February	18,	2016

Dan	Darby

Bluesky	Aerial	Imaging,	LLC

		1443	Tome	Charles	Rd.	

		Summerton	SC,	29148

U.S.	Department	ofTransportation	

Docket	Management System

1200	New Jersey	Ave., SE	

3Washington,	DC 20590

Dear	Sir	or Madam:

Attached,	please	find	Bluesky	Aerial	Imaging,	LLC’s	request	for	an	exemption	from	certain	stated	

Federal	Aviation Regulations to allow commercial operation of its small unmanned aircraft

systems	(hereafter	referred	to	as	“SUAS”	or	“Drone”)	for	the	purposes	of	aerial	photography,	

cinematography,	videography,	mapping,	crop	surveying,	inspections	and	other	flight	operations,	

so	long	as	such	operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	as	

may	be	established	by	the	FAA	as	required	by	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of2012.

Please	be	advised	that	the	FAA	has	previously	issued	grants	of	exemption	in	circumstances	

similar	in	all	material	aspects	to	those requested	in	this	petition,	most	recently	in	Exemption	

Nos.	11442	to	HAZON	Solutions,	11157to	Likeonatree	Aerial	and	in	11446	to	Trumbull	

Unmanned	LLC	– including	the	specific	SUAS	to	be	operated.	Therefore,	Bluesky	Aerial	Imaging,	

LLC respectfully requests this exemption be considered under the “summary grant” process.

As detailed in this document, a granted exemption would permit the commercial operation	of	

SUAS	under	controlled	conditions	in	airspace	that	is	limited	and	controlled	via	subsequent	COA	

applications.	Predominantly,	Bluesky	Aerial	Imaging,	LLC	seeks	to	operate	under	the	“Blanket	

200ft	COA”	guidance	that	was	issued	by	the	FAA	in	March	2015	and	respectfully	requests the

“Blanket 200ft COA” be granted in concert with these exemptions.

The requested exemptions and proposed limitations provide for at least an equivalent or	higher	

level	of	safety	to	operations	under	the	current	regulatory	structure,	specifically	safety	

enhancements to	personnel climbing vertical infrastructure and	create	a	low---risk alternative	to	

certain	manned	aviationoperations.

As outlined in this request for exemption, the SUAS Bluesky	Aerial	Imaging, LLC proposes to

use are:	DJI	Phantom	II, III

DJI	Inspire I,	Matrice	100

If	I	can	provide	any	additional	information	in	support	of	your	review	of	this	petition,	please	do not

hesitate to call me at 803---473---0871 or send an email to dmdarby1@yahoo.com.

Sincerely,

Dan	Darby

Owner,	Bluesky	Aerial	Imaging
2

Section	1:	Introduction	&	Interest	of	Bluesky	Aerial	Imaging,LLC

Bluesky	Aerial	Imaging,	LLC	proposes	to	commercially	operate	its	DJI	SUAS	platforms	for	

the	purposes	of	aerial	inspections,	timber	and	agricultural	surveys,	aerial	photography,	

videography,	data	collection	and	other	flight	operations	conforming	to	the	proposed	

limitations	and	restrictions. Bluesky	Aerial	Imaging, LLC holds that commercially operating

an SUAS within the NAS under	these	same	limitations	and	restrictions	will	not	pose	a	

hazard	to	manned	aircraft,	and	that	operation of	its	SUAS is	in	the	public best	interest	by	

providing an	inexpensive, low---risk alternative	to	manned	surveyoperations.

Section	2:	Regarding	the	Unmanned	AircraftSystem

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below.	

This section intends to fulfill each requirement of this guidance.

1. Petitioners	should	describe	how	the	proposed	UAS	operation	will	be	safely	conducted	to	

minimize	risk	to	the	NAS	or	to	persons	and	property	on	the	ground.	Specifically,	petitioners	

should describe the design and operational characteristicsfor the type(s) of UAS they intend to	

operate,	e.g.	aircraft	performance	and	performance	limitations,	operating	procedures,	and	

aircraft	loading	information	in	as	much	detail	as	possible.	This	could	be	provided	in	the	

petition	or	in	an	Aircraft	Flight	Manual	or	similardocument.

