**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 filmmakin g, 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 com pared 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 A GL. 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 emplo yees 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 pe rmits, 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 e quipment 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/Vide ography 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 proce dures 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. Airworthines s 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 a ccount 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 willbe available to FAA for use in collecting data regarding the use of sUAS as part of this application. This

data may be submi tted 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 turnaroun d 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 Specification s** 
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 C ustomizable 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 y our cooperation in this matter.

Sincerely,

Matthew S. Blaskowski