UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Daniels Elite Photography FO R AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF T HE 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 B lade Chroma UNMANNED A IRCRAFT SYSTEMS

PURSUANT T O SECTION 333 OF T HE FAA MODERNIZATION AND REFORM ACT OF 2012

( PUBLIC LAW 112-95)

Submitted on June 2 3 th , 2015
Deontae L Daniels Daniels Elite Photography 4 0 6 1 Bluebird drive

. Waldorf , MD 20603 Tel: ( 757 ) 613-3371TABLE 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 ............................................................ 7
THE S PECIFIC SECTIONS O F 1 4 C. F.R. F ROM W HICH D ANIELS PHOTOGRAPHY SEEKS EXEMPTION. ............................................................... 8
THE E XTENT O F R ELIEF Daniels Elite Photo g r ap hy SEEKS AND THE R EASON D ANIELS ELITE PHOTOGRAPHY SEEKS T HE RELIEF.............. .................................................................................................. 11
THE R EASONS W HY GRANTING D ANIELS PHOTOGRAPHY’S REQUEST WOULD BE IN THE PUBLIC INTEREST ......... ............................ 15
THE R EASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFET Y ......................................................................... 19
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. .... 34
ANY ADDITIONAL INFORMATION, V IEWS, OR ARGUMENTS AVAILABLE T O SUPPORT DANIELS ELITE PHOTOGRAPHY ’S R EQUEST... ................................................................................................................................. 34
CONC LUSION

................................................................................................................... 35
APPENDICES........................................................................................37

2GLOSSARY OF ABBREVIATIONS
AGL A bove 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

3SUMMARY Daniels Elite Photography 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

o f the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Daniels Elite Photography to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real
estate, an d landscape over cer tain ar eas o f

t he United States.
INTRODUCTION AND INTERESTS OF THE PETITIONER Daniels Elite Photography Continually provides its clients with expertise in the
f ield of photography and videography. Daniels Elite Photography has worked with many

c lients o n races, special events and weddings. Daniels Elite Photography is experienced in
all aspects of videography and photography. The objective of Daniels Photography’s
aerial video and photography Department is to provide high quality imaging for a variety
of commercial and residential customers. Owner Deontae Lee Daniels has extensive
k nowledge with Model Aircrafts to include R/c Jets, helicopters and plan es. currently a member of the AMA as well as the Charles County Remo te Control Club lo cated in Brandywine Maryland.



### Unmanned Aircraft Systems: Blade Chroma Camera Drone UASs Daniels Elite Photography seeks an exemption to operate Blade
Chroma within the NAS. The Blade Chroma Camera Drone
Features are v ertical t akeoff an d l anding (VTOL) U nmanned A ircraft (UA) with a Ground C o ntrol Station ( GCS)
4systems. The Blade Chroma Camera Drone has a maximum gross weight of

approximately 3 pounds 9 ounces, while having a length of 16 inches width of 16 inches, height of 8 in ches, an d a maximum s peed of approximately 29 knots. The UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric

motors.

The Blade Chroma Camera Drone UAs that will b e operated by Daniels Elite Photography will be registered in accordance with 49
U.S.C

. 44103, Registration of A ircraft , a s w el l a s 14 C.F .R P ar t 47, Aircraft Registration ,

an d m arked in accordanc e w ith 14 C.F.R. Par t 45, Identification and Registration Marking

. BASIS FOR PETITION Petitioner, Daniels Elite Photography , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act o f
2 012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , h ereby
p etitions th e A dministratorto c ommercially o p erate th e Blade Chroma Camera
Drone 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, Daniels Photography’s operation of 5Blade Chroma Camera Drone UASs meets the conditions of FMRA Section 333 and

therefore, will not require an airworthiness certificate in acco rdan ce with 1 4 C.F.R. Part 21, Subpart H. Daniels Elite Photography 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

r eq uirements for m aintenance that only apply to aircraft with an airworthiness
certificate. Daniels Elite Photography submits that the requested relief is proper since an equivalent

l evel o f s afety w ill b e ensured

. Daniels Elite Photography will Only use

ex perienced personnel or technicians to perfo r m maintenance, alterations, or preventive
maintenance on the UASs using the methods, techniques, and practices prescribed in the

o perating documents (i.e., I nstruction Manual). Furthermore, Daniels Elite Photography
will document and ma intain a ll maintenance records for th e Blade Chroma Camera Drone
UASs.

