### UNITED STATES OF A:MERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.

Regulatory Docket #

_____ _

IN THE MATTER OF THE PETITION FOREXEMPTION OF: 

### Blue_ SkiG§

**Inv~stments.** 1,1

## ,<; FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL

OPERATION OFDJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA

## MOQERWZAIION AlSl! REFORM ACT 

### QfZ,Q12 

## ClliBIJCI:AW

**1Z-2~l**



### Submitted October 16,2015
Todd A. Barnes Blue Skies Investments, LLC 5815 Cool Springs Drive 

### Cumming, 

### Ga. 30040 Tel: (678) 522-2651

### TABLE OF CONTENTS Page**<=J~<:>~~~~~ <=>~** **~~lEJ~~~~J['I<:>l'r~**

## ...................................................................................**~ ~~~~** 

### •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••LJ
INTRODUCTION**~ND** INTERESTS**<=>~** PETITIONER

...................................................

### .4**~~C~<=JRO~D**....................................................................................................................**~ ~~~~~** **~OR** 

## PETIJ['ION

.........................................................................................................<i**1\l~l\11~ ~l'JD** **~DD~SS <=>~** **P~TITIONE~**...............................................................jr 

### THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BLUE 

## SKIES**IN~ESTMENTS,** LLC SEEKS EXEMPTION

...........................................................

### 7
THE EXTENT OF**RELIE~** BLUE SKIES INVESTMENTS, LLC SEEKS AND THE REASON BLUE SKIES INVESTMENTS, LLC SEEKS 

## THE RELIEF

......................................................................................................................... 

### 1 0
THE**RE~SONS** WHY GRANTING BLUE SKIES**IN~ESTMENTS,** LLC'S REQUEST WOULD BE IN THE PUBLIC INTEREST

...................................... 11
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

.......................................................................... 13**S~MM~RY TH~T** **C~N** BE**PU~LISHED** IN THE FEDERAL REGISTER

......21
ANY**~DDITIONAL** INFORMATION, VIEWS, ORARGUMENTS**A~ AILA~LE**  TO SUPPORT**~LUE** SKIES INVESTMENTS, LLC'S

### REQUE~T..

### ·······················~·····················································································~2 CONCLUSION

....................................................................................................................**2~** APPEND ICES

......................................................................................... 26AGL AOI ATC 

### ATO AV CFR COA 

### FAA FAR 

### GCS GPS 

## LOL NAS 

### NOT AM PIC Section 333 

# so SOP UA 

### UAS VFR 

## VLOS VMC 

### VTOL Above Ground Level Area 

### ofInterest Air

### Traffic Control 

### Air Traffic Organization Aerial Vehicle Code ofFederal Regulations 

### Certificate ofAuthorization Federal 

### Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink 

### National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Section 333 

### Safety Observer Standard Operating Procedures Unmanned 

### Aircraft UnmannedAircraft System Visual Flight Rules Visual Line ofSite 

### Visual Meteorological 

### Conditions

' Vertical Takeoffand 

### Landing

### SIJMMARY Blue Skies Investments, 

### LLC seeks exemption from the requirements of 14 

### C.F.R §§ 

### 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a) (2), and 91.417(a) & 

### (b), to operate an Unmanned Aircraft System pursuant to Section 333 

### ofthe FAA 

### Modernization and Reform Act

### of2012 (FMRA). This exemption will 

### permit Blue Skies Investments, LLC to operate an

### Unmanned Aircraft System (UAS) for the commercial purpose ofconducting aerial video and photography for wedding videography, real estate photography, corporate marketing, special events, and landscape over certain areas ofthe United States.



