Page	1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ROBERT H. CARLISLE

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 BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on November 24, 2015

ROBERT H. CARLISLE

134 MORNINGSIDE RD.

NILES, OH 44446

(330) 883-4566
Page	2

TABLE OF CONTENTS

 Page

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

THE SPECIFIC SECTIONS OF 14 C.F.R......................................................................................4

SUMMARY.....................................................................................................................................5

INTRODUCTION AND INTERESTS OF PETITIONER.............................................................5

BACKGROUND............................................................................................................................6

BASIS FOR PETITION..................................................................................................................7

NAME AND ADDRESS OF PETITIONER......................................................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

ROBERT H. CARLISLE SEEKS EXEMPTION...............................................................9

THE EXTENT OF RELIEF ROBERT H. CARLISLE SEEKS AND 

THE REASON ROBERT H. CARLISLE SEEKS THE RELIEF.............................12

THE REASONS WHY GRANTING ROBERT H. CARLISLE REQUEST 

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY....................................................................................17

CONCLUSION..............................................................................................................................23

APPENDIX A................................................................................................................................24

BLADE CHROMA TECHNICAL DATA SHEET

APPENDIX B................................................................................................................................27

YUNEEC TYPHOON Q500 TECHNICAL DATA SHEET

APPENDIX C................................................................................................................................31

DJI PHANTOM 3 TECHNICAL DATA SHEET

APPENDIX D................................................................................................................................37

MAINTENANCE LOG 
Page	3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

AMA Academy of Model Aeronautics

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

ESC Electronic speed control 

FPV First Person View 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LI-PO Lithium Polymer battery

LOL Loss of Link 

MPH Miles Per Hour

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

RCV Radio Controlled vehicle 

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

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 Takeoff and Landing 
Page	4

The specific sections of 14 C.F.R.

14 C.F.R. Part 21; Certification Procedures for Products and Parts

14 C.F.R. 45.23(b); Display of marks; general

14 C.F.R. 61.113(a) 

& (b); Private pilot privileges and limitations: Pilot in command.

14 C.F.R 91.7(a); Civil aircraft airworthiness

14 C.F.R. 91.121; Altimeter settings

14 C.F.R. 91.151(b); Fuel requirements for flight in VFR conditions

14 C.F.R. 91.405(a); Maintenance required.

14 C.F.R. 91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, 

or alteration.

14 C.F.R. 91.409(a)(1)

& (a)(2}; Inspections

14 C.F.R. 91.417(a) & (b); Maintenance records
Page	5

SUMMARY

ROBERT H. CARLISLE 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 ROBERT H. CARLISLE to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting search & rescue, aerial inspections,

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is ROBERT H. CARLISLE, and I am a drone operator (pilot) with expertise and knowledge 

in all aspects of operating multiple types of UAS's along with camera set up and operation. ROBERT 

H. CARLISLE also provides clients with the highest quality digital content for use in their search &

rescue operations, aerial inspections, and aerial video photography. ROBERT H. CARLISLE is a 

member of AMA and has 25 years of radio controlled aircraft operation and 2 years of drone 

experience.

The objective of ROBERT H. CARLISLE aerial video and photography operations is to provide 

search & rescue, aerial inspections, high quality imaging for a variety of commercial and residential 

uses. ROBERT H. CARLISLE will also provide knowledge of UAS’s and promote safe UAS 

operations. 
Page	6

BACKGROUND

Unmanned Aircraft Systems: BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 

3 UAS.

ROBERT H. CARLISLE seeks an exemption to operate Blade and Yuneec systems for 

compensation or hire within the NAS. The BLADE CHROMA, YUNEEC TYPHOON Q500, and 

DJI PHANTOM 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS). The BLADE CHROMA has a maximum gross weight of 45.9

ounces while having a length of 15.7 inches, height of 9.5 inches and a maximum speed of 

approximately 30 mph. YUNEEC TYPHOON Q500, DJI PHANTOM 3 has a maximum gross 

weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, 

height of 8 inches, and a maximum speed of approximately 29 knots. The BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s are equipped with four main rotors; driven 

by Lithium Polymer battery powered electric motors. The BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UAS’s that will be operated by ROBERT H. CARLISLE 

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 Markings. 
Page	7

BASIS FOR PETITION

Petitioner, ROBERT H. CARLISLE, 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 BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s in the National Airspace System (NAS), and for an 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). 

