U.S Department of Transportation December 30, 2015 Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Filed with www.regulations.gov

Re: Petitions for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Madam, Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act"), P .L. 112

- 95, "Special Rule s for Certain Unmanned Aircraft Systems" and 14 C.F .R. Part 11, Bruce L. Bates dba BruceB Photography providing Real Estate and Sporting Event , W edding photography and videography services, seeks an exemption from the Federal Aviation Regulations ("F ARs") and listed below:

14 C.F.R. Part 21

14 C.F.R. 45.23

14 C.F.R. 45.29

14 C.F.R. 61.3

14 C.F.R .61.23 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 61.133(a) 14 C.F.R. 91.7(a)

14 C.F.R. 91.9 14 C.F.R. 91.109(a)

14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R. 91.151(a)

14 C.F.R. 91.203

14 CF R Subpart E (91.401

- 91.417)

Summarized for purposes of Federal Register publication: Applicant seeks an exempt ion from the following rules : 14 C.F.R. Part 21, 14 C.F.R. 45.23, 14 C.F.R. 45.29, 14 C.F.R. 61.3, 14 C.F.R . 61.23 , 14 C.F.R. , 1.113(a)

& (b), 14 C.F.R. 61.133(a), 14 C.F.R. 91. 7(a), 14 C.F.R. 91.9, 14 C.F.R. 91.109(a), 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151 (a), 14 C.F.R. 91.203, 14 CFR Subpart E (91.401

- 91.417) to operate commercially a small unmanned vehicle (55lbs or les s) augmenting its rea l estate, sporting event , and wedding photography and videography operations.

Contact for the Applicant is:

Bruce L. Bates BruceB Photography LLC

820 Clif ford Drive Emmett, Idaho 83617 Cell Phone: (208 ) 891

- 0408

Email: zona5101 (@) yahoo.com

The requested exemption would authorize commercial operations using the UAV for real estate

, sporting

event

, and wedding photography and videography. These operations will be subject to strict operating

conditions defin ed by the UAV manufacturer’s standards and procedures in order to ensure at least an equivalent level of safety to currently authorized operations using manned aircrafts.Upon receipt of the exemption contemplated herein, I shall, if required, obtain a C ertificate of Waiver or Authorization (COA) form the FAA Air Traffic Organization prior to conducting operation(s) in the NAS.

**Proposed Use**

The main use of this UAS would be ta king photos and videos for real estate , wedding portrait and sporting

event photography . The UAS systems that I plan to use is a DJI PHANTOM 3 STANDARD and will be

referenced in this document

.

1. The safe operation to the NAS and/or persons and/or property will be kept to a minimum by always flying the UAS within visual eye contact, less than 400 ft above ground and never directly above persons or public places. The orientation of flights will be such that the pilot in command (PIC) always has a visual on the rear mounted LED flight Indicator. Additi onal safety features on the DJI PHANTOM 3 STANDARD include, return to home, low voltage, enhanced failsafe along with operating in the less populated 2.4

- 2.483 GHZ frequency range.

2. Pre

- flight inspection would be checking battery condition/level in both the transmitter and UAS. The binding/link feature will not let the UAS start if communication is not established. A check for power lines, antennas and other overhead objects would be performed. Wind conditions would be monitored and be a

factor for f lying. 3. The radio frequency of the DJI PHANTOM 3 STANDARD is in the 2.4

- 2. 483 GHZ range. The

maximum take off weight less than 1200g. Max Ascent speed is 5 m/s, and the Max Descent speed it 3 m/s. The Maximum flight Velocity is 16 m/s. The cruise speed is 5 m/s. 4. The PIC will be only Bruce L. Bates who has a previou s flying time as a hobbyist . Testing, updating and programming the DJI PHANTOM 3 STANDARD firmware would be done on a monthly schedule 5. I am in good medical health and sound mental health. I have no outstanding legal issues that would prohibit me from owning or operating said aircraft.

6. The intended use of this DJI PHANTOM 3 STANDARD is to provide affordable alternative to manned aircraft in providing high quality aerial pho tography services. 7. All photo flights for hire would have the date, time, GPS coordinates along with the camera metadata recorded on a hard drive and backed up to cloud storage services. This data would be kept readily available for a period of 1 year a fter each aerial flight for hire. 8. The proposed flight time will be the lesser of 25 minutes or the time

- duration of the UAV battery.

The DJI PHANTOM 3 STANDARD will never be flown in the flight path of manned aircraft. The first condition listed to always keep visual eye contact on the 22mm LED flight indicator is probably the most important. My main objective is to offer aerial photography at a competitive rate for the general public in the safest way possible.

**Public Interest:** Granting my request would be in public interest by giving an opportunity for real estate, sporting event , and wedding photographers to offer safer and more competiti vely priced aerial photography to the general public.

This exemption would not adversely affect the safety of the general public due to the size, weight, and keeping of the UAS in visual sight. The safety mechanisms of the herein described UAS provide fu rther protections when the PIC is no longer in control of the UAS. In comparisons to aerial photography from manned aircraft, low altitude photography from a UAS would be safer and have less of an environmental impact.

Thank you for your attention to thi s matter. Respectfully submitted,

Bruce L. Bates