Blackfish	Autonomous	Solutions,	LLC		 1

Lionel	A.	Thomas	II

2800	Aeropark	Dr.

Traverse	City,	MI	49686

231-218-4379

Lionel@blackfishsolutions.us

August	24,	2015

U.S.	Department	of	Transportation

Docket	Operations

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Submission	of	Request	for	Determination	under	Section	333	of	the	FAA	Modernization	

and	Reform	Act	and	Exemptions	under	14	C.F.R.	Section	11.81

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(“FMRA”),	I,	Mr.

Lionel A. Thomas	II	hereby	request	a	determination	by	the	Secretary	of	Transportation	

authorizing	conduct	of	commercial	operations	of	its	UAS	for	the	purposes	of	photography,	

videography,	inspection	of	infrastructure,	precision	agriculture,	and	scientific	&	

environmental	research.	Pending	a	grant	of	exemption,	I	will	be	launching	my	company	

which	will	provide	a	broad	spectrum	of	safe	and	efficient	aerial	solutions.	I	will	be	using	

UAS	manufactured	by	DJI	Innovations.	Operations	will	be	conducted	within	and	under	the	

safeguards	outlined herein	and	as	may	be	established	by	the	FAA	under	FMRA	Section	

333(c).

I	also	petition	for	exemptions	as	necessary	to	effect	the	determination	requested	pursuant	

to	FMRA	Section	333.	The	attached	documentation	includes	detailed	exemption	requests	

that	demonstrate	how	these	exemptions	are	in	the	best	public	interest	and	will	maintain	at	

least	an	equal	level	of	safety	to	existing	regulations.	Authorizing	me	to	conduct	commercial	

UAS	operations	would	enhance	community	education	and	awareness	of	UAS.	Further,

operation	of	these	UAS	in	these	commercial	operations	are	less	disruptive,	safer,	and	more	

cost	effective	than	manned	aviation	equivalents	due	to	the	low	altitude	environment,	size,	

speed and	inherent	risk	of	traditional	commercial	helicopter	operations.	These	commercial	

operations	often	occur	in	the	unsafe	areas	of	the	height-velocity	diagram	requiring	special	

precision	and	skill.	I	will	conduct	the	commercial	UAS	operations	in	a	manner	that	will	

meet,	and	in	many	cases	exceed,	the	current	level	of	safety of	commercial	helicopter	

operations.	I	will	deploy UAS	that	are	under	25	lbs,	have	a	low	noise	signature,	and	carry	no	

volatile	fuel,	which	will	limit	collateral	damage	in	the	event	of	catastrophic	failure.	The	low	

expense	of	operation	compared	to	cost	prohibitive	manned	aviation	alternatives	allow	a	

greater	economic	benefit	to	businesses.	For	these	reasons,	granting	an	exemption	under	

FMRA	Section	333(c)	is	in	the	public	interest.	UAS	technology	used	for	these	commercial	

purposes	benefit	the	public	interest	in	the	following	ways:
Blackfish	Autonomous	Solutions,	LLC		 2

 Reduces	the	collateral	damage	risks	to	life	and	property	associated	with	low	

altitude	helicopter	operations	in	undesirable	portions	of	the	height-velocity	

envelope.

 Increased	public	awareness	regarding	safe	and	responsible	utilization	of	

UAS.

 Increased	economic	wellbeing	to	local	businesses	via	cost	reductions.

 Enabling	aerial	business	solutions	to	be	available	to	a	larger	market.

 Enhanced	agriculture	practices	resulting	in	reduced	environmental	

contamination	from pesticide/fertilizer	runoff	and	increased	crop	yields.

 More	efficient	and	frequent	inspection	of	infrastructure	due	to	reduced	cost.	

