Aug 17th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Bridger Aerospace, LLC. – DBA BA UAS for an Exemption Pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAAModernization and Reform Act of 2012 ("Reform Act") 

and 14 C.F.R. Part 11, Bridger Aerospace, LLC. ("BA") hereby applies for an exemption from the 

Federal Aviation Regulations ("FARs") identified below to allow commercial operation of small 

unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting; 

aerial search and rescue operations in South Western Montana’s Mountainous terrain in support of 

state and county search and rescue efforts, law enforcement, firefighting support, police, fire and 

rescue services, education and capability demonstrations and aerial videography for Montana’s

prairie families and ranching real estate and inspection and agriculture survey.

This petition for exemption is made based on information outlined in this Petition for 

Exemption, as well as the accompanying documents.

1. PIC Flight Operations Manual

2. Operations Manual

(collectively referred to as "BA's Operations Manuals")

3. User Guide

4. User Manual

(collectively referred to as "Manufacturer's Manual")

1

BA submits these and all materials as confidential documents pursuant to 14 C.F.R. § 

11.35(b), as the materials contain confidential commercial and/or proprietary information that BA

has not and will not share with others. Additionally, these documents contain operating conditions 

and procedures that are not generally available to the public and are protected from release under 

the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1

The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, 

but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot 

training manuals, service information letters and, safety/service bulletins.
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Page 2

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial Emergency, Real Estate Videography and Inspection, and Agriculture 

Surveying Services

II. Relevant Statutory Authority

IV. BA's Proposed UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot

Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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Page 3

I. DESCRIPTION OF PETITIONER

Based in Belgrade, MT, Bridger Aerospace is a provider of Unmanned Aircraft Systems (UAS) that 

is leveraging this rapidly improving technology, designing and significantly enhancing emergency 

management solutions for the private and public sectors. BA’s UAS emergency management, first 

responder situational awareness solution and UAS training services are designed to improve 

Emergency Management Operations (EMO) for the public, ranch owners, prairie families, industry 

and government to protect all people in natural disasters; weather, fires, snow avalanches, for 

medical needs, search & rescue, and other lifesaving and protective operations. BA strives to protect 

and save lives through broad base adoption of its UAS services in South Western Montana providing 

first responders and location teams with BA UAS equipment and training. Additionally, BA will 

provide its expanded services for video photography and photogrammetry for agriculture, real 

estate, fire fuel management, surveying and other Infrared multi-spectral imaging tasks for its 

clients. 

The contact information for Petitioner is as follows: 

Tim Sheehy

President

Bridger Aerospace 

351 Floss Flats Rd, Suite A

Belgrade, MT, 59714

Phone: 651-592-5140

Email: timsheehy@bridgersolutionsgroup.com

II. DESCRIPTION OF PROPOSED OPERATION

BA seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI 

Phantom UAS ("Phantom") for the proposed operations discussed below. All UAS operations will 

occur under tightly controlled conditions on private property where BA has received permission to 

operate from the landowner, controller or authorized representative. The proposed UAS operations 

will be conducted in accordance with the conditions and limitations of this Petition for Exemption 

and BA's Operations Manuals. As detailed in BA's Operations Manuals, all UAS operations will be

limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator, in 

uncontrolled airspace, and will occur at least 5 nm away from an airport. Moreover, BA's 

Operations Manuals incorporate redundant safeguards to assure that the aircraft does not travel 

outside the controlled area of UAS operations, including GPS "geo-fencing" technologies.

A. Aerial Emergency, Real Estate Videography and Inspection, and Agriculture 

Surveying Services
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BA seeks to use small UAS for the purpose of conducting aerial emergency support 

services and provide real estate videography and inspection, and agriculture surveying. BA has 

tailored its operations to meet the requirements established by the FAA in prior grants of

exemption authorizing commercial use including;

 Windtrap Digital Media, LLC (Exemption No. 12544)

 Mr. Greg Priest (Exemption No. 12522)

 HAZON Solutions, LLC (Exemption No. 11487)

 Visual Arts Group, LLC (Exemption No. 11733)

 Land Grant Surveyors LLC (Exemption No. 12505)

 RPA/UAS Consulting LLC (Exemption No. 12515)

 Legend Creative Group (Exemption No. 11789)

 Digitals by Ronnie (Exemption No. 11787)

All UAS EM training operations will occur on private property in a controlled area, away 

from spectators and persons. In addition, the UAS training operations will be conducted during

daylight, VFR conditions, at altitudes below 400' AGL. As set forth below, BA's operations provide 

an equivalent level of safety that is superior to performing the same work using conventional fixedwing aircraft or helicopters.

