UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Dana Robert Mailloux

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF CARBON CORE OCTOCOPTER/HH BLADE 350QX2 AP UNMANNED 

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on April 16, 2015 

Dana Robert Mailloux

10973 N. Joshua Ct.

Hayden, Idaho 

208-215-8058
2

TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS....................................................................................3 

SUMMARY............................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................4 

BASIS FOR PETITION.........................................................................................................5 

NAME AND ADDRESS OF PETITIONER.............................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Dana Robert Mailloux 

SEEKS EXEMPTION...............................................................................................8 

THE EXTENT OF RELIEF Dana Robert Mailloux SEEKS AND THE REASON 

Dana Robert Mailloux SEEKS THE RELIEF......................................................11 

THE REASONS WHY GRANTING Dana Robert Mailloux's REQUEST 

WOULD BE IN THE PUBLIC INTEREST .........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT Dana Robert Mailloux's REQUEST......................34 

CONCLUSION....................................................................................................................35 

APPENDICES.........................................................................................36
3

 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interrst

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle 

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

HH Horizon Hobby Blade 350QX2AP

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing

Wkm M DJI Flight Control System

 

CCO Carbon Core Octocopter

 
4

SUMMARY

 Dana Robert Mailloux seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose 

of conducting aerial video and photography of construction sites, real estate and landscape 

over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Dana Robert Mailloux provides his clients with expertise and knowledge in advanced 

photography and video solutions to increase efficiency, productivity and effectiveness. 

Dana Robert Mailloux has over 8 years of experience in Photographic and Video 

Technology. He has over 4 years recreational and hobby experience in all aspects of aerial 

video and photography. The objective of Dana Robert Mailloux's aerial video and 

Photography operations is to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting:

 • Construction sites before, after and during

• Appraisals

• Real-estate marketing

• Aerial acquisitions used for inspections of public and private structures.

• Search and Rescue operations
5

BACKGROUND

 Dana Robert Mailloux seeks an exemption to operate DJI & HH Blade systems for compensation 

or hire within the NAS. The CCO w/Wkm M and HH Blade 350QX AP are vertical take off 

and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

Utilizing a 2.8Mhz Remote Control system. The CCO w/Wkm M has a maximum

gross weight of approximately 15 pounds 0 ounces, while having a width of 40 

inches and a height of 19 inches, and a maximum speed of approximately 43 knots. 

The HH Blade 350QX2 AP has a maximum gross weight of 4 pounds 0 ounces, a length of 

18.3 inches, width of 17.7 inches, height of 7.48 inches, and a maximum speed of 

Approximately 29 knots. The CCO w/Wkm M is equipped with 8 main rotors, and the HH Blade 

350QX2 AP with four main rotors; utilizing Lithium Polymer batteries to power the electric motors. 

The CCO w/Wkm M and HH Blade 350QX2 AP UAS's that will be operated by Dana 

Robert Mailloux will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Dana Robert Mailloux , pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act 

of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate the CCO w/Wkm M

And HH Blade 350QX2 AP UAS's in the National Airspace System (NAS), and for an 

exemption from the 

 Unmaned Aircraft Systems: CCO w/Wkm M, HH Blade 350QX2 AP UAS's
6

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Dana Robert Mailloux's operation of CCO 

w/Wkm M and HH Blade 350QX2 AP UAS's meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. 

Accordingly, Dana Robert Mailloux requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

 Dana Robert Mailloux submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Dana Robert Mailloux will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance 

on the UAS's using the methods, techniques, and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, and CCO w/Wkm M and HH Blade 350QX2 AP 

Instruction Manual). Furthermore, Dana Robert Mailloux will document and maintain 

all maintenance records for the CCO w/Wkm M and HH Blade 350QX2 AP UAS's. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Dana Robert Mailloux to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and current requirements, that the PIC is able to safely operate the 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's in a manner consistent with this 
7

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

 Dana Robert Mailloux seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the CCO w/Wkm M and HH Blade 350QX2 AP UAS's do not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, 

Dana Robert Mailloux submits that he will ensure that the CCO w/Wkm M and HH Blade 350 

QX2 AP UAS's are in an airworthy condition, prior to every flight, by determining that the 

UAS's are in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and CCO w/Wkm M and HH Blade 350QX2 AP Instruction Manual), and that the aircraft are 

in a condition for safe flight. 

