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Business Transformations

8 Chipping Woods Ct

Medford, NJ 08055-2154

December 22, 2015

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition of Business Transformations for Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of the FAA 

Modernization and Reform Act 

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. part 11, 

Business Transformations ("BT") hereby petitions the Federal Aviation Administration ("FAA") for 

exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), and any other 

rules the FAA deems necessary, to enable Business Transformations to operate unmanned aircraft 

systems ("UAS") for aerial data collection. Specifically, BT seeks to operate UAS for photography of 

residential and commercial properties, commercial facilities inspection, UAS PIC training under the 

direct supervision of an FAA certified Flight Instructor (CFII) using the Omega Spy Drone, DJI 

Phantom 2, DJI Phantom 3, 3DR Solo, Yuneec Q500+, and the DJI Inspire 1. Because this petition is 

similar in all material respects to previously-granted Section 333 petitions, BT requests expedited 

approval pursuant to the FAA's summary grant process. 

 PROPOSED OPERATIONS

The UAS BT requests an exemption to operate are the Omega Spy Drone, DJI Phantom 2, DJI 

Phantom 3, 3DR Solo, Yuneec Q500+, and the DJI Inspire 1, all of which are well below 55 

pounds including payload. Through the Section 333 exemption process, the FAA has 

authorized use of all UAS for which exemption is requested herein. 

 REQUEST FOR SUMMARY GRANT 

Because this petition is similar in material respects to previous petitions the FAA has granted, 

Business Transformations requests that the FAA issue a summary grant of exemption 

pursuant to the agency's expedited summary grant process. Specifically, the public interest 

and safety benefits Business Transformations' operations will achieve are materially similar 

to those recognized in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 
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FAA-2014-0352), Ill 09 to Clay co, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, 

LLC (see Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA2014-0642). Business Transformations will adhere to a series of operating parameters that 

will offer the same level of safety as the conditions the FAA currently requires in its summary 

grants.

 The name and contact information of the applicant is: 

Charles S. Braddy

President Business Transformations

8 Chipping Woods Court

Medford, NJ 08055-2154. 

Mr. Braddy is an active FAA Certified Flight Instructor, Instrument with over 6,600 hours of 

PIC time, without accident or incident. Mr. Braddy holds a current Class III Medical certificate, 

and has completed the TSA training necessary to conduct pilot training in the United States.

Mr. Braddy is also a Member of the Academy of Model Aviation, and will utilize an AMA 

sanctioned site for all PIC training, under AMA rules and guidelines.

 BT will adhere to the following operating parameters when operating UAS pursuant to a 

grant of the requested exemption: 

1. Operations will be conducted using the Omega Spy Drone, DJI Phantom 2, DJI 

Phantom 3, 3DR Solo, Yuneec Q500+, and the DJI Inspire 

2. The UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour), 

at an altitude greater than 400 feet above ground level, or, when visibility is less than 

3 statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All 

operations will be conducted during the day under visual meteorological conditions. 

3. All operations will be conducted in accordance with a Certificate of Waiver or 

Authorization ("COA''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and 

the UAS will remain within the visual line of sight of the PIC or the VO at all times. The 

PIC will maintain VLOS capability and the ability to communicate verbally with the VO 

at all times. 

5. The PIC will hold an airline transport, commercial, private, recreational, or sport 

pilot certificate, as well as an FAA airman medical certificate or a valid U.S. driver's 

license. The PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate.

6. BT will ensure prior to operation that the PIC has demonstrated the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 
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flight hours and currency will be logged in a manner consistent with 14 C.F.R. § 

61.51(b).

7. BT’s operating documents will be accessible during UAS operations and made 

available to the Administrator upon request. 

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the UAS will not be operated until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe 

flight. 

9. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

will undergo a functional test flight prior to conducting further operations under this 

exemption. 

10. BT will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements, as well as safety bulletins, for the aircraft and 

aircraft components. 

11. The PIC will safely abort the flight in the event of unpredicted obstacles or 

emergencies, and will yield to all manned aviation activities. 

12. Business Transformations will register and mark its UAS in accordance with 14 

C.P.R. parts 47 and 45.

 TERMS OF REFERENCE: 

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United States Code (49 USC) § 

40102) 

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, equipment and services, 

airports or landing areas; aeronautical charts, information and services; rules, regulations and procedures, technical 

information, and manpower and material 

3. Operational Control: with respect to a flight, means the exercise of authority over initiating, conducting or terminating a 

flight (14 CFR § 1.1) 

4. Pilot in Command (PIC): the person who has final authority and responsibility for the operation and safety of the flight; 

has been designated as PIC before or during the flight; and holds the appropriate category class and type-rating, if 

appropriate, for the conduct of the flight (14 CFR § 1.1) 

5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct human intervention from within or 

on the aircraft (P.L. 112-95, Section 331) 

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, including communication links and the 

components that control the unmanned aircraft, that are required for the pilot in command to operate safely and 

efficiently in the national airspace system (P.L. 112-95, Section 331) 

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic Organization to an operator 

for a specific unmanned aircraft activity 
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8. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual contact between a pilot in 

command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know its location, and be 

able to scan the airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground

As demonstrated above, the UAS operations Business Transformations has proposed in this petition 

for exemption will garner significant local benefits while presenting minimal safety risks. BT's 

petition satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous 

petitions the FAA has granted, meriting a summary grant of exemption. BT respectfully requests that 

the FAA grant this petition to enhance BT's ability to provide support for important building, 

landmark photographic, inspection, and training purposes. Please do not hesitate to contact BT at 

609-315-1522 or Charles Braddy at email address csbraddy@verizon.net, with any questions about 

this filing.

Sincerely, 

Charles S. Braddy

Business Transformations