Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Brad Blosser

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 17, 2016

Brad Blosser

10069 County Road 16

Middlebury, IN 46540

brad@goshenhealth.com

574.238.1087
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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Table of Contents

GLOSSARY OF ABBREVIATIONS ................................................................................ 3

INTRODUCTION AND INTERESTS OF THE PETITIONER........................................ 4

Executive Summary............................................................................................................ 4

Expeditious Summary Grant Approval Request............................................................. 4

Description of Type, Make and Models of sUAV/UAS Requested:.......................... 5

Commercial (Mission, Operation) Purpose: ............................................................... 7

Regulations from which the Exemption Relief is requested:...................................... 8

The name and address of the Petitioner:..................................................................... 9

Background..................................................................................................................... 9

Commitment to Safety ................................................................................................ 9

Expertise & Experience .............................................Error! Bookmark not defined.

The Exemption Request.................................................................................................... 10

Operator Requirements................................................................................................. 11

Aircraft and Equivalent Level of Safety ....................................................................... 14

Specific Uses Public Benefits....................................................................................... 18

Equivalent Level of Safety............................................................................................ 19

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. ..................................................... 20

14 C.F.R. §91.119: Minimum safe altitudes............................................................. 20

14 C.F.R. §91.121 Altimeter Settings....................................................................... 21

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ............... 21

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections ................................................................................................................ 22

Federal Register Publication............................................................................................. 22

Privacy and National Security .......................................................................................... 23

Summary........................................................................................................................... 23
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 

333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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INTRODUCTION AND INTERESTS OF THE PETITIONER

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, Brad Blosser Operator of Small Unmanned 

Aircraft Systems (“sUAS’s”) equipped to offer on-demand commercial UAS operations 

for a host of industries and applications and to perform the purposes listed below, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its sUAVs/UAS, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA in 

an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the operation of a 

UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) 

would provide safety enhancements in the fields in which it will operate, which now 

depend upon conventional aircraft or humans climbing high on dangerous structures, 

walking in insect laden swamps, and working adjacent to treacherous infrastructure.

Approval of this exemption would thereby enhance safety and fulfill 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 system.” Section 

333(c) of the Reform Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this application. 

Petitioner has provided in a confidential document attachment labeled as petitioner 

proprietary information, specific exemption numbers whereby the FAA has already 

granted a previous exemption similar or identical to each and every request, herein. 

For the FAA’s benefit, Petitioner’s Consultant, Brad Blosser, has researched, categorized 

and arranged all 631 exemptions granted as of June 23, 2015 into a usable searchable 

database, based upon the following criteria: date submitted, date grant issued, time to 

petition grant, petitioner, petitioner’s state, exemption number, sUAV equipment type, 

grant purpose (mission/operation), along with other supporting data. 

																																																							

1		Brad	Blosser relies	upon	the	following	exemptions	where	specific	reference	to	an	

exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080,	11109	through	

11112,	11114,	11213,	11062	and	as	recent	as	11857.
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Petitioner has identified four previous approved exemptions for each of the Petitioners 

FAA submission requests:

 Commercial (mission/operation) purposes;

 Type of sUAVs (UAS);

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAVs makes and 

models as follows: 

