Pursuant to Section 333 of the FAA Modernizations and Reform Act of 2012 

and 14 CFR Part 11, “ BarryAir”, LLC, operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography for the purpose 

of constructing Videos in the Real Estate, Commercial Plant , Inspection of 

Infrastructure, and farming industries, hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of sUASs under the conditions outlined here or modified by the 

FAA. In the detailed explanation to follow, the series of exemptions being 

requested would allow operation of the commercially procured, Blade 

Chroma, a four engines and propellers, light weight, relatively slow, 

unmanned rotary aircraft (or like platform) in the United States of America, 

events using very controlled conditions and operational procedures to provide 

robust safety buffers both vertically and horizontally to ensure personnel and 

property safety. These flights would only fly within 400 feet of the control 

station with a pilot and VO team. Approval of this exemption would help to 

prove the safe concept of UAS activity, to provide proactive risk 

management that is technically within the National Airspace System, but 

realistically segregated well below any other air traffic and well clear of legal 

flying altitudes utilized by Certificated Aircraft. The Company/Owner/Pilot 

of BarryAir LLC is a Commercial Rated Pilot with Single and Multi-engine 

instrument ratings with over 11.000 TT flying hours, mostly on a Low 

Altitude Waiver, flying Pipeline Patrol along the Gulf Coast, from Texas to 

Florida. The Company/Owner/Pilot of BarryAir also holds an FAA 

Certificate to build and repair Experimental Aircraft.

The following is contact information for the applicant and specifications of 

the UAS.

BarryAir LLC

Barry Tanner Sr. Owner

210 Rue Chavaniac

Lafayette, Louisiana

70508

barryair@cox.net

337-315-0829

FAA Commercial Pilot Certificate #3401992

FAA Experimental Aircraft Repair #3523550
FAA Medical Certificate #1997107576

Reserved N-Number N851BA

Blade Chroma Model # BLH8665

Blade Chroma Serial # 2153644450

Blade Ground Station # ST10

Flying Weight 1323 G

Height 290MM

Length 325MM

Width 325MM

EXEMPTIONS (Regulations from which the exemption is requested)

14 CFR Part 21, Subpart H– Airworthiness Certificates 14 CFR 45.23 (b), ,

o AircraftMarking

o Certification and Registration 14 CFR 61.113 (a) & (b)

o Pilot in Command 14 CFR 91.7 (a)

o Civil aircraft airworthiness 14 CFR 91.9 (b) (2)

o Document/Flight Manuals 14 CFR 91.103 (b)

o Preflight action 14 CFR 109

o Flight instruction 14 CFR 91.113

o Right-of-way rules 14 CFR 91.119

o Minimum safe altitude 14 CFR 91.121
o Altimeter setting 14 CFR 91.131 (a) (1) (c) (2) (d) (1)

o Operations in Class B airspace 14 CFR 91.145 (b)

o Management of aircraft operations in the vicinity of aerial demonstrations 

and major sporting events.

14 CFR 91.151 o Fuel requirements for VFR flight

14 CFR 91.203 (a) & (b) o Civil Aircraft: Certifications required

14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b) o Maintenance and 

maintenance inspections

• 14 CFR 407 o Operation after Maintenance,preventive maintenance, 

rebuilding and inspections 

• 14 CFR 409 o Inspections 

• 14 CFR 417 o Maintenance records 

• NOTAM 9/5151 o Flying Around Sporting Events

. AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF 

SAFETY

. Section 333 refers to exemptions for sUASs for commercial 

operations.

. The sUAS aircraft to be employed by BarryAir, LLC has 

a number of safety features that make it ideal for use 
in this environment. The state of the art Blade 

Chroma with a 30 minute Battery Life, 12volt battery 

technology, is well under 55 pounds with a top speed 

of approximately 30 knots. The aircraft would be 

employed utilizing Line-of Sight (LOS) operations 

not to exceed 30 and launched from a sterile area 

created upon arrival at the site by the safety team. 

Any vertical obstructions would be noted upon 

arrival and the pilot and safety team would ensure 

operations remained well clear of those obstructions. 

