1. U.S. Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
Washington, DC 20590
Petition of BCAeronautics, LLC. for Exemption Pursuant to Section 333 of the
FAA Modernization and Reform Act of 2012.
To Whom It May Concern:
Pursuant to Section 333 and 14 CFR Part 11, BCAeronautics, LLC, hereby applies for an exemption
and specific relief from the following FARs:
14 C.F.R. 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2);
14 C.F.R. 91.103; 14 C.F.R. 91.113; 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 (a) (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (1) and (2);
14 C.F.R. 91.417 (a) and (b), to allow commercial operations with sUASs for the purposes of aerial
data collection, academic and commercial research and development, real estate support, inspection
support, oil and gas support, commercial and personal promotional videography, scripted closed set
filming for the motion picture and television industry, and any other safe aerial viewing needs both
private and public currently not possible or too expensive or dangerous for conventional aircraft.
BCAeronautics intends to support any individual or entity in need of aerial data, in any locality, that
can be served safely and legally in reference to this requested exemption and the current blanket COA,
any future approved COA, and in concordance with any necessary local ATC approval or law
enforcement directive. The inherent safety and cost of operating sUASs for close aerial data collection
compared with traditional manned aircraft clearly defines the benefits to Society associated with this
petition for exemption.
BCAeronautics will operate the DJI PHANTOM 2 Vision+, DJI Phantom 3, Firefly 6, the DJI
INSPIRE 1, the DJI S1000, and any further and comparable sUAS's that can be operated for the above
stated purposes and in the same safe manner. All proposed sUASs will operate safely at less than 37
pounds, at speeds never exceeding 50 knots, at altitudes never exceeding 400 feet AGL, and always
within visual line of sight of a PIC and VO. All flights will occur only after preflight procedures (for
the environment and aircraft) have been completed. Flights will take place only during daylight hours,
not less than 5nm from designated Airports, with VMC (unless prior authorization is granted from the
applicable FSDO or ATC facility).
The sUASs will be operated in accordance with DJI operating manuals at all times and are inherently
FCC compliant. BCAeronautics will operate sUASs using a PIC and a VO who are in possession of at
least a private pilot license (PIC only) and a third class medical or valid driver's license.

2. Regulations from which exemption is requested:
14 C.F.R. 21 (h) Airworthiness Certificates
The sUASs operated in the restricted environments and characteristics described above provide
equivalent safety to manned aircraft with Airworthiness Certificates. Based on the proposed operations
and sUASs safety can be maintained as the prime directive and relief from the above regulation is
appropriate.
14 C.F.R. 45.23 (b) Marking of the Aircraft
It is not possible to comply with this regulation in it's entirety regarding cockpit and cabin markings.
Additionally it is not practical to mark the fuselage of each sUAS in a manner that either upholds or
enhances safety in relation to this regulation. To the extent possible, BCAeronautics will mark aircraft
for the purposes of identification and maintain documents at the ground station that satisfy this need to
the extent possible. Relief is requested in reference to the marking of aircraft for the purpose of
identification in the air.
14 C.F.R. 61.113 (a) (b) Private Pilot Privileges and Limitations/Pilot in Command
The sUASs will not carry pilots or passengers. They pose a greatly reduced risk for catastrophic failure
and damage compared to manned aircraft based on flight characteristics and size alone. So much so,
that an equivalent level of safety will exist in requiring only private pilot qualifications for PIC
operation of the sUASs. Relief is requested in reference to flight for hire and the need for a commercial
pilot certificate.
14 C.F.R. 91.7 (a) Civil Aircraft Airworthiness
Not applicable (reference 14 C.F.R. 21(h)) – No Airworthiness Certificate. All applicable documents
will be available for inspection at the groundstation.
14 C.F.R. 91.9 (b) (2) Civil Aircraft Flight Manual
Size and payload capacity restrict the possibility of compliance with this regulation and require relief.
All applicable documents including FOM will be available for inspection at the ground station.
14 C.F.R. 91.103 Preflight Action
sUASs manufactured by DJI do not have approved takeoff and landing distance data. Furthermore,
BCAeronautics will not operate under SVFR or IFR conditions. Relief from preflight action is
appropriate as safety equivalent to that provided by the regulation shall be upheld.
14 C.F.R. 91.113 Right of Way Rules
The inherent safety in relation to size, flight characteristics, and operational capabilities of the sUASs
provide an equivalent level of safety in regards to see and avoid and yielding right of way after visual
identification of traffic during VMC. During all missions right of way and cessation of flight operations
will be given and executed immediately in the presence of manned aircraft.