1. 3D Robotics Aero – M 101. HexaCrafter HQ-850

2. 3D Robotics Fixed Wing 102. HexaCrafter HQ-1150

3. 3D Robotics Iris 103. HobbyKing Bixler 2

4. 3D Robotics Solo 104. Hoverfly – Livesky

5. 3D Robotics X8 105. HSE UAV – DRASS Q1000

6. 3D Robotics X8+ 106. Hubsan – X4 Microdrone

7. 3D Robotics X8-M 107. Inova Drone – Inova One

8. 3D Robotics Y6 108. Intuitive Aerial – Aerigon IAH 3

9. AeroCamera - SR 15 109. Kespry Drone Systems

10. Aerial Pixels - Fx8Pro Elite 110. KongCopter FQ700

11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump-15

12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump-20

13. AeroLogix – Geostar 113. Latitude HQ-20

14. Aeronavics SkyJib-8 Ti-QR 114. Latitude HQ-40

15. Aeronavics X4 Titanium 115. Latitude HQ-60

16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ

17. AeroVironment Puma 117. Leptron – Avenger

18. AeroVironment Qube 118. Lockheed Martin – Desert Hawk III

19. AeroVironment Shrike 119. Lockheed Martin – Indago

20. Aeryon Scout 120. Mavinci – Sirius Pro

21. Aeryon Sky Ranger 121. Microdrones MD4

22. AgEagle 122. Microdrones – MD4-200

23. Agribotix Enduro Quad 123. Microdrones – MD4-1000

24. Agribotix Hornet Drone 124. Microdrones – MD4-3000

25. Aibotix X – 6 125. MikroKopter – ARF OctoXL

26. AirCover ORT-825 126. MLB- Super-Bat UAV

27. AirCover QR-425 127. Multirotor G4

28. Airfield – Extreme Surfer Power Glider 128. MultiRotor – G4 Blackbird V2

29. AirRobot AR 100-B 129. MultiRotor – G4 Skycrane

30. AirRobot AR 100-C 130. Parrot – AR Drone 2

31. AirRobot AR 180 131. ParkZone – Radian RTF

32. AirRobot AR 200 132. Parrot – Bebop

33. Airwing UAV – Talon 133. PrecisionHawk – Lancaster
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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34. Align M690L Multicopter 134. Precision Drone – PaceSetter

