Black Dirt Drone

18 Baron Dr.

Warwick, NY 10990

January 25, 2016

U.S. Department of Transportation

Federal Document Management System

1200 New Jersey Ave., SE

Washington, DC 20590

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform act of 2012,

Public Law 112-95, Black Dirt Drone, operator of a Small Unmanned Aircraft System

(“sUAS”) requests an exemption from the below listed regulations to allow commercial

operation of its sUASs, provided that the proposed sUAS operation complies with the

conditions outlined below or as established by the Federal Aviation Administration

(“FAA”) under section 333.

Operator’s name: Christopher Robert Clark

Owner/President of Black Dirt Drone

-Airline Transport Pilot

-First Class Medical

-Known Crew Member

-UAS Certificate Registration number: FA3FHFF9XR

1Regulations from which the exemption are requested:

14 C.F.R. Subchapter C - Aircraft. part 21

14 C.F.R. Subchapter F - Flight Rules. Subpart B part 91.103

91.105

91.109

91.119

91.121

91.151

91.405

91.407

91.409

91.417

The proposed sUAS operator will maintain an equivalent level of safety without impact to

persons and property due to the extensive experience as an ATP fixed wing pilot and following

the limitations listed below. Together, working within the National Airspace System (NAS) for

more than 26 years, and with the continuous, ongoing training and safety requirements of being

an ATP pilot, granting the exemption would be in the public interest.

Proposed Commercial Operations of Black Dirt Drone:

- Aerial Videography and Photography for business and private sector

- Aerial mapping, inspection and assessment for agriculture, real estate,

wind farms, solar, and cell towers

Aircraft Make and Model:

- DJI Phantom 3 professional

- DJI Inspire 1 Professional

2The proposed sUAS operation will be conducted safely to minimize risk to

the national airspace system (“NAS”) and to persons and property on the ground. Black

Dirt Drone proposes that the exemption apply to the previously listed sUAS that

operate within the limitations listed below.

1. The sUAS will weigh less than 55 pounds

2. The sUAS may not be operated at a speed exceeding 87 KTS ( 100 MPH)

3. The sUAS will not be operated at an altitude above 400 feet AGL

4. The sUAS will be operated within visual line of sight (VLOS) of the

operator. A visual observer ( VO) will be used if needed to maintain

VLOS requirements. If a VO is needed, communication will be

maintained using VFH radios. Electronic messaging or texting will not be

permitted during flight operations. The operator will be designated

before the flight and cannot transfer his or her duty for the duration of the

flight. The operator will ensure that the VO can perform the duties

required of the VO

5. Any UAS that has undergone maintenance must undergo a functional test

flight prior to conducting further operations

6. Prior to each flight, the operator will conduct a pre-flight inspection and

determine the sUAS is in a condition for safe flight

7. Black Dirt Drone will follow the sUAS manufacturer’s maintenance,

overhaul, replacement, and life limit requirements for the aircraft and

aircraft components as well as safety bulletins and firmware updates

8. Black Dirt Drone will not permit any operator to operate an UAS unless

the operator demonstrates the ability to safely operate the sUAS in a

manner consistent with how the sUAS will be operated under this

exemption, including evasive and emergency maneuvers and safe distances

from persons and property. Operators qualification flight hours and

currency will be logged in a manner consistent with 14 CFR 61.51 (b).

Flights for the purpose of training the operator and VOs (training,

proficiency, and experience-building) and determining the operator’s

3ability to safely operate the sUAS in a manner consistent with how the

sUAS will be operated under this exemption are permitted under the

terms of this exemption. Training flights may only be conducted during

dedicated training sessions.

9. UAS operations will only be conducted during day, VMC conditions.

3 SM visibility and 500 feet below and 2000 feet horizontally from a cloud

10. If the sUAS loses communication with the control station, or loses its GPS

signal, the UAS will return to a pre-determined location.

11. The operator will be prohibited from beginning a flight if the actual or

forecast winds exceed the operators’s experience level

12. The sUAS will remain clear and give way to all manned aviation

operations and activities at all times

13. The sUAS will not operate within 5 NM of an airport with a control

tower

14. The sUAS will not operate within 2nm of an airport without a procedure

and control tower

15. The sUAS will not be operated from any moving device or vehicle

16. All flight operations will not be conducted within 500 feet horizontally

or overhead any nonparticipating persons or property

17. Air Traffic Organization (ATO) Certificate of Waiver or Authorization

(COA). All operations will be conducted in accordance with an

ATO-issued COA.

18. Any incident, accident, or flight operation that transgresses the flight

profile defined by the applicable COA will be reported to the FAA’s

Integrations office (AFS-80) within 24 hours. Accidents will be reported to

the National Transportation Safety Board (NTSB) per instructions

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

.

19. The manufacture DJI, complies with part 15 of the FCC rules

20. In the event of an existing requirement to notify a Flight Standard

District office, the Teterboro FSDO will be used

21. No careless or reckless operation

4Allowing Black Dirt Drone to operate sUAS commercially with the exemption

333 of the FAA Modernization and Reform Act, will put in place an operator with 26 years

experience as a professional pilot working in the NAS. UAS operation is in its infancy as a

industry and granting this petition will ensure the highest level of safety within the NAS, to the

general public, and pose no threat to national security.

Christopher Robert Clark

President

Black Dirt Drone

18 Baron Dr.

Warwick, NY 10990

201 230-1899

bddrone@gmail.com

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