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# CUMALANDER ADCOCK11P

W. MARK CUMALANDER JAMES S. ADCOCK Ill

February 19, 2016 

### ATTORNEYS

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New JerseyAve., 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 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14C.F.R. Part 21: 14C.F.R. 61.23(a) 

### & (c); 14C.F.R. 61.113(a) 

### & (b); 14C.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); 14C.F.R. 407(a)(1); 14C.F.R. 409(a)(1) & (2); 14 C.F.R. 417 (a) & (b).
Dear Siror Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 {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 allowforcommercial 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 underthe conditions outlined herein oras may be established by the FAA as required by Section 333.
As detailed in this document, the requested exemption would permitthe operation of UAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to access. Approval ofthis exemption would thereby enhance safety and fu!fill.the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "establish requirements forthe safe operation ofsuch aircraft systems in the national airspace." Section 333{c) ofthe Reform Act. The name and address ofthe 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 Chroma4k
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 takeoffand landing {VTOL} Unmanned Aircraft (UA} with a Ground Control Station (GCS}.
The Blade Chroma 4k has a maximum gross weight ofapproximately 45.9 ounces, while having a maximum flying height of400' AGL. The Blade Chroma 4k is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.
The Blade Chroma4kthatwill be operated by HBJ will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, aswell as 14 C.F.R Part 47, AircraftRegistration, and marked in accordancewith 14 C.F.R. Part 45, Identification andRegistration Marking.



### II. STATUTORYAUTHORITY 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 ofthe Act, including UAS, from the requirement that all civil aircraft must have a current airworthiness certificate.
The Administrator may grantan exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section orany sections 44702-44716 ofthis title ifthe Administratorfinds 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} ofthe 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; • Whetherthe UAS operateswithin the visual line ofsight ofthe operator • Whetherthe UAS operates outside ofhighly populated areas and away from close proximity to Airports.
Reform Act §333{a); Ifthe Secretary determines that a UAS "may operate safely in the national airspace system, the Secretaryshall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." 

### ld. §333(c).
HBJ's UAS are multirotorvehicles, weighing 10 orfewer 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 ofsite at all times and will operate only within the sterile area of HBJ's commercial and residential real property sites. Such operations will ensure thatthe UAS will "not create a hazard to users ofthe national airspace system orthe public". 

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# -Given the small size ofthe UAS involved and the area within which they will operate, HBJ's applications falls squarely within the zone ofsafety (an equivalent level ofsafety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also due to the small size ofthe UAS and the low altitudes and limited areas in which the UAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, HBJ respectfully requests that the FAA grantthe 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) ofthe Reform Act. This law directs the Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAAwill 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 ofcommercial and residential real estate, events and civic landscape over certain areas ofthe United States. Additionally, use of UAS will decrease congestion ofthe 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 aircrafttraditionally utilized to obtain aerial imagery. By reducing the amountof manned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa 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 aircraftthat must be handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. Conducting aerial acquisitions with UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels ofair 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 aircraftthat 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 ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, ratherthan 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 orcompletely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the UAS (weighing less than 

### 15 pounds at their maximum gross weight, and with no fuel on board), has less physical potential forcollateral 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 of146,000 pounds with a wingspan ofapproximately42 feet, a length of34 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 ofthe UAS will allow United States based companies, like HBJ, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt newand alternative technology in orderto 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 ofa traditional manned aircraft. By operating the UAS, companies such as HBJ, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller orauthorized 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 OfSection 61.23(a) 

### & (c). Section 61.23(a) & (c), entitled Medicalcertificates: Requirementandduration, subsections (a) and (c) prescribe the following, in relevant part: (a) Operations requiring a medicalcertificate. Except as provided in paragraphs (b) and (c) ofthis section, a person- (1) Must hold a first-class medical certificate: (i) When exercising the pilot-in-command privileges ofan airline transport pilot certificate; {ii) When exercising the second-in-command privileges ofan airline transport pilot certificate in a flag orsupplemental operation inpart 121 ofthis chapter that requires three or more pilots; or (iii) When serving as a required pilot flightcrew member in an operation conducted underpart 121 ofthis chapter ifthe pilot has reached his or her60th birthday. (2) Must hold at least a second class medical certificate when exercising: 