3. 14 C.F.R. 91.119 Minimum Safe Altitudes
Relief from this regulation is requested due to the intended safe operations and designed use of these
sUASs for close proximity photography and inspection. The operations that BCAeronautics intends to
support, as stated above, must be accomplished at altitudes below 500 feet AGL thus an exemption
from 91.119 (c) is needed. In accordance with current guidelines, we request operations 400 feet AGL
and below.
14 C.F.R. 91.121 Altimeter Settings
14 C.F.R. § 91.121 requires a person operating an aircraft to maintain cruising altitude or a flight level
by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure.
The sUASs BCAeronautics intends to operate are not equipped with a barometric altimeter, but instead
use GPS for altitude control, which is transmitted to the pilot via a digitally encoded telemetric data
feed. Relief from § 91.121 is requested to allow the GPS, radio, or laser altimeter to be used to
maintain the correct AGL altitude.
14 C.F.R. 91.151(a) Fuel Requirements for Flight in VFR Conditions
The intended operations of BCAeronautics will span between 18 and 25 minutes and therefore cannot
comply with the minimum 30 minutes of extra fuel for planned VFR flight. The sUASs flown by
BCAeronautics have fuel failsafe procedures both internal and contained in the system from DJI.
Return to Home procedures are initiated prior to critical fuel levels and BCAeronautics will cease all
operations at 25% battery remaining or at an agreed upon safe critical battery level based on the
operational environment. Relief from the above regulation is therefore requested.
14 C.F.R. 91.203 (a) (b) Carrying Civil Aircraft Certifications and Registrations
As the sUASs flown by BCAeronautics will not have Airworthiness Certificates relief from this
regulation is requested. An equivalent level of safety shall be maintained by housing these documents
(if and when applicable) at the ground station.
14 C.F.R. 91.405(a); 407(a)(1); 409(a)(1)(2); 417 (a)(b) Maintenance
BCAeronautics believes that an exemption from these maintenance requirements is warranted because
the sUASs will not have an airworthiness certificate, and the FAA has not developed equivalent part 91
maintenance requirements for sUAS. More specifically, no individuals are authorized by the FAA to
approve a sUAS for return to service under 91.407(a) or to conduct initial airworthiness inspections.

4. A Summary the FAA may publish in the Federal Register:
Pursuant to Section 333 and 14 CFR Part 11, BCAeronautics, LLC, hereby applies for an exemption
and specific relief from the following FARs:
14 C.F.R. 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2);
14 C.F.R. 91.103; 14 C.F.R. 91.113; 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 (a) (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (1) and (2);
14 C.F.R. 91.417 (a) and (b), to allow commercial operations with sUASs for the purposes of aerial
data collection, academic and commercial research and development, real estate support, inspection
support, oil and gas support, commercial and personal promotional videography, scripted closed set
filming for the motion picture and television industry, and any other safe aerial viewing needs both
private and public currently not possible or too expensive or dangerous for conventional aircraft.
BCAeronautics requests relief from the above mentioned regulations and any other applicable parts of
14 C.F.R. 61 and 91 to allow for safe, reliable, financially efficient, and vital commercial operation of
sUASs in support of any entity or individual in need of aerial data collection services. Our customers
range from the Energy Industry all the way to wedding photographers and rely on our commitment to
safety and ethics in the budding sUAS industry.
14 C.F.R. 11.81(h) Request to exercise the privileges of the Exemption outside the United States
The global nature of our intended customers means that BCAeronautics will need the ability to work
outside of the United States. The ability to bring this technology, the associated applications, the
premier safety protocols and procedures, along with the world's foremost aviation regulatory
compliance practices are an invaluable resource that could be provided to countries in desperate need
after natural disasters or for development purposes.
If the FAA believes additional exemptions beyond those requested in this petition are required for
BCAeronautics to conduct the sUAS operations described here, we respectfully request an exemption
from any such regulatory provisions as deemed necessary. For any questions or concerns, please
contact us directly at the phone numbers or email address provided.

5. Best Regards,
Kelly Coble Franz Willette
MGR. BCAeronautics, LLC. MGR. BCAeronautics, LLC.
PO BOX 7259 PO BOX 7259
Houston, TX 77248 Houston, TX 77248
281.772.9372 612.709.0421
info@bcaeronautics.com info@bcaeronautics.com