Blue 

Goose 

Construction 

U. S. Department ofTransportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Blue Goose Construction LLC 

Section 333 Petition to Operate 

Small Unmanned Aerial Systems 

Prepared By: 

Scott Holmes 

9901 Okeechobee Road 

Fort Pierce, FL 34945 

(772)461-3020 

sho lmes@bluegooseconstruction.com 

Petition Summary: 

State Certified Licensed 

General Contractor #CGC1517686 

Pollutant System Contractor # PCC056727 

Underground Utility & Excavation # CUC 1225110 

Pursuant to Section 333 ofthe FAA Moderation and Reform Act of2012, Pub. L. No. 112-95 

(2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's (FAA") general 

Exemption authority under 49 U.S.C. section 44701(f), Scott Holmes ("Petitioner") hereby 

petitions for exemptions from 14 C.F. R. Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. 

Part 27. 

(Airworthiness Standards: Normal Category Rotocraft), 14 C.F.R. sections 61.113(A)-

(b ),91.1 03(b )(1 ), 91.119( c), 91.121, 91.151, 91.405(a)(l ), 91.409(a)(2), and 91.417(a)-(b ). 

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of 

Small unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational and safety 

Requirements Congress has set forth in Section 333. 

Petitioner is a Civil Construction company that plans to exploit the capabilities of Unmanned 

Aerial Systems to offer a multitude of services, including: 

• Aerial Surveying 

• Remote Sensing 

• Telecommunications 

• Agriculture 

• Aerial filmmaking and photography 

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669 
• Energy systems inspections and monitoring 

• Wildlife and Forestry monitoring 

• Educational and research operations 

• Pipeline inspection and patrolling 

• Infrastructure Inspections 

Statutory Authority: 

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Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism 

for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) 

States that the FAA "shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion ofthe (comprehensive) plan and rulemaking required 

by section 332(b)(l) ofthis Act or the guidance required by section 334 ofthis Act". In Section 

332 (b)(l), Congress made it clear that Section 333 provides a mechanism for "expedited operation 

authorization" if several factors are met. Petitioner meets all requirements to permit FAA approval 

of commercial UAS operations. 

The Petitioner Requests Relief from the Following: 

Section 61.113(a) and (b) prescribes that-

(a) No person who holds a private pilot certificate may act as a pilot in command of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 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. 

Section 91.1 03 prescribes, in pertinent part, that each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight, to include -

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

fuel requirements, alternatives available if the planned flight cannot be completed, and any 

known traffic delays ofwhich the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

1. For civil aircraft for which an approved Airplane or Rotocraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data 

contained therein; 

2. For civil aircraft other than those specified in paragraph (b)(l) ofthis section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected 

values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature. Section 91.119 prescribes that, except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes: 

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669 
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(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open 

air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal 

radius of2,000 feet ofthe aircraft. 

(c) Over other than congested areas. An altitude of500 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, vesse~ vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. lfthe operation is 

conducted without hazard to persons or property on the surface -

1. A helicopter may be operated at less than the minimums prescribed in paragraph (b )or (c) of 

this section, provided each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and 

2. A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph© of this section. 

Section 91.121 requires, in pertinent part, 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". 

Section 91.151(a) prescribes that no person may begin 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 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. (emphasis added) 

Section 91.405 (a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as 

prescribed in part 43 of the chapter. 

Section 91.407 (a)( 1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under Section 43.7 ofthe same chapter. 

Section409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had an inspection for the issuance of an of an 

airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that-

(a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) ofthis section: 

1. Records ofthe maintenance, preventative maintenance, and alteration and record ofthe 100-

hour, annual, progressive, and other required or approved inspection, as appropriate, for 

each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an 

aircraft. The records must include -

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669 
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1. 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 

111. 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 oflife-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

111. The time since last overhaul of all items installed on the aircraft which are required to 

be overhauled on a specified time basis. 

tv. 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. 

vt. Copies of the forms prescribed by Section 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

1. The records specified in paragraph (a)(1) ofthis section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

2. 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. 

3. A list of defects furnished to a registered owner or operator under Section 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for return 

to service 

Unmanned Aircraft System 

The Petitioner states that the unmanned aircraft(s) (UA) to be operated under this request is less 

than 55 lbs. fully loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within 

a secured areas as set out in the POH. The crafts are as listed: 

• (2) Steadi Drone QU40 2014- four blade craft, four motor VTOL design, GPS, full 

autonomous autopilot capabilities, telemetry and manual ground control. 

