Brandon	Blackard

Blackard	Media

9415	Panther	Creek	Pkwy	#1133

Frisco,	TX	75035

469-766-0959

brandon@blackardmedia.com

Re: Exemption	Request	Section	333	of	the	FAA	Reform	Act

Dear	Sir/Madam	I	am	submitting	this	petition	on	my	own,	on	the	behalf	of	my	company

Blackard	Media,	without	the	aid	of	legal	council.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform	

Act),	and	14	C.F.R.	Part	11,	Blackard	Media which	is	owned	and	operated	by	Brandon	

Blackard,	a	sole	proprietorship,	operating	in	the	State	of	Texas.	Brandon	Blackard	who	

has	been	operating	Small	Unmanned	Aircraft	Systems	for	the	past	5	years,	wishes	to	

apply	for	an	exemption	from	the	Federal	Aviation	Regulations	(FAR)	listed	below	to	

allow	operation	of	our	sUAS	commercially	in	airspace	regulated	by	the	Federal	Aviation	

Administration	(FAA)	so	long	as	such	operations	are	conducted	with	and	under	the	

conditions	outlined	herein	or	as	may	be	established	by the	FAA	as	required	by	Section	

333.

The	requested	exemption	would permit	Blackard	Media to	pursue	its	commercial	

interests	in providing	services	to	companies	interested	in	aerial	data	that	can	only	be	

captured	by using	newly	developed	sUAS	in	the	following	areas:

·	Surveying	and	3D	aerial	mapping

·	Agriculture	crop	assessment	and	growth	patterns

·	Golf	course	management

·	Insurance	company	claim	assessment

·	Special	events

·	Construction	site	and	ecological	impact	assessment

Blackard	Media	asserts	that	all	sUAS	flights	that	will	occur	over	private	or	controlled	

access property	will	do	so	with	the	property	owner’s	consent	and	knowledge	and	that	

only people	who	have	consented	or	otherwise	have	agreed	to	be	in	the	area	where	

flight activity	is	taking	place.	Additionally,	I	have	extensive	flight	time	logged	with	sUAS

devices.	Our	observers	will	attend	ground	school	to	be	taught	the	rules	and	regulation

as	they	pertain	to	operating	private	aircraft	under	Visual	Flight	Rules	(VFR)	over	civilian

population	areas	as	described	and	set	forth	in	the	Aeronautical	Information	Manual.

The	substance	of	this	request	is	essentially	the	same	as	that	granted	to	Falcon

Sky	Cam	Regulatory	Docket	No.	FAA-2014-0884 in	that	Blackard	Media is	engaged	in	

aerial photography	and	videography	of	land,	buildings,	and	insurance	claims,	by	using	
remote controlled	sUAS	to	see	the	condition	of	fields,	crops,	ecological	impact,	and	

financial losses	do	to	destruction	by	fire	and	other	natural	disasters,	without	the	need	to	

drive	over	or	climb	on	the property	being	so	assessed.	In	doing	so	Blackard	Media will

have	the	ability	to	produce	high-resolution	photography	of	remote	locations	that	would

be	difficult	or	dangerous	to	reach	on	foot.	This	would	be	especially	problematic	while

doing	loss	claim	work	for	insurance	companies.	Blackard	Media’s	exemption	request

would	permit us	to	operate	lightweight,	unmanned	(remotely	controlled	in	line	of	sight)	

sUAS’s	in tightly	controlled	and	limited	airspace.	Predetermined,	specifically	marked	

areas	of operation	as	well	as	Global	Positioning	Satellite	(GPS)	navigation	maps	which

incorporate	restricted,	no	fly	zones	and	control	zones	of	airports,	will	allow	EAI	to

operate	within	current	safety	parameters	as	well	as	the	new	ones	being	implemented.

