**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: 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 O F 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**Page 2**  **TABLE OF CONTENTS**
Page GLOSSARY OF A BBREVIATIONS.....................
. .................................................. .... .... . ...... ... ...3 T HE SPECIFI C SECTIONS OF 14 C .F.R
.. ................... ......................... . ..... ... .. ....... . .. . . . .... . .... . . .. . ... 4 SUMMARY......................
............................................................................................... .... ....... . . .. ..5 IN TRODUCTION AND INTERESTS OF PETITIONER..............................................
.... .... ... . ....5 BACKGROUND........................
.................................................................................... .... ... ... . ......6 BASI S FOR PETITION...................................................................................................
.... ... . . .......7 NAME AND ADDRES S OF PETITIONER..............
...... ............ .. ............. ...... ... .. . ...... . .. ...8 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH PAULJUDKINS SEEKS EXEMPTI ON..............
........................ ... ..... .. ... . ............. .... . . ..... 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 RE ASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY........................................................................
.. .. . . ... . ..1 7 CONCLUSION..........................................................................................
......................... . . ... .. ....2 3 APPENDIX A
................ ... ................................................................................................... . .. . . .. ...2 4 BLADE CHROMA TECHNI CALDATA SHEET APPENDIX D
................ ... ........ ........................................................................................... ....... ... 2 7 MAINTENANCE LOG**Page 3**  **GLOSSARY OF ABBREVIATIONS**
AGL Above Ground Level AOI Area of Interest AMA Academ y of Model Aeronautics ATC Air Traf fic 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 Poly mer battery LOL Loss of Link MPH Miles Per Hour NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command RCV Radi o 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 Sy stem VFR Visual Flight Rules VLOS Visual L ine of S ite 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 a nd Parts 14 C.F.R. 45.23(b); D isplay of marks; general
**14 C.F.R. 61.113 (a)**  **& (b);** Private pi lot 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**
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 Moderni zation and Reform Act of 2012 (FMRA). This exemption will permit PAULJUDKINS to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial inspections, aerial video and photography of construction sites areas .

**INTRODUCTIO N AND INTERESTS OF THE PETITIONER**  My name is PAULJUDKINS , and I am a drone operator (pilot) with expertise and knowledge in all aspects of o perating multiple ty pes of UAS's along with camera set up and operation. PAUL JUDKI NS also provides clients with t he highest quality digital content for use in their aerial inspections and aerial video photography of construction sites

. PAULJUDKINS is a member of AMA

. The objective of PAULJUDKINS aerial video and photo graphy operations is to provide aerial inspecti ons, high quality imag ing for a variety of commercial uses. PAULJUDKINS will also provide knowledge of UAS ’s and promote safe UAS operations.**Page 6**  **BACKGROUND** Unmanned Aircraft Sy stems: BLADE CHROMA UAS
. PAULJUDKINS seeks an exemption to operate Blade UAS for compensation or hire within the NAS. The BLADE CHROMA is a v ertical 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 b y Lithium Poly

mer b attery

powered electric motors. The BLADE CHROMA UAS that will be operated b y PAUL JUDKINS will be register ed 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, I dentification and Registration Markings.**Page 7**  **BASIS FOR PETITION** Petitioner, PAULJUDKINS , p ursuant 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 Sy stems, hereby petitions the Administrator to commerciall y operate the BLADE CHROMA UAS in the National Airspace Sy stem (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 considerati on 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 certif icate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, 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 onl y apply t o aircraft with an airworthiness certificate. PAULJUDKINS 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 Manual s ). Furthermore, PAULJUDKINS 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 b y PAUL JUDKINS to the extent necessary to allow a Pilot in Command (PI C) who has demonstrated, by meeting minimum flight

- hour requirements, that the PI C 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, vehic les and structures. PAULJUDKINS seeks relief from Section 91.7(a), entitled c ivil aircraft airworthiness, because the BLADE CHROMA UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, PAUL JUDKINS s ubmits that he will ensure that the BLADE CHROMA UAS is in an airworth y condition, prior to every flight, b y 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 c ondition for safe flight.**Page 8** 

PAULJUDKINS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the BLADE CHROMA UA will not have a ty pical barometric altimeter onboard. However, altitude information of the BLADE CH ROMA UA will be provided to the PI C via Global Positioning Sy stem (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 PAULJUDKINS ’ 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 Se ction 91.151(b), entitle d Fuel R equirements for flight in VFR conditions. PAULJUDKINS submits that safety will not be affected b y 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 2 5 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 safel y 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: PAULJUDKINS 3165 Hustleville Rd. Albertville , AL 35951 ( 256 ) 558
- 3938 Email: paul3165 @ charter

. net**Page 9** 

**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) a**  **nd (b):**  (a) Section 61.113, entitled P rivate 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 (PI C) of an aircraft that is carrying pa ssengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b ) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or employment if

— a. The flight is only

incidental to that business or employ ment; 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, e ntitled c ivil 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, b y reference to an altim eter that is set, when operating UA b elow 18,000 feet MSL, to: (i) The current reported altimeter setting of a station along the route and within 1 00 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) Inthe 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. 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 rotorc raft under VFR conditions unless considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 20 minutes. **5 .**  **PAUL JUDKINS Seeks E**  **xemption 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 be tween 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 b y 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 provide d 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 se rvice 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.**Page 11** 