The pilot would launch the aircraft and navigate to an 

acceptably safe hover point at which time a waypoint 

would be designated and the auto-pilot would be 

engaged in an auto-hover mode while filming 

commences. A loss of communication “return to 

base” fail-safe system is integrated as well. The 

battery life is approximately 30 minutes with a 

planned flight time of not more than 20 minutes.

. All sUAS pilots being employed by BarryAir, LLC 

for this mission will have the FAA Pilot 

Certificate, FAA medical certificate with 

additional experience in unmanned aircraft 

operations as outlined in the 333 and 

COA. Pilots will be well trained in areas of 

both normal and abnormal operations equipped 

with checklists and operations and maintenance 

manuals to be able to contend with any 

scenario.

. 14 CFR Part 21, Subpart H– Airworthiness 

Certificates 14 CFR 91.203 (a) (1) Subpart 

H (Airworthiness Certificates) defines the 

requirements for airworthiness certificate 

issuance IAW FAR 91.203 (a) (1). Existing law 

(49 USC 44701 (f)), Part 11 and Section 333 

allow the FAA to exempt aircraft from the 
requirements of an airworthiness certificate 

upon consideration of the size, weight, speed, 

operational capability and proximity to airports 

and populated areas of the identified sUAS. 

Unlike a manned helicopter, the sUAS being 

employed is lightweight, has no flammable fuel 

or other lubricants, operates at very slow 

speeds and stays well below any conflicting air 

traffic thereby providing, an equivalent level of 

safety when compared to currently employed 

manned aircraft. The proposed sUAS to be 

employed is under 55 lbs. when outfitted with 

all equipment and batteries. There are no 

flammable liquids or other hazardous materials 

that would propose a danger to the public or 

event participants. Accordingly, no threat to 

national security exists due to the inability of 

carriage of any external stores or ordnance and 

the exhaustive vetting of team personnel. 

14 CFR 45.23 (b) Display of Marks; general 

CFR 45.23 states: When marks include 

only the Roman capital letter “N” and the 

registration number is displayed on limited, 

restricted or light-sport category aircraft or 

experimental or provisionally certificated 

aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words 

“limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as 

applicable.      An exemption to this 

section is needed due to the lack of a cabin, 

cockpit or pilot station where any reference to 

the term “Experimental” could be affixed. 

Accordingly, the wording will be placed on the 

fuselage. This equivalent level of safety will 
allow the team to clearly see “Experimental.” 

Previous precedence exists within Exemptions 

10700, 10167, and 10167A. CFR 61.113 (a) 

& (b) Private Pilot Privileges and 

Limitations: Pilot in Command CFR 

61.113 (a) & (b) states: (a) Except as 

provided in paragraphs (b) through (h) of this 

section, no person who holds a private pilot 

certificate may act as pilot in command of an 

aircraft that is carrying passengers or property 

for compensation or hire; nor may that person,

for compensation or hire, act as pilot in 

command of an aircraft. (b) A private pilot 

may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any 

business or employment if: (1) The flight is 

only incidental to that business or employment; 

and (2) The aircraft does not carry passengers 

or property for compensation or hire. To 

reach an equivalent level of safety, the 

self-imposed experience and training 

requirements would more than offset any risk 

introduced by using private pilots to fly an 

unmanned aircraft in very restricted and 

controlled areas. CFR 91.7 (a) Civil aircraft 

worthiness CFR 91.7 (a) states: No 

person may operate a civil aircraft unless it is in 

an airworthy condition. Assuming no 

airworthiness certificate will be required due to 

relief from Subpart H, no regulatory standard 

exists for determining airworthiness. The 

equivalent level of safety will be achieved 

through the employment of flight manual and 

maintenance manual procedures, pilot training 

and analytical risk management for each event. 

CFR 91.9 (b) (2) Civil Aircraft Flight 
Manual in the Aircraft     CFR 91.9 (b) 

(2) states: No person may operate a 

U.S.-registered civil aircraft— For which an 

Airplane or Rotorcraft Flight Manual is not 

required by § 21.5 of this chapter, unless there 

is available in the aircraft a current approved 

Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or 

any combination thereof. Given the size of 

the sUAS being utilized in this endeavor, there 

is no room onboard for an aircraft flight 

manual. The equivalent level of safety will 

be achieved by keeping the flight manual with 

the pilot/team on the ground with easy access. 

