SUBMISSION: PART 1

UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

MICHAEL SMITH

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) CONCERNING 

COMMERCIAL OPERATION OF THE CHROMA “BLADE” CAMERA DRONE

UNMANNED AIRCRAFT SYSTEM (UAS) PURSUANT TO SECTION 333 OF THE FAA

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted: November 30, 2015 

MICHAEL SMITH

SMITH INSPECTION SERVICES, LLC

P.O. BOX 126

504 WEST CAMPBELL AVE.

SHERRILL, NEW YORK 13461

OFFICE 315-363-8074

CELL 315-264-1518 (BEST #)

FAX 315-363-9046
TABLE OF CONTENTS 

Page 

GLOSSARY OF

ABBREVIATIONS.................................................................................................................3 

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

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

BACKGROUND.....................................................................................................................5 

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

NAME AND ADDRESS OF PETITIONER................................................................6 

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

MICHAEL SMITH SEEKS EXEMPTION............................................................7 

THE EXTENT OF RELIEF MICHAEL SMITH SEEKS AND 

THE REASON MICHAEL SMITH SEEKS THE RELIEF...............................9

THE REASONS WHY GRANTING MICHAEL SMITH’S REQUEST

WOULD BE IN THE PUBLIC INTEREST .............................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................13 

CONCLUSION.......................................................................................................................19 

APPENDICES A - F 
GLOSSARY OF ABBREVIATIONS

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 Federal 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) 

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 Landing 

DJI UAV manufacturer

ESC Electronic speed control
FPV First Person View 

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle 

SUMMARY

Michael Smith, operating under the company title, Smith Inspection Services, LLC, 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 Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Michael Smith to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography for Marketing, 

Real Estate Photography, Roofing Inspection, and Property and Landscape Imaging over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Michael Smith. I have been a New York State licensed Home Inspector for 

10 years. I am the Owner / Home Inspector for Smith Inspection Services. LLC. Currently, I 

provide home inspections and various other inspection and testing services for the real estate and 

construction industries. I have 1.5 years experience operating quad-copter UAS’s. Michael Smith 

provides customers with detailed inspections and quality ground based video and photography

for a wide range of applications. However, given today’s technology and competition, Michael 

Smith needs to expand the services of Smith Inspection Services, LLC to include aerial imaging. 

Michael Smith currently is considered to be an experienced and competent UAS pilot (PIC).

In addition to the above, the NYS Home Inspection Standards of Practice states: Title 19 

NYCRR Section 197-5.7 Roof Systems; Sub-Section (g) “Home inspectors are not required to 

walk on or access a roof where to do so could result in damage to the roof or roofing material or 

endanger the health and safety of the home inspector.” 

Therefore, in the future, a roof that would have been reported on from a ground level 

based view, either with or without binoculars, this exemption now will provide my client a much 

more comprehensive and accurate evaluation of the roof structure, membrane, penetrations and 

flashing details, not to mention adding a greater level of safety for myself. 

The objective of Smith Inspection Services, LLC is to provide low cost, high quality 

aerial imaging for various industries while promoting safe UAS operations and promoting public 

knowledge of UAS’s as well as providing a high level of knowledge about UAS’s.
BACKGROUND 

Unmanned Aircraft Systems: Chroma “Blade” Camera Drone

Michael Smith seeks an exemption to operate the Chroma Drone system for compensation or 

hire within the NAS. The Chroma “Blade” Camera Drone is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing a ST-10+ 

controller.

CHROMA BLADE SPECS

Approx. Flying Time 30 minutes

Battery 11.1V 3S 6300mAh Li-Po

Motor to Motor Distance 15.75 in (400 mm)

Height 9.50 in (242 mm)

Weight 2.9 lbs (45.9 oz) (1.3 kg)

Motors 780 Kv Brushless Outrunner

Prop Diameter 10.25 in (260 mm)

Flight Control Link 2.4 GHz

Video Link 5.8 GHz

Approx. Video Link Range 1,970 ft (600 m)

GPS Receiver GLONASS and U.S.

