Attention:  

United States Secretary of Transportation 

Mr. Anthony R. Foxx  

1200 New Jersey Ave, SE 

Washingt on DC 20590  

Re:  Exemption  Request  Section  333  of  the  FAA  Reform Act  and  14  CFR Part  11  of the  Federal 

Aviation Regulations from 14 CFR 45.23(b);  14 CFR Part 21; 14 CFR 61.113 (a)  & (b);  91.7 (a);  91.9 (b)

(2);  91.103 (b);  91.109; 91.119; 91.121; 91.151 (a);  91.203 (a)  & (b);  91.409 (a)  (2);  91.417 (a)  & (b)

Dear Mr. Secretary, 

Pursuant to Section 333 of  the FAA  Modernization  and  Reform Act  of 2012 (the Reform Act) and 

14  CFR  Part  11,  MY BLUE ROBOT LLC, a  Florida Limited  Liability  Corporation,  consultant, and 

operator  of  Small  Unmanned  Aircraft  Systems  (“sUASs”)  equipped  to  conduct  aerial 

photography  and  videography  purposes,  hereby  applies  for  an  exemption  from  the  listed 

Federal  Aviation  Regulations  (“FARs”)  to  allow  commercial  operation  of  its  sUASs,  so  long  as 

such  operations  are  conducted  within  and  under  the  conditions  outlined  herein  or  as  may  be 

established by the FAA as required by Section 333.  

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)  limited, 

2) predetermined, and 3)  controlled as to access. Approval of this exemption would thereby fulfill the

Secretary  of  Transportation’s  responsibilities to  “...establish  requirements for the  safe  operation  of such 

aircraft systems in the national airspace system.” Section 333 (c) of the Reform Act.

MY BLUE ROBOT LLC, requests to use the DJI Inspire 1& DJI Phantom 3 for aerial imaging. The FAA has 

previously  issued  Grants  of  Exemption  in  circumstances  similar  in  nearly  all  material  respects  to  those 

presented in this petition. In previous Grants of Exemption [Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC 

(see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc.  (see Docket No. FAA−2014−0642)], 

the  FAA  found  that  the  enhanced  safety  achieved  using  an  unmanned  aircraft  with  the  specifications 

described by the petitioners, carrying no passengers or crew—rather than a manned aircraft of far greater 

proportions, carrying crew and flammable fuel—gave the FAA good cause to find that the UAS operations 

were in the public interest. MY BLUE ROBOT LLC, feels that the reasons stated by the FAA for granting 

Exemption Nos. 11062, 11109, 11112, and 11213 would also reasonably apply to the situation presented 

by  this  petition.  Additionally,  we  feel  that  considering  the  enhanced  safety  features  provided  by  the  DJI 

Inspire  1  (the  “No­Fly  Zone” feature  in  particular),  as  well  as the  cost  effectiveness  of  small  UAS  aerial 

photography, a grant of exemption would be in the public interest. 
The  name  and  address  of  the  applicant  is:  MY BLUE ROBOT LLC, Attn:  Chris Nesci

Phone: 727-637-4251 Email:  chris@mybluerobot.com Address:  310 10th Ave North Safety Harbor, 

FL 34695.  

Regulations from which the exemption is requested: 

14 CFR Part 21  

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 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a)  

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)  

14 CFR 407 (a) (1)  

14 CFR 409 (a) (2)  

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section                          

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider                                

whether certain unmanned aircraft systems may operate safely in the national airspace system                          

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making                                

this determination, the Secretary is required to determine which types of UASs do not create a                              

hazard to users of the NAS or the public or pose a threat to national security in light of the following:  

• The sUAS’s size, weight, speed, and operational capability

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. Reform                              

Act §333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Reform Act §333 (c). The Federal Aviation Act expressly 

grants the FAA the authority to issue exemptions. This statutory authority by its terms includes 

exempting civil aircraft, as the term is defined under §40101 of the Act; that includes sUASs, from the 

requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may 

grant an exemption from a requirement of a regulation prescribed under subsection (a)  or (b)  of this 

section or any sections 44702­44716 of this title if the Administrator finds the exemption in the public 

interest. 49 U.S.C. §44704; 14 CFR §91.203 (a) (1).  

