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February 3, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition of Blade Imaging, LLC, for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012.

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Blade Imaging, LLC, (hereinafter referred to as “Blade Imaging”) hereby applies for an exemption 

from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of 

small-unmanned aerial system (sUAS).

The exemption is based upon information outlined in this document, Blade Imaging’s enclosed 

Operations Manuals, including DJIs UAS manufacturer’s manuals and guides, and any other 

requirements established by the FAA pursuant to Section 333 of the Reform Act. 

This exemption would permit commercial operations by Blade Imaging, which will use the DJI 

Inspire 1, and DJI Phantom 3 Professional to conduct sUAS flight training, education, general 

photography and videography, real estate photography and videography, film and movie production, 

wildlife surveys, pipeline patrols, infrastructure and industrial inspections, news gathering, 

agricultural surveys, demonstration flights, and any other related entities/activities that can utilize the 

safe and efficient operation of sUAS aircraft. Blade Imaging’s operation under the exemption will be 

subject to strict operating requirements and conditions to ensure a level of safety equivalent to that of 

currently authorized operations using manned aircraft and under conditions as may be modified by 

the FAA as required by Section 333.

Blade Imaging will operate under controlled visual flight rules (VFR) conditions at low altitude in 

airspace that is permitted in accordance with the approved Certificate of Authorization (COA). Blade 

Imaging will operate the sUASs with pilots that meet Blade Imaging’s pilot requirements that strictly 

coincides with the FAA’s requirement that operators must possess an FAA Issued Pilot Certificate. 

Finally, the FAA Air Traffic Control (ATC) will approve in advance the airspace in which the sUASs 

will operate. 

Blade Imaging respectfully submits this request for an exemption due to its operation of sUASs. In 

its current form, the operations Blade Imaging will be conducting replace comparatively hazardous 

operations now conducted with both fixed and rotary winged aircraft by other companies. The FAA 

can have confidence that Blade Imaging’s operations will be conducted at an equivalent level or 

greater level of safety than that of sUASs counterparts of larger manned aircraft. Approval of this 

exemption would therefore enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities under section 333(c) of the Reform Act to “establish requirements 

for the safe operation of such aircraft systems in the national airspace system.”
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For your convenience, Blade Imaging has organized this Exemption request as follows:

I. Petitioner’s Description ...................................................................................................................2

II. Relevant Statutory Authority...........................................................................................................3

III. Qualification for Approval Under Section 333 of the Reform Act .................................................4

IV. Description of Proposed Operations................................................................................................5

V. Regulations From Which Exemption is Requested......................................................................... 6

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in Command6 

B. 14 CFR § 91.103: Preflight Action............................................................................................7

C. 14 CFR § 91.109(a): Flight Instruction .....................................................................................8

D. 14 CFR § 91.113: Right-of-Way Rules.....................................................................................8

E. 14 CFR § 91.119: Minimum Safe Altitudes.............................................................................. 9

F. 14 CFR § 91.121 Altimeter Settings....................................................................................... 10

G. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions................................. 10

H. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections11

VI. Public Interest................................................................................................................................ 11

VII. Privacy..................................................................................................................................... 13

VIII. Federal Registry Summary ......................................................................................................... 13

IX. Conclusion ..................................................................................................................................... 13

I. Petitioner’s Description

Blade Imaging, LLC, is headquartered in Bend, Oregon. Their core competencies are providing 

services of sUAS in flight training, education, general photography and videography, real estate 

photography and videography, film and movie production, wildlife surveys, pipeline patrols, 

infrastructure and industrial inspections, news gathering, agricultural surveys, and demonstration 

flying in a compliant and safe environment. Blade Imaging plans on providing a wide range of 

services as the sUAS market expands.

The executive management at Blade Imaging has over 20 years of experience in aviation and more 

than two years experience working with unmanned aerial systems. The President and CEO of the 

company has worked with both military and civilian manned and unmanned aircraft supporting 

maintenance and flight operations. The Vice President has over four years experience managing 

large-scale projects and developing processes to make business operations safe and efficient. The 

Chief Pilot possesses a Private Pilot Rotorcraft License with Instrument Rating. He has flown as a 

crewmember aboard military helicopters for over 5 years both domestically and abroad, as well as 

flown piston helicopters for over two years in controlled and uncontrolled airspace without incident. 

