UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Keith A. Redlin FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CO NCERNING COMMERCIAL OPERATION OF BLADE 350QX AP AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on April 26 , 2015

Keith A. Redlin 49252 Kilkenny Drive Macomb, MI 48044 Tel: ( 248 ) 881

- 28612 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................... .....................................................4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................................................................................................................... .4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH KEITH A. REDLIN SEEKS EXEMPTION.................................................................8

THE EXTENT OF RELIEF KEITH A. REDLIN SEEKS AND THE REASON KEITH A. REDLIN SEEKS THE RELIEF.........................11

THE REASONS WHY GRANTING KEITH A. REDLIN ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENT S AVAILABLE TO SUPPORT KEITH A. REDLIN ’S REQUEST.........34

CONCLUSION................................................................................................................... .35

APPENDICES........................................................................................373 GLOSSARY OF ABBREVI ATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization
FAA Federal Aviation Administration
FAR Fe deral Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System
VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landi ng4 SUMMARY

KEITH A. REDLIN seeks exemption from the requirements of 14 C.F.R §§
61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),
and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Secti on 333 of
the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

KEITH A. REDLIN to operate an Unmanned Aircraft System (UAS) for the commercial
purpose of conducting aerial video and photography of construction sites, real estate,
special events, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

KEITH A. REDLIN provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. KEITH

A. REDLIN also provides its clients with the highest quality digital content for use in their

commercial , personal, and non

- profit multimedia projects. KEITH A. REDLIN has over 15
years of professional experience in Information Technology and is recognized as an expert

in netw ork infrastructure, computer systems, and multimedia content creation. He has over

3 years recreational/hobby experience in all aspects of aerial video and photography.
Additionally, he is an active Police Reserve with the Dearborn Police Department. The
objective of KEITH A. REDLIN ’s aerial video and photography operation s is to provid e high quality imaging (under 400 ft) for real estate, construction , and recreational markets
in Michig an and the surrounding states as well as special events.

BACKGROUND5 Unmanned Aircraft Systems: BLADE 350 QX AP and INSPIRE I UASs

KEITH A. REDLIN seeks an exemption to operate DJI and Blade systems for
compensation or hire within the NAS. The BLADE 350 QX AP and DJI Inspire 1 are
vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control
Station (GCS) utilizing electronic tablet or smart phone systems. The BLADE 350 QX AP

has a maxi mum gross weight of approximately 33.7 ounces, whi le having a length of 18.3

inches width of 18.3 inches, height of 7.48 inches, and a m aximum speed of approximately

20 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of
approximately 42 knots. The BLADE 350 QX AP and DJI Inspire 1UAs are equipped with
four main rotors; driven by Lithium Polymer battery powered electric motors.

The BLADE 350 QX AP and DJI Inspire 1 UAs that will be operated by KEITH A.

REDLIN will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14
C.F.R. Part 45, Iden tification and Registration Marking

. BASIS FOR PETITION
Petitioner, KEITH A. REDLIN , pursuant to the provisions of the Federal Aviation
Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012
(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby
petitions the Administrator to commercially operate the BLADE 350 QX AP and DJI Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the
requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).6 In consideration of the speed, weight, size, and limited operating area associated
with the unmanned aircraft and its operation, KEITH A. REDLIN ’s operation of BL ADE
350 QX AP and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and
therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part
21, Subpart H.
Accordingly, KEITH A. REDLIN requests relief from Sections 91.405(a ),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth
requirements for maintenance that only apply to aircraft with an airworthiness certificate.