Previous precedence is resident in Exemptions 

8607, 8737, f8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, f32827, and 10700. 

CFR 91.103 (b) Preflight action CFR 

91.103 (b) states: Each pilot in command 

shall, before beginning a flight, become 

familiar with all available information 

concerning that flight. This information must 

include— (b) For any flight, runway lengths 

at airports of intended use, and the following 

takeoff and landing distance information: (1) 

For civil aircraft for which an approved 

Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is 

required, the takeoff and landing distance data 

contained therein; and (2) For civil aircraft 

other than those specified in paragraph (b)(1) of 

this section, other reliable information 

appropriate to the aircraft, relating to aircraft 

performance under expected values of airport 

elevation and runway slope, aircraft gross 

weight, and wind and temperature. This 
regulation dictates that a pilot conduct preflight 

activities. Without an FAA approved flight 

manual, relief is required from this regulation. 

Extensive pre-flight planning will provide an 

equivalent level of safety by using the 

operations plan, aircraft flight manual, 

maintenance manual and available weather and 

NOTAM information. CFR 91.109 Flight 

instruction CFR 91.109 states: No person 

may operate a civil aircraft (except a manned 

free balloon) that is being used for flight 

instruction unless that aircraft has fully 

functioning dual controls. sUASs clearly 

have no onboard flight controls. An equivalent 

level of safety will be accomplished by 

conducting pilot training via the control system 

that communicates with the aircraft from the 

ground. CFR 91.113 Right-of-way rules: 

Except water operations. CFR 91.113 

deals with the many scenarios whereby 

different types of aircraft in different states 

must give way to other aircraft. Because the 

sUAS PIC does not have “see and avoid” 

capability, the petitioner requests relief from 

this regulation. All operations will be within 

LOS of the pilot and well below any airspace 

where other flight activity is taking place. 

CFR 91.119 (d) (1) Minimum safe altitudes; 

general CFR 91.119 states: (d) 

Helicopters, powered parachutes, and 

weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or 

property on the surface— (1) A helicopter 

may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this 

section, provided each person operating the 
helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the 

FAA. Recognizing that this relief is 

unprecedented, the petitioner asks that the FAA 

recognize the inherent capability of the 

BarryAir, LLC team. The current altitude 

and/or horizontal restrictions on rotorcraft 

assumes a much heavier manned aircraft loaded 

with fuel and possible external stores. The 

light-weight sUAS being proposed for use in 

this activity along with its precise guidance and 

redundant systems create an entirely different 

paradigm that should be considered by 

regulatory bodies. The activities being 

proposed by this petitioner are in a very 

controlled and open area. The flights would be 

confined to the immediate area of the mobile 

control center (MCC). Given these 

considerations, BarryAir LLC proposes 

allowing flights to operate no more than 400 

feet from the ground station and well clear of 

the Class B airspace and attendant manned air 

traffic. CFR 91.121 Altimeter settings 

CFR 91.121 states: Each person operating an 

aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, 

by reference to an altimeter that is set, when 

operating— Below 18,000 feet MSL, to—

The current reported altimeter setting of a 

station along the route and within 100 nautical 

miles of the aircraft; The sUAS aircraft 

intended for this activity will not be equipped 

with a barometric altimeter. Instead it will 

incorporate radio altimetry via the onboard 

GPS. An equivalent level of safety will be 

achieved through use of the operations and 
maintenance manuals governing altitude

control. A preflight calibration of launch site 

altitude will be accomplished. CFR 91.131 

(a) (1) (c) (2) & (d) (1) Operations in Class B 

airspace CFR 91.131 states: (a) Operating 

rules. No person may operate an aircraft within 

a Class B airspace area except in compliance 

with § 91.129 and the following rules: (1) 

The operator must receive an ATC clearance 

from the ATC facility having jurisdiction for 

that area before operating an aircraft in that 

area. (c) Communications and navigation 

equipment requirements. Unless otherwise 

authorized by ATC, no person may operate an 

aircraft within a Class B airspace area unless 

that aircraft is equipped with— (2) For all 

operations. An operable two-way radio capable 

of communications with ATC on appropriate 

frequencies for that Class B airspace area. 

