'-----' 

CUMALANDER 

ADCOCK11P 

W. MARK CUMALANDER 

JAMES S. ADCOCK Ill 

February 19, 2016 

ATTORNEYS 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

't 

CUMAL.ANDER ADCOCK, I..I..P 

WWW.CAML.AWFIRM.COM 

300 JUDD PLACE DRIVE 

POST OFFICE BOX I OSS 

FUQUAY-VARINA, NC 27526 

(T) 91 9-552·2929 

(F) 91,9·552-2558 

Re: Exemption Request - Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. Part 21: 14 C.F.R. 61.23(a) & (c); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 

91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 

407(a)(1); 14 C.F.R. 409(a)(1) & (2); 14 C.F.R. 417 (a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 {the "Reform Act") and 14 

C.F.R. Part 11, HBJ Group, Inc., a North Carolina business corporation ("HBJ") hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") listed herein to allow for commercial operation 

of its Unmanned Aircraft Systems ("UAS") for aerial data collection, video, and photography of 

commercial and residential real properties, and events 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. 

As detailed in this document, the requested exemption would permit the operation of UAS under 

controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. 

Approval of this exemption would thereby enhance safety and fu!fill.the Secretary of Transportation's (the 

FAA Administrator's) responsibilities to "establish requirements for the safe operation of such aircraft 

systems in the national airspace." Section 333{c) of the Reform Act. 

The name and address of the applicant is: 

HBJ Group, Inc. 

Braxton Jones, President 

8421 Walter Myatt Road 

Willow Spring, NC 27592 

PH: (919) 6014984 

Email: Braxton@ncrealestatepro.com 

Regulations from which the exemption is requested: 

14 CFR 61.23{a) & {c), 

14 C.F.R. 61.113{a) & (b) 

14 C.F.R. 91.7(a) 

Page 1 of14 

/ 
14 C.F.R. 91.119{c} 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a}(1} 

14 C.F.R. 91.405(a} 

14 C.F.R. 407(a)(1) 

14 C.F.R. 409(a)(1) & (2} 

14 C.F.R. 417 (a) & (b) 

I. UAS PROPOSED BY PETITIONER 

Unmanned Aircraft Systems: Blade Chroma 4k 

HBJ seeks an exemption to operate the Blade Chroma 4k UAS system for compensation or hire within 

the NAS. The Blade Chroma 4k UAS is a vertical takeoff and landing {VTOL} Unmanned Aircraft (UA} 

with a Ground Control Station (GCS}. 

The Blade Chroma 4k has a maximum gross weight of approximately 45.9 ounces, while having a 

maximum flying height of 400' AGL. The Blade Chroma 4k is equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors. 

The Blade Chroma 4k that will be operated by HBJ will be 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. 

II. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority 

includes exempting civil aircraft, as the term is defined under §40101 of the Act, including UAS, from the 

requirement that all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f). See also 49 U.S.C. §44711(a}; 49 U.S.C. §44704; 

14 CFR §91.203(a)(1}. 

Section 333(b} of the Reform Act assists the Secretary in determining whether UAS may operate in the 

National Airspace System (NAS) without creating hazard to the user, the public, or a threat to national 

security. In making this determination, the Secretary must consider: 

• The UAS size, weight, speed, and operational capability; 

• Whether the UAS operates within the visual line of sight of the operator 

• Whether the UAS operates outside of highly populated areas and away from close proximity to 

Airports. 

Reform Act §333{a); If the Secretary determines that a UAS "may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the national 

airspace system." ld. §333(c). 

HBJ's UAS are multirotor vehicles, weighing 10 or fewer lbs. including payload. They operate under 

normal conditions at a speed of no more than 50 mph and have the capability to hover, and move in the 

vertical and horizontal plane simultaneously. The UAS will operate only in the Pilot's visual line of site at 

all times and will operate only within the sterile area of HBJ's commercial and residential real property 

sites. Such operations will ensure that the UAS will "not create a hazard to users of the national airspace 

system or the public". 

Page 2 of 14 

-
Given the small size of the UAS involved and the area within which they will operate, HBJ's applications 

falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also due to 

the small size of the UAS and the low altitudes and limited areas in which the UAS will operate, approval 

of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public 

interest. Accordingly, HBJ respectfully requests that the FAA grant the requested exemption without 

delay. 