KEITH A. REDLIN submits that the requested relief is proper since an equiv alent
level of safety will be ensured. KEITH A. REDLIN will use experienced personnel or
technicians to perform maintenance, alterations, or preventive maintenance on the UASs
using the methods, techniques, and practices prescribed in the operating documen ts (i.e.,
Monthly Maintenance Log , and BLADE 350 QX AP and DJI Inspire 1 Instruction
Manual). Furthermore, KEITH A. REDLIN will document and maintain all maintenance

records for the BLADE 350 QX AP and DJI Inspire 1 UASs.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command , is requested by KEITH A. REDLIN to the
extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level
certificate, as well as an airman medical certificate, and who has demonstrated, by meeting
minimum flight

- hour and currency requirements, that the PIC is able to safely operate the
BLADE 350 QX AP and DJI Inspire 1 UASs in a manner consistent with this exemption,
including evasive and emergency maneuvers and maintaining appropriate distances from
people, vessels, vehicles and structures.7 KEITH A. REDLIN seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the BLADE 350 QX AP and DJI Inspire 1 UASs do not require an
airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, KEITH

A. REDLIN submits that he will ensure that the BLADE 350 QX AP and DJI Inspire
1UASs are in an airworthy condition, prior to every flight, by determining that the UASs
are in compliance with the operating documents (i.e., Monthly Maintenance Log, and
BLADE 350 QX AP and DJI Inspire 1 Instruction Manual), and that the aircraft are in a
condition for safe flight.

KEITH A. REDLIN also seeks an exemption from the requirements of Section
91.121, entitled Altimeter Settings , as the BLADE 350 QX AP and DJI Inspire 1 UAs will
not have a typical barometric altimeter onboard. However, altitude information of the
BLADE 350 QX AP and DJI In spire 1UAs will be provided to the PIC via Global
Positioning System (GPS) equipment and radio communications telemetry data link, which
downlinks from the UA to the GCS for active monitoring of the flight path. This altitude
information, combined with KEI TH A. REDLIN ’s operation of the BLADE 350 QX AP
and DJI Inspire 1 UASs within visual line of sight, at or below 4 00 feet AGL, will ensure a
level of safety equivalent to Section 91.121.
Additionally, KEITH A. REDLIN seeks an exemption from the requirement s of
Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. KEITH A.

REDLIN submits that safety will not be affected by operation of the BLADE 350 QX AP
and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (V MC)
under visual flight rules (VFR), with enough battery power to fly for a total duration of8

approximately 13.5 minutes to the first point of intended 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, KEITH A. REDLIN provides the following
information in support of its petition for exemption:

A. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:

KEITH A. REDLIN 49252 Kilkenny Drive Macomb, MI 48044 Tel: ( 248 ) 881

- 2861 Email: keithredlin@yahoo.com
B. The Spec ific Sections Of 14 C.F.R. From Which KEITH A. REDLIN Seeks Exemption.

1. KEITH A. REDLIN Seeks Exemption From The Requirements Of Section 61.113(a) And (b).
Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot certificate ma y act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.
(b) A private pilot may, for compensation or hire, act as PIC of a n aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.

2. KEITH A. REDLIN Seeks Exemption From T he Requirements Of Section 91.7(a).
Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the
following:9 (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. KEITH A. REDLIN Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in
part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that airc raft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or
(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. KEITH A. REDLIN Seeks Exemption From The Requirements Of Section 91.151(b).
Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection
(b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising s peed, to fly after that for at least 20 minutes.

5. KEITH A. REDLIN Seeks Exemption From The Requirement Of Section 91.405(a).
Section 91.405, entitled Maintenance required , subsection (a), states the following:
Each owner or operator of an aircraft

—10 (a ) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. KEITH A. R EDLIN Seeks Exemption From The Requirements Of Section 91.407(a)(1)
Section 91.407, entitled Operation after maintenance, preventive maintenance,
rebuilding, or alteration , subsection (a)(1), 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 return to service by a person authorized under § 43.7 of this chapter[.]

7. KEITH A. REDLIN See ks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).
Section 91.409, entitled Inspections , subsection (a), states the following:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, w ithin the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. KEITH A. REDLIN Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).
Section 91.417, entitled Maintenance records , sub sections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records o f the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and11 each engine, propeller, rotor, and applia nce of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.
(ii) The current status of life

- limited parts of each airf rame, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retain ed and transferred with the aircraft at the time the aircraft is sold.12 (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.