 Additionally,	I	commit	to	hiring	appropriately	qualified	pilots	and	observers

from	the	local	community	whenever	possible	in	future	expansions.	I	

appreciate	your	careful	consideration	in	granting	this	exemption.
Blackfish	Autonomous	Solutions,	LLC		 3

Table	of	Contents

I. Regulations	– Exemptions	Requested

II. Commercial	Operation/Operator

III. Unmanned	Aircraft	System	(UAS)

IV. UAS	Pilot-in-Command	(PIC)

V. Public	Interest

VI. Summary

VII. Appendix	A	– Inspire	1 Operating	Documents

VIII. Appendix	B	– S1000 Operating	Documents
Blackfish	Autonomous	Solutions,	LLC		 4

I.	Regulations	– Exemptions	requested

Pursuant	to	14	C.F.R.	§	11.81(e),	Blackfish	Autonomous	Solutions,	LLC. seeks	exemption	

from	the	below	mentioned	regulations	and	provide	reason	as	to	why	the	exemption	should	

be	approved	based	on	the	level	of	safety	at	least	equal	to	that	of	which	the	rules	require.

14	C.F.R.	Part	21	Subpart	H	– Airworthiness	Certificates

Establishes:	The	procedural	requirements	for	the	issuance	of	airworthiness	certificates	as	

required	by	14	C.F.R.	§	91.203(a)(1).	Given	the	small	size	of	the	UAS	and	the	safeguards	

that	will	be	taken	as	outlined	below,	an	exemption	from	Part	21	Subpart	H	meets	the	

requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	the	FMRA	

with	consideration	“of	the	size,	weight,	speed,	operational	capability,	and	proximity	to	

airports	and	populated	areas	of	the	particular	UAS.”

14	C.F.R.	§	45.23(b)	– Aircraft	Marking	and	Identification	Requirements

When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is	

displayed	on	limited,	restricted	or	light-sport	category	aircraft	or	experimental	or	

provisionally	certificated	aircraft,	the	operator	must	also	display	on	that	aircraft	near	each	

entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	

than	6	inches	high,	the	words	"limited,"	"restricted,"	"light-sport,	"experimental,"	or	

"provisional," as	applicable.	Our	UAS	will	ensure	compliance	with	§	45.29(f)	to	meet	the	

intent	of	the	regulation	by	displaying	the	registration	number	in	the	largest	practicable	

lettering.

14	C.F.R.	61.113	(a)(b)	and	61.133(a)(1)(ii)	– Private	and	Commercial	Pilot	Privilege	

and	Limitations

14	C.F.R.	§	61.113:	(a)	Except	as	provided	in	paragraphs	(b)	through	(g)	of	this	section,	no	

person	who	holds	a	private	pilot	certificate	may	act	as	pilot	in	command	of	an	aircraft	that	

is	carrying	passengers	or	property	for	compensation	or	hire;	nor	may	that	person,	for	

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

compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft	in	connection	with	any	

business	or	employment

14	C.F.R.	§	61.133:	(a)	Privileges	– (1)	General.	A	person	who	holds	a	commercial	pilot	

certificate	may	act	as	pilot	in	command	of	an	aircraft	– (ii)	For	compensation	or	hire,	

provided	the	person	is	qualified	in	accordance	with	this	part	and	with	the	applicable	parts	

of	this	chapter	that	apply	to	the	operation.	Currently,	there	are	no	applicable	areas	

identified	for	UAS	in	either	the	private	or	the	commercial	sector	and	therefore	an	

exemption	is	required	to	conduct	commercial	operations.	As	flight	operations	will	be	

conducted	with	an	abundance	of	caution	following	the	procedure	outline	below,	our	

operations	will	achieve	an	equivalent	level	of	safety	for	each	individual	flight	especially	

when	compared	to	commercial	flights	identified	in	Part	61	when	originally	developed.	Our	

operation	will	be	conducted	with	pilots	who	hold,	at	a	minimum,	a	private	certificate	of	any	

category	or	class	and	a	3	rd	class	medical.
Blackfish	Autonomous	Solutions,	LLC		 5

14	C.F.R.	91.7(a)	– Civil	Aircraft	Airworthiness

No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.	Currently	there	

is	no	airworthiness	certificate	for	UAS.	Daily	pre	and	post	flight	inspections	will	be	

accomplished	in	accordance	with	manufactures	maintenance	manual(s)	and	guidance.	

During	flight,	the	PIC	will	adhere	to	§	91.7(b)	and	abort	air	operations	immediately	upon	

identification	of	an	in-flight	emergency	or	other	unsafe	condition.	By	complying	with	

procedures	outlined	by	the	manufacturer,	an	equivalent	level	of	safety	will	be	achieved.

