1/20/16 Blue Water Aerial Camera Co. 

U.S Department of Transportation 5455 Blue Water Lake Dr. 

Docket Management System Fort Worth, TX 76137 

West Building Ground Floor, Room w12-140 John D Mortensen 

RE: Exemption request Section 333 of the FAA Reform Act. C.F.R. 14. Part II. 

Dear Sir or Madam: 

If the following exemptions are granted from FARS Blue Water Aerial Camera Co (The Company) will be 

a small family owned and operated business in low altitude and lightweight (under 55 lbs.) UAS still and 

video photography. Following any and all guidelines, present or future set forth by the FAA. 

Blue Water Camera Co. would provide services to public and private sector clients possibly including: 

New Construction of large commercial construction projects. 

Large warehouse and factory exterior applications. 

Real estate Developers. 

Survey 

Construction Inspection. 

Environmental work and inspection. 

The Company would benefit the public in various ways including safety aspects. Improving safety and 

lowering risk by cutting down human exposure to danger in work at height. IE: climbing ladders, walking 

large commercial roofs and construction sites, using boom lifts and the dangers of low altitude 

conventional forms of flight. Also, allowing more frequent and cost effective UAS visual flight data and 

inspection as the UAS carries no pilot, passenger or payload except the onboard camera. The UAS leaves 

no carbon footprint and no noise pollution. The UAS reduces risk and increases safety when applied to 

the above mentioned applications. 

The current UAS proposed is the Blade Chroma 4k Camera Drone by Horizon Hobbies. Model # BLH8675 

The Blade Chroma weighs 2.91bs at lift off weight. It utilizes both horizontal and vertical GPS lock and 

stabilization. Safety features include a "home" switch that can bring it back to the take off point and 

land it on its own, if needed. A sixteen foot safety circle for the operator in some modes. Automatic 

landing if supplied voltage becomes too low. The radio system (transmitter) is the Yuneec ST 10+. It 

complies with FCC Part 15 rules. The ST 10+ transmitter continually updates altitude, distance, GPS Lock, 

GPS coordinates, battery levels and FPV. PAGE 1 
The current PIC (Pilot in Command) would be I, John Mortensen. An R/C Hobbyist for 10 years, I have 

been flying R/C gas powered airplanes, running gas powered trucks and boats, electric helicopters, and 

flying model rocketry as a hobbyist. I have been flying Blade Drones (UAS) as a hobbyist for 3 years with 

no incidents. I am 60 years old with no health issues and an American Citizen living in Fort Worth TX. 

Currently flying the Blade Chroma 3 times a week at about 20-25 minutes per flight. Again, as a hobbyist. 

The Blade Chroma is currently registered with the FAA, #FA3YPEMYYC. I had been a member of The 

AMA and The Greater Southwest Aero modelers Club of Fort Worth TX in the past but not currently. I 

carry a valid Texas Driver's License and a United States Passport. Though I have no plans to use a UAS 

outside the United States. 

Operations would include, but not limited to, photo and video capture of large commercial construction 

projects, large warehouses (exterior) , business parks, acreage and real estate. Most ofthese type of 

commercial projects can take up anywhere from 5 to 15 acres and beyond. Using multiple take off 

locations to retain line of sight flight. Flying criteria would be below 400' . Not operating less than 500 

feet below or less than 2000' horizontally from a cloud when visibility is less than 3 statute miles from 

the PIC. 

Maximum operating speed is less 26 knots. Flight is line of sight (VLOS) to maintain safety and 

transmitter/receiver contact. Also including "return home" and auto landing on power loss safety 

features. 

Flight log, Mission plan, Pre-flight checklist and Flight Authorization forms are included in this 

correspondence. 

Both the UAS and Blue Water Camera Company will be insured with Commercial General Liability 

Insurance. 

+Blue Water Aerial Camera Company, if granted exemptions requested, intends to secure a Certificate 

of Waiver Authorization from the FAA. 

Limits and Conditions of Operation which will achieve an equivalent or higher level of safety under 

current regulatory guidelines. 

*The UAS will weigh less than 55 lbs. 

*The UAS will not be operated at speed exceeding 30 knots. 

*Pre-flight inspections will be made and logged. 

*Maximum ' flight time will be 20 minutes, leaving a 10 minute window to return home. The ST-10+ 

transmitter tracks both the UAS and transmitter battery levels. 

*Flight will never exceed 400' AGL. 