35. Altavian Nova F6500 135. Prioria – Hex

36. Altus UAS Delta X-4 136. Prioria – Hex Mini

37. Altus UAS Delta X-8 137. Prioria – Maveric UAS

38. American Drones – Eagle 550 138. ProJet – RC Drone

39. American Drones – Falcon 450 139. ProJet – RQ-11 Raven

40. American Drones – Nighthawk 550 140. Pulse Aerospace – Scout B1-100

41. American Drones – Phoenix 650 141. Pulse Aerospace – Vapor

42. Arch Aerial – Atlas-1 142. RangeVideo – Jet

43. Arch Aerial – OCTO 143. RF70 Aircraft

44. ARRIS – M680 Hexa 144. RIEGL RiCopter

45. Ascending Technologies – AscTec 

Falcon 8 145. Ritewing - Drak

46. Birdseyeview – FireFly 6 146. Ritewing - Spade 70"

47. Blade 350 QX3 147. Ritewing - Zephyr 3 Spade

48. Blade Chroma 148. SenseFly eBee

49. Bormatec – Maja UAV 149. SenseFly – eXom

50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace – Magpie

51. CarbonCore – Cortex ARTF 151. Skycatch

52. CineStar – 6 MK Heavy Lift RTF 152. Skyhunter

53. Cinestar 8 Octo 153. Skywalker X-8

54. Cyber Technology – Cyber Quad 154. Splash Drone

55. Delair-Tech – DT – 18 155. SteadiDrone – Flare

56. DJI-F450 156. SteadiDrone – Mavrik

57. DJI-F550 157. SteadiDrone – Vader

58. DJI - Inspire 1 158. Swift Radioplanes – Lynx

59. DJI – Matrice 100 159. T-Rex 800E Pro

60. DJI - Phantom 2 160. Tactical Robotics – InstantEye Mk2

61. DJI - Phantom 3 161. Tarot – 450

62. DJI – Spreading Wings S800 162. Tarot – 690

63. DJI – Spreading Wings S900 163. Tarot – 960

64. DJI – Spreading Wings S1000 164. Tarot- 680 Pro

65. DJI – Spreading Wings S1000+ 165. Tarot – T18

66. DraganFlyer - Commander 166. Tarot – T810

67. DraganFlyer - Guardian 167. Tayzu Robotics – Quadra

68. DraganFlyer - X4-ES 168. Tayzu Robotics – Titan X8

69. DraganFlyer - X4-P 169. TBS Caipirinha V2

70. DraganFlyer – X6 170. Trimble UX5

71. Event 38 - E384 171. Trimble UX5-HP

72. Finwing – Penguin 1720 172. Trimble ZX5

73. FlyPro PX400 173. Turbo Ace – Cinewing 6

74. FoxTech FPV – D130 X8 V2 174. Turbo Ace – Matrix G

75. FoxTech FPV – K130 V3 175. Turbo Ace – Matrix I

76. Freefly – Alta 176. Turbo Ace – Matrix E
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77. GB-250z 177. Turbo Ace – Matrix S

78. GB-450z 178. Turnigy Talon Quad

79. Germap – G47-X8 179. UAV Solutions – Phoenix 30

80. Germap – G65-Y6 180. UAV Solutions – Phoenix 60

81. Germap – G180 181. UAV Solutions – Phoenix 60LE

82. Germap – G212

182. Vanguard Defense Industries 

ShadowHawk

83. Germap – SmartOneC 183. Viking UAS – Patriot X4

84. Gryphon Dynamics – Dodeca 184. Viking UAS – Patriot X8

85. Gryphon Dynamics – Hexa 185. Viking UAS – Ranger EX

86. Gryphon Dynamics – Octo 186. Viking UAS – VikingOne

87. Gryphon Dynamics – X8 187. Viking UAS - VK X6 Model 800

88. Gryphon Dynamics – Y6 188. Volt Aerial Robotics - Venture

89. Hawkeye 1700 189. Vulcan – Black Widow

90. Hawk UAS – Silex Systems F15 190. Vulcan – Mantis

91. Helipal - Storm Drone AntiGravity 191. Vulcan – Raven

92. Helipal - Storm Drone 4 192. Walkera – QR X350PRO

93. Helipal - Storm Drone 4 Mini 193. Walkera – QR X800

94. Helipal - Storm Drone 4 Naza 194. Walkera – QR X900

95. Helipal - Storm Drone 6 Naza 195. Walkera – Scout X4

96. Helipal - Storm Drone 8 Naza V2 196. Walkera – Tali H500

97. HexaCrafter HC-650 197. Walkera – Voyager 3

98. HexaCrafter HC-800 198. Yamaha RMAX

99. HexaCrafter HC-1100 199. Yuneec - Tornado H920

100. HexaCrafter HO-1250 200. Yuneec - Typhoon Q500

201. Shotover – U1

Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment.

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge 

Inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection, photography and videography of residential and commercial 

real estate, weddings, aerial inspection, photography and videography of utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site inspection 

and monitoring, public entity support operations, Aerial imaging for safety, monitoring 

and comparing work efforts and completion percentages, and security of controlled 

environment of various sites, aerial video and live video feed to assist with search and 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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rescue operations under the authority and support of local authority officials, aerial video 

and photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering, training to persons individually or 

belonging to both private and public organizations to increase awareness and improve 

safety for current and future UAS operations within the NAS, special events: including 

high schools, colleges, professional sports, open air events and fairs, research, risk 

management and assessment, surface mining, closed set filming2, disaster and catastrophe 

events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

																																																							
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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The name and address of the Petitioner:

Brad Blosser

10069 County Road 16

Middlebury, IN 46540

brad@goshenhealth.com

574.238.1087

Please direct any question or comment regarding this petition to Petitioners Consultant: 

Brad Blosser

10069 County Road 16

Middlebury, IN 46540

brad@goshenhealth.com

574.238.1087

Background

The Petitioner, Brad Blosser is a highly accomplished, capable, experienced and trusted 

professional.

Commitment to Safety

As part of its commitment to safety and innovation, Brad Blosser is asking for this

exemption in part, to reduce the risk of injury to its employees and contractors who 

participate in the proposed activities the petitioner requests, including but not limited to 

damage to agriculture, natural habitat, buildings and other structures within the United

States. 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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The Exemption Request

Brad Blosser proposes the use of the sUAVs will be for capture of high resolution 

imagery and video of residential or commercial applications and purposes to a level of 

quality that allows the Petitioner to use the imagery to identify, record, memorialize 

events and objects according to the purposes noted. 