14	C.F.R.	91.9(b)	civil aircraft	flight	manual,	marking,	and	placard	requirements

(b)(2)	prohibits	operation	of	U.S.-registered	civil	aircraft	unless	there	is	available	in	the	

aircraft	a	current	approved	Airplane	or	Rotorcraft	Flight	Manual,	approved	manual	

material,	markings,	and	placards,	or	any	combination	thereof.	By	keeping	all	operating	

documents,	manuals,	authorizations	and	exemptions	in	a	binder	co-located	with	the	GCS,	

we	can	meet	the	intent	of	the	regulations	and	therefore	achieve	an	equivalent	level	of	

safety.

14	C.F.R.	91.109(a)	– Flight	Instruction

No	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	being	used	for	

flight	instruction	unless	that	aircraft	has	fully	functioning	dual	controls.	The	majority	of	

sUAS	by	design	are	developed	with	single	operational	control	through	the	use	of	predetermined	GPS	enabled	waypoints	programmed	before	or	during	flight	in	addition	to	the	

use	of	a	single	hand	held	transmitter	or	control	station	controlled	by	the	PIC.	The	design	

does	not	allow	for	dual	controls	during	flight	training	and	therefore	the	exemption	is	

requested	to	train	operators,	build	experience,	and	maintain	proficiency.	An	equal	level	of	

safety	will	be	achieved	by	conducting	all	training	in	a	controlled	environment.	Training	

sessions	will	be	accomplished	separately	from	flights	conducted	for	compensation	or	hire.

14	C.F.R.	91.119	(c)	– Minimum	Safe	Altitudes

Except	when	necessary	for	takeoff	or	landing,	no	person	may	operate	an	aircraft	below	the	

following	altitudes:	(a)	Over	any	congested	area	of	a	city,	town,	or	settlement,	or	over	any	

open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	highest	obstacle	within	a	

horizontal	radius	of	2,000	feet	of	the	aircraft.	(b)	Over	other	than	congested	areas.	An	

altitude	of	500	feet	above	the	surface,	except	over	open	water	or	sparsely	populated	areas.	

In	those	cases,	the	aircraft	may	not	be	operated	closer	than	500	feet	to	any	person,	vessel,	

vehicle,	or	structure.	(c)	Helicopters,	powered	parachutes,	and	weight-shift-control	aircraft.	

If	the	operation	is	conducted	without	hazard	to	persons	or	property	on	the	surface—(1)	A	

helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in	paragraph	(a)	or	(b)	of	

this	section,	provided	each	person	operating	the	helicopter	complies	with	any	routes	or	

altitudes	specifically	prescribed	for	helicopters	by	the	FAA.	Commercial	UAS	operations	

will	be	conducted	at	or	below	400	ft.	AGL.	Given	the	size,	weight	and	lack	of	fuel;	combined	

with	operation	limitations	listed	below,	the	operation	will	be	conducted	with	a	greater	

level	of	safety	than	exists	with	current	manned	aviation	operations.

14	C.F.R.	91.121	– Altimeter	Settings
Blackfish	Autonomous	Solutions,	LLC		 6

Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	flight	level	of	that	

aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	when	operating.	UAS	

are	equipped	with	Global	Positioning	System	(GPS),	which	provide	altitude	and	geolocation	data	to	the	operator	without	utilizing	an	altimeter.	Due	to	this	fact,	an	exemption	is	

required.	GPS	are	precise	within	a	few	feet	and	combined	with	fail-safes	and	a	visual	

observer	the	operation	will	meet	an	equivalent	level	of	safety.

14	C.F.R.	91.151(a)	– Fuel	Requirements	for	Flight	in	VFR	Conditions

No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	(considering	wind	

and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	first	point	of	intended	

landing	and,	assuming	normal	cruising	speed— (1)	During	the	day,	to	fly	after	that	for	at	

least	30	minutes;	This	regulation	is	written	based	on	the	capabilities	of	a	traditional	

aircraft,	which	have	flight	times	of	several	hours	or	greater;	therefore,	with	the	majority	of	

sUAS	which	have	flight	times	of	only	an	hour	or	less,	this	regulation	would	effectively	deny	

the	ability	of	the air	vehicle	to	operate.	The	DJI	UAS	display	a	visual	Warning	and	in	case	of	

the	DJI	Inspire 1,	emit	an	audible	low	battery	alert	at	30%	at	which	time	the	UAS	will	

automatically	engage	the	landing	sequence.	Based	upon	that	safeguard	and	the	small	

operational	area	in	VLOS,	the	operation	can	meet	an	equivalent	level	of	safety.