NOTE:	The	FAA	will	consider	all	information	and	data	submitted	by	the	petitioner	that	

describesthe UAS developmental and operational history. This could include statistical data or	

other	documentation	for	the	specific	design	and	performance	characteristics	of	the	UAS,	

including	the	operational	history	and	operational	failure	modes,	obtained	through	previous	

Research	&	Development	(R&D)	and/or	flight	test	activities,	e.g.	operations	conducted	under	a	

COA, with a civil airworthiness certificate, or under other authorized operating conditions.

2. Petitioners should describe any procedures they	would implement, such	as	pre---flight

inspections, maintenance, and repair, to ensure that the UAS isin a condition for safe flight.	

This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and	

Inspection	Manual,	or similardocument.

NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manualmay	

be	separate	documents	or	combined	in	a	singledocument.

3. The	petitioner	should	describe	the	Radio	Frequency	(RF)	spectrum	used	for	control	of	the	

UAS and associated equipment that is part of the UAS (i.e.,sensors, cameras, etc.), and whether	

it	complies	with	Federal	Communications	Commission	(FCC)	or	other	appropriate	government	

oversight	agencyrequirements.
3

NOTE: Petitionersshould be able to provide the FCC approval letter or show compliance with	

FCC	requirements	uponrequest.

Bluesky	Aerial	Imaging,	LLC intends	to		commercially		operate		SUAS		weighing		less	than		

10lbs,	during	daylight	hours,	within	visual	line	of	sight	of	the	PIC,	at	altitudes	less	than	400ft	

AGL	and	at	speeds	less	than	35mph.	As	described	later,	Bluesky	Aerial	Imaging	 PICs	shall	be	

fully	qualified	airmen,	holding	at	least	a	sport	pilot	certificate	and	associated	medical	

clearance.	The	proposed	SUAS are	equipped with GPS---enabled autopilots, capable of	safe,	

steady autonomous flight and	guided	by	the	PIC.	The	proposed	SUAS	are	commercially	

available,	“off	the	shelf”					products	that	have	accumulated	innumerable	flight	hours	across	

the	world,	and	they	have	proven themselves low---risk, safe	aircraft.	Given the	small size	and

weight, low	altitudes, slow	speeds, a	qualified PIC, a	GPS---equipped autopilot, data---link and

countless flight	hours, Bluesky	Aerial	Imaging,	LLC	holds	that	commercially	operating	these	

SUAS	under	the	limitations	and	restrictions	set	forth	is	a	safe	alternative	to	the	current	

regulatory	structure	and	minimizes		risk to the NAS or to persons and property on the

ground.

2.1 Proposed SUAS

Bluesky	Aerial	Imaging,	LLC	intends	to	operate	the	DJI	Phantom	and	Inspire	family	

of	SUAS,	with	the ability to conduct vertical takeoffs and landings, hover, and carry

payloads such	as	cameras,	sensors	and	other	equipment	necessary	to	complete	its	

aerial	photography,	cinematography,	videography,	mapping,	crop	surveying	and	

inspection	tasks.	Each	SUAS	is	describedbelow.

DJI Phantom

The Phantom system is	comprised of	a	four---rotor unmanned aircraft	and	

handheld	controller,	which	is	responsible	for	both	operation	and	camera	

functions.	The	maximum	gross	weight	of	the	Phantom	is	1250g,	and	it	measures

350mm across	rotor---to---rotor. Its	maximum horizontal, ascent	and	descent	

speeds	are	15	m/s,	6m/s	and	2m/s	respectively.	The	Phantom	is	powered	with	

a	Lithium	Ion	battery	and	flies	for	approximately	20	minutes.	More	detailed	

specifications	are	available	in	the	DJI	Phantom	Operations	Manual,	which		is	

attached		as	Appendix	 1.

