BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

17 February 2016

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE

Washington DC 20590

Re: Exemption Request § 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR § 21;

61.113 (a) & (b); 91.7 (a); 91.9 (b); 91.103(b); 91.109 (a); 91.119 (c); 91.121; 91.109; 119.121; 91.151(a);

91.203(a)&(b); 91.405(a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam,

I, Joshua R. Black, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the

procedures contained within 14 C.F.R. 11, to request that I, Joshua R. Black, an owner and operator of

small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I,

Joshua R. Black, may operate my Small Unmanned Aircraft Systems (sUAS) in commercially regulated

airspace by the Federal Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, Joshua R. Black, will primarily use my professionally built

DJI Inspire 1 Pro & Aeronavics XM Heavy Lift, and future professionally built sUAS equipped with cameras

for the following applications: Closed­Set Film Operations on Film and Television Productions, as well as

aerial videography/cinematography to safely enhance films and commercials; augmentation of real estate

listing videos; and the creation of visual and topography layout videos for Search and Rescue (SAR)

missions for state and local agencies, education, agricultural inspections and building and construction zone

inspections.

I am 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 you require additional

information or clarification.

Name and address is:

BLAXSTUDIOS, LLC

Joshua Ryan Black

Phone: 281­782­3631

Email: ryan@blaxstudios.com

Address: 1230 Valley St, Unit B, Anchorage, Alaska 99504

1 of 20 | Joshua R. Black’s Petition for Exemption Under Section 333
BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

BACKGROUND OF PETITIONER

BLAXSTUDIOS, LLC is a Veteran/Family owned business and is operated by Joshua Ryan Black. Mr. Black

is an FAA licensed pilot with a rotary­wing rating. Additionally Mr. Black is an FAA certified air traffic

controller with over 8 years experience working in accordance with FAA regulation. Mr. Black is well

equipped with knowledge of FAA air traffic regulations and ATC radio communications with military,

commercial and general aviation. Mr. Black has experience in combined full scale and model aviation with

extensive military aviation background and an A.S. degree in Airway Science.

Mr. Black currently possesses multiple not in use UASs to be registered for use under this

exemption.

● DJI Inspire 1 Pro X (currently registering)

● Aeronavics XM Heavy Lift (pending)

● Freefly ALTA (pending)

Joshua R. Black’s, exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted

by remote control) UAS’s for the development of community and government use videos, permissible within

property boundaries for individual homeowners and within in tightly controlled, limited airspaces

predetermined in areas away from the general public, airports, heliports and vehicular traffic.

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur

hobbyists with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to

assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific video and

photography usage by sharing information with the FAA as I, Joshua R. Black, record flight data and other

pertinent information gained through permitted flight operations.

In addition, granting my, Joshua Black’s, exemption request will comply with the Secretary of

Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace

system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real

estate/Realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field

monitoring, film/video productions, closed­set motion picture film operations and television, and structure

inspections, to aid state and local agencies.

Further I, Joshua Black, will conduct my operations in compliance with the protocols described herein or as

otherwise established by the FAA. For the reasons stated below, I, Joshua R. Black, respectfully request the

grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to aid academic

community awareness, to benefit/stimulate attraction to the state of Alaska and to enhance personal and

public video feeds. A grant that will ultimately allow UAS’s to play a more positive role in our local community

by increasing employment opportunities, heightening security measures and decreasing government

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BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel­ a

potential public hazard in and of itself.

I. Contact Information:

Joshua R. Black

BLAXSTUDIOS, LLC

Anchorage, Alaska 99504

Phone: 281­782­3631

Email: group@blaxstudios.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which Joshua R.

Black Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Joshua R. Black Seeks and the Reason He Seeks Such Relief:

I, Joshua R. Black, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331­334,

seeking relief from any currently applicable FARs operating to prevent me, Joshua R. Black, contemplated

commercial cinematic, academic and other flight operations within the national airspace system. The Reform

Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace

system as it is in the public’s interest to do so. My, Joshua R. Black’s, ultra lightweight UAS meets the

definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra

light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight

UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such

craft. Thereby, providing direct experience and valuable information for formal regulation that can be

administered uniformly to all related UAS aerial video and photography. The Reform Act guides the

Secretary in determining the types of UAS's that may operate safely in our national airspace system.

Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will

be operated near airports or heavily populated areas; and, Whether the UAS will be operated by line of

sight. 112 P.L. 95 § 333 (a).

