1
Richard Ray Blodgett , Section 333 Exemption Petition

January 16, 2016 1950 NE OLD BELF

AIR HWY BELF AIR, W A 98528

Re : Exemption Request Section 333 of the F AA R eform Act of the Federal Aviation Regulations from 14 C.F .R.45.23(b); 14 C.F

.R. Part 21; 14 C.F

.R. 61.113(a)&(b); 91. 7(a); 91.9(b) (2); 91.103(b); 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)

To Whom It May Concern: I, Richard Ray Blodgett, am writing pursuant to the F AA Modernization and Re form Act of 2012 and the procedures in 14 C.F .R. 11, to request that I, Richard Ray Blodgett, may operate my small unmanned aircraft systems (UAS) in commercially regulated airspace by the F eder al Aviation Administration (F AA). I, Richard Ray Blodgett, ha ve been flying UAS for recreational purposes for the past 3 years. I have experience in flying hobby planes, drones, and helicopters. In the 3 years, I have flown without incident and pledge my continued commitment to safety on all future flights. With the exemption and approval by the F AA, I, Richard Ray Blodgett, will use my DJI Inspire 1, as a professional aerial f ilmmaking platform / Safety Inspection for the following applications: for real estate/Realtor purposes, Search and Rescue, agricultural fi eld monitoring, land/trusts inspections, structure inspections, f ilm/video productions, Cell T ower / Tw o way Radio Safety Inspections / Bridge or Infrastructure Safety Inspections.

I. Safety

, Design, and Operations The DJI Inspire 1, that I will be using for videography will be safely conducted to minimize risk to NAS, people and property on the ground and in the air . The DJI Inspire are professional aerial f ilm making platforms. The advanced flight controller makes the DJI Inspire stable, safe, and e asy to fly. The Vision P ositioning system, on the Inspire 1 and Phantom 3, gives it the power to hover in position at low altitudes even without GPS. The UASs are able to return home if the remote controller signal is lost or if the low battery warning i s triggered. They are equipped with an onboard camera. The Inspire 1 has a maximum flight speed of 22m/s (no wind), and a maximum flight time of 18 minutes using one fully charged 4500mAh Intelligent Flight Battery . I have2

programmed the UASs to give me an automatic low battery warning at 30%, and at 10%, they will automatically R TL (return to launch). I, Richard Ray Blodgett have personally installed safety protocols and regulations exclusive to lightweight UAS’ s for specif ic video usage by sharing info rmation with the F AA as I, Richard Ray Blodgett , record flight data and other important information gained through permitted flight operations. I, Richard Ray Blodgett will be cognitive of surroundings by checking for people, power lines, etc. On the DJ I website ( http://www .dji.com/product/inspire

- 1 ) when describing the Inspire 1 and Phantom 3 it states, “ As it flies, the position of your Inspire 1 is constantly updated and recorded using a high

- stren gth, intelligent GLONASS + GPS system. This dual positioning system enables higher precision and quicker satellite acquisition, allowing you to see where the aircraft is on a live map and giving it a point to hover at when you release the controls. In addi tional to traditional GPS, GLONASS offers an even greater level of precision by providing even more satellites. The Inspire 1 even remembers its takeoff point and dynamically tracks your current position, so you can bring your Inspire 1 back to you at the press of a button. ” The DJI Inspire 1, also feature Electronic Speed Controllers (ESCs) that handle communication between the Main Controller and motors. “They tell each motor exactly how fast to spin and how much power to use at all times. As you fly a nd maneuver around, each motor moves at its own speed as calculated by DJI’ s advanced algorithms, giving you complete control” ( DJI, 2015 , website). The fail

- safe feature on the DJI Inspire assist them in landing before an accident can occur . “If the battery runs low or connection with your remote controller is lost, the Inspire 1 uses its positioning system and smart flight technology to return back to you” ( DJI, 2015, website ). The DJI Inspire are steady and stable during flight, because the advanced Inertial Measurement Unit (IMU) handles everything. “The IMU incorporates both a 6

- axis gyroscope and an accelerometer to monitor miniscule changes i n tilt and movement. This allows the aircraft to compensate and adjust immediately , holding its position at all times” ( DJI, 2015 , website). Because of the DJI Inspire 1 advanced technology in maintainin g a stable flight, the chances of losing control over the UAS are slimmer; thus, making the UASs a safer UAS then most. The small UASs will not only be a benef it to me, Richard Ray Blodgett, commercially , but it will also play a positive role in reducing Risk and improving Safety for Cell T ower / T wo way Radio Mountain top inspection teams. My light weight UASs are battery powered and creates no emissions that can harm the environment.3

II. Procedures and Inspections

I, Richard Ray Blodgett, use a fully cha rged battery with each flight as a safety precaution. The Inspire 1 full flight time limit for each battery is approximately 20mins. I fly at a limit of 7

