# BLUE AND GRAY SKY PHOTOGRAPHY, LLC

125 County Road 1850 Tupelo, MS 38804 Phone: 662/316

- 4129 Facsimile: 662/844

- 1975 Email: blueandgraysky@gmail.com February 18, 2016 U.S. Department of Transportation Docket Management System West Building, Ground Floor, Room W12
- 140 1200 New Jersey Ave., S.E. Washington, DC 20590 RE: Am endment to Existing Exemption No.: 14676 (adding UAVs only ) Regulatory Docket No.: FAA
- 2015
- 3593 Dear Sir/Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), and 14 C.F.R. Part 11, Blue and Gray Sky Photography, LLC seeks to amend Exempti on No. : 14676, Regulatory Docket No.: FAA
- 2015
- 3593 , granted by the FAA on February 4, 2016. Specifically, Blue and Gray Sky Photography, LLC wishes to amend the above Exemption to a dd the following additional UAVs: 1. The DJI Phantom 3 Advanced; 2. The DJI S
- 1000; and 3. The Precision Drone Pacesetter. All UAS requested have received relief under Section 333 by previous commercial entities. The added UAS are comparable in type, size, weight, speed, and operating capabilities to those in the original grant, and meet the 333 Exemption Guidelines. All ai rcraft have the same safety features as those listed in the original exemption. Copies of User Manuals are appended hereto. The Pacesetter drone already has a 333 Exemption approved to Precision Drone Works, LLC (Exemption No.: 11316). The area of oper ation for this drone is rural and sparsely populated areas, and all flights are planned and coordinated in advance, as set forth in the Precision Drone User’s Manual. The level of safety provided by the requirements, including the Precision Drone User’s M anual, exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. All those UAS weigh less than 55 pounds, have a built
- in capability to limit the height flown above the ground, to limit the ra dius of the distance it flies from the operator and to exclude it from Class B, C, and D airspace, including a no fly zone feature. Each system also has a fail
- safe function of the auto
- pilot system, which means if the communication between the main controller and the transmitter is lost, the system will return to home and land safely.This amendment to the existing exemption would permit commercial operations by Blue and Gray Sky

Photography, LLC to use the DJI models listed above, as well as the Pacese tter, to conduct aerial photography, agriculture assessment of crops, and data collection. The general public will greatly benefit from such operations, as it will help farmers better manage their crops and increase their yield. Both the pilot and the ob server went through a 72 hour class in operations, functions, and safety features of the Pacesetter, as presented by Precision Drones. There have been no changes in the request for exemption from specific regulations or conditions and reasons relative to public interest and safety that were the basis for granting the original exemption. We will operate these aircraft in accordance with the initial exemption we have been granted. We are not requesting any amendment s to our existing operating procedures
. As this is an amendment to the existing Exemption request, Blue and Gray Sky respectfully submits that good cause exists so that notice does not need to be published in the Federal Resister for the requested amendment. In summary, Blue and Gray Sky P hotography, LLC respectfully requests that the Amendment be granted. Should you need further information to process this request, please do not hesitate to contact us. Sincerely, BLUE AND GRAY SKY PHOTOGRAPHY, LLC

J eff Cunningham President JC /gcb Attachments: DJIPhantom 3 Advanced User Manual http://download.dji
- innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_ User_Manual_v1.0_en.pdf DJIS100 User Manual http://download.dji
- innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf Precision Drone Pacesetter User Manual http://portal.blackfrogdesigns.com/wp
- content/uploads/2015/03/2015
- Pacesetter
- User
- Manual.pdf