February 4 , 2016

U.S Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23( b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 91.119;

14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a)&(b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1) ; 14 C.F.R. 91.409(a) (2); 14 C.F.R. 91.417(a)&(b)

Dear Sir or Madam:

Request:

Pu rsuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FRMA”) and the procedures contained within 14 C.F.R. 11, I, James Mil lard, an owner and operator of a s mall unmanned aircraft system ( UAS), requests to be exempted from the following Section 333

regu l ations:

 14 C.F.R. 45.23(b)

 14 C.F.R. Part 21

 14 C.F.R. 61.113(a)& (b)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9(b)(2)

 14 C.F.R. 91.103

 14 C.F.R. 91.109

 14 C. F.R. 91. 119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a)& (b)

 14 C.F.R. 91.405(a)

 14 C.F.R. 91.407(a)(1)

 14 C.F.R. 91.409(a)(1) and (2)

 14 C.F.R. 91.417(a)& (b)

Following exemption and approval by the FAA

, I may safely operate the Yuneec Blade Chroma

UA S commercially along the guidelines of the accompanying operator’s manual as well as FAA guidelines for UAS flight and safety guidelines set by the Academy of Model Aeronautics (AMA).

Proposed UAS and Operations

The Yuneec Blade Chroma weighs less than t hree pounds, w ill always be flown under 400 feet limited via software by it s GPS and barometric sensors, i s electronically powered by a lithium polymer battery, carries no combustible fuel or crew and (in accordance with FAA guidelines) will be transported in proper storage to and from all flight areas.The aforementioned proposed exemptions would allow me to operate the Yuneec Blade Chroma

UAS for commercial purposes of aerial videography and photography as a service to public and

business interests in cluding: photography and videography, real estate, wedding and private photography

.

The proposed UAS has been proven a reliable and safe flying machine managed by gyroscopically

stabilized flight, ground detection, GPS

- aided navigation, a built

- in compass , blinking LED lights, a manual and automatic failsafe “Return to Home” mode for returning to the point of takeoff, propeller guards in order to protect both the UAS and the environment. This UAS combines state

of

- the

- art, proven technology with high qua lity manufacturing and user

- friendly control to ensure safe operation and easy maintenance and care.

Specific section(s) of 14 CFR wh ich I seek relief and the reason(s) I seek relief:

14 C.F.R Part 21 , Subpart H : Airworthiness Certificates

14 C.F.R. § 9 1.203 (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 the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part II 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 for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particulate UAS. In all cases, an analy sis 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 (fixed wing or rotorcraft) opera ting with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 3 lbs. carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates excl usively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements, to provide securit y for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements 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 UAS due to its size, speed of operation, location of

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

external load.

14 C.F.R. § 45.23 (b) : Marking of the Aircraft

Because the Yuneec Blade Chroma does not have a cabin, cockpit, pilot station, fuselage, boom, o r tail on which to mark large words, numbers, or phrases, I request exemption from the above regulation. In an effort to comply with the above regulation and those set by the Academy of Model Aeronautics (AMA), I will affix a small label to the external h ull of the UAS indicating my name, address and my AMA Member Number.14 C.F.R. § 61. 113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in C ommand

Sections 61.113 ( a) and (b) limit private pilots to non

- commercial operations. However, I am able to achieve an equivalent level of safety through current FAA regulations of UAS operation and AMA safety guidelines (outlined in the summary of this document) without such a certification because of the above mentioned safety features of the Yuneec Blade Chroma. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated

in adva nce. Therefore, bearing any pilot certification or license will not ensure remote piloting skills of a UAS; the risks of operating this UAS are far less than the risk levels inherent in commercial activities with traditional aircraft given the Yuneec Blade Chroma’s safety features and the limited range and speed of the UAS.

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness

Currently there is no certificate applicable to this UAS, and therefore it will be up to myself, James Millard, to determine the airw orthiness of the Yuneec Blade Chroma in accordance with its official operating manual. Written and signed pre and post

- flight inspections of the propellers, motors, frame, landing stands, camera and gimbal unit, connected tablet devices, a compass calibra tion and properly ensured GPS locks as indicated by the Yuneec Blade Chroma’s display of “Safe to Fly” message will be performed before and after each flight, accurate records of which will be kept with the UAS’s storage and transportation system at all ti mes. These records will be date and will include the total flight time of each flight.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a 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 of Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where I

will have immedi ate 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 C.F.R. § 91.103: Preflight action

This regulation requires each pilo t in command to take certain actions before flight to ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flig ht battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. § 91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon)

t hat 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 contro l box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fullyfunctional dual controls for a number of aircraft and for flight instruction in experimental aircraft.