- 10 minutes on the Inspire 1 on each battery , preferring to remain well within a safe operating ran ge to insure adequate communication between radio control and UAS. Reserve batteries are always on hand with each flight, to insure replacement for suff icient safe level of operation. Before switching the DJI Inspire on for calibration and parameter sett ing, I, Richard Ray Blodgett, check/remove all propellers/wings to ensure the safet y of myself and others. I, Richard Ray Blodgett, check all connections and keep other people, animals, or obstructions a safe distance away during f irmware upgrades, system calibration, and parameter setting. When putting my propellers/wings on the Inspire1, I check to make sure they ’re tight before flight. Before flight, I check for damaged or worn propellers/wings, batteries, and other parts that should be replaced or re paired. I check to make sure the flight battery , remote controller

, Wi

- Fi range extender

, and all other necessary items are fully charged.
III. Specif ications The Inspire 1 operating frequency is 2.400~2.483 GHz for the flight controls. According to the DJ I website on the Inspire 1 aircraft, it has the following specif ications: Model: T600, Weight: 2935 g (about 6.47 pounds), Hovering Accuracy (GPS Mode): V ertical

0.5m and Horizontal

- 2.5m, Max Angular V elocity: Pitch

- 300°/s and Y aw - 150°/s, Max Tilt Ang le: 35°, Max Ascent Speed: 5 m/s, Max Descent Speed: 4 m/s, Max Speed: 22 m/s, Max Flight Altitude: 4500 m, Max Wind Speed Resistance: 10 m/s, Max Flight Time: Approximately 18 minutes, Motor Model: DJI 3510, Propeller Model: DJI 1345, Operating T emperatu re Range:

- 10° to 40° C, Diagonal Distance: 559 to 581 mm, Dimensions: 438x451x301 mm (see attached manual) The Inspire 1 has a weight of about 6.47lbs. This is well below the maximum F AA requirement of 55lbs. The maximum speed that I, Richard Ray Blodget t, use on the DJI Inspire 40 Knots. According to Overview of Small UAS Notice of Proposed Rulemaking, it states that a small UAS should not exceed 87 knots. I, Richard Ray Blodgett, pilot my UASs through remote control only by line of sight, and have liv e video feed for a secondary pilot to monitor video recording. I receive a live telemetry feed from my UASs during all flights which include remaining battery voltage, distance, altitude, and any abnormalities that may occur during flight.4

IV. Qualif ication s

Re mote UASs can be controlled by unmonitored amateur hobbyists with no safety plan or controls in place to help prevent catastrophe. I, Richard Ray Blodgett, have many years of experience in flying UAS, and can put a mind at ease knowing I have pers onally installed safety controls to avoid and prevent public hazard. I, Richard Ray Blodgett, have operated UASs for 3 years. During this experience, I have learned the standard safety protocols required before and during flight.
V. Intended UAS Oper at ion I, Richard Ray Blodgett’ s intended UAS operations would be for the development of community

, for real estate/realtor purposes, Search and R escue, agricultur al f ield monitoring, land/trusts inspections, structure inspections, and f ilm/video productions, spe cial events coverage, Cell T ower/ T wo - way Radio T

owers residing on Mountain T ops and provide a recordable safety inspection service to Commercial Operators of those services. My UAS oper ations would not affect safety , because I would fly within tigh tly controlled, predetermined areas away from the general public, airports, and vehicular traff ic. I would fly in wide open areas that are permissible property boundaries according to the local laws and regulations, F AA, and my clients.

In addition to m y intention of flying the DJI Inspire safely according to the F AA rules, all of them were engineered to be as safe as possible for the PIC and its surroundings. The DJI Inspire have built in flight control system and was made to be as safe as possible. The DJI Inspire 1 has an advanced “ready to fly” design, and have “ safety features, including R

eturn Home and position stabilization. ”

VI. Oper ate Within R

egulations I, Richard Ray Blodgett will fly only within line of sight. The maximum altitude I will fl y my UAS is 300 feet (well within the 400 ft regulated by the F AA Modernization and Re form Act of 2012). I will not fly behind obstacles or at distances that make it impossible to see my platform. The maximum operating speed I will operate is 40knots. I, Richard Ray Blodgett, will not operate my UAS near airports, hospitals or police heliports, and near areas where gener al public is within f ifty to one hundred yards.5

The DJI Inspire are programmed for flight restriction in/within 5miles of any airports. According to the DJI website, when describing the Inspire 1 it states, “In order to increase flight safety and prevent accidental flights in restricted areas, DJI has introduced a No Fly Z ones feature to help everyone use their DJI products safely and le gally. These zones include airports worldwide and other areas where flying might pose an unnecessary risk, including national borders and sensitive institutions. ” A safety NO fly zone map database is being updated constantly and is available for UAS operators to check before flying the UAS. The link is: http://flysafe.dji.com/no