The imagery and video will be used to identify the condition of landscapes, agriculture, 

events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, 

utility-power generation system inspections and patrolling, aerial inspection, photography

and videography of residential and commercial real estate, weddings, aerial inspection, 

photography and videography of utility infrastructure including but not limited to 

electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, 

filmmaking, cinematography, and videography, precision agriculture with on board 

sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support operations, 

aerial imaging for safety, monitoring and comparing work efforts and completion 

percentages, and security of controlled environment of various sites, aerial video and live 

video feed to assist with search and rescue operations under the authority and support of 

local authority officials, aerial video and photography for public and private use 

including television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public organizations to 

increase awareness and improve safety for current and future UAS operations within the 

NAS, special events: including high schools, colleges, professional sports, open air 

events and fairs research, risk management and assessment, motion picture production, 

surface mining, closed set filming, disaster and catastrophe events.

The UAS will be operated by a Brad Blosser and or contracting operators on occasion to 

capture high-resolution imagery/video of large structures (wide and tall) such as 

warehouses, high rise buildings, bridges, and construction sites, as well as “bird’s eye” 

views of fire and explosion sites. Given the small size of the sUAVs involved, no more 

than 55 lbs., majority of the speed of operation be between 5-15 mph and the restricted 

environment within which they will operate, the Petitioner falls squarely within that zone 

of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 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 national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UASs do not create a hazard to users of the NAS or 

the public or pose a threat to national security in light of the following:

 The UAS’ size, weight, speed, and operational capability;
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “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.” Id. §333(c) (emphasis 

added).

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

This statutory authority, by its terms, includes exempting civil aircraft, as the term is 

defined under §40101 of the Act: The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any of 

sections 44702-44716 of this title if the Administrator finds the exemption is in the public 

interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of 

commercial operation of aircraft without an FAA issued pilot’s license.

Brad Blosser in filing this application is requesting that the FAA combine the grant of the 

Section 333 exemption with a standard Certificate of Operation (COA) that will allow

commercial operations of its Brad Blosser’s sUAV without the necessity of filing for a 

COA for each flight, unless such flight is to be conducted in an area not approved in the 

exemption. Compliance with the conditions agreed to herein and that may be imposed by

the FAA, as set forth in prior Section 333 exemptions, provide the separation needed 

from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer

than 5 nautical miles of the geographic center of an airport as denoted on a current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management 

is obtained, Brad Blosser requests that operations over congested or densely populated 

areas be allowed. The new sUAVs do have GPS geo-fencing, it will operate at a very low 

altitude, within confined areas, at low speed and weighs no more than 55 lbs. Such 

operations will only be under-taken with the approval of the land or home owner, as set 

forth herein, and will comply with the requirements that operations be no closer than 500 

feet to the adjacent building unless the land owner has provided permission, and the 

Operator has made a safety assessment of the risk from such operations. 

Operator Requirements

Given the sUAV proposed by Brad Blosser, Operators should not be required to hold a

private pilot license. Brad Blosser believes that 1) the operator, instead of understanding 

how to operate a passenger carrying aircraft, should have knowledge and experience that 

enables the safe operation of a small, remotely piloted sUAV should understand airspace 

restrictions and know how to ensure separation from other aircraft as well as nonparticipants and property; 2) the sUAV has built-in technical capabilities that limit the 

potential for unsafe operation and 3) there are other security screening mechanisms 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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already in existence that Brad Blosser will utilize to ensure the operators are acting 

consistently with national security interests. 

Given the sUAV safety features outlined below, Brad Blosser proposes that its operations 

under this Exemption request should not be required to hold a commercial or private pilot 

certification. Instead, Operators should be required to: have completed Brad Blosser’s 

training program for operation of the UAS.

