U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

Petition ofBCAeronautics, LLC. for Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012.

To Whom It May Concern: Pursuantto Section 333 and 14 CFRPart 11, BCAeronautics, LLC, hereby applies for an exemption and specific relieffrom the following FARs: 14 C.P.R. 21; 14 C.P.R. 45.23(b); 14 C.P.R. 61.113(a) (b); 14 C.P.R. 91.7 (a); 14 C.P.R. 91.9 (b) (2); 14 C.P.R. 91.103; 14 C.P.R. 91.113; 14 C.P.R. 91.119; 14 C.P.R. 91.121; 14 C.P.R. 91.151 (a); 14 C.P.R. 91.203 (a) (b); 14 C.P.R. 91.405 (a); 14 C.P.R. 91.407 (a) 

### (1); 14 C.P.R. 91.409 (a) (1) and (2); 14 C.F.R. 91.417 (a) and (b), to allow commercial operations with sUASs for the purposes ofaerial data collection, academic and commercial research and development, real estate support, inspection support, oil and gas support, commercial and personal promotional videography, and any other safe aerial viewingneeds bothprivate and public currently notpossible ortoo expensive ordangerous for conventional aircraft. BCAeronautics intends to support any individual orentity in need ofaerial data, in any locality, that can be served safely and legally in reference to this requested exemption and the current blanket COA, any future approved COA, and in concordance with any necessary local ATC approval or law enforcement directive. The inherent safety and cost ofoperating sUASs for close aerial data collection compared withtraditional manned aircraft clearly defines the benefits to Society associated withthis petition for exemption. BCAeronautics will operatethe Dn PHANTOM 2 Vision+, the Dn INSPIRE 1, the Dn S1000, and any further and comparable sUAS's that can be operated for the above stated purposes and in the same safe manner. All proposed sUASs will operate safely at less than 37 pounds, at speeds never exceeding 50 knots, at altitudes never exceeding 400 feet AGL, and always within visual line ofsight ofa PIC and VO. All flights will occur only afterpreflightprocedures (forthe environment and aircraft) have been completed. Flights will take place only during daylight hours, not less than 5nm from designated Airports, with VMC (unless prior authorization is granted from the applicable PSDO or ATC facility). The sUASs will be operated in accordance with DJI operating manuals at all times and are inherently FCC compliant. BCAeronautics will operate sUASs using a PIC and aVO who are inpossession ofat least a private pilot license (PIC only) and a third class medical orvalid driver's license.Regulations from which exemption is requested: 14 C.F.R. 21 {h) Airworthiness Certificates The sUASs operated in the restricted environments and characteristics described above provide equivalent safety to manned aircraft with Airworthiness Certificates. Based on the proposed operations and sUASs safety can be maintained as the prime directive and relieffrom the above regulation is appropriate. 14 C.F.R. 45.23 (b) Marking oftheAircraft Itis notpossible to comply with this regulation in it's entirety regarding cockpit and cabin markings. Additionally it is notpractical to markthe fuselage ofeach sUAS in a mannerthat either upholds or enhances safety in relation to this regulation. To the extent possible, BCAeronautics will mark aircraft for the purposes ofidentification and maintain documents atthe ground station that satisfy this need to the extentpossible. Reliefis requested in reference to the marking ofaircraft for thepurpose of identification in the air. 14 C.F.R. 61.113 (a) (b) Private PilotPrivileges and Limitations/Pilot in Command The sUASs will not carrypilots orpassengers. Theypose a greatly reduced risk for catastrophic failure and damage compared to manned aircraft based on flight characteristics and size alone. So much so, that an equivalent level ofsafety will exist inrequiring only private pilot qualifications for PIC operation ofthe sUASs. Reliefis requested in reference to flight for hire and the need for a commercial pilot certificate. 14 C.F.R. 91.7 (a) Civil Aircraft Airworthiness Not applicable (reference 14 C.F.R. 21(h))- NoAirworthiness Certificate. All applicable documents will be available for inspection atthe groundstation. 14 C.F.R. 91.9 (b) (2) Civil AircraftFlightManual Size and payload capacity restrict the possibility ofcompliance with this regulation andrequire relief. All applicable documents including FOMwill be available for inspection atthe ground station. 14 C.F.R. 91.103 Preflight Action sUASs manufactured by 

### Dll do nothave approved takeoffand landing distance data. Furthermore, BCAeronautics will not operate under SVFRor IFRconditions. Relieffrom preflight action is appropriate as safety equivalentto thatprovidedbythe regulation shall be upheld. 14 C.F.R. 91.113 Right ofWayRules The inherent safety in relation to size, flight characteristics, and operational capabilities ofthe sUASsI

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I provide an equivalent level ofsafety in regards to see and avoid and yielding right ofway after visual identification oftraffic during VMC. During all missions right ofway and cessation offlight operations will be given and executed immediately in thepresence ofmanned aircraft. 14 C.F.R. 91.119 Minimum Safe Altitudes Relieffrom this regulation is requested due to the intended safe operations and designed use ofthese sUASs for close proximity photography and inspection. The operations that BCAeronautics intends to support, as stated above, must be accomplished at altitudes below 500 feet AGL thus an exemption from 91.119 (c) is needed. In accordance with current guidelines, we request operations 400 feet AGL and below. 14 C.F.R. 91.121 Altimeter Settings 14 C.F.R. §91.121 requires a person operating an aircraft to maintain cruising altitude or a flight level by reference to an altimeterthat is setto the elevation ofthe departure airport orbarometric pressure. The sUASs BCAeronautics intends to operate are notequipped with a barometric altimeter, but instead use GPS for altitude control, which is transmitted to the pilotvia a digitally encodedtelemetric data feed. Relieffrom§ 91.121 is requested to allowthe GPS, radio, or laser altimeterto be used to maintain the correctAGL altitude. 14 C.F.R. 91.151(a) Fuel Requirements for**Fli~ht** in VFR Conditions The intended operations ofBCAeronauticswill span between 18 and 25 minutes and therefore cannot comply with the minimum 30 minutes ofextra fuel for planned VFRflight. The sUASs flown by BCAeronautics have fuel failsafe procedures both internal and contained in the system from 

