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: Amendment 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 Exemption 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 add 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 aircraft 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 operation 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 Manual, 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 radius 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 Pacesetter, 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 observer 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 amendments 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 Photography, 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

Jeff Cunningham

President

JC/gcb

Attachments: 

 

DJI Phantom 3 Advanced User Manual

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_

User_Manual_v1.0_en.pdf

DJI S100 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