C. The Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks The Relief.

1. Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks Relief From Section 61.113(a) And (b).
Relief from Section 61.113( a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a
private pilot or higher level certificate, as well as a current and valid airman medical
certificate, and who has met certain flight

- hour and currency requirements, to conduct the
proposed UAS flight operations for compensation or hire.
This relief is requested since the limitations set forth in Section 61.113(a) and (b)
state that a private pilot may, for compensati on or hire, act as PIC of an aircraft in
connection with any business or employment if: (1) The flight is only incidental to that
business or employment; and (2) The aircraft does not carry passengers or property for
compensation or hire.

As set forth mor e fully below, KEITH A. REDLIN submits that an equivalent level
of safety will be maintained because no PIC will be allowed to operate the BLADE 350
QX AP UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and
currency requirements, demon strating that the PIC is able to safely operate either the
BLADE 350 QX AP or DJI Inspire 1 UAS in a manner consistent with the operations
specifications as described in this exemption, including evasive and emergency maneuvers,
as well as maintaining appr opriate distances from people, vessels, vehicles and structures.13 Further, KEITH A. REDLIN submits that all flights of the BLADE 350 QX AP and
DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to KEITH A . REDLIN ’s business; and (2) will not carry passengers or property
for compensation or hire.

2. Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the
extent required to allow KEITH A. REDLIN to determine that the BLADE 350 QX AP
and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the
UAS is in compliance with the operating documents (i.e., the KEITH A. REDLIN Aerial
Operations Manual, Monthly Maintenance Log, and BLADE 350 QX AP and DJI Inspire 1
Instruction Manual).

KEITH A. REDLIN seeks the requested relief because the BLADE 350 QX AP
and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14
C.F.R. Part 21, Subpart H. Therefore, KEITH A. REDLIN will ensure that the BLADE
350 QX AP and DJI Inspire 1 UASs are in airworthy condition based upon its compliance
with the operating documents (i.e ., Monthly Maintenance Log, and BLADE 350 QX AP
and DJI Inspire 1 Instruction Manual) prior to every flight, and further, deter mine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Al timeter settings , may be required to allow
flight operations of the BLADE 350 QX AP and DJI Inspire 1 UASs, which utilize 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 station14

(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), KEITH A.

REDLIN seeks the requested relief because the BLADE 350 QX AP and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric
pressure or field altitude, before each flight.
Considering the limited altitude of the proposed operations, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below. As more fully set forth herein, an equivalent level of safety wi ll

be maintained since the BLADE 350 QX AP and DJI Inspire 1 UAs are 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 P IC with

altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions , is requested to the extent required to allow flights of the battery powered
BLADE 350 QX AP and DJI Inspire 1 UAs during daylight hours in visual meteorological
conditions (VMC), under visual flight rules (VFR), for a total duration of 1 3.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for

at least 4.5 minutes. KEITH A. REDLIN seeks the requested relief because without an
exemption from Section 91.151(b), the flight time duration of the battery powered BLADE
350 QX AP and DJI Inspire 1 UAs will severely constrain the practicality of any aerial
video or still photo flight operations that KEITH A. REDLIN proposes to conduct pursuant

to this Petition.15 Significantly, as set forth below, the technical specifications of the BLADE 350
QX AP and DJI Inspire 1 UASs, the BLADE 350 QX AP and DJI Inspire 1 operating
documents, and KEITH A. REDLIN ’s proposed operating limitations, ensure that KEITH

A. REDLIN will safely operate the battery powered BLADE 350 QX AP and DJI Inspire 1
UAs during daylight hours in visual meteorological conditions (VMC), under visual flight
rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the
first point of intended landing and, assum ing normal cruising speed, to fly after that for at

least 4.5 minutes.

5. Extent Of Relief KEITH A. REDLIN Seeks And The Reason KEITH A. REDLIN Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
only apply to aircraft with an airworthiness certificate, KEITH A. REDLIN requests relief

from these Sections because the BLADE 350 QX AP and DJI Inspire 1 UASs do not
requi re airworthiness certificates. As set forth more fully below, the BLADE 350 QX AP
and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without
an airworthiness certificate. Accordingly, KEITH A. REDLIN will use trained technicians

t o perform maintenance, alterations, or preventive maintenance on the UASs using the
methods, techniques, and practices prescribed in the UAS operating documents (i.e., the

KEITH A. REDLIN Aerial Operations Manual, Monthly Maintenance Log, and BLADE
350 QX AP and DJI Inspire 1 Instruction Manual). Furthermore, KEITH A. REDLIN will

document and maintain all maintenance records for the BLADE 350 QX AP and DJI
Inspire 1 UASs.
D. The Reasons Why Granting KEITH A. REDLIN ’s Request Would Be In The Public Interest ; That Is, How It Would Benefit The Public As A Whole.16 Granting the present Petition will further the public interest by allowing KEITH A.

