RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam:

I respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal 

Aviation Regulations.

Petitioner:

Matthew Steven Blaskowski

2079 County Road 235

Wedowee, Alabama 36265

Cell: (256) 276-9572 

Email: MattBlaskowski@gmail.com

Matthew S. Blaskowski intends to incorporate the use of sUASs for a variety of projects which may 

include, but not be limited to Jacksonville State University projects; construction management, 

inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; 

educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; 

aerial filmmaking, aerial photography, real estate purposes; search and rescue, etc. 

Specific Section(s) seeking exemption:

14 C.F.R Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) and (b) 14 C.F.R. 91.215

14 C.F.R. 91.104 through 91.417

Extend of relief requested:

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. Said exemption would permit the operation of sUASs under controlled conditions in 

limited, predetermined and controlled airspace. Upon granting of this proposed exemption request, I 

would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333.
Reasons why the exemption would not adversely affect safety or how the exemption would provide 

a level of safety at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when compared with 

helicopters and aircraft for the following reasons:

1. The sUASs will weigh less than ten (10) pounds;

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times may be 

less than thirty (30) minutes as the sUAS will continuously monitor battery reserve and return to the 

ground station with at least 20% battery power reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL;

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer;

6. A briefing will be conducted daily by all personnel working with said sUAS;

7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent 

will be required of all persons within 100 feet of flight operation;

8. Written and/or oral permission from relative property owners will be obtained prior to operating the 

sUAS;

9. All permits, permissions, etc. will be obtained from local government offices as required;

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and 

horizontally;

12. The sUAS will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the sUAS lose communication or GPS signal during any operations;

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies;

14. Operations will not be conducted over densely populated areas or heavily traffic highways; and

15. Operations will not be conducted within five (5) NM of an airport or heliport. 

Matthew S. Blaskowski will abide by all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates;

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks;

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations;

4. 14 C.F.R. 91.7 Civil aircraft airworthiness;

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements;

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests;

7. 14 C.F.R. 91.119 Minimum safe altitudes: general;

8. 14 C.F.R. 91.121 Altimeter settings;

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions;

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required;

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: 

Instrument and equipment requirements;

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use;

13. 14 C.F.R. 91.401 Applicability;
14. 14 C.F.R. 91.403 General;

15. 14 C.F.R. 91.405 Maintenance required;

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration;

17. 14 C.F.R. 91.409 Inspections;

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and inspections;

19. 14 C.F.R. 91.413 ATC transponder tests and inspections;

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 

21. 14 C.F.R. 91.417 Maintenance records.

Additional Information: 

Matthew Steven Blaskowski will be graduating from Jacksonville State University with a Bachelors in 

Arts (Photography/Videography Concentration) and a Computer Science minor in Applied Information 

Processing this December 2015. By gaining this exemption he hopes to be able to use sUAS to create a 

professional Senior Exhibit and start to create a portfolio of aerial works. Having filed for this exemption 

is one of his first steps for continuing his lawful pursuit in this exciting new field.

Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations section and 

believes that the procedures specified therein are reasonable and will be utilized in order to manage and 

mitigate risk and ensure public safety. A preflight checklist will be developed and employed to ensure 

that the UA airworthiness will be verified before launch. Airworthiness will be maintained by 

performance of routine inspections before each flight, maintaining flight and maintenance logs to record 

time on failure prone components. These documents will be made available to the FAA and SoT to assist 

in future implementation of safety standards and regulations. The petitioner will only operate the sUAS 

over designated properties with the owner’s consent. Flight plans will be predetermined to limit the 

sUASs flight time and limit safety concerns. The petitioner will take into account distance from persons 

and potential flight obstacles prior to operating the sUAS. sUAS operation will always be within VLOS 

of the PIC and the observer.

Public Interest

Use of the sUAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact 

as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew 

and flammable fuel. Additionally, use of the sUAS in order to facilitate commerce could lead to economic 

growth. Operations for this petition will enable service for property owners or their designees seeking an 

enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects 

that cannot be displayed through ground level videography/photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance personal photography. Aerial surveying 

and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The 

petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis acting as an 

independent contractor. A visual observer will be utilized. Flight data including UA flight time, Control 

Unit operation time, incident, accident, and details concerning any deviations from normal operations will 
be available to FAA for use in collecting data regarding the use of sUAS as part of this application. This 

data may be submitted to FAA via traditional means or other means as required. 

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, 

videography, inspections and other flight operations”. The reason for such a general and broad based 

request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model is based on the 

idea of offering ad hoc small sUAS services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has 

refrained from engaging in commercial use of the sUAS. The primary purpose of seeking this exemption 

is to obtain the capability to offer those services while remaining in compliance. 

Equipment and Specifications

3DR SOLO KIT ~ 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set – Black, 

3DR Solo Battery Charger, 3DR Solo Controller Charger

Specifications: Up to 26 minutes of flight time (20 with camera and Solo Gimbal), HD video streaming to 

mobile

Top speed: 55 mph Max Altitude: 400ft, per FAA rules

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

Wifi range: up to a half a mile, depending on environment Controller with color screen and live flight 

data Pixhawk 2 flight controller software Customizable color LEDs for orientation

Solo Battery: 14.8 V LiPo (5200mAh)

Rechargeable controller battery: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available) 

10x4.5 self-tightening props

880 kV motors 

Plug and play with 3-axis Solo Gimbal from 3DR

I have attached a more detailed specification document as well as the User Manual for the 3DR Solo 

Drone.

Please feel free to contact me should you have any additional questions or comments. Thank you for your 

cooperation in this matter.

Sincerely,

Matthew S. Blaskowski