Ill. EXEMPTION REQUEST IS IN THE PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking required 

under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress' intent of 

allowing UAS to operate with significant safety precautions in low risk environments. 

Granting the present Petition will further the public interest by allowing HBJ to safely, efficiently, and 

economically perform aerial video and photography of commercial and residential real estate, events and 

civic landscape over certain areas of the United States. 

Additionally, use of UAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. 

The UAS to be operated hereunder 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 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. 

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 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. 

Conducting aerial acquisitions with UAS, 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 UAS produces 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 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 s UAS 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 members located 

on board the aircraft, the UAS (weighing less than 15 pounds at their maximum gross weight, and with no 

fuel on board), 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 

Page 3 of14 
6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons). 

In addition to being safe and efficient, the UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the UAS will allow United States based 

companies, like HBJ, 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 UAS 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 UAS, companies such as HBJ, can remain competitive and profitable, and therefore, 

provide greater job stability to employees and contractors, which will ultimately contribute to growth of the 

U.S. economy. 

All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted. This limitation protects the 

privacy concerns of private citizens. 

IV. DESCRIPTION OF SPECIFIC REGULATIONS FROM WHICH HBJ SEEKS EXEMPTION 

1. HBJ Seeks Exemption From The Requirements Of Section 61.23(a) & (c). 

Section 61.23(a) & (c), entitled Medical certificates: Requirement and duration, subsections (a) and (c) 

prescribe the following, in relevant part: 

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, 

a person-

( 1) Must hold a first-class medical certificate: 

(i) When exercising the pilot-in-command privileges of an airline transport pilot certificate; 

{ii) When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires three 

or more pilots; or 

(iii) When serving as a required pilot flightcrew member in an operation conducted 

underpart 121 of this chapter if the pilot has reached his or her 60th birthday. 

(2) Must hold at least a second class medical certificate when exercising: 

(i) Second-in-command privileges of an airline transport pilot certificate in part 121 of this 

chapter (other than operations specified in paragraph (a)(1 )(ii) of this section); or 

(ii) Privileges of a commercial pilot certificate; or 

(3) Must hold at least a third-class medical certificate-

(i) When exercising the privileges of a private pilot certificate; 

(ii) When exercising the privileges of a recreational pilot certificate; 

(iii) When exercising the privileges of a student pilot certificate; 

(iv) When exercising the privileges of a flight instructor certificate and acting as the pilot in 

command; 

(v) When exercising the privileges of a flight instructor certificate and serving as a 

required pilot flight crewmember; 

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, 

commercial pilot, or airline transport pilot certificate, or for a flight instructor certificate; or 

(vii) When performing the duties as an Examiner in an aircraft when administering a 

practical test or proficiency check for an airman certificate, rating, or authorization. 

(c) Operations requiring either a medical certificate or U.S. driver's license. 

Page4 ofl4 
(1) A person must hold and possess either a medical certificate issued underpart 67 of this 

chapter or a U.S. driver's license when-

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges 

in a light-sport aircraft other than a glider or balloon; 

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a 

glider or balloon; 

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while 

acting as pilot in command or serving as a required flight crewmember of a light-sport 

aircraft other than a glider or balloon; or 

(iv) Serving as an Examiner and administering a practical test for the issuance of a sport 

pilot certificate in a light-sport aircraft other than a glider or balloon. 

(2) A person using a U.S. driver's license to meet the requirements of this paragraph must-

(i) Comply with each restriction and limitation imposed by that person's U.S. driver's 

license and any judicial or administrative order applying to the operation of a motor 

vehicle; 

(ii) Have been found eligible for the issuance of at least a third-class airman medical 

certificate at the time of his or her most recent application (if the person has applied for a 

medical certificate); 

(iii) Not have had his or her most recently issued medical certificate (if the person has 

held a medical certificate) suspended or revoked or most recent Authorization for a 

Special Issuance of a Medical Certificate withdrawn; and 

(iv) Not know or have reason to know of any medical condition that would make that 

person unable to operate a light-sport aircraft in a safe manner. 

2. HBJ Seeks Exemption From The Requirements Of Section 61.113(a) & (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 

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

3. HBJ 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. 

4. HBJ Seeks Exemption From The Requirements Of Section 91.119(c). 

Section 91.119 entitled Minimum safe altitudes: General states the following: 

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

Page 5 of 14 
5. HBJ 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. 