14	C.F.R.	91.405(a),	91.407(a)(1),	91.409(a)(2)	and	91.417(a)	&	(b)	– Maintenance	

Inspections

91.405(a)	States:	Each	owner	or	operator	of	an	aircraft—(a)	Shall	have	that	aircraft	

inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	

except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	

prescribed	in	part	43	of	this	chapter

91.407(a)(1)	States:	(a)	No	person	may	operate	any	aircraft	that	has	undergone	

maintenance,	preventive	maintenance,	rebuilding,	or	alteration	unless—(1)	It	has	been	

approved	for	return	to	service	by	a	person	authorized	under	§	43.7	of	this	chapter.

91.409(a)(2)	States:	(a)	Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	

may	operate	an	aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had—(2)	

An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of	

this	chapter.	No	inspection	performed	under	paragraph	(b)	of	this	section	may	be	

substituted	for	any	inspection	required	by	this	paragraph	unless	it	is	performed	by	a	

person	authorized	to	perform	annual	inspections	and	is	entered	as	an	‘‘annual’’	inspection	

in	the	required	maintenance	records.

91.417(a)	&	(b)	States:	(a)	Except	for	work	performed	in	accordance	with	§§91.411	and	

91.413,	each	registered	owner	or	operator	shall	keep	the	following	records	for	the	periods	

specified	in	paragraph	(b)	of	this	section:	(paragraphs	1	(i– iii),	2	(i	– vi));	(b)	The	owner	or	

operator	shall	retain	the	following	records	for	the	periods	prescribed:	(paragraphs	1	– 3)	

Because	DJI UAS	at	present	do	not	have	airworthiness	certificates,	these	regulations	do	not	

apply	and	therefore	an	exemption	is	required.	Pre/Post flight	inspections	and	maintenance	

will	be	conducted	in	accordance	with	the	manufacturer’s	guidance	as	stated	in	the	
Blackfish	Autonomous	Solutions,	LLC		 7

operations	manual.	In	addition,	to	meet	the	intent	of	these	regulations,	I	will	maintain	daily	

logs	of	pre	and	post	flight	inspections.	If maintenance	is	required,	a	dedicated	test	flight	will	

be	conducted	to	ensure	safety	before	resuming	commercial	operations.	All	inspection,	

maintenance	and	alterations	will	be	documented	and	maintained	in	a	record.	These	actions	

will	meet	the	intent	of	the regulations	from	which	exemption	is	being	requested	and	lead	to	

an	equivalent	level	of	safety.

II.	Commercial	Operator/Operation

Initially,	One	of	our	pilots	holding	at	least	a	private	pilots	license	will	be	the	operator	of	the	

exempted	UAS,	with	subsequent	hiring	of	employees	to	follow.	Co-founder	and	myself	are	

very	educated	in	UAS	subject	matter	and	believe	our	knowledge	is	what	is	needed	to	

operate	successfully	and	efficiently.	I	request	that	my	future	employees	be	exempt	from§	

61.113	(a)	and	(b)	allowing	operations	of	my	UAS	for	compensation	or	hire,	possessing	

only	a	private	pilot	certificate	and	3rd	class	medical.	A	private	pilot	certificate	will	

demonstrate	a	safe	and	equivalent	level	of	aeronautical	safety,	judgment,	security	and	

responsibility	to operate	my	UAS.	I	am	knowledgeable	in	human	factors	awareness;	crew	

resource	management;	and	risk	management.	I	will	apply	those	principles	to	my	operation.	

For	each	flight,	my	employees	or	I:

Will	contact	the	controlling	air	traffic	organization	to	issue	a	NOTAM.

Will	obtain	a	preflight	briefing	from	a	pilot	briefer,	DUATS,	or	similar	means.

Will	conduct	a	comprehensive	worksite	inspection	and	analysis,	identifying	limits	

of	customer	property	or	authorized	access	areas.

Will	conduct	preflight	planning	in	accordance	with	Section	91.103	Preflight	Action.