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

unmanned aircraft and its operation, ROBERT H. CARLISLE’s operation of BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 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, ROBERT H. CARLISLE 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. 

ROBERT H. CARLISLE submits that the requested relief is proper since an equivalent level of 

safety will be ensured. ROBERT H. CARLISLE 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., and BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 Instruction Manuals). Furthermore, ROBERT H. 

CARLISLE will document and maintain all maintenance records for the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 ROBERT H. CARLISLE to the extent necessary to 

allow a Pilot in Command (PIC) who has demonstrated, by meeting minimum flight-hour 

requirements, that the PIC is able to safely operate the BLADE CHROMA, YUNEEC TYPHOON 

Q500, DJI PHANTOM 3 UAS’s in a manner consistent with this exemption, including evasive and 

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

structures. 

ROBERT H. CARLISLE seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s do not 

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

ROBERT H. CARLISLE submits that he will ensure that the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 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, and BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 Instruction Manuals, and that the 

aircraft are in a condition for safe flight. 
Page	8

ROBERT H. CARLISLE also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UA will not have a typical barometric altimeter onboard. However, altitude 

information of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA will 

be provided to the PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight 

path. This altitude information, combined with ROBERT H. CARLISLE’s operation of the 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, ROBERT H. CARLISLE seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel Requirements for flight in VFR conditions. ROBERT H. CARLISLE

submits that safety will not be affected by operation of the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UA during daylight hours in visual meteorological 

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

duration of approximately 25 minutes. Battery power indicators are also able to show how much 

battery power is left, as well as how much time is needed to return safely back to the point of take 

off.

In accordance with 14 C.F.R. § 11.81, ROBERT H. CARLISLE 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: 

ROBERT H. CARLISLE 

134 Morningside Rd., 

Niles, OH 44446

(330) 883-4566

Email: r.carlisle50@gmail.com 
Page	9

B. The Specific Sections of 14 C.F.R. From Which ROBERT H. CARLISLE Seeks 

Exemption. 

1. ROBERT H. CARLISLE Seeks Exemption from the Requirements of Section 

61.113(a) and (b):

(a) Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

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

(i) 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. 

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

in connection with any business or employment if—

a. The flight is only incidental to that business or employment; and 

b. The aircraft does not carry passengers or property for 

compensation or hire. 

2. ROBERT H. CARLISLE Seeks Exemption from The Requirements Of Section 

91.7(a):

(a) 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. ROBERT H. CARLISLE Seeks Exemption from The Requirements Of Section 

91.121:

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

in part: 

(i) 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 UA below 18,000 feet MSL, to: 

a. The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft; 

b. If there is no station within the area of this section, the current 

reported altimeter setting of an appropriate available station; or 

c. 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. 
Page	10

4. ROBERT H. CARLISLE Seeks Exemption from The Requirements Of Section 

91.151(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. ROBERT H. CARLISLE Seeks Exemption from The Requirement Of Section 

91.405(a):

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

following: Each owner or operator of an aircraft—

(i) Shall have that aircraft inspected as required and shall between required 

inspections have discrepancies repaired as required. 

6. ROBERT H. CARLISLE Seeks Exemption from The Requirements Of Section 

91.407(a)(1):

(a) Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

preventive maintenance, rebuilding, or alteration unless--

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

§ 43.7 of this chapter [.] 

7. ROBERT H. CARLISLE Seeks Exemption from The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2):

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

(i) 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 --

a. 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 

b. An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 
Page	11

8. ROBERT H. CARLISLE Seeks Exemption from the Requirements of Sections 

91.417(a) and 91.417(b):

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

following: 

(i) 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: 

a. 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--

1. A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

2. The date of completion of the work performed; and 

3. The signature and certificate number of the person 

approving the aircraft for return to service. 

b. Records containing the following information: 

1. The total time in service of the airframe, each engine, 

each propeller, and each rotor. 

2. The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. 

3. The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified 

time basis. 

4. 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. 

5. 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. Any the AD or safety directive involves 

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

required. 

