Blackfish	Autonomous	Solutions ,	LLC 1

Lionel	A.	Thomas	II 2800	Aeropark	Dr. Traverse	City,	MI	49686 231
- 218
- 4379 Lionel@blackfishsolutions.us August	24,	2015 U.S.	Department	of	Transportation Docket	Operations 1200	New	Jersey	Ave.,	SE Washington,	DC	20590 Re:	Submission	of	Request	for Determination	under	Section	333	of	the	FAA	Modernization and	Reform	Act	and	Exemptions	under	14	C.F.R.	Section	11.81 Dear	Sir	or	Madam: Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(“FMRA”),	I,	Mr. Lionel A. Thomas II hereby	re quest	a	determination	by	the	Secretary	of	Transportation authorizing	conduct	of	commercial	operations	of	its	UAS	for	the	purposes	of	photography, videography,	inspection	of	infrastructure,	precision	agriculture,	and	scientific	& environmental	research.	Pen ding	a	grant	of	exemption,	I	will	be	launching	my	company which	will	pr ovide	a	broad	spectrum	of	safe and	efficient	aerial	solutions.	I	will	be	using UAS	manufactured	by	DJI	Innovations.	Operations	will	be	conducted	within	and	under	the safeguards	outlined herein	and	as	may	be	established	by	the	FAA	under	FMRA	Section 333(c). I	also	petition	for	exemptions	as	necessary	to	effect	the	determination	requested	pursuant to	FMRA	Section	333.	The	attached	documentation	includes	detailed	exemption	requests that	de monstrate	how	these	exemptions	are	in	the	best	public	interest	and	will	maintain	at least	an	equal	level	of	safety	to	existing	regulations.	Authorizing	me	to	conduct	commercial UAS	operations	would	enhance	community	education	and	awareness	of	UAS.	Further, operation	of	these	UAS	in	these	commercial	operations	are	less	disruptive,	safer,	and	more cost	effective	than	manned	aviation	equivalents	due	to	the	low	al titude	environment,	size, speed and	inherent	risk	of	traditional	commercial	helicopter	operations. These	commercial operations	often	occur	in	the	unsafe	areas	of	the	height
- velocity	diagram	requiring	special precision	and	skill.	I	will	conduct	the	commercial	UAS	operations	in	a	manner	that	will meet,	and	in	many	cases	exceed,	the	current	level	of	safety of	commercial	heli copter operations.	I	will	deploy UAS	that	are	under	25	lbs,	have	a	low	noise	signature,	and	carry	no volatile	fuel,	which	will	limit	collateral	damage	in	the	event	of	catastrophic	failure.	The	low expense	of	operation	compared	to	cost	pr ohibitive	manned	aviation	alternatives	allow	a greater	economic	benefit	to	businesses.	For	these	reasons,	granting	an	exemption	under FMRA	Section	333(c)	is	in	the	public	interest.	UAS	technology	used	for	these	commercial purposes	benefit	the	public	intere st	in	the	following	ways:Blackfish	Autonomous	Solutions ,	LLC 2  Reduces	the	collateral	damage	risks	to	life	and	property	associated	with	low altitude	helicopter	operations	in	undesirable	portions	of	the	height
- velocity envelope.  Increased	public	awareness	regarding	safe	and	responsible	utiliz ation	of UAS.  Increased	economic	wellbeing	to	local	businesses	via	cost	reductions.  Enabling	aerial	business	solutions	to	be	available	to	a	larger	market.  Enhanced	agriculture	practices	resulting	in	reduced	environmental contamination	from pesticide/fertilizer	runoff	and	increased	crop	yields.  More	efficient	and	frequent	inspection	of	infrastructure	due	to	reduced	cost.  Additionally,	I	commit	to	hiring	appropriately qualified	pilots	and	observers from	the	local	community	whenever	possible	i n	future	expansions.	I appreciate	your	careful	consideration	in	granting	this	exemption.Blackfish	Autonomous	Solutions ,	LLC 3



# Table	of	Contents
I. Regulations

– Exemptions	Requested II. Commercial	Operation/Operator III. Unmanned	Aircraft	System	(UAS) IV. UAS	Pilot
- in
- Command	(PIC) V. Public	Interest VI. Summ ary VII. Appendix	A