### I:NTRODUCIJON"AISD INIERESTS OF THE PETITIONER 

### Blue Skies Investments, 

### LLC provides its clients with 

### expertise 

### arid knowledge in Real Estate investments and marketing. Blue Skies Investments, LLC 

### also provides its clients with the highest quality digital content for use intheir commercial, personal, and 

### non-profit multimedia projects. Blue Skies Investments, LLC 

### owner, Todd A. Barnes has over 13,000 flight 

### hours and 15 

### years of experience 

### as an 

### Airline Pilot and holds an

### Airline Transport Pilot Certificate, Flight

### Instructor Certificate, and 

### a First Class Medical Certificate with No Restriction. Blue Skies Investments, LLC has over 3 years ofrecreational/hobby experience in all aspects ofaerial video and photography. The objective ofBlue Skies Investments, LLC's aerial video and

### photography operations is to provide high quality

### imaging for a variety ofresidential, commercial, and public uses, specifically targeting:

• Real Estate Marketing
• Event Videography and 

### Photography
• Business Marketing
• Aerial Imaging Used For Inspections of_Public and Private Structures
• Emergencies Services

-

**Seru;~h** 

### and Rescue Assistance
• Increasing public knowledge ofUAS and promoting safe UAS operations. BACKGRQUNp 

### Unmanned Aircraft System: DJI Phap_1pm 3 UAS Blue Skies Investments, LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DTI Phantom 3 

### has 

### a maximum gross weight ofapproximately 2 pounds 13 ounces, while having a length of 18 inches, width of 13 inches, height of 8 inches, and a maximum speed ofapproximately 30 knots. The DJI Phantom 3 is equipped with four n1ain rotors; driven by Lithiwn Polymer battery powered electric motors. · The DJI Phantom 3 UA that will be operated by Blue Skies Investments, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, 

### as well as 14 C.F.R Part 47, AircraftRegistration, 

### and marked in accordance with 14 C.F.R. Part 45, Identification and RegistrationMarking.

### BASIS FOR PETIUQN Petitioner, Blue Skies Investments, LLC, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. 

### § 11.61) and the FAA Modernization and Refoun Act of2012 (FMRA), Section 333, 

### SpecialRules for Certain UnmannedAircraftSystems, hereby petitions the Administrator to commercially operate the DJI Phantom 3, UA inthe National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

### §§ 91.7(a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

### & (b). In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Blue Skies Investments, LLC's operation ofDJI Phantom 3 UA meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21 , Subpart H.

· Accordingly, Blue Skies Investments, LLC requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Blue Skies Investments, LLC submits that the requested reliefis proper since an equivalent level ofsafety will be ensured. Blue Skies Investments, LLC will use experienced personnel or technicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribed 

### inthe operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthennore, Blue Skies Investments, LLC will document and maintain all maintenance records for the DJI Phantom 3 UA. Blue Skies Investments, LLC seeks relieffrom Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the DJI Phantom 3 UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Blue Skies Investments, LLC submits that they will ensure that the DJI Phantom 3 UA is in an airworthy condition, prior to every flight, by determining that the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the UA is in a condition for safe flight. Blue Skies lnvesttnents, LLC also seeks an exemption from the requirements ofSection 91.121 , entitled

### Altimeter Settings, as the DJI Phantom 3 UA will nothave a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3 UA will beprovided to the PIC via Global Positioning System (GPS) equipment and radio commllllication s telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with Blue Skies Investments, LLC's operation ofthe DJI Phantom 3 UA within visual line ofsight, at or below 500 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. Additionally, Blue Skies Investments, LLC seeks an exemption from the requirements of Section 91.151(b), entitled 

### Fuel requirements forflight in 

### VFR conditions. Blue Skies Investments, LLC submits that safety will not be affected by operation ofthe DJI Phantom 3 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81 , Blue Skies Investments, LLCprovides the following information in support ofits petition for exemption:

I

.

### A. Name And Address OfThe Petitioner. 

### The name and address ofthe Petitioner and point ofcontact is: Blue Skies Investments, LLC c/o Todd A. Barnes 5815 Cool Springs Drive Cumming, Ga. 30040 

### Tel: (678) 522-2651 

### Email:**BlueSkiesTB@ginaiJ.~QlTI** 

### B. The Specific Sections Of 14 C.F

### .R. from Which Blue Skies Investments, LLC Seeks Exemption.


### 1. Blue Skies Investments, LLC Seeks Exemption From The Requirements OfSection 91.7(a). 

### Section 91.7, entitled Civil aircraft airworthiness, 

### subsection (a), states the following: (a) No person may operate a civil aircraft unless it 

### is in an aif\iVorthy condition.
2. Blue Skies Investments, LLC Seeks Exemption From The Requirements Of Section 91.121. 