DJIInspire

The Inspire system	is	comprised of	a	four---rotor unmanned aircraft	and	

handheld	controller,	which	is	responsible	for	both	operation	and	camera	

functions.	The	maximum	gross	weight	of	the	Inspire	is	3000g,	and	it	

measures	438	x	451	x	301mm.	The	Inspire’s	maximum	horizontal,	ascent	

and descent speeds are 22m/s, 5m/s and 4m/s respectively. The Inspire is	

powered	by	a	Lithium	Ion	battery	and	flies	for	approximately	20	minutes.	

More	detailed	specifications	are	available	in	the	DJI	Inspire	Operations	

Manual,	which	is	attached	as	Appendix2.

2.2 Maintenance	& Inspection

Bluesky	Aerial	Imaging,	LLC	shall	follow	the	manufacturer’s	maintenance,	overhaul,	

inspection and	record---keeping guidelines as	specified	in	both the	maintenance	manual	and	

operations	manual,	attached	as	Appendices	1,	2	and	3.	Bluesky	Aerial	Imaging,	LLC	will	

conduct	inspections	and	maintenance,	which	shall	be noted in the aircraft’s logbook

including total flight hours and the nature	of maintenance performed. Comprehensive
4

maintenance will be performed after every 200 flights or 50 flight hours – whichever is

earliest – in	conformance	with	the	manufacturer’sguidelines.

In	advance	of	every	flight	operation,	the	Pilot	In Command	(PIC)	will	

thoroughly	inspect	the	SUAS	to	ensure	it	is	safe	to	fly	as	described	in	

Appendix 3.	Furthermore, the	PIC	will conduct a	pre---flight checklist as	

described in the Operations Manual. With both inspections completed and	

passed,	the	SUAS	shall	be	deemed	safe	tofly.

All SUAS proposed under this request for exemption will be in compliance	

with all manufacturer maintenance, system and safety bulletins.

2.3 Radio Communications

All	radio	systems	used	in	the	proposed	SUAS	comply	with	FCC	regulations	

and	have	earned	FCC	approval.	Bluesky	Aerial	Imaging,	LLC	shall	operate	

the	SUAS	in	compliance with those approvals. Certificates of compliance may

be found in	Operations	manuals	in	Appendices	1	and2.

Both the	Phantom and Inspire SUAS operate in	two different FCC---approved

bands.	The	remote	control	operates	between	5.728	and	5.85GHz,	and	the	

video/data		link		operates		between		2412MHz		and 2462MHz.

Section	3:	Regarding	the	Unmanned	AircraftPIC

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below.	

This section intends to fulfill each requirement of this guidance.

Regarding	the	Unmanned	AircraftPIC

4. Petitioners	should	describe	the	qualifications	required	of	any	PIC(s)	who	will	be	directly	

responsible	for	the	operation	of	the	UAS,	including	information	such	as:	the	level	of	airman	

certificate	held;	any	applicable	training	related	to	the	operation;	and	any	minimum	hours	of	

flight experience required by the PIC(s), both total flight time and the time with the particular	

UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and	

qualifications.

5. Petitionersshould describe the medicalstandards and certification of the PIC(s) directly	

responsible	for	the	operation	of	theUAS.

Bluesky	Aerial	Imaging, LLC PICs shall possess a current airline transport, commercial,

private, recreational	or	sport	pilot	certificate.	The	PIC	shall	also	hold	a	current	FAA	airman	

medical	certificate	or	a valid U.S. Driver’s License. The PIC shall also meet the flight review

requirements specified	in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or

her pilot certificate.

Prior	to	commercial	operations,	Bluesky	Aerial	Imaging,	LLC	PICs	shall	have	accumulated	

and	logged	a	minimum	of	25	hours	total	time	as	an	SUAS	pilot.	Flights	for	the	purposes	of	

training	Bluesky	Aerial	Imaging, LLC’s PICs and	VOs (training, proficiency, and	experience---

building) and	determining the PIC’s ability to safely operate the UAS in a manner consistent

with how the	UAS	will	be	operated	under	this	exemption,	are	requested	under	the	terms	of	

this	exemption. Training operations shall only be conducted during dedicated training
5

sessions.	During training, proficiency, and	experience---building flights, all	persons not

essential for flight operations shall be considered nonparticipants, and the PIC shall

operate the UA with	appropriate distance from nonparticipants in accordance with 14 CFR

§ 91.119.
6

Section 4: Regarding the Operation of the Unmanned Aircraft

The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below,	

along with Bluesky	Aerial	Imaging, LLC’s proposal. This section intends to fulfill each

requirement of this	guidance.

