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Wild Blue Media

Robert Hawley

825 S. River Dr., Suite 135

Tempe, AZ 85281

budhawley@gmail.com

(480) 331-5022

September 22, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

(submitted electronically to www.regulations.gov)

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), Wild Blue

Media respectfully requests exemption from 14 CFR §§ 61.23 (a) and (c), 61.101 (e)(4) and (5), 61.113

(a), 61.315 (a), 91.7 (a), 91.119 (c), 91.121, 91.151 (a)(1), 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) and (2),

and 91.417 (a) and (b), to the extent necessary to allow Wild Blue Media to operate a UAS to perform

aerial data collection.

The requested exemption would permit Wild Blue Media to pursue its commercial interests in providing 

services to clients using sUAS’s in the following areas:

 Real estate

 Marketing

 Special events

 Surveying

Wild Blue Media states that all sUAS flights will occur over private or controlled access property and will 

do so with the property owner’s consent and knowledge.

Wild Blue Media is petitioning for an exemption to operate the following sUAS’s:

 DJI Phantom 3 Professional

 DJI Inspire1

 Yuneec Typhoon Q500

Each sUAV has a failsafe function that will be activated in the event communication is lost between the 

sUAS and the main controller transmitter. In that instance, the sUAV will return to its point of takeoff 
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and land safely. If the connection is restored, the pilot in command (PIC) can regain control of the flight 

and land manually.

The operator will adhere to the following conditions:

1. The petitioner will only operate its sUAV in visual line of sight (VLOS) of the PIC and/or a visual 

observer (VO). The VO and PIC will be able to communicate verbally at all times; electronic 

messaging will not be permitted during flight operations. The PIC will be designated before the 

flight and will not transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the duties required of the VO. Such operations will ensure that 

the sUAV will not create a hazard to users of the national airspace system or the public.

2. When flying the sUAS within five (5) miles of an airport, a letter of agreement with the airport’s

management will be obtained.

3. Maximum flight time for each operation will be 30 minutes.

4. Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time 

to safely land the sUAV.

5. The sUAV will be programmed so it will not be operated at an altitude that exceeds 400 feet 

above ground level (AGL), will not be more than 200 feet above an elevated platform from 

which videography is planned.

6. The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and 

a current FAA medical certificate.

7. The sUAS operated by the petitioner weights less than 55 pounds, including all payload (camera, 

lens and stabilizing gimbal.)

8. The sUAV will operate at speeds of no more than 87 knots (100 miles per hour).

9. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft will be prohibited from operating until the necessary maintenance has 

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

11. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection and life limit requirements for the aircraft and aircraft components.

12. Each UAS will comply with all manufacturer safety bulletins.

13. UAS operations will not be conducted during night. All operations will be conducted under 

visual meteorological conditions (VMC).

14. The UAS will not be operated less than 500 feet below or less than 2,000 horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC.

15. If the UAS loses communications or loses its GPS signal, the UAS will return to a pre-determined 

location within the private or controlled-access property.

16. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

17. The PIC will be prohibited from beginning a flight unless there is enough available power for the 

UAS to conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater.

18. Documents used by the operator to ensure the safe operation and flight of the UAS will be 

available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents will be made available to the Administrator or any law enforcement official 

upon request.
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19. The UAS will remain clear and will give way to all manned aviation operations and activities at all 

times.

20. The UAS will not be operated by the PIC from any moving device or vehicle.

Wild Blue Media hereby requests an exemption under Section 333 to enable Wild Blue Media to operate 

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

Respectfully,

Robert Hawley

Owner of Wild Blue Media