Brad Blosser notes that 1) the FAA has found that safety factors permitted operation of 

sUAVs by Operators with these qualifications in the case of operations pursuant to public 

COAs when the mandatory operating conditions specified above were present; and 2) that 

the Notice of Proposed Rulemaking entitled Operation and Certification of Small 

Unmanned Aircraft Systems, 80 F.R. 9544 (February 23, 2015) (“NPRM”), does not 

require the operator to hold a private pilot license or a third class medical.

Advanced sUAVs have a navigation and control system and auto-pilot that allows it to

execute very accurate pre-programed flights. Flights are pre-programmed with GPS 

waypoint to establish perimeters beyond which the aircraft will not operate. Flights under 

auto-pilot are not directed by positive manual input, but through pre-programmed flight 

parameters that are executed by the auto-pilot. In the case of unplanned events, the 

Operator inputs preprogrammed evasive maneuvers from the control unit, and the 

autopilot executes those maneuvers. Pre-programmed Operator interventions include: 

initiation of holding at present position; suspension of mission; fly back to launch point; 

abort mission and land immediately; and emergency power cut off and land (flight 

termination system). Additional automated safety functions and safety enhancing features 

of the advanced sUAVs may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate

landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down in 

flight in the event of a loss of control or un-commanded deviation from the flight 

path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) 

nor above 200 feet above the structure (imaging altitude) or a maximum of 400 

feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has determined in 

Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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requirements for private pilot knowledge and the knowledge required for a commercial 

pilot, that knowledge associated with a private pilot license, and therefore private pilot 

ground school, was sufficient to allow private pilots to operate sUAVs under those 

exemptions. 

A handheld radio controller controls the sUAV and the vehicle is operated within the line 

of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 

(private flight proficiency), to the extent they are relevant to UAS operations, can be 

taught in the training proposed herein. As a review of the requirements of part 61.127 and 

107 demonstrate, the issues presented as they relate to a 55-pound aircraft, operating at 

less than 30 mph during filming operations are those taught in flight training with the 

particular UAS and not gained from accumulating flight hours in a fixed wing or 

rotorcraft gas or jet A powered aircraft completing cross country flights and take offs and 

landings at controlled and uncontrolled airports.

As to national security review of pilots, each of Brad Blosser’s pilots/operators will 

obtain internally provided certified training (Ground and Practical) from Brad Blosser to 

operate the sUAV. This review and certification could reasonably vet the Operators 

against any known terrorist or no fly listings that are relevant and publically available.

Brad Blosser additionally asks that the exemption be issued without the requirement for a 

visual observer. As set forth herein, an equivalent level of safety is provided by the size,

speed and control capabilities of the aircraft, as well as the operational procedures that 

will be applicable to all flight hereunder. These obviate the need for the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will 

walk and follow the aircraft around the inspection area so that while it is flying its preprogramed and at times, manual flight path, the UAS will always be directly in his or her 

line of sight. The Operator will not be distracted by viewing the pictures taken during the 

flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the 

flight of the UAS over the structure and intervene to address flight path deviations or 

other issues that arise during the flight. The functions that an observer performs where 

the aircraft is flown at long distances from the launch area will not be necessary as the

Operator will always have the aircraft in his or her direct sight. The observer also will not 

be necessary because the Operator will conduct a pre-flight inspection of the area, will 

and if needed, cordon off the area and will perform frequent visual scans of the area 

while the vehicle is operating.

Brad Blosser again notes that the NPRM does not require the use of a visual observer. 

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,

reduction in environmental impacts, including reduced emissions associated with 

allowing battery powered sUAVs for these functions instead of turbine or gas power 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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aircraft/rotorcraft and operations with pilots having at least a private pilot license, the 

grant of the requested exemptions is in the public interest. 3

Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the operations conducted with conventional aircraft or with humans 

climbing up and around structures. These conditions are drawn from Exemptions 11136, 

11138, 11172, 11174 and 11177, 11062, 11109, 11112, and 11213 and as recent as 

11857.