6. 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. 

c. The owner or operator shall retain the following records for the 

periods prescribed: 

1. The records specified in paragraph (a) 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. 
Page	12

2. The records specified in paragraph (a) 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 ROBERT H. CARLISLE Seeks And The Reason ROBERT 

H. CARLISLE Seeks The Relief. 

1. Extent of Relief ROBERT H. CARLISLE Seeks and The Reason 

ROBERT H. CARLISLE 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

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

proposed UA flight operations for compensation or hire. 

(a) 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, ROBERT H. CARLISLE submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the Blade Chroma, 

Yuneec Typhoon Q500, DJI PHANTOM 3 UAS unless that PIC has met certain flight-hour 

and currency requirements, demonstrating that the PIC is able to safely operate either the 

Blade Chroma, Yuneec Typhoon, DJI PHANTOM 3 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. 

Further, ROBERT H. CARLISLE submits that all flights of the BLADE CHROMA, 

YUNEEC TYPHOON, DJI PHANTOM 3 UAS’s, conducted by the PIC pursuant to the 

grant of this Petition: 

1. Will be incidental to ROBERT H. CARLISLE's business; and 

2. Will not carry passengers or property for compensation or hire. 
Page	13

2. Extent Of Relief ROBERT H. CARLISLE Seeks And The Reason ROBERT H. 

CARLISLE 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 ROBERT H. CARLISLE to determine that the BLADE CHROMA, 

YUNEEC TYPHOON, DJI PHANTOM 3 UAS’s are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., Blade 

Chroma, Yuneec Typhoon, DJI PHANTOM 3 Instruction Manuals). 

ROBERT H. CARLISLE seeks the requested relief because the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, ROBERT H. 

CARLISLE will ensure that the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 Instruction Manuals) 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 ROBERT H. CARLISLE Seeks And The Reason ROBERT H. 

CARLISLE Seeks Relief from Section 91.121:

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

operations of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

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 (GCS). Since the FAA requires that any altitude 

information concerning UA operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), ROBERT H. CARLISLE seeks the requested relief because the 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 BLADE CHROMA, YUNEEC TYPHOON Q500, 

DJI PHANTOM 3 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. 
Page	14

4. Extent of Relief ROBERT H. CARLISLE Seeks And The Reason ROBERT H. 

CARLISLE 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 BLADE CHROMA, 

YUNEEC TYPHOON, DJI PHANTOM 3 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

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

fly after that for at least 4.5 minutes. ROBERT H. CARLISLE seeks the requested relief

because without an exemption from Section 91.151(b), the flight time duration of the 

battery powered BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA 

will severely constrain the practicality of any aerial video or still photo flight operations 

that ROBERT H. CARLISLE proposes to conduct pursuant to this Petition. Significantly, 

as set forth below, the technical specifications of the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UAS’s, the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 operating documents, and ROBERT H. 

CARLISLE’s proposed operating limitations, ensure that ROBERT H. CARLISLE will 

safely operate the battery powered BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 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 

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

fly after that for at least 4.5 minutes. 

5. Extent of Relief ROBERT H. CARLISLE Seeks And The Reason ROBERT H. 

CARLISLE 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, ROBERT H. CARLISLE requests relief 

from these Sections because the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s do not require airworthiness certificates. As set forth more fully

below, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s 

meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. 

Accordingly, ROBERT H. CARLISLE 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., ROBERT H. 

CARLISLE Aerial Operations Manual, Monthly Maintenance Log, and BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 Instruction Manuals). 

Furthermore, ROBERT H. CARLISLE will document and maintain all maintenance 

records for the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

UAS’s. 
Page	15

D. The Reasons Why Granting ROBERT H. CARLISLE Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing ROBERT H. 

CARLISLE to safely, efficiently, and economically perform search & rescue, aerial 

inspections, and video photography of real estate properties over certain areas of the United 

States. 