(d) Other equipment requirements. No person 

may operate an aircraft in a Class B airspace 

area unless the aircraft is equipped with—

(1) The applicable operating transponder and 

automatic altitude reporting equipment 

specified in § 91.215 (a), except as provided in 

§ 91.215 (e), and this regulation is required. An 

equivalent level of safety will be achieved by 

limiting the operating ceiling of the sUAS to 

altitudes well below any conflicting manned 

aircraft traffic (no higher than 400 feet). This 

assures safe separation with all other traffic, 

and specifically traffic within the Class B 

airspace. CFR 91.145 (b) Management of 

aircraft operations in the vicinity of aerial 

demonstrations and major sporting events. 
.

CFR 91.145 states: In deciding whether a 

temporary flight restriction is necessary for an 

aerial demonstration or major sporting event 

not listed in paragraph (a) of this section, the 

FAA considers the following factors: (1) 

Area where the event will be held. (2) Effect 

flight restrictions will have on known aircraft 

operations. (3) Any existing ATC airspace 

traffic management restrictions. (4) Estimated 

duration of the event. (5) Degree of public 

interest. (6) Number of spectators. (7) 

Provisions for spectator safety. (8) Number 

and types of participating aircraft. (9) Use of 

mixed high and low performance aircraft.

(10) Impact on non-participating aircraft. (11) 

Weather minimums. (12) Emergency 

procedures that will be in effect. CFR 

91.151 (b) Fuel requirements for flight in 

VFR conditions. CFR 91.151(b) states: 

No person may begin a flight in a rotorcraft 

under VFR conditions unless (considering wind 

and forecast weather conditions) there is 

enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed, 

to fly after that for at least 20 minutes. The 

battery that powers the Blade Chroma have a 

mission life of approximately 30 minutes. A 

more liberal flight time is a reasonable request. 

The aircraft would never be further than 400 

feet from the recovery area, literally 

representing seconds to land. The Aircraft will 

only be operated with less than 25% battery life 

remaining in order to return home to land.. 

Night time operations are currently planned if

granted. The Blade Chroma has excellent 
Lighting and visibility from great distances at 

night. In case of LOS, loss, the return to home 

feature affords a large safety margin. CFR 

91.203 (a) & (b) Civil Aircraft: Certifications 

required CFR 91.203 (a) & (b) states: (a) 

Except as provided in § 91.715, no person may 

operate a civil aircraft unless it has within it the 

following: (1) An appropriate and current 

airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with 

this subparagraph (except a special flight 

permit, a copy of the applicable operations 

specifications issued under § 21.197(c) of this 

chapter, appropriate sections of the air carrier 

manual required by parts 121 and 135 of this 

chapter containing that portion of the 

operations specifications issued under 

§21.197(c), or an authorization under § 91.611) 

must have on it the registration number 

assigned to the aircraft under part 47 of this 

chapter. However, the airworthiness certificate 

need not have on it an assigned special 

identification number before 10 days after that 

number is first affixed to the aircraft. A revised 

airworthiness certificate having on it an 

assigned special identification number, that has 

been affixed to an aircraft, may only be 

obtained upon application to an FAA Flight 

Standards district office. (2) An effective 

U.S. registration certificate issued to its owner 

or, for operation within the United States, the 

second copy of the Aircraft registration 

Application as provided for in § 47.31(c), or a 

registration certification issued under the laws 

of a foreign country. (b) No person may 

operate a civil aircraft unless the airworthiness 
certificate required by paragraph (a) of this 

section or a special flight authorization issued 

under § 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to 

passengers or crew. The sUAS to be 

employed has no cockpit or pilot and therefore 

has no ability to carry onboard any certification 

or registration documentation. The equivalent 

level of safety will be achieved by keeping 

these documents with the pilot/team on the 

ground at the event. Previous precedence is 

resident in Exemptions 9565, 9665, 9789, 

9789A, 9797, 9797A, 9816A and 10700. 