### (i) Second-in-command privileges ofan airline transport pilot certificate inpart 

### 121 ofthis chapter (otherthan operations specified in paragraph (a)(1)(ii) ofthis section); or (ii) Privileges ofa commercial pilot certificate; or (3) Must hold at least a third-class medical certificate- (i) When exercising the privileges ofa private pilot certificate; (ii) When exercising the privileges ofa recreational pilot certificate; (iii) When exercising the privileges ofa student pilot certificate; (iv) When exercising the privileges ofa flight instructor certificate and acting asthe pilot in command; (v) When exercising the privileges ofa flight instructorcertificate and serving as a required pilot flight crewmember; (vi) When taking a practical test in an aircraftfor a recreational pilot, private pilot, commercial pilot, orairline transport pilot certificate, orfor a flight instructor certificate; or (vii) When performing the duties as an Examiner in an aircraftwhen administering a practical test or proficiency check foran airman certificate, rating, orauthorization. (c) Operations requiring eithera medicalcertificate orU.S. driver's license. Page4 ofl4(1) A person must hold and possess either a medical certificate issued underpart 67 ofthis chapter ora U.S. driver's license when- (i) Exercising the privileges ofa student pilot certificate while seeking sport pilot privileges in a light-sport aircraft otherthan a glider or balloon; (ii) Exercising the privileges ofa sport pilot certificate in a light-sport aircraft otherthan a glider or balloon; (iii) Exercising the privileges ofa 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 otherthan a glider or balloon; or (iv) Serving as an Examiner and administering a practical test for the issuance ofa sport pilot certificate in a light-sport aircraft otherthan a glider or balloon. (2) A person using a U.S. driver's license to meetthe requirements ofthis paragraph must- (i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and anyjudicial oradministrative order applying to the operation ofa 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 (ifthe person has applied for a medical certificate); (iii) Not have had his or her most recently issued medical certificate (ifthe person has held a medical certificate) suspended or revoked or most recent Authorization for a Special Issuance ofa Medical Certificate withdrawn; and (iv) Not know or have reason to know ofany 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 OfSection 61.113(a) & (b). Section 61.113, entitled Private pilot privileges and limitations: 

### Pilotin 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) ofan aircraftthat is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan 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 OfSection 91.7(a). Section 91.7, entitled 

### Civilaircraftairworthiness, 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 OfSection 91.119(c). Section 91.119 entitled 

### Minimum safe altitudes: Generalstates the following: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) 

### Overotherthan congestedareas. An altitude of500 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 

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### 5. HBJ Seeks Exemption From The Requirements OfSection 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 orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating-- (1) Below 18,000feet MSL, to-- (i) The current reported altimetersetting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure. 

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

### &(b).
Section 91.151, entitled 

### Fuelrequirements forflight in VFR conditions, subsection (a)(1) & (b), states the following: (a) No person may begin a flight in an airplane underVFR 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 afterthatfor at least 30 minutes; or (b) No person may begin a flight in a rotorcraft underVFR 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 afterthat for at least 20 minutes.


### 7. HBJ Seeks Exemption From The Requirement OfSection 91.405(a).
Section 91.405, entitled 

### Maintenance required, subsection (a), states the following:
Each owner oroperator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.]



### 8. HBJ Seeks Exemption From The Requirements Of Section 91.407(a)(1)
Section 91.407, entitled 

### Operation aftermaintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(1), states the following: (a) No person may operate any aircraftthat has undergone maintenance, preventive maintenance, rebuilding, oralteration unless-- (1) It has been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.] 

