Blackhawk Drones Group, LLC, Nevada – Section 333 Exemption Petition

Aug 31, 2015

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 

91.119(a)(b), 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(2); and 14 C.F.R. 417(a)&(b)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Blackhawk Drones Group, LLC (“Blackhawk Drones”), the owner and 

operator of the 3DR IRIS quad-copter Unmanned Aircraft System (UAS), seeks an exemption 

from the Federal Aviation Regulations (“FARs”) listed below so that Blackhawk Drones can 

operate our small ultra-light weight UAS commercially in airspace regulated by the Federal 

Aviation Administration (“FAA”). Blackhawk Drones will utilize an experienced, licensed pilot 

holding an FAA third-class airman medical certificate as the operator(1) (Pilot in Charge [PIC]) 

and a visual observer (VO) (2) that can perform the functions prescribed in the operating manual 

for all flights under this Exemption, if granted.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to perform aerial mapping to enhance academic community

awareness, augment real estate listing videos, filmmaking, golf course mapping, agricultural 

mapping, and photogrammetry for various industries.

Use of the 3DR IRIS UAS for aerial mapping reduces the need to operate conventional aircraft 

for the same purpose and provides very high quality imagery at a fraction of the dollar cost and 

danger to human life (3) of using conventional aircraft. By approving these exemptions,

1. See Appendix A for PIC qualifications and certifications. 

2. Note; the VO will not be operating the UAS. 

3. See National Aeronautics and Space A dministration.2000.U.S. Civil Rotorcraft Accidents,1963 Through

1997.http://www.ihst.org/portals/54/industry_reports/NASA%20TP%20209597.pdf 2
the FAA will create benefits through safer survey methods by UAS, resulting in decreased 

potential for loss of life and enhanced efficiency and productivity for the affected activities, as 

well as environmental benefits, which are all ultimately in the public interest.

Committed to safety with each flight, Blackhawk Drones, exemption request would permit 

operation of ultra-light weight, unmanned (piloted by remote control) and comparatively 

inexpensive UAS in tightly controlled and limited airspace. Currently, similar lightweight, 

remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety 

plan or controls in place to prevent catastrophe. In addition, Mr. Christopher C. Knight, Dark 

Technologies, LLC (Exemption No. 12368) and - Steve Fincher Photography (Exemption No. 

11859) were granted exemptions for these types of surveys with the 3DR IRIS.

Blackhawk Drones has created and will follow its UAS Flight Protocols and Controls for safe 

operation to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. 

This will act to further safety protocols exclusive to lightweight UAS's specific video and 

photography usage as Blackhawk Drones records flight data and other information gained 

through permitted flight operations to share with the FAA through any required FAA reports to 

assist with future protocol and safety regulation.

Granting Blackhawk Drones request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes. Further, Blackhawk Drones, will conduct its own 

operations in compliance with the protocols described herein or as otherwise established by the 

FAA.

For the reasons stated below, Blackhawk Drones, respectfully request the grant of an exemption 

allowing Blackhawk Drones to operate ultra-light weight, remote controlled UAS’s for 

community awareness, enhance real estate listing videos for homeowners, filmmaking, golf 

course mapping, agricultural mapping, and photogrammetry for various industries. All of which 

will promote local economic growth through increased employment and increased tax base. Both 

with public safety in mind by keeping heavier manned aircraft containing combustible fuel that 

that poses potential public hazard.

4. See Helicopter Accident Analysis Team. 1998. The Final Report of the Helicopter Accident Analysis Team. June

1998.http://www.ihst.org/portals/54/industry_reports/HAATFinalReport.pdf

5. See Appendix B. for Blackhawk Drones UAS Flight Protocols and Safety Controls. Applicant submits this manualas a confidential document

under 14CFR11.35(b). The manual contains proprietary information that the applicant does not wish to be shared publically . The manual

contains operating. Requirements and procedures that are not available to the public and are protected from release under the Free domo

Information Act 5USC552.
I. Contact Information, Antony Fritsche 

Blackhawk Drones LLC 4255 Ranchita Way, Reno, Nevada, 89502 

Mobile: (775) 250-8745 Email: Tony@RealtyCorner.com
II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Blackhawk 

Drones Requests Exemption are: 

14 CFR Part 21;14 C.F.R. 45.23(b);14 C.F.R. 91, et seq.;14 CFR 407 (a) (1);14 CFR 409 (a) (2); 

and, 14 CFR 417 (a) & (b).

III. The Extent of relief Blackhawk Drones seeks and the Reason Blackhawk Drones Seeks 

Such Relief:

Blackhawk Drones submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FARs operating to prevent Blackhawk 

Drones contemplated commercial cinematic, academic and other flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do 

so. Blackhawk Drones’, ultra-light weight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of Blackhawk Drones ultra-light 

weight UAS is expressly contemplated by the Reform Act. Blackhawk Drones would like to 

operate its ultra-light weight UAS prior to the time period by which the Reform Act requires the 

FAA to promulgate rules governing such craft. Thereby, providing direct experience and 

valuable information for formal regulation that can be administered uniformly to all agriculture, 

mapping, and real estate related UAS aerial video and photography.