• (2) Sensefly ebee- fixed wing, forward flight only, single motor design, GPS, full 

autonomous autopilot capabilities, telemetry and manual ground control. 

• Birds Eye View Aerobotics- FireFLY 6- 6 blade craft, three motor VTOL design, GPS, full 

autonomous autopilot capabilities, telemetry and manual ground control. 

• DJI Phantom 4 - four blade craft, four motor VTOL design, GPS, full autonomous autopilot 

capabilities, telemetry and manual ground control. 

In addition, the above listed crafts have integrated safety features built into the design of the UAS, 

as described in the POH, to ensure the safety of persons and property within and surrounding the 

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669 
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limited operating area. The Petitioner further describes that, in the event the UAS loses 

communications or its GPS signal, the UA will have the capability to return to a pre-determined 

location within the Security Perimeter and land. It will also have the capability to abort a flight in 

the event ofunpredicted obstacles or emergencies. 

Pre-llight Inspection, Maintenance 

Before each flight the PIC will perform a series of pre-flight and takeoff checks as determined by 

the POH supplied. After each 60 minutes of airtime, the craft will undergo a thorough inspection 

of all aircraft components, including, but not limited to: 

a. Actuators I Servos 

b. Motors, wiring and connectors 

c. Propellers/Wings, smooth, no chips 

d. Electronic speed controller, wiring and connectors 

e. Batteries, wiring and connectors 

f. Remote command and control 

g. Ground control station 

UAS Operating Parameters 

The Petitioner states that all flights will be operated with visual line of sight (VLOS) if pilot, in 

daytime VFR flight conditions and all operations will be conducted with the assistance of a second 

spotter/observer. The UAS flights will be limited to a maximum altitude of 4oo feet AGL. 

Altitude is accurately measured by GPS. The Petitioner further states that an operator will ensure 

that only consenting production personnel will be allowed within 100 feet ofthe UA operation, and 

UAS will be kept at least 100 feet from any inhabited structure. Generally, the Petitioner's UAS 

will be operated in rural or suburban areas that will permit significantly larger safety zones. 

Flight Standards District Offices (FSDOs) will be notified, as required, prior to operation to 

describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic 

Organization ("ATO") issued Certificate ofWaiver or Authorization ("COA'') prior to conducting 

any operations under this grant of exemption. In fulfilling its requirements under the COA, 

Petitioner will be required to request a NOT AM not more than 72 hours in advance, but not less 

than 48 hours to the operation. 

Petitioner's UAS will remain clear and yield the right of way to all manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5 nautical 

miles of the geographic center of a non-towered airport unless a letter of agreement with that 

airport's management is obtained and the operation is conducted in accordance with a Notice to 

Airman (''NOT AM"). 

Pilot in Command (PIC) 

The Pilot in Command will be James Wise. He received his Private Pilot License with MultiEngine and Instrument Rating and has logged more than 200 hours in fixed wing types of aircraft. 

(Certification #3498396) 

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669 
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Regarding Petitioner's requested relief from 14 C.F.R Section 91.1 03(b )(1 ), Petitioner will comply 

with the other applicable procedures and requirements stated in Section 91.103(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, 

aircraft performance data, and landing and takeoff distances before initiation of a flight. The PIC 

will also account for all relevant site-specific conditions in their preflight procedures. Risks 

presented by sun glare will be mitigated by the PIC's and YO's ability to see other air traffic and 

initiate a return-to-home sequence if needed. 

Radio Frequencies 

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle control 

in unlicensed frequency bands. All devices used will comply with FCC usage and emissions 

regulation. 

Safety Benefits of the UAS 

The Petitioner will be using the UAS in a variety of applications that generally require expensive 

full-sized manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad 

benefits over the use of full-sized manned aircraft for inspection of large civil construction sites, 

electric power lines inspection, advanced agriculture, film and still photography, just to name a 

few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small 

UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and 

crew. By granting Petitioner's requested exemptions, the FAA will help drive development of safe 

and successful commercial UAS operations and will advance the public knowledge base for such 

operation. Petitioner is committed to promoting the UAS research efforts ofpolicymakers 

including the FAA, NASA, DOD, and DARPA by sharing data from its commercial UAS 

operations and serving as a resource for suture UAS research operation. Thus, the FAA has good 

cause to grant this Petition. 

Conclusion 

For the foregoing reason, the exemptions requested herein should be granted and Petitioner should 

be permitted to conduct small UAS operations in accordance with its manuals and all other 

operating parameters deemed necessary and appropriate by the FAA 

P.O. Box 14709 * Ft Pierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669