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 Modernizatio n 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 thir d

- 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 s upport 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 c onventional 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 2the FAA will create benefits through safer survey methods by

UAS, resulting in decreased potential for loss of life and enhanced efficiency and productivity

for th e 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 c ontrol) and comparativel y inexpensive UAS in tightly controlled and limited airspace. Currentl y, similar lightweight, remote controlled UAS's are legally operated b y unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastro phe. 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 vide o and photograph y 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 sy stem, but to “...establish requirements for the safe operation of such aircraft s y stems [UAS's] in the national airspace s ys tem” 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 herei n or as otherwise established by the FAA. For the reasons stated below, Blackhawk Drones , respectfull y 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 emplo ym ent and increased tax base. Both with public sa fety 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 Repor t 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 . R equirements 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 s ys tem. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national airspace s ys tem as it is in the public’s interest to do
so. Blackhawk Drones’ , ultra

- light weight UAS meets the defin ition of “small unmanned aircraft” as defined in Section 33 1 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 th e time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereb y, providing direct experience and valuable information for formal regulation that can be administered uniformly to all agriculture, mapping, and real es tate related UAS aerial video and photograph y. The Reform Act guides the Secretary in determining the types of UAS's that may operate safel y in our national airspace sy stem. Considerations include: The weight, size, speed and overall capabilities of the UA S' s; Whether the UAS will be operated near airports or heavil y populated areas; and, Whether the UAS will be operated b y 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 safe ty technology

if communication is lost between the UAS and the controller, Real

- Time Fight Data Display 6, and a No Fl y Zone7 software default setting to force the device to abide b y International Civil Aviation Organization regulations. Blackhawk Drones co nsiders 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 fl y in winds exceedi ng 16 kph (10 mph) nor exceed an indicated airspeed of 29 knots (15 m/s). Built

- in safety sy stems 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 videograph y/

photograph y. This is the safest, most reliable and stable mode to preventaccident and hazard. When PI C communication is lost, Blackhawk Drones ’s UAS is designed to

slowly descend to point of take

- off (Re turn 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. Black

hawk Drones ’s PI C 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 Dro nes ’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 PI C and VO. Utilizing battery power rather than combustible fuels, flights with Blackhawk Drones ’s UAS generall y 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 precautio n; 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 ins ure 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 b elieve 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 extremel y cautious when operating an y UAS and will not “create a hazard to users of the national airspace s ys tem 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 IRI S ’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 GP S 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 sy stem 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 wi ll 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 s ys tem. Blackhawk Drones UAS, used in hobby flight, has a demonstrable safety record and does not pose an y threat to the general public or national security. **IV. How Blackhawk Drones**  **Request Will Benefit the Public As A Whole:** Aerial videograph y fo r 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 thre at to the public through potential catastrophic crash that Nevada has experienced in the past with privat e 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 s ys tem, 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 m y ultra

- light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heav y, contain combustible fue l and can cause catastrophic devastation to the public. The public’s interest is furthered b y 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 videograph y 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 photo grammetry for various industries as well as continuing to educate the public through publishing articles. In addition, Blackhawk Drones submits the following representationsof enhancements to current aerial videograph y and photograph y for real estate, fil mmaking, golf

courses, agricultural mapping, and photogrammetry for various industries:

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

- l ight weight high quality GoPro 3 Black camera;

 Blackhawk Drones will only operate this UAS b elow 400 feet, as recommended by the FAA Modern ization 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% batte ry

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 r emote control by line of sight;

 Blackhawk Drones UAS has GPS

- controlle d 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 whereb y Blackhawk Drones UAS automatically hovers and then slowl y lands if communication with the remote control pilot is lost;

 Blackhawk Drones will actively anal yz e 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 strictl y controlled and are away

from: power lines, elevated lights, airport s 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 alway s obtain al l necessary permissions prior to operation, including issuing a notice

- to

- airmen (N OTAM) 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 F AA’s Exemption No. 11304A , and specificall y Exemption No. 12368 for the same UAS model ( 3DR IRI S ); prior to conducting operations for the purpose of aerial photograph y/videography , Blackhawk Drones ’s PIC will have accumulated 25 hours of total time as a UA S rotorcraft pilot including at least 10 hours as a UAS pilot with a multi

- rotor UAS. Prior to operations, Blackhawk Drones PI C must also have accumulated a minimum of 5 hours as a UAS pilot operation the 3DR IRI S 2. In addition to the hour requirements, the PI C must accomplish 3 take

- offs and landings in the preceding 90 day s (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 comm ercial UAS into our national airspace sy stem, 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 los s 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 sp ecific areas away from mass populations.

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

 Third, the small size and extreme maneuverability of Blackhawk Drones UAS allow the PI C to remotel y pilot away from and avoid hazards quickly and safel y. 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. Accordingl y, Blackhawk Drones UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. Furthermore, Blac khawk Drones PI C has accumulated 40 hours of total time as a UAS multi

rotor pilot. Blackhawk Drones ’s PI C 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 L ike. 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 a ircraft 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 o f 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 PI C will still ensure that the UAS is in an airworthy condition based on compliance with the operating d ocuments 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 b e achieved b y m aintaining 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 PI C. 14 C.F.R. § 91.103 regarding preflight action. Blackhawk Drones PI C will take certain actions before flight to ensure safety of the flight. The se 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 UA S 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 safel y 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 certif ications and registrations by Blackhawk Drones in a location accessible by Blackhawk Drones PI C. ( 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) prescribe s 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; safel y within the standard 400 AGL as
recomm ended b y 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 Protocolsand 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 le vel 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, appl y to Blackhawk Drones' UAS. However, as a safety precaution Blackhawk Drones ’ PI C and VO will inspect Blackhawk Drones ’ UAS before and after each flight. ( 10 ) See Appendix B

. A Summary

the FAA May

Pub lish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthi ness 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 p ieces 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 ex ceeds 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 b y m aintaining a manual. The FAA has previousl y 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 wi ll 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 commerciall y operate Blackhawk Dro nes ’ 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 es tate and golf courses. Currently , area awareness, filmmaking, real estate aerial videography /photography , golf course mapping, agricultural mapping, and photogrammetry for various industries relies primaril y on the use of larger aircraft running on combust ible 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 mo re 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 informall y anal yz ing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currentl y accepted means and methods for safe flight. Fo rmal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for compl yi ng with the FAA Modernization and Reform Act of 2012. There are no personnel on board Blackhawk Drones ’ UAS and therefore the likel ihood of death or serious bodily

injury is significantl y 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 c urrent FARs. Accordingly, Blackhawk Drones respectfull y 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 , LL C 4255 Ranchita Way . NV 89502 Mobile: (775) 250

- 8745 Company (775) 410

- 4042 or Tony @RealtyC orner.com