Completion Level Ready-To-Fly

Recommended Environment Outdoors

The Chroma “Blade” Camera Drone has a maximum gross weight of approximately 2 pounds 14 

ounces, while having a length of 15.75 inches and width of 15.75 inches (without blades), height 

of 9.5 inches, and a maximum speed of approximately 30 knots. The Chroma “Blade” Camera 
Drone UAS is equipped with four main rotors; driven by a Lithium Polymer battery powering 4 

electric motors. 

The Chroma “Blade“ Camera Drone UAS that will be operated by Michael Smith and 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, Identification and 

Registration Markings. 

BASIS FOR PETITION 

Petitioner, Michael Smith, 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 Chroma “Blade” Camera Drone UAS 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). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Michael Smith’s operation of Chroma “Blade” 

Camera Drone UAS 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, Michael Smith 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. 

Michael Smith submits that the requested relief is proper since an equivalent level of safety will 

be ensured. Michael Smith will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 

Chroma “Blade” Camera Drone O & M Manual). Furthermore, Michael Smith will document 

and maintain all maintenance records for the Chroma “Blade” Camera Drone. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private Pilot - Privileges 

and Limitations: Pilot in command, is requested by Michael Smith 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 Chroma “Blade” Camera Drone 

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

Michael Smith seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Chroma “Blade” Camera Drone UAS does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Michael Smith submits that he will ensure that the 

Chroma “Blade” Camera Drone UAS is in an airworthy condition, prior to every flight, by

determining

that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log 

and Instruction Manual), and that the aircraft is in a condition for safe flight. 

Michael Smith also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the Chroma “Blade” Camera Drone UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the Chroma “Blade” Camera 

Drone UAS will be provided to the PIC via Global Positioning System (GPS) equipment and 

radio communications telemetry data link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path. This altitude information, combined with Michael Smith’s 

operation of the Chroma “Blade” Camera Drone UAS within visual line of sight (VLOS), at or 

below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Michael Smith seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Michael Smith submits that safety will 

not be affected by operation of the Chroma “Blade” Camera Drone 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 approximately 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, Michael Smith 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:

MICHAEL SMITH

SMITH INSPECTION SERVICES, LLC

P.O. BOX 126

504 WEST CAMPBELL AVE.

SHERRILL, NEW YORK 13461

OFFICE: 315-363-8074

CELL: 315-264-1518 (BEST #)

FAX: 315-363-9046

Email: sisllc08@yahoo.com
A. The Specific Sections Of 14 C.F.R. From Which Michael Smith Seeks Exemption.

1. Michael Smith 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 may 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 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. 

2. Michael Smith Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following: (a) 

No person may operate a civil aircraft unless it is in an airworthy condition.

3. Michael Smith 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 aircraft, as the case may be, by reference to an altimeter that is set, 

when operating-- 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. Michael Smith 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 speed, to fly 

after that for at least 20 minutes. 

5. Michael Smith 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— 

(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. Michael Smith 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. Michael Smith Seeks 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, within 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. Michael Smith Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

Section 91.417, entitled Maintenance Records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

1. Records of 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) and each engine, propeller, rotor, and appliance 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 airframe, 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. 

3. The owner or operator shall retain the following records for the periods 

prescribed: 

(i) 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. 

(ii) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is 

sold. 

(iii) 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. 

B. The Extent Of Relief Michael Smith Seeks And The Reason Michael Smith Seeks The 

Relief. 

1. Extent Of Relief Michael Smith Seeks And The Reason Michael Smith 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 ( PIC ), 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 compensation 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 more fully below, Michael Smith submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the Chroma “Blade” 

Camera Drone UAS unless that PIC has met certain flight-hour and currency

requirements, demonstrating that the PIC is able to safely operate the Chroma “Blade” 

Camera Drone UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Furthermore, Michael Smith submits that all flights of the Chroma “Blade” 

Camera Drone UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will 
be incidental to Michael Smith business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Michael Smith Seeks And The Reason Michael Smith 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 Michael Smith to determine that the Chroma “Blade” Camera 

Drone UAS is in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., Michael Smith’s Aerial Operations 

Manual, Monthly Maintenance Log, and Chroma “Blade” Camera Drone Instruction 

Manual, Pre-Flight Checklist). 