The Reform Act guides the Secretary in determining the types of UAS's that may operate safely 

in our national airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated 

areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of 

these items reflect in favor of an exemption for Blackhawk Drones. Blackhawk Drones UAS 

utilizes four (4) counter-rotating propellers for balance, control and stability. Weighing less than 

five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. 

Blackhawk Drones UAS is equipped with a compass, GPS, auto return safety technology if 

communication is lost between the UAS and the controller, Real-Time Fight Data Display6, and 

a No Fly Zone7 software default setting to force the device to abide by International Civil 

Aviation Organization regulations.

Blackhawk Drones considers safety as foremost with each flight. Blackhawk Drones small UAS 

is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For 

safety, stability and fear of financial loss, Blackhawk Drones will not fly in winds exceeding 16 

kph (10 mph) nor exceed an indicated airspeed of 29 knots (15 m/s). Built-in safety systems 

include a GPS mode that allows Blackhawk Drones’s UAS to hover in place when radio controls 

are released. With three modes to choose from, Blackhawk Drones will utilize the Smart Mode 

for aerial videography/photography. This is the safest, most reliable and stable mode to prevent 
accident and hazard. When PIC communication is lost, Blackhawk Drones’s UAS is designed to 

slowly descend to point of take-off (Return to Home). Blackhawk Drones will not operate the 

UAS near Airports, Hospitals, nor Police heliports, and will not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions and 

weather. Blackhawk Drones’s PIC and VO will be on constant alert for any manned aircraft 

(Police/Medical helicopters, etc.) or other UAS, and prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft or UAS approach Blackhawk Drones’s 

location, or Blackhawk Drones suspects manned aircraft or UAS may approach near our 

location. Blackhawk Drones’s UAS is capable of vertical and horizontal operations, and is only

flown within the line of sight of both the PIC and VO.

Utilizing battery power rather than combustible fuels, flights with Blackhawk Drones’s UAS

generally last between five (5) to seven minutes, with an altitude under 400 feet. Blackhawk 

Drones will utilize a fresh fully charged battery with each flight as a safety precaution; full flight 

time limit for each battery is nine (9) to 12 minutes as tested. Blackhawk Drones will not operate 

our UAS at or below manufacturer recommend minimum charge levels for operation; preferring 

to remain well within a safe operating range to insure adequate communication between radio 

control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are 

at hand with each exercise to insure replacement for sufficient safe level of operation.

Blackhawk Drones does not believe in taking risk that may cause a crash that could create hazard 

to the public/property/manned aircraft, and have no desire to lose an investment. Blackhawk 

Drones has clocked numerous practice flights in remote areas as a hobbyist simulating flights for 

future commercial use to gain familiarization with the characteristics of this specific UAS's 

performance under different temperature and weather conditions. Blackhawk Drones also 

practices computerized simulated flights to maintain adequate skills and response reflex time, for 

the sake of safety.

Blackhawk Drones is extremely cautious when operating any UAS and will not “create a hazard 

to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b).

6. Real-Time Flight Data includes UAS flight height, horizontal speed, vertical speed, and distance from the PIC. 

7. 3DR’s “NoFlyZone” : Two classes in this mode limit the 3DR IRIS’s ability to fly near restricted airport air space. Class A will not allow the

UAS to take off within 1.5 miles of the GPS location of an airport. Class B will has incorporated an increasing height limit from 35 feet AGL at

1.5 miles from an airport, increasing to 400 feet at 5 miles an airport. The UAS control system will also automatically warn the PIC when the

UAS has approached within 330 feet of the 5-mile buffer zone around an airport. This software will also not allow the user to set GPS waypoints

within 5 miles of the 5-mile No Fly Zone around an airport. For further details, visit http://www.3dr.com/fly-safe/iris/category-mc. 
Given the small size and weight of Blackhawk Drones’ UAS, it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the corresponding directive 

to integrate UAS's into the national airspace system. Blackhawk Drones UAS, used in hobby

flight, has a demonstrable safety record and does not pose any threat to the general public or 

national security.

IV. How Blackhawk Drones Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness in real estate, filmmaking, golf course mapping, 

agricultural mapping, and photogrammetry for various industries has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget companies, farms and 

average homeowners, the expense of manned aerial videography is cost prohibitive. Only large 

companies can afford to absorb such expense, this depriving the remainder of the public from a 

valuable marketing and mapping tool. Manned aircraft pose a threat to the public through 

potential catastrophic crash that Nevada has experienced in the past with private and public 

officials involved in crashes in recent years. 