Will	operate	in	those	areas	only	with	the	consent	of	the	landowner	or	designated	

representative.

Will	identify	potential	obstructions	or	other	hazards	to	safe	operation.

Will	clear	the	area	of personnel	or	bystanders	that	are	non-essential	to	the	

operation,	maintaining	at	a	minimum,	500	feet	away	from	non-participating	

persons.

Will	conduct	a	preflight	safety	briefing	to	Visual	Observer	(VO)	and	participating	

persons.

Will	at	all	times	yield	to	manned	air	traffic.

Will	operate	within	VLOS	of	both	PIC	and	VO	during	daylight	hours	only.

Will	maintain	voice	communications	with	VO	and	participating	persons.

Will	operate	under	Class	D	visual	flight	rules,	defined	as	500	feet	below	and	2000	

feet	horizontal	from	clouds	with	a	minimum	of	3	statute	miles	of	visibility.

Will	not	exceed	an	altitude	400	feet	AGL	as	determined	by	the	installed	GPS.

Will	keep	operating	documents,	manuals,	authorizations	and	exemptions	in	a	

binder	collocated	with	the	GCS.

Will	immediately	terminate	flight,	in	the	safest	manner	possible,	when	safety	to	

persons	or	property	become	compromised.

Will	terminate	flight,	in	the	safest	manner	possible,	when	unable	to	comply	with	

these	limitations	or	any	other	limitations	granted	as	part	of	this	exemption.	In	order	

to	remain	at	an	altitude	at	or	below	400	feet	AGL,	relief	is	needed	from	Section	
Blackfish	Autonomous	Solutions,	LLC		 8

91.119	(c)	and	(d).	By	following	these	operating	standards,	the	commercial	

operation	will	meet	an	equivalent	level	of	safety	to	the	regulation	in	which	relief	is	

sought.

III.	Unmanned	Aircraft	System

I	seek	an	exemption	to	operate	the	DJI	line	of	UAS.	The	Inspire	1	is	the	primary	aircraft	in	

our	operation	for	which	we	seek	exemption.	We	will	also	be	utilizing	the	S1000	for	larger	

scale	projections.	The	DJI	UAS	utilize	a	common	autopilot	system	and	common	ground	

control	station	software	(GCS).	The	UAS	will	be	flown	via	a	combination	of	RC	control,	

Tablet	GCS,	or	PC-based	GCS.	The	Inpire1	and	S1000	are	GPS	equipped,	multirotor	

helicopters.	The	Inspire	1	is	a	quad-type	utilizing	four	rotors.	The	S1000	is	an Octo-type	

utilizing	eight	rotors.	The	UAS	are	powered	by	lithium-polymer	batteries.	The	UAS	will	

carry	the	proprietary camera	from	DJI	or	a	Canon	Mark	III	camera.	The	Inspire	1	and	S1000	

UAS	have	the	capability	to	land	at	its	current	location	with	a	dedicated	switch.	The	UAS	also	

has	several	fail-safes	for	loss	of	RC	signal,	loss	of	GPS,	and	low	battery	as	outlined	in	the	

respective	Operation	Manuals.	The	UAS	display	a	visual	low	battery	alert	at	25%	at	which	

time	the	UAS	will	automatically	engage	the	landing	sequence.	Based	upon	that	safeguard,	I	

request	exemption	from	Section	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions.	

The	UAS	also	has	a	height	restriction	function,	which	will	be	programmed	for	a	maximum	

altitude	of	400	feet.	Given	the	aircraft	will	be	operated	within	VLOS	with	the	aid	of	a	VO,	I	

believe	the	operation	can	be	conducted	with	an	equivalent	amount	of	safety	and	therefore	

request	exemption	from	Section	91.121.	Given	the	size,	weight,	speed,	and	controlled	

operating	area	associated	with	the	UAS	to	be	utilized,	an	exemption	from	14	CFR	part	21,	

Subpart	H	(Airworthiness	Certificates)	and	§91.203	(a)	and	(b)	is	requested.	I	seek	

exemption	from	§	45.23	Marking	of	the	aircraft.	The	UA will	display	the	registration	

number	in	the	largest	practicable	lettering.	We	wish	to	be	exempt	from	§	91.405(a),	

91.407(a)(1),	91.409(a)(2)	and	91.417(a)	and	b).	Maintenance	inspections	will	be	

conducted	according	to	operations	manual	and	prudent	judgment	as	previously	outlined	to	

determine	the	integrity	and	safety	of	the	UAS	and	associated	equipment.	Further,	I	require	

relief	from	91.7(a),	which	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	

certificate	and	91.9(b)	(2)	requiring	an	approved	flight	manual	in	the	aircraft.	The	UAS	will	

not	be	operating	with	an	airworthiness	certificate	therefore,	this	would	be	inappropriate.	