### 9. HBJ Seeks Exemption From The Requirements OfSections 91.409(a)(1) and 91.409(a)(2).
Section 91.409, entitled 

### Inspections, subsection (a), states the following:


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### (a) Except as provided in paragraph (c) ofthis 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 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7 ofthis chapter; or {2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 10. HBJ Seeks Exemption From The Requirements OfSections 91.417(a) and 91.417(b). 

### Section 91.417, entitled Maintenance records, 

### subsections (a) and (b), state the following: (a) Exceptfor work performed in accordance with §§ 91.411 and 91.413, each registered owneror operatorshall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 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 ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate numberofthe person approving the aircraftfor return to service. (2) Records containing the following information: (i} 

### The total time in service ofthe airframe, each engine, each propeller, and each rotor. {ii) The current status of life-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since lastoverhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, theAD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§43.9{d) ofthis chapterfor each majoralteration to the airframe and currently installed engines, rotors, propellers, and appliances. {b) The owner or operatorshall retain the following records for the periods prescribed: (1) The records specified in paragraph (a){1) ofthis section shall be retained until the work is repeated or superseded by otherwork orfor 1year afterthe 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 listofdefects furnished to a registered owneror operator under§43.11 ofthis 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). 

### Relieffrom Section 61.23{a) & {b) 

### entitled Medicalcertificates: Requirementandduration, 

### is requested to the extent necessary to allow a PIC holding an airline transport, commercial, private, recreational, or sport Page 7 

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### ·-------------------------------------------------------------------------------------------------

pilot certificate to operate with a valid airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal government. An equivalent level ofsafety 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 ofa motorvehicle are proportional to or higherthan 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 pilotprivileges andlimitations: 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 ofan 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 setforth more fully below, HBJ submits that an equivalent level ofsafety 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 ofthe UAS, conducted by the PIC pursuant to the grant ofthis 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 Civilaircraftairworthiness, 

### is requested to the extent required to allow HBJ to determine thatthe UAS are in airworthy condition priorto 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). Relieffrom 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 ataltitudes higherthan 400' AGL and will maintain minimum separation from all nonparticipating persons, vessels, vehicles, and structures as set forth below.



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### The equivalent level ofsafety will be achieved given the size, weigh_t, and speed ofthe 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. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe 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 atthe ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to airtraffic 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 orfield altitude, before each flight. Considering the limited altitude ofthe 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 ofsafety 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 priorto each flight, and provides the PIC with altitude information of the UA on the heads-up display ofthe GCS.
6. Extent Of Relief HBJ Seeks And The Reason HBJ Seeks Relief From Section 91.151(a)(1) 

### &(b). Relieffrom Section 91.151 (a)(1) & (b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered UAS during daylight hours in visual meteorological conditions (VMC}, undervisual flight rules (VFR), for a total duration of20 minutes. HBJ seeks the requested relief because without an exemption from Section 91.151 (b), the flight time duration ofthe battery powered UAS will severely constrain the practicality ofany aerial video orstill photo flight operations that HBJ proposes to conduct pursuant to this Petition. Significantly, as setforth below, the technical specifications ofthe 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), undervisual flight rules (VFR}, with enough battery powerto fly for a total duration of20 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 ofthe UAS are considered. Relief has been granted for manned aircraftto 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 aircraftwith an airworthiness certificate, HBJ requests relief from these Sections because the UAS does not require airworthiness certificates. As setforth more fully below, the UAS meetthe 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 ofsafety 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 

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### 14can land immediately and will be operating no higherthan 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 ofthe 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 ofexemption are limited to the Blade Chroma 4k when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a new petition or a petition to amend this exemption.
2. Operations for the purpose ofclosed-set motion picture and television filming are not permitted.
3. The UA may not be operated ata speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed orcalibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greaterthan 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 ofsight (VLOS) ofthe PIC atall times. This requires the PIC to be able to use human vision unaided by any device otherthan 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) ofthe 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 ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required ofthe 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 ofexemption, 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. Ifa 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 mustfollow 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 oramendment to this grant of exemption. Ifthe operator determines that any update or revision would affectthe basis upon which the Page 