BA seeks to use its small UAS for the purpose of conducting BA UAS emergency and additional 

video photography services to improve emergency management UAS disaster operations and 

training systems. BA will perform a verity of emergency and operational scenarios for law 

enforcement, firefighting support, police, fire and rescue and disaster emergency operations. 

Additionally, BA will provide aerial videography real estate and inspection and agriculture survey

for South Western Montana’s prairie families and ranchers. Traditional methods of disaster - search 

and rescue training expose personnel to risks of harm or serious injury. Without the use of UAS for

real life emergency operations require a wide variety of dangerous demands on personnel 

including but not limited to climbing mountains, traversing ravines, climb buildings, walls, roof 

tops, towers, etc, and perform work which exposes them to the risk of dangerous or fatal falls. 

Additionally, proximity to equipment often involves a risk of exposure to hazardous situations that 

can include chemicals, oxygen-deficient atmospheres, and other natural hazards associated with

fires, collapsed buildings, bridges and facilities failures from weather and other natural disasters. 

The use of small UAS mitigates these hazards and is ultimately a much safer method of performing

these types of EM operations.

UAS use for real estate, inspection and agriculture survey for Montana’s prairie families and 

ranchers is also safer than traditional low flying aircraft performing the same functions in such

terrain. Conventional operations using rotorcraft and fixed-wing aircraft in low level operations 

present risks associated with vehicles weighing thousands of pounds and carrying a crew and large

amounts of fuel. 
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It is important to note that the use of small UAS in this area will not only be safer and more cost 

effective, but the quality of the information will be far superior. Small UAS inspection is more

reliable, and allows for the collection, dissemination, and storage of visual and other sensory data 

with greater precision and duration. Small UASs will also be capable of accessing and inspecting

areas that would otherwise be inaccessible using personnel in mountainous canyon regions. 

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system."

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following

considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and

§§ 44702 – 44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 

(petitions for exemption).

IV. BA'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT

The small UAS operations proposed by BA in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and 

relevant factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

A Grant of Exemption is appropriate for operations conducted using the DJI Phantom UASs due to

their size weight, speed, and operational capability.
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 Both the DJI Phantom have been approved for use in prior Section 333 Grants of 

Exemption from the FAA.

2

 The DJI Phantom weighs less than 55 pounds, including payload.

 The DJI Phantom will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using

GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any

combination thereof. This information will be transmitted to the pilot via telemetric data

feed.

 The UASs will have system redundancies and independent functionality to ensure the 

overall safety and predictability of the system. If connection to the remote control or

ground control station is lost, failsafe systems will permit the UAS to return to a 

predetermined location and safely land without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the 

Federal Communications Commission ("FCC") and other appropriate government 

oversight agency requirements. The operating frequency for the DJI Phantom is 2.4 

GHz frequency band.

If the same operations were conducted using a helicopter, the aircraft's take-off weight 

would likely exceed 6,000 pounds. The difference in weight between the DJI Phantom and a

helicopter significantly reduces the potential harm to the participating and non- participating

individuals or property in the event of an accident or incident. In addition, the risk to the onboard 

pilot and camera operator is eliminated.

2

See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to LowCountryRC, 

Corp. (Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant 

of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156). 
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Aug 17th, 2015

Page 7

B. Approval is Warranted Based on the Operational Restrictions Set Forth in

BA's Operations Manuals

BA's Operations Manuals and the Manufacturer's Manual for the selected UASs will contain 

all the procedures and limitations necessary to safely and successfully perform the operations 

specified in this Petition for Exemption. To assist the FAA in making a safety assessment of BA's

proposed operations, below is a summary of operational limitations and conditions that BA will

adhere to, and which will ensure an equivalent or higher level of safety to operations conducted 

under current regulatory guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number)

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large

as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in 

Command ("PIC") of the UAS, and one or more Visual Observers ("Observer") as 

necessary to safely conduct the mission.

5. PICs shall possess at least a Sport Pilot's Certificate and current Class III Medical 

Certificate and a valid state driver’s license. The PIC will also meet the flight review 

requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The 

PIC must use human vision unaided by any device other than corrective lenses, as 

specified on the PIC's FAA-issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate 

verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.
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9. The additional requirements identified in the Grant of Exemption shall be added to 

the BA's Operations Manuals. The Operations Manuals will be maintain and made 

available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in the Grant of Exemption and BA's Operations

Manuals, the conditions and limitations in the Grant of Exemption shall take

precedence and must be followed. Otherwise, BA shall follow the procedures 

outlined in their Operations Manuals.