See Exemption Nos . 5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes

I, James Millard, will en sure that the UAS does not operate any higher than 400 feet at ground level by setting the maximum altitude at 400 feet in the Yuneec Blade Chroma’s pilot application and ensuring this is set before each flight as part of the pre

- flight inspection. I will not fly over congested areas or directly above unprotected people or moving vehicles. I will plan operations before hand for proper flight safety and proper height analysis as to avoid collisions. The GPS and barometric sensors equipped on the Yuneec Bl ade Chroma will ensure accurate altitude readings, the output of which will be fed to my built in screen on the transmitter in real time as I operate the

UAS.

14 C.F.R. § 91.121: Altimeter settings

The Yuneec Blade Chroma utilizes the latest GPS/GLONASS technologies as well as a barometric sensor with live data output to the built in screen on the transmitter. An equivalent level of safety and accurate altimeter telemetry will be achieved by using this.

14 C.F.R § 91.151 (a) : Fuel Requirements for flig ht in VFR conditions

The Yuneec Blade Chroma is electrically

- powered by lithium polymer batteries which are made by Yuneec specifically for this particular UAS. They are rated as providing no longer than 30 minutes of flight time. Therefore, due to the l imitations of the batter ies, it is currently impossible to comply

with §91.151.

14 C.F.R. § 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 (a) of this section or a spe cial flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS is no more than 3 lbs. and is operated without an onboard pilot. As such, there is no ability or place to ca rry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where I will have immediate access to them, to the extent they are applicable to the UAS. The FAA has issued numberous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a): Maintenance Required, 14 C.F.R. § 91.407(a)(1): Operation after maintenance, prevent ative maintenance, rebuilding, or alteration, 14 C.F.R. § 91.409 (a)(1) and (2): Inspections & 14 C.F.R. § 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they apply to the aircraft with an airworthiness certificate. However, I, James Millard, will perform both preflight and post

- flight inspections of the UAS before and after each flight as outlined in the operating documents. I, James

Millar d, will also follow manufacturer recommendations from said operating documents and keep a written record of any maintenance done to the UAS.Public Interest and Public Safety:

Ae rial photography and videography provided to the public allows for a more cos t

- effective, safe, and environmentally

- friendly method to capturing imagery than its alternative: manned aircraft and helicopters. The latter are expensive to operate and maintain, create a high level of noise, and are

much more hazardous due to size and combustible fuel

– especially if flown at low altitudes required for some operations.

Given that there is no fuel and no crew on this UAS, that it weighs less than three pounds and has propeller guards, as well as having a low maximum speed (less than 2 5mph), safe operation of this craft does not pose any immediate danger to the environment, wildlife, infrastructure or people. The Yuneec Blade Chroma has built in a “No Fly Zone” for major cities and points of interest that have registered as a “do not f ly zone”. Operation of the Blade Chroma cannot happen in these locations, as any flight capabilities becomes blocked by the UAS itself if within range and the operator is notified. Given its GPS and ground

- sensing capabilities, a failsafe “Return To Home ” mode will safely return the craft to the operator at the push of a single button or automatically when the craft is either low on power or operating outside of its transmitter’s range. This ensures that the

craft will not remain airborne in unsafe condi tions and pose any public dange r

.

Summary

I, James Millard, am seeking exemption from the following rules: 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 91.103(b); 14
C.F.R. 91.109; 1 4 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a)&(b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (2); 14 C.F.R. 91.417(a)&(b). With the exemptions of the mentioned rules I, James Millard, will be seeking to make my UAS photography/videography services available to public an d commercial interests. Public and commercial interests had previously sought the use of manned aircraft to achieve what I can offer in a safe, more cost

- efficient and environmentally

- fri endly manner by not using combustible fuel, flying at safe heights and strictly following the usage recommendations from Yuneec and safety procedures by the Academy of Model Aeronautics. These include, but are not limited to:

 Flying the Yuneec Blade Chro ma safely in accordance with its operator’s manual.