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Granting 

Blackhawk Drones exemption request furthers the public interest through academic/visual 

awareness of the geographical benefits around Nevada. Blackhawk Drones ultra-light weight 

UAS is battery-powered and creates no emissions that can harm the environment. The 

consequence of my ultra-light weight UAS crashing is far less than a full size helicopter or fixed 

wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation 

to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through our battery operated ultra-light weight UAS's. Permitting 

Blackhawk Drones to immediately fly within national air space furthers economic growth by

offering cost-effective videography and mapping products.

V. Reasons Why Blackhawk Drones Exemption Will Not Adversely Affect Safety Or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

Blackhawk Drones exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated, permitting Blackhawk Drones to log more flight time in FAA controlled airspace, 

with communication with the FAA, will allow us to contribute to the innovation and 

implementation of new and novel techniques for realtors, filmmaking, golf courses, agricultural 

mapping, and photogrammetry for various industries as well as continuing to educate the public 

through publishing articles. In addition, Blackhawk Drones submits the following representations 
of enhancements to current aerial videography and photography for real estate, filmmaking, golf 

courses, agricultural mapping, and photogrammetry for various industries:

 Blackhawk Drones UAS weighs less than 5 pounds complete with a small ultra-light 

weight high quality GoPro 3 Black camera;

 Blackhawk Drones will only operate this UAS below 400 feet, as recommended by the 

FAA Modernization and Reform Act of 2012;

 Blackhawk Drones UAS will only operate for 10 minutes per flight;

 Blackhawk Drones will land this UAS prior to manufacturer recommended minimum 

level of battery power, 30% battery power remaining. Also, Blackhawk Drones UAS has 

an automated function which results in immediate landing when a low battery is detected;

 Blackhawk Drones will pilot this UAS through remote control by line of sight;

 Blackhawk Drones UAS has GPS-controlled autopilot system to maintain UAS stability

and control,

 Blackhawk Drones UAS has an Auto Return-to-Home & Landing function to increase 

safe return of the UAS to the ground, 

 A pre-programmed flight safety feature whereby Blackhawk Drones UAS automatically

hovers and then slowly lands if communication with the remote control pilot is lost;

 Blackhawk Drones will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols;

 Blackhawk Drones will only operates in reasonably safe environments that are strictly 

controlled and are away from: power lines, elevated lights, airports and actively

populated areas;

 Blackhawk Drones will conduct extensive pre-flight inspections and protocol review, 

during which safety carries primary importance;

 Any maintenance or alterations of Blackhawk Drones UAS that could affect operation or 

flight characteristics will require a functional test flight before returning to work;

 Blackhawk Drones will always obtain all necessary permissions prior to operation, 

including issuing a notice-to-airmen (NOTAM) prior to operations; and,

 Blackhawk Drones will have procedures in place to abort flights in the event of safety 

breaches or potential danger. 

In recognition of the FAA’s Exemption No. 11304A, and specifically Exemption No. 12368 for 

the same UAS model (3DR IRIS); prior to conducting operations for the purpose of aerial 

photography/videography, Blackhawk Drones’s PIC will have accumulated 25 hours of total 

time as a UAS rotorcraft pilot including at least 10 hours as a UAS pilot with a multi-rotor UAS. 

Prior to operations, Blackhawk Drones PIC must also have accumulated a minimum of 5 hours 

as a UAS pilot operation the 3DR IRIS 2. In addition to the hour requirements, the PIC must 

accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes).
Blackhawk Drones, safety protocols provide a level of safety equal to or exceeding existing 

rules. It is important to note that absent the integration of commercial UAS into our national 

airspace system, helicopters are the primary means of aerial video and photography for 

community awareness and real estate. While the safety record of such helicopters is astounding, 

there has been local incidents involving loss of life as well as extensive property damage; it is far 

safer to operate a battery powered ultra-light weight UAS.

 First, the potential loss of life is diminished because UAS's carry no people on board and 

Blackhawk Drones will only operate its UAS in specific areas away from mass 

populations.

 Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished.

 Third, the small size and extreme maneuverability of Blackhawk Drones UAS allow the 

PIC to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its 

small size and weight, even when close enough to capture amazing images, Blackhawk 

Drones UAS need not be so close to the objects they are focused on through the 

technology and use of post editing software allowing pan and zoom.

Accordingly, Blackhawk Drones UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

Furthermore, Blackhawk Drones PIC has accumulated 40 hours of total time as a UAS multirotor pilot. Blackhawk Drones’s PIC has also accumulated more than 20 hours as a UAS pilot 

operation the 3DR IRIS.