– Inspire	1 Operating	Documents VIII. Appendix	B

– S1000 Operating	DocumentsBlackfish	Autonomous	Solutions ,	LLC 4

**I.	Regulations**
**– Exemptions	requested**  Pursuant	to	14	C.F.R .	§	11.81(e),	Blackfish	Autonomous	Solutions ,	LLC. seeks	exemption from	the	below	mentioned	regulations	and	provide	reason	as	to	why	the	exemption	should be	approved	based	on	the	level	of	safety	at	least	equal	to	that	of	which	the	rules	require. **14	C.F.R.	Part	21	Subpart	H**
**– Airworthiness	Certificates**  **Es tablishes:**  The	procedural	requirements	for	the	issuance	of	airworthiness	certificates	as required	by	14	C.F.R.	§	91.203(a)(1).	Given	the	small	size	of	the	UAS	and	the	safeguards that	will	be	taken	as	outlined	below,	an	exemption	from	Part	21	Subpart	H	meet s	the requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	FMRA with	consideration	“of	the	size,	weight,	speed,	operational	capability,	and	proximity	to airports	and	populated	areas	of	the	particular	UAS.” **14	C.F.R.	§	45.23(b )** 
**– Aircraft	Marking	and	Identification	Requirements**  When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is displayed	on	limited,	restricted	or	light
- sport	category	aircraft	or	experimental	or provisionally	certificated	aircraf t,	the	operator	must	also	display	on	that	aircraft	near	each entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more than	6	inches	high,	the	words	"limited,"	"restricted,"	"light
- sport,	"experimental,"	or "provisional," as	applicable.	Our	UAS	will	ensure	compliance	with	§	45.29(f)	to	meet	the intent	of	the	regulation	by	displaying	the	registration	number	in	the	largest	practicable lettering. **14	C.F.R.	61.113	(a)(b)	and	61.133(a)(1)(ii)**
**– Private	and	Commercial	Pilot	Pri** **vilege and	Limitations**  **14	C.F.R.	§	61.113:** (a)	Except	as	provided	in	paragraphs	(b)	through	(g)	of	this	section,	no person	who	holds	a	private	pilot	certificate	may	act	as	pilot	in	command	of	an	aircraft	that is	carrying	passengers	or	property	for	compens ation	or	hire;	nor	may	that	person,	for compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft.	(b)	A	private	pilot	may,	for compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft	in	connection	with	any business	or	employment **14	C.F.R.	§	61.13 3**  :	(a)	Privileges

– (1)	General.	A	person	who	holds	a	commercial	pilot certificate	may	act	as	pilot	in	command	of	an	aircraft

– (ii)	For	compensation	or	hire, provided	the	person	is	qualified	in	accordance	with	this	part	and	with	the	applicable	parts of	th is	chapter	that	apply	to	the	operation.	Currently,	there	are	no	applicable	areas identified	for	UAS	in	either	the	private	or	the	commercial	sector	and	therefore	an exemption	is	required	to	conduct	commercial	operations.	As	flight	operations	will	be conducted	with	an	abundance	of	caution	following	the	procedure	outline	below,	our operations	will	achieve	an	equivalent	level	of	safety	for	each	individual	flight	especially when	compared	to	commercial	flights	identified	in	Part	61	when	originally	developed.	Our operation	will	be	conducted	with	pilots	who	hold,	at	a	minimum,	a	private	certificate	of	any category	or	class	and	a	3 rd class	medical.Blackfish	Autonomous	Solutions ,	LLC 5