### Section 91.121, 

### entitledAltimeter settings, 

### subsection (a), states the following, inpart: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may 

### be, byreference to an altimeter that is set, when operating;..- (1) Below 18,000 

### feet MSL, to-- (i) The current reported altimeter setting ofa station along the route and within 1 00 nautical miles ofthe aircraft; (ii) 

### Ifthere is no station within the area prescribed in paragraph (a)(l)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or 

### (iii) In

### the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.
3. Blue Skies Investments, LLC Seeks Exemption From The Requirements OfSection 91.151(b). 

### Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

### subsection (b), 

### states the following:

(b) 

### Noperson may begin a flight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enough fuel to fly 

### to the first pointqf 

### intended landingand, assuming normal cruisingspeed, tofly after 

### that for at least 20 •

### minutes.
4. Blue Skies Investments, LLC Seeks Exemption From The Requirement OfSection 91.405(a).
Section 91.405, entitled

### Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- 

### (a) Shall have that aircraft inspected 

### as prescribed in subpart E ofthis part and shall between required inspections, except 

### as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.]
5. Blue Skies Investments, LLC Seeks Exemption From The Requirements OfSection 91.407(a)(1). Section 91.407, entitled 

### Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration**unless~-** 

### ( 1) It has been approved for returnto service 

### by a person authorized under 

### § 43.7 ofthis chapter[.]
7. Blue Skies Investments, LLC Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2).
Section 91.409, entitled

### Inspections, subsection 

### (a), states the following: (a) Except as provided 

### inparagraph (c) ofthis section, no person may operate an aircraft unless, withinthe preceding 

### 12 calendar months, it has had**~~** 

### (1) 

### An annual inspection in accordance 

### with part 43 ofthis chapter and has been approved for return to service by 

### a person authorized by§ 43.7 ofthis chapter; or 

### (2) An inspection for the issuance ofan 

### airworthiness certificate in accordance 

### withpart 21 ofthis chapter.
8. Blue Skies Investments, LLC Seeks Exemption From The Requirements OfSections 91.417(a) And 

### 91.417(b).
Section 91.417, entitled

### Maintenance records, subsections (a) and (b), state the following: · 

### (a) Except for work performed in accordance with§§ 91.411 and 91.413, eachregistered owner or operator shall keep 

### the following records forthe periods specified in paragraph (b) ofthis section: 

### (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 

### 1**OO~hour,** 

### annual, progressive, 

### and other required 

### or approved 

### inspections, asappropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (orreference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work perfonned; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. (iv) The currentinspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis 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)(l) ofthis 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) ofthis section shall be retained and transferred withthe aircraft at the time the ahcraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for
• return to servtce.

### C. The Extent OfReliefBlue Skies Investments, LLC Seeks And The Reason Blue Skies Investments, LLC Seeks The Relief.
1. Extent OfReliefBlue Skies Investments, LLC Seeks And The Reason Blue Skies Investments, LLC Seeks ReliefFrom Section 91.7(a). Relief from Section 91.7(a) entitled 

### Civil aircraft airworthiness, is requested 

### to the extent required to allow Blue Skies Investments, LLC to determine that the DJI PhantOm 3 UA is in airworthy condition prior to every flight by ensuring that the UA is in compliance with the operating documents (i.e. , the Blue Skies Investments, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Blue Skies Investments, LLC seeks the requested reliefbecause the DJI Phantom 3 UA does not require an airworthiness certificate in accordance with 14 C

.F

.R. Part 21 , Subpart H. Therefore, Blue Skies Investment

. s, LLC will ensure that the DJI Phantom 3 UA is in airworthy condition based upon its compliance 

### with the operating documents (i.e., Monthly

· Maintenance Log, and DJIPhantom 3 Instruction Manual) prior to every flight, and further, determine thatthe aircraft is in condition for safe flight, as stated inthe conditions and limitations below.