Additionally, use of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI

PHANTOM 3 UAS’s will decrease congestion of the NAS, reduce pollution, crashes and 

accidents caused by pilot error and provide significant benefits to the economy. Notably, 

the benefits of ROBERT H. CARLISLE’s proposed operation of the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion of The NAS:

The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA’s are battery

powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized for search & rescue, aerial inspections, and to obtain aerial imagery. By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UA 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 BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting search & 

rescue and 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 BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s:

Conducting search & rescue, aerial inspections, and aerial acquisitions with the BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 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 for search & rescue, aerial inspections, 

and aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI

PHANTOM 3 UAS’s, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS’s are propelled by battery powered electric motors, 

rather than an internal combustion engine. 
Page	16

By using the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s 

to perform search & rescue, aerial inspections, and 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 BLADE 

CHROMA, has a maximum gross weight of 45.9 ounces while having a length of 15.7

inches, height of 9.5 inches and a maximum speed of approximately 30 mph. The 

YUNEEC TYPHOON Q500 has a maximum gross weight of 60 ounces while having a 

length of 22 inches, height of 8.3 inches and a maximum speed of approximate speed of 32 

mph. The DJI PHANTOM 3 has a maximum gross weight of 45.1 ounces, a length of 16.2 

inches, width of 16.6 inches, height of 10.5 inches, and a maximum speed of approximately

33 mph. The UAS’s are equipped with four main rotors; Driven by Lithium Polymer 

battery powered electric motors., 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 with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 

180 gallons). 

3. Performing Aerial Video and Photography Operations With The BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s Will Benefit The 

Economy:

In addition to being safe and efficient, the BLADE CHROMA, YUNEEC TYPHOON 

Q500, DJI PHANTOM 3 UAS’s are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operations of the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s will allow United States based 

companies 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 BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

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 BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

UAS’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 BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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. 
Page	17

4. There Are No Privacy Issues:

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

decades, ROBERT H. CARLISLE’s proposed operation of the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s will not implicate any privacy

issues. Specifically, the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI

PHANTOM 3 UAS’s will be operated only in compliance with operating documents (i.e., 

Aerial Operations Manual, Monthly Maintenance Log, and BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 Instruction Manuals) which requires property owner 

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

Federal Aviation Regulations, including the minimum altitude requirements 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 ROBERT H. CARLISLE Seeks Exemption:

1. Reasons Why The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

UA 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, ROBERT H. CARLISLE’s operation of the 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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: 

(i) 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. 

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

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

(a) which types of unmanned aircraft system (UAS), 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 

(b)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). 
Page	18

(iii) 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, ROBERT H. CARLISLE submits that the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by:

(a) The characteristics of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI

PHANTOM 3 UAS’s; 

(b) The pilot certification requirement; and 

(c) The specific operating limitations. 

a. The Specifications of The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s Demonstrate Its Safe Characteristics:

The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s. 

The technical specifications of the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s are set forth by the BLADE CHROMA, YUNEEC TYPHOON 

Q500, DJI PHANTOM 3 Specifications and Data Sheets, attached. 

(ii) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s 

Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area. The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s may be operated in both manual and fully autonomous flight modes. 

A complete description of the flight and navigational modes of the BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s is provided in the BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 user manuals.

(iii) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 BLADE CHROMA, 

YUNEEC TYPHOON Q500, DJI PHANTOM 3 UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the BLADE CHROMA, YUNEEC TYPHOON Q500, 

DJI PHANTOM 3 UAS’s do not reacquire control link data from the GCS, the UAS will 

assume that the Control Link is lost and the UA 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 BLADE CHROMA, YUNEEC TYPHOON 

Q500, and DJI PHANTOM 3 are set in the owner’s manuals,

(iv) The BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 GCS and its 

Operation. A complete description of the operation and specifications of the BLADE 

CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 GCS and flight control 

software is provided in the User Manuals.
Page	19

b. Flight Operations Of BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3

UAS’s Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer:

ROBERT H. CARLISLE will only utilize pilots who have been trained and meet the 

requirements to act as a pilot in command (PIC) of the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UAS’s. Additionally, a safety observer will assist all 

pilots during flight time. 

c. Flights Of BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s 

Will Be Conducted Pursuant To Specific Operating Limitations:

In seeking this exemption, ROBERT H. CARLISLE proposes to commercially operate 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s for the 

special purpose of conducting search & rescue, aerial inspections, and 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. 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 search & rescue, aerial inspections, and aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 35 mph. 