### 10

### of 14FAA granted this exemption, then the operator must petition foran amendmentto its grantofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8. Any UASthat has undergone maintenance oralterations that affectthe UAS operation orflight characteristics, e.g., replacement ofa flight critical component, must undergo a functional testflight prior to conducting further operations underthis exemption. Functional testflights 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 mannerso 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. Priorto 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 mustaccount for all potential discrepancies, e.g., inoperable components, items, orequipment. Ifthe inspection reveals a condition that affects the safe operation ofthe 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 mustfollow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated underthis exemption must comply with all manufacturersafety bulletins.
13. Underthis grantofexemption, a PIC must hold either an airline transport, commercial, private, recreational, orsport pilot certificate. The PIC mustalso hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the DistrictofColumbia, Puerto Rico, a territory, a possession, orthe Federal government. The PIC mustalso meetthe 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 unlessthe PIC demonstrates the ability to safely operate the UAS in a manner consistentwith howthe UAS will be operated underthis 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 consistentwith 14 CFR 

### § 61.51 (b). Flights forthe purposes oftraining 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 consistentwith howthe UAS will be operated underthis exemption are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons notessential for flight operations are considered nonparticipants, and the PIC mustoperate the UAwith 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 undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR} are notauthorized.
16. The UAS may not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAAAirport/Facility Directory (AFD) orfor airports not denoted with an ARP, the centerofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letterofagreement with that airport's management is obtained orotherwise permitted by a COA issued to the exemption holder. The letter ofagreementwith the airport management must be made available to theAdministrator orany 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 orwhen visibility is lessthan 3 statute miles from the PIC.



### Page 11 of1418. 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 ofthe earth and visible from at least one mile. This requirement for pennants orstreamers is not applicable when operating exclusively below the top ofand within 250 feet ofany structure, so long as the UAS operation does not obscure the lighting ofthe structure.
19. Ifthe UAS loses communications or loses its GPS signal, the UAS must return to a pre-determined location within the private orcontrolled-access property.
20. The PIC must abortthe flight in the event of unpredicted obstacles oremergencies.
21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available powerfor the UA to conduct the intended operation and to operate afterthat for at least 5 minutes orwith the reserve power recommended by the manufacturer ifgreater.
22. Air Traffic Organization (ATO) Certificate ofWaiver orAuthorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted underthe terms ofthe COA granted underthis petition.
23. All aircraft operated in accordancewith this exemption must be identified by serial number, registered in accordance with 14 CFR part47, 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 operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 

### §§ 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administrator orany 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 orvehicle.
27. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers orstructures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
b. The owner/controller ofany vessels, vehicles, orstructures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does not present an undue hazard.
The PIC, VO, operatortrainees oressential persons are not considered nonparticipating persons under this exemption.
28. All operations shall be conducted over private orcontrolled-access property with permission from the property owner/controller orauthorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
29. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe 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 ofexemption, 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 ofthe nature ofthe exemption sought: 

### This exemption willpermit HBJ Group, Inc. to commerciallyoperate an UnmannedAircraftSystem (UAS) forthe purpose ofconducting aerial video andphotographyovercertain areas ofthe 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 of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, HBJ's request for exemption may be granted pursuantto 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 ofthe NAS orthe 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 ofthe NAS, orthe public, orotherwise 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 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe UAS commercially, without an airworthiness certificate, forthe limited purpose of conducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAAAdministratorwill be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe 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 of2012, 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 ofthe United States.

Page 

### 13 of14Respectfully submitted, HBJ Group, Inc.

Attachment: Specifications for Blade Chroma 4k CUMALANDER ADCOCK, LLC



### Page 14of14

# BLRIJE' BLH8680 Chroma (with CG03 4K Camera Gimbal and ST10+ Personal Ground Station) Warranty, Service and Compliance Information 

### I Garantie,Service und RechUiche lnformationen 

### 1 

## BLH8t Garantie, Reparations

### etInformations deconformite I 

### Garanzia,Assistenza elnformazioni sullaconformita 

# am

LimitedWarranty WhatthisWarranty Covers Horizon Hobby, LLC, (Horizon) warrants to the original.purchaserthatthe product purchased (the "Product") will be free from defects in materials and workmanship atthe date of purchase.

