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 aircr aft (or like platform) in the U nited 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 realisti cally 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 11.0 00 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 #3523550FAA Medical Certificate #1997107576

Reserved N

- Number N851BA Blade Chroma Model # BLH8665 Blade Chroma Serial # 2153644450 Blade Ground Station # ST10 Flying Weight 1 323 G Height 290MM Length 325MM Width 3 25MM

**EXEMPTIONS** (Regu lations 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 91.121o Altimeter setting 14 CF R 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 usein 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 approxi mately 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 pi lot 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 employe d 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 o perations 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 requireme nts 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 therequirements 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 liq uids 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 per sonnel. **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,” “experimenta l,” 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. T his equivalent level of safety willallow the team to clearly see “Experimental.” Previous precedence exists within Exemptions 10700, 10167, and 10167A. **CFR 61.113 (a) & (b) Private Pilot Privileges and**  **Lim itations: Pilot in Comm**  **and** 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 busin ess 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 priva te 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 certifica te 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 ana lytical 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 b y § 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 en deavor, 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, f873 8, 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. T his 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. Thisregulation dictates that a pilot conduct preflight activities. Without an FAA approved flight manual, relief is requir ed 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 91.1 09 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 safe ty 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 a ircraft 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 whe re other flight activity is taking place. **CFR 91.119 (d) (1) Minim um**  **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 o n 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 thehelicopter complies with any routes or altitudes specifically prescribed for helicopters by th e 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 lo aded 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 acti vities 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 t han 400 feet from the ground station and well clear of the Class B airspace and attendant manned air traffic. **CFR 91.121 Altim eter 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 inten ded 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 andmaintenance 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 e xcept 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 requ irements.**  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 frequ encies 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 equipmen t 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**  **dem onstrations and m**  **ajor sporting events.**. C FR 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 h eld. **(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 i ntended 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 wou ld 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 excellentLighting and visibility from great distances at night. In case of LOS, l oss, 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 subparag raph (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

o perations 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 spe cial 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 applic ation 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

r egistration certification issued under the laws of a foreign country. **(b)** No person may operate a civil aircraft unless the airworthinesscertificate required by paragraph (a) of this section or a special flight authorization issued under § 91.715 is disp layed 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 safe ty 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 discr epancies 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 alte ration 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 pa ragraph (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 airworthinesscertificate 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 appr opriate, 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 dat e 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 d ate 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 t he 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 manu al and operations manual. The ability for an almost immediate safe recovery and landing if a malfunction occurs.



### . **The reasons why granting BarryA**  **ir 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 do es 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 P art 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 lev el 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 w ay 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 f or 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 descr ibe 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 t he 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 polici es 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 S ystem) 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 ev ent 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
st akeholders 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 fin ders, 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, flig ht 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 requirem ents 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 tea m 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 onlyduties they are qualifie d 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

– requirement s (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 specifica tions 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 an d 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. N arrative 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 progr ams 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 underst anding.



# . **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 BarryAirdesignation and authorities.



# . Ground Operations are aircraft operations without intent for flight. Specific operation s 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 sam e aircrew, mission, and flight profile or exact same event) may be authorized. Pilots should k now 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

a pproval 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 determi ned.

. 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 ini tial 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 reques t with the following** 

**inform ation:** 



# . The petitioner has provided the following inform ation

– contained in his petition and supporting documentation including: 1) Blade chro ma operating specs. (all hereinafter referred to as operating docum ents). 2.) Drawin gs of the Blade Chroma and the Ground Station.



# . **Unm anned Aircraft System** 

. The petitioner states he plans to operate a UAS, The Blade Chroma, referred to as a quad

- copter with a maximu m g ross weight of about 3 pounds. It is equipped with four rotors tha t are driven by electric motors powered by batteries. The UA has a maxim um 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 barri er 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 environm ents.

.