Regarding	the	Operation	of	the	UnmannedAircraft

6. Petitioners	should	fully	describe	their	intended	UAS	operation(s).	Petitioners	should	

describe how the proposed operation(s) would not adversely affectsafety, or how they	

would	provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule	from	

which	exemption	is	sought.	Petitioners	should	address	any	plans	to	implement	clearly	

defined	operational	borders	and	procedures	to	ensure	public	safety,	which	includes	

persons	and	property	both	in	the	air	and	on	the	ground.	This	can	be	described	in	the	

petition,	in	an	Operations	Manual,	or	similar	document.	NOTE:	The	FAA	will	closely	

examine	the	proposed	operation(s)	with	respect	to	safety	of	flight,	NAS	safety	

considerations, and the	safety	of	the	non---participating persons and property during		the	

operational	period	and	within	the	operationalarea.

7. Petitionersshould specify the proposed maximum operating speed and altitude, and	

describe	minimum	flight	visibility	and	distance	from	clouds	for	their	intended	

operation(s).	Petitioners	should	describe	potential	hazards	and	safety	mitigations	

associated	with	these	proposed	conditions.	These	issues	can	be	addressed	in	the	

petition,	an	Operations	Manual,	or	similardocument.

The	SUAS	will	be	operated	during	daylight	hours,	in	compliance	with	visual	flight	rules,	and	

flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times	and	never	over	congested	or	

densely populated areas	unless specifically	authorized by	the	Air	Traffic	Organization---		issued	

COA.	The	PIC	shall	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	

specified	on	the	PIC’s	FAA---issued airman medical certificate	or	U.S.	driver’s			license.

The	SUAS	shall	be	operated	at an	altitude	of	no	more	than	400ft	AGL,	unless	specifically	

authorized	and	operating	under	the	terms	of	the	COA,	at	speeds	less	than	15m/s	(34mph).	

The SUAS will not be operated less than 500ft below or less than 2000ft horizontally from a	

cloud,	or	when	visibility	is	less	than	3	statutemiles.

Prior	to	beginning	a	flight,	the	PIC	shall	clearly	establish	the	limits	in	latitude,	longitude	and	

altitude	AGL	to	ensure	compliance	with	the	COA	under	which	the	SUAS	is	flown	and	

establish	the	“sterile	area”	for	operations.	If	at	any	time,	this	area	is	breached	by	

unpredicted obstacles (manned aircraft or otherwise), the PIC shall abort the flight. Manned	

aircraft	shall	have	right	of	way	at	alltimes.

In	case	of	a	reduced	or	diminished	control	link,	the	SUAS	will	automatically	return	to	a	

predetermined point within the	private	or	controlled---access		 property.

The PIC shall not begin a flight unless there is sufficient available power for the SUAS to	

complete the intended mission and to operate for at least five minutes after that.

By	operating	within	the	limitations	and	guidelines	set	forth	herein,	Bluesky	Aerial	Imaging,	

LLC	shall	provide an equivalent level of safety to operations under the existing regulatory

structure.
7

8. Petitionersshould describe the characteristics of the area of intended operation(s) and	

the	associated	potential	hazards,	in	accordance	with	the	statutory	mandate	under	

Section	333	regarding	proximity	to	populated	areas.	These	issues	can	be	addressed	in	

the	petition,	an	Operations	Manual,	or	similardocument.

9. Petitionersshould describe if they intend to operate in the proximity of any airports, in	

accordance	with	the	statutory	mandate	under	Section	333	regarding	proximity	to	

airports.