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 

417 (a) & (b) Maintenance These CFRs 

state: Each owner or operator of an aircraft—

(a) Shall have that 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; Operation after maintenance, 

preventive maintenance, rebuilding, or 

alteration. (a) No person may operate any 

aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or 

alteration unless— (1) It has been approved 

for return to service by a person authorized 

under § 43.7 of this chapter; and (2) The 

maintenance record entry required by § 43.9 or 

§ 43.11, as applicable, of this chapter has been 

made. Except as provided in paragraph (c) 

of this section, no person may operate an 

aircraft unless, within the preceding 12 

calendar months, it has had— (2) An 

inspection for the issuance of an airworthiness 
certificate in accordance with part 21 of this 

chapter. operator shall keep the following 

records for the periods specified in paragraph 

(b) of this section: (1) Records of the 

maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, 

progressive, and other required or approved 

inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. 

The records must include— (i) A description 

(or reference to data acceptable to the 

Administrator) of the work performed; and (ii) 

The date of completion of the work performed; 

and (iii) The signature, and certificate number 

of the person approving the aircraft for return 

to service. (2) Records containing the 

following information: (i) The total time in 

service of the airframe, each engine, each 

propeller, and each rotor. (ii) The current 

status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. (iii) 

The time since last overhaul of all items 

installed on the aircraft which are required to 

be overhauled on a specified time basis. (iv) 

The current inspection status of the aircraft, 

including the time since the last inspection 

required by the inspection program under 

which the aircraft and its appliances are 

maintained. (v) The current status of 

applicable airworthiness directives (AD) and 

safety directives including, for each, the 

method of compliance, the AD or safety 

directive number and revision date. If the AD 

or safety directive involves recurring action, the 

time and date when the next action is required. 
(vi) Copies of the forms prescribed by § 

43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, 

rotors, propellers, and appliances. (b) The 

owner or operator shall retain the following 

records for the periods prescribed: (1) The 

records specified in paragraph (a) (1) of this 

section shall be retained until the work is 

repeated or superseded by other work or for 

1 year after the work is performed. (2) The 

records specified in paragraph (a) (2) of this 

section shall be retained and transferred with 

the aircraft at the time the aircraft is sold. (3) 

A list of defects furnished to a registered owner 

or operator under § 43.11 of this chapter shall 

be retained until the defects are repaired and 

the aircraft is approved for return to service. 

These FARs only concern aircraft with an 

airworthiness certificate and therefore would 

not apply in this situation. All maintenance and 

inspections will be conducted IAW the 

maintenance manual and operations manual. 

The ability for an almost immediate safe 

recovery and landing if a malfunction occurs. 

. The reasons why granting BarryAir LLC’s request 

would be in the public interest; that is, how it 

would benefit the public as a whole: Quad

copter HD Videos provide a whole new view in 

inspection, real estate, and farming as an 

upcoming industry emerges. Many new 

opportunities to expand businesses will be 

realized. In addition, enhanced safety is achieved 

by using an unmanned aircraft that does not carry 

passengers or crew and does not carry 

flammable fuel.    IAW 14 CFR Part 11.81, 

the following summary is provided for 
publication in the Federal Register, should it 

be deemed necessary: Applicant seeks 

relief from the following rules: 14 CFR Part 

21, Subpart H– Airworthiness Certificates, 14 

CFR 45.23 (b),14 CFR 61.113, (a) & (b), 14 

CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 

91.103 (b), 14 CFR 109, 14 CFR 91.119, 14 

CFR 91.113, 14 CFR 91.121, 14 CFR 91.131 

(a) (1) (c) (2) (d) (1), 14 CFR 91.145 (b), 14 

CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 

91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b), 

14 CFR 407, 14 CFR 409, 14 CFR 417, 

NOTAM 9/5151     Fire fighting 

Medical response  Incident investigation 

These capabilities, in total, provide a level of 

safety that should be satisfactory to the FAA 

and general public. In view of the beneficial 

advantages to public safety, we respectfully 

submit our Section 333 exemption request.