. What is NotCovered This warranty is nottransferable and does notcoverOl cosmetic damage, (ii) damage due to acts ofGod, accident, misuse, abuse, negligence, commercial use, ordue to improper use, installation, operation or maintenance, (iii) modificationoforto any part ofthe Ov) attempted service by anyone otherthan aHorizon Hobby authorized service center, (v) Product not purchased from an authorized dealer, (vi) Product notcompliantwith applicable technical regulations, or (vii) usethatviolates any applicable laws, rules, or regulations. OTHERTHANTHE EXPRESSWARRANTYABOVE, HORIZON MAKES NO OTHERWARRANTY OR REPRESENTATION,AND HEREBY DISCLAIMSANYAND ALL IMPLIEDWARRANTIES, INCLUDING,WITHOUT LIMITATION,THE IMPLIEDWARRANTIES OF NON-INFRINGEMENT, MERCHANTABILITYAND FITNESS FOR APARTICULAR PURPOSE.THE PURCHASERACKNOWLEDGESTHATTHEYALONE HAVE DETERMINED THATTHE PRODUCTWILL SUITABLY MEETTHE REQUIREMENTS OFTHE 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 Productdetermined by Horizon to be defective. Horizon reserves the right to inspectanyand all Product(s) involved in a Service or replacement decisions are atthe sole discretion of Horizon. Proofof purchase is required for all warranty claims. REPLACEMENTAS PROVIDED UNDERTHIS WARRANTY ISTHE PURCHASER'S SOLEAND 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 INANYWAY, REGARDLESS OFWHETHER SUCH CLAIM IS BASED IN CONTRACT. WARRANTY,TORT, NEGLIGENCE, STRICT LIABILITY ORANY OTHERTHEORYOF LIABILITY, EVEN IF HORIZON HAS BEENADVlSED OFTHE POSSIBILITY OF SUCH DAMAGES. Further, in no eventshall the liabilityof Horizon exceed the individual price ofthe Producton which liability is asserted.As Horizon has no control over use, setup,final assembly, modification or misuse, no liability shall be assumed noraccepted for any resulting damage or injury. Bythe actof use, setup or assembly, the u.seraccepts all resulting liability. Ifyou as the purchaseror userare not prepared to acceptthe liability associated with the use ofthe Product, purchaser is advisedto 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 givesyou specific legal rights, and or modify this warranty at any time varyfrom state to state. Horizon reserves the notice. WARRANTYSERVICES Questions,Assistance, and Services Your local hobbystore and/or place of been started, you mustcontactyour

France
China 

### Specifications Main Rotor Diameter: 253mm Length: 325mm Height 290mm Width: 325mm**r"l~.:**..............;
......... i """

.... cannot provide warrantysupport orservice. Once assembly, setup or use ofthe Product has or Horizon directly.Thiswill enable Horizon to betteransweryourquestions and service

ST-10+TransmitterFrequency Bands:

Control Band: 2.4GHz WiFi Downlink Bands: 5.1GHz and 5.8GHz CG03 Camera Frequency Bands: I I'll• ,:;1**QIL~'Mn U~,**  anyassistance. Forquestions or assistance. pleasevisit ourwebsite aProduct Support Inquiry, orcall the toll free telephone number referenced in the Warranty and Service Contact lnfnrmotinn )'lith aProduct Supportrepresentative. Inspection orServices Ifthis Product needs to be inspected orserviced and is compliant in the countryyou live and use Online Service Request submission processfound on ourwebsite orcall Horizon to obtain aReturn Merchandise number. Packthe Productsecurely using ashipping carton. Please note that original boxes may be included, but are not'designedto withstand the rigors ofshipping without additional protection. Ship via acarrierthat providestracking and insurance for lost ordi parcels, as Horizon is not responsible for merchandise until itarrives and is accepted atourfacility. An Online Service Request is 