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

p ilo t privileges and limitations: Pilot in command , is requested by Daniels Elite Photography to t he ex tent necessary to allow a Pilot in Command (PIC) and who ha s d e monstrated, b y m eeting min imum flight - hour and currency requirements, that the PIC
is able to safely operate the Blade Chroma Camera Drone UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Daniels Elite Photography seeks relief from Section 91.7(a), entitled Civil aircraft

6airworthiness , because the Blade Chroma Camera UASs do not req uire an airworthiness

certificate in accordance with 14 C.F.R. Par t 21, Subpart H. As such, Daniels Elite Photography submits that it will ensure that the Blade Chroma Camera Drone UASs are in an airworthy condition, prior to every flight, by determining that the U ASs a re in compliance with t he operating documents (i.e., Instruction Manual), and that the aircraft

are in a condition f

o r safe flight.

Daniels Elite Photography also seeks an exemption from the requirements of Section 91.121, entitled Altimeter S ettings , as the Blade Chroma Camera Drone UAs w ill

n o t h ave a t ypical barometric a lt imeter onboard. However, altitude information of the
Blade Chroma Camera Drone UAs will be provided to the PIC via Glob al Positioning
S ystem ( GPS) equipment and radio communications telemetry data link, which downlinks from
the UA to th e G CS f

ora ctive mo nitoring o f

th e f light path. T his a ltitude in formation,

c ombined w ith D aniels Photography’s operation of the Blade Chroma Camera Drone
UASs within visual line of sight, at or below 400 fe et A GL, will en sure a lev el o f s afety
eq uivalent

t o S ection 91.121. Additionally, Daniels Elite Photography seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements fo r flig ht in VFR
conditions

. Daniels Elite Photography submits that safety will not be affected by operation of the Blade Chroma Camera Drone UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total

7duration of approximately 13.5 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, Daniels Elite Photography 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: Deo n tae L Daniels Daniels Elite Photography 4 0 6 1 Bluebird D r ive Waldorf , MD 20603 Tel: ( 757 ) 613

- 3371 Email: DeontaeDaniels@gmail.com B. The Specific Sections Of 1 4 C.F.R. From W hich Daniels Elite Photography Seeks Exe m ption.
1. D aniels Elite Photography Seeks Exemptio n From T he Requirements Of Section 61.113(a ) A nd (b).
Section 61.1 13, 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 pil ot may, for compensation or hire, act as PIC of an aircraft in connection with any business o r employment if — (1) The flight is o nly incidental to that business or employment; and (2) The aircra ft does not carry passengers or property for compensation or hire.

2. Daniels Elite Photography Seeks E x emption F rom The R equirements O f Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

8(a) No person may operate a civil aircraft unless it is in an airworthy condition.
3. Daniels Elite Photography Seeks E x emption F rom The R equirements 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 s et, 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 the re 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 c ase of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
4. Daniels Elite Photography Seeks E x emption F rom The R equirements O f Section 91.151(b).
Secti on 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.
5. Daniels Elite Photography Seeks E x emption F rom T he Requirement Of Section 91.405(a).
Secti on 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[.] 96. Daniels Elite Photography Seeks E x emption F rom T he R equirements O f Section 91.407(a)(1)
Section 91.407, e ntit led 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 b een approved for return to service by a person authorized under § 43.7 of this chapter[.]
7. Daniels Elite Photography Seeks E x emption F rom T he R equirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, e ntitled 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 i nspection in accordance with part 43 of this chapter and has been appro ved for return to service by a person authorized by § 43.7 of this chapter; or (2) An ins pection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
8. Daniels Elite Photography Seeks E xemption F rom The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, e ntitled Maintenance records , subsections (a) and (b), state the following: (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 a ircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A des cription (or reference to data acceptable to the Administrator) of the work performed; and

10(ii) The date of completion of the work performed; and (iii) The s ignature, and certificate number of the person approving the aircraft for return to service. (2) Re cords containing the following information: (i) T he 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 s ince 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) Th e current status of applicable airworthiness directives (AD) and safety directives includ ing, 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: (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 l ist 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.

