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:

Pursuant 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 Millard, an owner and operator of a small 

unmanned aircraft system (UAS), requests to be exempted from the following Section 333 

regulations:

 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 

UAS 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 three pounds, will always be flown under 400 feet 

limited via software by its GPS and barometric sensors, is 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 including: photography and videography, real estate, wedding and private 

photography.

The proposed UAS has been proven a reliable and safe flying machine managed by gyroscopicallystabilized 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 stateof-the-art, proven technology with high quality manufacturing and user-friendly control to ensure 

safe operation and easy maintenance and care.

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

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

14 C.F.R. § 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 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 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 (fixed wing or rotorcraft) operating 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 exclusively 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 security 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 

operation, 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, or 

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 hull 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 Command

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 advance. 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 airworthiness 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 calibration 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 times. 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 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 C.F.R. § 91.103: Preflight action

This regulation requires each pilot 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, flight 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) 

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 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 ensure 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 Blade 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 flight 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 limitations of the batteries, 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 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 UAS is no more than 3 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 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, preventative 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 

Millard, 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:

Aerial photography and videography provided to the public allows for a more cost-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 25mph), 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 fly 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 conditions and pose any public danger.

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; 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).

With the exemptions of the mentioned rules I, James Millard, will be seeking to make my UAS 

photography/videography services available to public and 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-friendly 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 Chroma 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 Yuneec 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 conditions 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 

facilities, 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 permission.
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 aircraft.

(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 any 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 model 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 control 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. Model 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 intended 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 accordance 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 Document #706)

(a) Only personnel 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 behind 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 individual.

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 mechanics, 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 electric 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, please contact:

James Millard

6527 Crabapple

Troy, MI 48098

impactfundraising@gmail.com

810-923-8583