All	flight	operations	will	be	conducted	at	least	500ft	from	all	nonparticipating	persons,	

vessels,	vehicles	and	structures	on	private	or	controlled	access	property	with	permission	

from	the	property	owner/controller	or	authorized	representative.	In	some	cases	due	to	

mission	requirements,	the	SUAS	will	be	operated	closer	than	500ft	to	commercial	and	

industrial	infrastructure	and	facilities.	In	these	instances,	Bluesky	Aerial	Imaging,	LLC	shall	

have	the	authorization	of	the	property	owner/controller	or	from	an	authorized	

representative,	and	the PIC shall have conducted a safety assessment and determined that it

does not present an	undue hazard. Permission from the property owner/controller or

authorized representative	will	be obtained	for	each	flight	to	beconducted.

Flight operations will not take place with 5nm of airport unless a letter of agreement with	

that	airport’s	management	is	obtained	and/or	otherwise	permitted	by	an	Air	Traffic	

Organization---issued COA.

Foreseen hazards include encroachment of	manned aviation operations and non---	

participants on	the	ground. Both of	these	hazards are	mitigated by	choice of	location (non---

congested	areas)	and	strict	limits	on	range	(visual	line	of	sight)	and	altitude	established

herein. Operation under these limits effectively mitigates these risks.

10. The UAS must be	operated within visual line---of---sight (VLOS), in	accordance with	the	

statutory	mandate	under	Section	333(b)(1).	Petitioners	should		describe		how		they	

intend	to			comply	with	his	 mandate.

11. Petitionersshould describe any proceduresthey would implement for conducting a	

preflight	safety	risk	assessment	to	determine	that	the	UAS	is	in	a	condition	for	safe	

flight	(14	CFR	§	91.7(b))	and	that	the	planned	operation	can	be	completed	safely.	

These	procedures	can	be	addressed	in	the	petition,	an	Aircraft	Flight	Manual,	

Operations	Manual,	or	similardocument.

As	described	above,	The	SUAS	will	be	operated	during	daylight	hours,	in	compliance	with	

visual flight rules, and flown within direct visual line of sight of the PIC at all times. The PIC	

shall	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	specified	on	

the	PIC’s	FAA---issued		airman medical certificate	or	U.S.	driver’s	 license.

In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect the	

SUAS to	ensure it	is	safe	to	fly	as	described in	Appendix 1---5 and	Appendix 7.	Furthermore, the	

PIC	will conduct a	pre---flight checklist as	described in	Appendix 1	and	2,	and	ensure the	

planned	operation	can	be	completed	safely	with	sufficient	battery	reserves	(including	wind	

and	terrain	limitations).	With	both	inspections	completed	and	passed,	the	SUAS	shall	be	

deemed	safe	to fly.

12. If petitionersintend to conduct operations which have existing requirementsto notify	

Flight Standards District Offices(FSDOs) prior to operations – such as motion picture
8

and television filming, or pipeline and powerline patrol – petitionersshould describe	

their intended coordination in this regard for their proposed operation(s).

Bluesky	Aerial	Imaging, LLC’s aerial infrastructure inspections,

cinematography/videography or	agricultural operations do not require notification to

FSDOs.

13.	The	FAA	intends	to	require	entities	who	obtain	an	exemption	under	this	process	to	also	

obtain	a	Certificate	of	Waiver	or	Authorization	(COA)	from	the	FAA	Air	Traffic	

Organization	prior	to	conducting	operation(s)	in	the	NAS.	The	COA	application	is	

available here.

As	stated	previously, Bluesky	Aerial	Imagery, LLC shall obtain an	Air	Traffic	Organization---

issued COA prior to	conducting	any	operations	under	this	requested	grant	of	exemption.	

Bluesky	Aerial	Imagery,	LLC	seeks	primarily	to	operate	under	the	“Blanket	200ft	COA”

guidance	offered	by	the	FAA	in	March,	2015 and respectfully requests that COA be issued

concurrently with these exemptions. For	operations	not	conforming	to	the	“Blanket	200ft	

COA”	guidance,	Bluesky	Aerial	Imagery,	LLC	will	seek	separate	and	additional	COAs	to	

operate	itsSUAS.

