February 8, 2016

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119 {c); 

91.121; 91.151 (a); 91.407{a)(1) and {2}; 91.417{a) & (b). 

To Whom it May Concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Christopher Long, 

operator of an Unmanned Aircraft System (UAS), hereby apply for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of it's UAS, 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.

I would like to formally submit for an exemption from part 21, subpart H; and Sections 

45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR). This proposed exemption would allow the operation of unmanned aircraft systems 

(UAS) for the purpose of aerial videography and photography real estate purposes and events.

Applicant:

Christopher Thomas Long

2981 West State Road 26

Hartford City, IN 47348

Support@SPAS-12.COM

(765) 702-3357

Commercial operation of an UAS, as described herein, which are equipped with camera and 

sensors, would operate in the following manner:

-Aerial photography and/or video for public and/or private use including real estate and 

other related professional activities.

-Aerial video and/or photography for public and/or private use including public and 

private events.

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and 

d) will provide safety enhancements to the already safe operations in the industry presently 

using conventional aircraft. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.”
As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a 

Phantom 2 UAS. I will operate a UAS, the Blade Chroma which is comprised of an unmanned 

aircraft (UA or Chroma), an attached 4k camera and transportable ground station.

The Blade Chroma is a quad-copter with a gross weight of 2.9lbs. It is equipped with four 

rotors that are driven by electric motors powered by batteries. The UA has a maximum speed 

of 25mph. It will be operated over various metropolitan and rural areas, primarily around 

Bluffton, IN, to capture real estate listing videos, capture event aerial video and photography, 

and related business operations.

UAS Operating Parameters

I will abide by the following additional operating conditions under this exemption, which 

ensures a level of safety at least equal to existing rules:

– operate UAS below 300 feet and within a radius of 1000 feet from the controller to 

aid in direct line of sight visual observation;

– obtain permission from the owner/controller of any vessels, vehicles and structures 

when operation may be conducted closer than 500 feet to any such vessels, vehicles 

or structures; I will conduct a safety assessment of the risk of operating closer to 

those objects and determine that it does not present an undue hazard;

– operate the UAS for 5-10 minutes per flight;

– land UAS prior to the manufacturer's minimum level of battery power; 

– operate the UAS during daylight hours and only within visual line of sight (VLOS);

– use the UAS's global positioning system (GPS) flight safety feature whereby it 

hovers then slowly lands if communication with the remote control pilot is lost;

– conduct all operations under the flight safety protocols (including posting a warning 

sign reading: “Attention, Aerial Photography in Progress -Remain Back 150 feet”) 

and will actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

– contact respective airports if operations will be within 5 miles to advise them of my 

estimated flight time, flight duration, elevation of flight, and other pertinent 

information;

– always obtain all necessary permissions prior to operation; have procedures in place 

to abort flights in the event of safety breaches or potential danger;

– only operate in safe environments that are strictly controlled, away from power lines,

elevated lights, airports, and densely populated areas (defined by areas depicted in 

“yellow” on VFR charts and through obtaining information regarding congested 

areas from the local Flight Standards District Office (FSDO);

– conduct extensive preflight inspections and protocols, during which safety carries 

primary importance (reference Chroma Flying Reference Guide and User Manual).

Regarding UAS operational training, I have flown numerous practice flights on my personal 
property as well as at the local Academy of Model Aeronautics simulating flights for future 

commercial use to gain familiarization with the characteristics of the UAS's performance under 

varying temperature and weather conditions.

In a manner consistent with 14 CFR 61.51(b), I will have logged 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with multi-rotor UAS. I 

will 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. In addition to the hour requirements, 

I will accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes) 

prior to any flight.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with the UA, I feel an 

exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and 

(b) (Certification Required), subject to certain conditions and limitations, is warranted 

and meets the requirements for an equivalent level of safety under 14 CFR part 11 and 

Section 333 of P.L. 112-95 (Section 333).

I request an exemption from §45.23 Marking of the aircraft because the UA will not have a 

cabin, cockpit, or pilot station on which to mark certain words or phrases. Further, the 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller 

than the minimal lettering requirement. Regardless of this, I can mark the UAS in the 

largest possible lettering by placing the word “Experimental” on it's fuselage as required 

by § 45.29(f) so that anyone will be able to see the markings.

I request an exemption from §91.7(a) which prohibits operation of an aircraft without an 

airworthiness certificate, since there is currently no certificate applicable to my operation,

this regulation is inapplicable.

I request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and 

(b) Maintenance inspections since they only apply to aircraft with an airworthiness 

certificate. However as a safety precaution I will perform a pre-flight inspection of the 

UAS before each flight as outline in the attached operating documents. 

I request an exemption from §91.9(b)(2) which requires an aircraft flight manual in the 

aircraft, however since there are no pilots or passengers on board the aircraft and given 

it's size, this regulation is inapplicable. I believe an equivalent level of safety will be 

achieved by maintaining a safety/flight manual with the UAS ground station. 

I request an exemption from §91.119 which prescribes safe altitudes for the operation of 

civil aircraft, but it allows helicopters to be operated at lower altitudes in certain 

conditions. I will not operate my UAS above the altitude of 300 feet above ground level 

(AGL) and will also only operate in safe areas away from the public and traffic, thus 
“providing a level of safety at least equivalient to or below those in relation to minimum 

safe altitudes.” Given the size, weight, maneuverability, and speed of the UAS, an 

equivalent or higher level of safety will be achieved. 