These limitations and conditions to which Brad Blosser (referred to as “Operator”) agrees 

to be bound when conducting commercial operations under an FAA issued exemption

include:

1) Operations authorized by this grant of exemption are limited to the 

aircraft described in the Operator’s manual, which is a multi-rotor

weighing up to 55 pounds. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30

mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet 

above ground level (AGL), as indicated by the procedures specified 

in the Operator’s manual. All altitudes reported to ATC must be in 

feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the 

Aircraft Operator at all times. This requires the Aircraft Operator to 

be able to use human vision unaided by any device other than 

corrective lenses.

																																																							

3 Should	the	FAA	determine	that	it	cannot	grant	such	an	exemption	for	operations	

without	 a	FAA	licensed	private	pilot,	despite	the	 showing	made	herein,	under	the	

statutory	authority	the	FAA	already	has,	Brad	Blosser	will	operate	its	aircraft	with	

pilots	 holding	 at	 least	 a	 private	 pilot	 certificate	 issued	 by	the	 FAA.	 In	that	 event,	

Brad	 Blosser	 requests	 that	 the	 exemption	 be	 granted	 with	 conditions	 similar	 to	

those	contained	in	numbered	paragraphs	14-15	in	Exemption	11136
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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5) The Exemption Holder’s Manuals must be amended to include all 

conditions and limitations required by the FAA. The Manuals must 

be maintained and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations in the 

exemption and the procedures outlined in the Exemption Holder’s 

Operator’s manual, the conditions and limitations in the exemption 

take precedence and must be followed. Otherwise, the Aircraft

Operator must follow the procedures as outlined in its Aircraft’s 

manual. The Exemption Holder may update or revise its Manuals. It

is the Exemption Holder’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon 

request. The Exemption Holder must also present updated and 

revised documents if it petitions for an extension or amendment of 

this exemption. If the Exemption Holder determines that any update 

or revision would affect the basis upon which the FAA granted this

exemption, then the Exemption Holder must petition for amendment 

to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to 

ensure it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been 

performed, and the UAS is found to be in a condition for safe flight. 

The Ground Control Station must be included in the preflight

inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

7) 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 in 

accordance with the Exemption Holder’s Manuals. The Aircraft 

Operator who conducts the functional test flight must make an entry

in the UAS aircraft records of the flight. The requirements and

procedures for a functional test flight and aircraft record entry must 

be added to the Exemption Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, 

and life limit requirements, with particular attention to flight critical 

components that may not be addressed in the manufacturer’s 

manuals.

9) The Exemption Holder must carry out its maintenance, inspections, 

and record keeping requirements in accordance with the Operator’s 

Manuals. Maintenance, inspection, and alterations must be noted in 

the aircraft logbook, including total flight hours, description of work 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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accomplished, and the signature of the authorized technician 

returning the UAS to service.

10) The authorized technicians must receive and document training 

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record 

entry in the UAS logbook or equivalent document of the corrective 

action taken against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have 

logged at least 25 hours of total time as a UA rotorcraft pilot and at 

least ten hours logged as a UA pilot with a similar UA type and 5 

hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA 

must return to a pre-determined location within the private or 

controlled-access property and land or be recovered in accordance 

with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of 

unpredicted obstacles or emergencies, including unauthorized people 

entering the flight area, in accordance with the Exemption Holder’s 

Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight 

unless (considering wind and forecast weather conditions) there is 

enough power to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 10 

minutes.

17) All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 CFR 

part 47, and have identification (N- Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings must be as large as 

practicable.

18) Before conducting operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be 

available to the Operator at the Ground Control Station of the UAS 

any time the aircraft is operating. These documents must be made 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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available to the Administrator or any law enforcement official upon 

request. 

20) The UA must remain clear and yield the right of way to all other 

manned operations and activities at all times (including, but not 

limited to, ultra-light vehicles, parachute activities, parasailing 

activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any 

moving device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14 

CFR 1.1.

23) All operations must be conducted under visual meteorological 

conditions (VMC). The UA may not be operated less than 500 feet 

below or less than 2,000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the Operator.