6. HBJ Seeks Exemption From The Requirements Of Section 91.151(a)(1) & (b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (a)(1) & (b), states the 

following: 

(a) No person may begin a flight in an airplane 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-

(1) During the day, to fly after that for at least 30 minutes; or 

(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. 

7. HBJ 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[.] 

8. HBJ 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[.] 

9. HBJ 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: 

Page 6 of 14 
(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. 

10. HBJ 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: 

(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: 

(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. 

V. EXTENT OF RELIEF SOUGHT 

1. Extent Of Relief HBJ Seeks And The Reason HBJ Seeks Relief From Section 61.23(a) & (c). 

Relief from Section 61.23{a) & {b) entitled Medical certificates: Requirement and duration, is requested to 

the extent necessary to allow a PIC holding an airline transport, commercial, private, recreational, or sport 

Page 7 of14 
·-------------------------------------------------------------------------------------------------

pilot certificate to operate with a valid airman medical certificate or a valid U.S. driver's license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. 

An equivalent level of safety will be achieved because the UAS do not carry passengers or crew, are 

small in size, carry a small payload, and operate in limited areas for limited time periods. The medical 

requirements for the operation of a motor vehicle are proportional to or higher than those required to 

safely operate a UAS. In the event of pilot incapacity, there is little risk or danger to persons or property, 

compared to that of manned flight. 

2. Extent Of Relief HBJ Seeks And The Reason HBJ 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 an airline transport, commercial, private, 

recreational, or sport pilot certificate, as well as a current and valid airman medical certificate or a valid 

U.S. drivers license, 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, HBJ submits that an equivalent level of safety will be maintained because 

no PIC will be allowed to operate the UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate the UAS in a manner consistent with 

the operations and specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, HBJ submits that all flights of the UAS, conducted by the PIC pursuant to the grant of this 

Petition: 

(1) will be incidental to HBJ's business; and 

(2) will not carry passengers or property for compensation or hire. 

3. Extent Of Relief HBJ Seeks And The Reason HBJ 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 

HBJ to determine that the UAS are in airworthy condition prior to every flight by ensuring that the UAS is 

in compliance with the operating documents (i.e., UAS operation manual). 

HBJ seeks the requested relief because the UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, HBJ will ensure that the UAS are in airworthy condition 

based upon its compliance with the operating documents (i.e., maintenance logs, and UAS operation 

manuals) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as 

stated in the conditions and limitations below. 

4. Extent Of Relief HBJ Seeks And The Reason HBJ Seeks Relief From Section 91.119(c). 

Relief from Section 91.119(c), entitled Minimum safe altitudes, is requested in that the UAS will be 

operated at altitudes up to 400' AGL. The UAS will not operate at altitudes higher than 400' AGL and will 

maintain minimum separation from all nonparticipating persons, vessels, vehicles, and structures as set 

forth below. 

Page 8 of 14 
The equivalent level of safety will be achieved given the size, weigh_t, and speed of the UAS as well as 

the location within which the UAS is being operated. Flights will be in areas where permission has been 

granted, will not carry flammable fuel, and the low altitude operation will ensure separation between the 

UAS and conventional aircraft which must comply with Section 91.119. 

5. Extent Of Relief HBJ Seeks And The Reason HBJ Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

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

data link to downlink altitude information from the UAS 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}, HBJ seeks the requested relief because the UAS'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 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. 

6. Extent Of Relief HBJ Seeks And The Reason HBJ Seeks Relief From Section 91.151(a)(1) & (b). 

Relief from Section 91.151 (a)(1) & (b) entitled Fuel requirements for flight in VFR conditions, is requested 

to the extent required to allow flights of the battery powered UAS during daylight hours in visual 

meteorological conditions (VMC}, under visual flight rules (VFR), for a total duration of 20 minutes. HBJ 

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

of the battery powered UAS will severely constrain the practicality of any aerial video or still photo flight 

operations that HBJ proposes to conduct pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the UAS, the UAS operating documents, and HBJ's proposed operating 

limitations, ensure that HBJ will safely operate the battery powered 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 20 minutes. 

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). 