11C. The E x t ent Of Relief Daniels Elite Photography Seeks A nd T he Reason Da niels

Photography Se eks T he Relief.
1. E x tent Of Relief Daniels Elite Photography Seeks And The Reason D aniels Photography 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, Daniels Elite Photography submits that an equivalent l evel o f

s afety will b e maintained b ecause no P IC will b e allowed t o o p erate the
UAS unless that PIC h as me t certain flight -hour and cu rrency requirements, demonstrating
that the PIC is ab le to s afely o perat e Blade Chroma UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency
maneuvers, as w ell as ma intaining appropriate distances from people, vessels, vehicles and

structures.

Daniels Elite Photography submits that all flights of the UASs, conducted by the PIC pursuant to the grant of this

12Petition: (1) will be incidental to Daniels Photography’s business; and (2) will not

carry passengers or property for compensation or hire.
2. E x t ent Of Relief Daniels Elite Photography Seeks And The Reason Daniels Elite Photography Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled C ivil aircraft airworthiness , is requested to
the extent required to allow Daniels Elite Photography to determine that the UASs are in airworthy condition prior to every flight b y e nsuring th at the U AS is in c ompliance

w ith t h e o perating documents (i.e., Instruction Manual).

Daniels Elite Photography seeks the requested relief because the Blade Chroma
UASs do not re quire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Daniels Elite Photography will ensure that the Blade Chroma
UASs are in airworthy condition based upon its com p liance with the operating
documents (i.e., Instruction Manual) prior to every flight, and further, de termine th at
the aircraft are in condition for safe flight, as stated in the conditions and li mitations
below.

3. E x tent Of Relief Daniels Elite Photography Seeks A nd T he Reason

Daniels Elite Photography Seeks Relief From Section 91.121.
R elief f rom Section 91.121, e ntitled A ltimeters ettings, ma y b e required to allow flight operations of the Blade Chroma

13UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio

communications te lemetry data link to downlink altitude i nformation from t he U A t o the
PIC a t t he gr ound control station ( GCS). Since the FA A requires that any altitude
information concerning UAS operations b e reported t o ai r traffic control ( ATC) i n f eet above ground level (AGL), Daniels Elite Photograph y s eeks t h e requested r elief
b ecause the B lade Chroma U A’s a ltimeter may be set on the ground to zero feet AGL, rather than the local barometri c pressure or field a ltitude, before each flight.

Considering t he l imited altitude of t he pr oposed operations, relief f rom 14 CFR
91.121 is s ought t o the e xtent ne cessary t o comply with the a pplicable c onditions and
limitations stated below. As more fully set forth herein, an equivalent level of safety will
be maintained since the Blade Chroma UAs are equipped with a barometric pressure

sensor and GPS equipment, which a utomatically ensures th at a ground l evel p ressure setti ng 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. E x tent Of Relief Daniels Elite Photography Seeks A nd T he Reason Daniels Elite Photography 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 Blade
Chroma UAs during day light hours in visual meteorological conditions (VMC), under
visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Daniels Elite Photography seeks the requested r elief b ecaus e without an exemption from
Section 91.151(b), the flight time 14duration of the battery powered Blade Chroma U As w ill s everely co nstrain t he
p r acticality o f any aerial video o rs till photo flight operations that Daniels Elite Photography proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the techn ical specifications of the Blade Chroma UASs, the Blade Chroma operating documents, and D aniels Photography’s proposed operating limitations, ensure that Daniels Elite Photography will s afely o perate the
b attery powered UAs during daylight hours in visual meteorological conditions (VMC),

u nder visual flight rules (VFR), with enough battery power to fly for a total duration of
13.5 minutes to the first point of intended landing and, assuming normal cruising speed,
to fl y after th a t fora t least 4.5 minutes.