24) During operations the UA may not operate within 5 nautical miles of 

the geographic center of an airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM, if as required by the Operator’s COA. 

The letter of agreement with the airport management must be made 

available to the Administrator upon request.

25) The UA may not be operated over congested or densely populated 

areas unless the conditions set for in #26 are satisfied. These 

populated areas include but are not limited to the yellow areas 

depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 

However, aeronautical charts may not reflect pertinent local 

information. Ultimately, it is the Operator’s responsibility to 

maintain the minimum safe altitudes required by § 91.119 (d) (1).

26) 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 debris in the event of an 

accident. The Aircraft Operator must ensure that 

nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such 

protection and are within 30 feet of the UA, flight operations 

must cease immediately and/or;
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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b. The aircraft is operated near vessels, vehicles or structures 

where the land owner/controller has granted permission and/or 

the Aircraft Operator has made a safety assessment of the risk 

of operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an undue 

hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or 

authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be 

conducted.

28) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by 

the applicable COA must be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

Specific Uses Public Benefits 

Brad Blosser proposes use of its sUAV provided equivalent or augmented levels of safety 

for each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting the 

roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, 

mosquito and insect control are now conducted by either a person wading through 

swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or 

otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must climb on 

the roofs or require the use of aircraft that are orders of magnitude greater in size than the 

sUAV. Either method, manual inspection or large conventional aircraft, results in

increased risk of injury due to personnel falling off roofs or ladders, carrying heavy 

ladders and dealing with confined and dangerous spaces, or increased risk from low 

altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage 

from storms or other disasters, such as earthquakes or fires. Such flights are, of course, 

significantly more expensive than those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but those 

who are along the path of flight associated with the arrival and departure of the 

conventional aircraft at the inspection site because the aircraft must be flown to and from

the site. By contrast, the sUAV is carried to the site and transits no other property. 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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Conventional aircraft carry flammable fuels that are not carried by the UAS and emit

pollutants associated with internal combustion engines. The sUAVs proposed herein are

battery powered and have no emissions.

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in 

Command; 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, Brad Blosser’s sUAV is 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot’s license to be pilot in command of an 

aircraft for compensation or hire. 

Brad Blosser respectfully proposes that Operator requirements should take into account 

the characteristics of the particular UAS. Brad Blosser’s sUAV has a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the 

potential for operation outside of the operating conditions set forth in the exemption 

application. Brad Blosser’s sUAV has navigation and control system comprised of a 

Ground Control Station (GCS) and auto-pilot system that can be pre-programmed to set 

operational boundaries. All flights are pre-programmed with precision GPS guidance. In

the case of unplanned events, the Operator may input pre-programmed evasive 

maneuvers from the control unit, and the onboard autopilot executes those maneuvers.

Pre-programmed Operator interventions include initiation of holding at present position;

suspension of mission; fly back to launch point; abort mission and land immediately; and

emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of Brad Blosser’s 

sUAVs may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 

10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will 

hold position at its current location for 5 seconds and if the signal is not 

restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft down 

in flight in the event of a loss of control or un-commanded deviation from 

the flight path.

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximum of 400 AGL.
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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Given these safety features, Brad Blosser proposes that the sUAV should not be required 

to hold a commercial or private pilot certification. 

Brad Blosser notes that the FAA has found that safety factors permitted operation of 

UASs by Operators with these qualifications in the case of operations pursuant to public 

COAs where the mandatory operating conditions specified above were present. See, 

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(UAS) Operational Approval, at 20-21 (July 30, 2013). Likewise, Brad Blosser notes that 

the NPRM does not require that the Operator hold a private pilot license issued by the 

FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the Brad Blosser’s sUAV without a private pilot’s certificate or a 

commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the Brad Blosser’s sUAV (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of 

risk associated with private pilot operations or commercial operations contemplated by

Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of 

the UAS as set forth above meets or exceeds the present level of safety provided under 14 

