Gary Bilbao 

Gary Bilbao photography 

49 Stonehenge Dr. 

Lincroft, NJ 07738 

Business 732-530-3633

Cell 908-915-9943

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3)

(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

1) Supplemental Response for Petition

2) BLADE Chroma Camera Drone with CGO3-GB 4K with SAFE® Technology+ User 

Manual

3) Personal protocols and controls -Safety/Flight concerns Pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11,

I, Gary Bilbao, a board certified professional Photographer for more than 12

years. Would like to apply for an exemption from the following Code of Federal

Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned

Aircraft Systems (UAS) for aerial photography and video of homes listed for sale in

central New Jersey requested by the home owner or real estate agent. For

the exemption length of the maximum allowed by the FAA. (maximum gross

weight 64 ounces, equipped with four rotors that are driven by electric motors powered

by batteries, the approximate flight time 20 minutes.) A built in camera with intent for

aerial video and photography to enhance sales and better represent the home for Real

Estate marketing purposes. Following an exemption and approval by the FAA. My

exemption request would permit operation of ultra-light weight, unmanned (piloted by

remote control) in predetermined areas inside the home owners property lines, away

from general public, airports, heliports and vehicular traffic, under 300 ft. with a more

likely operational envelope of less than 100 ft. After carefully reviewing, inspecting and

examining the area of aerial observation. This would allow for photography within

property boundaries of an individual homeowner's real estate listing.

In a debate about I will abide all FAA requirements to ensure this exemption will provide 

a level of safety at least equal to existing rules and will only operate in a safe 

environment that is strictly controlled. Away from power lines, elevated lights, airports 

and actively populated areas; and I will conduct extensive preflight inspections and 

protocols, during which safety carries primary importance. 14 C.F.R. Part 21, Subpart H: 

Airworthiness Certificates 14 CFR 91.203. Given the size, weight, speed, and limited 

operating area associated with the aircraft to be utilized, I am asking exemption from

14CFRpart21,Subpart H (Airworthiness Certificates) and 91.203 (a) and (b)

(Certifications required),subject to certain conditions and limitations, is warranted and

meets the requirements for an equivalent level of safety under14CFRpart 11 and
Section 333of P.L. 112-95 (Section 333).14 C.F.R. 45.27(a): Location of marks; non

fixed-wing aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks

Furthermore I request an exemption from 45.23 Marking of the aircraft because my

UAS will not have a cabin, cockpit on which to mark certain words or

phrases. Additionally two -inch lettering will not fit on such a small aircraft with

dimensions smaller than the minimal lettering requirement. I understand the need for

markings and will mark my UAS in the largest possible lettering by placing the word

“Experimental” or assigned number or name (based on a request or ruling by the FAA )

on its fuselage as required by 45.29(f) so that anyone assisting me as a spotter will

see the markings. I also ask for an exemption from 91.405(a),91.407(a)(1),

91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be required and

should be granted since they only apply to aircraft with an airworthiness certificate. But,

as a safety precaution I will perform a preflight inspection of my UAS before each flight

as outlined in his operating documents.14 CFR 61.113 (a) & (b): Private pilot privileges

and limitations: Pilot in command. Under 61.113 (a) and(b) private pilots are limited to

non-commercial operations, however I can achieve an equivalent level of safety as

achieved by current regulations because my UAS does not carry any pilots or

passengers. While helpful, a pilots’ license will not ensure remote control piloting skills.

The risks of operating a UAS are far less than the risk levels inherent in the commercial

activities outlined in 14 CFR part61,et seq., I requests an exemption from 61.113

Private Pilot Privileges and Limitations .Regarding UAS operational training, I have

experience flying practice flights in a remote control park located in Farmingdale NJ an

area designated for hobbyist for remote control flight. The purpose is to gain

familiarization with the characteristics of my UAS’ performance under different

temperature and weather conditions. I am aware of a three-day drone training course in

Las Vegas Nevada and would attend if required by the FAA.14 C.F.R. 91.103 (b)(1),

(b)(2): Preflight Action If granted an exemption I agree to additional safety procedures

including, but not limited to:

1)Keeping my UAS within a radius distance of 1000 feet from the controller to both

aid in direct line of sight visual observation.

2)Operate the UAS for 3-7 minutes per flight; land my UAS according to the

manufacturer’s recommended minimum level of battery power.

3)Operate my UAS only within visual line of sight (VLOS).

4)Use the UAS’ global positioning system(GPS) flight safety feature; it hovers and

then slowly lands if communication with the remote control.

Public Benefit and Safety:
Granting the present petition will further the public interest by allowing Gary Bilbao

Photographers to safely, efficiently, and economically perform aerial video and 

photography of, real estate locations, and landscapes.

It will decrease congestion of the National air space by using unmanned aircraft that do 

not require an airport to takeoff or land. therefore it will reduce the amount of manned 

aircraft conducting aerial video and photography missions. It would then result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations, reduce pollution, and provide significant 

benefits to the economy.

My BLADE Chroma Camera Drone can be considered superior to full size manned 

aircraft for this company's purposed limited use, due to the smaller device size ,cheaper 

equipment and personnel cost, reduced noise that will greatly benefit the public by 

drastically reducing the levels of air and noise pollution that are generated during 

traditional full sized fixed wing aerial flight operations. By using battery power and 

electric motors, my UAs (Unmanned Aircraft System) will not produce air pollution, and 

is the most viable environmentally conscious alternative to the traditional full sized 

MANNED fixed wing aircraft.

I am petitioning for an exemption to operate a UAs with a built-in stabilized HD camera 

and GPS safety features which restrict its ability to a specified height above ground. It 

also has a feature that limits the distance it can fly from the controller thus adding an 

additional level to public safety.

my UAs also has a failsafe function that is triggered in the event communication is lost 

between the UAs and the main controller transmitter. At that time, the UAs will 

autonomously return to its point of takeoff and land safely.

Additional information:

Operating the battery powered UAs is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides 

such flexibility without the high operational cost of a traditional manned aircraft. By 

operating a UAs, companies such as Gary Bilbao Photography , can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors,

which will ultimately contribute to growth of the U.S. economy.

I will only operate my UAs in mine or my observer's line-of-sight and will operate at 

locations that are `sufficient distance' from populated areas within the flight area. Such 

operations will ensure that the UAs will "not create a hazard to users of the national 

airspace, or the public."

I will not fly the UAs within five (5) miles of an airport . Maximum flight time for each 

operation will be between 4-12 minutes.

Flights will be terminated when battery levels reach 25%, allowing sufficient reserve 

flight time to safely land the UAs.

The UAs will be programmed so it will not be operated at an altitude that exceeds 200 

feet AGL, and not more than 200 feet above an elevated platform from which video and 

photography is planned.

Minimum crew for each operation shall consist of: UAs operator, and a visual UAs 

observer,
The UAs operated by Gary Bilbao weighs less than 8 pounds, including all payload (i.e. 

camera, lens, and stabilized gimbal ).

The UAs will operate at speeds of no more than 18 knots per hour.