Section 333 

Exemption Request 

February 25, 2016

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE., 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

Blue Skies Drone Rental 

7527 148th Pl SE 

Snohomish, WA 98296 

225-341-0608 

droneanator@blueskiesdronerental.com 

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Table of Contents 

I. Summary 

II. Definitions 

III. Operating Procedures 

A. General 

B. Confined Area of Operations

C. Environmental Conditions 

D. Crew 

E. Aircraft 

IV. Basis for Petition 

V. The Extent of Relief and the Reasons Blue Skies Drone Rental, Seeks Relief

VI. Why Granting Blue Skies Drone Rental's Request Would Be in the Public Interest

VII.Summary

VIII.Additional Information to Support This Request

IX. Conclusion

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I. Summary 

Blue Skies Drone Rental (herein referred to as "BSDR") seeks exemption from the requirements 

of the following: 

• 14 CFR 21, Subpart H 

• 14 CFR 61.3 (c) 

• 14 CFR 61.113 & 14 CFR 61.133

• 14 CFR 91.9

• 14 CFR 91.105

• 14 CFR 91.109 

• 14 CFR 91.119

• 14 CFR 91.121

• 14 CFR 91.151

• 14 CFR 91.203 (a) & (b)

• 14 CFR 91.213

• 14 CFR 91 Subpart E 

BSDR is comprised of a team of FAA licensed private, commercial and ATP pilots and Certified 

Flight Instructors and Instrument Instructors (CFI/CFII) in both rotor and fixed wing operations 

as well as model aircraft enthusiasts. With thousands of hours of manned aircraft flight time and 

hundreds of hours of Small Unmanned Aircraft System (SUAS) experience, we are well 

acquainted with the National Airspace System and the challenges of incorporating this new 

category of aircraft into the skies. Our desire is to provide access to a more economical aerial 

perspective for our clients so that they can more efficiently provide their business services to the 

communities and industries which they service. We believe that this can be done safely by the 

use of SUAS without compromising safety within the National Airspace System. Our operations 

will benefit the public by providing cost efficient aerial solutions to public sector agencies and 

private sector companies, all within the proven structure and safety framework of Federal 

Aviation Regulations. 

Our proposed SUAS operations include: 

• Aerial photography and videography including, but not limited to: motion picture and 

television, special events, sporting events, real estate, construction, surveying, etc.,

• Educational, training and academic uses,

• Research and development, 

• Agricultural monitoring and development, 

• Geological Survey, 

• Powerline and pipeline inspections,

• Antenna and building inspections, 

• Bridge inspections, 

• Wildlife nesting area evaluations, 

• Aerial advertising and 

• Working closely with national, state and local emergency response teams to assist 

during natural disasters.

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This request for exemption will attempt to explain which exemptions we seek in order to fulfill 

our customer's needs while still maintaining a high level of safety for people and property within 

our operating environment. 

While this section of the industry is currently being developed, our desire at BSDR is to have the 

flexibility to utilize new, more advanced, and safer SUAS as they come to market by maintaining 

a working knowledge of current regulations regarding SUAS and ensure that we are operating 

our equipment in accordance with all applicable laws. 

II. Definitions 

Confined Area of Operations (CAO) – An area established to confine the flight of a small 

unmanned aircraft in order to allow the Operator to become familiar with the area of operation 

and create contingency plans for using the environment to mitigate the risk associated with the 

possible loss of positive control.

Control Station – An interface used by the Operator to control the flight path of the small 

unmanned aircraft.

Immediate Area of Influence (IAI) – The area immediately surrounding a CAO that SUAS 

operations may have secondary effects on. Example: an urban CAO may be limited to a small 

property but nearby neighbors could be affected by privacy concerns that the SUAS presents. 

Although IAI are not affected by the same safety concerns as CAOs, they may present nonsafety related issues that need to be addressed.

Loss of Positive Control (LPC) – A condition where the UAS Operator may become unable to 

directly control the UAS due to a failure of the control link between the aircraft and the 

Operator’s control station 

Operator (OP) – The person who manipulates the flight controls of a small UAS. The Operator is 

directly responsible for, and is the final authority as to the operation of the SUAS.

