UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Patrick V Cullen

W278 N2337 Prospect Ave

Pewaukee, WI 53072

262-893-3463

Pcullen1275@gmail.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part11, 

Patrick Cullen, a freelance multimedia producer, hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System 

(sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such 

operations are conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

The requested exemption would permit Patrick Cullen to pursue his commercial interests in providing 

services to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land 

Management/Surveying, and Special Events. Patrick Cullen states that all sUAS flights will occur over 

private or controlled access property at a Altitude no more than 200 feet and will do so with the 

property owner's consent and knowledge and that only people who have consented or otherwise have 

agreed to be within the UAS’ radius during filming and photography applications. Patrick Cullen is a 

member of the AMA, and has demonstrated the ability to safely and effectively fly the sUAS BLADE 

CHROMA 1080P which will be used for all commercial and private purposes. Patrick Cullen complies with 

local ordinances and laws regarding the operation of sUAS, and adheres to all weather and 

environmental restrictions or limitations in reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy. I, Patrick Cullen, am 

seeking the exemption because I am committed to complying with all of the rules, guidelines, 

limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I 

have described, and for the purposes that I have described. Without the exemption request granted, I 

would be unable to safely and effectively run my business, and it is my intention to comply with the FAA 

and obtain an exemption of the following regulations.
The following contains my list of regulations from which I am seeking exemption, and a complete list of

responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit

and safety features, and similar petitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119 the aircraft is operating. These documents must be made available to the Administrator 

or any law enforcement official upon request.

1. The UA must remain clear and give way to all manned aviation operations and activities at all times.

2. The UAS may not be operated by the PIC from any moving device or vehicle.

3. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations 

must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The 

owner/controller of any vessels, vehicles or structures has granted permission for operating closer to 

those objects and the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential 

persons are not considered nonparticipating persons under this exemption.

4. All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted.

5. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS−80) within 24 hours. Accidents must be reported to the Naonal Transportaon Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption 

Nos. 11062, 11109, 11112, and 11213

Public Benefit and Safety
Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering 

platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, 

a much smaller environmental impact which promotes public safety. Patrick Cullen is petitioning for an 

exemption to operate a BLADE CHROMA 1080P with a built-in stabilized HD camera and GPS safety 

features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of 

the distance it flies from the operator and to exclude it from operations within designated Class B, C and 

D airspace including a no-fly zone feature. BLADE CHROMA 1080P also has a failsafe function that is 

triggered in the event communication is lost between the sUAS and the main controller transmitter. At 

that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the 

PIC can regain control of flight and land manually. These specifications meet with the Model Aircraft 

Operating Standards as set below:

The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at 

sites that are `sufficient distance' from populated areas within the sterile area described in the FOPM. 

Such operations will ensure that the sUAS will "not create a hazard to users of the national airspace 

system or the public."

6. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., 

inoperable components, items, or equipment. 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.

7. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components.

8. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

9. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or 

a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. 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 or her pilot certificate. 5

10. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
11. 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.

12. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request.

13. The UA 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.

14. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property.

15. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

16. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.

17. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall

beconducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of the 

attached COA. 6

18. 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 (N−Number) markings in 

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

19. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

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 give the right-of-way to avoid flying in the proximity of full-scale 

aircraft. Maximum flight time for each operation will be 30 minutes.

1. Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to 

safely land the sUAS.

2. The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and 

not more than 200 feet above an elevated platform from which videography is planned.

3. Minimum crew for each operation shall consist of: sUAS pilot and the camera operator.

4. The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, 

lens, and stabilized gimbal).
5. The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move

vertically and horizontally.

6. Given the small size of the sUAS and the restricted sterile environment within which it will operate, 

SkyVideoCT’s operations adhere to the Reform Act's safety requirements.

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

7. Operations authorized by this grant of exemption are limited to the BLADE CHROMA 1080 P when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption.

8. Operations for the purpose of closed-set motion picture and television filming are not permitted.

9. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption 

holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot 

speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

10. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude 

must be reported in feet AGL.

11. The UA 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 FAA-issued airman medical certificate or U.S. driver’s license.

12. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of 

sight (VLOS) of the PIC and VO at all times. 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; electronic messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the VO can perform the duties required of the VO.

13. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between the 
conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may update or revise 

its operating documents. It is the operator’s responsibility to track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official upon request. The operator 

must also present updated and revised documents if it petitions for extension or amendment to this 

grant of exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its grant 

of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if quesons arise regarding 

updates or revisions to the operating documents.

14. 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 

prior to conducting further operations under this exemption. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test 

flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

15. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition 

for safe operation.

The applicant, Patrick Cullen requests your respective approval of this Section 333 exemption petition 

request. 

Thank you for your attention in this matter. Please notify Patrick Cullen Of your actions, and or 

approvals. Thank you, for your interest in this request

Patrick Cullen