7. Extent Of Relief HBJ Seeks And The Reason HBJ 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, HBJ requests relief from these Sections because the UAS does 

not require airworthiness certificates. As set forth more fully below, the UAS meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, HBJ will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the UAS operating documents (i.e., UAS instruction 

manual and operating manual). Furthermore, HBJ will document and maintain all maintenance records 

for the UAS. An equivalent level of safety will be achieved because the UAS are small in size, carry a 

small payload, and operate in limited areas for limited time periods. If mechanical issues occur, the UAS 

Page 9 of 14 
can land immediately and will be operating no higher than 400 feet AGL. The PIC will ensure the UAS is 

in working order before each flight. 

In consideration of HBJ's proposed operating limitations, the operating documents, and the technical 

aspects of the UAS, HBJ submits.that safety will not be adversely affected by granting exemption from 14 

C.F.R. 61.23(a) & (c); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 

91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(1) & (2); 14 

C.F.R. 417 (a) & (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). 

Vl. FUGHT CONDITIONS AND SPECIFIC LIMITATIONS 

HBJ proposes that the exemption requested herein apply to the UAS that have the characteristics and 

that operate with the limitations listed herein. HBJ will be bound by the following limitations when 

conducting its UAS operations under FAA-issued exemption: 

1. Operations authorized by this grant of exemption are limited to the Blade Chroma 4k when weighing 

less than 55 pounds including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (1 00 miles per hour). The exemption 

holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot 

speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude 

must be reported in feet AGL. 

5. The UA 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 or U.S. driver's license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of 

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The VO 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 VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to 

as the operating documents. The operating documents must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, the conditions and 

limitations herein 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 or any law enforcement official upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon which the 

Page 10 of 14 
FAA granted this exemption, then the operator must petition for an 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. 

8. 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 prior 

to conducting further operations under this exemption. Functional test flights may only be conducted by a 

PIC with aVO and must remain at least 500 feet from other people. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for 

safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

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

inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or 

a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight review requirements specified 

in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51 (b). Flights for the purposes of training the operator's PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC's ability to safely operate the UAS 

in a manner consistent with how the UAS will be operated under this exemption are permitted under the 

terms of this 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 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR} are not authorized. 

16. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport's management is obtained or otherwise permitted by a COA issued to the exemption 

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

or any law enforcement official upon request. 

17. The UAS 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. 

Page 11 of14 
18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at not 

more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least 

one mile. This requirement for pennants or streamers is not applicable when operating exclusively below 

the top of and within 250 feet of any structure, so long as the UAS operation does not obscure the lighting 

of the structure. 

19. If the UAS loses communications or loses its GPS signal, the UAS must return to a pre-determined 

location within the private or controlled-access property. 

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

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to operate 

after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. 

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be 

conducted in accordance with an A TO-issued COA. The exemption holder may apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of the COA 

granted under this petition. 

23. All aircraft operated in accordance with this exemption must be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordanc~ with 14 

CFR part 45, Subpart C. Markings must be as large as practicable. 

24. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made available to 

the Administrator or any law enforcement official upon request. 

25. The UA must remain clear and give way to all manned aviation operations and activities at all times. 

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

27. All Flight operations must 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. 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 in a manner ensuring the safety of 

nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles, or structures has granted permission for 

operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under 

this exemption. 

28. All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

29. 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 

Page 12 of 14 
(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. 

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the UAS operations 

must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

VII. SUMMARY FOR PUBLICATION IN THE FEDERAL REGISTER 

The rule from which exemption is sought 

HBJ Group, Inc. seeks exemption from the requirements of 14 C.F.R. 61.23(a) & (c); 14 C.F.R. 61.113(a) 

& (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 

91.405(a); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(1) & (2); 14 C.F.R. 417 (a) & (b). 

A brie1 description of the nature of the exemption sought: 

This exemption will permit HBJ Group, Inc. to commercially operate an Unmanned Aircraft System (UAS) 

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

Any additional information, views, or arguments available to support the 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, HBJ'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, HBJ will operate the UAS safely in the NAS, without creating a 

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

VIII. CONCLUSION 

As set forth herein, HBJ 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 UAS 

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 HBJ to safely, efficiently, and economically operate the 

UAS commercially within the NAS. 

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

Reform Act of 2012, Section 333, HBJ respectfully requests that the Administrator grant this Petition for 

an exemption from the requirements of 14 C.F.R. 61.23(a) & (c); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 

91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 

407(a)(1); 14 C.F.R. 409(a)(1) & (2); 14 C.F.R. 417 (a) & (b), and permit HBJ to operate the UAS 

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

States. 