**14	C.F.R.	91.7(a)**
**– Civil	Aircraft	Airworthiness**  No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	c ondition.	Currently	there is	no	airworthiness	certificate	for	UAS.	Daily	pre	and	post	flight	inspections	will	be accomplished	in	accordance	with	manufactures	maintenance	manual(s)	and	guidance. During	flight,	the	PIC	will	adhere	to	§	91.7(b)	and	abort	air operations	immediately	upon identification	of	an	in
- flight	emergency	or	other	unsafe	condition.	By	complying	with procedures	outlined	by	the	manufacturer,	an	equivalent	level	of	safety	will	be	achieved. **14	C.F.R.	91.9(b) civil**  **aircraft	flight	manual,	marking,	and	placard	requirements** (b)(2)	prohibits	operation	of	U.S.
- registered	civil	aircraft	unless	there	is	available	in	the aircraft	a	current	approved	Airplane	or	Rotorcraft	Flight	Manual,	approved	manual material,	markings,	a nd	placards,	or	any	combination	thereof.	By	keeping	all	operating documents,	manuals,	authorizations	and	exemptions	in	a	binder	co
- located	with	the	GCS, we	can	meet	the	intent	of	the	regulations	and	therefore	achieve	an	equivalent	level	of safety. **14	C.F. R.	91.109(a)** 
**– Flight	Instruction**  No	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	being	used	for flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	The	majority	of sUAS	by	design	are	developed	with	si ngle	operational	control	through	the	use	of	pre
determined	GPS	enabled	waypoints	programmed	before	or	during	flight	in	addition	to	the use	of	a	single	hand	held	transmitter	or	control	station	controlled	by	the	PIC.	The	design does	not	allow	for	dual	contro ls	during	flight	training	and	therefore	the	exemption	is requested	to	train	operators,	build	experience,	and	maintain	proficiency.	An	equal	level	of safety	will	be	achieved	by	conducting	all	training	in	a	controlled	environment.	Training sessions	will	be	a ccomplished	separately	from	flights	conducted	for	compensation	or	hire. **14	C.F.R.	91.119	(c)**
**– Minimum	Safe	Altitudes**  Except	when	necessary	for	takeoff	or	landing,	no	person	may	operate	an	aircraft	b elow	the following	altitudes:	(a)	Over	any	congested	are a	of	a	city,	town,	or	settlement,	or	over	any open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	highest	obstacle	within	a horizontal	radius	o f	2,000	feet	of	the	aircraft.	(b )	Over	other	than	congested	areas.	An altitude	of	500	feet	above	th e	surface,	except	over	open	water	or	sparsely	populated	areas. In	those	cases,	the	aircraft	may	not	be	operated	closer	than	500	feet	to	any	person,	vessel, vehicle,	or	structure.	(c)	Helicopters,	powered	parachutes,	and	weight
- shift
- control	aircraft. If	th e	operation	is	conducted	without	hazard	to	persons	or	property	on	the	surface

— (1)	A helicopter	may	be	operated	at	less	than	the	min imums	prescribed	in	paragraph	(a)	or	(b )	of this	section,	provided	each	person	operating	the	helicopter	complies	with	any	routes	or altitudes	specifically	prescribed	for	helicopters	by	the	FAA.	Commercial	UAS	operations will	be	conducted	at	or	below	400	ft.	AGL.	Given	the	size,	weight	and	lack	of	fuel;	combined with	operation	limitations	listed	below,	the	operation	will	be	condu cted	with	a	greater level	of	safety	than	exists	with	current	manned	aviation	operations. **14	C.F.R.	91.121 –**  **Altimeter	Settings**Blackfish	Autonomous	Solutions ,	LLC 6

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	altimete r	that	is	set,	when	operating. UAS are	equipped	with	Global	Positioning	System	(GPS),	which	provide	altitude	and	geo
location	data	to	the	operator	without	utilizing	an	altimeter.	Due	to	this	fact,	an	exemption	is required.	GPS	are	p recise	within	a	few	feet	and	combined	with	fail
- safes	and	a	visual observer	the	operation	will	meet	an	equivalent	level	of	safety. **14	C.F.R.	91.151(a)**
**– Fuel	Requirements	for	Flight	in	VFR	Conditions**  No	person	may	begin	a	flight	in	an	airplane	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