3 of 20 | Joshua R. Black’s Petition for Exemption Under Section 333
BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

Each of these items reflect in favor of an exemption for me, Joshua R. Black. My UAS’s utilize eight (8) or

less rotating propellers for balance, control and stability. My UAS’s are equipped with the following via video

and data telemetry:

1) Altimeter

2) Attitude indicator

3) Ground Speed indicator

4) Magnetic compass

5) Heading indicator

6) Vertical speed indicator

7) Course deviation indicator

8) Radio magnetic indicator

9) GPS location

10) Battery consumption and Battery Left with approximate time.

11) Loiter and circle mode.

12) Auto safety or RTL (Return To Launch)

13) Auto landing technology.

Each UAS weighing less than thirty five (35) pounds (far below the maximum 55 pound limit); Including

camera(s) with or without gimbal (a camera stabilizer). I, Joshua R. Black, considers safety as foremost with

each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter via

GPS and can be operated in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial

loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that

allows my UAS to hover/circle in place or land when radio controls are released.

With three (3) modes to choose from, I will fly with the modes safest to complete the videos for aerial

videography/photography and have the ability to choose the safest, most reliable and stable mode to

prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed

slowly descend to point of takeoff and or to land at point of launch after ascending to a pre­set altitude to

ensure the UAS will clear any obstacles that may be between the takeoff point and the current position of

the UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight.

I, Joshua R. Black, will not operate my UAS near airports, hospitals nor police heliports, and do not operate

near areas where general public is within fifty to one hundred (50­100) yards depending on location,

conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.)

and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft

approach my location or I suspect manned aircraft may approach near my location. My UAS’s are capable of

vertical and horizontal operations, and is flown only within my line of sight, as the remote control pilot. My

UAS's are also flown with a second operator who aids in watching for any obstacles, including manned

aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights

generally last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) feet.

(3)Smart Mode includes, position hold, self­leveling, altitude command, GPS, return home feature, and

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BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

safety control to return home or land in the event of communication interruption between RC transmitter and

UAS.

I, Joshua R. Black, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time

limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate my UAS at or below

manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe

operating range to insure adequate communication between radio control and UAS to eliminate potential for

crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for

sufficient safe level of operation. I do not believe in taking risk that may cause a crash that could create

hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked

numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain

familiarization with the characteristics of this specific UAS's performance under different temperature and

weather conditions. I also practice computerized simulated flights to maintain adequate skills and response

reflex time. All for the sake of safety.

I, Joshua R. Black, am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft

and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b).

Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it

promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace

system. Joshua R. Black’s UAS, used in hobby flight, has a demonstrable safety record and does not pose

any threat to the general public or national security.

IV. How Joshua R. Black’s Request Will Benefit the Public as A Whole:

Aerial videography for geographical awareness, education, search and rescue, land management, structure

inspections and for real estate marketing has been around for a long time through manned fixed wing

aircraft and helicopters. For small budget companies, average homeowners and property owners the

expense of such aerial videography is cost prohibitive. Only large companies and high end Realtors or

luxury homeowners can afford to absorb such expense; depriving non­luxury owners and lower budget

companies from a valuable marketing tool. Manned aircraft pose a threat to the public through potential

catastrophic crash that the Anchorage community has experienced in the past with military aircraft, medical

helicopters, and news helicopters crashes within the city of Anchorage. Each resulting in loss of life.

Each with combustible fuel that exploded and burned on impact. Police helicopters have made emergency

hard landings within city limits. My, Joshua R. Black'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 commercially flown UAS's into the national airspace system, hence the

passing of the Reform Act. Granting my, Joshua R. Black’s, exemption request furthers the public interest

through academic/visual awareness of the geographical benefits in and around the metro Anchorage area.

My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The

consequence of my ultra light weight 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

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BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture

through my battery operated ultra lightweight UAS's.

Permitting me, Joshua R. Black, to immediately fly within national air space furthers economic growth.

Granting my exemption request substantially furthers the economic impact for the metro Anchorage and

surrounding community for companies looking to relocate or build around the Anchorage metro area as well

as individuals looking to relocate for career advancement through academic and geographical awareness.

Both of which serve as a stimulus to the community.

V. Reasons Why Joshua R. Black’s Exemption Will Not Adversely Affect Safety or How the

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Joshua R. Black’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated

permitting me, Joshua R. Black, to log more flight time in FAA controlled airspace, with communication with

the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet

undiscovered safety protocols for Realtors, land and structured owners. For development in cooperation with

the FAA. In addition I, Joshua R. Black, submit the following representations of enhancements to current

aerial videography and photography: My UAS’s weigh less than thirty­five (35) pounds complete with a an

integrated ultra­light weight camera.; I only operate my UAS below 200 feet (well within the 400 foot

permissible ceiling set by the FAA Modernization and Reform Act of 2012); My UAS only operate for 3­30

minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot

my UAS through remote control only by line of sight; and have live video feed for a secondary pilot to

monitor video recording; I receive a live telemetry feed from my UAS during all flights which include

remaining battery voltage, distance, altitude, and any anomalies that may occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz­2.485Ghz frequencies in accordance with

CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz­5.875Ghz frequencies in accordance with CFR 47, Part 15.

