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 Rules for Certain Unmanned Aircraft Systems" and 14 C.F .R. Part 11, Bruce L. Bates dba 

BruceB Photography providing Real Estate and Sporting Event, Wedding 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 CFR Subpart E (91.401 - 91.417)

Summarized for purposes of Federal Register publication:

Applicant seeks an exemption 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 less) augmenting its real estate, sporting event, and 

wedding photography and videography operations. 

Contact for the Applicant is: 

Bruce L. Bates

BruceB Photography LLC

820 Clifford 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 defined 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 Certificate 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 taking 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. Additional 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 flying. 

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 previous 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 photography 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 after 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 competitively 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 further 

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 this matter. 

Respectfully submitted, 

Bruce L. Bates