— (1)	During	the	day,	to	fly	after	that	for	at least	30	minutes;	This	regulation	is	written	based	on	the	capabilities	of	a	traditional aircraft,	which	have	flight	times	of	several	hours	or	greater;	therefore,	with	the	majority	of sUAS	which	have	flight	times	of	only	an	hour	or	less,	this	regulation	would	effectively	deny the	ability	of	the air	vehicle	to	operate.	The	DJI	UAS	display	a	visual	Warning	and	in	case	of the	DJI	In s pire 1 ,	emit	an	audible	low	battery	alert	at	30%	at	which	time	the	UAS	will automatically	engage	the	landing	sequence.	Based	upon	that	safeguard	and	the	small operation al	area	in	VLOS,	the	operation	can	meet	an	equivalent	level	of	safety. **14	C.F.R.	91.405(a),	91.407(a)(1),	91.409(a)(2)	and	91.417(a)	&	(b)**
**– Maintenance**  **Inspections 91.405(a)	States**  :	Each	owner	or	operator	of	an	aircraft

— (a)	Shall	have	that	aircraft insp ected	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 **91.407(a)(1)	States** :	(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. **91.409(a)(2)	States:** (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

— (2) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of this	chapter.	No	inspection	performed	un der	paragraph	(b)	of	this	section	may	be substituted	for	any	inspection	required	by	this	paragraph	unless	it	is	performed	by	a person	authorized	to	perform	annual	inspections	and	is	entered	as	an	‘‘annual’’	inspection in	the	required	maintenance	records. **91.417(a)	&	(b)	States:** (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:	(paragraphs	1	(i

– iii),	2	(i

– vi)) ;	(b)	The	owner	or operator	shall	retain	the	following	records	for	the	periods	prescribed :	(paragraphs	1

– 3) Because	DJI UAS	at	present	do	not	have	airworthiness	certificates,	these	regulations	do	not apply	and	therefore	an	exemption	is	required.	Pre/Post flight	inspections	and	maintenance will	be	conducted	in	accordance	with	the	manufacturer’s	guidance	as	stated	in	theBlackfish	Autonomous	Solutions ,	LLC 7

operations	manual.	In	addition,	to	meet	the	intent	of	these	regulations,	I	will	maintain	daily logs	of	pre	and	post	flight	inspections.	If maintenance	is	required,	a	dedicated	test	flight	will be	conducted	to	ensure	safety	before	resuming	commercial	operations.	All	inspection, maintenance	and	alterations	will	be	documented	and	maintained	in	a	record.	These	actions will	meet	the	intent	of	the regulations	from	which	exemption	is	being	requested	and	lead	to an	equivalent	level	of	safety. **II.	Commercial	Operator/Operation** Initially,	One	of	our	pilots	holding	at	least	a	private	pilots	license	will	be	the	operator	of	the exempted	UAS,	with	subsequ ent	hiring	of	employees	to	follow. Co
- founder	and	myself	are very	educated	in UAS	subject	matter	and	believe	our	knowledge	is	what	is	needed	to operate	successfully	and	efficiently.	I	request	that	my	future	employees	be	exempt	from§ 61.113	(a)	and	(b)	allo wing	operations	of	my	UAS	for	compensation	or	hire,	possessing only	a	private	pilot	certificate	and	3 rd class	medical.	A	private	pilot	certificate	will demonstrate	a	safe	and	equivalent	level	of	aeronautical	safety,	judgment,	security	and responsibility	to operate	my	UAS.	I	am	knowledgeable	in	human	factors	awareness;	crew resource	management;	and	risk	management.	I	will	apply	those	principles	to	my	operation. For	each	flight,	my	employees	or	I:

 Will	contact	the	controlling	air	traffic	organization	to	is sue	a	NOTAM.  Will	obtain	a	preflight	briefing	from	a	pilot	briefer,	DUATS,	or	similar	means.  Will	conduct	a	comprehensive	worksite	inspection	and	analysis,	identifying	limits of	customer	property	or	authorized	access	areas.  Will	conduct	preflight	pla nning	in	accordance	with	Section	91.103 Preflight	Action.  Will	operate	in	those	areas	only	with	the	consent	of	the	landowner	or	designated representative.  Will	identify	potential	obstructions	or	other	hazards	to	safe	operation.  Will	clear	the	area	of personnel	or	bystanders	that	are	non
- essential	to	the operation,	maintaining	at	a	minimum,	500	feet	away	from	non
- participating persons.  Will	conduct	a	preflight	safety	briefing	to	Visual	Observer	(VO)	and	participating persons.  Will	at	all	times	yiel d	to	manned	air	traffic.  Will	operate	within	VLOS	of	both	PIC **and** VO	during	daylight	hours	only.  Will	maintain	voice	communications	with	VO	and	participating	persons.  Will	operate	under	Class	D	visual	flight	rules,	defined	as	500	feet	below	and	2000 feet	horizontal	from	clouds	with	a	minimum	of	3	statute	miles	of	visibility.  Will	not	exceed	an	altitude	400	feet	AGL	as	determined	by	the	installed	GPS.  Will	keep	operating	documents,	manuals,	authorizations	and	exemptions	in	a binder	collocated	with the	GCS.  Will	immediately	terminate	flight,	in	the	safest	manner	possible,	when	safety	to persons	or	property	become	compromised.  Will	terminate	flight,	in	the	safest	manner	possible,	when	unable	to	comply	with these	limitations	or	any	other	limitation s	granted	as	part	of	this	exemption.	In	order to	remain	at	an	altitude	at	or	below	400	feet	AGL,	relief	is	needed	from	SectionBlackfish	Autonomous	Solutions ,	LLC 8

91.119	(c)	and	(d).	By	following	these	operating	standards,	the	commercial operation	will	meet	an	equivalent	level	of	safety	to	the	regulation	in	which	relief	is sought. **III.	Unmanned	Aircraft	System** I	seek	an	exemption	to	operate	the	DJI	line	of	UAS.	The	Inspire	1	is	the	primary	aircraft	in our	operation	for	which	we	seek	exemption.	We	will	also	be	utilizing	the	S1000	for	larger scale	projections.	The	DJI	UAS	utilize	a	common	autopilot	system	and	comm on	ground control	station	software	(GCS).	The	UAS	will	be	flown	via	a	combination	of	RC	control, Tablet	GCS,	or	PC
- based	GCS.	The	Inpire1	and	S1000	are	GPS	equipped,	multirotor helicopters.	The	Inspire	1	is	a	quad
- type	utilizing	four	rotors.	The	S1000	is a n Octo
- type utilizing	eight	rotors.	The	UAS	are	powered	by	lithium
- polymer	batteries.	The	UAS	will carry	the proprietary camera	from	DJI	or	a	Canon	Mark	III	camera.	The	In s pire	1	and	S1000 UAS	have	the	capability	to	land	at	its	current	location	with	a	dedi cated	switch.	The	UAS	also has	several	fail
- safes	for	loss	of	RC	signal,	loss	of	GPS,	and	low	battery	as	outlined	in	the respective	Operation	Manuals.	The	UAS	display	a	visual	low	battery	alert	at	25%	at	which time	the	UAS	will	automatically	engage	the	lan ding	sequence.	Based	upon	that	safeguard,	I request	exemption	from	Section	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions. The	UAS	also	has	a	height	restriction	function,	which	will	be	programmed	for	a	maximum altitude	of	400	feet.	Given	the	airc raft	will	be	operated	within	VLOS	with	the	aid	of	a	VO,	I believe	the	operation	can	be	conducted	with	an	equivalent	amount	of	safety	and	therefore request	exemption	from	Section	91.121.	Given	the	size,	weight,	speed,	and	controlled operating	area	associate d	with	the	UAS	to	be	utilized,	an	exemption	from	14	CFR	part	21, Subpart	H	(Airworthiness	Certificates) and	§91.203	(a)	and	(b)	is	requested.	I	seek exemption	from	§	45.23 Marking	of	the	aircraft. The	UA will	display	the	registration number	in	the	largest practicable	lettering.	We	wish	to	be	exempt	from	§	91.405(a), 91.407(a)(1),	91.409(a)(2)	and	91.417(a)	and	b). Maintenance	inspections will	be conducted	according	to	operations	manual	and	prudent	judgment	as	previously	outlined	to determine	the	integrity	a nd	safety	of	the	UAS	and	associated	equipment.	Further,	I	require relief	from	91.7(a),	which	prohibits	the	operation	of	an	aircraft	without	an	airworthiness certificate	and	91.9(b)	(2)	requiring	an	approved	flight	manual	in	the	aircraft.	The	UAS	will not	b e	operating	with	an	airworthiness	certificate	therefore,	this	would	be	inappropriate. The	UAS	are	too	small	to	carry	the	operating	documents	so	an	equivalent	amount	of	safety can	be	achieved	through	keeping	the	operating	documents	and	manuals	at	the	GCS. **IV.	UAS	Pilot	in	Command	(PIC)** Under	§	61.113	(a)	and	(b)	private	pilots	are	limited	to	non
- commercial	operations, however	I	can	ensure	my	operation	will	achieve	an	equivalent	level	of	safety	as	current regulation	because	my	UAS	do	not	carry	any	pilots	or passengers.	A	commercial	pilot certificate	will	not	ensure	RC	piloting	ability,	as	the	psychomotor	skills	are	different.	The inherent	risks	of	operating	a	UAS	are	far	less	than	in	the	commercial	activities	outlined	in 14	CFR	part	61,	et	seq.,	thus	I	reques t	an	exemption	from	§	61.113 Private	Pilot	Privileges and	Limitations:	Pilot	in	command. All	UAS	PICs	will	have	logged,	in	accordance	with	61.51 (b),	appropriate	training	on	the	UA	consisting	of	25	hours	as	UAS	rotorcraft,	10	hours multirotor	UAS	or	25	hou rs	as	UAS	airplane,	10	hours	single
- engine	as	appropriate.	PICsBlackfish	Autonomous	Solutions ,	LLC 9