*Flight will be at least 500' from non-participants, vehicles or structures unless an approval is granted 

and recorded ahead of flight. PAGE 2 
*Flight will be daytime only. 

*Flight will be conducted with the PIC, a visual observer VO, and using visual line of sight at all t imes. 

VLOS. 

*The UAS will operate using a pre-planned flight path. 

*Weather and wind speed will be considered ahead of planned flight. 

*Flight will be conducted SNM outside of airport reference point. ARP. As called out in the current FAA 

Airport/Facility Directory. AFD. 

*The operator/PIC has and will have over 5 hours operating Blade Camera Drones, UAS, within in any 

previous 90 day period as my UAS is registered with the FAA and flown as a hobby at this time. 

*Pre-flight meetings will be conducted ahead of flight operations. 

*The PIC will abort flight in changing weather conditions or if obstacles or emergencies arise. 

*Any required permissions or permits will be obtained from private representatives, territorial, state, 

county or city entities including law enforcement and fire depts. if required. Written or verbal. 

*The PIC will perform continuing education in regards to the current Blade Chroma Camera Drone and 

other UAS under 55 lbs. 

*This applicant will obtain a Certificate of Waiver or Authorization (COA) before conducting commercial 

UAS operations in the NAS. (As required.) 

*Any incident, accident or boundary transgression as determined by and within the COA will be 

reported within 24 hours to the FAA's UAS Integration Office and all accidents will be reported to the 

NTSB. National Transportation Board. 

If required by 14 CFR Part 11 this summary is provided for publ ication in the Federal Register, should 

publication become necessary: 

Bluewater Ariel Camera Company requests an exemption from the following rules. 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 45.27(a); 14 CFR 61.113; 14 CFR 91.7(a); 

14 CFR 91.9 (b)(2); 14 CFR 91.9(c); 14 CFR 91.103; 14 CFR 91.105; 14 CFR 91.109(a); 14 CFR 91.119; 14 

CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)(b); 14 CFR 91.405(a); CFR 14 91.407(a)(1); 14 CFR 

91.409(a)(1)(2); 14 CFR 91.417(a)(b). 

PAGE3 
Requested exemptions: 

14 CFR Part 21, Subpart H---Airworthiness Certificates 

Given the size and limited operational area of the UAS an exemption could be granted. The UAS 

demonstrates no threat to National Security due to its size, speed, lack of explosive materials or 

flammable fuels and inability to carry a substantial payload. 

14 CFR Part 27---Air Worthiness Standards. 

Reasoning; Same as above. 

14 CFR 61.113---Private Pilot Privileges and limitations. 

The UAS does not carry a pilot, crew or passengers. Nor flammable fuels. It is flown in controlled areas 

from the ground with VLOS and an observer. Obtaining a private pilot's license or airmen's certificate 

would be a hardship to the small business. 

14 CFR 91.9(c}, 45.23(b}, and 45.27(a}--- Aircraft Marking and Identification Requirements. 

Considering the size of the UAS it can be marked with letters and numbers as large as practicable. 

14 CFR 91.9(b}(2}---Civil Aircraft Flight Manual in the Aircraft. 

An exemption could be granted because given the size of the UAS and the PIC is not actually on board 

operations manuals, logs and placards would be kept on the ground with the PIC. 

14 CFR 91.7(a}---Civil Aircraft Worthiness. 

The UAS will be maintained according to manufacturer's instructions and updates. 

14 CFR 91.103---Preflight Action. 

An exemption is requested as an equivalent level of safety can be maintained by the PIC by taking 

preflight actions. Including reviewing weather, flight battery requirements, proposed personal flight 

plan and any obstacles to that plan and aircraft performance data. 

14 CFR 91.105---Fiight Crew members at stations. 

The UAS will not carry a pilot or crew. The PIC and visual observer will be on the ground. 

141CFR 91.109(a}---Fiight Instruction. 

The UAS does not have dual controls. Due to the size and speed of the UAS and the fact that it carries no 

human pilot or passengers an exemption could be granted. If a COA is granted instruction could be 

accomplished under those rules and guidelines. 

PAGE4 
14 CFR 91.119---Minimum Safe Altitudes. 

The UAS will be operated below 400' and away from any person, vessel, vehicle or structure in noncongested areas. Again, size weight and speed of the UAS make it safer to fly at low altitude then 

conventional rotorcraft. 