VI. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Blackhawk Drones UAS permits exemption from Part 

21 because Blackhawk Drones UAS meets (and exceeds) an equivalent level of safety pursuant 

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. Blackhawk Drones current UAS 

meets or exceeds each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. However, Blackhawk Drones PIC will still ensure that the UAS is in an airworthy

condition based on compliance with the operating documents prior to every flight.
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas where safety can be defined9. The FAA has previously issued exemptions to this regulation 

in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 

and 32827. However, Blackhawk Drones UAS operations manual will be kept in a location 

accessible by Blackhawk Drones PIC.

14 C.F.R. § 91.103 regarding preflight action. Blackhawk Drones PIC will take certain actions 

before flight to ensure safety of the flight. These will include reviewing weather, flight battery

requirements(9), landings, and takeoff distances and aircraft performance data before initiation 

of the flight.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Blackhawk Drones

UAS utilizes electronic GPS with a barometric sensor. According to the manufacturer of 

Blackhawk Drones UAS, the GPS sensor is accurate to 2.6 feet Vertical and 8.2 feet Horizontal. 

These accuracies are adequate for Blackhawk Drones to safely operate the UAS for its exempted 

purposes.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by

Blackhawk Drones in a location accessible by Blackhawk Drones PIC. (9)SeeAppendix B. and 

C.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Blackhawk Drones’s UAS, by definition, is unmanned. Therefore the UAS does 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is difficult to place on such small aircraft with dimensions smaller that 

minimal lettering requirement. The FAA has previously issued exemptions to this regulation 

through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119(a) and (b) prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Blackhawk Drones’s UAS will 

never operate at an altitude greater than 400 AGL; safely within the standard 400 AGL as 

recommended by the FAA Modernization and Reform Act of 2012. Blackhawk Drones will 

however operate its UAS in safe areas away from areas depicted in “yellow” on VFR charts, 

providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes. Blackhawk Drones will conduct all operations under Blackhawk Drones’s Protocols 
and Controls10, including posting a warning sign reading: “Attention Aerial Photography in 

Progress – Remain Back 150 Feet”. Blackhawk Drones will operate its UAS in accordance with 

Exemption No. 11109, which may require the UAS be operated closer than 500 feet to essential 

persons. Non-participating persons must remain at appropriate distances (500 feet) from the 

UAS, and if they need to be closer than 500 feet, non-participating persons will remain behind 

barriers or structures that can sufficiently protect them from the UAS debris in the event of an 

accident. Given the size, weight, maneuverability and speed of Blackhawk Drones’s UAS, an 

equivalent or higher level of safety will be achieved.

D. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] aircraft inspected as prescribed in subpart E of this part and shall between required 

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

prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Blackhawk Drones' UAS. However, as a safety precaution Blackhawk 

Drones’ PIC and VO will inspect Blackhawk Drones’ UAS before and after each flight.

(10)See Appendix B.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and the Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Blackhawk Drones’ UAS permit exemption from Part 

21 because Blackhawk Drones’ UAS meets an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Blackhawk Drones’ UAS meets or exceeds each of the 

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA 

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety will be 

achieved.
In summary, Blackhawk Drones seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 

91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119 (a)(b); 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. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 

C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to 

commercially operate Blackhawk Drones’ small unmanned vehicle/lightweight unmanned 

aircraft vehicle in community awareness, real estate operations, filmmaking, golf course 

mapping, agricultural mapping, and photogrammetry for various industries and to develop 

economic platforms for real estate and golf courses.

Currently, area awareness, filmmaking, real estate aerial videography/photography, golf course 

mapping, agricultural mapping, and photogrammetry for various industries relies primarily on 

the use of larger aircraft running on combustible fuel, posing potential risk to the public. 

Granting Blackhawk Drones’ request for exemption will reduce current risk levels and thereby

enhance safety. Blackhawk Drones’ UAS craft does not contain potentially explosive fuel, is 

smaller, lighter and more maneuverable than conventional real estate video and photographic 

aircraft with much less flight time. Further, Blackhawk Drones will operate at lower altitudes and 

in controlled airspace eliminating potential public risk flying to and from established air fields. 

Blackhawk Drones has been informally analyzing flight information and will compile safety

protocols and the implementation of a flight operations manual for real estate usage that exceeds 

currently accepted means and methods for safe flight. Formal collection of information shared 

with the FAA will enhance the FAA's internal efforts to establish protocols for complying with 

the FAA Modernization and Reform Act of 2012.

There are no personnel on board Blackhawk Drones’ UAS and therefore the likelihood of death 

or serious bodily injury is significantly diminished. Blackhawk Drones’ operation of its UAS, 

weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Accordingly, Blackhawk Drones

respectfully request that the FAA grant Blackhawk Drones’ exemption request and Blackhawk 

Drones is willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large.

Respectfully submitted,

Anthony Fritsche Blackhawk Drones, LLC 4255 Ranchita Way. NV 89502

Mobile: (775) 250-8745 Company (775) 410-4042 or Tony@RealtyCorner.com