My UAS’s have a GPS controlled flight controller­ a flight safety feature whereby it hovers or

circles and then lands at the GPS takeoff point if communication with the remote control pilot

is lost; I actively record and analyze flight data through the DJI Inspire 1 and DJI phantom 3 flight controller

app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that

are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I

conduct extensive preflight inspections and protocol, during which safety carries primary importance; I

always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in

the event of safety breaches or potential danger. My, Joshua R. Black’s, safety protocols provide a level of

safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial

UAS into our national airspace system, helicopters are the primary means of aerial video and photography

for community awareness real estate, structured inspections, land management and search and rescue.

While the safety record of such helicopters is remarkably astounding, there has been local incident involving

loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra lightweight

UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only

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BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

operate my UAS in specific areas away from mass populations. Second, there is no fuel on board a UAS

and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme

maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely.

Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need

not be so close to the objects they are focused on through the technology and use of post editing software

allowing pan and zoom. Accordingly, my UAS has been experimentally operated for

familiarization/competency and will continue to operate at and above current safety levels.

VI. A Summary the FAA May Publish in the Federal Register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H,

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness

certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my, Joshua

R. Black’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level

of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as

airports and dense populations. My, Joshua R. Black’s, current and projected UAS's meet or exceed each of

the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will

be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A,

9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global

positioning systems with a barometric sensor or controlled GPS “geofencing”

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They

are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by

maintaining any such required certifications and registrations by me, Joshua R. Black.

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be

marked according to certain specifications. My UAS can be marked with the appropriate “N” number once

this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) &

(b), private pilots are limited to non­commercial operations. I, Joshua R. Black, The sUAS Pilot in Command

7 of 20 | Joshua R. Black’s Petition for Exemption Under Section 333
BLAXSTUDIOS, LLC

1230 Valley St Unit B, Anchorage, AK 99504

group@blaxstudios.com

281­782­3631

must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review

requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in

14 C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation

of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never

operate at an altitude greater than 300fclose AGL; safely below the standard of 400 AGL. I, Joshua R.

Black, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at

least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight,

maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2, Manual

The above­cited Regulations require, amongst other things, aircraft owners and operators to “have [the]

aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this

chapter. . . .” These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to my, Joshua R. Black's, UASs. However, as a safety precaution I inspect my UAS before

and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness

Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth

requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The

size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my,Joshua

R. Black’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is

authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. §

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's

from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability

and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no

such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the

aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, maintenance program that involves regular software updates and curative measures for any

damaged hardware. Therefore, an equivalent level of safety will be achieved. In summary, Joshua R. Black

seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 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(b); 14 C.F.R. §

91.109; 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) and (b); 14

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

14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Joshua R. Black's, small unmanned

vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural inspection land

management, search and rescue and real estate operations, and to develop economic platforms for the

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BLAXSTUDIOS, LLC

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aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate and to find in the

metro Anchorage area.

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as

indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must

be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than corrective lenses,

as specified on the PIC's state driver’s license.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS

requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able

to communicate verbally at all times.

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in this

operations manual, the conditions and limitations herein take precedence and must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the UAS is

found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in

the preflight inspection. All maintenance and alterations must be properly documented in the aircraft

records.

8. 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 the operator's manual. The PIC who conducts the functional test flight must

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

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements. When unavailable, aircraft

maintenance/component/overhaul, replacement, and inspection/maintenance

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1230 Valley St Unit B, Anchorage, AK 99504

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requirements must be established and identified in the operator's manual. At a minimum, the

following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current

state driver’s license. The PIC must also meet the flight review requirements specified in 14 CFR §

61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar operations),

the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a

minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten

hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented

flight experience that was obtained in compliance with applicable regulations may satisfy this

requirement. Training, proficiency, and experience­building flights can also be conducted under this

grant of exemption to accomplish the required flight cycles and flight time. During training,

proficiency, and experience­building flights, all persons not essential for flight operations are

considered non­participants, and the PIC must operate the UAS with appropriate distance from

non­participants in accordance with 14 CFR § 91.119.

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12. Prior to operations conducted for the purpose of motion picture filming (or similar operations),

the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a

minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for

operations under the exemption and three take­offs and three landings in the preceding 90 days.