### 3. Extent OfReliefBlue Skies Investments, LLC Seeks And The Reason Blue Skies Investments, LLC Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJI Phantom 3 UA, which utilizes a barometric pressure sensor, GPS equipment, and a radio communications telemetry 

### data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Blue Skies Investments, LLC seeks the requested reliefbecause the DJI Phantom 3 UA's altimeter may be set onthe ground to zero feet AGL, rather than the local barometric pressure orfield altitude, before each flight. Considering the limited altitude oftheproposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply withthe applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 3 US is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS. 

### 4. Extent OfReliefBlue Skies Investments, LLC Seeks And The Reason Blue Skies Investments, LLC Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extentrequired to allow flights ofthe batterypowered DJI Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming 

### nonnal cruising speed, to fly after that for at least 4.5 minutes. Blue Skies Investments, LLC seeks the requested reliefbecause without an exemption from Section 91.151

### (b), the flight time' duration ofthebattery powered DJI Phantom 3 UA will severely constrain the practicality of 

### any aerial video or still photo 

### flight operations that Blue Skies Investments, LLC proposes to conductpursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe 

### DnPhantom 

### 3 UA, the DJI Phantom 3 operating documents, and Blue Skies Investments, LLC's proposed operating limitations, ensure that Blue Skies Investments, LLC will safely operate the battery powered 

### DJI Phantom 

### 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbattery powerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming nomtal cruising speed, to fly after that for at least 4.5 minutes. 5. Extent OfReliefBlue Skies Investments, LLC Seeks And The Reason Blue Skies Investments, LLC Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & 

### (b) only apply to aircraftwith an airworthiness certificate, Blue Skies Investments, LLC requests relief from these Sections becausethe 

### DJI Phantom 

### 3 UA does not require 

### an airworthiness certificate. As set forth more fully below, the DJI Phantom 3 UA meets the conditions ofFMRA

. Section 333 for operation without 

### an airworthiness certificate. Accordingly, Blue Skies Investments, LLC will use experienced personnel ortrained technicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribed inthe UAS operating documents (i.e., the Blue Skies Investments, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Blue Skies Investments, LLC will document and maintain all maintenance records for the DJI Phantom 3 UAS.
D. The Reasons Why Granting Blue Skies Investments, LLC's Request Would Be In The Public Interest; That Is, How ItWould Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing Blue Skies Investments, LLC to safely, efficiently, and economicallyperform aerial video and photography for real estate, events, businesses, inspections ofstructures, emergency services, and increasing public knowledge ofUASs and promoting safe UAS operations. Additionally, use of

### the DJI Phantom 

### 3 UA 

### will decrease congestion ofthe
· NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofBlue Skies Investments, LLC's proposed operation ofthe 

### DJI Phantom 

### 3 UA will be realized without implicating
• • any 

### pnvacy tssues.


### 1. The Public Will Benefit From Decreased Congestion OfThe NAS. The DJIPhantom 3 UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing 

### the amount ofmanned aircraft 

### needed to 

### perform aerial acquisitions, an exemption allowing the use ofa 

### DJIPhantom 

### 3 UA wouldreduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, 

### as well as increase the safety oflife and property in the air and onthe ground. Furthermore, by reducing the number ofmanned aircraft operating 

### inthe NAS, congestion 

### around airports caused by 

### aniving and departing aircraft will be reduced. The DJI Phantom 3 UA does 

### notrequire 

### an airport

### to takeoff

### orland. Likewise, a reduction ofmanned aircraftconducting aerial video and photography missions would result 

### in fewer aircraft that mustbe handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.
2. ThePublicWill Benefit From The SafetyAnd Efficiency OfThe DJI Phantom 3 UA. Conducting aerial acquisitions with the DJI Phantom 3 UA, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noisepollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UA produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 3 UA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery poweredelectric motors, rather than 

### an internal combustion engine. Byusing the DJIPhantom 3 UA to perform aerial acquisitions, the substantial risk to life and property inthe air and onthe

**ground~** which is usually associated with traditional manned aircraft flight operations, will be substantiallyreduced orcompletely eliminated. Aside from the lack offlight crewmembers located onboard the aircraft, the 