Dana Robert Mailloux also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the CCO w/ Wkm M and HH Blade 350QX2 AP UAS's 

will not have a typical barometric altimeter onboard. However, altitude information of the 

CCO w/ Wkm M and HH Blade 350QX2 AP UAS's will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, 

which downlinks from the UAS to the GCS for active monitoring of the flight path. This 

altitude information, combined with Dana Robert Mailloux's operation of the CCO

W/ Wkm M and HH Blade 350QX2 AP UAS's within visual line of sight, at or below 400

feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Dana Robert Mailloux seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Dana 

Robert Mailloux submits that safety will not be affected by operation of the CCO w/ Wkm M 

and HH Blade 350QX2 AP UAS's during daylight hours in visual meteorological conditions 

(VMC) 
8

under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 10 minutes for the intended photo shoot and, assuming normal 

cruising speed, to fly after that for at least 2.5 minutes for recovery and landing. 

In accordance with 14 C.F.R. § 11.81, Dana Robert Mailloux provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner

The name and address of the Petitioner and point of contact is:

Dana Robert Mailloux

10973 N. Joshua Ct.

Hayden, Idaho

208-215-8058 

Email: multirotorpilot@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Dana Robert Mailloux seeks 

Exemption 

1. Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2.Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Section 91.7(a).
9

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Dana Robert Mailloux Seeks Exemption From The Requirements Of Section

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimetersetting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station;or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Section91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

5. Dana Robert Mailloux Seeks Exemption From The Requirement Of 

Section91.405(a).
10

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that 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[.] 

6. Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration,subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter. 

7. Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Dana Robert Mailloux Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 
11

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

Safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 
12

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana Robert 

Mailloux Seeks The Relief. 

1. Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana 

 Robert Mailloux Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and 

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Dana Robert Mailloux submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the CCO 

W/Wkm M or HH Blade 350QX2 AP UAS's unless that PIC has met certain flight-hour and 

And current requirements, demonstrating that the PIC is able to safely operate either the 

CCO w/Wkm M or HH Blade 350QX2 AP UAS's in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency maneuvers, 

as well as maintaining appropriate distances from people, vessels, vehicles and structures.
13

 Further, Dana Robert Mailloux submits that all flights of the CCO w/Wkm M

And HH 350QX2 AP UAS's, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to Dana Robert Mailloux's business; and (2) will not carry passengers or 

property for compensation or hire. 

2.Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana 

Robert Mailloux Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Dana Robert Mailloux to determine that the CCO w/Wkm M

and HH Blade350QX2 AP UAS's are in airworthy condition prior to every flight by ensuring 

that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance

Log and CCO w/Wkm M and 350QX2 AP manuals. 

 Dana Robert Mailloux seeks the requested relief because the CCO w/Wkm M and HH

Blade 350QX2 AP UAS's do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Dana Robert Mailloux will ensure that the CCO w/Wkm 

M and HH Blade 350QX2 AP UAS's are in airworthy condition based upon its compliance 

with the operating documents (i.e., Monthly Maintenance Log, and CCO w/Wkm M and HH

Blade 350QX2 AP Instruction Manual) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

 3. Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana 

Robert Mailloux Seeks Relief From Section 91.121.

 Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data 

link to downlink altitude information from the UA to the PIC at the ground control station 
14

(GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Dana Robert 

Mailloux seeks the requested relief because the CCO w/Wkm M and HH Blade 350QX2 AP 

UAS’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the CCO w/Wkm M and HH Blade 350QX2 AP UAS's are equipped with 

a barometric pressure sensor and GPS equipment, which automatically ensures that a ground 

level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana 

Robert Mailloux Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered CCO 

CO w/Wkm M and HH Blade 350QX2 AP UAS's during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 2.5 minutes. Dana Robert Mailloux seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered CCO 

W/Wkm M and HH Blade 350QX2 AP UAS's will severely constrain the practicality of any 

aerial video or still photo flight operations that Dana Robert Mailloux proposes to conduct 

pursuant to this Petition. 
15

Significantly, as set forth below, the technical specifications of the CCO w/Wkm M

and HH Blade 350QX2 AP UAS's, the CCO w/Wkm M and HH Blade 350QX2 AP operating 

documents and Dana Robert Mailloux's proposed operating limitations, ensure that Dana Robert 

Mailloux will safely operate the battery powered CCO w/Wkm M and HH Blade 350QX2 AP

UAS's during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 10 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 

2.5 minutes.

5.Extent Of Relief Dana Robert Mailloux Seeks And The Reason Dana 

Robert Mailloux Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Dana Robert Mailloux requests

relief from these Sections because the CCO w/Wkm M and HH Blade 350QX2 AP UAS's do

not require airworthiness certificates. As set forth more fully below, the CCO w/Wkm M 

and HH Blade 350QX2 AP UAS's meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Dana Robert Mailloux will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS's 

using the methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the Aerial Operations Manual, Monthly Maintenance Log, and CCO w/Wkm M and HH 

Blade 350QX2 AP Instruction Manual). Furthermore, Dana Robert Mailloux will document

and maintain all maintenance records for the CCO w/Wkm M and HH Blade 350QX2 AP UAS's. 

D. The Reasons Why Granting Dana Robert Mailloux Request Would Be In The 

Interest; That Is, How It Would Benefit The Public As A Whole. 
16

Granting the present Petition will further the public interest by allowing Dana 

Robert Mailloux to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the 

United States. 

Additionally, use of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

the economy. Notably, the benefits of Dana Robert Mailloux's proposed operation of the 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's will be realized without implicating 

any privacy issues. 

1.The Public Will Benefit From Decreased Congestion Of The NAS.

 The CCO w/Wkm M and HH Blade 350QX2 AP UAS's are battery powered and serve 

as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized 

to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of the CCO w/Wkm M and HH Blade 350QX2 

AP UAS's would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The CCO

W/Wkm M and HH Blade 350QX2 AP UAS's.
17

Conducting aerial acquisitions with the CCO w/Wkm M and HH Blade 350QX2 AP 

UAS's instead of manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the CCO 

w/Wkm M and HH Blade 350QX2 AP UAS's produce no air pollution, and is the most 

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized foraerial video and photography 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The CCO 

w/Wkm M and HH Blade 350QX2 AP UAS's, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA's are propelled by battery powered 

electric motors, rather than an internal combustion engine. 

By using the CCO w/Wkm M and HH Blade 350QX2 AP UAS's to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the CCO w/Wkm M and HH Blade 350QX2 AP UAS's (weighing 

approximately 15 pounds 0 ounces and 4 pounds 0 ounces respectively, at their maximum 

gross weights with respectively (and with no fuel on board) has less physical potential 

for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds, and a fuel capacity of 180 gallons. 
18

3. Performing Aerial Video and Photography Operations With The CCO

w/Wkm M and HH Blade 350QX2 AP UAS's Will Benefit The Economy.

