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Richard A. Blevins

817 Haylees Way

Piney Flats, TN37686-4050

 Home: rjm3@charter.net Work: rablevins@northeaststate.edu

 423.946.0579 423.354.5350

United States Department ofTransportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor RoomW12-140 

Washington, DC20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal

Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14

C.F.R. 91.7 (a); 14 CFR 91.9 (b) (2); 14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F. R. 91.119; 14

C.F.R. 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405 (a); 14 CFR 407 (a) (1);

14 CFR 409 (a)(2) ; 14 CFR 417 (a) & (b)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11,

Richard A. Blevins, operator of Small Unmanned Aircraft Systems (sUAS), hereby applies foran

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its

sUASs, so long as such operations are conducted within and under the conditions outlined herein or as

may be established by the Federal Aviation Administration (FAA) as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors,

would operate in the followingmanner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professionalactivities.

2. Aerial video/photography or providing live video feed to assist with search andrescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

3. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and news gathering.

4. Aerial inspection/photography of residential/commercial utility infrastructures including but 

not limited to electrical power lines, and other structures.

5. The ability to offer training to persons individually or belonging to both private and/or public

organizations that have interests in the safe use and operation of a UAS.
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BACKGROUND

sUAS DJI Phantom 3, Inspire Pro, Matrice and 3D Robotics - Solo

Richard A. Blevins seeks an exemption to operate DJI and 3D Robotics systems for compensation or hire

within the NAS. The DJI line of sUAS include Phantom 3 Professional, Inspire 1 Professional,and

Matrice, 3D Robotics aircraft will be the Solo. These aircraft are vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone

systems. The DJI aircraft specifications are as follows: Phantom 3 has a maximum gross weightof

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 

inches, and a maximum speed of approximately 35 mph. The DJI Inspire 1 has a maximum gross weight

of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 49 mph. The DJI Matrice has a maximum gross weight of 7.5 lbs., 

and measures 25” diagonally. The 3D Robotics Solo has a maximum gross weight of approximately 3.9 

pounds, measures 18" in length and 10"tall.

The DJI and 3D Robotics UASs that will be operated by Richard A. Blevins, will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

Specifically, each UAS is: A lightweight (< 55.0 lb gross weight with all on-board equipment), battery

operated 4- motor rotorcraft in the form of a quad copter that takes off and lands vertically, manufactured

by DJI and 3D robotics with the followingequipment:

− An on-board flight computer with GPS navigation and location ability that receives signals for flight

controls from a ground-based transmitter/controller;

− An on-board camera capable of capturing imagery in the form of full color, high definition still photos

and video;

− An on-board telemetry system that delivers flight data from the on-board flight computer to the onboard

radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and

direction back to its launch site;

− All aircraft operate on a frequency band of 2.4 GHz and/or 5.8 GHz. The aircraft on-board radio

transmitter transmits live video from the on-board camera plus all the flight data from the telemetry

system described above; 

− The Ground Station Includes:

− A UAS operator will be in operational control of a flight operation from liftoff to landing. 

− A radio receiver receiving live video and flight data from the on-board camera and computer projects it 

all together onto a screen for the UAS operator to monitor during flight.

− A Visual Observer will be utilized whenever there are obstacles in the flight pattern. An assessment 

will be conducted prior to each flight to increase situational awareness of the surroundings and to 

identify any hazards in the area. 
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BASIS FOR PETITION

Petitioner, Richard A. Blevins pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R.

§ 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,

hereby petition the Administrator to commercially operate the DJI and the 3D Robotics UAS in the

National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 21 subpart H, 61.113(a)&(b), 91.7(a), 91.9(b)2,91.103, 91.121, 91.151(a),

In consideration of the speed, weight, size, and limited operating area associated with the unmanned

aircraft and its operation, Richard A. Blevins' operation of the DJI Inspire 1 and DJI Phantom 3 and 3D

Robotics UAS meets the conditions of FMRA Section 333 and therefore will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Aerotek Imaging requests relief

from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set

forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Richard A. Blevins submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Richard A. Blevins will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UAS using the

methods, techniques, and practices prescribed in the operating documents (i.e., Maintenance Log, DJI and

3D Robotics Instruction Manuals. Furthermore, Richard A. Blevins will document and maintainall

maintenance records for the DJIUAS.

Richard A. Blevins will ensure that the DJI and/or 3D Robotics UAS/s are in an airworthy condition prior

to each flight.

Richard A. Blevins seeks relief from Section 45.23(b) Which states that when marks include only the

Roman capital letter “N” and the registration number is displayed on limited, restricted orlight-sport 

category aircraft or experimental or provisionally certificated aircraft, the operator must also display on

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,”

as applicable. The size of the UAS is too small to fit the required markings on the fuselage. A smaller

type or different designation could be used.