REDLIN to safely, efficiently, and economically perform aerial video and photography of
construction sites, real e state, special events, film sets, and landscape over certain areas of

the United States.
Additionally, use of the BLADE 350 QX AP and DJI Inspire 1 UASs will decrease
congestion of the NAS, reduce pollution, and provide significant benefits to the economy.
Notably, the benefits of KEITH A. REDLIN ’s proposed operation of the BLADE 350 QX

AP and DJI Inspire 1 UASs will be realized without implicating any privacy issues.
1. The Public Will Benefit From Decreased Congestion Of The NAS.

The BLADE 350 QX AP and DJI Inspire 1 UAs are battery powered and serve as a
safe, efficient, and economical alternative to the manned aircraft traditionally utilized to
obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial
acquisitions, an exemption allowing the use of a BLADE 350 QX AP or DJI Inspire 1
UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air
pollution, as well as increase the safety of life and property in the air and on the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The
BLADE 350 QX AP and DJI Inspire 1 UAs do not require an airport to takeoff or land.
Likewise, a reduction of manned aircraft conducting aerial video and photography
missions would result in fewer aircraft that must be handled by air traffic control during
the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Bene fit From The Safety And Efficiency Of The BLADE 350 QX AP and DJI Inspire 1 UASs.17 Conducting aerial acquisitions with the BLADE 350 QX AP and DJI Inspire 1
UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the

leve ls of air and noise pollution generated during traditional aerial video and still
photography flight operations. By using battery power and electric motors, the BLADE
350 QX AP and DJI Inspire 1 UASs produce no air pollution, and is the most viable

environ mentally 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 of leaded aviation fuel. The BLADE 350 QX A P and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also
eliminates noise pollution, as the UAs are propelled by battery powered electric motors,
rather than an internal combustion engine.
By using the BLADE 350 QX AP and DJI Inspire 1 UASs to perform aerial
acquisitions, the substantial risk to life and property in the air and on the ground, which is
usually associated with traditional manned aircraft flight operations, will be substantially
reduced or completely eliminate d. Aside from the lack of flight crew members located
onboard the aircraft, the BLADE 350 QX AP and DJI Inspire 1 UAs ( BLADE QX AP
weighing approximately 33.7 ounces and the DJI Inspire 1 weighing approximately 6 pound s respectively, at their maximum gross weights with BLADES 350 QX AP lengths

of 18.3 inches and DGI Inspire 1 17.2 inches respectively, BLADE 350 QX AP widths of

18.3 inches and DJI Inspire 1 17.8 inches respectively, and with no fuel on board), has less

p hysical potential for collateral damage to life and property on the ground, and in the air,
compared to the manned aircraft that typically conduct similar operations (weighing18

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet,
and a fuel capacity of 180 gallons).
3. Performing Aerial Video and Photography Operations With The BLADE 350 QX AP and DJI Inspire 1 UASs Will Benefit The Economy. In addition to being safe and efficient, the BLADE 350 QX AP and DJI Inspire 1
UASs are also an economical alternative to using manned aircraft to conduct similar aerial
operations. As such, operation of the BLADE 350 QX AP and DJI Inspire 1 UASs will
allow United States based companies, like KEITH A. REDLIN , to remain competitive a nd
contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded
aviation fuels, U.S. owned and operated companies must adopt new and alte rnative
technology in order to remain competitive. Operating the battery powered BLADE 350 QX

AP and DJI Inspire 1 UASs 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 of a traditional manned aircraft.
By operating the BLADE 350 QX AP and DJI Inspire 1 UASs, companies such as