5. E x tent Of Relief Daniels Elite Photography Seeks A nd T he Reason Daniels Elite Photography Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a)(2), And 9 1.417(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, Daniels Elite Photography requ ests

r elief from

t hese Sections b ecause the UASs do not require airworthiness certificates. As

set forth more fully below, the UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Daniels Elite Photography
will use trained technicians to perform maintenance, alterations, or preventive
maintenance on the UASs using the methods, techniques, and practices prescribed in th e UAS o perating documents (i.e.,

15Instruction Manual). Daniels Elite Photography will document and maintain all

maintenance records for the Blade Chroma Camera Drone UASs.
D. T he Reasons W hy Granting D aniels P hotography’s Request W o uld B e 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
Daniels Elite Photography to safely, efficiently, and economically perform aerial video
and photography of construction sites, real estate, and landscape over certain areas of
the United S tates. Additionally, use of the Blade Chrome Drone the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of D aniels Photography’s proposed operation of the Blade Choma Camera Drone U ASs w ill be

r ealized w ithout implicating any p rivacy issues.

1. The Pub lic Will Benefit From Decreased Congestion Of The NAS.
The Blade Chroma UAs are battery p owered an d serve a s a safe, efficient, a nd

eco nomical al ternative to t he m anned a ircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned ai rcraft n eeded t o perform aerial acquisitions, an e x emption allowing the use of a UAS would reduce the amount of
manned aircraft in the NAS, reduce noise and ai r pollution, as well as increase the safety
of life an d property in the air and on the ground.

Furthe rmore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 16UAs do not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial v ideo and photography missions would result in fewer aircraft
that must be handled b y ai r traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. T he Public Will B enefit F rom T he Safety A nd E fficiency O f The Blade Chroma Camera Drone UASs.

Conducting aerial acquisitions with the Blade Chroma Camera Drone UAS s, instead of manned aircraft, will greatly benefit the public b y d r astically reducing the levels
of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and e lectric mo tors, th e Blade Chroma Camera
Drone UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal
combustion e ngine aircraft that are t ypically u tilized f or a erial video and photography,
while burning approximately 20-30 gallons per hour of leaded aviation fuel. The Blade
Chroma Camera Drone , while reducing the carbon footprint of aerial acquisitions, a lso

e liminates n oise p ollution, as th e U As a re propelled by battery powered electric motors,
rather than an internal combustion engine.

By using the 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 f

light crew members located onboard the aircraft, the B lade Chroma
C amera Drone

17at only 3 pounds has less p h y sical potential f or collateral damage to lif e and property on
the ground, and in the air, compared to th e ma nned a ircraft that typically c onduct similar

o perations ( weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity o f 1 80 gallons).

3. Performing A erial Vid eo and Photography Operations With The B lade Chroma Camera Drone UASs W ill Benefit T he Economy.

In addition to being safe and efficient, the B lade Chroma Camera Drone UAS s

ar e also an ec onomical al ternative to u sing m anned aircraft t o co n d uct similar aerial operations. As such, operation wi ll allow U nited S tates based companies, like Daniels Elite Photography , to remain c o mp etitive a nd c ontribute to growth of the U.S.
economy. Specifically, with the r ising cost of aviation fuel and the Environmental
Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels

.

184. There A re No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, D aniels Photography’s proposed operation of the Blade Chroma Camera Drone
UASs w ill not implicate a ny privacy is sues. Specifically, U ASs w ill be o perated o nly in

c ompliance w ith operating documents (i.e., Instruction Manual) which requires property

owner involvement as well as local law e nforcement 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 B y The Rule From W hich Daniels Elite Photography Seeks Exemption. 1. Reasons Why The B lade Chroma Camera Drone U As Meet The C onditions O f T he F AA M odernization 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, D aniels Photography’s operation of the
Blade Chroma Camera Drone UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in 19accordance with 14 C.F.R. Part 21, Subpart H. 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.