**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 inspe ctions, 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 overh aul 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 b y 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. An y the AD or safety directive involves recurring action, the time and date when the next action is r equired. (vi ) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y 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 secti on shall be retained until the work is repeated or superseded b y other work or for 1 ye ar 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 th e 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**  **a nd T**  **he 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 PI C who has met certain flight

- hour and currency requirements, to conduct the proposed UA flight operations for compensation or hi re. (a) T his relief is requested since the limitations set forth in Section 61.113(a) and (b) S tate that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if: 1 . The flight is onl y incidental to that business or employ ment; and 2 . The aircraft does not carry passengers or property

for c ompensation or hire. As set forth more full y below, PAUL JUDKINS submits that an equivalent level of safety will be maintained be cause no PI C will be allowed to operate the BLADE CHROMA UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safel y 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 c onducted b y 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 propert y for compensation or hire.**Page 13** 

**2. Extent Of Relief PAUL JUDKINS**  **Seeks And The Reason PAUL JUDKI**  **NS See**  **ks Relief From Section 91.7(a):**  Relief from Section 91.7(a) entitled Civil Aircraft A irworthiness is requested to the extent required to allow PAUL JUDKI NS to determine that the BLADE CHROMA UAS is in airworth y condition prior to every flight b y e nsuring that the UAS is in compliance with the operating documents (i.e., Blade Chroma Instruction Manual s ). PAULJUDKINS seeks the requested relief because the BLADE CHROMA UAS do es 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 airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and BLADE CHROMA Instruction Manual s ) 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**  **Se eks**  **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 PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UA operations be reported to air traffic control (ATC) in feet above ground level (AGL), PAULJUDKINS 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, wh ich automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS.**Page 14** 

**4. Extent o f Relief**  **PAUL JUDKINS Seeks**  **A nd 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 fl y after that for at least 4.5 minutes. PAUL JUDKINS seeks the re quested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered BLADE CHROMA UA will severel y constrain the practicality of an y 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 JUDKI NS will safel y operat e the battery powered BLADE CHROMA UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fl y for a total duration of 15 .5 minutes to the first point of intended landing and, assum ing normal cruising speed, to fl y after that for at least 4.5 minutes. **5. Extent o f 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) onl y apply to aircraft with an airworthiness certificate, PAULJUDKINS requests relief from these Sections because the BLADE CHROMA UAS do es not require airworthiness certificates. As set f

orth more fully

below, the BLADE CHROMA UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, 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., PAULJUDKINS Aerial Operations Manual, Monthly Maintenance Log, and BLADE CHROMA Instruction Manual s ). Furthermore, PAULJUDKINS will document and maintain all maintenance records for the BLADE CHROMA UAS
.**Page 15** 

**D . The Reasons Why Granting**  **PAUL JUDKINS Request Would Be In The Public Interest;**  **That Is, How It Woul d Benefit The Public As A Whole:**  Granting the present Petition will further the public interes t by allowing PAULJUDKINS to safel y, efficientl y, and economicall y perform aerial inspections, and video photograph y of construction properties over certain areas of the United States. Additionally , use of the BLADE CHROMA UAS will decrease congestion o f the NAS, reduce pollution, crashes and accidents caused b y pilot error and provide significant benefits to the econom y. Notably, the benefits of PAULJUDKINS ’ s proposed operation of the BLADE CHROMA UAS will be realized without implicating any privacy is sues. **1. The Public Will Benefit From Decreased Congestion o**  **f 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 obt ain 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 increa se the safety of life and property in the air and on the ground. Furthermore, b y 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 do es not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial inspections and aerial video photography missions would result in fewer aircraft that must be handled b y air traffic control during the ground, takeoff, d eparture, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency o**  **f The BLADE CHROMA**  **UAS :**  Conducting aerial inspections, and aerial acquisitions with the BLADE CHROMA UAS , instead of manned aircraft , will greatl y benefit the public by drasticall y 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 typ ically 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 UA S’ s are propelled b y battery powered electric motors, rather than an internal combustio n 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 b e substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, th e 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 3 0 mph. The UAS are equipped with four main rotors driven b y Li thium Polymer battery powered electric motors , and with no fuel on board , has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the**Page 16** 

manned aircraft that typi cally 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 Photo**  **graphy 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. econom y. 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 fle xibility 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. econom y. 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 f light operations that have been conducted for decades, PAUL JUDKINS ’ s proposed operation of the BLADE CHROMA UAS will not implicate any

privacy issues. Specificall y, the BLADE CHROMA UAS will be operated only in compliance with operating documents (i.e., A erial Operations Manual, Monthly Maintenance Lo g, and BLADE CHROMA Instruction Manual s ) 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 W hich**  **PAUL JUDKINS Seeks Exem**  **ption :**  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 day s after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft s ys tems may operate safel y in the national airspace s ys tem before completion of the plan and rulemaking required b y section 332 of this Act or the guidance required b y s ection 334 of this Act. (ii) Assessment of Unmanned Aircraft S ys tems.
-- In making the determination under subsection ( a), the Secretary shall determine, at a minimum