The	UAS	are	too	small	to	carry	the	operating	documents	so	an	equivalent	amount	of	safety	

can	be	achieved	through	keeping	the	operating	documents	and	manuals	at	the	GCS.

IV.	UAS	Pilot	in	Command	(PIC)

Under	§	61.113	(a)	and	(b)	private	pilots	are	limited	to	non-commercial	operations,	

however	I	can	ensure	my	operation	will	achieve	an	equivalent	level	of	safety	as	current	

regulation	because	my	UAS	do	not	carry	any	pilots	or	passengers.	A	commercial	pilot	

certificate	will	not	ensure	RC	piloting	ability,	as	the	psychomotor	skills	are	different.	The	

inherent	risks	of	operating	a	UAS	are	far	less	than	in	the	commercial	activities	outlined	in	

14	CFR	part	61,	et	seq.,	thus	I	request	an	exemption	from	§	61.113	Private	Pilot	Privileges	

and	Limitations:	Pilot	in	command.	All	UAS	PICs	will	have	logged,	in	accordance	with	61.51	

(b),	appropriate	training	on	the	UA	consisting	of	25	hours	as	UAS	rotorcraft,	10	hours	

multirotor	UAS	or	25	hours	as	UAS	airplane,	10	hours	single-engine	as	appropriate.	PICs	
Blackfish	Autonomous	Solutions,	LLC		 9

will	maintain	recent	flight	experience	on	the	UAS.	Training	and	experience	flights	will	be	

conducted	separate	from	commercial	operations.

PIC	Training	will	consist	of:

Pre-flight	Tasks

Full	site	inspection

Assembly	and	inspection	of	UAS

Set-up	and	configuration	of	RC	radio	and	GCS

System	checks

Mission	Tasks

Establish	flight	plan

Takeoff	and	landing

Manual	flight	modes

Autonomous	flight	modes

Emergency	Procedures

Post-flight	Tasks

Inspection

Shutdown

Disassembly

Other	Tasks

Regulations

Operating	limitations

Flight	planning

V.	Public	Interest

Given	the	above	stated	evidence,	procedures,	and	precautions;	I	feel	that	operating	my	UAS	

commercially	for	the	purposes	of	photography,	videography,	inspection	of	infrastructure,	

precision	agriculture,	and	scientific	&	environmental	research	will	ultimately	be	in	the	

public	interest.	These	operations,	when	executed	with	prudence,	will	exceed	the	current	

level	of	safety	as	the	regulations	from which	I	seek	exemption.	My	operation	will	allow	

greater	access	to	commercial	aerial	services	that	were	not	previously	economically	feasible	

for	many	firms.	This	will	provide	a	much	needed	economic	uplift	to	the	community	and	

hence	the	public.	My	operation will	be	conducted	with	less	risk	of	collateral	damage	to	

persons	and	property	while	limiting	disruptive	noise	pollution	associated	with	low	altitude	

aviation	operations.	A	major	factor	to	consider	regarding	the	public	interest	is	the	current	

state	of	UAS	operations	in	the	US.	As	a	manned	aviator,	the	need	to	integrate	UAS	into	the	

national	airspace	system	in	a	safe,	deliberate	manner is	always	at	the	forefront	of	my	mind.	

As	the	technology	becomes	more	readily	available,	the	challenges	will	intensify.	By	

allowing	commercial	operations,	it	will	enable	communities	to	become	educated	in	the	

proper	use	of	this	technology.	As	an	educator,	I	am	already	working	to	foster	positive	

awareness	and	safe,	responsible	utilization	of	UAS	technology.	Granting	my	exemption	will	

result	in	a	direct	extension	of	these	efforts,	which	is	in	the	public	interest.