C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to 

operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of 

the UAS without an airworthiness certificate, no standard will exist for airworthiness of 

the UA. Given the size of the aircraft and the requirements that the Operator has agreed 

to as it relates to airworthiness, as contained in the manual, an equivalent level of safety 

will be achieved by insuring compliance with the manuals prior to each flight. The FAA

has granted exemptions to conduct similar operations in Exemptions 11062 through 

11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be 

needed to allow such operations. 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner, facility owner, and/or local officials. Because of the 

advance notice to the property owner and participants, all affected individuals will be 

aware of the planned flight operations as set forth in the Manuals. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the 

lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented by conventional aircraft operating at or below 500 AGL in the aerial 

photography industry. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. The FAA has granted exemptions to 

conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As Brad Blosser’s sUAV, in 

manual or emergency mode, will not have a barometric altimeter display, but instead a 

GPS altitude display, an exemption will be needed. The Operator, pursuant to the 

procedures set forth in the Manuals as indicated before flight, will achieve an equivalent 

level of safety. The FAA has granted exemptions to conduct similar operations in

Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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 (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 10 minutes in length. Given the limitations on the UAS’

proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly

controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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engender the type of risks that Section 91.151(a) was intended to alleviate given the size 

and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to

30 minutes or 25% of remaining battery power whichever happens first. This restriction 

would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, 

through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

These regulations require that an aircraft Operator or owner “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...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits an 

equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in defined areas for limited periods 

of time. If mechanical issues arise, the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual 

the Operator will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, 

the Operator and manufacturer are most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

The FAA has granted exemptions for similar operations in Exemptions 11062 through

11067, 11080 and 11110.

*********

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site inspection 

and monitoring, public entity support operations, aerial video and live video feed to assist 

with search and rescue operations under the authority and support of local authority 

officials, aerial video and photography for public and private use including television, 

public events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase awareness 

and improve safety for current and future UAS operations within the NAS, special

events: including high schools, colleges, professional sports, open air events and fairs, 

research, risk management and assessment, motion picture production, surface mining, 

closed set filming, disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Inspection will be of inanimate objects in areas where the 

owners will have consented to the inspections or otherwise have agreed to allow the UAS 

and the Operator to be in the area where operations will take place. 

The size of the UAS, its speed and restricted area of operation do not raise national

security issues.

Summary

Approval of exemptions allowing commercial operations of sUAVs for petitioner to 

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack 

inspection, utility-power generation system inspections and patrolling, aerial inspection 

and photography of residential and commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers, pipeline inspection and 

patrolling, filmmaking, cinematography, and videography, precision agriculture with on 

board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support operations, 

aerial video and live video feed to assist with search and rescue operations under the 

authority and support of local authority officials, aerial video and photography for public 

and private use including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools. colleges, professional 
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

Page	24

sports, open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, disaster and catastrophe events, 

will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing people in 

swamps, on roofs or tall, hazardous or weakened structures, exposes them to higher risks

than those created by use of a sUAVs. Conventional aircraft that operate at extremely low

altitudes just feet from the subject being inspected and in extreme proximity to people 

and structures present the risks associated with vehicles that weigh in excess of 6,000 

lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such 

aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer 

than 55 lbs. and powered by batteries eliminates virtually all of that risk given the 

reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the 

target area and not flown. The sUAV will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein. These lightweight aircraft operate at slow speeds, 

close to the ground, and in areas that are under the control of the customer for the 

operations and, as a result, are far safer than conventional operations conducted with 

turbine helicopters operating in close proximity to the ground and people or the use of 

individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions 

already granted, including Exemptions number 11171 through 11174, 11176, 11177, 

11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely,

Brad Blosser

10069 County Road 16

Middlebury, IN 46540

brad@goshenhealth.com

574.238.1087
Brad	Blosser,	10069	County	Road	16,	Middlebury	IN	46540,	brad@goshenhealth.com,	574.238.1087		

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