Michael Smith seeks the requested relief because the Chroma “Blade” Camera 

Drone UAS does not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, Michael Smith will ensure that the Chroma “Blade” 

Camera Drone UAS is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Chroma “Blade” Camera 

Drone Instruction Manual) prior to every flight, and further, determine that the aircraft is 

in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Michael Smith Seeks And The Reason Michael Smith Seeks 

Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter Settings, may be required to allow 

flight operations of the Chroma “Blade” Camera Drone UAS, which GPS equipment, and 

a radio communications telemetry data link to downlink altitude information from the UA

to the PIC at the ground control station (GCS). Since the FAA requires that any altitude 

information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), Michael Smith seeks the requested relief because the Chroma 

“Blade” Camera Drone UAS’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 will 

be maintained since the Chroma “Blade” Camera Drone UAS is equipped with GPS 

equipment, which automatically ensures that a ground level setting will be established 

prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS. 

4. Extent Of Relief Michael Smith Seeks And The Reason Michael Smith 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 

Chroma “Blade” Camera Drone UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 5 minutes. Michael Smith seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered 
Chroma “Blade” Camera Drone UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that Michael Smith proposes to conduct pursuant to 

this Petition.

Significantly, as set forth below, the technical specifications of the Chroma 

“Blade” Camera Drone UAS, the Chroma “Blade” Camera Drone UAS’s operating 

documents, and proposed operating limitations, ensure that Michael Smith will safely

operate the battery powered Chroma “Blade” Camera Drone 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 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

5. Extent Of Relief Michael Smith Seeks And The Reason Michael Smith 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, Michael Smith requests relief from 

these Sections because the Chroma “Blade” Camera Drone UAS does not require 

airworthiness certificates. As set forth more fully below, the Chroma “Blade” Camera 

Drone UAS meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Michael Smith will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

Michael Smith’s Aerial Operations Manual, Monthly Maintenance Log, Chroma “Blade” 

Camera Drone Instruction Manual, Pre-Flight Checklist). Furthermore, Michael Smith 

will document and maintain all maintenance records for the Chroma “Blade” Camera 

Drone UAS. 

C. The Reasons Why Granting Michael Smith’s Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole.

 Granting the present Petition will further the public interest by allowing Michael Smith to 

safely, efficiently, and economically perform aerial video and photography for a commercial 

purpose of conducting aerial video and photography for Marketing, Real Estate Photography,

Roofing Inspection, and Property and Landscape Imaging over certain areas of the United 

States. 

Additionally, use of the Chroma “Blade” Camera Drone UAS will decrease 

congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and 

provide significant benefits to the economy. Notably, the benefits of Michael Smith’s

proposed operation of the Chroma “Blade” Camera Drone UAS will be realized without 

implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Chroma “Blade” Camera Drone UAS is battery powered and serves 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 Chroma 

“Blade” Camera Drone 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 Chroma “Blade” Camera Drone UAS does 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 Benefit From The Safety And Efficiency Of The Chroma 

“Blade” Camera Drone UAS. 

Conducting aerial acquisitions with the Chroma “Blade” Camera Drone 

UAS, instead of manned aircraft, will greatly benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric 

motors, the Chroma “Blade” Camera Drone UAS produces no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that are typically utilized for aerial 

video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The Chroma “Blade” Camera Drone UAS, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAS is propelled by battery powered electric motors, rather than an internal 

combustion engine. 

