12/31/2015

David A. Flood

DAF Auction Inc - (614) 834-3300

4540 Vista Dr, Canal Winchester, OH 43110

U.S. Department of Transportation-Docket Operations

1200 New Jersey Ave SE - Washington, D.C. 20590

Dear Sir or Madam 

In accordance with Section 333 of the F.A.A. Modernization and Reform Act of 2012, I, David 

Flood, DAF Auction, Inc, herby formally request exemptions from the following sections for the 

commercial operations of a UAS Blade Chroma Quadcopter with a 4k Camera.

14 CFR Part 21 14 CFR 91.121

14 CFR 45.23 A & C 14 CFR 91.151 A 1

14 CFR 61.101 E, 4 & 5 14 CFR 91.203 A & B

14 CFR 61.113 A & B 14 CFR 91.405 A

14 CFR 61.315 A 14 CFR 91.407 A 1

14 CFR 91.7 A 14 CFR 91.409 A 1 & 2

14 CFR 91.119 C 14 CFR 91.417 A & B

My request for intended use of the UAS is to provide the Public with a safe, cost effective, 

environmentally friendly method to capture Aerial Videography and Still Photography for 

Public and Business interests. My primary operations will be for aerial video and photography to 

aid Homeowners, Realtors, Home Builders, Appraisers, Contractors, Agriculture, Industry in 

Marketing & Inspections. 

The Blade Chroma UAS weighs less than 3 pounds, utilizes many safety features including: GPS 

location and Altitude Sensors, Adjustable Flight Parameters, Has the capability to return to 

starting point in the event of signal loss, Auto Hold Position, Safe Circle Barrier, Low Battery 

Warning and provides a safe, quiet & environmental sensitive alternative to manned aircraft. 

The exemptions will not adversely affect safety due to abiding to, meeting and exceeding the 

following guidelines: All flights will be conducted only after a Pre-Flight Inspection of the UAS & 

Area to be photographed, Flown in Accordance with Manufacture's Procedures, During Daylight 
2DAF Auction Inc - (614) 834-3300

only, Visual Line of Sight at no more than 400 feet AGL, At all times maintaining safe distances 

from unprotected persons & vehicles, Contact with Airport for permission if within 5NM of 

their vicinity, Not Flying in Adverse Weather or Impaired Visibility, Not flying over sensitive 

infrastructure, All local laws and/or Ordinances will be followed, Flight will be aborted in the 

event of an emergency or unpredictable event, Post Flight Inspections will be completed after 

every flight and UAS will be stored and transported in a protective case. 

Please find the following extent of relief and reasons for relief requested: Given the size, weight, 

limited operating area of the UAS I intend to operate & meets the requirements of an equivalent 

level safety, I request exemption of of airworthiness certificate 14CFR Part 21; 14CFR 45.23 a&c 

UAS does not have a cabin, cockpit, pilot station, or area to mark I request exemption of 

Markings; 14CFR 61.113 a&b FAA has previously declared that additional manned airship 

experience of commercially certified pilot would not correlate to the airmanship skills necessary 

for similarly proposed operations in previously issued exemptions; 14CFR 91.7 Currently there is 

no certificate applicable to the Blade Chroma UAS. I will with Manufacture's Operating Manual, 

Pre & Post Flight Inspections of the Blade Chroma UAS including Electric Motors, Propellers, 

Frame, Landing Gear, Camera and Controller to determine airworthiness; 14CFR 91.119c I will 

ensure that no flight exceeds the 400 AGL height or fly over congested areas. All flights will be 

Pre-Planned for Obstructions, Flight Safety & Height Analysis; 14CFR 91.121 The Blade Chroma 

UAS utilizes a electronic GPS with sensor and live real time data to transmitter to meet an 

equivalent level of safety; 14CFR 91.151 A1 The Blade Chroma UAS is powered by a Lithium 

Polymer Battery and due to the limitations of the batteries (Flights no longer than 30 minutes) it 

is impossible to comply with 91.151 A1; 14CFR 91.203 A & B Currently no procedures for 

providing airworthiness certificates to comply with 91.203(a) & (b) for the Blade Chroma UAS, 

but I will always follow all safety procedures and fly in a safe responsible manner; 14CFR 405A, 

91.407A1, 91.409A1 & 91.417 A & B Maintenance may be required and should be granted since 

they only apply to aircraft with airworthiness certificate. But I will perform both Pre & Post 

Flight Inspections of the Blade Chroma UAS. 

Thank you for your consideration in this matter,

David A. Flood

President

DAF Auction Inc - (614) 834-3300

daf@dafauction.com