In addition to being safe and efficient, the CCO w/Wkm M and HH Blade 350QX2 AP 

UAS's are also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's will 

allow United States based companies, like Dana Robert Mailloux's to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation 

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered CCO w/Wkm M 

and HH Blade 350QX2 AP UAS's is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating the CCO w/Wkm M and HH Blade 350QX2 AP UAS's, companies such 

as Dana Robert Mailloux's can remain competitive and profitable and therefore, provide 

greater job stability to employees and contractors, which will ultimately contribute to 

growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's, provides a stable

workforce that increases consumer spending, improves local, state, and federal tax 

revenues and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4.There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Dana Robert Mailloux's proposed operation of the CCO w/Wkm M and HH Blade 350 
19

QX2 AP UAS's will not implicate any privacy issues. Specifically, the CCO w/Wkm M

And HH Blade 350QX2 AP UAS's will be operated only in compliance with operating documents 

documents (i.e. Aerial Operations Manual, Monthly Maintenance Log, and the CCO w/Wkm M 

And HH Blade 350QX2 AP Instruction Manual's) which requires property owner imvolvement as 

well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requiremants of 14 C.F. R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Dana Robert Mailloux Seeks Exemption. 

1. Reasons Why The CCO w/Wkm M and HH Blade 350QX2 AP UAS's Meet The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)

Section 333.

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Dana Robert Mailloux's operation of the 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 
20

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Dana Robert Mailloux submits that the CCO w/Wkm M

And HH Blade 350QX2 UAS's can operate safely in the NAS pursuant to FMRA Section 333, 

as demonstrated by: (a) the characteristics of the CCO w/Wkm M and HH Blade 350QX2 AP 

UAS's; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The CCO w/Wkm M and HH Blade 350QX2 AP UAS's

Demonstrate Its Safe Characteristics.

The CCO w/Wkm M and 350QX2 AP UAS's do not create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The CCO w/Wkm M and HH Blade 350QX2 

AP UAS's.

The technical specifications of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's 

are set forth by the CCO w/Wkm M and HH Blade 350QX2 AP Specifications and Data Sheet, 

attached hereto as Exhibit A and B. 
21

ii. The CCO w/Wkm M and HH Blade 350QX2 AP UAS's Autonomous 

Flight And Navigation Modes Enable The UAS's To Remain Within A

Defined Operational Area.

 The CCO w/Wkm M may be operated in both manual and fully autonomous flight modes.

The HH Blade 350QX2 AP may be operated in manual flight mode only. A complete discription of 

the flight and navigational modes of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's is 

provided at pages 23-32 of the DJI Wkm M and pages 8 & 11 of the HH Blade 350QX2 AP User

Manuals, attached hereto as Exhibit C and D.

Iii. The CCO w/Wkm and HH Blade 350QX2 AP UAS's Are Designed For

Automatic Return To Home Point Or Hover In The Event Of Loss Of

The Control Link Or Navigation.

When the Control Link is lost, the CCO w/Wkm M UAS and HH Blade 350QX2 AP will 

remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the CCO w/Wkm M and 

HH Blade 350QX2 AP due not reacquire control link data from the GCS, the UAS will assume that 

the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the CCO w/Wkm M and HH Blade 350

QX2 AP UAS's are set forth at pages 23 through 32 and for the Blade 350QX2 AP at pages 8 

and 11 of the CCO w/Wkm M and HH Blade 350QX2 AP User Manuals, attached hereto as

Exhibit C and D. 

iv. The CCO w/Wkm M and HH Blade 350QX2 AP GCS And Its

Operation.

A complete description of the operation and specifications of the CCO w/Wkm M 

and HH Blade 350QX2 AP GCS and flight control software is provided at pages 23 through 

32 of the DJI Wkm M User Manual and pages 8 and 11 of the HH Blade 350QX2 AP
22

User Manual. The CCO w/Wkm M and HH Blade 350QX2 AP User Manuals are attached 

hereto as Exhibits C and D.

b. Flight Operations Of CCO w/Wkm M and HH Blade 350QX2 AP UAS's

Are Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.

 Dana Robert Mailloux will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the CCO w/Wkm M 

And HH Blade 350QX2 AP UAS's. Additionally, a safety observer will assist all pilots during 

flight time. 

c. Flights Of CCO w/Wkm M and HH Blade 350QX2 AP UAS's Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Dana Robert Mailloux proposes to commercially 

operate CCO w/Wkm M and HH Blade 350QX2 AP UAS's for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS's weighing less

than 55 pounds maximum gross weight: CCO w/Wkm M and HH Blade 350QX2 

AP Unmanned Aircraft Systems. Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground

level (AGL), as indicated by the procedures specified in the operating

documents unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.