## at http://www.horizonhobby.com/content/ _service-cerrter_render-service-center. Ifyou do not have internetaccess, please contact Product Supportto otJtain aRMAnumberalong with instructionsfor submitting your productfor service. When calling Horizon, you asked to provide yourcomplete name, streetaddress, email address and phone numberwhere you can be reached during business ho When sending product into Horizon, please includeyour RMA number, alistofthe included items, and abriefsummaryofthe problem. copy ofyouroriginal sales receipt must be included forwarranty consideration. Be sureyour name, address, and RMA numberare clez Written on the outside of the shipping carton. NOTICE: Do notship Li-Po batteriesto Horizon.lfyou have any issue with aLi-Po battery, please contact the appropriate Horizon Prodt Supportoffice. • .Warranty Requirements ForWarranty consideration,you mustincludeyouroriginal sales receipt verifying the proof-of-purchase date. Provided conditions have been met,your Productwill be serviced or replaced free ofcharge. Service or replacementdecisions are attt of Horizon. Non-WarrantyService Should yourservice not be covered bywarranty, servicewill be completed and paymentwill be required without notiflc; brestimate ofthe expense unlessthe expense exceeds50% ofthe retail purchase cost By submitting the item forservice y 'are agreeing to payment ofthe service without notification. Service estimates are available upon request.You must includethis request .with your item submitted for service. Non-warrantyservice estimates will be billed aminimum of*hourof labor. In additionyou will bt ibilledforreturn freight. Horizon accepts moneyorders and cashier's checks, as well asVisa, MasterCard,American Express, a cards. By submitting any item to Horizon for service,you are agreeing to Horizon'sTerms and Conditionsfound on ourwebsite horizonhobby.com/content/ _service-center _render-service-center. ATTENTION: Horizon service is limitedto Productcompliant in the countryofuse and ownership. If received, anon-com .Productwill not be serviced. Further,the senderwill be responsible for.arranging return shipmentofthe un-servlced Pl'l through acarrier ofthe sender'schoice and atthesender's expense. Horizonwill hold non-compliant Productfor aperi. 60 daysfrom notification,afterwhich itwill be discarded.

l part 15ofthe FCC rules. Operation is to the following twoconditions: (1)Thisdevice may notcause interference, and (2)this device mustacceptany interference received, including interferencethat maycause undesired operation.



### 'ICInformation This device complies with Industry Canada license-exempt ASS .standard(s). Operation is subjectto the following two conditions: 

### ;ComplianceInformationfortheEuropeanUnion 

### At. CAUTION: Ch.anges or modifications notexpresslya1**~** proved bythe party responsible for compliance coulc the user's authorityto operatethe equipment. Thisproductcontains aradiotransmitterwith wireless technology which hasbeentested andfoundtobecompliantwiththe applica regulations governing aradiotransmitter inthe 2.400GHzto 2.4B frequency range. (1) this device may notcause interference, and (2)this device interference, including interference that maycaus€ operation ofthe device

.. 

## ·( ( eu compliance statement: Horizon Hobby, LLC herebydeclares thatthis product Acopy ofthe 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. Instructionsfordisposal ofWEEE by users in the European Union 

# ::a

This product must not be disposed of with other equipment at the time ofdisposal will help to conserve natura waste. Instead, it is the user's responsibility to resources and ensure that it is recycled in amannerthat dispose oftheirwaste equipmentby handing itover human health andthe environment. For more information • to adesignated collections pointfor the recycling where you can drop offyourwaste equipmentfor recycling, P of waste electrical and**electro~IC** eqUipment.The contactyour local city office,your householdwaste disposal s separate collection and recycling ofyourwaste orwhere you purchased the product.