 Maintaining active and full membership in the Academy of Model Aeronautics (AMA), which provides a high level of insurance and training programs to its members.

 Always flying below 400 feet, using the Yun eec Blade Chroma’s altitude limiter to ensure

this.

 Completing thorough inspection of UAS before and after flights and keeping inspection

records with the craft at all times.

 Keeping the UAS in visual sight at all times when in operation.

 Using an observer to assist if needed.

 Remaining safely clear of and do not interfere with manned aircraft operations.

 Not flying directly over unprotected persons or moving vehicles.

 Not flying within 5 miles of an airport or control tower.

 Not flying in adverse weather c onditions such as high winds, rain, or impaired visibility.

 Not flying under the influence of alcohol or drugs.

 Ensuring the operating environment is safe.

 Not flying over sensitive infrastructure or property such as power stations, water treatment

facilit ies, correctional facilities, etc.

 Checking and following all local laws and ordinances before flying over private property.

 Not conducting surveillance or photographing persons in areas where there is an expectation

of privacy without the individual’s per mission.In addition to these above general standards, I, James Millard, will follow and abide by the

following AMA safety guidelines:

A. [DEFINITION]: A “model aircraft” is a non

- human

- carrying aircraft capable of sustained flight in the atmosphere. [This includes UAS such as the Yuneec Blade Chroma].

1. Model aircraft will not be flown: (a) In a careless or reckless manner. (b) At a location where model aircraft activities are prohibited.

2. Model aircraft pilots will: (a) Yield the right of way to all human

- carrying air craft. (b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA

Document #540

- D.) (c) Not fly higher than approximately 400 feet above ground level or within five miles of an airport. (d) Not interfere with operations and traffic patterns at an y airport, heliport or seaplane

base. (e) Not exceed a takeoff weight, including fuel, of 55 pounds. (AMA Document #520

- A) (f) Ensure the aircraft is identified with the name and address or AMA number of the

owner on the inside or affixed to the outside of the mod el aircraft. (g) Not operate aircraft with metal

- blade propellers or with gaseous boosts (AMA Document #555) (h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot’s ability to safely contr ol the model. (i) Not operate model aircraft carry pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a hazard to persons

or property. (j) Not operate a turbine

- powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510

- A)

3. M odel aircraft will not be flown in AMA sanctioned events, air shows or model

demonstrations unless: (a) The aircraft, control system and pilot skills have successfully demonstrated all

maneuvers intend ed or anticipated prior to the specific event. (b) An inexperienced pilot is assisted by an experienced pilot.

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL, or NOCSAE approved or comply with comparable standards.

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others.

2. A successful radio equipment ground

- range check in acc ordance with manufacturer’s recommendations will be completed before the first flight of a new or repaired model

aircraft.3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Doc ument #706) (a) Only personne l associated with flying the model aircraft are allowed at or in front of the safety line. (b) At air shows or demonstrations, a straight safety line must be established. (c) An area away from the safety line must be maintained for spectators. (d) Intentional flying b ehind the safety line is prohibited.

4. RC model aircraft must use the radio

- control frequencies currently allowed by the Federal Communications Commission (FCC).

5. RC model aircraft will not knowingly operate within three (3) miles of any pre

- existing flying site without a frequency

- management agreement. (AMA Documents #922 and #923).

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors closer than 25 feet to any individual, except for the pilot and the pilot’s helper(s) located at the flight

line.

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an individ ual.

8. The pilot of an RC model aircraft shall: (a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. (b) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560.

C. FREE FLIGHT

1. Must be at least 100 feet downward of spectators and automobile parking when the

model aircraft is launched.

2. Launch area must be clear of all individuals except mechanic s, officials, and other fliers.

3. An effective device will be used to extinguish any [fire] on the model aircraft.

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above

- ground el ectric utility lines.

5. The flying area must be clear of all nonessential participants and spectators before the engine is started.

Thank you for your time and effort in processing this request. For more information or questions about this document, pleas e contact:

James Millard 6527 Crabapple Troy, MI 48098 impactfundraising@gmail.com

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