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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PAUL JUDKINS 

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 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

112-95)

Submitted on February 11, 2016

PAUL JUDKINS 

3165 HUSTLEVILLE RD.

ALBERTVILLE, AL 35951

(256) 558-3938
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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 

PAUL JUDKINS SEEKS EXEMPTION............................................................................9

THE EXTENT OF RELIEF PAUL JUDKINS SEEKS AND 

THE REASON PAUL JUDKINS SEEKS THE RELIEF........................................12

THE REASONS WHY GRANTING PAUL JUDKINS 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 D................................................................................................................................27

MAINTENANCE LOG 
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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 
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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
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SUMMARY

PAUL JUDKINS 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 PAUL JUDKINS to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial inspections, aerial video and photography of 

construction sites areas.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is PAUL JUDKINS, 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. PAUL

JUDKINS also provides clients with the highest quality digital content for use in their aerial 

inspections and aerial video photography of construction sites. PAUL JUDKINS is a member of 

AMA.

The objective of PAUL JUDKINS aerial video and photography operations is to provide aerial 

inspections, high quality imaging for a variety of commercial uses. PAUL JUDKINS will also provide 

knowledge of UAS’s and promote safe UAS operations. 
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BACKGROUND

Unmanned Aircraft Systems: BLADE CHROMA UAS.

PAUL JUDKINS seeks an exemption to operate Blade UAS for compensation or hire within the 

NAS. The BLADE CHROMA is a 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. The BLADE CHROMA UAS is equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. The BLADE CHROMA UAS that will be 

operated by PAUL JUDKINS 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, PAUL JUDKINS, 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 UAS 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, PAUL JUDKINS’s operation of BLADE CHROMA UAS 

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, PAUL JUDKINS 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. 

PAUL JUDKINS submits that the requested relief is proper since an equivalent level of safety will 

be ensured. PAUL JUDKINS 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 Instruction 

Manuals). Furthermore, PAUL JUDKINS will document and maintain all maintenance records for 

the BLADE CHROMA UAS. 

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

limitations: Pilot in command, is requested by PAUL JUDKINS 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 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

PAUL JUDKINS seeks relief from Section 91.7(a), entitled civil aircraft airworthiness, because 

the BLADE CHROMA UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, PAUL JUDKINS submits that he will ensure that the BLADE 

CHROMA UAS is in an airworthy condition, prior to every flight, by determining that the UAS is

in compliance with the operating documents (i.e, and BLADE CHROMA Instruction Manuals, and 

that the aircraft are in a condition for safe flight. 
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PAUL JUDKINS also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the BLADE CHROMA UA will not have a typical barometric altimeter 

onboard. However, altitude information of the BLADE CHROMA 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 PAUL JUDKINS’s operation of the BLADE CHROMA UA within 

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

91.121. 

Additionally, PAUL JUDKINS seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel Requirements for flight in VFR conditions. PAUL JUDKINS submits that safety will 

not be affected by operation of the BLADE CHROMA 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, PAUL JUDKINS 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: 

PAUL JUDKINS

3165 Hustleville Rd.

Albertville, AL 35951

(256) 558-3938

Email: paul3165@charter.net
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B. The Specific Sections of 14 C.F.R. From Which PAUL JUDKINS Seeks Exemption. 

1. PAUL JUDKINS 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: 

(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—

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. PAUL JUDKINS 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. PAUL JUDKINS Seeks Exemption from The Requirements Of Section 

91.121:

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

(i) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area 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. 
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4. PAUL JUDKINS 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. PAUL JUDKINS 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—

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

inspections have discrepancies repaired as required. 

6. PAUL JUDKINS 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: 

(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. PAUL JUDKINS 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: 

(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. 
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8. PAUL JUDKINS 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: 

(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: 

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. Any 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) 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 PAUL JUDKINS Seeks And The Reason PAUL JUDKINS Seeks 

The Relief. 

1. Extent of Relief PAUL JUDKINS Seeks and The Reason 

PAUL JUDKINS 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, PAUL JUDKINS submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the BLADE CHROMA 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 UAS 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, PAUL JUDKINS submits that all flights of the BLADE CHROMAUAS

conducted by the PIC pursuant to the grant of this Petition: 

1. Will be incidental to PAUL JUDKINS's business; and 

2. Will not carry passengers or property for compensation or hire. 
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2. Extent Of Relief PAUL JUDKINS Seeks And The Reason PAUL JUDKINS 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 PAUL JUDKINS to determine that the BLADE CHROMA UAS is in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the

operating documents (i.e., Blade Chroma Instruction Manuals). 