Page 13 of14 
Respectfully submitted, 

HBJ Group, Inc. 

Attachment: Specifications for Blade Chroma 4k 

CUMALANDER ADCOCK, LLC 

Page 14 of14 
BLRIJE' BLH8680 Chroma (with CG03 4K Camera Gimbal and ST1 0+ Personal Ground Station) 

Warranty, Service and Compliance Information I Garantie, Service und RechUiche lnformationen 1 

BLH8t 

Garantie, Reparations et Informations de conformite I Garanzia, Assistenza e lnformazioni sulla conformita 

am 

Limited Warranty 

What this Warranty Covers 

Horizon Hobby, LLC, (Horizon) warrants to the original.purchaser that the product purchased (the "Product") will be free from defects in 

materials and workmanship at the date of purchase. . 

What is Not Covered 

This warranty is not transferable and does not cover Ol cosmetic damage, (ii) damage due to acts of God, accident, misuse, abuse, 

negligence, commercial use, or due to improper use, installation, operation or maintenance, (iii) modification of or to any part of the 

Ov) attempted service by anyone other than a Horizon Hobby authorized service center, (v) Product not purchased from an authorized 

dealer, (vi) Product not compliant with applicable technical regulations, or (vii) use that violates any applicable laws, rules, or regulations. 

OTHER THAN THE EXPRESS WARRANTY ABOVE, HORIZON MAKES NO OTHER WARRANTY OR REPRESENTATION, AND HEREBY 

DISCLAIMS ANY AND ALL IMPLIED WARRANTIES, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF NON-INFRINGEMENT, 

MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. THE PURCHASER ACKNOWLEDGES THAT THEY ALONE HAVE DETERMINED 

THAT THE PRODUCT WILL SUITABLY MEET THE REQUIREMENTS OF THE PURCHASER'S INTENDED USE. 

Purchaser's Remedy 

Horizon's sole obligation and purchaser's sole and exclusive remedy shall be that Horizon will, at its option, either Ol service, or any Product determined by Horizon to be defective. Horizon reserves the right to inspect any and all Product(s) involved in a 

Service or replacement decisions are at the sole discretion of Horizon. Proof of purchase is required for all warranty claims. 

REPLACEMENT AS PROVIDED UNDER THIS WARRANTY IS THE PURCHASER'S SOLE AND EXCLUSIVE REMEDY. 

Limitation of Liability 

HORIZON SHALL NOT BE LIABLE FOR SPECIAL. INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES, LOSS OF PROFITS OR PRODUCTION 

OR COMMERCIAL LOSS IN ANY WAY, REGARDLESS OF WHETHER SUCH CLAIM IS BASED IN CONTRACT. WARRANTY, TORT, NEGLIGENCE, 

STRICT LIABILITY OR ANY OTHER THEORY OF LIABILITY, EVEN IF HORIZON HAS BEEN ADVlSED OF THE POSSIBILITY OF SUCH DAMAGES. 

Further, in no event shall the liability of Horizon exceed the individual price of the Product on which liability is asserted. As Horizon has no control over use, setup, final assembly, modification or misuse, no liability shall be assumed nor accepted for any resulting damage or injury. 

By the act of use, setup or assembly, the u.ser accepts all resulting liability. If you as the purchaser or user are not prepared to accept the 

liability associated with the use of the Product, purchaser is advised to return the Product immediately in new and unused condition to the 

place of purchase. 

law 

These terms are governed 

may also have other rights 

law (without regard to conftict of law warranty gives you specific legal rights, and 

vary from state to state. Horizon reserves the or modify this warranty at any time 

notice. 

WARRANTY SERVICES 

Questions, Assistance, and Services 

Your local hobby store and/or place of 

been started, you must contact your 

France 

China 

Specifications 

Main Rotor Diameter: 253mm 

Length: 325mm 

Height 290mm 

Width: 325mm r"l~.: .............. ; ......... i """ .... 

cannot provide warranty support or service. Once assembly, setup or use of the Product has or Horizon directly. This will enable Horizon to better answer your questions and service 

ST-1 0+ Transmitter Frequency Bands: 

Control Band: 2 .4GHz 

WiFi Downlink Bands: 5.1GHz and 5.8GHz 

CG03 Camera Frequency Bands: I I'll• ,:;1 QIL~'Mn U~, 

any assistance. For questions or assistance. please visit our website a Product Support Inquiry, or call the toll free telephone number referenced in the Warranty and Service Contact lnfnrmotinn 

)'lith a Product Support representative. 