   

. FLIGHT OPERATIONS

. Flight Operations Introduction

. The pilot-in-command is responsible for the safe employment of the 

UAS that is assigned to the operation. He/she will be responsible for all 

operations, establishing a safe operating zone, coordination with local law 

enforcement/first responders, giving way to other airborne assets, both 

manned and unmanned and any other contingencies that might present 

themselves. In addition, there will be a VO, (safety observer).

. Flight Operations Functional Areas
. Chief Pilot

. The CP is responsible to the FAA for all operations and ensuring those 

operations are conducted using the procedures outlined here and all other 

documents included and submitted for this 333 exemption. All flights and 

procedures for ground operations of installed engines and/or propeller(s), 

engaging of rotors, and movement of UAS aircraft conducted by the 

contractor are subject to final approval by the CP. The team shall prepare and 

maintain specific written procedures, separate and distinct from industrial or 

quality procedures that describe generic aircraft flight and ground operations 

at all events. If BarryAir LLC references existing company procedures, 

operating instructions, etc., in these procedures, the referenced document(s) 

must be readily available for review and become part of the FAA 333 

exemption approval process.

. Aviation Risk Management

. As per Federal Aviation Administration (FAA) Orders 8900 and 8130, 

all UAS operations will adhere to the Safety Management System (SMS) 

process as required in manned aircraft operations. Personnel will use Safety 

Risk Management (SRM) principles outlined in the current editions of FAA 

Advisory Circular (AC) 120-92-Safety Management Systems for Aviation 

Service Providers and FAA Order 8040.4A-Safety Risk Management Policy. 

These FAA policies maintain or improve the safety of the National 

Airspace System (NAS) by identifying safety risks, hazards, and mitigations 

associated with proposed UAS operations. .

. Airspace

. Pilots will use all means available to notify NAS (National Airspace 

System) partners (FAA, law enforcement, first responders, other airspace 

users, etc, if needed. All technology available (radios, telephonic, email, 
social media) will be considered to ensure any potential airspace users in 

close proximity to the ongoing event are aware that there will be an 

unmanned airborne asset in the area. Upon arrival on the launch sight, the 

Pilot and safety observer (VO) will quickly ascertain the operating 

environment and follow up prior coordination with any other aforementioned 

stakeholders prior to initial launch of the UAS. Other risk factors such as 

weather, onlookers, immediate obstructions to flight (trees, power lines, 

construction equipment, etc.) will be identified and mitigated. The maximum 

line of sight distance from the controlling pilot to the UAS is 400 feet. The 

Pilot will determine what geographical and/or electronic metrics can be 

employed to help determine the maximum line-of-sight distance restriction. 

This can be ascertained by using assets such as laser range finders, known 

physical distances and heights such as the length of the city block or height of 

utility poles. Once there is a determination that a safe launch can be made and 

the UAS is airborne, the Pilot and VO will closely monitor the time of flight, 

flight track, changing local conditions (weather, airspace saturation, crowd 

size and disposition, etc.) and continually assess any possible need to modify 

or discontinue operations in the interest of safety. Early and accurate 

planning of the on-site requirements to accommodate the air and ground 

footprint is critical to both planning and execution. All team members will be 

an integral part of the Airspace Management processes and must be well 

versed in flight, ground, and UAS operations. The Pilot and his team will 

conduct a flight readiness and operational risk management review via 

checklists.

. PROCEDURES

. The Procedures shall:

. Provide specific guidance describing activities and requirements for all 

UAS flight activities. All provisions pertaining to safety, and flight and 

ground operations applicable to all aircraft for each specific event will 

be clearly defined. 

. Describe in detail how the team ensures that individuals perform only 
duties they are qualified and authorized to perform. 

. Provide an overview of proposed operations plan including, but not limited 

to: 

. Aircraft system to be Utilized 

. Scope of flight operations 

. Communications support requirements 

. Emergency procedures – requirements (Aircraft Rescue and Fire 

Fighting, Traffic control, etc.) 

. Launch/Recovery requirements and procedures 

. Lost communications and lost link procedures 

. Generic on-scene safety outline, including safety observer and 

pre-post flight brief with all applicable staff, production 

personnel and flight crew. Copies of PIC and visual observers’ 

training hours/records may be requested at any time. 