PAUL JUDKINS seeks the requested relief because the BLADE CHROMA UAS does not 

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

Therefore, PAUL JUDKINS will ensure that the BLADE CHROMA UAS is in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and BLADE CHROMA 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 PAUL JUDKINS Seeks And The Reason PAUL JUDKINS 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 UAS 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), PAUL JUDKINS seeks the requested 

relief because the BLADE CHROMA UAS 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 UAS is 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. 
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4. Extent of Relief PAUL JUDKINS Seeks And The Reason PAUL JUDKINS 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

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. PAUL JUDKINS

seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered BLADE CHROMA UA will severely constrain the 

practicality of any aerial video or still photo flight operations that PAUL JUDKINS

proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical 

specifications of the BLADE CHROMA UAS, the BLADE CHROMA operating 

documents, and PAUL JUDKINS’s proposed operating limitations, ensure that PAUL

JUDKINS will safely operate the battery powered BLADE CHROMA UAS 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 PAUL JUDKINS Seeks And The Reason PAUL JUDKINS 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, PAUL JUDKINS requests relief from 

these Sections because the BLADE CHROMA UAS does not require airworthiness 

certificates. As set forth more fully below, the BLADE CHROMA UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, PAUL JUDKINS 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., PAUL JUDKINS Aerial 

Operations Manual, Monthly Maintenance Log, and BLADE CHROMA Instruction

Manuals). Furthermore, PAUL JUDKINS will document and maintain all maintenance 

records for the BLADE CHROMA UAS. 
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D. The Reasons Why Granting PAUL JUDKINS 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 PAUL JUDKINS

to safely, efficiently, and economically perform aerial inspections, and video photography 

of construction properties over certain areas of the United States. 

Additionally, use of the BLADE CHROMA UAS 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 PAUL JUDKINS’s proposed operation of 

the BLADE CHROMA UAS will be realized without implicating any privacy issues. 

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

The BLADE CHROMA UA’s are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized for 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 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 UAS does not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial inspections and aerial video 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 

UAS:

Conducting aerial inspections, and aerial acquisitions with the BLADE CHROMA UAS, 

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 UAS

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 aerial inspections and aerial video photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The BLADE CHROMA UAS, 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. 

By using the BLADE CHROMA UAS to perform 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 UAS 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 
Page	16

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 UAS Will Benefit The Economy:

In addition to being safe and efficient, the BLADE CHROMA UAS are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operations of the BLADE CHROMA UAS 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 UAS 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 UAS 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 UAS, 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, PAUL JUDKINS’s proposed operation of the BLADE CHROMA UAS will not 

implicate any privacy issues. Specifically, the BLADE CHROMA UAS will be operated 

only in compliance with operating documents (i.e., Aerial Operations Manual, Monthly

Maintenance Log, and BLADE CHROMA 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. 
Page	17

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 PAUL JUDKINS Seeks Exemption:

1. Reasons Why The BLADE CHROMA 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, PAUL JUDKINS’s operation of the 

BLADE CHROMA UAS 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). 

(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, PAUL JUDKINS submits that the BLADE CHROMA UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) The characteristics of the BLADE CHROMA UAS; 

(b) The pilot certification requirement; and 

(c) The specific operating limitations. 
Page	18

a. The Specifications of The BLADE CHROMA UAS Demonstrate Its Safe 

Characteristics:

The BLADE CHROMA UAS does 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 UAS. 

The technical specifications of the BLADE CHROMA UAS are set forth by the BLADE 

CHROMA Specifications and Data Sheets, attached. 

(ii) The BLADE CHROMA UAS Autonomous Flight and Navigation Modes Enable the 

UAS to remain within A Defined Operational Area. The BLADE CHROMA UAS may be 

operated in both manual and fully autonomous flight modes. A complete description of the 

flight and navigational modes of the BLADE CHROMA UAS is provided in the BLADE 

CHROMA user manuals.

(iii) The BLADE CHROMA UAS 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 will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the BLADE CHROMA UAS does 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 are 

set in the owner’s manuals.

(iv) The BLADE CHROMA GCS and its operation. A complete description of the 

operation and specifications of the BLADE CHROMA GCS and flight control software is 

provided in the User Manuals.

b. Flight Operations Of BLADE CHROMA UAS Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer:

PAUL JUDKINS will only utilize pilots who have been trained and meet the 

requirements to act as a pilot in command (PIC) of the BLADE CHROMA UAS. 

Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of BLADE CHROMA UAS Will Be Conducted Pursuant To Specific 

Operating Limitations:

In seeking this exemption, PAUL JUDKINS proposes to commercially operate BLADE 

CHROMA UAS for the special purpose of conducting aerial inspections, and aerial video 

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 aerial inspections and aerial video 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 
Page	19

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

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. 
Page	20

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 

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. 
Page	21

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.

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 
Page	22

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:

PAUL JUDKINS 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 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the BLADE 

CHROMA UAS in a manner consistent with the exemption, including evasive and 

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

and structures.

Considering PAUL JUDKINS’s proposed area of operations, the operating limitations set 

forth-above, and the airmanship skills necessary to safely operate the BLADE CHROMA 

UAS, PAUL JUDKINS 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. 

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. 

PAUL JUDKINS will not allow any PIC to operate the BLADE CHROMA UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the BLADE CHROMA UAS 

training and currency requirements, that the PIC is able to safely operate the BLADE CHROMA 

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). 

CONCLUSION 

PAUL JUDKINS 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 UAS 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 PAUL JUDKINS to safely, efficiently, and economically operate the BLADE CHROMA 

UAS commercially within the NAS. 
Page	23

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

and Reform Act of 2012, Section 333, PAUL JUDKINS 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 Paul Judkins to operate the BLADE CHROMA UAS commercially

for the purpose of conducting aerial inspections, aerial video photography over certain areas of the 

United States. 

Dated: February 11, 2016

Submitted by

PAUL JUDKINS
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 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