5. The UA's must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.
23

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability.

The SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

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

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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

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

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.
24

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. maintenance,

inspection, alterations, and status of replacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description

of work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS's operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third-class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate

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

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§61.51(b). Flights for the purposes of training the operator’s PIC's are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

proficiency, and experience-building flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to

the Administrator upon request.
25

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UAS with 25% battery power

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N-Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

and control of the UAS must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:
26

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UAS and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

 Dana Robert Mailloux submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

the CCO w/Wkm M and HH Blade 350QX2 AP UAS's unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the CCO w/Wkm M or HH Blade 350QX2 AP UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Considering Dana Robert Mailloux's proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge 
27

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the CCO w/Wkm M or HH Blade 350QX2 

AP UAS, Dana Robert Mailloux submits that the additional manned airmanship experience 

of a commercially certificated pilot would not correlate to the airmanship skills necessary 

for Dana Robert Mailloux's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

 Dana Robert Mailloux will not allow any PIC to operate the CCO w/Wkm M or 

HH Blade 350QX2 AP UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements of the CCO w/Wkm M or HH Blade 350QX2 AP UAS training and 

currency requirements, that the PIC is able to safely operate the CCO w/Wkm M or 

HH Blade 350QX2 AP UAS in a manner consistent with this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 
28

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Dana Robert Mailloux's proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Dana Robert Mailloux will ensure safe operations by not allowing 

any PIC to operate the CCO w/Wkm M or HH Blade 350QX2 AP UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC 

is able to safely operate the CCO w/Wkm M or HH Blade 350QX2 AP UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
29

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Dana Robert Mailloux will ensure that the CCO w/Wkm M 

or HH Blade 350QX2 AP UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's will 

will be provided to the PIC via GPS equipment and a radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with Dana Robert Mailloux's operation of the 

CCO w/Wkm M and HH Blade 350QX2 AP UA's within visual line of sight, at or below 400 

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed on board the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UAS's at 

ground level. 

The FAA has previou sly granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 
30

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the CCO

W/Wkm M and HH Blade 350QX2 AP UAS's; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, Dana 

Robert Mailloux will ensure that he will safely operate the battery powered CCO w/Wkm M 

and HH Blade 350QX2 AP UA's during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 10 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the CCO w/Wkm 

M and HH Blade 350QX2 AP UAS's the limitations on the proposed flight operations and the 

the location of the proposed operations, will ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the CCO w/Wkm 

M and HH Blade 350QX2 AP UAS's provide audible and visual warnings to the PIC at the 

GCS when the UA's experiences low battery voltage, the first warning occurring at 

approximately 33% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, the CCO w/Wkm M and HH Blade 350 

QX2 AP UAS's will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 
31

from Section 91.151 specific to UAS in circumstances similar in all material respects to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b)

Would Not Adversely Affect Safety.

In seeking this exemption, Dana Robert Mailloux submits that the equivalent level 

of safety with regard to the regulatory maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be 

met because Dana Robert Mailloux will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS's using the methods, techniques, and 

practices prescribed in the operating documents i.e., the Operations Manual, Monthly 

Maintenance Log, and CCO w/Wkm M and HH Blade 350QX2 AP Instruction Manual. 

Furthermore, Dana Robert Mailloux will document and maintain all maintenance records 

for the CCO w/Wkm M and HH Blade 350QX2 AP UAS's. 