-- Notwithsta nding 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) whic h 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, D aniels Elite Photography submits that the
B lade Chroma Camera Drone U ASs can o perate s af ely i n t he
NAS pursuant to FMRA Section 3 33, as d emon str ated b y: (a) t he character istics o f t he
Blade Chroma Camera Drone UASs; (b) the pilot certification requirement; and (c ) the specific operating limitations.

a. The Spe cifications Of The Blade Chroma Camera Drone UASs Demonstrate Its Safe Characteristics.

20The Blade Chroma Camera Drone UASs do not create a h azard 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. T echnica l S pecifications Of T he UASs.

The technical specifications of the Blade Chroma Camera D rone ar e set f orth by

t he , Blade Chroma Camera Drone Specifications and Data Sheet, at tached h er e to as
E x hibit A

iii. The Blade Chroma Camera Drone UASs Ar e Designed For

Automatic Return To Home Point Or Hover In The Event Of L o ss Of The Control Link Or Navigation.

When the Control Link is lost, the Blade Chroma Camera Drone UAs wi ll remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, UAs do not reacquire
control link data from the GCS, the UAs w ill assume th at the Control Link is lost and the
UAs will return to the home po sition (i.e., f ailsafe mode) via GPS, and will descend to the
takeoff position and shutdown.

21b. Fligh t O perations O f Blade Chroma Camera Drone UASs A re Limited T o T he Line Of

S ight Of A C ertificated P ilot i n Command W ith A S afety Observer. Daniels Elite Photography will only u tilize c ertificated p ilo ts to a ct as a
p ilo t in c ommand ( PIC) o f t he Blade Chroma Camera Drone UASs. Additionally, a safety o b server will assist all pilots during flight time.

c. Flights Of Blade Chroma Camera Drone U ASs W ill Be C onducted Pursuant T o S pecific Operating L imitations.
In seeking this exemption, Daniels Elite Photography proposes to co mmercially operate Blade Chroma Camera Drone UASs for the special purpose of conducting aerial
video and photography over certain areas of United States, pursuant to th e f o llowing

s pecific o perating limita tions:
1. Oper ations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less 22than 55 pounds maximum gross weight: Blade Chroma Unmanned Aircraft Systems. Proposed operations of any oth er 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 500 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 exis ts 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 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. 2310. 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 alterati ons 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 ope rator 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 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. § 2419.1. 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 pre
determined 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 operatin g 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 m ore 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. Markin gs must be as large as practicable. 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. 2529. 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. Barr iers 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

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Daniels Elite Photography 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 Blade Chroma Camera Drone UASs unless that PIC has demonstrated, b y me eting m in imum flight -hour requirements, a nd is a ble to safely operate the Blade Chroma Camera Drone
26in a manner consistent with the exemption, including evasive and e mergency m aneuvers

an d m aintaining appropriate distances from people, vessels, vehicles and structures.

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). Daniels Elite Photography will not allow any PIC to opera te the UAS in a
manner consistent with this exemption, including evasive and emergency maneuvers
and maintaining appropriate distances from people, vessels, vehicles an d structures.

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

27with 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 D aniels Elite Photography’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:
I n 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 tota l 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 m ake 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 t ime 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 i n compliance 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, Daniels Elite Photography will ensure safe operations by not allowing any PIC t o operate the Blade Chroma Camera Drone

28UAS unless that PIC has d emonstrated, b y me eting min imum flight -hour and currency

requirements, that the PIC is able to safely operate the Blade Chroma Camera Drone
UAS in a manner consistent with the exemption, including evasive and emergency

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

structures.
3. Reas ons Why An Exemption From The Requirements Of Sec tion 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, Daniels Elite Photography will ensure that the Blade
Chroma Camera Drone UAS is in an airworthy condition ba sed upon the UAS’s compliance with its operating documents and as stated in the conditions and limitation s h erein.
Addit ionally, 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. Reas ons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained
because the altitude information of the Blade Chroma Camera Drone UAs will be provided to the PIC via GPS equipment and a r adio c ommunications te lemetry data link,
which downlinks f

rom the UA to the GCS for a ctive monitoring of the flight path and
altitude. T his a ltitude in formation, c ombin ed with Daniels Photography’s operation of
the Blade Chroma Camera Drone UAs within visual line of sight, at or below 500 feet AGL,

29will 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 specif ic 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. Reason s 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 Blade
Chroma Camera Drone UASs; (2) the limitations on the proposed flight operations; and (3)
the lo cation of the proposed flight operations. Accordingly, Daniels Elite Photogr aph y will

ensure th at it will safe ly o perate th e battery powered Blade Chroma Camera Drone UAs during daylight hours in VFR conditions, with enough battery power to fly for a total
duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 mi n u tes.