KEITH A. REDLIN , can remain competitive and profitable, and therefore, provide greater
job stability to employees and contractors, which will ultimately contribute to growth of
the U.S. economy. Improved financial perf ormance of U.S. companies, through

commercial use of the BLADE 350 QX AP and DJI Inspire 1 UASs, provides a stable
workforce that increases consumer spending; improves local, state, and federal tax
revenues; and allows companies to invest in research and d evelopment in order to remain
competitive both in the United States and abroad.
4. There Are No Privacy Issues.19

Similar to the manned aerial acquisition flight operations that have been conducted for
decades, KEITH A. REDLIN ’s proposed operation of the B LADE 350 QX AP and DJI
Inspire 1 UASs will not implicate any privacy issues. Specifically, the BLADE 350 QX

AP and DJI Inspire 1 UASs will be operated only in compliance with operating documents
(i.e., the KEITH A. REDLIN Aerial Operations Manual, Monthly Maintenance Log, and
BLADE 350 QX AP and DJI Inspire 1 Instruction Manual) which requires property owner
involvement as well as local law enforcement notification, and in accordance with the
Federal Aviation Regulations, including the minimum altitude requ irements of 14 C.F.R. §

91.119.
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which KEITH A. REDLIN Seeks Exemption.
1. Reasons Why The BLADE 350 QX AP and DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated
with the unmanned aircraft and its operation, KEITH A. REDLIN ’s operation of the
BLADE 350 QX AP and DJI Inspire 1 UASs meet the conditions of FMRA Section 333,

and will not require 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 of the NAS or the public, or otherwise pose a threat to national security.
Speci fically, FMRA Section 333 states the following, in part:
(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certa in unmanned aircraft systems may20 operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.
(b) Assessment of Unmanned Aircraft Syste ms.
-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populate d areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthines s certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that cert ain unmanned aircraft 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, KEITH A. REDLIN submi ts that the BLADE 350 QX

AP and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333,
as demonstrated by: (a) the characteristics of the BLADE 350 QX AP and DJI Inspire 1
UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The BLADE 350 QX AP and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.
The BLADE 350 QX AP and DJI Inspire 1 U ASs do not create a hazard to users of
the NAS or the public, or otherwise pose a threat to national security considering its size,
weight, speed, and operational capability.

i. Technical Specifications Of The BLADE 350 QX AP and DJI Inspire 1 UASs.21 The technical specifications of the BLADE 350 QX AP and DJI Inspire 1 UASs are
set forth by the BLADE 350 QX AP and DJI Inspire 1 Specifications and Data Sheet,

attached hereto as Exhibit A and B.

ii. The BLADE 350 QX AP and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.
The BLADE 350 QX AP and DJI Inspire 1 UASs may be operated in both manual
and fully autonomous flight modes . A complete description of the flight and navigational

modes of the BLADE 350 QX AP and DJI Inspire 1 UASs is provided at page 8 of the
BLADE 350 QX AP and pages 12

- 16 and 45

- 50 of the DJI Inspire 1 User Manuals,

attached hereto as Exhibit C and D.

iii. The BLADE 350 QX AP and DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.
When the Control Link is lost, the BLADE 350 QX AP and DJI Inspire 1 UAs will
remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the BLADE 350 QX

AP and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will

assume that the Control Link is lost and the UAs will return to the home position (i.e.,
failsafe mode) via GPS, and will descend to the takeoff position and shutdown.
A complete description of the Failsafe Functions of the BLADE 350 QX AP UAS
are set forth at pages 27 through 29 and f or the DJI Inspire 1 at pages 11 of the B LADE
350 QX AP and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv. The BLADE 350 QX AP and DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the BLADE 350 QX

AP and DJI Inspire 1 GCS and flight control software is provided at pages 1 through 18 of

the BLADE 350 QX AP User Manual and pages 40 through 47 of the DJI Inspire 1 User22

Manual. BLADE 350 QX AP and DJI Inspire 1 User Manuals are attached hereto as

Exhibits C and D.

b. Flight Operations Of BLADE 350 QX AP and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