4. The UA must be operated at an altitude of no more than 500 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 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 government issued 

identification. 

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
Page	20

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. 

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 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 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 PICs 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 
Page	21

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

18. 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. 

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 UA 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 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 UA 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.
Page	22

29. The UA 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: 

(a) Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA 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. 

F. Reasons Why an Exemption From The Requirements Of Section 61.113(a) and (b) Would 

Not Adversely Affect Safety:

ROBERT H. CARLISLE 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 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s unless that 

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

the PIC is able to safely operate the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s in a manner consistent with the exemption, including evasive and 

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

and structures.

Considering ROBERT H. CARLISLE’s proposed area of operations, the operating 

limitations set forth-above, and the airmanship skills necessary to safely operate the 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s, ROBERT H. 

CARLISLE submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for specific 

proposed flight operations. 
Page	23

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. 

ROBERT H. CARLISLE will not allow any PIC to operate the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UAS’s unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the BLADE CHROMA, YUNEEC TYPHOON Q500, DJI 

PHANTOM 3 UAS’s training and currency requirements, that the PIC is able to safely operate the 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 UAS’s 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). 

CONCLUSION 

ROBERT H. CARLISLE 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 

BLADE CHROMA, YUNEEC TYPHOON Q500, DJI PHANTOM 3 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 ROBERT H. 

CARLISLE to safely, efficiently, and economically operate the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 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, ROBERT H. CARLISLE 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 Robert H Carlisle to operate the BLADE CHROMA, YUNEEC 

TYPHOON Q500, DJI PHANTOM 3 UAS’s commercially for the purpose of conducting search 

& rescue, aerial inspections, aerial video and photography over certain areas of the United States. 

Dated: November 24, 2015

Submitted by

ROBERT H. CARLISLE
Page	24

APPENDIX A: 

Technical Data Sheet: Blade Chroma

Motor to Motor 

Distance: 15.7 in (400mm) 

Rotor Type: Quadcopter 

Prop Diameter: 10.2 in (260mm) 

Approximate Flight 

Time: 30 minutes 

Battery: 11.1V 3S 6300mAh Li-Po 

Height: 9.50 in (242mm) 

Weight: 45.9 oz (1.3 kg) 

Motor Type: 4 × 780Kv Brushless Outrunner 

Control Link: 2.4GHz 

Video Link: 5.8GHz 

Video Link Range: 1,970 ft (600m) 

Satellite Navigation 

System: GPS, GLONASS 

Completion Level: Ready-to-Fly
Page	25

Blade Chroma Features

Smart	Mode

Perfect for the first-time drone flyers

 Stick Relativity moves drone in whatever direction the control stick is pushed, no matter which way 

the nose is pointed

 Creates a SAFE CircleTM barrier that prevents the aircraft from flying too close to you

 Auto-holds position and altitude when control sticks are released

AP	Mode

For more experienced drone pilots.

 Responds like a conventional drone without Stick Relativity

 Gives you greater control authority by turning off the SAFE Circle

 Keeps control response smooth so panning and tracking shots look great

 Auto-holds position and altitude when control sticks are released 

Follow	Me	Mode

The built-in copilot

 Frees you to focus on lining up the perfect shot

 Pan and tilt the camera while the drone follows

 Drone follows at an altitude and distance you set

Tracking	Mode

Follow me

 Drone follows and keeps the camera pointed at whoever holds the ST-10+ controller

 Drone follows at an altitude and distance you set

 Resume full control at any time

Return	Home

Safe landings with the flip of a switch

 Returns the drone to its start-up point and lands it for you

 Great for first-time flyers who aren’t ready to land themselves

 Easy way to regain visual contact if you lose sight in flight

 Resume full control at any time

 Activates automatically if controller signal is lost 

Adjustable	Flight	Boundaries

 Programmable flight boundaries limits flight to 400 ft AGL
Page	26

Blade Chroma Camera

The included CGO3 combines a high-definition camera and 3-axis stabilization gimbal into 

a single unit that captures steady aerial video and stills in unbelievable detail. All camera 

controls are placed within easy reach on the included ST-10+ controller.

