UAS	will	remain	within	the	visual	line	of	sight	of	the	PIC	and	VO	at	all	
times.	The	PIC	will	maintain	VLOS	(visual	line	of	sight)	capability	and	the	

ability	to	communicate	verbally	with	the	VO	at	all	times.	

5. Principal	of	BTS holds	Private	pilot	certificate,	as	well	as	FAA	airman	medical	

certificate	and/or	valid	US	drivers	license.	The	PIC	will	meet	the	flight	review	

requirements	specified	in	14	CFR	61.56	in	an	aircraft	which	the	PIC	is	rated	

on	his	or	her	pilot	license.	Petitioner	will	follow	all	manufacturer’s	training	

program	and	safety	and	UAS	aircraft	does	not	carry	passengers	or	property	

for	compensation	for	hire.

6. BTS will	ensure	prior	to	operation	that	the	PIC	has	demonstrated	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	fight	hours	and	currency	will	be	logged	in	

manner	consistent	with	14	CFR	61.51(b).

7. Prior	to	each	flight,	the	PIC	will	conduct	a	pre-flight	inspection	and	determine	

the	UAS	is	in	a	condition	for	safe	flight.	If	the	inspection	reveals	a	condition	

that	affects	the	safe	operation	of	the UAS,	the	UAS	will	not	be	operated	until	

the	necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	

a	condition	for	safe	flight.	

8. BTS will	follow	the	UAS	manufacturer’s	maintenance,	overhaul,	replacement,	

inspection	and	life	limit	requirements,	as	well	as	safety	bulletins	for	the	

aircraft	and	aircraft	components.

9. The	PIC	will	abort	the	flight	in	event	of	unpredicted	obstacles	or	emergencies	

and will	yield	to	all	manned	aviation	activities.	

10. BTS	and/or	principals	or	BTS will	register	and	mark/label	its	UAS	in	

accordance	with	14	CFR	parts	47	and	45.	

Conclusion:

As	demonstrated	above,	the	UAS	operations	Bay	Technical	Solutions	has	proposed	

in	this	petition	for	exemption	will	garner	significant	public	benefits	while	preserving	

minimal	safety	risks.	BTS petition	satisfies	the	criteria	of	Section	333	of	the	FMRA	

and	is	substantially	similar	to	previous	petitions	the	FAA	has	granted,	meriting	a	

summary	grant	of	summary	exemption.	BTS respectfully	request	that	the	FAA	grant	

this	petition	to	enhance	BTS	ability	to	provide	important	“professional	service”	

herein	described	above, items	1-6.

Please	do	not	hesitate	to	contact	BTS	principal’s,	Ron	Morris	757-751-2923,	

rmorriskdh@gmail.com or	Raynald	Morris	757-342-0685	with	any	questions	about	

this	filing.

Sincerely,

Ron	Morris