Blue Line Studio

1410 Easton Road 

Dallas, TX 75218 

(214) 731-7028 

frojas@bluelinestudio.us | bluelinestudio.us

February 13th 2016

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act and 

Part 11 of the Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 61.101(e) 

(4) and (5); 61.113(a); 61.315(a); 91.7(a), 91.119(c); 91.121; 91.151(a)(1)91.405(a); 

91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b).

PETITION FOR SUMMARY EXEMPTION

Dear Sir or Madam:

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

14 C.F.R. Part 11, Blue Line Studio LLC, an operator of Small Unmanned Aircraft (UA) hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UA.

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE,

West Building Ground Floor, Room 

W12-140, Washington, DC 20590
Table of Contents

QUICK REFERENCE SUMMARY

PETITIONER’S CONTACT INFO

THE REGULATIONS FROM WHICH THE PETITIONER IS REQUESTING

EXEMPTION

THE EXTENT OF RELIEF THE PETITIONER IS SEEKING

REASONS WHY THE PETITIONER IS SEEKING RELIEF FROM THE REGULATIONS 

AND WHY THE EXEMPTION WOULD PROVIDE AN EQUIVALENT LEVEL OF 

SAFETY

14 C.F.R. § 61.23(a) & (c): Medical Certificates

14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and 

Limitations; 14 C.F.R. § 61.113 (a): Private Pilot Privileges and

Limitations; and 14 C.F.R. § 61.315(a): Sport Pilot Limitations

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

14 C.F.R. § 91.121: Altimeter Settings 12

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) 

& (b): Maintenance Inspections

REASONS WHY GRANTING THIS PETITION WOULD BE IN THE PUBLIC

INTEREST

THE PETITIONER REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87

FEDERAL REGISTER SUMMARY

OPERATING DOCUMENTS

STATUTORY AUTHORITY TO GRANT THIS PETITION

CONCLUSION

I.

II.

III.

IV.

V.

VI.

VII.

VIII.

IX.

X.

XI.

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A.

B.

C.

D.

E.

F.

G.
I. QUICK REFERENCE SUMMARY

○ Types of aircraft to be flown:

• DJI Inspire 1

• DJI Phantom 2 

○ The operations will be for:

1. Aerial data collection*

2. Closed-set film/television production.

○ The petitioner will operate ALL the aircraft under the restrictions listed below and those in 

the flight operations and procedures manual which will be confidentially submitted.

○ Petitioner will operate:

• The DJI Inspire 1 under the:

1. Quick Start Guide: http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Quick_

Start_Guide_v2.2_en_1218.pdf

2. User Manual: https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218.pdf

3. Safety Guidelines: http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Safety_

Guidelines_and_Disclaimer_v1.2_en.pdf

4. Maintenance Manual: http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_

Maintenance_ManualV1.0_en.pdf

• The DJI Phantom 2 under the:

1. Quick Start Guide: http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_

Quick_Start_Guide_en.pdf

2. User Manual: http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_

Manual_v1.4_en.pdf

3. Safety Guidelines: http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Safety_

Guidelines_and_Disclaimer_v1.2_en.pdf

○ The MPTOM will be confidentially submitted.

○ The Petitioner is proposing to operate under the restrictions listed in a section below, which 

will provide an equivalent level of safety as the burdensome regulations.

II. PETITIONER’S CONTACT INFO:

Blue Line Studio, LLC

Attn: Fernando Rojas

1410 Easton Road 

Dallas, TX 75218

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*“Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery 

(photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.” Exemption No. 11482
III. THE REGULATIONS FROM WHICH THE PETITIONER IS REQUESTING 

 EXEMPTION 

• 14 C.F.R. § 61.23(a) and (c)

• 14 C.F.R. § 61.101(e)(4) and (5)

• 14 C.F.R. § 61.113(a)

• 14 C.F.R. § 61.315(a)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.119(c)

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)(1)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(1) & (2)

• 14 C.F.R. § 91.417(a) & (b)

IV. THE EXTENT OF RELIEF THE PETITIONER IS SEEKING

The Petitioner proposes these restrictions and believes that these limitations provide an equivalent level of safety, if not greater, as the regulations presently imposed upon the petitioner. Each 

of the regulations above will be talked about in greater detail in another section in this petition. 