will	maintain	recent	flight	experience	on	the	UAS.	Training	and	experience	flights	will	be conducted	separate	from	commercial	operations. PIC	Training	will	consist	of:

 Pre
- flight	Tasks Fu ll	site	inspection Assembly	and	inspection	of	UAS Set
- up	and	configuration	of	RC	radio	and	GCS System	checks  Mission	Tasks Establish	flight	plan Takeoff	and	landing Manual	flight	modes Autonomous	flight	modes Emergency	Procedures  Post
- flight	Tasks Inspection Shutdown Disassembly  Other	Tasks Regulations Operating	limitations Flight	planning **V.	Public	Interest** Given	the	above	stated	evidence,	procedures,	and	precautions;	I	feel	that	operating	my	UAS commercially	for	the	purposes	of	photography,	vid eography,	inspection	of	infrastructure , precision	agriculture,	and	scientific	&	environmental	research	will	ultimately	be	in	the public	interest.	These	operations,	when	executed	with	prudence,	will	exceed	the	current level	of	safety	as	the	regulations	from which	I	seek	exemption.	My	operation	will	allow greater	access	to	commercial	aerial	services	that	were	not	previously	economically	feasible for	many	firms.	This	will	provide	a	much	needed	economic	uplift	to	the	community	and hence	the	public.	My	operation will	be	conducted	with	less	risk	of	collateral	damage	to persons	and	property	while	limiting	disruptive	noise	pollution	associated	with	low	altitude aviation	operations.	A	major	factor	to	consider	regarding	the	public	interest	is	the	current state	of	UAS operations	in	the	US.	As	a	manned	aviator,	the	need	to	integrate	UAS	into	the national	airspace	system	in	a	safe,	deliberate manner is	always	at	the	forefront	of	my	mind. As	the	technology	becomes	more	readily	available,	the	challenges	will	intensify.	By allowing	commercial	operations,	it	will	enable	communities	to	become	educated	in	the proper	use	of	this	technology.	As	an	educator, I	am	already	working	to	foster	positive awareness	and	safe,	responsible	utilization	of	UAS	technology.	Granting	my	exemption	will result	in	a	direct	extension	of	these	efforts,	which	is	in	the	public	interest. **VI.	Summary**Blackfish	Autonomous	Solutions ,	LLC 10