— (a) which typ es of unmanned aircraft s ys tem (UAS), if an y, 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 s ys tems identified under paragraph (1). ( iii ) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft s ys tems may operate safel y in the national airspace sy stem, the Secretary shall establish requirements for the safe operation of such aircraft s ys tems in the national airspace s ys tem. In seeking this exemption, PAULJUDKINS submits that the BLADE CHROMA UAS can operate safel y 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 o f**  **The BLADE C**  **HROMA UAS Demon**  **strate Its Safe Characteristics:**  The BLADE CHROMA UAS do es 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) Tec hnical Specific ations 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 M odes Enable the UAS to remain w ithin 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 u ser m anuals. **(** iii) The BLADE CHROMA UAS are designed f or Automatic Return t o Home Point o r Hover In The event of Loss o f The Control Li nk o r Navigation. When the Control L ink is lost, the BLADE CHROMA will remain stationary , in flight, for 3 seconds or mo re. If, after 3 seconds, the BLADE CHROMA UA S do es not reacquire control link data from the GCS, the UA S will assume that the Control L ink 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 f unctions of the BLADE CHROMA are set in the owner’s manuals

. (iv) The BLADE CHROMA G CS and i ts o peration. 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:**  PAULJUDKINS will only utilize pilots who have been trained and meet the requirements to act as a pilot in command (PI C) 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 Lim itations:**  In seeking this exemption, PAULJUDKINS proposes to commerciall y operate BLADE CHROMA UAS for the special purpose of conducting aerial inspections, and aerial video photograph y over certain areas of United States, pursuant to the following spec ific 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 flo wn 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 b y 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 PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as s pecified on the PIC’s government issued identification

. **6.** The use of first person view (FPV) b y the PI C 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 alway s maintains VL OS capability . The SO and PI C 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 trans fer his or her designation for the duration of the flight. The PI C 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 PI C with seeing and avoiding othe r 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 c onditions and limitations contained in the grant of exemption take precedenc e 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 an d 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 th e 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 PI C 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 properl y 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 PI C 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 mus t 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 operati ng 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 PI C meets the operator’s qualification criteria and demonstrates the ability to safel y 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 purpo ses of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essent ial for flight operations are considered nonparticipants, and the PI C 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 PI C 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 f

light 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 ref erence 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 b y the operator’s COA. The letter of agreem ent 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 P IC
. **22.** If the UA loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. **23.** The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.**Page 21**  **24.** The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed t o 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 exempt ion. 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 i ssued 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 identi fication 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 Communicatio ns 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 yi eld the right of way to all manned aviation operations and activities at all times. **30.** The UAS may

not be operated b y 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 PI C, 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 immediatel y and/or; (b ) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehi cles or structures has granted permission and the PI C 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 PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). **3 2**  **.** All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission f

rom 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 b y the applica ble 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**  **:** PAULJUDKINS submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC wi ll be allowed to operate the BLADE CHROMA UAS unless that PI C has demonstrated, by meeting minimum flight

hour and currency

requirements, that the PI C is able to safel y operate the BLADE CHROMA UAS in a manner consistent with the exemption, including evasi ve 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 safel y operate the BLADE CHROMA UAS , PAULJUDKINS submits that the additional manned airmansh ip experience of a commerciall y certificated pilot would not correlate to the airmanship skills necessary for specific proposed flight operations. The FAA has previo usly granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein. PAULJUDKINS will not allow any PIC to operate the BLADE CHROMA UAS unless that PI C has demonstrated, b y me eting minimum flight

- hour requirements or the BLADE CHROMA UAS training and currency

requirements, that the PI C is able to safel y operate the BLADE CHROMA UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintai ning appropriate distances from people, vessels, vehicles and structures. Specifically , the PI C 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 PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). **CONCLUSION** PAULJUDKINS 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 photograph y 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, whil e also advancing the interests of the public, by allowing PAUL JUDKINS to safely , efficiently , and economicall y operate the BLADE CHROMA UAS commerciall y within the NAS.**Page 23** 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, PAULJUDKINS 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 photograph y 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 Ty pe: Quadcopter Prop Diameter: 10.2 in (260mm) Approximate Flight Time: 30 minutes Battery : 11.1V 3S 6300mAh L i

- Po
H eight: 9.50 in (242mm) Weight: 45.9 oz (1.3 kg) Motor Ty pe: 4 × 780Kv Brushless Outrunner
Control L ink: 2.4GHz
Video L ink: 5.8GHz
Video L ink Range: 1,970 ft (600m) Satellite Navigation Sy stem: GPS, GL ONASS Completion Level: Ready

- to
- F ly**Page 25** 

**Blade Chroma Features Smart	Mode**  Perfect for the first

- time drone fl yers

 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 b uilt

- 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 lan dings 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 t o 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 inc luded 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 eas y 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. Every thing 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
 Display s live video and real

- time telemetry info like speed, altitude and battery voltage
 Clearly

marked swi tches 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)



## Mainte **nance 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: m101

11/15