MY BLUE ROBOT LLCs, UASs are small rotorcraft  aircraft, weighing less than 60 oz including 

sensor payload. We operate our rotorcraft under normal conditions at a speed of no more than 17 
knots, usually 0­5 knots. The rotorcraft have the capability to hover and move in the vertical and 

horizontal plane simultaneously. We will manually operate only in Visual Line of Sight and will 

operate only within the operating parameters as described in the Operating Manual attached as 

Attachment 1.  

Adherence to the Operating Manual will insure that the sUASs will “not create a hazard to the 

national airspace system or the public.”  

Given the small size and weight of the sUASs involved and the restricted sterile environment 

within  which they  will  operate,  MY BLUE ROBOT LLC, falls  squarely within that zone of safety  (an 

equivalent level of  safety)  in  which  Congress  envisioned  that  the  FAA  must,  by  exemption,  allow 

commercial operations of  UASs  to  commence immediately. Also due to the size of the sUASs and 

the  areas in which  the  relevant sUAS will operate, approval of the application presents no national 

security issue. Given the  clear direction  in Section  333  of  the  Reform Act,  the  authority  contained 

in  the  Federal Aviation Act, as amended, granting the requested exemptions is in the public interest 

for  the  following  reasons:  (1)  the  strong  equivalent  level  of  safety  surrounding  the  proposed 

operations,  and  (2)  the  significant  public  benefits,  including  enhanced  safety,  reduction  in 

environmental  impact,  including  reduced  emissions  associated  with  allowing  UASs  for 

educational  and  marketing  operations,  (as  opposed to full  scale  aircraft).  Accordingly, MY BLUE 

ROBOT LLC, respectfully requests that the FAA grant the requested exemption without delay.  

AIRCRAFT  AND  EQUIVALENT  LEVEL  OF  SAFETY  MY BLUE ROBOT LLC, proposes 

that  the  exemption  requested  herein  apply  to  civil  aircraft  that  have  the  characteristics  and  that 

operate with the  limitations  listed  herein.  These  limitations  provide  for  at  least  an  equivalent  or 

possibly  higher  level  of  safety  to  operations  under  the  current  regulatory  structure  because  the 

proposed  operations  represent  a  safety  enhancement  to  the  already  safe  filming  operations 

conducted  with  conventional  aircraft.  These  limitations  and  condition  to  which  MY BLUE 

ROBOT LLC, agrees  to  be  bound  when  conducting  commercial operations under an FAA issued 

exemption include:   1. The sUASs will weigh less than 5 lbs.

2. Flights will be operated manually within visual line of sight (VLOS)  of the Pilot and aircrew

(Spotter / Observer). 

3. Maximum  total  flight  time  for  each  operational  flight  will  be  25  minutes.  Flights  will  be

terminated at 25% battery power reserve should that occur prior to the 25 minute limit.

4. Flights  will  be  operated  at  an  altitude  of  no  more  than  200  feet  AGL,  though  most

operations will be conducted within 50 feet of the ground

5. Minimum two (2)  man crew for each sUAS operation will consist of the Pilot and Spotter /

Observer. In most cases the third aircrew member will serve as the Safety Officer.

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate and

third class medical. The Spotter (Observer) will hold at least a third class medical.

7. The sUAS Pilot will serve as Pilot in Command (PIC).  If a pilot certificate holder, other than

the sUAS Pilot, possesses the necessary PIC qualifications and is also present, that person may also

be designated as PIC.

8. The  sUAS  will  only  operate  within  an  area  as  defined  in  the  Manual  on  pages  45­48.

Additionally, the sUAS will only operate under 200ft AGL, and outside a 3 statute mile radius of any
airport. The sUAS will never enter any MOA or Restricted Airspace, nor shall it violate any TFR as                                    

outlined by the FAA.  

