UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Blake Michael Kosicek 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

PROFESSIONAL MANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on February 9, 2016

Blake M. Kosicek

W330N4352 Glen Parc Circle

Nashotah, Wisconsin 53058-9550

(423) 305-5454
2

TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS...................................................................................3 

SUMMARY...........................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4 

BACKGROUND....................................................................................................................4 

BASIS FOR PETITION.........................................................................................................5 

NAME AND ADDRESS OF PETITIONER.........................................................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BLAKE MICHAEL 

KOSICEK SEEKS EXEMPTION.........................................................................................8 

THE EXTENT OF RELIEF BLAKE MICHAEL KOSICEK SEEKS AND THE REASON 

BLAKE MICHAEL KOSICEK SEEKS THE RELIEF...................................................12

THE REASONS WHY GRANTING BLAKE MICHAEL KOSICEK’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .....................................................................16

THE REASONS WHY GRANTING THE EXEMPTION FOR BLAKE MICHAEL 

KOSICEK WOULD NOT ADVERSELY AFFECT 

SAFETY...............................................................................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..................35

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT BLAKE MICHAEL KOSICEK’S REQUEST.................................................35

CONCLUSION....................................................................................................................35 

APPENDICES....................................................................................37-38
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Blake Michael Kosicek seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Blake Michael Kosicek to operate an Unmanned Aircraft System (UAS) for the 

commercial and residential purpose of conducting aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Blake Michael Kosicek will provide his clients with highest quality digital content for use 

in commercial, personal, and multimedia projects. Blake Kosicek has eight years of 

expertise and knowledge in radio controlled flight as well as four years of real estate 

insights. 

Blake Michael Kosicek has hobby experience in nitro and electric radio controlled cars, 

helicopters, planes, boats and quadcoptes for over eight years. 

The objective of Blake Michael Kosicek’s aerial video operations is to provide high quality 

imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Aerial acquisitions used for inspections of public and private infrastructure.

• Aerial video and photography for the Real Estate sector

• Increase public knowledge of UAS and promote safe UAS operations

• Search and Rescue operations.

BACKGROUND

Unmanned Aircraft Systems: 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Professional UASs
5

Blake Michael Kosicek seeks an exemption to operate TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K for compensation or hire within the NAS. The 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K are vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. 

The TRAXXAS ATON overall weight with landing gear is 860 grams, with 

dimension of 218mm height x 472mm wide, and a maximum speed of approximately 

50mph, 43.45 knots. 

The YUNEEC TYPHOON Q500 4K overall weight with landing gear is 1700

grams, 210mm height x 420mm wide, and a maximum speed of approximately 22mph, 

19.12 knots. 

Both the TRAXXAS ATON and the YUNEEC TYPHOON Q500 4K are equipped

with four main rotors; driven by Lithium Polymer battery powered brushless electric 

motors. 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs that will be operated 

by Blake Michael Kosicek are already registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking. Drone 

Registration # FA3KPE7X7L.

BASIS FOR PETITION

Petitioner, Blake Michael Kosicek, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 
6

petitions the Administrator to commercially operate TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated 

with the unmanned aircraft and its operation, Blake Michael Kosicek’s operation of 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Blake Michael Kosicek requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Blake Michael Kosicek submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Blake Michael Kosicek will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K Instruction Manual). Furthermore, Blake Michael Kosicek will 

document and maintain all maintenance records for the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs. 

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

privileges and limitations: Pilot in command, is requested by Blake Michael Kosicek to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 
7

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Blake Michael Kosicek seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

As such, Blake Michael Kosicek submits that he will ensure that the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs are in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

Instruction Manual), and that the aircraft are in a condition for safe flight. 