Here, as in Exemption No. 11109, the technical specifications of the Blade Chroma
Camera Drone UASs; the limitations on the proposed flight operations; and the location of
the proposed operations, will ensure an e quivalent l evel o f s afety es tablished by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Blade Chroma Camera
Drone UASs provide audible and visual warnings to the PIC at the GCS wh en t he UAs experiences low battery voltage, the first warning occurring at approximately 33%

30remaining battery power, and again at approximately 10% remaining b attery power . At

the critically low battery level, the Blade Chroma Camera Drone UASs will descend and
land a u tomatically. Signif icantly, 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. Reas ons 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.
In s eeking t h is exemption, Daniels Elite Photography submits that the equivalent
level of safety with regard to the regulatory maintenance and alteration r eq u irements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b) wi ll be m e t because Daniels Elite Photography will use trained technicians to per form maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Instruction Manual). Furthermore, Daniels Elite Photography will document and maintain all maintenance
records for th e Blade Chroma Camera Drone UASs.

31Since the Blade Chroma Camera Drone UA Ss w ill be in spected as prescribed by

the operating documents, Daniels Elite Photography w ill maintain the equivalent level o f

s afety e s tablished b y S ections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Blade Chroma Camera Drone
User Manuals are attached h ere as E x hibit B

.

Likewise, the exemption sought will not adversely affect safety b ecause Daniels Elite Photography will use trained technicians to perform maintenance,
alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents.
Furt hermore, the e xemption sought w ould maintain an equivalent l evel of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
Blade Chroma Camera Drone UASs will be performed b y trained technicians.
Maintenance will be documented and maintained u tilizing th e mo nthly ma intenance log.

Signific antly, 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 cons idered.
In consideration of D aniels Photography’s proposed operating limitations, the operating documents, and the technical aspects of the Blade Chroma Camera Drone UASs, Daniels Elite Photography submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections

3291.405(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 FA A May Prescribe Any Other Conditions For Safe Oper ation.
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, Daniels Elite Photography requests that the FAA prescribe special conditions for the intended operation of the Blade
Chroma Camera Drone UASs, which contain su ch s afety s tandards t hat the Administrator
finds n ecessary 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 w ill permit safe o peration o f th e U As f

orth e limite d p urpose of conducting aerial video and photography over cert ain ar eas o f t he United S tates for compensation or h ire. 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 fu rther, provid es the authority for such UAS to operate without airworthiness c ertification in a ccordance with a ny requirements th at must be
established for the safe operation of the UAS in the NAS.

Likewi se, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Blade Chroma Camera Drone UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain

33adequate or appropriate safety standards, due to the novel or unus ual 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 c hapter 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 p rescribe special co nditions f or D aniels intended operation of the
Blade Chroma Camera Drone 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).
F. A Summary That Can Be Published In The Federal Register, stating: The Rules From W hic h D a niels Elite P hotography Seeks Exemption:
Daniels Elite Photography 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 T h e N a t u re O f T h e E x emption D aniels Elite Photograph y Seeks: This exemption will permit Daniels Elite Photography 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 D aniels P hotography’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

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

UAS may operate safely in the NAS. As such, D aniels Photography’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 Se ction 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, Daniels Elite Photography will operate the
Blade Chroma Drone UASs safel y 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, Daniels Elite Photography seeks an exemption pursuant to 14
C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Blade Chroma Camera Drone U ASs

c ommercially, w ithout an a irworthiness c ertificate, for the limited purpose of conducting
aerial video and photography over certain areas of the United S tates. B y granting th is
P etition, th e F AA Administrator w ill be f ulfilling th e Congressional mandate of the FAA
Modernization and Reform Act of 2012, while also ad vancing t he interests of the public, by allowing Daniels Elite Photography to safely, ef f iciently, an d economically operate the
B lade Chro ma Camera Drone U ASs c ommercially within th e NAS.

