### October 8 2015

U.S. Department of Transportation Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 91.409 (a)(1) and {2}; 91.417{a) & (b).

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Joey Blackstone, operator of an Unmanned Aircraft System (UAS), hereby apply, on behalf of Blackstone Aerial Photography, for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation o f its UAS, so long as such operations are conducted wi thin and under the conditions outlined herein or as may be established by the FAA as required by Section 333. I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.20 3(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and photography real estate purposes and events. Applicant: Jo ey Blackstone Owner Blackstone Aerial Photography 6038 Lynwood Blvd Mound, MN 55364 Info@BlackstoneAerialPhotography.com ( 952) 456

- 2698 Commercial operation of an UAS, as described herein, whi ch are equipped with camera and se nsors, would operate in the following manner: • Aerial photography and/or video for public and/or private use including real estate and other related professional activities. • Aerial video and/or photography for public and/or private use including pub lic and private events.As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a PHANTOM 2

UAS. We will operate a UAS, the DJI Phantom 3 Professional, which is comprised of an unmanned aircraft (UA or Phantom), an attached 4K camera and a transportable ground station. The PHANTOM 3 is a quad

copter with a gross weight of 2.8 pounds. It is equipped w ith four rotors that are driven by electri c m otors pow ered by batteries. The UA has a maximum airspeed of 16 m/s. It will be operated over various metropolitan areas, primarily around Mound, MN, to augment real estat e listing videos, capture event areal video and photography, and related business operations. **UAS Operating**  **Param eters**  We will abide by the following additional operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:

o operate UAS below

300 feet and within a radius distance of 1000 f eet from the co ntroller to aid in direct line of sight visual observation; o obtain permission from the owner/controller of any vessels, vehicles and structures when operations maybe conducted closer than 500 feet to any such vessels, vehicles or structures ; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard; o operate the UAS for 5

- 10 minutes per flight; o land UAS prior to the manufacturer’s recommended minimum level of b attery pow er; o operate UAS during daylight hours only within visual line of sight (VLOS); o use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; o con duct all operations under the flight safety protocols (including posting a warning sign! reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) contained in the operating documents and will actively analyze flight d ata and other sourc es of information to constantly update and enhance safety protocols; o contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertine nt inform ation; o alw ays obtain all necessary permissions prior to operation; have procedures in place to abort flights in the event of safety breaches or potential danger; o only operate in safe environments that are strictly controlled, are aw ay from po we r lines, elevated light s, airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO); o conduct extensive preflight inspections and protocols, during which safety carries primary importance (reference PHANTOM Flying Flow Chart and User Manual). Regarding UAS operational training, we have flown numerous pract ice flights in remote areas as hobbyists simulating flights for future commercial use to gain familiariz ation with the characteristics of the UAS’ performance under different temperature and weather conditions. Any PIC operating our UAS will have accumulated and logged, in a manner consistent wi th 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hour s logged as a UAS pilot with a multidrotor UAS. The PIC w ill also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and m odel of UAS to be used for operations. In addition to the hour requirements, the PIC will acco mp lish 3 take

- offs and landings in the preceding 90 days (for currency purposes) prior to any flight.**Specific Exemptions Requested** 

Given the size, weight, speed, and limited operating area associated wi th the UA, we feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and§ 91.203(a) and (b) (Certifications required), subject to certain conditions and limitati ons, is warranted and meets the requirements for an equivalent level o f safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further , the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the larg est possible lettering by placing the word “E xperimental” on its f

uselage as required by § 45.29(f) so that anyone will see the mar kings. We request an exemption from § 91.7(a) w hich prohibits the operation of an aircraft without an airw orthiness certifi cate, since there is currently no certificate applicable to our ope ration, this regulation is inapplicable. We request an exemption from §§!91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to airc raft with an airworthiness certificate. How ever, as a safety precaution we will perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents. We request an exemption from § 91.9(b)(2) which requires an ai rcraft flight manual in the aircraft, however since there are no pilo ts or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety wil l be achieved by maintaining a safety/flight manu al with the UAS ground station. We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at low er altitudes in certain conditions. We will not operate our UAS ab ove the altitude of 300 feet above ground level (AGL) and will al so only operate in safe areas aw ay from the public and traffic, thus “providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the siz e, weight, maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved. We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and tw o low battery alerts are issued

– per the operating documents, the UAV will be landed at the first alert. Also, our flights will last o nly 5

- 10 minutes each, and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless (cons idering wind and forecast w eathe r conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

**Public Interest** Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts and increase business success. The industry is not new. However, until recently it was conducted through the use of costly manned aircraft, a prohibitive business activity for small companies. By granting this exemp tion I w ould be able to provide affordable services.Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel

when compared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to the environment economic growth by providing information to companies and the public looking to relocate or build in the metro areas w e service. Public and private events serviced by our business enhance vibrancy and add culture to the community an d its citizens. **Summary**
We will comply with all of the following conditions and limitations should this exemption be provided: 1) Operations will be limited to the following aircraft described in the operating documents, which is a quad

- rotor aircraft w eighing 2.8 pounds: Phantom 3 Unmanned Aircraft System. 2) The UA will not be flown at an indicated airspeed exceeding 50 knots. 3) The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), All altitudes reported to ATC mu st be in feet AGL. 4) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) at all times. 5) All operations will utilize a visual observer (VO). The UA w ill be operated within the visual line of sight (VLOS) of the VO a t all times. The VO and PIC w ill be able to communicate verbally at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functio ns prescribed in the operating documents. 6) The operating documents will be accessible during UAS operations and made available to the Ad ministrator upon request. Any revisions to the operating documents will be presented to the Ad ministrator upon reques t. 7) Prior to each flight, the PIC w ill inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has bee n performed and the UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records. 8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records. 9) The pre - flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 10) We will follow

the UAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement,inspection, and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance w ith the operating documents. Maintenance, inspection, and a lterations will be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.
12 ) Any incident, accident, or flight operation that transgresses th e lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instr uctions contained on the NTSB Web site: www.ntsb.gov

.

If you have questions or need additional information, please contact me at Info@BlackstoneAerialPhotography.com or (952) 456

- 2698

. Thank you, Joey Blackstone Owner Blackstone Aerial Photography