10. BA may update or revise its Operations Manuals. Revisions will be tracked and a

revised copy of the Manual will be provided to the Administrator upon request. BA

will also present an updated and revised Operations Manuals if it petitions for

extension or amendment to its Grant of Exemption. If an update or revision would 

affect the basis upon which the FAA grants the exemption, BA will seek an 

amendment to its Grant of Exemption. BA will contact the FAA’s UAS Integration 

Office (AFS-80) if questions arise regarding updates or revisions to the operating

documents.

11. BA Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a DJI Phantom flight unless (considering wind 

and forecast weather conditions) there is enough power to fly to the first intended 

point of landing, and assuming normal cruising speed, to fly after that for at least 10 

minutes.

13. Maximum total flight time for each operational flight using the DJI Phantom will be

limited to 40 minutes or the amount of time the UAS can be flown and still maintain 

a reserve battery power of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never 

enter navigable controlled airspace without prior written authorization and approval 

from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the

UAS will not be operated more than 100 feet above the highest point on the structure, 

and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons. (persons other than the PIC, VO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:
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Page 9

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of operating

closer to those objects and determined that it does not present an undue

hazard, and;

c. Operations nearer to the PIC, VO, operator, trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a).

16. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The UAS may not operate within 5 nm of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the BA COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition 

safe for flight. The pre-flight inspection will account for all discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. The PIC shall not operate the UAS if the 

inspection reveals a condition that affects the safe operation of the UAS until the 

necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The ground control station shall be included in the preflight 

inspection. All maintenance and alternations must be properly documented in the

UAS records as required by BA's Operations Manuals.

19. BA will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations 

will be noted in the UAS records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to 

service.
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20. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics (e.g., replacement of a flight critical component) 

must undergo a functional test flight in accordance with BA's Operations Manuals.

The PIC who conductsthe functional test flight must make an entryin the UAS aircraft

records of the flight. The requirements and proceduresfor a functional test flight and

UAS record entry shall be included in the BA's Operations Manuals.

21. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the 

requirements on BA's Operations Manuals.

23. BA will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under 

this Grant of Exemption. A NOTAM will be issued as required by the COA. All 

operations will be conducted in accordance with airspace requirements in the ATO

issued COA including class of airspace, altitude level and potential transponder

requirements.

24. All required permissions and permits will be obtained from territorial, state, county

or city jurisdictions, including local law enforcement, fire or other appropriate

governmental agencies.

25. If the UAS loses communication with the pilot, it will have the capability to return 

to a pre-determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted 

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate or a 

 valid state driver’s license.

29. Prior to conducting flight operations for the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 

25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS 

pilot with a similar UAS type.
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Page 11

30. Prior to conducting flight operations for the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §

61.51(b), a minimum of hours as UAS pilot operating the make and model of UAS

to be utilized for operations under the exemption and three take-offs and three

landing in the preceding 90 days.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

special visual flight rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute

activities, parasailing activities, hang gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are 

prohibited.

34. The UAs will not be operated from an elevated platform or moving device/vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation

and control of the UAS will comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §

40101 of the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.

3

BA seeks an exemption from several interrelated provisions of Title 14 of the Code of

Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested 

operations using a UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption 

is sought, and (2) the operating procedures and safeguards that Petitioner has established which will

ensure a level of safety better than or equal to the rules from which exemption is sought.

4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting

the exemption would not adversely affect safety, or how the exemption would provide a level of

safety at least equal to that provided by the rule from which you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no exemption 

is needed.

5 If, however, the FAA determines that there are some characteristics of the chosen UAS

that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

BA's use of the DJI Phantom is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV(A), the 

DJI Phantom weighs less than 55 pounds, including payload and will not be flown at a ground speed 

in excess of 50 knots. Both UASs are also equipped with safety features that will allow Petitioner 

to operate the UAS safely after experience certain in-flight contingencies or failures.

6 7Additionally, 

the UASs carry neither pilots nor passengers, carry no explosive materials or flammable liquid fuels, 

and operate exclusively within the parameters stated in BA's Operations Manuals.

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to LowCountryRC, Corp. (FAA-2014-0803 at pg. 3): 

"The [DJI S1000] has the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses an auto-pilot system to maintain UAS stabilityand control.

The UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link

event with a pre-coordinated, predictable, automated flight maneuver, and manual flight

control functionality as a backup. These safety features provide an equivalent level of safety 

compared to a manned aircraft performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The DJI Phantom can be operated entirely by a touch-screen, map-based interface.

This means the operator only needs to command the system where to go, and the system 

does all the flying for the operator. The DJI Phantom can be operated in both semi and fully

autonomous flight modes, with the operator simply clicking on a map to create a pre-planned

flight path for a flight. In addition, the operator can create no fly zones or maximum flight

ranges and altitudes so the system cannot enter areas

{footnote continued}
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Operations conducted under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. BA will also provide the FAA with advance notice of all

operations via NOTAMs as required by the applicable COA. In all cases, operation of the DJI 

Phantom under the proposed conditions will be at least as safe as, or safer than, conventional 

rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because 

those capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In

addition, no sense-and-avoid technology is necessary for the UASs because they will be operated 

at all times in VFR conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category

Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that BA's small UASs would otherwise require

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H,

supra.

__________________________

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in

intelligent fault handling which allows the DJI Phantom to detect a system fault while in the air and

automatically fly back to its takeoff location and land. Faults that can be detected include: loss of

communication; exceeding pre-set wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. The flight control system employs not only GPS positioning

but a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to

ensure stabilityso long as wind thresholds are not exceeded. Also a flight termination link – to prevent 

a 'fly away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id
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Page 14

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

BA seeks an exemption from the aircraft marking and identification requirements contained 

in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number

is displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches

nor more than 6 inches high, the words "limited," "restricted," "light-sport,

"experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both

surfaces of the cabin, fuselage, boom, or tail the marks required by

§ 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings in 

accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by BA will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

11

10

FAA Docket No. FAA-2014-03

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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Aug 17th, 2015

Page 15

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

BA seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. §

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ...have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is

needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, 

which the UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or 

Service Bulletins. Further, as required by BA's Operations Manuals, the PIC will conduct a preflight inspection of the UAS and all associated equipment to account for all discrepancies and/or 

inoperable components. Maintenance will be performed and verified to address any conditions 

potentially affecting safe operation of the UAS and no flights will occur unless, and until, all flight 

critical components of the UAS have been found to be airworthy and in a condition safe for 

operation. A functional test flight will be conducted following the replacement of any flight-critical 

components. As required by BA's Operations Manuals, the PIC who conducts the functional test 

flight will make an entry in the UAS aircraft records of the flight.

BA's Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for 

the following applicable components: powertrain system (powerplant), propellers, avionics and 

control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical

systems (including batteries), ground control station, hazard accessories, and spare parts. Further,

BA's Operations Manuals also includes procedures to document and maintain a record of the UAS

maintenance, preventative maintenance, alterations, and status of replacement /overhaul component 

parts, and the total time in service of the UASs used under this Grant of Exemption. As a whole, 

the maintenance and inspection procedures required in BA's Operations Manuals ensure that an 

equivalent or higher level of safety will be achieved.
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Aug 17th, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

BA seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical 

certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches 

the airspace in which the PIC will be operating, as well as requiring certifications if the private pilot 

is carrying passengers or cargo for hire. In this case, while the UASs will be operated as part of a

commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption to 

Astraeus Aerial

12, the FAA determined that the unique characteristics of UAS operation outside of

controlled airspace did not warrant the addition cost and restrictions attendant with requiring a the 

PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment of the 

additional requirements for a private pilot to become qualified as a commercial pilot would not lead 

to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions BA has placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. BA will operate on private property away from persons and 

property not involved in the operation. BA will also obtain an ATO issued COA prior to conducting 

any operations under this Grant of Exemption. All operations will be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. A NOTAM will also be issued as required by the applicable

COA.

In addition to these flight restrictions, BA will further ensure safe operation by requiring

that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all

aircraft operators but also in the unique aspects of UAS flight. As set forth in the Operations 

Manuals, pilots will have experience not only in UAS operations generally but have logged flight 

time in the specific make and model used for the operations before they are permitted to participate

in commercial flights on behalf of BA. The pilot qualification, training, and currency requirements 

in the Operations Manuals ensure that BA's pilots are competent and proficient in the UAS they are

operating. BA's training and qualification requirements are consistent with those contained in prior 

FAA Section 333 Grants of Exemption, and will provide a higher level of competency and

proficiency for its pilots and will ensure at least an equivalent level of safety.