### DJI Phantom 

### 3 UA (weighing approximately 2 pounds 13 ounces, at its maximum gross weight with a length of 18 inches, width of 13 inches, and with no fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and inthe air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan 

### of approximately 42 feet, 

### a length of34 feet, and a fuel capacity of 180 gallons).
3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 UAS Will Benefit The Economy.
In addition to being safe and efficient, the DJIPhantom 3 UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

### DnPhantom 

### 3 VA will allow United Statesbased companies, like Blue Skies Investments, LLC, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel 

### and the Environmental Protection Agency (''EPA'') regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology 

### in order to remain competitive. Operating the battery powered DJIPhantom 3 UA 

### is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the DJI Phantom 3 UA, companies such as Blue Skies Investments, LLC, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and 

### contractors, which 

### will ultimately contribute to 

### growth of

### the U.S. 

### economy. Improved financial performance ofU.S. companies, through commercial use ofthe 

## Dn Phantom 3 UA, provides a stable workforce that increases conswner spending; improves local, state, and federal tax revenues; and allows companies to invest inresearch and development in orderto 

### remain competitive both 

### in

### the United States and abroad.

### 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Blue Skies Investments, LLC'sproposed operation ofthe DJIPhantom 3 UA will not implicate any privacy issues. Specifically, the DJI Phantom 3 UA will be operated only in compliance with operating documents (i.e., the Blue Skies Investments, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 Instruction Manual) whichrequires property ownerinvolvement as well as local law enforcement notification, and in accordance 

### with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

### § 91.119.


### E. The Reasons Why Granting The Exemption Would Not Adversely Mfect Safety, OrHow The Exemption Would Provide A Level OfSafety At Least Equal To That Provided By The Rule From Which Blue Skies Investments, LLC Seeks Exemption.
1. Reasons Why The DJI Phantom3 UAS Meets The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333.
In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Blue Skies Investments, LLC's operation ofthe DJI Phantom 3 UA meets the conditions ofFMRA Section 333, and will notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General. --Notwithstanding any other requirement of this subtitle, andnot later than 180days after the date of enactment of thisAct , the Secretary of Transportation shall determine 

## if certain unmannedaircraftsystems mayoperate safely in the national airspace system before completion of theplan andrulemaking requiredbysection 

### 332 of thisActor the guidance requiredbysection 

### 334 of this Act. 

### (b) Assessmentof UnmannedAircraftSystems.--In making the determination under subsection (a), the Secretary shall determine, ata minimum-- (1) which types of unmannedaircraft systems, 

## if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, andoperation within visual line of sight do not create a hazardto users of the national airspace system or thepublic orpose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, orairworthiness certification under section 44704 of title 49, UnitedStates Code, is required for 

### the operation of unmannedaircraft systems identifiedunderparagraph (1).

### (c) Requirements for Safe Operation.--Ifthe Secretary determines under this section 

### that certain unmannedaircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. 

### In seeking this exemption, Blue Skies Investments, LLC submits that the DJI Phantom 3 

### UA can operate safely in

### the NAS 

### pursuant to FMRA 

### Section 333, 

### as demonstrated by: (a) 

### the characteristics ofthe DJI Phantom 3 UAS; 

### (b) 

### the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications OfThe DJI Phantom 3 UA Demonstrates Its Safe Characteristics. 

### The DJI Phantom 3 

### UA does not create a hazard to users ofthe NAS or the public, or otherwise pose a 

### threat to national security considering its size, weight, speed, and operational capability.
i. Technical Specifications OfThe DJI Phantom 

### 3 UAS. 

### The technical specifications ofthe DJIPhantom 3 

### UAS is set forth by the DJI Phantom 3 

### Specifications and Data Sheet, attached hereto as 

### Exhibit A.
ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The UA To Remain Within A Defined Operational Area. 

### The DJI Phantom 3 UA may be operated in both manual and fully 

### autonomous flight modes. A 

### complete description ofthe flight and navigational modes ofthe DJI Phantom 3 U A is provided at pages 11-17 and 40-46 ofthe DJI Phantom 3 User Manual, attached hereto as Exhibit B.
iii. TheDJI Phantom 3 UA Is Designed ForAutomatic Return To Home Point Or Hover 