Training, proficiency, experience­building, and take­off and landing currency flights can be

conducted under this grant of exemption to accomplish the required flight time and 90 day currency.

During training, proficiency, experience­building, and take­off and landing currency flights, all

persons not essential for flight operations are considered non­participants, and the PIC must

operate the UAS with appropriate distance from non­participants in accordance with 14 CFR §

91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual

observer (VO) must have successfully completed a qualification process, as outlined in the

operator’s manual. As this is a requirement stipulated by the operator, the test must be

developed and implemented by a qualified person designated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and made

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar operations),

a flight demonstration, administered by an operator­approved and ­qualified pilot must be

successfully completed and documented. This documentation must be available for review upon

request by the Administrator. Because the knowledge and airmanship test qualifications have

been developed by the operator, and there are no established practical test standards that

support a jurisdictional FAA FSDO evaluation and approval of company designated examiners,

the petitioner will conduct these tests in accordance with the operator’s manual.

15. The UAS may not be operated directly over any person, except authorized and consenting

production personnel, below an altitude that is hazardous to persons or property on the surface in

the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety mitigations

for authorized and consenting production personnel. At all times, those persons must be essential to

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the closed­set film operations. Because these procedures are specific to participating persons, no

further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the

distances specified in the petitioner’s manuals. This is consistent with the manned aircraft

procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion

Picture and Television Filming.

17. Regarding distance from non­participating persons, the operator must ensure that no persons

are allowed within 500 feet of the area except those consenting to be involved and necessary for the

filming production. This provision may be reduced to no less than 200 feet if it would not adversely

affect safety and the Administrator has approved it. For example, an equivalent level of safety may

be determined by an aviation safety inspector’s evaluation of the filming production area to note

terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect

non­participating persons (observers, the public, news media, etc.) from debris in the event of an

accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. If the UAS loses

communications or loses its GPS signal, the UA must return to a predetermined location within the

security perimeter and land or be recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined

location within the security perimeter and land or be recovered in accordance with the operator’s

manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not

more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N­Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

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23. The operator must develop procedures to document and maintain a record of the UAS

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

parts, and the total time in service of the UAS. These procedures must be added to the

operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer's Safety

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be added

to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the

following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable

components, items, or equipment, not covered in the relevant preflight inspection sections of the

operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control of

the UAS must comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the

area of proposed filming. The 3­day notification may be waived with the concurrence of the

FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming production under

this grant of exemption

c. Name and phone number of the person responsible for the on­scene operation of the UAS.

d. Make, model and serial or N­number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming production event

f. A statement that the operator has obtained permission from property owners and/or local

officials to conduct the filming production event; the list of those who gave permission must

be made available to the inspector upon request.

g. Signature of exemption­holder or representative

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h. A description of the flight activity, including maps or diagrams of any area, city, town,

county, and/or state over which filming will be conducted and the altitudes essential to

accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at the

ground control station of the UAS any time the aircraft is operating. These documents must be

made available to the Administrator or any law enforcement official upon request.

30. The UAS must 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.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations

must be conducted under visual meteorological conditions (VMC). Flights under special visual flight

rules (SVFR) are not authorized.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. 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.

34. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA.

The UAS may not operate within 5 miles of the geographic center of a non­towered airport as

denoted on a current FAA­published 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 operator’s COA. The letter of agreement with the airport management must be

made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to the

Federal Aviation Administration’s (FAA) UAS Integration Office (AFS­80) within 24 hours. Accidents

must be reported to the National Transportation Safety Board (NTSB) per instructions contained on

the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident,

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accident, or transgression is reviewed by AFS­80 and authorization to resume operations is

provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of larger aircraft

running on combustible fuel. Posing potential risk to the public. Granting my, Joshua R. Black’s, request for

exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain

potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and

photographic aircraft with much less flight time.

Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and

from established airfields. I, Joshua R. Black, have been informally analyzing and recording flight information

and will compile safety protocols and the implementation of a flight operations manual for usage that

exceeds currently accepted means and methods for safe flight. Formal collection of information shared with

the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA

Modernization and Reform Act of 2012. There are no personnel on board my, Joshua R. Black’s, UAS and

therefore the likelihood of death or serious bodily injury is significantly diminished. My, Joshua R. Black’s,

operation of my UAS, weighing less than forty (40) pounds and traveling at lower speeds within limited areas

low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly

I, Joshua R. Black, respectfully request that the FAA grant my exemption request and am willing to

cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at

large.

Respectfully submitted,

Joshua R. Black

1230 Valley St, Unit B

Anchorage, Alaska 99504

Appendix A

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List of Aircraft

No. Make and

Model

Description Serial No. Registration

No.