The list of limitations and conditions include the following:

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2, DJI Inspire 1, when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater 

than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 800 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible 

during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures 

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outlined in the operating documents, the conditions and limitations herein 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 or any law enforcement official upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to this 

grant of exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted this exemption, then the operator must petition for an 

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.

8. 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 prior to conducting further operations under this exemption. Functional test 

flights may only be conducted by a PIC with a VO and must remain at least 500 feet from 

other people. The functional test flight must be conducted in such a manner so as to not pose 

an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

10.Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12.Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13.Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet 

the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate.

14.The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience- building) 

and determining the PIC’s ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under this exemption are permitted under the terms of this 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 CFR § 91.119

15.UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special 

visual flight rules (SVFR) are not authorized.
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16.The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with 

an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the 

airport management must be made available to the Administrator or any law enforcement 

official upon request.

17. The UA 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.

18.If the UAS loses communications or loses its GPS signal, the UA must return to predetermined location within the private or controlled-access property.

19.The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20.The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation 

and to operate after that for at least five minutes or with the reserve power recommended 

by the manufacturer if greater.

21.Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted 

under the terms of the attached COA.

22.All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23.Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request.

24.The UA must remain clear and give way to all manned aviation operations and activities at 

all times.

25.The UAS may not be operated by the PIC from any moving device or vehicle.

26.All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating persons; and

B. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

27.All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.
28.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.

For the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29.The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption.

30.At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) 

with jurisdiction over the area of proposed filming. The 3-day notification may be waived 

with the concurrence of the FSDO. The plan of activities must include at least the following:

A. Dates and times for all flights;

B. Name and phone number of the operator for the UAS aerial filming conducted under 

this grant of exemption;

C. Name and phone number of the person responsible for the on-scene operation of the 

UAS;

D. Make, model, and serial or N-Number of UAS to be used;

E. Name and certificate number of UAS PICs involved in the aerial filming;

F. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

G. Signature of exemption holder or representative; and

H. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential 

to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption 

holder’s MPTOM.

Blue Line Studio, LLC’s UA are rotorcraft, weighing 55 lbs. or less including payload. They 

will operate only within VLOS and only within the restrictions above and inside the submitted manuals. Such operations will insure that the UA will “not create a hazard to users of the national 

airspace system or the public.”

Given the small size of the UA involved and the restricted environment within which they 

will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UA to commence immediately. Also, due to the size of the UA and the restricted areas in which the 

relevant UA will operate, approval of the application presents no national security issue.

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an onboard 

pilot, there is no ability or place to carry certification and registration documents or to display 

them on the unmanned aircraft. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UA will have immediate access to 

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them. Also, given the size of the unmanned aircraft, the FAA registration number will be displayed 

on the airframe in as large a font as possible.

V. REASONS WHY THE PETITIONER IS SEEKING RELIEF FROM THE

 REGULATIONS AND WHY THE EXEMPTION WOULD PROVIDE AN 

 EQUIVALENT LEVEL OF SAFETY

A. 14 C.F.R. § 61.23(a) & (c): Medical Certificates

The reason why the Petitioner is seeking relief from 61.23(a) & (c) is because Exemption # 11221, # 11284, and many others have determined that a U.S. driver’s license being used in lieu of a medical certificate provides an equivalent level of safety as sub-sections (a) and (c).

Therefore, since the proposed restrictions have already been determined by the FAA 

to provide an equivalent level of safety, the Petitioner is seeking the same exact restrictions as other previously granted exemptions to allow for commercial operations using at 

a minimum either a third class medical or a driver’s license with an airman certificate.

B. 14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations; 14 C.F.R. 

§61.113 (a): Private Pilot Privileges and Limitations; and 14 C.F.R. § 61.315(a): Sport 

Pilot Limitations.

The reason for this petition is that the regulations applying to these three pilot certificates all limit the commercial activities of the pilots; thus, commercial activities would be 

almost completely prohibited leaving the only alternative to be the pilots obtaining an 

extremely burdensome alternative of a commercial pilot certificate.

Regarding private pilots, sub-section 61.113(a) limits private pilots to non-commercial 

operations; “[h]owever, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating . . . [a] UAS 

would not adversely affect operations in the NAS or present a hazard to persons or 

property on the ground” by conducting commercial operations. “[M]anned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for” commercial drone operations. Additionally, in Exemption # 11221, # 

11284, and many others the FAA has declared that requiring the PIC to “hold either an 

airline transport, commercial, private, recreational, or sport pilot certificate” provides an 

equivalent level of safety as the regulations.

