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Richard Ray Blodgett , Section 333 Exemption Petition

January 16, 2016

1950 NE OLD BELFAIR HWY 

BELFAIR, WA 98528

Re: Exemption Request Section 333 of the FAA Reform 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 FAA Modernization and 

Reform 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 Federal Aviation Administration (FAA).

I, Richard Ray Blodgett, have 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 FAA, I, Richard Ray Blodgett, will use my DJI Inspire 1, as a professional 

aerial filmmaking platform / Safety Inspection for the following applications: for 

real estate/Realtor purposes, Search and Rescue, agricultural field monitoring, 

land/trusts inspections, structure inspections, film/video productions, Cell Tower / 

Two 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 film making platforms. The advanced flight controller makes the 

DJI Inspire stable, safe, and easy to fly. The Vision Positioning 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 is 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 have 
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programmed the UASs to give me an automatic low battery warning at 30%, and at 

10%, they will automatically RTL (return to launch). I, Richard Ray Blodgett have 

personally installed safety protocols and regulations exclusive to lightweight UAS’s for 

specific video usage by sharing information with the FAA 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 DJI 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-strength, 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 additional 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 and 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 in 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 

maintaining 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 benefit to me, Richard Ray Blodgett, commercially, 

but it will also play a positive role in reducing Risk and improving Safety for Cell Tower 

/ Two way Radio Mountain top inspection teams. My light weight UASs are battery 

powered and creates no emissions that can harm the environment. 
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II. Procedures and Inspections

I, Richard Ray Blodgett, use a fully charged 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 range to insure adequate communication between radio 

control and UAS. Reserve batteries are always on hand with each flight, to insure 

replacement for sufficient safe level of operation. 

Before switching the DJI Inspire on for calibration and parameter setting, I, Richard 

Ray Blodgett, check/remove all propellers/wings to ensure the safety of myself and 

others. I, Richard Ray Blodgett, check all connections and keep other people, animals, 

or obstructions a safe distance away during firmware 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 repaired. I 

check to make sure the flight battery, remote controller, Wi-Fi range extender, and all 

other necessary items are fully charged. 

III.Specifications 

The Inspire 1 operating frequency is 2.400~2.483 GHz for the flight controls. 

According to the DJI website on the Inspire 1 aircraft, it has the following 

specifications: 

Model: T600, Weight: 2935 g (about 6.47 pounds), Hovering Accuracy (GPS Mode): Vertical0.5m and Horizontal- 2.5m, Max Angular Velocity: Pitch- 300°/s and Yaw- 150°/s, Max Tilt 

Angle: 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 Temperature 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 FAA 

requirement of 55lbs. The maximum speed that I, Richard Ray Blodgett, 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 live 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. 
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IV. Qualifications 

Remote 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 

personally 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 Operation

I, Richard Ray Blodgett’s intended UAS operations would be for the development of 

community, for real estate/realtor purposes, Search and Rescue, agricultural field 

monitoring, land/trusts inspections, structure inspections, and film/video productions,

spe cial events coverage, Cell Tower/ Two-way Radio Towers residing on Mountain Tops 

and provide a recordable safety inspection service to Commercial Operators of those 

services. My UAS operations would not affect safety, because I would fly within tightly 

controlled, predetermined areas away from the general public, airports, and vehicular 

traffic. I would fly in wide open areas that are permissible property boundaries 

according to the local laws and regulations, FAA, and my clients. 

In addition to my intention of flying the DJI Inspire safely according to the FAA 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 Return Home and position stabilization.” 

VI. Operate Within Regulations

I, Richard Ray Blodgett will fly only within line of sight. The maximum altitude I will fly 

my UAS is 300 feet (well within the 400 ft regulated by the FAA Modernization and 

Reform 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 general public is within fifty to one hundred yards. 
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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 Zones feature to help everyone use their DJI products safely and 

legally. 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 and 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 craft to breach those boundariesthe 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 specific UAS’s performance under 

different temperature and weather conditions. This helps 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 Regulations

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. 
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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 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 

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, Richard 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 

certificate. This regulation is inapplicable, because no such certificate will be applicable 

in contemplated by the FARs.

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 exemption 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 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 same 

level of safety will be achieved by maintaining any such required certifications and 

registrations by me, Richard Ray Blodgett.

B. 14 C.F.R. 45.23: Marketing 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 non-commercial operations. I, Richard 

Ray Blodgett, can have equivalent level of safety as achieved by current Regulations, 

because my UAS does not 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, allowing 
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me, Richard 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 operate 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 traffic in minimum safe 

altitudes. 

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

Inspections. These Regulations only apply to aircraft with an airworthiness certificate. 

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 

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); and 14 C.F.R. 91.417 (a) 

& (b) to commercially operate my, Richard Ray Blodgett, small UASs in community 

awareness, structural inspection, search and rescue, and real estate , special event, Cell 

Tower, Two-Way Radio Tower Safety Inspection ( Mountain Tops ) documentation to 

provide future services for operations within the Washington 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 FAA grant my exemption request, and I am willing to cooperate in sharing 

information with the FAA for the safety of the public.

Sincerely,

Richard Ray Blodgett 

1950 NE OLD BELFAIR HWY

BELFAIR, WA 98528

richardblodgett@hotmail.com