KEITH A. REDLIN will only utilize certificated pilots who possess a current and
valid airman medical certificate to act as a pilot in command (PIC) of the BLADE 350 QX

AP and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during
flight time.

c. Flights Of BLADE 350 QX AP and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, KEITH A. REDLIN proposes to commercially operate
BLADE 350 QX AP and DJI Inspire 1 UASs for the special purpose of conducting aerial
video and photography over certain areas of United States, pursuant to the following
specific operating limitations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: BLADE 350 QX AP and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photog raphy. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a sp ecial request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any devi ce other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.23 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO m ay be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be des ignated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assis ting 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 of exemption must be accessible during UAS ope rations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations containe d in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to t rack such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines t hat 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 of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding upd ates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is pro hibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly d ocumented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who cond ucts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the o perating documents.24 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraf t records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.
16. T he authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and 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 emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of tr aining the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for f light 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 not be conducted during night, as defined in 14 C.F.R. § 1.1. Al l operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not a uthorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted i n accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.25 21. The UA may not be operated less than 500 feet below or less than 2,000 feet hor izontally 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 pre

determined location within the planned operating area and land or be recovered in ac cordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and for ecast 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 of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All op erations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, 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. part 47, and have identification (N

- Number) 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 of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement officia l upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be conducte d at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:26 a. Barriers or structures are present that sufficiently protect nonparticipating per sons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, f light operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the ris k of operating closer to those objects and determined 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 op erations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be co nducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be r eported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

KEITH A. REDLIN submits that the equivalent level of safety established by
Section 61.113(a) and (b) will be maintained because no PIC will be allowed to ope rate the
BLADE 350 QX AP and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting
minimum flight

- hour and currency requirements, that the PIC is able to safely operate the
BLADE 350 QX AP or DJI Inspire 1 UAS in a manner consistent with the exem ption,
including evasive and emergency maneuvers and maintaining appropriate distances from
people, vessels, vehicles and structures.
Considering KEITH A. REDLIN ’s proposed area of operations, and the operating

limitations set forth

- above; the parallel na ture of private pilot aeronautical knowledge27

requirements to those of commercial pilot requirements ( See Exemption No. 11062); and
the airmanship skills necessary to safely operate the BLADE 350 QX AP or DJI Inspire 1
UAS, KEITH A. REDLIN submits that the additional manned airmanship experience of a
commercially certificated pilot would not correlate to the airmanship skills necessary for

KEITH A. REDLIN ’s specific proposed flight operations.
The FAA has previously granted relief from Section 61.113(a) and (b) 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, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

KEITH A. REDLIN will not allow any PIC to operate the BLADE 350 QX AP or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour
requirements or the BLADE 350 QX AP or DJI Inspire 1 UAS training and currency
requirements, that the PIC is able to safely operate the BLADE 350 QX AP or DJI Inspire

1 UAS in a manner consistent with this exemption, including evasive and emergency
maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. Specifically, the PIC must have accumulated and logged, in a manner consistent
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operatin g the same make and model of
UAS to be used for operations under the exemption). In addition to the hour requirements,
the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
purposes).28 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight
experience that was obtained in compliance with applicable regulations will ensure an
equivalent level of safety during KEITH A. REDLIN ’s proposed operations. The
Administrator has held that prior documented flight experienc e that was obtained in
compliance with applicable regulations would ensure safe operations, stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062 , the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeo ffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petition er’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted un der the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at p age 15.
Accordingly, KEITH A. REDLIN will ensure safe operations by not allowing any
PIC to operate the BLADE 350 QX AP or DJI Inspire 1 UAS unless that PIC has
demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is

able t o safely operate the BLADE 350 QX AP or DJI Inspire 1 UAS in a manner consistent
with the exemption, including evasive and emergency maneuvers and maintaining
appropriate distances from people, vessels, vehicles and structures.29 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained
because prior to every flight, KEITH A. REDLIN will ensure that the BLADE 350 QX AP