WHEREFO RE , in accordance with the Federal Aviation Regulations and the FAA

35Modernization and Reform Act of 2012, Section 333, Daniels Elite Photography

respectfully requests that the Administrator grant this Petition for an exemption from the

r equirements 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 Daniels Elite Photography to operate the Blade Chroma Camera Drone UASs commercially for the
purpose of conducting a erial v ideo an d photography over ce rtain ar eas o f

t h e United
States.
Dated: June 23 th , 2015
R espectfully submitted,
Daniels Elite Photography /s/
Deontae Lee Daniels 4 061 Bluebird Dr , MD 20603 ( 757 ) 613

- 3371

Appendices:
A. Blade Chroma Camera Drone Specifications Data B

. Blade Chroma Camera Drone Manual C. Monthly Maintenance Log

36APPENDIX – A Blade Chrome Drone Log + TECHNICAL

SPECIFICATIONS Daniels Elite Photography only utilizes safe and reliable UASs. Horizon Hobby is an industry leader in small UAS production. Horizon Hobby's Blade Line of UASs are loaded with ground breaking software enabling the user to set p ar ameters which will not allow flight in to controlled ai r space. Pa r ameters
can also b e s et to limit flight to n o h igherth an a p redetermined and s et altitude a s w ell as limit flight to a predetermined and set distance. In addition, Blade software provides r eal -ti me a ltitude a nd lo cation in formation to th e P IC v ia th e lin ked mo nitor

" SAFE Plus technology gives you several flight modes that have been specially p r o grammed to make smooth, steady image capture easy. In fact, it can make you look like a pr o ev en if you’ve never flown a c amera drone before! All flight modes feature self-leveling and use GPS and altitude sensors to precisely hold position. SAFE Plus technology will even land the aircraft for you if you activate the Return Home function. This version of the Chroma drone gives you the added benefit of Follow Me and Watch Me flight modes that let you focus on getting the shot while the drone does the f lying. "

" Return Home Safe landings with the flip of a s witch. Returns the drone to its start-up point and lands it for you Great for first-time flyers who aren’t ready to land themselves Easy way to regain visual contact if you lose sight in flight Resume full control at any time Activates automatically if controller signal is lost Adjustable Flight Boundaries Stay legal. Stay safe. Fly responsibly. Keeps the drone within altitude and distance limits you de fine Easily adjusted using the Chroma programmer Helps you avoid sensitive airspace ...and neighbors "Aircraft Motor to Motor Distance: 15.7 in (400mm) Rotor Type: Quadcopter Prop Diameter: 10.2 in (260mm) Approximate Flight Time: 30 minutes Battery: 11.1V 3S 5400mAh Li-Po Height: 9.50 in (242mm) Weight: 45.9 oz (1.3 kg) Motor Type: 4 × 780Kv Brushless Outrunner Control Link: 2.4GHz Video Link: 5.8GHz Video Link Range: 1,970 ft (600m) Satellite Navigation System: GPS, GLONASS Completion Level: Ready-to-Fly

Camera Operating Environment Temperature 0 °C -4 0 °C Sensor Si ze 1/2.3" Effective P ixels 14 Megapixels Resolution 4384×3288 HD Recording 1080p30 & 720p Recording FOV 110° / 8 5°

Remote Control Operating F requency 5.728 GHz

- 5.85 GHz Communication Distance ( Open Area) CE C ompliance: 400m; F CC C ompliance: 80 0m Receiver S ensitivity ( 1%PER) -9 3dBm

38APPENDIX – B

Blade Chroma Manufacturer ’s User M anual
* See attached PDF File

39APPENDIX – C

Monthl y Maint enance Log

UAS #_____ Date Issue Mantainence Performed Initials
Firmware

Check Frame Engines Propellers

Camera Gimbal Landing

Gear Vibration

Other:

40