Part 107 – The proposed new part of Title 14 of the CFR that would govern small UAS 

operations. Since this regulation does not yet exist, the exemption request references the 

proposed Part 107 details as described in the recently released NPRM Draft SUAS Law RIN 

2120-AJ60 dated Feb. 15, 2015.

Small Unmanned Aircraft System (SUAS) – A small unmanned aircraft (which, as defined by 

statute, is an unmanned aircraft weighing less than 55 pounds) and equipment necessary for 

the safe and efficient operation of that aircraft.

Visual Observer (VO) – A person who assists the SUAS Operator in seeing and avoiding other 

air traffic or objects aloft or on the ground. A VO is required for operations when the Operator is 

incapable of seeing the SUAS. Example: First Person View (FPV) operations. 

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III. Operating Procedures 

BSDR will operate drones following the guidelines listed below. 

A. General 

• A SUAS Operator is required to see and avoid all other users of the National Airspace System 

in the area in which the SUAS is operating.

• SUAS are prohibited from operating in Class A airspace and require prior permission from Air 

Traffic Control to operate in Class B, C or D airspace, or within the lateral boundaries of the 

surface area of Class E airspace designated for an airport. Operations are allowed within Class 

G airspace without ATC permission.

• SUAS must yield right-of-way to other aircraft, manned or unmanned.

• No person may act as an Operator (OP) or Visual Operator (VO) for more than one unmanned 

aircraft operation at one time.

• No careless or reckless operations are permitted. 

B. Confined Area of Operations 

BSDR embraces the FAA’s proposed performance-based operator responsibility standard built 

around the concept of a confined area of operation (CAO) for SUAS operations as a means to 

mitigate the risk associated with a loss of positive control condition. The BSDR SUAS Operator 

will establish a CAO prior to all SUAS operations and will continually monitor it to ensure it is not 

compromised. A CAO will have the following properties:

• Lateral Boundaries: The CAO will be limited to a circle around the person maintaining visual 

contact with the aircraft with the radius of that circle being limited to the farthest distance at 

which that person has sufficient view of the aircraft. As a good operating practice, the CAO will 

be no larger than the area required for the specific operation.

• Vertical Boundaries: The CAO will not exceed 500 feet AGL unless inspecting

a ground-based structure more than 500 feet in height such as a building, bridge or antenna. 

When inspecting a ground-based structure above 500 feet, the SUAS will remain within 50 

meters (164 feet) laterally and will fly no more than 10 meters (33 feet) above the highest point 

on the structure. BSDR will coordinate with the local ATC facility prior to conducting any 

operations over 500 feet.

• No one will operate an SUAS from a moving platform with the exception of watercraft.

• All personnel within the CAO and the IAI will be informed of: 

• The purpose of the SUAS operations,

• Where they can expect the SUAS to be operating and at what altitude, 

• What they should do to ensure their safety,

• BSDR’s privacy policy, and

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• BSDR’s contact information for use in the event they have any concerns.

• No SUAS will be flown over personnel who are not directly involved in the

operation. This does not include personnel protected by a structure with sufficient overhead 

cover to nullify the danger of an SUAS impact such as a building or automobile.

• Personnel directly involved in the operation will be briefed by the Operator on the following 

items in order to reduce risk of injury: 

• Operating conditions,

• Emergency procedures,

• Contingency procedures,

• Roles and responsibilities, and

• Potential hazards.

C. Environmental Conditions 

BSDR will operate SUAS within the following environmental conditions: 

Daylight Only – BSDR will only conduct SUAS operations between the hours of official sunrise 

and official sunset for the location in which they are operating. 

Cloud Clearances – SUAS will maintain a minimum of the following distance separation from 

clouds: 

• 500 feet below

• 2000 feet horizontal

Visibility 

• 3 Statute Miles from the control station

Winds

Unless otherwise specified in the SUAS operator’s manual, predominant wind not to exceed 80 

percent of the SUAS max airspeed. 