9. A pre­flight briefing will be conducted in regard to the planned sUAS operation prior to each                              

day’s flying / recording activities. It will be mandatory that all personnel who will be performing duties                                  

as “flight crew” be present for this briefing.  

10. The Operator will obtain the consent of all persons involved in the filming and ensure that                              

only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be                                    

reduced to 30 feet based upon an equivalent level of safety determination.  

11. Pilot, and Spotter (Observer) will have been trained in operation of sUASs generally and                          

received up­to­date information on the particular sUAS to be operated as required. 

12. Spotter (Observer) and Pilot will at all times be able to communicate by voice or radio.

13. Written and/or oral permission from the relevant property holders will be obtained.

14. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability                            

to return to a predetermined location and land. 

15. The  sUAS  will  have  the  capability to  abort  a flight  in  case  of  unpredicted  obstacles  or

emergencies. 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a)  (1).  Given the size and limited 

operating area associated  with the aircraft to be utilized by MY BLUE ROBOT LLC,, an exemption 

from 14 CFR  Part  21 Subpart H  meets  the  requirements of  an equivalent  level of safety under 14 

CFR  Part 11 and Section 333 of  the  Reform  Act.  The Federal Aviation  Act (49 U.S.C. §44701 (f)) 

and Section 333 of the  Reform Act both authorize the FAA to exempt aircraft from the  requirement 

capability,  and  proximity  to  airports  and  populated  areas  of  the  particular  UAS.  In  all  cases,  an 

analysis  of  these  criteria  demonstrates  that  the  UAS  operated  without  an  airworthiness 

certificate,  in  the  restricted environment and under the conditions  proposed will be at least as safe, 

or  safer,  than  a  conventional  aircraft  (fixed­wing  or  rotorcraft)  operating  with  an  airworthiness 

certificate without the restrictions and conditions proposed.  

The sUAS to be operated hereunder weighs less than 5 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a limited radius area as set out in the pre flight briefing / VLOS operations. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the 

Operator, pursuant to safety requirements, and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation as is now done with 

conventional aircraft. These safety enhancements, which already apply to civil aircraft operated in 

connection with video production, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no

credible threat to national security posed by the sUAS, due to its size, speed of operation, location of

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial

external load.
14 CFR §45.23 (b): 

With regard to marking of the aircraft, this regulation requires: 

When marks include only the Roman capital letter “N” and the registration number is                            

displayed on limited, restricted or light­sport 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”, “light­sport,” “experimental,” or “provisional,” as applicable. 

Even though the sUASs will have no airworthiness certificate, an exemption may be needed as the                                

sUASs will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental”                                

can be placed. Given the size of the sUAVs, two­inch lettering will be impossible. The word                                

“Experimental” will be placed on the fuselage in compliance with 14 CFR §45.29 (f).  

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as                                  

required by 14 CFR §45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAV                                  

will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions                              

to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.  

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations ­ Pilot in Command (PIC) 

Sections 61.113 (a) & (b) limit private pilots to noncommercial operations. Because the sUASs will                              

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of                                  

current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather                                

than a commercial pilot’s license to operate this sUAS. Unlike a conventional aircraft that carries the                                

pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of                                  

operation is controlled and restricted, and all flights are planned and coordinated in advance as set                                

forth in the Operating Manual. The level of safety provided by the requirements included in the                                

Operating Manual meets that provided by a single individual holding a commercial pilot’s certificate                            

operating a conventional aircraft. The risks associated with commercial operations contemplated by                        

Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the                                    

PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b). 

14 CFR §91.7 (a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.                                  

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted,                                

no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and                              

the requirements contained in the Operating Manual for maintenance and use of safety checks prior                            

to each flight, as set forth in the Operating Manual, an equivalent level of safety will be provided.                                    

However, as required by 14 CFR 91.7(b) a preflight assessment will be conducted. 

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

Section 91.9 (b) (2) provides: 
No person may U.S.­registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight                              

Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a                                  

current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings,                      

and placards, or any combination thereof.  