Pursuant	to	Section	333	of	PL	112
- 95	commonly	known	as	the	“FAA	Modernization and Reform	Act	of	2012”,	Lionel A.	Thomas II ,	hereby	applies	for	authorization	to	conduct commercial	unmanned	aerial	systems	(UAS)	operations	for	the	purposes	of		photography, videography,	inspection	of	infrastructure,	precision	agriculture,	and	scientific	& environmental	research. Rules	in	which	I	seek	exemption:  14	C.F.R.	Part	21	Subpart	H  14	C.F.R.	§	45.23(b)  14	C.F.R.	§	61.113	and	61.133(a)(1)(ii)  14	C.F.R.	§	91.7(a)  14	C.F.R.	91.9(b)  14	C.F.R.	§ 91.103  14	C.F.R.	§	91.109(a)  14	C.F.R.	§	91.119  14	C.F.R.	§	91.121  14	C.F.R.	§	91.151(a)  14	C.F.R.	§	91.405(a)  14	C.F.R.	§	91.407(a)(1)  14	C.F.R.	§	91.409(a)(2)  14	C.F.R.	§	91.417(a)	&	(b) Throughout	this	exemption	request,	I	have	shown how	my	expertise	and	knowledge	with UAS	technology	will	ensure	the	public’s	best	interest	is	at	hand	and	how	my	operation	will aid	in	safely	integrating	civil	UAS	into	the	national	airspace	system.Blackfish	Autonomous	Solutions ,	LLC 11 **VII.** Unmanned Aircraft Vehicle: Inspire 1 UAV

Blackfish Autonomous Solutions , LLC. seeks an exemption to operate its existing Inspire 1, UAV, for compensation or hire within the national airspace s ystem (“NAS”). The Inspire 1 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. The Inspire 1 UAV has a maximum gross weight of approximately six and one half (6.5) pounds and the following technical and operational specifications:

Weight (Battery

Included) 2935 g Hovering Accuracy

(GPS mode) Vertical: 0.5 m

Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) 4500 m Max Flight Altitude 4500m Max Wind Speed Resistance 10 m/s **Figure 1**  **.	DJI	Inspire	1	UAV**Blackfish	Autonomous	Solutions ,	LLC 12

Max Flight Time Approximately 18 minutes Motor Model DJI3510 Propeller Model DJI1345 Indoor Hovering Enabled b y Default Operating Temperature Range

- 10° to 40° C Diagonal Distanc e 559 to 581 mm Dimensions 438 x 451 x 301 mmBlackfish	Autonomous	Solutions ,	LLC 13 **VIII.** Unmanned Aircraft Vehicle: S1000 UAV Blackfish Autonomous Solutions , LLC. seeks an exemption to operate its existing S1000, UAV, for compensation or hire within the national airspace s ystem (“NAS”). The S1000 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. The S1000 UAV has a maximum gross weight of approximately nine and one half (9.5) pounds and the following technical and operational specifications:

Diagonal Wheelbase: 1045mm Frame Arm Length: 386mm Frame Arm Weight: 325g (Including Motor, ESC, Propeller) Center Frame Diameter: 337.5mm Center Frame Weight: 1330g (with Landing Gear Mounting Base, Servos) Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) Motor: Stator Size: 41×14mm KV: 400rpm/V Max Power: 500W Weight: 158g (with Cooling Fan) Working Current: 40A Working Voltage: 6S LiPo **Figure 2**  **.	DJI	S1000	UAV**Blackfish	Autonomous	Solutions ,	LLC 14

Signal Frequency : 30Hz ~ 450Hz Drive PWM Frequency : 8KHz Weight: 35g (with Radiators) Foldable Propeller: (1552/1552R) Propeller Size: 15×5.2inch Weight: 13g Takeoff Weight: 6.0Kg

– 11.0Kg Total Weight: 4.2Kg Power Battery : Lipo (6S 10,000mAh

– 20000mAh 1 5C(Min)) Max Power Consumption: 4000W Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight) Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature:

- 10 °C ~ +40 °C For A2 flight controller: Basic: Roll 120%, Pitch 120%, Yaw 120% Attitude: Roll 170%, Pitch 170%, Vertical 120% For WooKong

- M flight controller: Basic: Roll 180%, Pitch 180%, Yaw 120% Attitude: Roll 180%, Pitch 180%, Vertical 120%