February	18,	2016

Dan	Darby Bluesky	Aerial	Imaging,	LLC 1443	Tome	Charles	Rd. Summerton	SC,	29148
U.S.	Department	of Transportation Docket	Management System 1200	New Jersey	Ave., SE 3 Washington,	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	of 2012. 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 appl ications.	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 re quested 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	aviation operations.
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

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**Section	1:	In troduction	&	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	sam e	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	survey operations.
**Section	2:	Regarding	the	Unmanned Aircraft**  **System** 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	t o 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 describes the 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	failur e	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 is in a condition for safeflight. This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and Inspection	Manual,	or similar document. NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manual may 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 ofthe UAS (i.e., sensors, cameras, etc.), and whether it	complies	with	Federal	Communications	Commission	(FCC)	or	other	appropriate	government oversight	agency requirements.

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NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC	requirements	upon request. 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	35 mph.	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	described below. **DJI Phanto** **m** 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.

**DJI Inspire**  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	300 0g,	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	Appendix 2.

**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

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

– whichever is earliest

– in	conformance	with	the	manufacturer’s guidelines.

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	to fly.
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	and 2.
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	Aircraft**  **PIC** 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 totalflight time and the time with the particular UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and qualifications.
5. Petitioners should describe the medical standards and certification ofthe PIC(s) directly responsible	for	the	operation	of	the UAS. 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	Unmanned Aircraft 6. Petitioners	should	fully	describe	their	intended	UAS	operation(s).	Petitioners	should describe how the proposed operation(s) would not adversely affect safety, 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,	whic h	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	safet y considerations, and the	safety	of	the non ---participating persons and property during the operational	period	and	within	the	operationalarea. 7. Petitioners should 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	similar document. 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	statute miles. 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	op erations.	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	all times. 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. Petitioners should describe the characteristics ofthe area ofintended 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. Petitioners should describe ifthey intend to operate in the proximity ofany airports, in accordance	with	the	statutory	mandate	under	Section	333	re garding	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	be conducted. 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. Petitioners should describe any procedures they would implementfor 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	similar document. 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. Ifpetitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture

### 8 and television filming, or pipeline and powerline patrol

– petitioners should describe their intended coordination in this regardfor 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	its SUAS.
**Section	5:	Requested Exemptions**  **14	C.F.R Part**  **Summary	of Regulation**  **Proposed Action**  21,	Subpart H Airworthiness Certification 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	people or structures	on	the	ground.	Relief,	subject to	the	limitations	provided	in	this document,	is requested.

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91.7(a) Civil	Aircraft Airworthiness PIC s	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	not necessary. 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	is not	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	in previous	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	instead of	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,	the SUAS 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 Certifications Required Bluesky	Aerial	Imagery,	LLC	will	place these documents

### 11 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	the limitations and conditions	set	forth in	Section 2.2 of this document. 91.407 Operation	After Maintenance Relief	is	requested	within	the limitations 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	the limitations and conditions	set	forth in	Section 2.2 of this document.

**Section	6:	Public	Interest	&	Equivalent	Level	of Safety**  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**  **Exemp tion**  **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	commercial purposes. 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	CFR 11.81**  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	and 5. 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.

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