### In The Event OfLoss OfThe Control Liilk OrNavigation. 

### When the Control Link is lost, the DJI Phantom 3 UA will remain stationary, inflight, for 3 

### seconds ormore. If, 

### after 3 

### seconds, the DJI 

### Phantom 3 UA does not reacquire control link data from the GCS, the UA will assume that the Control Link 

### is lost and the UA 

### will return to the home position (i.e., failsafe mode) via GPS, 

### and will 

### descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 3 UA are set forth at pages 12 through 14 of

### the DJI Phantom 3 User Manual, attached hereto as Exhibit B. iv. The DJI 

### Phantom 3 GCS And Its Operation. 

### A complete description ofthe operation and specifications ofthe DJI Phantom 3 GCS and flight control software is provided at pages 23 through 38 ofthe DJIPhantom 3 User Manual. The DJIPhantom 3 User



### . Manual is attached hereto as Exhibits B.b. Flight Operations OfThe DJI Phantom 3 UA Are Limited To The Line OfSight Of A Certificated Pilot in Command With A Safety Observer. Blue Skies Investments, LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJI Phantom 3 UA. Additionally, a safety observer will assist all pilots during flight time.

c. Flights OfThe DJI Phantom 3 UA Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking this exemption, Blue Skies Investments, LLC proposes to commercially operate a DJI Phantom 3 UA for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations:

1. Operations authorized by this grant ofexemption will be limited to the following aircraft described 

### in the operating documents, rotorcraft UASs weighing less than 

### 55 pounds maximum gross weight: DJIPhantom 3 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a newpetition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UA may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude ofno more than 500 feet above ground level (AGL ), as indicated by the procedures specified 

### inthe operating documents unless a special request is made and approved byATC. All altitudes reported to ATC must be 

### in feetAGL.
5. The UA mustbe operated within visual line ofsight (VLOS) ofthe 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 onthe PIC's FAA-issued airman medical certificate.
6. The use offirst person view (FPV) 

### by the PIC or safety observer (SO) is not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC mustbe able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannottransfer his orher designation for the duration ofthe 

### flight. The PIC must ensure that the SO canperform the functions prescribed inthe operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not

### permitted to operate the camera or other instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations contained 

### in the grant ofexemption and the procedures outlined inthe operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow theprocedures as outlined inits operating documents. The operatormay update orrevise its operating documents. Itis the operator's responsibilityto track such revisions and present updated and revised documents to the Administrator uponrequest. The operator must also present updated and revised documents ifitpetitions for extension or amendment to the 

### grant ofexemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to 

### its grant ofexemption. The FAA'sUAS Integration Office (AFS-80) maybe contacted ifquestions atise regarding updates or revisions to the operating documents. 10. Priorto each flight the PIC mustinspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessarymaintenance has been perfotmed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included inthe preflight inspection. All maintenance and alterations must be properly documented 

### in the aircraft records. 

### 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry 

### inthe aircraft records.
12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, orequipment, not already covered in the relevant sections ofthe operating documents.
13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 

### 14. The operator must carry outits maintenance, inspections, and record keeping requirements, in accordance withthe operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts mustbe noted 

### in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections.17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 18. The operator maynot permit any PIC to operate unless the PIC meets the operator's qualification criteriaand demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged 

### ina manner consistent with 14 C.F.R. 

### § 61.51(b). Flights for the purposes oftrainingthe operator's PICs are permitted under the tenns ofthe 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 C.F.R. §91.119. 19. UAS operations may notbe conducted during night, as defined in 14 C.F.R. 

### § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.
20. The UA may not operate within 

### 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required bythe operator's COA. The letter ofagreement with the airport management must be made available to the Administrator upon request. 21. 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. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating docwnents. 23. The PIC must abortthe flight in

**~e** event ofunpredicted obstacles or emergencies 

### in accordance 

### with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder 

### requirements.26. All aircraft operated in accordance with the exemption must be identified by serial number, registered 

### in accordance with 14 C.F.R. part47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.P.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right ofway to 

### all manned aviation operations and activities at all times. 30. The UAS may notbe operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthanthe PIC, SO, operator trainees or essential 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 ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and detennined that 

### it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per 

### § 91.119( a). 32. All operations shall be conducted overprivate or controlled-access property with permission from the land owner/controller or authorized representative. Pennission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COAmust be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reportedto the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

### 2. Reasons 

### WhyAn Exemption From The Requirements OfSection 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Blue Skies fuvestments, 

### LLC will ensure that the DJI Phantom 

### 3 UA is 

### in an airworthy condition based upon the UA's compliance with

### its operating documents and 

### as stated inthe conditions and ]imitations herein. Additionally, the 

### FAA has previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in 

### all material respects, to those presented herein (e.g

. ExemptionNos.11062, 11063 , 11064,11065, 11066,11067,11080, 11109,11110, 11112,

11136,11138, 11150,11153 , 11156,11157, 11158,11159,11160, 11161 , 12928).


### 3. Reasons 

### Why An Exemption From The Requirements OfSection 91.121 Would Not Adversely Affect Safety. The equivalent level ofsafety established 

### by Section 91.121 will be maintained because the altitude inforn1ation ofthe DJI Phantom 

### 3 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data 

### link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. 1bis altitude infonnation, combined with Blue Skies Investments, 

### LLC's operation ofthe DJI Phantom 

### 3 UA within visual line ofsight, at orbelow

### 500 feet 

### AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information 

### will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established bythe UA at ground level.
The 

### FAAhaspreviously granted relieffrom Section 91.121 specific to UAs, 

### in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150,11153,11156,11157, 11158,11159,11160,11161, 12928).


### 5. Reasons 

### Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent lev el ofsafety established by 14 C.F.R. Section 91.151(b) as a result of( 1) the technical specifications ofthe DJI Phantotn 3 UA; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Blue Skies Investments, LLC will ensure that it will safely operate the battery powered DJI Phantom 3 UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes 

### to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 4.5 minutes. Here, as inExemption No. 11109, the technical specifications ofthe DJIPhan tom 3 UA; the limitations onthe proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established 

### by 14 C.F.R. Section 

### 91.151(b). Furthermor e, safety will be ensured as the DJIPhantom 3 UAS provides audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33%remaining battery power, and again at approximately 10% remainingbatterypower. At the critically lowbattery level, the DJIPhantom 3 UAS willdescend and land automatically. Significantly, previous exemptions granted bythe 

### FAA concerning Section 

### 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed

### in Section 91.151 , including Exemption Nos. 2689, 5745, and 10650. Moreover, the 

### FAAhas previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067,

11080,11109,11110,11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161).



### 6. Reasons Why An 

### Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b)

### WouldNotAdversely Affect Safety.
In seeking this exemption, Blue Skies Investments, LLC submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will 

### be met because Blue Skies Investments, 

### LLC will perform maintenance, alterations, or preventive maintenance on the UAusing the methods, techniques, and practices prescribed in the operating docrunents (i.e., the Blue Skies Investments, 

### LLC Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 Instruction Manual). Furthennore, Blue Skies Investments, LLC will document and maintain all maintenance records for the DJIPhantom 3 UA.
Since the DJIPhantom 3 UA will be inspected as prescribedbythe operating documents, Blue Skies Investments, LLC will maintain the equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI Phantom 3 User Manual is attached hereto as Exhibit B; a copy ofthe DJI Phantom 3 

## u· As Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Blue Skies Investrnents, LLC will perform maintenance, alterations or preventive maintenance onthe UA using the methods, techniques, and practices prescribed bythe operating documents. Furthennore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 UA will be perfonned by using the methods, techniques, and practices prescribed by the DJI Phantom 3 User Manual. Maintenance will be documented and maintained utilizing the monthlymaintenance log. Significantly, previous exemptions granted bythe 

### FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UA are considered. In consideration ofBlue Skies Investments, LLC's proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 3 UA, Blue Skies 