Since the CCO w/Wkm M and HH Blade 350QX2 AP UAS's will be inspected as 

prescribed by the operating documents, Dana Robert Mailloux will maintain the equivalent 

level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy 

of the CCO w/Wkm M and HH Blade 350QX2 AP User Manuals are attached hereto as 

Exhibit C and D; a copy of the CCO w/Wkm M and HH Blade 350QX2 AP UAS 

Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Dana 

Robert Mailloux will use trained technicians to perform maintenance, alterations or 

preventive 
32

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Dana Robert Mailloux's proposed operating limitations, the 

operating documents, and the technical aspects of the CCO w/Wkm M and HH Blade 350 

QX2 AP UAS's, Dana Robert Mailloux submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)

(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Dana Robert Mailloux requests 

that the FAA prescribe special conditions for the intended operation of the CCO w/Wkm M 

And HH Blade 350QX2 AP UAS's, which contain such safety standards that the 
33

administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

special conditions will permit safe operation of the UA's for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§21.16, for operation of the CCO w/Wkm M and HH Blade 350QX2 AP UAS's, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, it may prescribe special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Dana Robert Mailloux's intended operation of the CCO

w/Wkm M and HH Blade 350QX2 AP UAS's, which contain such safety standards that the 
34

administrator finds necessary to establish a level of safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register stating: The Rules 

From Which Dana Robert Mailloux Seeks Exemption: 

Dana Robert Mailloux seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Dana Robert 

Mailloux Seeks: 

This exemption will permit Dana Robert Mailloux to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Dana 

Robert Mailloux's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Dana Robert Mailloux request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Dana Robert Mailloux will operate the CCO w/Wkm 

M and HH Blade 350QX2 AP UAS's safely in the NAS, without creating a hazard to 

users of the NAS, or the public, or otherwise pose a threat to national security. 
35

CONCLUSION

As set forth herein, Dana Robert Mailloux seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the CCO w/Wkm M and HH Blade 350QX2 

AP UAS's commercially, without an airworthiness certificate, for the limited purpose 

of conducting aerial video and photography over certain areas of the United States. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing 

the interests of the public, by allowing Dana Robert Mailloux to safely, efficiently, 

and economically operate the CCO w/Wkm M and HH Blade 350QX2 AP UAS's 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Dana Robert Mailloux respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Dana Robert Mailloux to operate the 

CCO w/Wkm M and HH Blade 350QX2 AP UAS's commercially for the purpose of conducting

aerial video and photography over certain areas of the United States.

Dated: April 16, 2015

Respectfully submitted,

Dana Robert Mailloux
36

 APPENDICES:

 A - CCO w/Wkm M Specifications 

 B – HH Blade 350QX2 AP Specifications

 C - DJI Wkm M User Manual

 D – HH Blade 350QX2 AP User Manual

 E - Monthly Maintance Log 
37

APPENDIX –A

 CCO w/Wkm M TECHNICAL SPECIFICATIONS

Dana Robert Mailloux only utilizes safe and reliable UAS's. DJI is an industry leader in 

small UAS production. DJI UAS's are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor, Spektrum DX 9 Radio 