• Example: If the SUAS max airspeed is 40 knots, operations will not commence if 

observed predominant winds are greater than 32 knots. Also, operations in progress 

will terminate if predominant wind speeds exceed 32 knots.

• Operator must exercise good judgment as UAS max airspeed may be affected by a 

variety of factors such as atmospheric conditions, low battery, and variation in payload.

D. Crew 

General 

The Operator will serve in the role of Pilot in Command (PIC) for SUAS operations. Operators 

will report an accident to the FAA within 10 days of any operation that results in injury or 

property damage. 

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Operator Licensing 

Until the FAA begins issuing UAS specific licenses, all Operators will be FAA licensed pilots with 

a minimum of a sport pilot endorsement.

Operator Medical

The Operator will be required to self-certify, prior to all SUAS operations that they do not have a 

medical condition that could interfere with the safe operation of a small UAS. The operator will 

hold a current FAA airman medical certificate or a valid U.S. driver's license or make a 

statement declaring that they do not have a medical condition that could interfere with the safe 

operation of a small UAS. 

Visual Observer

A Visual Observer (VO) may be used to assist the Operator in maintaining visual contact with 

the SUAS in place of the operator. VOs are not required to have any formal FAA certification; 

however, the Operator must brief them on the operation to be performed prior to 

commencement. The VO and Operator are required to remain in contact throughout the 

operation. This can be by unassisted oral communication or by radio or other communicationassisting device. 

As a best practice, BSDR will maintain a crew briefing program where the Operator and VO will, 

before the flight, determine the safety of the flight based upon the minimum following 

parameters: 

• Weather checked and is within operating parameters, 

• If operating within a controlled airspace, permission has been requested and granted 

from the appropriate authority, 

• Aircraft preflight inspections completed, 

• Operator and VO recency of experience qualifications on type of SUAS to be flown, 

• All pertinent NOTAMS have been checked, to include TFRs within the CAO. 

E. Aircraft

It is the intent of BSDR to service a variety of industries and, as such, will utilize different models 

based upon the application. In most cases, BSDR will use off the shelf products from 

manufacturers such as DJI or 3DR with proven safety features built in to meet the needs of 

customers. New SUAS models are being developed at a rapid pace, and BSDR will choose to 

incorporate new models into the flightline based upon the following parameters: 

 

• FAA airworthiness certification is not required. However, the Operator must maintain a SUAS

in condition for safe operation and prior to flight must inspect the UAS to ensure that it is in a 

condition for safe operation.

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• All BSDR aircraft will be registered with the FAA in accordance with existing procedures. 

Registration information will be maintained at the control station.

• Max calibrated airspeed at full power in level flight will not exceed 87 knots (100 mph).

• Total weight of the unmanned aircraft will not exceed 55 lbs (25 kg).

• Manuals and checklists:

• All SUAS will have operator’s manuals that include pre-flight procedures that will be 

executed by the crew prior to each flight operation in order to determine that the SUAS 

is safe for operation.

• All SUAS will have emergency procedure checklists.

• Manuals and checklist will be maintained at the control station and must be accessible 

to the Operator at all times. 

• Any of the above manual and checklists that are not provided by the manufacturer 

must be created and thoroughly vetted prior to performing any commercial operations.

• Aircraft markings will be displayed on the aircraft in the largest practicable manner in 

accordance with 14 CFR §45.29(f).

• Prior to operating any SUAS for commercial purposes in an urban area, BSDR will first 

conduct flight training in a controlled rural CAO, with the minimum personnel required to safely 

familiarize Operators with the aircraft’s characteristics. This includes, but is not limited to: 

• Preflight procedures,

• Take off, inflight, and landing procedures, 

• Automated LPC settings (if available), and 

• Emergency procedures.

• Only after the Operator has confidence in both the SUAS and their operating proficiency will 

they perform operations in an urban CAO.

• Operators will ensure that the small UAS has enough power to operate for its intended 

operational time and an additional five minutes. The Operator will be required to monitor 

power levels throughout the flight and modify the mission if required.