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Aug 17th, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UASs, BA seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to 

be operated. The FAA has stated that no exemption is required for 14 C.F.R. §

91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable.

13

Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with

Section V(A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry 

airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. §

91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unlessit has within 

it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

 _________________

13

See id. at 13-14, 22.
U.S. Department of Transportation

Aug 17th, 2015

Page 18

Given the small size and configuration of the UASs, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the UAS because there is simply no 

room and the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean 

E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 

91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, 

registration certificate, and other required documents from the ground control station from which 

he or she is operating the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the

intent of the rule is to ensure the pilot has access to these key documents during flight. Therefore, 

an equivalent level of safety will be achieved by ensuring that the pilot has access to the documents

at the ground control station from which he or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

BA seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA-approved

Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary

to safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flight 

Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the BA's Operations Manuals 

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify

any defects or inoperable components in accordance with the BA's Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be 

required to review weather, flight requirements, battery charge, landing and takeoff distance, UA

performance data, and contingency landing areas—before initiation of flight. BA's Operations

Manuals and the Manufacturer's Manual will be kept at the ground control station and will be

accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

________________________

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation 

and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. 

FAA-2014-0352 at 16-18.
U.S. Department of Transportation

Aug 17th, 2015

Page 19

BA seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"no person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished 

through the use of a device that communicates with the aircraft via radio communications. 

Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 

91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that BA intends to use, an equivalent level of safe

training can still be performed without dual controls because no pilot or passengers are aboard the

UAS, and as required by the BA's Operations Manuals, all persons will be a safe distance away in 

the event that the UAS experiences any difficulties during flight instruction. Moreover, as required 

by the BA's Operations Manuals, all flight training will be conducted in controlled and sterile 

environment. As a whole, the safety procedures provided for in BA's Operations Manuals ensure

that the proposed UAS operations provide an equivalent or higher level of safety than that provided 

by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

BA requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure

in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to

operate at less than those minimum altitudes when it can be operated "without hazard to persons or

property on the surface," provided that "each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur

below 400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height 

exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on 

the structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the

proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the 

UAS.

____________________

15 Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an 

emergency landing without undue hazard to persons or property on the ground in the event of a 

failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an 

exemption from § 91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to 

Slugwear, Inc., dba Likeonatree Aerial (FAA-2014-0534 at 15).
U.S. Department of Transportation

Aug 17th, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the UASs, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the UASs, as well the controlled 

location where the operations will occur. In order to avoid any risk to manned aircraft, flight

operations will be restricted to 400 feet AGL or below, or when inspecting a structure whose height

exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet 

horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and 

all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, 

unless that person is in a position where he or she is shielded from the UAS and any possible debris 

resulting from UAS failure. As required by the Operations Manuals, flights will be terminated if a

nonparticipating person within 500 feet of the UAS leaves a shielded position. Further, UAS

operations will occur at least 500 feet away from vehicles or structures unless the property

owner/controller has granted permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and, operations near the PIC or Observer will not present an undue

hazard per § 91.119(a). Adherence to these restrictions in BA's Operations Manuals will ensure

operations can be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

BA seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of

the departure airport or barometric pressure. An exemption is required to the extent that the UASs 

do not have a barometric altimeter, but rather a GPS altitude read out.

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the

UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons

afforded such protection. The operator must also ensure that nonparticipating persons remain under

such protection. If a situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons.

In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles

and structures when the owner/controller of anysuch vessels, vehicles orstructures grants permission

for the operation and the PIC makes a safety assessment of the risk of operating closer to those 

objects and determines that it does not present an undue hazard."
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Aug 17th, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL

or below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to 

the operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude

initiation point is established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that BA intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by BA's Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 

Grants of Exemption, the UASs BA intends to use, and the safety mitigation procedures contained 

in the Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a

Grant of Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

BA requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from 

the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

 ____________________

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated 

more than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21)
U.S. Department of Transportation

Aug 17th, 2015

Page 22

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved 

by prohibiting the PIC from beginning a DJI Phantom flight unless (considering wind and forecast 

weather conditions) there was enough power to fly to the first intended point of landing and, 

assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, 

the FAA considered that the UAS batteries for the DJI Phantom provided provide approximately

50 minutes of powered flight (with payload) and provided battery level and battery time remaining

in minutes and seconds to the PIC.