Control Transmitter

1.1 CCO w/Wkm M

1.1.1 Aircraft

1.1.1.1 Batteries –(2)Thunder Power 5000mAH LiPo Battery

1.1.1.2 Weight, Flight –7 lbs 6 oz (3345g)

1.1.1.3 Hover Accuracy–Vertical: +/-.5m; Horizontal: +/-2m

1.1.1.4 Max Tilt Angel -35deg

1.1.1.5 Max Ascent/Descent Speed –6m/s

1.1.1.6 Max Flight Speed –15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

 1.1.2.1 Photohigher AV200 w/360 Pan

 1.1.2.2 Controler – Hoverfly Gimbal 3Axis Control Board

1.1.2.3 Battery 2700mAh 2s 

1.1.2.4 Pan - Controllable 360deg

1.1.2.5 Pitch - Controllable -90deg

 1.1.2.6 Horizon – Automatic

1.1.3 Transmitter FPV (CAMERA OPERATOR ONLY)

 1.1.3.1 Immersion RC 5.8GHz AV

 1.1.3.2 Power Out-put 600mW 28dBm +/- 1dBm

 1.1.3.3 Frequencies 5740, 5760, 5780, 5800, 5820, 5840 and 5860MHz 

1.1.4 Camera

 1.1.4.1 Canon

 1.1.4.2 EOS 60 D

1.1.4.4 Operating Temperature Range -32deg F / 104deg F

1.1.4.3 Effective Pixels –18M

1.1.5 Transmitter 1 Aircraft

 1.1.5.1 Spektrum DX9

 1.1.5.2 Operating Frequency 2.400GHz – 2.4835GHz

 1.1.5.3 Communication Distance (unobstructed) FCC Compliance 800m

 1.1.5.4 Transmitter Power FCC Compliance 100mW

 1.1.5.5 Battery 2000mAh Li-lon 2S

 1.1.5.6 Operating Temperature -14deg to 104deg F 
38

 1.1.6 Transmitter 2 Gimbal

 1.1.6.1 Spektrum DX8

 1.1.6.2 Operating Frequency 2.400GHz – 2.4835GHz

 1.1.6.3 Communication Distance (unobstructed) FCC Compliance 800m

 1.1.6.4 Transmitter Power FCC Compliance 100mW

 1.1.6.5 Battery 2000mAh NiMH 4S

 1.1.6.6 Operating Tempterature -14deg to 104deg F 
39

APPENDIX –B

HH Blade 350QX2 AP TECHNICAL SPECIFICATIONS

Dana Robert Mailloux only utilizes safe and reliable UAS's. HH is an industry leader in 

small UAS production. HH UAS's are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, HH software provides real-time 

altitude and location information to the PIC via the linked RC Control Transmitter. 

2.2 HH Blade 350QX2 AP

2.2.1 Aircraft

2.2.1.1 Battery – Thunderpower 3300 mAh LiPo 

2.2.1.2 Weight (Battery Included) – 2 lbs 3.5oz (1006g)

2.2.1.3 Hovering Accuracy (GPS Mode) –Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity –Pitch: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle -350

2.2.1.6 Max Ascent Speed –5m/s

2.2.1.7 Max Descent Speed –4m/s

2.2.1.8 Max Speed –22m/s (ATTI mode, no wind –NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude –4500m

2.2.1.10 Max Wind Resistance –10m/s

2.2.1.11 Max Flight Time –Approximately 13 minutes

2.2.2 Gimbal

2.2.2.1 Model – Blade GB200 2 Axis Brushless Gimbal

2.2.2.2 Controllable Range 0 deg to -90deg

2.2.2.3 Horizon - Automatic

2.2.2.4 Operating Temp -32deg to 140 F

2.2.3 Camera

2.2.3.1 Name – GoPro

 2.2.3.2 Model – Hero 3 Silver

 2.2.3.3 Pixel 11M

2.2.4 Transmitter

 2.2.4.1 Spektrum DX9

 2.2.4.2 Operating Frequency 2.400GHz to 2.4835 GHz

 2.2.4.3 Communication Distance (unobstructed) FCC Compliance 800M

 2.2.4.4 Transmitter Power FCC Compliance 100mW

 2.2.4.5 Battery 2000mAh 2S Li-lon 2S

 2.2.4.6 Opertating Temperature -14deg to 104deg F 
40

 APPENDIX – C

 DJI Wkm M – Manufacturer's User Manual

 http://www.dji.com/product/wookong-m
41

APPENDIX – D

HH Blade 350QX2 AP Manufacturer’s User Manual

http://www.horizonhobby.com/pdf/BLH7900_Manual_EN.pdf
42

 

 

 APPENDIX - E 

 Dana Robert Mailloux 

 Monthly Maintance and Repair Log

 Aircraft:

 Hours:

 Date: 

 Date Issue Date Issue Issue Decription/Maintance Conducted Repair/Maintance 

 Discovered Resolved Performed By 

 

Airframe

Motors

Propellers

Flight Control

Update

Gimbal

Misc