Camera features include:

 4K/30fps or 1080p/120fps video

 16MP photo

 No-distortion lens – eliminates fisheye effect

 Integrated, 3-axis brushless stabilization gimbal

 Adjustable resolution and frame rate

 Adjustable settings for different lighting conditions

 Streams live video to the ST-10+ controller from as far as 600 meters

 Streams live video to multiple mobile devices within 90-120 meters *

Blade	Chroma	ST-10	transmitter

You don’t need a separate smart device with the ST-10+ controller. Everything you need, 

including the camera controls and a touch-screen video display is built right in.

 Large, 5 1⁄2 inch touch-screen display with intuitive Android interface

 Displays live video and real-time telemetry info like speed, altitude and battery voltage

 Clearly marked switches and buttons

 Super-simple flight and camera controls

 Slider switch for adjusting camera tilt

 Slider switch for adjusting drone speed
Page	27

APPENDIX B:

Technical Data Sheet: Yuneec Typhoon Q500

Typhoon Aircraft 

Dimension

Flight Time up to 25 minutes

Weight with Battery and 

Payload 60.0 oz (1700g)

Weight without Battery 

and Payload 40.0 oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

Transmitter 10-channel 2.4GHz with 5.8GHz video downlink (included)

3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home

Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the Typhoon GUI)
Page	28

Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature 

Range −5°C to 80°C

Radio Control Frequency 

Band 2.4GHz

Max. Descent Speed 2m/s

Max. Flight Speed 8m/s

Gimbal Camera 

Type CGO3

Weight 6.9oz (195g)

Focusing System Aerial Optimized Fixed Focus

Field of View 115°

Video Transmission 

Range

FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) with ST10

Video Resolution UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS — FULL HD: 1080p at 

24/25/30/48/50/60/120FPS 

Photo Resolution 12 Megapixels
Page	29

Storage (memory) microSD Class 10 ~ 4 to 128 GB

Control Angle Accuracy ±0.02°

White Balance Automatic or manual settings

Transmission Band 5.2GHz–5.8GHz

Input/Operating 

Voltage 12V

Working Temperature −10°C–50°C

Storage Temperature −20°C–60°C

Angular Vibration 

Range ±0.02°

Control Range Pitch: between −90° and 0° Yaw: between 0° and 360°

Microphone Yes

Camera Lens 0.6in (14mm)/f2.8 (1.4in/35mm)—No distortion

Sensor 1/2.3′′ CMOS

Personal Ground Station 

Dimensions

Type ST10+

Operating System AndroidTM

Number of Channels 10

Control Transmission 

Range (Optimum

FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m

(1312.34 ft) Warning: You Must Follow Local Laws and Maintain Visual Line 
Page	30

Conditions) of Sight of Aircraft at All Times

Robust Radio Control 

Modulation Yuneec Protocol

Video Link Frequency 

Band 5.8GHz

Video Transmission 

Range (Optimum

Conditions)

FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 

ft) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of 

Aircraft at All Times

Flight Systems 

Telemetry Data On 

Screen Display

Yes

LED Backlit LCD 

Screen Capacitive Multi-touch 5.5′′

Tactile (Vibrating) 

and Audible Feedback Yes

Built-in LiPo Battery 

Voltage / Capacity 3.6V/5200mAh 18.72Wh

Screen Resolution 854 × 480px

Camera Settings White balance, light exposure, ISO, shutter speed, video resolution, FPS, record 

video, take pictures
Page	31

Appendix C: 

Technical Data Sheet: DJI PHANTOM 3

Performance 

Maximum Speed Ascent: 16.4' fps / 5 m/s

Descent: 9.8' / 3 m 

Hover Accuracy Vertical: ±3.9" / 10 cm

Horizontal: ±3.3' / 1 m 

Maximum Altitude Above Sea Level: 19,685' / 6000 m 

Flight Time 23 minutes (depending on conditions) 

Flight Control System 

GPS Mode GPS / GLONASS 

Vision Positioning 

Frequency: 50 Hz

Velocity Range: Below 26.2 fps / 8 m/s (6.6' / 2 m 

above the ground)

Altitude Range: 11.8" to 118.1" / 30 cm to 300 cm

Operating Range: 11.8" to 118.1" / 30 cm to 300 cm 

Operating Environment: Surface with clear pattern 

and adequate lighting (> 15 lux) 