Richard A. Blevins seeks relief from certain requirements of Section 61.113(a) and (b), entitled Private

pilot privileges and limitations: Pilot in command, to the extent necessary to allow a Pilot in Command

(PIC) holding an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour 

and currency requirements, that the PIC is able to safely operate the DJI /3D Robitics UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles andstructures.

Richard A. Blevins also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI nor the 3D Robitics UA will not have a typical barometric altimeter

onboard. However, altitude information of the UA will be provided to the PIC via Global Positioning

System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA

to the GCS for active monitoring of the flight path. This altitude information, combined with Richard A. 

Blevins' operation of the DJI / 3D Robitics UA within visual line of sight, at or below 400 feet AGL, will

ensure a level of safety equivalent to Section91.121.
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Additionally, Richard A. Blevins seeks an exemption from the requirements of Section

91.151(a), entitled Fuel requirements for flight in VFRconditions.

Richard A. Blevins submits that safety will not be affected by operation of the DJI / 3D Robotics

aircraftduring daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR),

with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In 

accordance with 14 C.F.R. § 11.81.

Richard A. Blevins provides the following information in support oftheir petition for

exemption:

Maintenance:

To ensure safe operational control a maintenance program will be followed. Scheduled and preventive

maintenance shall be documented and only quality replacement parts will be used.

Safety:

Safety is paramount in all aircraft operations, as a fixed wing pilot, I cannot emphasize enough that

everyone flying a UAS, regardless of size, take this seriously and operate within the guidelines of

FAA regulations.

Pre-Flight Inspection:

- Will be conducted prior to each flight, while in flight, the aircraft will be monitored closely through the

utilization of the ground station.

- Before each flight, the UASs operational condition will be inspected for damage anddeterioration,

paying close attention to the propellers for cracks, wear, or apparent damage. Replacement ofthe

propellers will done on a periodic basis, even if obvious wear isn't visible. All squawks will be

recorded in the aircraft logbook to include: parts replaced, the purpose for replacing, and the

manufacture of the parts.

Situational Awareness: To ensure safety and situational awareness the spotter will be trained on

Situational Awareness and Human Factors. Hazards in the flight area will be discussed and constantly 

emphasized during the operation.

Populated Areas: All non-essentail personnel will be removed from the immediate area. No flights over

heavily populated areas like stadiums, schools, malls, casinos, and the like during operating hours will 

be conducted. 

Respect for Personal Privacy: I will not operate the aircraft in any manner that will interfere with 

someone’s privacy or disruption of their ability to enjoy their surroundings, such as a park or picnic 

area. If people are in the area I will obtain their permission prior to conducting any flight operations.

Airports: According FAA rules and to ensure pilot(s) safety, there will no flight in or around airports

unless explicit permission is granted according to current FAA regulations.

Weather: To ensure safety of spotter, agents, property owners, pet and wildlife flights will be conducted

in optimal weather conditions. Flights will not be conducted in winds steady 18, or gusting to above 20

mph.
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Return-to-Home Feature: In the event the DJI or 3D Robotics lose signal or runs

critically low on battery the UAS has a GPS controlled return to home feature. The 

"home" isset upon flight startup. - Auto Return-to-Home &Landing.

Confined Areas: Confined areas present a set of challenges that may require one or 

more observers. In this situation an appropriate number of spotters will be positioned 

in close proximately to hazards. Constant communication will be maintained between 

the UAS operator and every observer. Radio discipline will be adhered to, only 

communication associated with the operation will be allowed.

Line of Site: The UAS will always be within the line of site of the pilot and spotter.

If line-of-site is disrupted the return home feature will be activated. If the UAS 

operator regains line-of-site and the aircraft is performing correctly the operation may 

continue. 

Height: Flights will not exceed 400 ft AGL above subject properties at any time.

PilotQualifications

- The Pilot in command will be familiar with current FAA regulations regarding UAS 

 commercial usage.

 - The Pilot in command will have sufficient eye sight (with or without corrective lenses and without the 

 aid of binoculars) to see and operate the UAS at thedistances necessary for the purpose of the 

 flight.

- New Pilots in training will observe the UAS operator until they can demonstrate a 

 workable knowledge of the UAS and proficiency in operational control at all times. A written and 

 practical examination will be conducted on each potential pilot. The test results will be keep of file and 

 made available for FAA examiners. 