19 The FAA also considered the fact that the DJI Phantom

operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and 

that in the event that the UAS should run low on power, the PIC will be alerted and can land the

DJI Phantom as soon as possible. Like the VDOS Grant of Exemption, BA's use of the DJI 

Phantom, combined with the requirements of Petitioner's Operations Manuals, ensure that an 

equivalent level of safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the DJI Phantom unless 

(considering wind and forecast weather conditions), there was enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 25% battery power remaining. 

BA will adhere to this limitation for DJI Phantom flights.

The DJI Phantom includes a low battery warning system and the amount of battery reserve 

power remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS

to a ground-based-on-screen display.

20 As required by BA's Operations Manuals, the PIC will

promptly fly the UAS back to the home launch location or pre-determined abort location where the

UAS may safely land, while still maintaining a minimum of 25% reserve battery power. BA

submits that the procedures requiring flights to be safely terminated once the batteries fall below 

25% capacity, combined with the requirement that flights only be conducted within a secure, 

isolated area, using a UAS weighting less than 55 pounds, and within VLOS of the PIC and 

Observer(s), ensure that the proposed operation will provide an equivalent or higher level of safety

to that provided by the regulations from which exemption is sought.

________________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20

The DJI Phantom ground control station displays, the UASs position, navigation route, tail 

number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time,

and sensor heading and orientation relative to the UAS.
U.S. Department of Transportation

Aug 17th, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

BA will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug.

VII. PUBLIC INTEREST

The public interest will be served by granting BA's Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe

working environments such as those proposed in this Petition. Granting this Petition for Exemption 

helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA

Administrator's assessment of whether certain UAS may operate safely in the NAS before

completion of the statutorily required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improve safety 

and reduce risk harm or serious injury to personnel. Traditional methods of disaster - search and 

rescue expose personnel to risks of harm or serious injury. Without the use of UAS most real life 

emergency operations require personnel to work in a wide variety of dangers which exposes them

to be subjected to risks of life threatening dangers. Proximity to equipment disasters such as oil 

and gas rigs and other implement equipment often involves exposure to hazardous chemicals, 

oxygen-deficient atmospheres, fires and other dangers associated with manmade disasters. The use 

of small UAS mitigates these hazards and is ultimately a much safer method of performing nearly 

all types of EM operations.

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no 

passengers or crew. Further, in the unlikely event of an accident, BA's small battery powered UASs 

presents significantly less danger to persons on the ground when compared to operations by

conventional manned aircraft.

21 As Petitioner's UASs are battery powered, the public will also 

benefit from a reduction in harmful emissions associated with the FAA in prior Section 333 Grants 

of Exemption to search and rescue and disaster recovery , UASs provide an additional tool for aerial

search and rescue and disaster recovery, adding a greater degree of flexibility, which supplements 

the current capabilities offered by manned aircraft.

22

____________________

21

See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12):

"Manned helicopters conducting aerial reconnaissance can weigh 6,000 pounds or more and are

operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The

petitioner’s UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew

will be remotely located from the aircraft. The limited weight significantly reduces the potential for

harm to participating and nonparticipating individuals or property in the event of an incident or

accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the 

use of a UA for the aerial search and rescue reconnaissance operation."
U.S. Department of Transportation

Aug 17th, 2015

Page 24

VIII. PRIVACY

All BA UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each flight to be

conducted.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c);

91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent film work and aerial 

search and rescue efforts, law enforcement, firefighting support, police, ranching and real estate 

operations, agriculture and precision aerial surveys with conventional fixed-wing aircraft, 

rotorcraft, or other methods.

X. CONCLUSION

BA's Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed UAS operations will benefit the public

as a whole by improving safety and reducing risk by alleviating human exposure to danger. In

consideration of the foregoing, this Petition for Exemption provides the FAA with more than 

adequate justification for granting the requested exemptions allowing BA to use small UASs for: 

conducting search operations in Mountainous terrain in support of state and county search and 

rescue efforts, law enforcement, firefighting support, police, fire and rescue education and 

capability demonstrations, commercial photography and videography in support of ranching and 

real estate operations in Montana and agriculture survey operations.

22

See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Aug 17th, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully submitted,

Should you have any questions, or if you need any additional information to support the 

requested exemptions, please contact the undersigned at:

Bridger Aerospace 

Phone: 651-592-5140

Email: timsheehy@bridgersolutionsgroup.com

(The following attached items contain proprietary and commercial information exempt from 

disclosure under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachments:

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals