October 1

, 2015

Exemption No. 13055 Regulatory Docket No. FAA

− 20 15

− 2876

Mr. Gordon Hutton Blue Sky Consulting/Aerial Survey Inc.

11991 Hidden Links Drive Fort Myers, FL 33913

Dear Mr. Hutton :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 9, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Blue Sky Consulting/Aerial Survey Inc. ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to

conduct aerial photography, videography, and survey

.

See the docket, at www.regulations.gov , for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1

.

In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in

reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transp ortation

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA2

finds that relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certi fication and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Blue Sky Consulting/Aerial Survey In c. is granted an exemption from 14 CFR §§ 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), and 91.417(a) and (b), to the extent necessary to allow the pet itioner to operate a UAS to perform

aerial data collection

. This exemption is subject to the conditions and limitations listed

below.

1 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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Blue Sky Consulting/Aerial Survey Inc. is hereafter referred to as

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exempt ion are limited to the 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

not 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 400 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 PI C always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic 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 conditi ons and limitations in this exemption and the procedures outlined in the operating documents,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating

docum ents. 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 a lso 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 mus t petition for an amendment to its grant of exemption. The FA A’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 aff ect 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 wi th 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 en sure 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.

, i noperable 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 condi tion 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 manufa cturer 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or he r pilot certificate.5

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 V Os (traini ng, 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,

trainin g operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appr opriate 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.

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 air port symbo l 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 managem ent 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 PI C.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate 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 5 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 cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends t o conduct operations that cannot be conducted under the terms of the enclosed COA

.6

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 a nd 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, v ehicles, 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 protectio n. 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 t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.

P ermission 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 FA A'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

.7

If this exemption permits operations 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 m otion 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 a rea 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 th e 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 cer tificate 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 availa ble 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

es sential 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.

Unless otherwise spe cified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.8

This exemption terminates on October 31, 2017 , unless sooner superse ded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosureJune 9, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 2050

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 CFR Part 61.113(a); 14 CRF PArt 91.7(a); 91.119; 91.121; 91.151(b); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b).

Dear Madam/Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Blue Sky Consulting/Aerial Survey Inc. is applying for an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its Unmanned Aircraft Systems (“UAS”).

I Gordon Hutton, owner of Blue Sky Consulting/Aerial Survey am a FAA licensed , ATP RotorCraft/Airplane Instrument pilot of over 17,000 accident/incident free PIC hours in MD11, B737, CL

- 65, SF

- 340, LR

- 31, B

- 200, B214ST, B412, B212, AS350B, and B206. I was
also a Check Airman in the CL

- 65. I will be the primary PIC o f the Inspire I.

Blue Sky Consulting/Aerial Survey is based in Fort Myers Florida. Blue Sky strives to provide the absolute best aerial survey experience, in doing this, capturing quality images, videos from country clubs, boats, and real

- estate is impor tant and valuable to the advertising process. In the past, aerial photography has been obtained for projects by the use of a single engine helicopters or airplanes with a pilot and a photographer. This form of aerial photography has benefited the advertisi ng process in many ways; however, to take aerial photography to the next level, Blue Sky is procuring the use of UAS. The transition from
manned aircraft

- aerial photography to the UAS photography and videography for data collection has been a well thought

- out decision for Blue Sky. In the advertising industry, it is important to capture aerial images and videos. This data will be obtained more effectively and safely from a UAS than it would be with the traditional manned aircraft. Initial site surveying, site logistics planning, progress inspections, thermal imaging and pre and post construction completion , boat and home photography videos are some of the main uses for the UAS By Blue Sky. Blue Sky is requesting this exemption to permit operations of it s UAS under controlled conditions within the National Airspace System, which will be 1) site specific, 2) pre

- planned, 3) access controlled, and 4) will provide a greater level of safety, which is already a high priority and best practice with all
tasks th at are performed by Blue Sky. Therefore, an approval of this exemption by the FAA would provide a greater level of safety and reduce the risks associated with these activities on the above listed activities. As such, the use of UAS is in the public intere st.

I. The contact information of the applicant is:

Blue Sky Consulting/Aerial Survey
11991 Hidden Links Drive Fort Myers, Florida 33913
Gordon Hutton
Phone: 503

- 551

- 7009
Email: md11flier@aoal.comII. The s pecific sections of Title 14 of the Code of Federal Regulations from which Blue Sky

requests exemption are:

14 CFR 61.113(a) 14 CFR 91.7(a)

14 CFR 91.119

14 CFR 91.121 14 CFR 91.151(b) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and ( 2) 14 CFR 91.417(a) and (b)

III. Aircraft, Increased Level of Safety & the Public Benefit:

The UAS, which will be operated by Blue Sky, weighs less than 10 pounds, including all equipment as indicated in the attached manual. The UAS can be maneuvered vertically and horizontally at the same time and hover in place. Specifically, the UAS that Blue SKy intends to use is the Inspire 1 manufactured by DJI. The provided supporting documentation

inc ludes the user manual, safety guidelines and quick

- start guid e for this model of UAS. As a requirement for compliance, all documentation and relevant manual materials for the flight and sUAS will be kept in an accessible location that will be available to the PIC at all times. As determined in a previous Grant of Ex emption, relief from 14 CFR Section 91.9(b) (2) and 91.203(a) and (b) is not required. As indicated within the user manual and to increase the safety of all personnel within the site, the UAS is equipped with the use of GPS and motion sensors which can br ing the unmanned aircraft back to the ground safely upon command, during low battery levels, and loss of communications or GPS signal. Additionally, if there are any unexpected obstacles or emergencies that come up during the flight, the UAS will be capabl e of aborting the flight. Furthermore, as required by 14 CFR Section 45.29(f), and due to the small size of the unmanned aircraft, the UAS will have identifiable markings that will be as large as practicable on the largest surface available.

If the submit ted exemption is approved, Blue Sky intends to utilize the UAS as previously stated above with the following conditions and limitations: 1. Aircraft will weigh less than 55 pounds. 2. Unless prior written approval is provided, all UAS flights will be at or below 200 feet AGL. 3. Operations will occur during daytime Visual Flight Rules (VFR) conditions, from sunrise to

sunset. 4. Maximum total flight time for each flight shall be no more than 18 minutes or flights will be terminated at 15% battery power reserve or when low battery level indications are present as indicated in the user manual and safety guidelines.

5. The UAS Pilot will have at least a Private Pilot Certificate and a current 3 rd Class Medical
Certificate. 6. At a minimum, the crew for th e UAS will include the pilot and an observer trained by the pilot. 7. All flights will be within Visual Line of Sight (VLOS) of the pilot and/or visual observer. 8. The UAS will remain close enough to the operator/pilot for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses. 9. The UAS Pilot will be the Pilot In Command (PIC). 10. The UAS will only operate within the designated area as discussed and planned during the pre

- flight briefing.11 . During UAS operations within 10 nautical miles (NM) of an airport, the closest air traffic

radio frequency channel will be monitored for air traffic via a hand held aviation radio. 12. With operations within 5 NM of an air traffic control tower, the air port operator or air traffic controller will be notified and clearance accepted prior to operations, and a NOTAM
filed. 13. A pre

- flight briefing will be conducted prior to each UAS flight. All personnel involved in the flight are required to be present du ring this briefing. 14. Prior to each flight, a pre

- flight inspection will be conducted as per the pre

- flight checklist provided within the Inspire 1 User Manual. 15. The UAS will not operate directly over any persons not directly involved in the operati on. 16. The UAS PIC will obtain the consent of all personnel onsite and within the area and perimeter of the site in which the sUAS will be operating above. 17. Property owners’ approval will be obtained prior to UAS operations on each site. 18. The pil ot and observer will be trained in the operation of UAS generally and received up

to

- date information on the specific sUAS that is being operated. 19. At all times voice communications between the observer and the pilot will be
maintained. 20. All requir ed permissions and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate government agencies.

14 CFR 61.113 (a): Private Pilots Privileges and Limitations: Pilot in Co mmand. Section 61.113 (a) limits private pilots to non

- commercial operations. Although, these flights will be operating an aircraft for compensation or hire, but the UAS will not physically carry a pilot or any passengers. Therefore, the proposed flight o perations can achieve a level of safety that is equal to manned aircraft operations, provided that the PIC operating the aircraft holds at least a Private Pilot Certificate, in lieu of having a commercial pilot Certificate. In order to achieve a higher lev el of safety for all personnel involved in the operations of the sUAS, Blue Sky will require that the PIC operating the UAS have at least 100 hours of total flight time experience and hold, at least a Private Pilot Certificate. There is a greater level of safety and reduced level of risk, with not only the UAS crew, but all personnel and construction inspectors involved in the project. The level of safety that is provided by the UAS exceeds that of a single individual with a commercial pilot certificate

whi le PIC of a manned aircraft flight. The level of risk associated with the UAS is far lower than could be achieved on the commercial operations of a manned aircraft. Therefore, allowing commercial operations of UAS as requested with a Private Pilot as PIC w ill surpass the current level of safety provided by 14 CFR Section 61.113(a).

14 CFR 91.7(a): Civil Aircraft Airworthiness. This regulation section requires that the aircraft be in an airworthy condition prior to flight. Although, a UAS is not required to have an airworthiness certificate, the PIC will operate the UAS and comply with all user manuals and operating documents to ensure that the aircraft and all aircraft systems are in an airworthy condition prior to each flight. The PIC will perform the re quired pre

- flight inspection with the pre

- flight checklist as provided in the sUAS user manual, which will provide an equivalent level of safety.

14 CFR 91.119: Minimum safe altitudes. Section 91.119 provides the requirements for safe altitudes for civi l aircraft operations. Section 91.119(d) (1) allows the operations of helicopters below the minimum altitudes described under parts (b) and (c). As this exemption request is for the UAS which is a “quad

- copter” (4 rotor type) unmanned aircraft, similar to a helicopter, an equivalent levelof safety will be provided. Based on the operating conditions and limitations for the UAS, all

essential and non

- essential personnel and property on the surface will not be exposed to any hazards due to an emergency or pow er failure as per part (a). Altitudes will be limited to no more than 200 AGL, which will require an exemption from parts (b) and (c). Currently
there are manned rotor

- crafts that operate at altitudes less than the 500 AGL, with more
hazardous materials an d on a larger scale than unmanned aircraft have. Therefore, this will reduce the risk of flights at lower altitudes with less weight and no flammable materials which will not pose a high risk to people or property on the surface. No flight will begin
witho ut the prior approval of the property owners and/or local officials. Due to the short periods of operations being limited to 20 minutes or less, and limited to confined areas while maintaining visual line of site, an equivalent level of safety will be prov ided.

As stated within the UAS list of conditions and limitations, if flight operations plan to take place within class B, C or D airspace and within 5 NM of an air traffic control tower, the airport operator or air traffic controller will be notified an d clearance provided prior to operations. As an added safety precaution, the closest aviation radio frequency will be monitored for any air traffic in the area by the use of a handheld aviation radio. The air traffic controller will be aware of the UAS ope rations and the PIC will be aware of any air traffic within the area. This will benefit the public and any pilots of manned aircraft above by the PIC ensuring that there are no other aircraft in the area prior to visual confirmation. The
use of the handhel d aviation radio will greatly reduce the risk and provide a greater level of safety. Furthermore, the low altitude operations will ensure separation from the sUAS and any conventionally manned aircraft operations that will comply with this regulation.

14 CFR 91.121: Altimeter Settings: This section requires that “each person operating an aircraft shall maintain the cruising altitude... by reference to an altimeter that is set... [at] the elevation of the departure airport or an appropriate altimeter setting available before departure.” An exemption may be required, because the UAS provide the PIC with the altitude reading on the remote controller, from a GPS signal on the UAS. An equivalent level of safety can be achieved by the PIC by ensuring the correct al titude is provided during the pre

- flight checks prior to each flight while on the ground.

14 CFR 91.151(b): Fuel Requirements for Flight in VFR Conditions: For this regulation, all flights in a rotorcraft, during the day require an additional 20 minutes of fuel for each flight. However, similar to rotor

- crafts, the particular unmanned aircraft that Blue Sky uses has a total flight time of approximately 18 minutes as indicated in the user manual. With this total flight time, it is impossible to have 20 mi nutes of additional fight time beyond the planned flight time. An equivalent level of safety will be provided because the Inspire 1 has an emergency feature equipped which will automatically return to the departure location upon reaching low battery power levels. At low battery levels there are several alerts to notify the Pilot that the UAS has a low battery. During a low battery level warning, the aircraft status indicator will blink red slowly which is notifying the Pilot to
return the aircraft to the ho me position. If, after 10 seconds the Pilot does not begin to return the aircraft to the home position the aircraft will automatically return to the home position and land while the remote is sounding an alarm. By maintaining visual line of sight
with the UAS the aircraft will always be in close proximity to the home position. Although the UAS is equipped with the automatic low battery settings, there is a battery level percentage indicator on the remote. If the battery level indicator reaches 15% or the fl ight time is 15 minutes (whichever occurs first) the PIC will start to return to the home position. With these features incorporated within the sUAS and the standards set in the conditions and limitations herein, an equivalent level of safety can be provid ed for this requested exemption.14 CFR Subpart E: 91.405(a); 407(a)(1); 409(a)(1) and (2); 417(a) and (b): Maintenance,

Preventive Maintenance, Inspections and Maintenance Records. These regulations require the aircraft owner or operator to have the ai rcraft inspected and maintained “...in accordance with part 43 of this chapter.” It is understood that these regulation sections apply to aircraft that hold an airworthiness certificate, therefore the above mentioned sections will not apply to the operation s of the UAS. The operator of the UAS will perform all required and periodic maintenance as indicated within the user manual and any supporting documents included with the UAS being used. Due to the small scale of the unmanned aircraft systems and specific area of operations, this can be achieved by the operator, and an equivalent level of safety will be provided. In the event that any extensive mechanical repairs are required, these tasks will be perfumed by the aircraft manufacturer if needed. During any flight, if mechanical failures occur, the UAS will immediately terminate the flight and return to land. As indicated previously, pre

- flight inspections will take place prior to all flight operation to verify all systems and equipment are functioning proper ly. Any maintenance performed by the operator will be logged appropriately for documentation. Overall, to provide an equal level of safety, the aircraft will be maintained in an airworthy condition by the operator, which is
most familiar with the aircraft.

IV. Summary:

Pursuant to 14 CFR Part 11, the following is a summary to be provided for publication in the Federal Register if needed: Blue Sky is seeking an exemption from the following regulations: 14 CFR Part 61.113(a); 91.7(a); 91.119; 91.121; 91. 151(b); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b) for the commercial operation of its small Unmanned Aircraft Systems (55lbs or less) for arial site imaging, inspections, boat, home photography and event photography. The approval of exemptions to allow commercial operations of UASs in the above mentioned areas will greatly enhance safety and reduce risks associated with these activities in the past. The conventional methods included the use of manned aircraft or rotorcraft, which

pos e a greater risk to personnel involved. By the use of the UAS that will carry no passengers or crew, this will eliminate the majority of the risks associated with these tasks. The operation of the sUAS that will be conducted in the specific conditions lis ted above will provide a greater than or equal level of safety supporting the grant of the Part 21 and allowing commercial operations. The lightweight Unmanned Aircrafts operate at low speeds, generally close to ground level, and always being monitored wit h line of sight operations, as a result, they are far safer than the conventional methods with manned single engine aircraft or rotorcraft that are just as close to ground level.

V. Privacy & Public Acknowledgement:

As indicated above, all UAS operati ons will occur after receiving prior approval and authorization from the property owners of the area in which the operations are being
conducted within. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

— size, weight, speed, op erating characteristics, operations within visual line of sight, and the use of radio communications will provide considerable justification to grant the requested exemptions and allow commercial operations of the applicant’s UAS for use in the constructio n industry.Regards,

Blue Sky Consulting/Arial Survey 11991 Hidden Links Drive, Fort Myers, Florida, 33913
Phone: 503 551 7009

APPENDIX

– A
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 Adm inistration FAR Federal Aviation Regulation
GCS Ground Control Station GPS Global Positioning System
LOL Loss of Link
NAS Nation al Airspace System
NOTAM Notice to Airman
PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures
UA Unm anned Aircraft
UAS Unm anned Aircraft System VFR Visual Flight Rules
VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

APPENDIX

- B Inspire 1 User Manual