Since the FAA has numerously determined that a minimum of a sport pilot certificate 

be required for commercial UA operations, Blue Line Studio LLC is asking for the PIC to 

be required to have at a minimum a sport pilot certificate when conducting commercial 

operations. This requirement also alleviates any security concerns as the TSA would have 

already done a background check on the individual possessing the pilot certificate.

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The reason the Petitioner is requesting relief from this regulation is because the FAA 

does not need to issue an airworthiness certificate for this unmanned aircraft and the 

requirements contained in the submitted manuals will be sufficient for determining the 

airworthiness of the aircraft.
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The restrictions already agreed to will require the PIC to conduct a pre-flight check to 

determine airworthiness and the operator to be “responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.” The submitted manuals 

along with the restrictions obligating the PIC and operator to check and ensure the UA 

will provide “sufficient means for determining an airworthy condition in accordance with 

§ 91.7(a).” Clayco Exemption No. 11109 at 13. Therefore, the Petitioner seeks relief to 

operate under the proposed restrictions and the submitted manuals.

D. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Section 91.119, sub-section (c) requires the petitioner to operate at “[a]n altitude of 

500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure.” This regulation is burdensome because it would require the Petitioner to operate at 500ft above the ground for many operations. This is a burdensome 

problem because many of the objects that need photographing will all be at least 500ft 

away. In addition the limitation restricts the observtion of the UA by a second UA acting 

as an aerial observer to ensure safe operation.

The Petitioner proposes to operate within the restrictions given in the Clayco Exemption which the FAA has previously determined will provide an equivalent level of safety. 

“[A]ll persons not essential to flight operations (nonparticipating persons) must remain 

at appropriate distances. In open areas this requires the UA to remain 500 feet from 

all persons other than essential flight personnel (i.e. the PIC and VO). . . . If barriers or 

structures are present that can sufficiently protect nonparticipating persons from debris in 

the event of an accident then the UA may operate closer than 500 feet to persons afforded such protection. 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. . . . [O]

perations may be conducted closer than 500 feet to vessels, vehicles and structures when 

the land owner/controller grants such permission and the PIC makes a safety assessment 

of the risk of operating closer to those objects.” Clayco Exemption No. 11109 at 15.

E. 14 C.F.R. § 91.121: Altimeter Settings

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

by reference to an altimeter that is set “... to the elevation of the departure airport or 

an appropriate altimeter setting available before departure.” Many UA do not have an 

altimeter but use GPS to determine height.

An equivalent level of safety will be achieved by the operator, pursuant to following 

the submitted manuals and operating under the proposed restriction. Furthermore, the 

Clayco petition and many other petitions have been granted allowing GPS to be used in 

lieu of an altimeter.

F. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

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

under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed - (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 
after that for at least 45 minutes.” Most unmanned aircraft cannot fly longer than 30 minutes; therefore, most would always be violating this regulation if they took off.

The Petitioner believes that an equivalent level of safety can be achieved by restricting 

operations to “the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater.” Exemption # 

11284, at page 5.

G. 14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): 

Maintenance Inspections

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

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

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant.

An equivalent level of safety will be achieved because these small UAS’s are very limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. Moreover, the operator is the person most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Lastly, the petitioner will operate in accordance with the submitted manuals 

which will provide an equivalent level of safety as the burdensome regulations.

VI. REASONS WHY GRANTING THIS PETITION WOULD BE IN THE PUBLIC

 INTEREST

The Petitioner intends to produce picture and video content. If the petitioner does not have 

the option of using the Petitioner’s UA, the only other way to obtain the aerial footage is by using 

manned aircraft which pose a danger to the pilot as well as individuals on the ground. There are 

no pilots on board the UA and due to the small size of the UA, there is less risk posed to the public on the ground in case of an emergency. Additionally, the UA has multiple motors while most 

manned aircraft have only one engine; thus, there is some motor redundancy for some UA in case 

of a motor malfunction.

Manned airplanes and helicopters produce great amounts of noise pollution disrupting the 

quiet enjoyment of private property of the public on the ground. UA are much quieter and will not 

disrupt the public as much as manned aircraft; thus, the public will benefit from a reduction in noise 

pollution.

In addition to the noise pollution reduction, engine or turbine powered aircraft produce exhaust which affects the environment while the UA of the petitioner are electric and do not produce 

any emission. The byproduct of 100LL emissions is lead entering the air the public breaths while 

electric motors produce none. The environment and the public are benefited by the use of UA.

UA use batteries for power which are not as flammable and explosive as 100LL or Jet A. If 

there was an emergency where the UA crashed, there is less chance of individuals being injured 

from an explosion or fire. UA also use smaller propellers than manned helicopters which will 

cause far less damage in the case of a crash than the “grenading” that typically happens during a 

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manned helicopter crash.

Lastly, the UA will be operated at lower altitudes than manned aircraft. Thus, the public benefits because the danger of a mid-air collision is lessened.

VII. THE PETITIONER REQUESTS THAT THE PUBLICATION AND COMMENT

 PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87.

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of my 

petition for exemption?

The FAA may not publish a summary of your petition for exemption and request comments 

if you present or we find good cause why we should not delay action on your petition. The factors 

we consider in deciding not to request comment include:

(a) Whether granting your petition would set a precedent.

(b) Whether our delaying action on your petition would affect you adversely.

(c) Whether you filed your petition in a timely manner.

Corresponding to the above sub-sections, the Petitioner has good cause to request the FAA 

to waive the comment period and not delay action on the petition because:

(a) Blue Line Studio LLC would not set any precedent.

(b) Delaying the granting of this petition would adversely affect the public, the FAA, and 

Blue Line Studio LLC. The public, as well as the FAA, would be better served by the 

FAA quickly granting this petition and thereby freeing up limited FAA resources and 

allowing FAA inspectors to dedicate their time and attention to much higher priorities. 

Moreover, Blue Line Studio LLC. is adversely affected by the above listed regulations.

(c) The petition has been filed in a timely manner.

VIII. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed.

Applicant seeks an exemption from the following rules:

14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(a); 

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b) 

to operate commercially a small unmanned vehicle (55 lbs. or less) for aerial data collection and 

closed-set TV/movie filming using a DJI Inspire 1 DJI Phantom 2 .

This exemption will allow commercial operations of UA’s which will enhance safety by reducing risk. The alternative to using a UA is to use a jet or piston power aircraft carrying large 

amounts of jet A or other fuel. Not only is the operation dangerous at the location, the aircraft 

must fly to the location and back to the home airport. Our UA will weigh less than 55 lbs. and 

powered by batteries which eliminates most of the risk because no highly flammable fuel will be 

involved. The UA will carry no passengers or crew; thus, eliminating most of the risk to the pilot 

and personnel. The operations of the UA listed under the restrictions proposed herein will provide 

an equivalent level of safety as the Federal Aviation Regulations.

IX. OPERATING DOCUMENTS

Blue Line Studio, LLC will operate only within the limitations above and the limitations listed 

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in the submitted manuals. The limitations above, from the previously granted exemption, will be 

followed if there is a conflict with the manuals.

X. STATUTORY AUTHORITY TO GRANT THIS PETITION

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under § 

40101 of the Act that includes UAS’s, from the requirement that all civil aircraft must have a current 

airworthiness certificate. “The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest.” 49 U.S.C. § 44701(f). See also 

49 U.S.C. § 44711(b).

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

333(a) through (c) of the FAA Modernization and Reform Act of 2012. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rulemaking required under Section 

332 of the FAA Modernization and Reform Act. In making this determination, the Secretary is required to determine which types of UA do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of the following:

The UA’s size, weight, speed, and operational capability;

Operation of the UA in close proximity to airports and populated areas; and,

Operation of the UA within visual line of sight of the operator (VLOS)*

If the Secretary determines that such vehicles “may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added).5 The FAA has already established requirements for summary grants which will be further discussed below.

XI. CONCLUSION

The operation of Blue Line Studio LLC using a small UAS, weighing less than 55 lbs., conducted under the proposed restrictions outlined above, will provide an equivalent level of safety 

supporting the grant of the exemptions requested herein.

If I can be of any assistance to further expedite this petition, please do not hesitate to contact me at (214) 731-7028 or at my email frojas@bluelinestudio.us 

Sincerely yours,

Fernando Rojas

*FAA Modernization and Reform Act of 2012 at § 333(a).

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