I request an exemption from §91.121 Altimeter settings as it is inapplicable since the UAS 

utilizes electronic GPS with a barometric sensor.

I request an exemption from §91.151(a) Fuel requirements for flight in VFR conditions. 

The UAV is 100% electric and two low-battery alerts are issued – per the operating 

documents, the UAV will be landed at the first alert. Also my flights will only last 5-10 

minutes each, and the UAS has an automated function which results in immediate landing 

when a low batter is detected. I will not begin a flight unless (considering wind and 

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

landing and, assuming normal cruising speed, land the UA with 30% battery power 

remaining.

Public Interest

Aerial photography and videography for real estate and events are proven strategies to 

enhance marketing efforts and increase business success. The industry is now new, 

however until recently it was conducted through the use of costly manned aircraft, a 

prohibitive business activity for small companies. By granting this exemption I would be 

able to provide affordable services. 

Further, the small UAS will pose no threat to the public given it's small size and lack of 

combustible fuel when compared to larger manned aircraft. Additionally, the operation of

my UAS will minimize harm to the environment economic growth by providing 

information to companies and the public looking to relocate or build in the rural areas I 

will service. Public and private events serviced by my business enhance vibrancy and add 

culture to the community and it's citizens. 

Summary

I will comply with all of the following conditions and limitations should this exemption be 

provided:

 1)Operations will be limited to the following aircraft described in the operating 

documents, which is a quad-rotor aircraft weighing 2.9 pounds: Blade Chroma

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above ground level 

(AGL), All altitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot in Command 

(PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated within 
the visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to 

communicate verbally at all times. The PIC will be designated before the flight and 

will not transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the functions prescribed in the operating 

documents.

6) The Operating Documents will be accessible during UAS operations and made 

available to the Administrator upon request. Any revisions to the operating 

documents will be presented to the Administrator upon request.

7) Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight.

8) Any UAS maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional 

test flight. The PIC who conducts the functional test flight will make an entry in the 

aircraft records.

9) The pre-flight inspection section in the operating documents will account for all 

discrepancies i.e. inoperable components, items, or equipment, not already covered in 

the relevant sections of the operating documents. 

10) I will follow the UAS manufacturer's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

11)I will carry out maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations will 

be noted in the aircraft records, including total flight hours, description of work 

accomplished, and signature of the PIC.

12)Each UAS operated will comply with all manufacturer Safety Bulletins.

13)An authorized person will make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

14)Prior to operations conducted for the purpose of aerial videography/photography and for

real estate listing videos and public and private events and similar operations, the PIC 

will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a 

minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours 

logged as a UAS pilot with multi-rotor UAS.

15)Prior to operations conducted for the purpose of aerial videography/photography and for

real estate listing videos and public and private events and similar operations, the PIC 

will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a 

minimum of 5 hours as a UAS pilot operating the make and model of the UAS to be 

used in operations. The PIC will accomplish 3 take-offs and landings in the preceding 

90 days.

16)The PIC will not operate the UAS for the purpose of aerial videography/photography 

and for real estate listing videos and public and private events and similar operations, 

unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 

61.51(b), the ability to safely operate the UAS in a manner consistent with the operating 

documents, including evasive and emergency procedures and maintaining appropriate 

distance from people, vessels, vehicles, and structures.

17)UAS operations will not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart.
18)UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All 

operations will be conducted under visual meteorological conditions. (VMC). 

19)The UA will 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 statue miles from the PIC.

20)If a UA loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered in accordance with 

the operating documents. 

21)The PIC will abort a flight in the event of unpredictable obstacles or emergencies in 

accordance with the operating documents.

22)The PIC will not begin a flight unless(considering wind and forecast weather conditions)

there is a enough power to fly at normal cruising speed to the intended landing point and

land the UA with 30% battery power remaining.

23)I will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations, and also request a Notice to 

Air-man (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior 

to the operation.

24)Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA will comply with the Federal Communications, Commission (FCC) or

other appropriate government oversight agency requirements. 

25)The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at 

the Ground Control Station of the UAS any time the UAS is operating. These 

documents will be made available to the the Administrator or any law enforcement 

official upon request.

26)The UA will remain clear and yield the right of way to all manned aviation operations 

and activities at all times.

27)The UAS will not be operated by the PIC from any moving device or vehicle.

28)The UA will not be operated over congested or densely populated areas.

29)Flight operations will be conducted at least 500 feet from all nonparticipating 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. I will ensure that 

nonparticipating persons remain under such protection. If a situation arises where

a 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 or operating closer to those 

objects and determined that it does not present an undue hazard, and;

C. Operations nearer to the PIC, VO operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).All operations will be 

conducted over private or controlled-access property with permission from 

the land owner/controller or authorize representative. Permission from lane

owner/controller or authorized representative will be obtained for each 
flight to be conducted.

30)Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 

will be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.

If you have any questions or need additional information please contact me at 

Support@SPAS-12.com, or (765) 702-3357

Thank you,

Christopher Long