• BSDR recognizes and applauds the FAA's consistent efforts to include SUAS safely in our 

national airspace system. Recently, the FAA has begun to consider different classifications for 

UAS according to a performance based regulatory framework. If/when these regulations are 

adopted, BSDR intends to operate any SUAS that fall under a different classification 

according to the operational provisions written in the rule.

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IV. Basis for Petition

Specific Sections of 14 CFR From Which BSDR Seeks Exemption

Below is a list of specific sections from which this exemption request relief:

• 14 CFR 21, Subpart H – This subpart prescribes procedural requirements for the issue of 

airworthiness certificates.

• 14 CFR 61.3 (c) – Requirements for certificates, ratings, and authorizations. Medical 

certificate.

• 14 CFR 61.113 – Pilot privileges and limitations: Pilot in command

• 14 CFR 61.133 – Commercial pilot privileges and limitations.

• 14 CFR 91.9 – Civil aircraft flight manual, marking and placard requirements.

• 14 CFR 91.105 – Flight crew members at stations.

• 14 CFR 91.109 – Flight instruction, simulated instrument flight and certain flight tests.

• 14 CFR 91.119 – Minimum safe altitudes: General.

• 14 CFR 91.121 – Altimeter settings

• 14 CFR 91.151 – Fuel requirements for flight in VFR conditions.

• 14 CFR 91.203 (a) & (b) – Civil aircraft: Certifications required.

• 14 CFR 91.213 – Inoperative instruments and equipment.

• 14 CFR 91 Subpart E – Maintenance, Preventive Maintenance, and Alterations

V. The Extent of Relief and the Reasons BSDR, Seeks Relief 

Below is a list of each section of 14 CFR from which BSDR seeks relief, the extent of the relief 

requested, and the reasoning behind the request: 

14 CFR 21, Subpart H – This subpart prescribes procedural requirements for the issue of 

airworthiness certificates. 

• BSDR agrees with the FAA opinion that “due to their light weight, small unmanned 

aircraft generally pose a significantly lower risk to people and property on the ground 

than manned aircraft.”

• The FAA acknowledges and BSDR agrees that: “obtaining a type certificate and a 

standard airworthiness certificate, which permits the widest range of aircraft operation, 

currently takes about 3 to 5 years” and “it is not practically feasible for many small UAS 

manufacturers to go through the certification process required of manned aircraft. This 

is because small UAS technology is rapidly evolving at this time, and consequently, if a 

small UAS manufacturer goes through a 3-to-5-year process to obtain a type 

certificate, which enables the issuance of a standard airworthiness certificate, the 

small UAS would be technologically outdated by the time it completed the certification 

process.”

• Additionally, none of the current avenues for airworthiness listed in 14 CFR 21 Subpart 

H “provide flexibility for most routine small UAS operations.”

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• Therefore, BSDR requests relief from obtaining an airworthiness certification for the 

SUAS it operates.

To provide an equivalent level of safety, BSDR will require: 

• Prior to each flight, the Operator must inspect the small UAS to ensure that it is in the 

proper condition for safe operation. The Operator could do this, for example, by 

performing a manufacturer-recommended preflight inspection or performing an on-theground test of the small UAS to determine whether safety-critical systems and 

components are working properly.

• If, as a result of the inspection, the Operator determines that the small UAS is no 

longer in a condition for safe operation, then they would prohibit the operation of the 

small UAS until the necessary maintenance has been made and the small UAS is 

once again in a condition for safe operation.

• The Operator must discontinue the flight of the small, unmanned aircraft when he or 

she knows or has reason to know that continuing the flight would pose a hazard to 

other aircraft, people, or property.

• If any component or parts are used in an SUAS are governed by an airworthiness 

directive, BSDR will comply with all applicable airworthiness directives pertaining to 

that component or part.

14 CFR 61.23 (c) – Medical certificates: Requirement and duration. 

• The FAA has proposed and BSDR agrees that: “The primary reason for medical 

certification is to determine if the airman has a medical condition that is likely to 

manifest as subtle or sudden incapacitation that could cause a pilot to lose positive 

control of the aircraft, or impair the pilot’s ability to “see and avoid.”