or DJI Inspi re 1 UAS is in an airworthy condition based upon the UAS’s compliance with
its operating documents and as stated in the conditions and limitations herein.
Additionally, the FAA has previously granted relief from Section 91.7(a) specific
to UAS, in circums tances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,
11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exempti on From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the BLADE 350 QX AP and DJI Inspire 1 UAs 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 of the flight path and
altitude. This altitude information, combined with KEITH A. REDLIN ’s opera tion of the
BLADE 350 QX AP and DJI Inspire 1 UAs within visual line of sight, at or below 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 by the UASs at ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those prese nted herein (e.g. Exemption
Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).30 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adverse ly Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by
14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the BLADE
350 QX AP and DJI Inspire 1 UASs; (2) the limitations on the pr oposed flight operations;
and (3) the location of the proposed flight operations. Accordingly, KEITH A. REDLIN will ensure that it will safely operate the battery powered BLADE 350 QX AP and DJI
Inspire 1 UAs during daylight hours in VFR conditions, with e nough battery power to fly
for a total duration of 13.5 minutes to the first point of intended landing and, assuming
normal cruising speed, to fly after that for at least 4.5 minutes.
Here, as in Exemption No. 11109, the technical specifications of the BL ADE 350
QX AP and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the
location of the proposed operations, will ensure an equivalent level of safety established by
14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the BLADE 350 QX

AP and DJI Inspire 1 UASs provide 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% r emaining
battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will descend and land automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151
establish that safety is not a dversely affected when the technical characteristics and
operating limitations of the UAS are considered. Relief has been granted for manned
aircraft to operate at less than the minimums prescribed in Section 91.151, including
Exemption Nos. 2689, 5745, an d 10650. Moreover, the FAA has previously granted relief31

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to
those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,
11064, 11065, 11066, 1 1067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,
11157, 11158, 11159, 11160, 11161).
6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, KEITH A. REDLIN submits that the equivalent level of
safety with regard to the regulatory maintenance and alteration requirements established by
Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b) will be met

because KEITH A. REDLIN will use trained technicians to perform maintenance,
alterations, or preventive maintenance on the UASs using the methods, techniques, and
practices prescribed in the operating documents (i.e., the KEITH A. REDLIN Aerial
Operations Manual, Monthly Maintenance Log, and BLADE 350 QX AP and DJI Inspire 1
Instruction Manual). Furthermore, KEITH A. REDLIN will document and maintain all

maintenance records for the BLADE 350 QX AP and DJI Inspire 1 UASs.

Since the BLADE 350 QX AP and DJI Inspire 1 UASs will be inspected as
prescribed by the operating documents, KEITH A. REDLIN will maintain the equivalent
level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy

of the BLADE 350 QX AP and D JI Inspire 1 User Manuals are attached hereto as Exhibit
C and D; a copy of the BLADE 350 QX AP and DJI Inspire 1 UAS Maintenance LOG is

attached hereto as Exhibit E.
Likewise, the exemption sought will not adversely affect safety because KEITH A.

REDLIN will use trained technicians to perform maintenance, alterations or preventive32

maintenance on the UAS using the methods, techniques, and practices prescribed by the
operating documents.
Furthermore, the exemption sought would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
BLADE 350 QX AP and DJI Inspire 1 UASs will be performed by trained technicians.
Maintenance will be documented and maintained utilizing the monthly maintenan ce log.
Significantly, previous exemptions granted by the FAA concerning Sections
91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is
not adversely affected when the technical characteristics and operating limitati ons of the

UAS are considered.

In consideration of KEITH A. REDLIN ’s proposed operating limitations, the
operating documents, and the technical aspects of the BLADE 350 QX AP and DJI Inspire
1 UASs, KEITH A. REDLIN submits that safety will not be adversel y affected by granting
exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and
91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances
similar, in all material respects, to those presented h erein (e.g. Exemption Nos. 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 Other Conditions For Safe Operation.