Section	5:	RequestedExemptions

14	C.F.R Part Summary	ofRegulation Proposed Action

21,	Subpart H AirworthinessCertification In	consideration	of	the	size,	weight,	

speed,	and	limited	operating	area	

associated	with	the	aircraft	and	its	

operation,	the	FAA	has	previously	held	

that	this	aircraft	meets	the	conditions	of	

Section	333,	therefore,	requested	relief	

from	14	CFR	part	21,	and any associated	

noise	certification	and	testing	

requirements	of	part	36,	is	not	

necessary.

45.23(b) Display	of Marks Bluesky	Aerial	Imagery,	LLC	SUAS	shall	

be	identified	by	serial	number and N---

number, in		markings as	large	as	practical	

given	the	small	size	of	the	aircraft.	

However,	the	2	inch	minimum	set	forth	

in	this	rule	is	impractical,	therefore	

61.23(a)

61.101(e)(4&5)

61	113(a)	& (b)

61.133(b)

61.315(a)

Certification:	Pilots, Light	

Instructors	and	Ground	

Instructors

In	previous	petitions	for	exemption,	the	

FAA	has	held	that	a	PIC	of	an	SUAS	

holding	at	least	a	Sport	Pilot	certificate	

and	a	U.S.	Driver’s	License,	or	greater	

medical	certification,	would	not	

adversely	affect	safe	operations	within	

the	NAS	or	present	a	hazard	to	peopleor	

structures	on	the	ground.	Relief,	subject	

to	the	limitations	provided	in	this	

document,	is requested.
9

91.7(a) Civil	AircraftAirworthiness PICs	operating	on	behalf	of	Bluesky	

Aerial	Imagery,	LLC	shall	perform	

preflight	inspections	and	ensure	

airworthiness	prior	to	flight	as	

described	in	this	document,	manuals	

and	appropriate	appendices.	Relieffrom
10

this	requirement	is	notnecessary.

91.9(b)(2)	& (c) Civil	aircraft	flight manual,	

marking,	and	placard	

requirements

Bluesky	Aerial	Imagery,	LLC	shall	

provide	a	current	SUAS	Flight	Manual,	

and	operational	instruction	material	at	

the	location	of	the	PIC	and/or	Ground	

Station.	The FAA	has	previously	

determined	that,	given	this,	relief	from

this	requirement	is	not	necessary.

91.103 Preflight Action Bluesky	Aerial	Imagery,	LLC	will	

perform.	Relief	isnot	necessary.

91.105 Flight	Crewmembers at	

Stations

No	human	will	be	aboard	the	SUAS	

operated	by	Bluesky	Aerial	Imagery	,	

LLC,	however,the	FAA	has	held	in	

previous	petitions	that	relief	is	not

91.109(a) Flight Instruction Bluesky	Aerial	Imagery,	LLC	will	

conduct	flight	training	in	accordance	

with	the	guidance	and	limitations	

offered	in	this	document,	as	well	as	the	

Operations	&	Flight	Manuals	attached	

as	appendices	to	this	document.	The	

FAA	has	held	inprevious	petitions	that	

91.119 Minimum	Safe Altitudes Request	relief	within	limitations	and	

restrictions	proposed	herein, specifically	

in	Section 4.

91.121 Altimeter Settings Each	of	the	SUAS	Bluesky	Aerial	

Imagery,	LLC	proposes	to	operate	

measure	altitude	with	both	barometric	

pressure	sensors	and	GPS.	Prior	to	each	

flight,	the	barometric	altimeter	will	be	

set	to	0ft	AGL	insteadof	the	setting	of	

the	nearest	reporting	station.	Bluesky	

Aerial	Imagery,	LLC	holds	that	by	

counting	altitude	in	AGL,	zeroed	at	the	

point	of	departure,	will	ensure	

conformance	to	the	COA	restrictions	

under	which	the	SUAS	is operating.