• Subsequently, “The FAA has determined that traditional FAA medical certification may 

not be warranted for small UAS Operators subject to this proposed rule mainly 

because small UAS Operators and visual observers are operating within a “confined 

area of operation,” and subject to other operational limitations, discussed previously in 

this preamble. This is because the proposed visual-line-of-sight requirement for the 

Operator and/or visual observer to be able to see the aircraft’s direction and attitude of 

flight in the proposed rule is preferable to a vision standard. Even with normal vision it 

is foreseeable that a small unmanned aircraft may be so small that the operational 

space must be reduced to meet the operational requirements proposed in this rule. As 

such, prescriptive medical standards may not be as critical as they are for individuals 

exercising pilot privileges and therefore are not proposed under this action.”

• Although most BSDR Operators will hold a medical certificate as a currency 

requirement for their FAA Sport Pilot and Commercial Pilot certificates to perform 

manned operations, we feel an equivalent level of safety can be provided by the FAA’s 

proposal to allow: “operators (and Visual Observers to) self-certify, at the time of their 

airman application, that they do not have a medical condition that could interfere with 

the safe operation of a small UAS. As proposed in § 107.61(d), an applicant for an 

unmanned aircraft operator certificate with a small UAS rating would be ineligible for 

the certificate if he or she knows or has reason to know of any physical or mental 

condition that would interfere with the safe operation of a small UAS. The FAA also 

proposes, in § 107.63(a), that the applicant be required to make a certification to that 

effect. Both of these proposed requirements are similar to the regulatory provision of § 

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61.53(b), which prohibits operations during medical deficiency for individuals 

conducting operations that do not require a medical certificate.” Until a formal 

procedure is established for this, BSDR will maintain a copy of either an operator’s 

FAA medical certificate or driver's license on file or a statement reflecting the 

information detailed above. Additionally, it will be the responsibility of the briefer/

dispatcher to ensure that the individual self-certifies they are medically fit to prior to 

performing each operation.

14 CFR 61.113 – Pilot privileges and limitations: Pilot in command. & 14 CFR 61.133 – 

Commercial pilot privileges and limitations. 

• There is currently no FAA endorsement specifically for UAS operators. BSDR plans to 

use operators who have a minimum of a sport pilot certificate 

• To provide an equivalent level of safety, BSDR intends to establish a program 

where all proposed operations would be reviewed and approved by another 

rated aviator prior to commencement, as described previously in this 

document.

• Since the aircraft cannot carry passengers or property, we feel we meet the 

intent of 61.113 Subparagraph (b), even though the intent of this application is 

to conduct a business.

• At which time an FAA SUAS certification becomes available, all BSDR 

Operators will seek that endorsement and will abide by the associated 

regulatory requirements as soon as practicable.

14 CFR 91.9 - Civil aircraft flight manual, marking, and placard requirements. 

• With a max weight of 55 lbs., SUAS are too small to carry documentation, they don’t 

have an entrance, and are not capable of carrying passengers or crew. Therefore, 

placing an aircraft manual on board an SUAS is not feasible.

• To provide an equivalent level of safety, BSDR will maintain an aircraft manual at the 

control station so that the Operator may access it at any time.

• BSDR will affix a placard on each aircraft that identifies the FAA registration number.

14 CFR 91.105 – Flight crewmembers at stations. 

• Since the aircraft is unmanned, there are no crew stations that require safety belts.

• To provide an equivalent level of safety and to meet the intent of this section, 

crewmembers will position themselves wherever they deem appropriate to ensure the 

safest operation possible. This includes taking into account visual line of sight 

requirements and areas of probable contact hazards such as takeoff or landing areas.

14 CFR 91.109 – Flight instruction; simulated instrument flight and certain flight tests. 

• For the purposes of flight instruction, few SUAS have a set of fully functioning dual 

controls; however, the controls can be quickly transferred from a student to an 

instructor in the event of an emergency

• As previously mentioned, due to the limitations stated in the “Aircraft performance 

capabilities & design” section of this document, BSDR believes that SUAS do not 

exhibit the same level of risk as manned aircraft. Additionally, that risk can further be 

mitigated through the “Operational Guidelines” established in this document.