Summary

Section 61.113(a) and (b) prescribesthat—

(a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is

carrying passengers or property for compensation or hire; nor may that person, for compensation or hire,

act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with

any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

The UAS is not capable of carrying passengers or is able to carry cargo aside from the mentioned gimbal

mounted camera.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition.

There are no specifications on what makes a UAS airworthy, during the preflight checks all propellers

and mountings are checked for damage andoperation.

Section 91.7(a) prescribes that the pilot in command of a civil aircraft is responsible for determining

whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
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Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in the

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings,

and placards, or any combination thereof.

Supplemental materials will include equipment and flight manuals issued with the UAS.

Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at

airports of intended use, and takeoff and landing distance information.

All landing zones will be thoroughly checked and flight areas reviewed before any flights are made. 

Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft (excepta 

manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

The system is not available with dual controls, though with the UAS size and training in safe areas the

instruction could be contained to a safe altitude and area where safety can be optimized for all involved.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an

aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of

2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or

sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any

person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted

without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or

(c) of this section, provided each person operating the helicopter complies with any routes or altitudes

specifically prescribed for helicopters by the FAA;and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums

prescribed in paragraph (c) of this section.

Due to altitude limitations and the desire to avoid passenger carrying aircraft it is requested to maintain

a maximum ceiling of 400’ with typical heights being below that dependent on angles and shots for

photographic use.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the

chapter.

As there are no current maintenance requirements for UAS of this type it is not possible to meet this

requirement at thistime.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude

by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate

altimeter setting available beforedeparture.”

The UAS is single operator only with no dual controls so there will be only one pilot during flight, the

GPS system will reference the altitude at the launch point for every flight. This will also be the point that

the UAS will return to upon completion.

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes.

Petitioner will operate UAS until the earlier of a maximum of thirty (30) minutes or when 25% of battery 

remains. All UAS are additionally equipped with a low battery failsafe that allow the UAS to safely land

when little battery remains. The UAS are not propelled by fuel and will operate only within the safety

constraints of the UAS battery life
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Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has

within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration

certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft

registration Application as provided for in §47.31(c).

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the

airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers orcrew.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to

service by a person authorized under § 43.7 of the samechapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the

preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter.

There are currently no airworthiness certificates for the UAS to be used and also as there is no cabin

cockpit or passenger compartment on the UAS it is not possible to store certificates on board the craft.

Section 91.417(a) and (b) prescribes, in pertinent part,that—

(a) Each registered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for eachaircraft

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must

include—

(i) A description (or reference to data acceptable tothe

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return toservice.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and eachrotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, andappliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled

on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by

the inspection program under which the aircraft and its appliances aremaintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next action isrequired.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or

superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the

aircraft at the time the aircraft issold.

(3) A list of defects furnished to a registered owner or operator under

§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

Records of maintenance and engine replacement can be kept as well as prop changes and any repairs or

fixes to the gimbal, electronics, and camera system. Maintenance records may not apply due to the

relatively inexpensive cost of completely replacing parts instead of repair them.
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Conclusion

I’m (Richard A. Blevins) a retired Chief Master Sergeant from the U.S. Air Force, (28 years). I hold a 

current Private Pilot certificate #3361660. In addition, for the last nine years I was the Training Manager 

for Bell Helicopter designing courses to meet FAR 14.145 requirements. Currently I’m the Director of 

Aviation for Northeast State Community College responsible for developing an Airframe / Powerplant, 

program and soon a UAS certificate program. 

During my time at Bell Helicopter we developed technical training courses on FAA regulations, Human 

Factors in Aviation Maintenance, Aircraft Maintenance Documentation, etc. I take aviation very 

seriously and understand the consequences of lack of focus. 

Operating sUAS in the NAS is a very serious matter that requires situational awareness, understanding 

the regulations, ensuring the area is safe, and knowing if other aircraft are in the area or if a “Temporary 

Flight Restriction” is in place. 

I will use my training and experience to ensure safe operations of the UAS.

Richard A. Blevins Petition for exemption demonstrates the appropriate safeguards and criteria, including

weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS

and national security concerns Congress expressed in Section 333 of the FAA Modernization and Reform

Act of 2012 (FMRA), which will permit safe commercial operations of the DJI and 3D Robotics aircraft. 

By granting this Petition, theFAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing

Richard A. Blevins to safely operate the DJI and 3D Robotics aircraft commercially within theNAS.

Thank you for considering my requests in these exemptions. Please contact me if you have any 

questions or concerns.

Manufactures instruction manuals are available uponrequest.

Respectfully,

Richard A. Blevins

817 Haylees Way

Piney Flats, TN 37686-4050

423.946.0579

 Home: Rjm3@charter.net Office: rablevins@northeaststate.edu