- fly I, Richard Ray Blodgett, am constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearest a nd safest ground point should a manned aircraft approach, or I my location. My UAS is capable of vertical and horizontal operations, and is flown only within my line of sight. It has capabilities of geofencing which will prevent the craft from exceeding a set altitude or distance. No matter what causes the cr aft to breach those boundaries

the craft is forced back within the boundary limits. It will take over the craft to keep it within those set boundary lines and allow the pilot to regain control once the craft is within those boundaries. My UAS is flown with a second operator who aids in watching for any obstacles. I, Richard Ray Blodgett, do not believe in taking risks that may cause a crash, that could create hazard to the public/property/aircraft ’s , and I have no desire to lose an investment. I have clocked numerous practice flights and simulated flights to gain familiarization with the characteristics of this specif ic UAS’ s performance under different temperature and weather conditions. This he lps me build adequate skills and response reflex time for safety

. I, Richard Ray Blodgett, will only operate in safe environments that are strictly controlled. The environment will be safely away from power lines, elevated lights, airports, and actively populated areas. I conduct extensive preflight inspections and protocols. I always will have all necessary permissions prior to operation, and have procedures in place to abort flights in the event of safety breaches or potential danger

. VII. Exemption from Re gulations The F AA May Publish in the F eder al Register:
14 C.F .R. 21 and 14 C.F

.R. 91: Airworthiness Certif icates, Manuals and the like.6

14 C.F .R.21, Subpart H, entitled Airworthiness Certif icates, sets forth requirements for procurement of necessary ai rworthiness certif icates in relation to F AR 91.203 (a) (1). The size, weight, and operational area of my , Richard Ray Blodgett, UAS, permits exemption from Part 21, because my UAS meets (and exceeds) and equivalent level of safety pursuant to Section 333 of the Reform Act. Both pieces of legislation permit the FA A to exempt UAS’

s from the airworthiness certif icate requirement in consideration of the weight, size, speed, maneuverability , and proximity to areas such as airports and dense populations. My , R ichard Ray Blodgett’ 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 certif icate. This regulation is inapplicable, because no such certif icate will be applicable in contemplated by the F ARs. 14 C.F .R. 91.9 (b) (2) R

equires an aircr aft 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 saf ety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be def ined. The F AA has previously issued exemption to this regulation in Exemption Nos. 8607 , 8737, 8738, 9299, 9299A, 9565, 9565B, 10167 , 10167A, 10602, 1070 0, and 32827

. 14 C.F .R. 91.121 R

egarding altimeter settings is inapplicable 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 ai rcraft certif ications and registr ations. They are inapplicable for the same reasons described above. The same level of safety will be achieved by maintaining any such required certif ications and registr ations by me, Richard Ray Blodgett.
B. 14 C.F .R. 45. 23: Marketing of the Aircraft. Applicable Codes of F eder al Regulation require aircraft to be marked according to certain specif ications. 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 non

- commercial operations. I, Richard Ray Blodgett, can have equivalent level of safety as achieved by current Regulations, because my UAS does n ot carry any pilots or passengers. A pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS are far less than the risk levels in the commercial activities outlined in 14 C.F .R. 61. Thus, allowing7

me, R ichard Ray Blodgett, to operate my UAS to meet and exceed current safety levels in relation to 14 C.F

.R. 61.113 (a) & (b).
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. My UAS will never oper ate at an altitude greater 200ft above ground level; safely below the standard of 400 AGL. I, Richard Ray Blodgett, will however operate my UAS in safe areas away from public and traff ic in minimum safe altitudes.
E. 14 C.F .R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections. These R

egulations only apply to aircraft with an airworthiness certif icate. They will not, therefore, apply to my , Richard Ray Blodgett’ s, UAS. However

, as a safety precaution, I inspect my UAS before and after each flight.

In summary

, I, Richard Ray Blodgett, wish to receive exemption from the following Re gulations: 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); and 14 C.F .R. 91.417 (a) & (b) to commercially operate my , Ric hard Ray Blodgett, small UASs in community awareness, structural inspection, search and rescue, and real estate , special event, Cell To wer , T wo - Wa y Radio T

ower Safety Inspection ( Mountain T ops ) documentation to provide future services for operations wit hin the W ashington State. I will use safety protocols and the implementation of a flight operations manual for the means and methods for safe flight. I, Richard Ray Blodgett, respectively request that the F AA grant my exemption request, and I am willing to cooperate in sharing information with the F

AA for the safety of the public. Sincerely ,

Richard Ray Blodgett 1950 NE OLD BELF

AIR HWY BELF AIR, W A 98528 richardblodgett@hotmail.com