Blake Michael Kosicek also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UAs will not have a typical barometric altimeter onboard. However, altitude 

information of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with Blake Michael 

Kosicek’s operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 
8

Additionally, Blake Michael Kosicek seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Blake Michael 

Kosicek submits that safety will not be affected by operation of the TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UAs during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a 

total duration of approximately 10.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Blake Michael Kosicek 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:

Blake M. Kosicek

W330N4352 Glen Parc Circle

Nashotah, Wisconsin 53058-9550

(423) 305-5454

Email:	1AirborneDrone@Gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Blake Michael Kosicek Seeks 

Exemption. 

1. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 
9

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

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

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 
10

5. Blake Michael Kosicek Seeks Exemption From The Requirement Of Section 

91.405(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 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[.] 

6. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Blake Michael Kosicek Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 
11

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 
12

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake Michael 

Kosicek Seeks The Relief. 

1. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake 

Michael Kosicek Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Blake Michael Kosicek submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a 
13

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, Blake Michael Kosicek submits that all flights of the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs, conducted by the PIC pursuant to the grant of 

this Petition: (1) will be incidental to Blake Michael Kosicek’s business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake 

Michael Kosicek Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Blake Michael Kosicek to determine that the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs are in airworthy condition prior to every flight 

by ensuring that the UAS is in compliance with the operating documents (i.e., the Blake 

Michael Kosicek Airborne Drone Operations Manual, Monthly Maintenance Log, and

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual). 

Blake Michael Kosicek seeks the requested relief because the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Blake Michael Kosicek will 

ensure that TRAXXAS ATON and YUNEEC TYPHOON Q500 4K the UASs are in 

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

Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

Instruction Manual) 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 Blake Michael Kosicek Seeks And The Reason Blake 

Michael Kosicek Seeks Relief From Section 91.121. 
14

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, 

which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning 

UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), 

Blake Michael Kosicek seeks the requested relief because the TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UA’s 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 TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs are 

equipped with a barometric pressure sensor and GPS equipment, which automatically 

ensures that a ground level pressure setting will be established prior to each flight, and 

provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake 

Michael Kosicek 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 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 10.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. Blake Michael Kosicek seeks the 
15

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

duration of the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

UAs will severely constrain the practicality of any aerial video or still photo flight 

operations that Blake Michael Kosicek proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs, the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K operating documents, and Blake Michael Kosicek’s proposed 

operating limitations, ensure that Blake Michael Kosicek will safely operate the battery 

powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with 

enough battery power to fly for a total duration of 10.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes.

5. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake 

Michael Kosicek Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Blake Michael Kosicek requests 

relief from these Sections because the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UASs do not require airworthiness certificates. As set forth more fully below, the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Blake 

Michael Kosicek will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the Blake Michael Kosicek Airborne 
16

Drone Operations Manual, Monthly Maintenance Log, and TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K Instruction Manual). Furthermore, Blake Michael 

Kosicek will document and maintain all maintenance records for the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs. 

D. The Reasons Why Granting Blake Michael Kosicek’s Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Blake 

Michael Kosicek to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the 

United States.

Additionally, use of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

UASs will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Blake Michael Kosicek’s proposed 

operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be 

realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs are battery 

powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and 

property in the air and on the ground. 
17

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs. 

Conducting aerial acquisitions with the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, 

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are 

propelled by battery powered electric motors, rather than an internal combustion engine. 

By using the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs to 

perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack of flight crew 
18

members located onboard the aircraft, the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UAs (weighing 860 grams, 1700 grams respectively), has less physical potential 

for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity 

of 180 gallons). 

3. Performing Aerial Video and Photography Operations With TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs Will Benefit The 

Economy. 

In addition to being safe and efficient, the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UASs will allow United States based companies, like 

Blake Michael Kosicek, to remain competitive and contribute to growth of the U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 

By operating the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, 

companies such as Blake Michael Kosicek, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately 
19

contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UASs, provides a stable workforce that increases consumer spending; improves 

local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Blake Michael Kosicek’s proposed operation of the TRAXXAS ATON and

YUNEEC TYPHOON Q500 4K UASs will not implicate any privacy issues. Specifically, 

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be operated only in 

compliance with operating documents (i.e., the Blake Michael Kosicek Airborn Drone 

Operations Manual, Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K Instruction Manual) 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. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Blake Michael Kosicek Seeks Exemption. 