The	Extent	of	Relief	EAI	Seeks	and	Its	Justification	for	Such	Relief:

Regulation	from	EAI	request	exemption:

14	C.F.R.	61.113(a)	and	(b)

14	C.F.R.	91.7(a)

14	C.F.R.	91.9(b)	(2)

14	C.F.R.	91.109

14	C.F.R.	91.119

14	C.F.R.	91.121

14	C.F.R.	91.151(a)

14	C.F.R.	91.205(b)

14	C.F.R.	91.215

14	C.F.R.	(91.401-91.417)

Unmanned	Aircraft	System

sUASs	are	seen	as	a	better	photographic	platform	to	helicopters	because	these	smaller

devices	are	less	expensive,	they	produce	less	noise,	and	they	have	much	less

environmental	impact	and	are	less	likely	to	cause	injury	to	the	public	and	or	property.

I	am	petitioning	for	exemption	to	enable	EAI	to	operate	DJI	Phantom	3	Professional	and	

the	DJI	Inspire	1.	The	DJI	Phantom	3	Pro	and	Inspire	1 have a	built	in	capacity	to	limit the	

height	they	fly above	the	ground,	to	limit	the radius	of	the	distance they	fly from	the

operator	and	to	exclude	them for	Class	B,	C,	and	D	airspace	including	No	Fly	Restricted

Zones.	The	Phantom	3 Pro	and	Inspire	1	also	have the	failsafe	feature	of	the	Naza-M	

autopilot	system which	means	when	the	communication	between	the	main	controller	

and	the	transmitter is	lost,	the	Phantom 3	Pro and	Inspire 1 will	return	to	the	home	

starting	point	and	land	safely.

The	above	specifications	meet	with	the	Model	Aircraft	Operating	Standards	as	set

below:

· The	petitioner	will	only	operate	its	sUAS	in	line	of	sight	of	a	pilot/observer	and	will

operate	at	sites	that	are	sufficient	distance	from	populated	areas	within	the	sterile	area
described	in	the	FOPM.	Such	operations	will	insure	that	the	sUAS	will	not	create	a

hazard	to	users	of	the	national	airspace	or	the	public.

· When	flying	sUAS	within	3	miles	of	an	airport,	airport	operators	will	be	notified	and

the	operator	will	give	the	right	of	way	to	avoid	flying in	the	proximity	of	full	scale	aircraft.

· Maximum	flight	time	for	each	operational	flight	will	be	25	minutes.

· Flights	will	be	terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the

30	minute	limit.

· The	sUAS	will	be	programmed	so	it	will	not	be	operated	at	an	altitude	of	no	more	than

400	feet	AGL,	and	not	more than	200	feet	above	a	fixed	platform	from	which	operations

are	conducted.

· The	minimum	crew	for	each	operation	will	consist	of	the	sUAS	pilot	and	the	Visual

Observer.

· The	sUAS	will	weigh	less	than	55	pounds	including	its	payload	of	camera	and	gimbal.

· The	sUAS	will	fly	no	more	than	50	knots	and	can	hover	plus	move	horizontally	and

vertically.

· Given	the	small	size	of	the	sUAS,	and	the	restricted	airspace	within	which	it	will

operate,	I	believe	our	sUAS operations	will	comply	with	both	the	spirit	and	the	rules

intended	by	the	Reform	Act	safety	requirements.

As	part	of this	request	for	exemption,	Blackard	Media gives	personal	assurance	that	all	

persons involved	in	aerial	operations	have	completed	sUAS	education	and	training	

including	all applicable	regulations	and	guidance	documents.

I	respectfully	request	exemption	under	Section	333	to	enable	Blackard	Media to	operate	

efficient, limited,	low	risk	commercial	sUAS	operations	for	the	activities	stated,	

respecting	at	all times,	the	space	and	privacy	of	citizens	and	property	as	we	keep	our	

skies	safe.

Sincerely	yours,

Brandon	Blackard

Blackard	Media

9415	Panther	Creek	Pkwy	#1133

Frisco,	TX	75035

469.766.0959

brandon@blackardmedia.com