The sUAS, given its size and configuration, has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the Operating Manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued 

the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A 10602, 32827, and 10700  

14 CFR §91.103: Preflight Action 

This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. An equivalent level of safety will be provided as set forth in the Operating Manual. The PIC 

will take all actions including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.  

14 CFR §91.109: Flight Instruction 

Section 91.109 provides that 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 

and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions 

Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact that aircraft will be piloted 

by a certified private pilot who has previously trained in remote flight areas before attempting flight 

within filming distance of structures. 

14 CFR §91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter  complies  with  any  route  or  altitudes  prescribed  for  helicopters  by  the  FAA.  As  this 

exemption  is  for  a  sUAS,  MY BLUE ROBOT LLC, requests  authority to  operate at altitudes  up to 

200 ft. AGL;  an exemption may be needed to allow such operations. As set forth herein, the sUAS 

will never operate  at higher than 200 ft. AGL. It will however be operated in a controlled area where 

buildings and people will not be exposed to operations without their pre­obtained consent.  

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as 

location where it is operated. No flight will be taken without the permission of the property owner and 
without advance notice to participants. Because of the advance notice to the property owner and 

participants in the photographic activity, all affected individuals will be aware of the planned flight 

operations as set forth in the Operating Manual. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the maximum 5 lbs. proposed herein and because of the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 ft. AGL. In addition, the low­altitude operations of 

the sUAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 CFR §91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS will not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Operating Manual and Safety Checklist, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.  

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point 

of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at 

least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the 

sUAS provides approximately 25 minutes of powered flight. To meet the 30 minute reserve 

requirement in 14 CFR §91.151, sUAS flights would be impossible. Given the limitations on the 

sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, 

a longer time frame for flight in daylight or night VFR conditions is reasonable. 

MY BLUE ROBOT LLC, believes that an exemption from 14 CFR §91.151 (a) falls within the scope 

of prior exemptions.  See  Exemption  10673  (allowing  Lockheed  Martin  Corporation  to  operate 

without compliance with FAR 91.151  (a)). Operating the sUAS in a tightly controlled area where only 

people and  property  owners  or  official  representatives  who  have  signed  waivers  will  be  allowed, 

with  less  than  30  minutes  of  reserve  fuel,  does  not  engender  the  type  of  risks  that  Section 

91.151  (a)  was  intended  to  alleviate  given  the  size  and  speed  of  the  sUAS.  Additionally,  limiting 

sUAS flights would greatly reduce the utility for which the exemption will be granted.  

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 25 minutes 

or 25% of battery power whichever happens first. This restriction would be more than adequate 

return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar  exemptions  have  been  granted  to  other  operations,  including  Exemptions  2689F,  5745, 

10673, and 10808.  

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 
The regulation provides in pertinent part: 

(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...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by                        

paragraph (b) of this section or a special flight authorization issued under §91.715 is                          

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 5 lbs. and is operated without an onboard Pilot. As such,                                      

there is no ability or place to carry certification and registration documents or to display them on the                                    

sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point                                  

where the Pilot flying the sUAS will have immediate access to them, to the extent they are applicable                                    

to the sUAS, and should they be issued. The FAA has issued numerous exemptions to this                                

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789,                          

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

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as                            

prescribed in subpart E of this part and shall between required inspections, except as provided in                                

paragraph C of this section, have discrepancies repaired as prescribed in Part 43 of this chapter...,”                                

and others shall inspect or maintain the aircraft in compliance with Part 43.  

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these                                

sections will not apply to the applicant. Maintenance will be accomplished by the operator; pursuant                              

to the Operating manual. An equivalent level of safety will be achieved because these sUASs are                                

very limited in size and will carry a small payload and operate only in restricted areas for limited                                    

periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from                                  

no higher than 200 ft. AGL. As provided in the Operating Manual, the PIC (operator) will ensure that                                    

the sUAS is in working order prior to initiating flight, and perform required maintenance. Moreover,                              

the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an                                      

airworthy condition to provide the equivalent level of safety.  