1. Reasons Why The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

UAs 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, Blake Michael Kosicek’s operation of the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 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. 
20

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: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Blake Michael Kosicek submits that the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs can operate safely in the NAS pursuant 

to FMRA Section 333, as demonstrated by: (a) the characteristics of the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UASs Demonstrate Its Safe Characteristics.
21

The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs do not create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs. 

The technical specifications of the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K Professional UASs are set forth by the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K Specifications and Data Sheet, attached hereto as Exhibit A and B. 

ii. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 

Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area. 

The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs may be 

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

flight and navigational modes of the TRAXXAS ATON and YUNEEC TYPHOON Q500 

4K is provided at page 7 of the TRAXXAS ATON and page 15-19 of the YUNEEC 

TYPHOON Q500 4K User Manuals, attached hereto as Exhibit C and D. 

iii. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 

Are Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, 

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs do not reacquire control 

link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will 

return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. 
22

A complete description of the Failsafe Functions of the TRAXXAS ATON UAS 

are set forth at pages 7 and on page19 of the YUNEEC TYPHOON Q500 4K User 

Manuals, attached hereto as Exhibit C and D. 

iv. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K GCS 

And Its Operation.

A complete description of the operation and specifications of the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K GCS and flight control software is provided at 

pages 4 through 10 of the TRAXXAS ATON User Manual and pages 3 through 24 of the 

YUNEEC TYPHOON Q500 4K User Manual. TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K User Manuals are attached hereto as Exhibits C and D.

b. Flight Operations Of TRAXXAS ATON and YUNEEC TYPHOON Q500 

4K UASs Are Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

Blake Michael Kosicek will only utilize certificated pilots who possess a current 

and valid airman medical certificate to act as a pilot in command (PIC) of the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs. Additionally, a safety observer will 

assist all pilots during flight time, however, under current law, a valid drivers license and 

valid drone certification code is all that is required and thus will be followed for current 

legal compliance for flying a microscopic vehicle

c. Flights Of TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs 

Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Blake Michael Kosicek proposes to commercially 

operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs for the special 

purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations:
23

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K Professional Unmanned Aircraft Systems. 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 video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 
24

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs 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 PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 
25

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 
26

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be 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. 
27

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Blake Michael Kosicek submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a

manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Blake Michael Kosicek’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UAS, Blake Michael Kosicek submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for Blake Michael Kosicek’s specific proposed flight 

operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Blake Michael Kosicek will not allow any PIC to operate TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the TRAXXAS ATON and YUNEEC TYPHOON 
28

Q500 4K training and currency requirements, that the PIC is able to safely operate the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Blake Michael Kosicek’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 
29

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Blake Michael Kosicek will ensure safe operations by not allowing 

any PIC to operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UAS in a manner consistent with the exemption, including evasive 

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

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Blake Michael Kosicek will ensure that the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UAS is in an airworthy condition based upon 

the UAS’s compliance with its operating documents and as stated in the conditions and 

limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.
30

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UAs will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the 

flight path and altitude. This altitude information, combined with Blake Michael Kosicek’s 

operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Blake Michael Kosicek will ensure that it will safely operate the battery 

powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 10.5 
31

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs provide audible and 

visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the 

first warning occurring at approximately 33% remaining battery power, and again at 

approximately 10% remaining battery power. At the critically low battery level, 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 
32

In seeking this exemption, Blake Michael Kosicek submits that the equivalent level 

of safety with regard to the regulatory maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be 

met because Blake Michael Kosicek will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Blake Michael Kosicek Airborne 

Drone Operations Manual, Monthly Maintenance Log, and TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K Instruction Manual). Furthermore, Blake Michael 

Kosicek will document and maintain all maintenance records for the TRAXXAS ATON 

and YUNEEC TYPHOON Q500 4K UASs. 