### Dll. Returnto Home procedures are initiated prior to critical fuel levels and BCAeronautics will cease all operations at 25% batteryremaining or at an agreed upon safe critical battery level based on the operational environment. Relieffrom the above regulation is therefore requested. 14 C.F.R. 91.203 (a) (b) Carrying Civil Aircraft Certifications and Registrations As the sUASs flown by BCAeronautics will nothave Airworthiness Certificates relieffrom this regulation is requested. An equivalent level ofsafety shall be maintained by housing these documents (ifand when applicable) at the ground station. 14 C.F.R. 91.405(a): 407(a)(l): 409(a)(1)(2): 417 (a)(b) Maintenance BCAeronautics believes that an exemption from these maintenance requirements is warranted because the sUASs will nothave an airworthiness certificate, andthe FAAhas not developed equivalentpart 91 maintenance requirements for sUAS. More specifically, no individuals are authorized bythe FAAto approve a sUAS for return to service under 91.407(a) or to conduct initial airworthiness inspections.A Summary the FAA maypublish in the FederalRegister:

Pursuantto Section 333 and 14 CFRPart 11, BCAeronautics, LLC, hereby applies for an exemption and specific relieffrom the following FARs: 14 C.P.R. 21; 14 C.P.R. 45.23(b); 14 C.P.R. 61.113(a) (b); 14 C.P.R. 91.7 (a); 14 C.P.R. 91.9 (b) (2); 14 C.P.R. 91.103; 14 C.P.R. 91.113; 14 C.P.R. 91.119; 14 C.P.R. 91.121; 14 C.P.R. 91.151 (a); 14 C.P.R. 91.203 (a) (b); 14 C.P.R. 91.405 (a); 14 C.P.R. 91.407 (a) (1); 14 C.P.R. 91.409 (a) (1) and (2); 14 C.F.R. 91.417 (a) and (b), to allow commercial operations with sUASs for the purposes ofaerial data collection, academic and commercial research and development, real estate support, inspection support, oil and gas support, commercial and personal promotional videography, and any other safe aerial viewing needs bothprivate andpublic currently notpossible ortoo expensive ordangerous for conventional aircraft. BCAeronautics requests relieffrom the above mentioned regulations and any other applicableparts of 14 C.F.R. 61 and 91 to allow for safe, reliable, financially efficient, and vital commercial operation of sUASs in support ofany entity or individual in need ofaerial datacollection services. Our customers range from the Energy Industry all the way to weddingphotographers and rely on our commitmentto safety and ethics in the budding sUAS industry. Benefits to the Public as a Whole: BCAeronautics' entry into the NAS will benefit the public as a whole by by providing enhanced saftey, and at minimum an equivalent level ofsafety, to all aspects ofUAS operations described above when those operations supplement orreplace use ofmanned aircraft. Additionally, fuel savings and affordability will be greatly enhanced by the use ofsUASs for operations such as real estate photography, aerial survey, and oil industry support. The slow speeds andpractical altitudes sUASs will be used at for collectingpreviously impossible to obtain data (because ofsafety and cost) arethe inherentbenefits to society and the commercial driving forces behind BCAeronautics' request for exemption. The ability to supportthe real estate market in Houston, TX and play a role in the health ofthat marketby answering the need for aerial photography ofa wide range ofproperties will benefitthe local economy. The ability to supportthe oil and gas industry (in a time ofdownturn for that economy) by allowing more frequent and non-destructive testing will enhance human safety in the oil field and present a much needed cost saving measure that will contribute tojob savings. Telecommunications infrastructure is an additional area ofsafety sensitivity where fall danger is an ongoing concern. sUAS operation can virtually eliminate the need for manned inspection of transmitters that accounts for up to 20 fall casualties peryear. Additionally, the enhanced safety and cost savings ofidentifying towers definitively in need ofmaintenance with the use ofsUASs has been explicitly requested bythe Telecommunications industry. Finally, an increasing number of"hobbyists" and sUAS operators who have notparticipated in the regulatory process are putting significant strain onthe NAS. BCAeronautics' adherence to strict regulatory compliance and the active participation ofall sUAS operators is ofutmost importance. BCAeronautics intends toprovide guidance and consultation to any interested party regarding the safe and legal operation ofsUASs andtheir appropriate entry to the NAS.14 C.F.R. 11.81(h) Requestto exercise the privileges ofthe Exemption outside the United States The global nature ofour intended customers means that BCAeronautics will need the ability to work outside ofthe United States. The ability to bring this technology, the associated applications, the premier safety protocols and procedures, along with the world's foremost aviation regulatory compliance practices are an invaluable resource that could beprovided to countries in desperate need after natural disasters or for developmentpurposes. IftheFAA believes additional exemptions beyond those requested in this petition are required for BCAeronautics to conduct the sUAS operations described here, we respectfully request an exemption from any such regulatoryprovisions as deemed necessary. For any questions orconcerns, please contact us directly at the phone numbers oremail address provided.

Best Regards, Kelly Coble MGR. BCAeronautics, LLC. POBOX7259 Houston, TX 77248 281.772.9372 info@bcaeronautics.com

# ~ Franz Willette MGR. BCAeronautics, LLC. POBOX7259 Houston, TX 77248 612.709.0421 info@bcaeronautics.com