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• Given this information, BSDR believes it achieves an equivalent level of safety as 

would be achieved with a “functioning throwover control wheel” as detailed in 14 CFR 

91.109

14 CFR 91.119 – Minimum safe altitudes: General. 

• In general, BSDR request to operate at 500 feet and below at all times with the 

exception of inspecting a ground-based structure in excess of 500 feet. When 

inspecting a ground-based structure above 500 feet, the SUAS will remain within 50 

meters (164 feet) laterally and will fly no more than 10 meters (33 feet) above the 

highest point on the structure. BSDR will coordinate with the local ATC facility prior to 

conducting any operations over 500 feet. Since no aircraft should be operating this 

close to a ground-based structure, our proposed operations should present minimal 

risk to manned aircraft.

• By implementing the controls listed above and in the “Operation Guidelines” section of 

this document, BSDR feels they can provide a level of safety greater than those listed 

in this section.

14 CFR 91.121 – Altimeter settings 

• Most UAS do not have the ability to adjust altimeter settings. Additionally, many UAS 

use GPS to determine altitude. In both cases, it is impossible to comply with 14 CFR 

91.121

• Since operations occur within a confined area of operations and they are usually less 

than one hour in duration, it is unnecessary to update altimeter settings once a base 

altitude has been established.

• To provide an equivalent level of safety the Operator will determine the altitude reading 

at the point of takeoff and use that to determine the altitude of the aircraft throughout 

the flight abiding to the altitude limitations listed above. They must also take into 

account rising or falling terrain to maintain within the prescribed altitudes.

14 CFR 91.151 – Fuel requirements for flight in VFR conditions. 

• Currently, most SUAS currently have flight time limited to 30 minutes or less. 

Therefore, it is impractical to maintain a 20 or 30-minute fuel reserve.

• The FAA proposes and BSDR endorses that: “Proposed §107.49(a)(4) would require a 

small UAS Operator to ensure that, if powered, the small UAS has enough power to 

operate for its intended operational time and an additional five minutes. The 5-minute 

buffer would ensure that the small UAS has sufficient power to return to the Operator, 

or another location, and be able to make a controlled landing. Additionally, control 

inputs to a small UAS may degrade as batteries lose charge because power to the 

flight control system(s) may be lost. Accordingly this proposed rule would help to 

ensure that the small UAS remains controllable throughout its intended operational 

time. The FAA notes that a small UAS traveling at 10 miles per hour would be able to 

cover nearly one mile in 5 minutes.” BSDR believes that operating with a 5 minute 

buffer would

provide an equivalent level of safety as presented in 14 CFR 91.151. 

14 CFR 91.203 (a) & (b) – Civil aircraft: Certifications required. 

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• As previously mentioned, BSDR petitions to be waived from the airworthiness 

requirements of 14 CFR 21 Subpart H for the reasons listed above.

• Since the SUAS operated by BSDR will not be issued an airworthiness certificate, 

none will be available to meet this requirement.

• With a max weight of 55 lbs, SUAS are too small to carry documentation, they don’t 

have an entrance, and are not capable of carrying passengers or crew.

• To provide an equivalent level of safety, BSDR will maintain all required documentation 

at the control station for review if requested.

14 CFR 91.213 – Inoperative instruments and equipment 

• As previously mentioned, BSDR petitions to be waived from the

airworthiness requirements of 14 CFR 21 Subpart H for the reasons listed above. If 

approved, BSDR will not be able to meet the requirements of 14 CFR 91.213.

• To provide an equivalent level of safety, BSDR will prepare a Minimum Equipment List 

for each aircraft it operates that which instruments and equipment are essential for 

safe operations under all operating conditions. These items will be checked during 

preflight and if any are found to be inoperative or unreliable, the SUAS will be 

prohibited from taking off until the deficiency is corrected.