### Investments, LLC submits that safety will not be 

### adversely affected by 

### granting exemption 

### from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 

### and (a)(2), 91.409(a)(2), and 91.417(a)and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presentedherein (e.g. ExemptionNos. 11062, 11063,

11064,11065,11066,11067, 11080,11109,11110,11112,11136,11138,11150,11153, 

### 11156, 11157,11158,11159, 11160, 11161).
7. The FAA May 

### Prescribe Any 

### OtherConditions For Safe Operation.
In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 

### (FMRA) and 14 

### C.F.R. § 

### 21.16 entitled Special Conditions, Blue Skies Investments, LLC requests that the FAAprescribe special conditions for the intended operation ofthe DJI Phantom 3 UA, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 

### 14 C.F

### .R. Part 

### 21, Subpart

### H, and 14 C.F.R 

### §§ 91.7 (a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a ) & (b). Such special conditions will permit safe operation ofthe UASs for the limited purpose of conducting aerial video and photography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator mayprescribe special conditions pursuant to 14 C.F

### .R. § 21.16, for operation ofthe DJI Phantom 3 UA, since the airworthiness regulations of 14 

### C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for 

### an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued 

### in accordance 

### with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller as the FAA finds necessary to establish a level ofsafety equivalent to that established in the regulations. See 14

**F.R~** 

### § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.P .R.§ 21.16, the FAA may prescribe special conditions for Blue Skies Investments, LLC' s intended operation ofthe 

### Dn Phantom 

### 3 UA, which contain such safety standards that the Administrator finds necessaryto establish 

### a level 

### ofsafety equivalent to 

### that established by 14 C.F.R. Part 

### 21, Subpart

### H, and 

### 14 

### C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

### 91.409(a)(l) & (a)(2), 

### and 91.417(a) & (b).


### F. A Summary That Can Be Published 

### In The Federal Register, stating: The Rules From Which 

### Blue Skies Investments, LLC Seeks 

### Exemption:. .



### Blue Skies Investments, LLCseeks exemption from the requirements of 

### 14 C.F.R Sections 

### 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(J), 91.409(a)(l)& (a)(2), and91.417(a) & 

### {b).

A BriefDescription OfThe Nature OfThe Exemption Blue Skies Investments, LLC Seeks:

. This exemption willpermitBlue Skies Investments, LLCto commercially operate an UnmannedAircraft System (UAS)for thepurpose of conducting aerial video and photography over certain areas of the United States. 

### G. Any Additional Information, Views, Or Arguments Available 

### To Support Blue Skies Investments, LLC's Request.
This Petition is made pursuant to the FAA Modernization and Refom1 Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to detennine ifcertain UAS may operate safely in the NAS. As such, Blue Skies Investments, LLC's request for exemption maybe granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FlvfRA Section 33 3 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for suchUAS to operate without airworthiness certification. As discussed in detail above, Blue Skies Investments, LLC will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

As set forth herein, Blue Skies Investments, LLC seeks an exemption pursuantto 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will pennit safe operation ofthe 

### Dll Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAAModernization and Refonn Act of2012, while also advancing the interests ofthe public, by allowing Blue Skies Investments, LLC to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within theNAS. WHEREFORE, in accordance 

### with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, Blue Skies Investments, LLC respectfully requests that the Administrator grant this Petition for an exemptionfrom the requirements of 14 C.F.R Sections 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and

### pennit Blue Skies Investments, LLC to operate the DJIPhantom 3 UAS commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.Dated: October 14, 2015

EXHIBITS**(Unlq~<l**

### file):
A

- DJI Phantom 3 Specifications Data B- DJI Phantom 3 Manufacturer's User Manual 

### C -Maintenance Log Respectfully Submitted Blue Skies Investments, LLC

,,· , .. •• .. / 

## / 

## ./

.**~.........** . • .,.>i'

:·**.~** 

### .

, ./'./ "'**~·** t' Todd

### A. Barnes Blue Skies Investments, LLC, President 5815 Cool Springs Drive Cumming, Ga. 30040 Tel: (678) 522-2651