1 DJI Inspire 1 Electric powered, 4 rotor, small

unmanned multirotor helicopter

W21ACL25020

025

Pending

1 Aeronavic

XM HL

Electric powered, 8 rotor, small

unmanned multirotor helicopter

No S/N Pending

1. DJI INSPIRE ONE

The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials

I. Plastic

II. Aluminum

2. Motor Configuration

I. The DJI Inspire 1­ flight is a 4 motor quadcopter setup. ,

3. Payload

I. The DJI INSPIRE ONE flies it’s own light­weight integrated camera.

II. Maximum All­up weight­ 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as

necessary.

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary.

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

and/or chips. Replace if propeller is questionable.

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and

perform a minimum of 15 test flights before conducting commercial work.

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Appendix B

2. Aeronavics XM Heavy Lift

The operation of the system is as follows.

1. Build Materials

I. Carbon Fiber, Plastic

II. Aluminum

2. Motor Configuration

I. The Aeronavics XM Heavy Lift flight in a 8 motor octocopter setup.

3. Payload

I. The Aeronavics XM Heavy Lift.

II. Maximum All­up Weight­ 15lbs

4. Maintaining the Aeronavics XM Heavy Lift

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary.

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary.

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

and/or chips. Replace if propeller is questionable.

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and

perform a minimum of 15 test flights before conducting commercial work.

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Appendix C

Personal Protocols/Controls/Flight Manual

Protocols and Controls

Joshua R. Black, Anchorage, Alaska.

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration

for aerial videos and photography. As such, safety protocols and controls must be implemented through

pre‐flight preparation and during flight. Pre‐Flight Protocol:

Check batteries with voltage meter to insure fully charged and ready for use.

Inspect batteries for damage or leakage that may affect proper operation.

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or

unmanageable/uncontrolled flight.

Check all GPS and Telemetry connections prior to flight.

Check weather forecasts for wind advisory or other conditions that my impact flight.

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of

possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of

flight, and any other pertinent information.

Inspect flight area for

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports

Vicinity of light poles vicinity or utility wires

Vicinity of trees flocks of birds that may cause interference and potential flight impact Vicinity of any

elevated obstructions that may pose potential flight hazard

Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may

attract viewers optional point of control for best visual site of UAS while in flight

Emergency landing areas

Takeoff and landing

Inspect area for best and safest point of takeoff and landing

If in a subdivision or area that is within 150 feet of a residential street, post warning

Sign(s)/stand(s) "Attention Aerial Photography In Progress ‐ Remain Back 150 Feet”

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Flight Protocol:​takeoff and land from same location (have alternate landing areas in case of emergencies)

remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to

engage in conversation or distract the remote control pilot restrict flight to minimal elevation sufficient to

acquire desired results remained prepared for emergency landing at all times pay attention to flight time –

warning meter for low voltage.

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut down propulsion

immediately following landing – priority of disconnecting batteries

Post flight:

1. a) Disconnect battery to prevent accidental activation of propulsion system

2. b) Secure UAS in a safe location

c) Remove all warning signs from public access areas Emergency or Suspected Hazard:

Immediate land UAS at safest and closet ground location in the event

Manned aircraft is heard or seen in vicinity of flight

There is a public gathering within established safety boundary wanting to observe flight

Pilot is being distracted from focusing on flight and safety

Sudden change in weather (wind bursts)

Sudden increase in vehicular traffic in vicinity of flight

Birds enter into proximity of flight

Any sudden unsafe event that can cause collision, distraction or interruption of control

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration

for aerial videos and photography.

Maintaining a record of safe flight for FAA request and for determining future UAS safety protocols is

imperative.

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Date:____________________ Location:___________________________________________________

Pre‐flight Inspection:

o Yes o No

Comment: _________________________________________________

Elements

Proximity to airport: _________________ (see attached map pinpointing approximate location of flight)

Airport notified: No Yes

Date:_______________ Time: ______________

Phone Number: _______________________

Contact Name:___________________________________

Nearest major intersection: ______________________________________________________________

Proximity to medium traffic road: _________________________________________________________

Proximity to heavily traveled roadway road: _________________________________________________

Proximity to congested population: ________________________________________________________

Approx. Takeoff Time: GMT:

Weather Good Fair Poor Comment:

Visibility Good Fair Poor Comment:

Wind Speed ___ mph ___ Gusts/MPH ___ avg/MPH Comment:

Approx. Landing Time: GMT: Estimated Elevation Ground level:

Safety Concerns:

Additional Comments:

Sea level:

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