. Provide Operational Requirements such as ownership information; aircraft 

description (performance specifications and speed, altitude, arrival and 

take off, movement and camera operations); program purpose for 

which the aircraft will be used; anticipated hours, time of ground 

tests/flights and days for use; and areas over which the flights are to be 

conducted and address of base operation. 

. Provide a narrative (i.e. – Flight Plan and parameters for operation) 

summarizing overall experience as well as describing equipment and 

the various specific modes of operation, including routes and altitudes 

to be flown. Narrative will also include details for exit criteria. Flight 

Plan must also include Lost Link procedures and other emergency 

procedures. 

. Risk Assessment
. During the initial standup of UAS activity pre-planning, the staff and 

UAS flight crew identify and assess possible hazards consistent with FAA 

Safety Risk Management process.

. Changes

. All proposed changes shall be submitted to the CP in writing. 

Approved changes shall be incorporated into all copies of the Procedures. 

Changes are not in effect until the CP approves them.

. Crewmember Approval

. All crew members must be approved as a requisite step for 

indemnification under the BarryAir Risks Clause. The CP shall ensure that 

the appropriate numbers of crew members are authorized and that programs 

include sufficient flying time for currency in accordance with the Mission 

Assurance Risk Assessment. The CP shall not approve any crew member 

until the procedures have been approved and that crew member has 

demonstrated a complete and thorough understanding.

. Ground Operations

. The CP shall not approve any ground operations until the procedures 

have been approved.

. Flight Approval

. The CP shall not approve any flight until the procedures have been 

approved. CP approval is required for all flights using the BarryAir 
designation and authorities.

. Ground Operations are aircraft operations without intent for flight. 

Specific operations include, but are not limited to:

. Aircraft maintenance

.

. Overhaul Modification Repair Ground Test

. Subsystem warm-up/checkout

. Ground Station “interference” Ground Test

. Engine run or other operation of installed engines and propeller(s) or 

rotor(s), as appropriate

. Preflight/post flight

. Operation of associated aerospace ground support equipment

. Multiple Flight Approvals

. Highly repetitive flights and events (such as flight instruction or a 

repeated flight training involving the same aircrew, mission, and flight profile 

or exact same event) may be authorized. Pilots should know the general 

profile and objectives for each event as well as the currency and 

qualifications of the flight/ground crews involved for the duration of the 

approval period.
. ALL PROCEDURES HAVE BEEN DEVELOPED TO NEVER 

INTENTIONALLY OVERFLY THE GENERAL PUBLIC  

Assumptions and Restrictions for all Emergency 

Events

. During emergency operations all team members will focus 

exclusively on the safe recovery of the Blade Chroma. Upon 

emergency flight termination, no additional flights will be 

launched until a complete understanding of what caused the 

malfunction is determined. 

. When possible all Emergencies will be terminated at the Launch and 

Recovery location. Once the Pilot has completed all ground ops 

he’ll check in with the CP who will provide an “all clear for 

launch”. The safety observer should verify that the initial 

operating area is clear. If at any point the safety observer realize 

the area isn’t clear, he/she should announce this fact and make a 

recommendation to the pilot of a known clear area. 

. The petitioner supports his request with the following 

information:

. The petitioner has provided the following information – contained 

in his petition and supporting documentation including: 1) Blade chroma 

operating specs. (all hereinafter referred to as operating documents). 2.) 

Drawings of the Blade Chroma and the Ground Station.

. Unmanned Aircraft System

. The petitioner states he plans to operate a UAS, The Blade 

Chroma, referred to as a quad-copter with a maximum gross weight of 

about 3 pounds. It is equipped with four rotors that are driven by electric 

motors powered by batteries. The UA has a maximum airspeed of 30 

knots. • Stick Relativity moves this drone in whatever 
direction the control stick is pushed, no matter which way the nose 

is pointed and creates a SAFE Circle barrier that prevents the 

aircraft from flying too close to the Pilot and auto holds position and 

altitude when control sticks are released. Another feature is “Follow 

Me Mode”: Your built-in copilot:

. Frees you to focus on lining up the perfect shot

. Pan and tilt the camera while the drone follows

. Drone follows at an altitude and distance you set

.

. The petitioner states that he will only operate in reasonably safe 

environments.

.