# 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



### Blue Skies Drone Rental Section 333 Exemption Request of 1 15

# 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



### Blue Skies Drone Rental Section 333 Exemption Request of 2 15I. 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 3 15This 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 4 15III. 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



### Blue Skies Drone Rental Section 333 Exemption Request of 5 15• 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 6 15Operator 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 O perator are required to remain in contact throughout theoperation. 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 7 15• 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 8 15IV. 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.”



### Blue Skies Drone Rental Section 333 Exemption Request of 9 15• 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, byperforming 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 §



### Blue Skies Drone Rental Section 333 Exemption Request of 10 1561.53(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.



### Blue Skies Drone Rental Section 333 Exemption Request of 11 15• 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 12 15• 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 13 15VI. 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 14 15VIII. 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.



### Blue Skies Drone Rental Section 333 Exemption Request of 15 15