Publication Summary 

Pursuant to 14 CFR 11.81(f), the following summary is provided for publication in the Federal                              

Register, should it be determined that publication is needed: Applicant seeks an exemption from the                              

following rules: 14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a);                                            

91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a)                                    

(1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially Small Unmanned Aircraft Systems                              

(5lbs or less) in photography and videography operations.
Privacy 

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge, or over remote public land. Image capture of people will rarely take place, but in the 

event they are, they will have consented prior to being filmed or otherwise have agreed to be in the 

area where data collection will take place.  

Airborne Image Capture 

With  regard  to  airborne filming,  MY BLUE ROBOT LLC, adheres to all FAA regulations. Further MY 

BLUE ROBOT LLC, airborne  teams  operate  under  the  principles  of:  Safety  First,  Quality 

Assurance,  Accountability,  Reporting,  and  Training.  When  approved  by  the  FAA,  it  is  MY 

BLUE ROBOT LLC, mandate  to  treat  all  sUAS  operations  the  exact  same  level  of 

professionalism  and seriousness  as that of conventional aircraft. Approval of exemptions allowing 

commercial  operations  of  sUASs  in  our  industry  will  enhance  safety  by  reducing  risk. 

Conventional  operations,  using turbine  or  piston powered  aircraft,  present  the  risks  associated 

with  vehicles  that  weigh  in  the neighborhood  of  2,000lbs.+,  carrying  large  amounts  of  Jet A  or 

100LL  (90  gallons  for  the  aircraft previously used by MY BLUE ROBOT LLC,).  Such aircraft  must 

fly to  and  from  location.  In contrast, a sUAS weighing  fewer than  5 lbs, and powered  by  batteries, 

eliminates virtually all of the risk, given the  substantial  reduced  mass  and  lack  of  combustible  fuel 

carried  on  board.  The  sUAS  is  typically  transported  to  the  location  via  auto,  or  cargo  van,  in  a 

medium sized case and is never flown to the site.  The  sUAS  will  carry  no  passengers  or  crew  and, 

therefore,  will  not  expose them to the  risks associated with manned aircraft. 

The  operation  of  sUASs, weighing less than 5lbs, conducted in the strict conditions outlined above, 

will  provide  an equivalent  level  of  safety  supporting the  grant of the  exemptions  requested herein, 

including  exempting  the  applicant  from  the  requirements  of  14  CFR  Part  21  and  allowing 

commercial  operations.  These  lightweight  aircraft  operate  at  slow  speeds,  close  to  the  ground, 

and  in  a  sterile  environment.  As  a  result,  they  are  far  safer  than  conventional  operations 

conducted  with  piston helicopters, or fixed wing aircraft operating in relatively close proximity to the 

ground and people.  

The  primary  market  of  interest  for  MY BLUE ROBOT LLC, utilizing  sUASs  is  aerial  videography 

and photography. 

It is anticipated that the airborne image capture process will be accomplished exclusively in daytime 

VFR  environments.  To  capture  the  highest  quality  of  resolution  the  majority  of  airborne  data 

collections will take place during the 10:00am – 4:00pm window. 

Summary of Application 

Satisfaction  of  the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, 

operating capabilities,  proximity to  airports  and  populated  areas  and  operation  within  visual  line of 

sight  and  national  security – provide more than adequate justification for the grant of the requested 

exemptions  allowing  commercial  operation  of  applicant’s  sUASs  for  aerial  videography  and 

photography.  Operating  Manual  appended  hereto.  MY BLUE ROBOT LLC, is  eagerly  standing 

by  to 
support the FAA and sUAS community in its quest to establish proper regulations and protocols for 

the safe introduction of unmanned aircraft into the national airspace. 

Sincerely, 

Chris Nesci

MY BLUE ROBOT LLC,

310 10th Ave North

Safety Harbor, FL 34695

727-637-4251

Chris@mybluerobot.com