1/20/16 Blue Water Aerial Camera Co. U
.S Department ofTransportation 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 : Ifthe following exemptions are granted from FARS Blue WaterAerial 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 orfuture 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 offlight
. 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 offweight. 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 ifsupplied 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 1The 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 3times a week at about 20-25 minutes perflight
. Again, as a hobbyist. The Blade Chroma is currently registered with the FAA, #FA3YPEMYYC. I had been a member ofThe AMA and The Greater Southwest Aero modelers Club of Fort Worth TX in the past but not currently
. I carry avalid 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 acresand beyond. Using multiple take off locations to retain line ofsight 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 ofsight (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, ifgranted 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 ofsafety under current regulatory guidelines. *The UAS will weigh lessthan 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 offlight. PAGE 2*Flight will be daytime only. *Flight will be conducted with the PIC, a visual observerVO, and using visual line ofsight 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 atthistime. *Pre-flight meetings will be conducted ahead offlight operations
. *The PIC will abort flight in changing weather conditions or ifobstacles 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 orverbal. *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: BluewaterAriel 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; 14CFR 91.105; 14CFR 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 1491.407(a)(1); 14 CFR 91.409(a)(1)(2); 14 CFR 91.417(a)(b).

PAGE3Requested exemptions: 14 CFR Part 21 , Subpart H---Airworthiness Certificates Given the size and limited operational area ofthe UAS an exemption could be granted. The UAS demonstrates no threat to National Security due to its size, speed, lack ofexplosive materials or flammable fuels and inabilityto carry a substantial payload. 14 CFR Part 27---AirWorthiness Standards. Reasoning; Same as above. 14 CFR 61.113---Private Pilot Privileges and limitations
. The UAS does not carry a pilot, crew or passengers. Norflammable 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 ofthe 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 ofthe UAS and the PIC is not actually onboard 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 ofsafety can be maintained bythe 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. 14 1 CFR 91.109(a}---Fiight Instruction. The UAS does not have dual controls. Due to the size and speed ofthe 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 underthose rules and guidelines. PAGE414 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 ofthe 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 atthe transmitter. 14 CFR 91.151(a)--- Fuel requirements forflight 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 flyfor upto thirty minutes. Limiting actual flight time to 20 minutes with 10 minutes of reserve lithium ion battery power should apply an equivalent level ofsafety. 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 ofthe 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 thatthe 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 ofthe Reform Act of 2012 for size, weight, speed, operations and proximity to airports, populated areas and using VLOS provides morethan enough justification forthe grant ofthe 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 loweringthe 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 Takeof f Location WeatherReport Expected wind speeds (if>20knots, do not fly) UAS Maintenance Status Status offirmware InspectMotors Inspect Props Nearest town Nearest Airport: Distance From? Max Elevation Max Speed Approval from landowner(s) Intendedpurpose offlight CheckNOTAM FSDO approval RequestCOA Pilot Name Visua1 Observer (VO) Name Duties of VO Expect ed duration offlight Time of Sunrise Time ofSunset Boundaries offlight plan Characteristics ofterrain Review obstacles within flight plan Review obstacles adjacent to plan boundaries Potential hazards within flight plan Emer gency landing scenario

# Pre-Flight Checklist Pre-Flight Checklist Yes No NA Comment Currentweatheronsite Does visibility exceed 3nm Battery Status ofUAS (%) 

### Battery Status offlight controller (%) 

### Battery Status offlight 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 FlightMode to the correctpositioning (P) mode Turn on remote controller Insert Battery into UAS Ensure UAS 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 flyFlightLogBatteryBatteryLocationPICvoActivityBeforeAfterComments

# Flight Authorization Form By signing below, you are granting ' permission to operate their sUAS within 500 feet ofthe specified person(s),vehicle(s), vessel(s) , and structure(s) to which you own orhave authority over_ 

### only on the date specified. 

### Relation to ObjectsUAS Date Name Location Operation will fly 

### over Signature