Inspection or Services 

If this Product needs to be inspected or serviced and is compliant in the country you live and use Online Service Request submission process found on our website or call Horizon to obtain a Return Merchandise 

number. Pack the Product securely using a shipping carton. Please note that original boxes may be included, but are not 'designed to 

withstand the rigors of shipping without additional protection. Ship via a carrier that provides tracking and insurance for lost or di 

parcels, as Horizon is not responsible for merchandise until it arrives and is accepted at our facility. An Online Service Request is 

at http://www.horizonhobby.com/content/ _service-cerrter_render-service-center. If you do not have internet access, please contact 

Product Support to otJtain a RMA number along with instructions for submitting your product for service. When calling Horizon, you 

asked to provide your complete name, street address, email address and phone number where you can be reached during business ho 

When sending product into Horizon, please include your RMA number, a list of the included items, and a brief summary of the problem. 

copy of your original sales receipt must be included for warranty consideration. Be sure your name, address, and RMA number are clez 

Written on the outside of the shipping carton. 

NOTICE: Do not ship Li-Po batteries to Horizon.lf you have any issue with a Li-Po battery, please contact the appropriate Horizon Prodt 

Support office. • 

.Warranty Requirements 

For Warranty consideration, you must include your original sales receipt verifying the proof-of-purchase date. Provided 

conditions have been met, your Product will be serviced or replaced free of charge. Service or replacement decisions are at tt 

of Horizon. 

Non-Warranty Service 

Should your service not be covered by warranty, service will be completed and payment will be required without notiflc; 

br estimate of the expense unless the expense exceeds 50% of the retail purchase cost By submitting the item for service y 

'are agreeing to payment of the service without notification. Service estimates are available upon request. You must include this request 

.with your item submitted for service. Non-warranty service estimates will be billed a minimum of* hour of labor. In addition you will bt 

ibilled for return freight. Horizon accepts money orders and cashier's checks, as well as Visa, MasterCard, American Express, a cards. By submitting any item to Horizon for service, you are agreeing to Horizon's Terms and Conditions found on our website 

horizonhobby.com/content/ _service-center _render-service-center. 

ATTENTION: Horizon service is limited to Product compliant in the country of use and ownership. If received, a non-com .Product will not be serviced. Further, the sender will be responsible for. arranging return shipment of the un-servlced Pl'l 

through a carrier of the sender's choice and at the sender's expense. Horizon will hold non-compliant Product for a peri. 

60 days from notification, after which it will be discarded. 

l 

part 15 of the FCC rules. Operation is 

to the following two conditions: (1) This device may not cause 

interference, and (2) this device must accept any interference 

received, including interference that may cause undesired operation. 

'IC Information 

This device complies with Industry Canada license-exempt ASS 

.standard(s). Operation is subject to the following two conditions: 

;Compliance Information for the European Union 

At. CAUTION: Ch. anges or modifications not expressly a1 

~ proved by the party responsible for compliance coulc 

the user's authority to operate the equipment. 

This product contains a radio transmitter with wireless technology 

which has been tested and found to be compliant with the applica 

regulations governing a radio transmitter in the 2.400GHz to 2.4B 

frequency range. 

(1) this device may not cause interference, and (2) this device 

interference, including interference that may caus€ 

operation of the device .. 

·( ( eu compliance statement: 

Horizon Hobby, LLC hereby declares that this product A copy of the EU Declaration of Conformity is available online. i 

is in compliance with the essential reqUirements and http://www.horizonhobby.com/content/support-render-comph< 

other relevant provisions of the A& TIE. EMC and LVD Directives. 

Instructions for disposal of WEEE by users in the European Union ::a This product must not be disposed of with other equipment at the time of disposal will help to conserve natura 

waste. Instead, it is the user's responsibility to resources and ensure that it is recycled in a manner that 

dispose of their waste equipment by handing it over human health and the environment. For more information 

• to a designated collections point for the recycling where you can drop off your waste equipment for recycling, P 

of waste electrical and electro~IC eqUipment. The contact your local city office, your household waste disposal s 

separate collection and recycling of your waste or where you purchased the product.