In accordance with S ection 333 of the FAA Modernization and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , KEITH A. REDLIN requests that the FAA prescribe special conditions for the intended operation of the BLADE 350
QX AP and DJI Inspire 1 UASs , which contain such safety standards that the33

Administrator finds necessary to establish a level of safety equivalent to that established by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,
91.151(b), 91.405(a), 91.407(a)(1 ), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such
special conditions will permit safe operation of the UAs for the limited purpose of
conducting aerial video and photography over certain areas of the United States for
compensation or hire. FMRA Section 3 33 sets forth the requirements for considering
whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a
threat to national security; and further, provides the authority for such UAS to operate

without airworthiness certific ation in accordance with any requirements that must be
established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16, for operation of the BLADE 350 QX AP and DJI Inspi re 1 UASs, 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 of the aircraft. Section 21.16,

entitled Special Conditions , states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or prop eller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds n ecessary to establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16.
Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the BLADE
350 QX AP and DJI Inspire 1 UASs, which contain such safety standards that the34

Administrator f

inds necessary to establish a level of safety 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which KEITH A. REDLIN Seeks Exemption:

KEITH A. REDLIN seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.4 07(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
A Brief Description Of The Nature Of The Exemption KEITH A. REDLIN Seeks:
This exemption will permit KEITH A. REDLIN to commercially operate an Unmanned Aircraft System (UAS) for the purpose of cond ucting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support KEITH A. REDLIN ’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012
(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain
UAS may operate safely in the NAS. As such, KEITH A. REDLIN ’s request for
exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R.
Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will
create a hazard to users of the NAS or the pub lic, or otherwise pose a threat to national
security; and further, provides the authority for such UAS to operate without airworthiness

certification.
As discussed in detail above, KEITH A. REDLIN will operate the BLADE 350 QX

AP and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the
NAS, or the public, or otherwise pose a threat to national security.35 CONCLUSION
As set forth herein, KEITH A. REDLIN seeks an exemption pursuant to 14 C.F.R.
§ 11.61 and S ection 333 of the FAA Modernization and Reform Act of 2012 (FMRA),
which will permit safe operation of the BLADE 350 QX AP and DJI Inspire 1 UASs
commercially, without an airworthiness certificate, for the limited purpose of conducting
aerial video and pho tography over certain areas of the United States. By granting this
Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA
Modernization and Reform Act of 2012, while also advancing the interests of the public,
by allowing K EITH A. REDLIN to safely, efficiently, and economically operate the
BLADE 350 QX AP and DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA
Modernization and Reform Act of 2012, Sectio n 333, KEITH A. REDLIN respectfully
requests that the Administrator grant this Petition for an exemption from the requirements
of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the
BLADE 350 QX AP and DJI Inspire 1 UASs commercially for the purpose of conducting
aerial video and photography over certain areas of the United States.

Date d: April 11, 2015

Respectfully submitted,

KEITH A. REDLIN

_________________________36 KEITH A. REDLIN 49252 Kilkenny Macomb, MI 4804 Tel: ( 248 ) 881

- 2861

Appendic es :

A

– BLADE 350 QX AP Specifications Data Sheet B

– DJI Inspire 1 Specifications Data Sheet C

– BLADE 350 QX AP Manufacturer’s User Manual D

– DJI Inspire 1 Manufacturer’s User Manual E

– Monthly Maintenance Log37 APPENDIX

– A
BLADE 350 QX AP TECHNICAL SPECIFICATIONS

KEITH A. REDLIN only util izes safe and reliable UASs. BLADE is an industry lea der in small UAS production. BLADE UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined an d set distance. In addition, BLADE software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 BLADE 350 QX AP

1.1.1 Aircraft 1.1.1.1 Supported Battery

– 3000mAh 3S 11.1V 20C Li

- Po Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 35.5 oz (1006 g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 2 00 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current

– GB200 2

- Axis Brushless Gimbal 1.1.2.2 Control Accuracy

- ±0.03 0 1 .1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensi tivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V38 APPENDIX

– B39 DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

KEITH A. REDLIN only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)
2.2 DJI Inspire 1

2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance

– 10m/s 2.2.1.11 Max Flight Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.030 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3 200 2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size

– 4000x300040 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 940 2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3 .10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S41 APPENDIX

– C
BLADE 350 QX AP Manufacturer’s User Manual42 APPENDIX

– D DJI Inspire 1 Manufacturer’s User Manual43 APPENDIX

– E