By using the Chroma “Blade” Camera Drone UAS 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 eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the Chroma “Blade” Camera Drone 

UAS (weighing approximately 2 pounds 14 ounces at its maximum gross weight, 

with a length of 15.75

inches, and a width of 15.75 inches, and with no fuel on board), has less physical 

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 

(weighing 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 Chroma 

“Blade” Camera Drone UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Chroma “Blade” Camera Drone 

UAS is also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the Chroma “Blade” Camera Drone UAS 
will allow United States based companies, like Smith Inspection Services, LLC, to 

remain competitive and 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 alternative technology in order to remain 

competitive. Operating the battery powered Chroma “Blade” Camera Drone UAS 

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 Chroma “Blade” Camera Drone UAS, companies such as 

Smith Inspection Services, LLC, 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 

performance of U.S. companies, through commercial use of the Chroma “Blade” 

Camera Drone UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the 

United States and abroad. 

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, Michael Smith’s proposed operation of the Chroma 

“Blade” Camera Drone UAS will not implicate any privacy issues. Specifically, 

the Chroma “Blade” Camera Drone UAS will be operated only in compliance 

with operating documents (i.e., Michael Smith’s Aerial Operations Manual, 

Monthly Maintenance Log, Chroma “Blade” Camera Drone Instruction Manual, 

Pre-Flight Checklist) which requires property owner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How 

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The 

Rule From Which Michael Smith Seeks Exemption. 

1. Reasons Why The Chroma “Blade” Camera Drone UAS Meets 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, Michael Smith’s operation of the Chroma 

“Blade” Camera Drone UAS meets 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. Specifically,

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 certain unmanned aircraft systems may 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 Systems.--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 populated 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 whether a 

certificate of waiver, certificate of authorization, or airworthiness 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 certain 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, Michael Smith submits that the Chroma “Blade” 

Camera Drone UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the Chroma “Blade” Camera Drone UAS; (b) 

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

a. The Specifications Of The Chroma “Blade” Camera Drone UAS 

Demonstrates Its Safe Characteristics. 

The Chroma “Blade” Camera Drone UAS does 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 Chroma “Blade” Camera Drone UAS. 

The technical specifications of the Chroma “Blade” Camera Drone UAS is 

set forth by the Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The Chroma “Blade” Camera Drone UAS’ Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The Chroma “Blade” Camera Drone UAS may be operated in both manual 

and fully autonomous flight modes. A complete description of the flight and 

navigational modes of the Chroma “Blade” Camera Drone UAS’ User Manual, 

attached hereto as Exhibit B. 

iii. The Chroma “Blade” Camera Drone UAS is 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 Chroma “Blade” Camera Drone UAS 

will remains stationary in flight as reacquisition is attempted. If the Chroma 

“Blade” Camera Drone UAS does 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., RETURN HOME function) via GPS, and will descend to the 

takeoff position and shutdown. Refer to the UAS’ User Manual, attached hereto as 
Exhibit B.

iv. The Chroma “Blade” Camera Drone UAS And Its Operation.

A description of the operation and specifications of the Chroma “Blade” 

Camera Drone and flight controls is provided in the Chroma “Blade” Camera 

Drone UAS User Manual - attached hereto as Exhibit B.

b. Flight Operations Of Chroma “Blade” Camera Drone UAS is Limited To

The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

Michael Smith will be the only certified pilot who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the 

Chroma “Blade” Camera Drone UAS. Additionally, a safety observer will assist 

during flight time operations.

c. Flights Of Chroma “Blade” Camera Drone UAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, Michael Smith proposes to commercially 

operate the Chroma “Blade” Camera Drone UAS 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: Chroma “Blade” Camera 

Drone Unmanned Aircraft System. 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 photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UAS 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 special 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 device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate. 

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 may 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 designated 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 assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations 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 contained 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 track 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 that any update or revision 

would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates 

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 prohibited 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 documented in the 

aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts 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 operating documents.
13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry 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 aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to 

service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record 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 training 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 flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All 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 authorized. 

20. The UAS 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 in 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. 

21. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

 horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

22. If the UAS 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 accordance 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 

forecast weather conditions) there is enough power to fly at normal cruising speed 

to the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

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 operations 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 official 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 conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event 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, flight 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 risk 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 operations 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 conducted. 

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 reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.