VI.	Summary
Blackfish	Autonomous	Solutions,	LLC		 10

Pursuant	to	Section	333	of	PL	112-95	commonly	known	as	the	“FAA	Modernization and	

Reform	Act	of	2012”,	Lionel A.	Thomas II,	hereby	applies	for	authorization	to	conduct	

commercial	unmanned	aerial	systems	(UAS)	operations	for	the	purposes	of		photography,	

videography,	inspection	of	infrastructure,	precision	agriculture,	and	scientific	&	

environmental	research.

Rules	in	which	I	seek	exemption:

14	C.F.R.	Part	21	Subpart	H

14	C.F.R.	§	45.23(b)

14	C.F.R.	§	61.113	and	61.133(a)(1)(ii)

14	C.F.R.	§	91.7(a)

14	C.F.R.	91.9(b)

14	C.F.R.	§ 91.103

14	C.F.R.	§	91.109(a)

14	C.F.R.	§	91.119

14	C.F.R.	§	91.121

14	C.F.R.	§	91.151(a)

14	C.F.R.	§	91.405(a)

14	C.F.R.	§	91.407(a)(1)

14	C.F.R.	§	91.409(a)(2)

14	C.F.R.	§	91.417(a)	&	(b)

Throughout	this	exemption	request,	I	have	shown	how	my	expertise	and	knowledge	with	

UAS	technology	will	ensure	the	public’s	best	interest	is	at	hand	and	how	my	operation	will	

aid	in	safely	integrating	civil	UAS	into	the	national	airspace	system.
Blackfish	Autonomous	Solutions,	LLC		 11

VII. Unmanned Aircraft Vehicle: Inspire 1 UAV

Blackfish Autonomous Solutions, LLC. seeks an exemption to operate its existing Inspire 1, 

UAV, for compensation or hire within the national airspace system (“NAS”). 

The Inspire 1 UAV is comprised of a VTOL unmanned aircraft and a transportable ground 

station. The Inspire 1 UAV has a maximum gross weight of approximately six and one half (6.5) 

pounds and the following technical and operational specifications: 

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode) Vertical: 0.5 m 

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind) 4500 m

Max Flight Altitude 4500m

Max Wind Speed Resistance 10 m/s

Figure	1.	DJI	Inspire	1	UAV
Blackfish	Autonomous	Solutions,	LLC		 12

Max Flight Time Approximately 18 minutes 

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by Default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm
Blackfish	Autonomous	Solutions,	LLC		 13

VIII. Unmanned Aircraft Vehicle: S1000 UAV

Blackfish Autonomous Solutions, LLC. seeks an exemption to operate its existing S1000, UAV, 

for compensation or hire within the national airspace system (“NAS”). 

The S1000 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station. 

The S1000 UAV has a maximum gross weight of approximately nine and one half (9.5) pounds 

and the following technical and operational specifications: 

Diagonal Wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight: 325g (Including Motor, ESC, Propeller)

Center Frame Diameter: 337.5mm

Center Frame Weight: 1330g (with Landing Gear Mounting Base, Servos) 

Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height),

(Top width: 155 mm)

Motor: Stator Size: 41×14mm

KV: 400rpm/V

Max Power: 500W

Weight: 158g (with Cooling Fan)

Working Current: 40A

Working Voltage: 6S LiPo

Figure	2.	DJI	S1000	UAV
Blackfish	Autonomous	Solutions,	LLC		 14

Signal Frequency: 30Hz ~ 450Hz

Drive PWM Frequency: 8KHz

Weight: 35g (with Radiators) 

Foldable Propeller: (1552/1552R) 

Propeller Size: 15×5.2inch 

Weight: 13g

Takeoff Weight: 6.0Kg – 11.0Kg

Total Weight: 4.2Kg

Power Battery: Lipo (6S 10,000mAh – 20000mAh 15C(Min))

Max Power Consumption: 4000W

Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature: -10 °C ~ +40 °C 

For A2 flight controller:

Basic: Roll 120%, Pitch 120%, Yaw 120% 

Attitude: Roll 170%, Pitch 170%, Vertical 120% 

For WooKong-M flight controller:

Basic: Roll 180%, Pitch 180%, Yaw 120% 

Attitude: Roll 180%, Pitch 180%, Vertical 120%