James Bender

434 Foreland Garth Abingdon, MD 21009

Jamie@J65Productions.com

Website: www.J65Productions.com

Dear Sir or Madame,

Please see the below exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. I had a previous submission and it was requested that i provided information on public safety. I have decided to reor ganize my submission to better match the requirements of the exemption submission. Previous submission was FAA

- 2015

- 2525

- 0001.

(B) Specific Sections of 14 CFR Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 CFR 21 subpart H 14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119(c)

14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 (a) and (b) 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)

(C) E xtent of Relief I Seek

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, James Bender, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow

com mercial operation of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section

333. Commercial operation of an UAS, as described herein, which are equip ped 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 and other related professional ac tivities. 2. Aerial video and/or photography for public and/or private use including television, publicevents, 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 w ith 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 individually or belonging to both private and/or public organizatio ns to increase awareness and improve safety for current and future UAS operations within the

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 th e 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.”

(D) R easons Why Granting My Request Would be in the Public Interest Aerial photography and has been around for a long time through manned fixed wing aircraft and helicopters. For small budget productions the expense of such aerial photography and videography is cost prohibitive. Only larger companies can afford to absorb such expense. Manned aircraft pose a threat to the publi c through the potenti al of a catastrophic crash. My

s UAS poses no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercial ly flown

sUASs into the national airspace system, hence the passing of the Reform Act. Granting my exemption request furthers the public interest through academic/visual awareness of the photography and videography fields throughout the Grand Rapids area. My ultra

- lightweights UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra

- lightweights UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial photography and videography captured through my battery operated ultra

- lightweights UAS's.

Permitti ng me to immediately fly within national air space furthers economic growth. Granting

my exemption request substantially furthers the economic impact for the Grand Rapids area for companies looking to use aerial photography and videography, both of which s erve as a stimulus to the community

(E) Reasons Why Granting the Exemption Would Not Adversely Affect Safety

Given the small size of the UAS’s involved and the restricted controlled environment within which they will operate, the applicant fits within tha t zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the

controlled areas in which the relevant UASs will operate, approval of the application presents nonational security issue. Given the following, the grant of the requested exemptions is clearly in the public interest: James Bender proposes that the exemption requested herein apply to civil

aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for an exceptional level of safety to operations. These limitations and

conditions to which James Bender agrees to be bound when conducting commerc ial operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of operator. 3. Maximum total flight time for each operational flight will be 30 minutes. 4. Flights will be t erminated at 15% battery power reserve. 4. Flights will be operated at an altitude of no more than 400 feet AGL 5. UAS operator will be trained and certified in the proper safety and operations of the UAS. 6. The UAS will only operate within a controlled a rea as defined in the Procedures. 7. The operator will post advisor notice around the controlled area. 8. The operator will have been trained in operation of UAS generally and received up

- to

- date

information on the particular UAS to be operated as required. 9. If the UAS loses communications or loses its GPS signal, the UAS will have capability to

return to a pre

- determined location within the Security Perimeter and land. 10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

(F) A summary you can publish in the Federal Register

(1) The Rules From Which I Seek Exemption

14 CFR 21 subpart H
14 CFR 45.23(b)
14 CFR 61.113(a) and (b)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121
14 CFR 91.151(a)
14 CFR 91.203 (a) and (b)
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)

(2) A Brief Description of the Relief I Seek

Approval of exemptions allowing commercial operations of sUASs in the the media industry will enhance safety by reducing risk associated with conventional aircraftoperations and other means of elevated remote sensing involving persons. The public

benefit served by approval of this petition is increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than 11 kg and powered by sealed batteries eliminates virtually all associated risk inherent in operating conventional

aircraf t in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed data.The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and

is prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. I look forward to working with your office. Please contact me at any time if

additional information or clarification s is needed.

Sincerely,

James Bender