Since the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be 

inspected as prescribed by the operating documents, Blake Michael Kosicek will maintain 

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K User 

Manuals are attached hereto as Exhibit C and D; a copy of the TRAXXAS ATON and 

YUNEEC TYPHOON Q500 4K UAS Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Blake 

Michael Kosicek will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be performed by 
33

trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Blake Michael Kosicek’s proposed operating limitations, the 

operating documents, and the technical aspects of the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs, Blake Michael Kosicek submits that safety will not be 

adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) 

and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Blake Michael Kosicek

requests that the FAA prescribe special conditions for the intended operation of the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 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). 

Such special conditions will permit safe operation of the UAs for the limited purpose of 
34

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the 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; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 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).
35

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Blake Michael Kosicek Seeks Exemption: 

Blake Michael Kosicek seeks 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). 

A Brief Description Of The Nature Of The Exemption Blake Michael Kosicek

Seeks: 

This exemption will permit Blake Michael Kosicek to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Blake 

Michael Kosicek’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Blake Michael Kosicek’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

FMRA Section 333 sets forth the 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; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Blake Michael Kosicek will operate the TRAXXAS 

ATON and YUNEEC TYPHOON Q500 4K UASs safely in the NAS, without creating a 

hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Blake Michael Kosicek seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 
36

(FMRA), which will permit safe operation of the TRAXXAS ATON and YUNEEC 

TYPHOON Q500 4K UASs commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the 

United States. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Blake Michael Kosicek to safely, 

efficiently, and economically operate the TRAXXAS ATON and YUNEEC TYPHOON 

Q500 4K UASs commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Blake Michael Kosicek 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 Leading Edge to operate the 

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs commercially for the 

purpose of conducting aerial video and photography over certain areas of the United States.

Dated: February 9, 2016

Respectfully submitted,

Blake Michael Kosicek

_________________________

Blake Michael Kosicek

W330N4352 Glen Parc Circle

Nashotah, Wisconsin 53058-9550

(423) 305-5454
37

Appendices:

A – Traxxas Aton Specifications Data Sheet

B – Yuneec Typhoon Q500 4K Specifications Data Sheet

C – Traxxas Aton Manufacturer’s User Manual

D – Yuneec Typhoon Q500 4K Manufacturer’s User Manual

E – Monthly Maintenance Log

APPENDIX – A

TRAXXAS ATON TECHNICAL SPECIFICATIONS

Blake Michael Kosicek only utilizes safe and reliable UASs. TRAXXAS is an industry 

leader in small UAS production. TRAXXAS UASs are loaded with ground breaking 

software enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a predetermined and 

set altitude as well as limit flight to a predetermined and set distance. In addition, 

TRAXXAS software provides real-time altitude and location information to the PIC via 

the linked monitor (smart phone/tablet devices)

1.1 TRAXXAS ATON 

See User Manual 

APPENDIX – B

YUNEEC TYPHOON Q500 4K TECHNICAL SPECIFICATIONS

Blake Michael Kosicek only utilizes safe and reliable UASs. Yuneec is an industry leader 

in small UAS production. Yuneec UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude 

as well as limit flight to a predetermined and set distance. In addition, Yuneec software 

provides real-time altitude and location information to the PIC via the linked monitor 

(smart phone/tablet devices)

2.2 Yuneec Typhoon Q500 4K

See User Manual

APENDIX – C
38

Traxxas Aton Manufacturer’s User Manual

Dowload User Manual - https://traxxas.com/sites/default/files/KC2363-R02-AtonOwners-Manual_EN.pdf

APPENDIX – D

Yuneec Typhoon Q500 4K Professional Manufacturer’s User Manual

Dowload User Manual -

https://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf

APPENDIX – E