14 CFR 91 Subpart E – Maintenance, Preventive Maintenance, and Alterations 

• Regulations require that aircraft be maintained in accordance with 14 CFR 39 and 43, 

which apply to aircraft and components issued an airworthiness certificate. Since 

BSDR is requesting that our SUAS be exempt from requiring an airworthiness 

certificate, we request exemption to 14 CFR 91 Subpart E. This does not apply to any 

components used that are governed by an airworthiness certificate.

• To provide an equivalent level of safety, BSDR plans to establish a maintenance 

program that mirrors one in use by commercial airline operators. The intent is to track 

the usage, repair, and component failure rates of our SUAS fleet with the overall goal 

of developing a preventative maintenance program and associated operational 

procedures (including preflight and periodic checks) to enhance overall safety. This is 

intended to be a shared responsibility between the SUAS Operators, designated 

maintainers, and maintenance supervisors.

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VI. Why Granting BSDR’s Request Would Be in the Public Interest

The FAA has already stated that there are significant safety and economic benefits of allowing 

SUAS to operate in the NAS with certain operating limitations. The primary reason for 

allowance of SUAS is an increased margin of safety. There are many situations where aerial 

photography or videography can be taken from SUAS instead of traditional manned aircraft with 

a much larger safety margin because of decreased exposure of the pilots operating the manned 

aircraft. Additionally, because of their small size, SUAS limit danger for the people and property 

over which the vehicles operate, should a problem arise during flight. Beyond these immediate 

safety considerations, financial limitations are the biggest reason that many do not use aerial 

systems to enhance their work. Granting this request to BSDR would provide many clients with 

an avenue to enter the world of aviation on a much smaller carbon and financial footprint. 

It a priority for BSDR to enhance and increase public awareness of the benefits of responsible 

use of SUAS in the skies over our neighborhoods, cities and states. BSDR is made up of 

individuals who are familiar with Safety Management Systems, Crew Resource Management, 

Hazard and Risk Analysis and Aeronautical Decision Making and can use this combined 

knowledge and experience to improve public perception of this fledgling industry. To that effect, 

BDSR will seek opportunities with local schools, universities and other research institutions to 

further develop this industry so that SUAS technology can be implemented to expand the safety, 

wellbeing and economic security of our nation as a whole. 

VII. Summary 

BSDR hereby requests exemption from the following sections: 

• 14 CFR 21, Subpart H 

• 14 CFR 61.3 (c) 

• 14 CFR 61.113 

• 14 CFR 61.133 

• 14 CFR 91.9 

• 14 CFR 91.105 

• 14 CFR 91.109 

• 14 CFR 91.119 

• 14 CFR 91.121

• 14 CFR 91.151 

• 14 CFR 91.203 (a) & (b) 

• 14 CFR 91.213 

• 14 CFR 91 Subpart E 

This exemption will grant BSDR to operate SUAS commercially in various locations within the 

United States. 

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VIII. Additional Information to Support This Request 

As further demonstration of the benefits of using SUAS to augment, and in some cases replace 

manned aircraft, a recent article about the Grand Forks County Sheriff’s Office in North Dakota 

who currently uses drones for crime and accident scene reconstruction cites the following while 

comparing SUAS to manned systems: 

"What we’ve done here [in Grand Forks] indicates to us that we can do about a third of 

the missions of a helicopter, but we can do that for four percent of the purchase costs 

and two percent of the operating costs." 

-Alan Frazier in the article "The Remote Arm of the Law" culled 7/28/2015 

http://www.verticalmag.com/news/article/32286 

This type of access to aerial imagery is indispensable in stretching limited resources of public 

service departments, increasing community safety and speeding up the process of solving 

crimes. Such societal and economic benefits will become more commonplace in the months and 

years ahead. 

IX. Conclusion 

As presented above, BSDR seeks an exemption pursuant to 14 CFR 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012. This will permit the safe operation of various 

SUAS Commercially and non-recreationally without an airworthiness certificate for the purposes 

of providing businesses, research institutions, and government agencies access to the most 

economical aviation solutions to meet their needs, while not compromising the safety or integrity 

of the National Airspace System. By granting this petition, the FAA Administrator will be fulfilling 

Congressional mandate of the FAA Modernization and Reform act of 2012, while also advancing 

the interests of the public. 

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