Given	the	low	operating	altitudes of	

system	and	operating	within	the	

proposed	restrictions,	relief	is	

91.151 Fuel	Requirements	in VFR	

Conditions

As	described	in	this	document,	theSUAS	

Bluesky	Aerial	Imagery,	LLC	proposes	

to	operate	have	total	endurance	of	

between	20	and	30	minutes.	Bluesky	

Aerial	Imagery,	LLC	will	ensure	

missions	are	conducted	with	sufficient	

reserve	to	operate	for	at	least	five	

minutes	after	the	intended	mission	is	

complete.	The	short	flight	time	makes	

the	reserves	specified	in	91.151	

impractical	and	therefore	relief	is

91.203 CertificationsRequired Bluesky	Aerial	Imagery,	LLC	will	place	

thesedocuments
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at the	location	of	the	ground	station	

and/or	with	the	PIC.	The	FAA	has	

previously	held	that	this	is	sufficient	to	

provide	an	equivalent	level	of	safety, and	

therefore,	relief	is requested.

91.405 Maintenance Required Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

91.407 Operation	After Maintenance Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

91.409 Inspections Relief	is	requested	within	the limitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

91.417 Maintenance Records Relief	is	requested	within	thelimitations	

and	conditions	set	forth	in	Section	2.2	of	

this document.

Section	6:	Public	Interest	&	Equivalent	Level	ofSafety

Though this is addressed in pieces of this petition, a more complete answer is provided in	

this section.

Bluesky	Aerial	Imagery,	LLC	proposes	certain	14	CFR	exemptions	to	allow	commercial	

operation	of	its	small unmanned aircraft systems for the purposes of aerial photography,

cinematography,	videography,	mapping,	crop	surveying,	inspections	and	other	flight	

operations,	so	long	as	such operations are conducted within and under the conditions

outlined herein.

Traditional agricultural operations such as crop inspections and data collections under the	

current	regulatory	structure	include	the	use	of	manned	aircraft,	which	are	expensive,	

inefficient and cannot be safely operated in close proximity to the ground. By using Drones	

to	complete	these	missions	the	public	interest	is	served	by	increasing	safety	to	pilots,	

passengers and non---participants on	the	 ground.

Traditional	industrial	infrastructure	inspection	operations	under	the	current	regulatory	

structure are often performed 1) from the ground, where high detail is impossible 2) by a	

climber at great risk to his or her personal safety, or 3) by a manned aircraft where flying	

close	to	elevated	infrastructure	is	extremely	dangerous,	and	not	permitted	by	14	CFR	

91.119.

Grant of exemption, with the conditions and limitations set forth herein, to Bluesky	Aerial	

Imagery, LLC will	provide	for	at	least	an	equivalent	or	better	level	of	safety,	reduce	risk	to	

life	and	property,	thereby	serving	the	public interest.
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Section 7: Summary of Exemption Request for the Federal Register

In	accordance	with	14	CFR	11.81	and	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	

2012, P.L.	112---95,		, Bluesky	Aerial	Imagery LLC seeks exemption from	the	requirements of	14	

C.F.R

§§Part 21, Subpart H, 45.23(b), 61.23(a), 61.101(e)(4&5), 61 113(a) & (b), 61.133(b),

61.315(a), 91.7(a), 91.9(b)(2) & (c ), 91.103, 91.105, 91.109(a), 91.119, 91.121, 91.151,

91.203, 91.405, 91.407, 91.409 and 91.417 to operate small unmanned vehicles weighing	

55lbs	or	less	for	commercialpurposes.

Approval of these exemptions will allow Bluesky	Aerial	Imagery , LLC to conduct safe,

commercial operation	of	small	unmanned	aircraft	for	the	purposes	of	aerial	photography,	

cinematography,	videography, mapping, crop surveying, inspections and other flight

operations.

Section	8:	Compliance	with	14	CFR11.81	

14	CFR	11.81a	– Published	on	Cover	Page.	

14	CFR	11.81b	– Please	see	Section 5.

14	CFR	11.81c	– Please	see	Sections	2,	3,	4	and5.	

14	CFR	11.81d	– Please	see	Section 6.

14	CFR	11.81e	– Please	see	Section

6.	14	CFR	11.81f	– Please	see	Section

7.

14	CFR 11.81g – Please	see	Appendices 1---7.	

14	CFR	11.81h	– Not		 applicable.

*See	Link	for	All	DJI	Product	Guides	

http://www.dji.com/support
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