14 CFR 91.121---Aitimeter Settings. 

The UAS does not have a barometric altimeter. It uses a GPS read out to show altitude and continually 

updates that information to the PIC at the transmitter. 

14 CFR 91.151(a)---Fuel requirements for flight in VFR conditions. 

Given the limitations on the UAS's proposed flight area and its location in a VLOS predetermined area, a 

safety margin of battery use would have to be applied. The Blade Chroma can fly for up to thirty 

minutes. Limiting actual flight time to 20 minutes with 10 minutes of reserve lithium ion battery power 

should apply an equivalent level of safety. 

14 CFR 91.203(a) and (b)---Carrying Civil Aircraft Certification and Registration. 

The UAS load capacity and size does not allow it to carry certification or registration numbers. Any 

registration numbers or markings required can be placed on the hull of the UAS as large as practical. 

14 CFR 91.405(a), 91.407 (a)(1), 91.409 (a)(1), 91.409 9(a)(2), 91.417(a) and (b)----Maintenance 

Inspections. 

An equivalent level of safety will be achieved because the operator or PIC will ensure that the UAS is in 

working order prior to flight using owner's manuals, manufacturers recommendations and updates and 

using a pre-flight checklist. (Attached.) The UAS creates less risk than that associated with conventional 

rotorcraft performing similar operations. 

****Conclusion. 

In satisfying the criteria in Section 333 of the Reform Act of 2012 for size, weight, speed, operations and 

proximity to airports, populated areas and using VLOS provides more than enough justification for the 

grant of the requested exemptions to allow Blue Water Aerial Camera Company to operate in its role as 

a viable aerial data/photography supplier to the public. 

Granting the requested exemptions and issuing a COA for Blue Water Aerial Camera Company can 

benefit the public interest by improving safety and reducing risk by lowering the risk of low level flight I 

operations, improving business performance and bottom line while decreasing operating cost in the 

intended UAS areas of use. While keeping the environment a cleaner and greener place. 

Sincerely, p.~ 

John D. M~nsen, Blue Water Aerial Camera Company. PAGE 5 
Mission Plan Worksheet 

Mission Plan Worksheet Yes No NA Comment 

Takeoff Location 

Weather Report 

Expected wind speeds (if>20knots, do 

not fly) 

UAS Maintenance Status 

Status of firmware 

Inspect Motors 

Inspect Props 

Nearest town 

Nearest Airport: Distance From? 

Max Elevation 

Max Speed 

Approval from landowner(s) 

Intended purpose of flight 

CheckNOTAM 

FSDO approval 

RequestCOA 

Pilot Name 

Visua1 Observer (VO) Name 

Duties of VO 

Expected duration of flight 

Time of Sunrise 

Time of Sunset 

Boundaries of flight plan 

Characteristics of terrain 

Review obstacles within flight plan 

Review obstacles adjacent to plan 

boundaries 

Potential hazards within flight plan 

Emergency landing scenario 
Pre-Flight Checklist 

Pre-Flight Checklist Yes No NA Comment 

Current weather onsite 

Does visibility exceed 3nm 

Battery Status ofUAS (%) 

Battery Status of flight controller (%) 

Battery Status of flight viewer (%) 

Ensure no frequency conflicts with video 

and transmitter 

Check all moving parts and body of 

aircraft for any damage 

Check motor mounts 

Attach propellers 

Inspect landing gear 

Check electrical connections 

Check camera mount is secure 

Check for SD memory card 

Set camera settings 

Set Flight Mode to the correct positioning 

(P) mode 

Turn on remote controller 

Insert Battery into UAS 

Ensure U AS is on level ground and safe 

for takeoff 

Power up UAS 

Ensure LED indicator lights and audible 

tones are correct 

Connect mobile device to remote 

controller 

Acquire satellites for GPS 

GPS Signal Strength 

Ensure Return to Home function is set 

Calibrate Compass 

Check for nearby people, animals, cars 

Announce "Takeoff" 

Hover at 3-5 feet for 30 seconds, listen for 

unusual noise/vibrations 

Confirm safe to fly 
Flight Log 

Battery Battery 

Location PIC vo Activity Before After Commen
Flight Authorization Form 

By signing below, you are granting ' permission to operate their sUAS 

within 500 feet of the specified person(s), vehicle(s), vessel(s), and structure(s) to which 

you own or have authority over_ only on the date specified. 

Relation to ObjectsUAS 

Date Name Location Operation will fly over Signature