Transmitter 

Frequency 2.400 to 2.483 GHz 
Page	32

Communication Distance 6561.7' / 2000 m (outdoors and unobstructed) 

Receiver Sensitivity 1%PER: 101 dBm ±2 dBm 

Transmitter Power EIRP: 20 dBm 

Working Current 1.2 A at 7.4 V 

Connectivity

1 x USB type A female for mobile device interface

1 x Micro-USB female for firmware updates / 

assistant software 1 x Charge port 

Lightbridge Support Yes; compatible iOS or Android mobile device with 

USB required 

Mobile Device Holder Compatibility: Tablet or smartphone 

Operating Temperature 32 to 104°F / 0 to 40°C 

Camera 

Sensor 

Make: Sony EXMOR

Size: 1/2.3"

Resolution: 12.76 MP (12.4 MP effective) 

Lens 

Aperture: f/2.8

FOV: 94° 

Focal Length: 20 mm (35 mm equivalent)

Elements: 9

Focus: 0 to ∞ 
Page	33

Photo Resolution Up to 12 MP (4000 x 3000) 

ISO Range Video: 100 to 3200 

Photo: 100 to 1600 

Video Resolutions 

DCI 4K (4096 x 2160): 24p, 25p

UHD 4K (3840 x 2160): 24p, 25p, 30p

1080p (1920 x 1080): 24p, 25p, 30p, 48p, 50p, 60p

720p (1280 x 720): 24p, 25p, 30p, 48p, 50p, 60p 

Photo Modes 

Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7 EV Bias

Time-lapse 

File Formats 

Video: MPEG-4 AVC/H.264 in MOV wrapper (up 

to 60 Mbps)

Photo: JPEG, DNG RAW 

Recording Media 

Type: microSD/SDXC card up to 64 GB

Format: FAT32 / exFAT 

Note: Class 10, UHS-1 or faster card required 

Operating Temperature 32 to 104°F / 0 to 40°C 

Gimbal 

Number of Axes 3-axis (pitch, roll, yaw) 

Control Range -90° to +30° 
Page	34

Motor 

Type Brushless 

Recommended Takeoff Weight 10.6 oz / 300 g per axis 

Maximum Tension 1.8 lb / 800 g per axis 

Stator Size 0.9 x 0.5" / 23 x 12 mm 

Motor Velocity Constant KV: 960 rpm/V 

Working Temperature 23 to 104°F / -5 to 40°C 

Weight 1.9 oz / 55 g 

Flight Battery 

Chemistry Lithium-polymer 

Capacity 4480 mAh

68 Wh 

Configuration 4S 

Voltage 15.2 VDC 

Weight 12.9 oz / 365 g 
Page	35

Maximum Charging Power 100 W 

Operating Temperature 32 to 104°F / 0 to 40°C 

Charger Voltage: 17.4 VDC

100 W 

Mobile App 

Name DJI Pilot 

System Requirements 

OS: iOS 8.0 or later; Android 4.1.2 or later

Recommended Devices:

iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air 

(Wi-Fi and cellular versions), iPad mini 2 (Wi-Fi 

and cellular versions), iPad Air 2 (Wi-Fi and cellular 

versions), iPad mini 3 (Wi-Fi and cellular versions)

(Note: Optimized for iPhone 5s, iPhone 6, and 

iPhone 6 Plus) 

Android: Samsung S5, Note 3, Sony Xperia Z3, 

Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 

mini 

Note: Additional devices may be compatible but 

have not yet been tested 

General 

Operating Temperature 32 to 104°F / 0 to 40°C 
Page	36

Dimensions Diagonal (Including Propellers): 23.2" / 590 mm 

Weight Including Battery and Propellers: 2.8 lb / 1.3 kg 

Packaging Info 

Package Weight 9.8 lb 

Box Dimensions (LxWxH) 15.4 x 14.3 x 8.3" 
Page	37

Appendix D: Maintenance Log: (sample)

Maintenance Log

UAS: Chroma 1

Date: 

mm/dd/yy Discrepancy: Corrective Action: Tech/Date

11/9/2015 Left Front prop has chip (sample) Replaced left front prop RC 11/10

Form: m10111/15