That time and experience has provided the knowledge and tools necessary to ensure safe operations 

within the National Airspace System (NAS).

Blade Imaging’s goal is to operate in an accident-free environment by:

 Ensuring all employees are trained on the latest safety procedures for the sUAS they operate 

as well as Blade Imaging’s safety procedures outlined in the Operations Manual.
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 Being proactive when performing pre-flight operations and identifying any potential safety 

hazards.

 Demonstrating the ability to identify and appropriately eliminate hazards and risks to the 

aircraft as well as persons involved in the flight. 

The contact information for Petitioner is as follows:

Blade Imaging, LLC

17295 Scaup Drive

Bend, Oregon 97707

Member Managers:

Arin Hanohano

Cell: 541-508-6065

Kelsie Hanohano

Cell: 541-350-8935

II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress’ goal in passing Section 333(a) through 

(c) of the Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system.” Pursuant to Section 333 of the 

Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may 

operate safely in the National Airspace System (NAS) before completion of the formal UAS 

rulemaking, based on the following considerations: 

 The weight, speed, and operational capability of the UASs

 Operating the UAS in a relatively close proximity to airports or other populated areas

 UAS will be in direct visual line-of-sight with the observer and pilot

If the Secretary determines that such vehicles “may operate safely in the National Airspace System, 

the Secretary shall establish requirements for the safe operation of such aircraft in the National 

Airspace System.”

Additionally, the FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. A party requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined in 40101 of the Act, 
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from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of the sections.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under Section 

333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The 

proposed operations would permit Blade Imaging the use of sUASs under controlled conditions in 

airspace that is: (1) predetermined; (2) exercises controlled access; and that (3) provides an 

increased level of safety beyond existing comparable operations when fixed or rotary winged 

aircraft are used.

Blade Imaging uses sUASs that are multi-rotor, weighing less than 25 pounds including payload. 

They operate, under normal conditions, at speed not to exceed 45 mph. They have the capability to 

hover in a location and move in the vertical and horizontal plane. Blade Imaging’s sUASs will 

operate in line-of-sight, under VFR flight conditions, and within a working environment similar to 

the Sterile Cockpit Concept employed by Manned Commercial Aircraft Pilots during critical phases 

of flight. Blade Imaging will operate at or below 500 feet Above Ground Level (AGL) and will file 

a Notice to Airmen (NOTAM) for each flight operated in controlled airspace. All required 

permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies prior to operating 

a sUAS. Given the small size of the UASs involved and the restricted sterile environment that they 

will operate in, this exemption falls within the zone of safety and demonstrates an equivalent level 

of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption 

pending completion of formal rulemaking. Also, due to the aforementioned conditions, approval of 

the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in the 

public interest.

IV. Description of Proposed Operations

To assist the FAA in its safety assessment said proposal, below is a summary of operational 

limitations and conditions that will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Blade Imaging will designate a Pilot in Command (PIC) for each mission.

3. Flights will be operated within line-of-sight of the PIC and observer.
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4. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power of no less than 

20%.

5. Flights will be operated at an altitude of no more than 500 feet AGL.

6. Flights will be operated at a lateral distance of at least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or who 

have not signed a waiver in advance of the operation.

7. Minimum crew for each operation will consist of the sUAS PIC and a visual observer.

8. The sUAS PIC will be an FAA licensed airman with at least a private pilot’s certificate, 

third class medical, and a current check required by 14 CFR Part 61.56 in an aircraft in 

which the PIC is rated on his or her certificate.

9. The sUAS will operate only within a confined “sterile environment” as explained prior. 

10. A site inspection will be conducted prior to the operations at a particular location. On the 

day of the mission, the management person with operational control and the PIC will 

concur on dispatching of the mission.

11. A briefing will be conducted regarding the planned sUAS operations prior to each 

mission. It is mandatory that all personnel who will be performing duties within the 

boundaries of the mission area be present for the briefing.

12. Blade Imaging’s crew will use checklists and callouts that will be implemented. 

13. All sUASs will be maintained in accordance with the manufacturer’s guidelines. 

14. In the event of an accident involving Blade Imaging’s sUAS, that mission’s operators 

will cease and the accident reported to the NTSB and AFS-80.

15. PIC and Visual Observer will at all times be able to communicate by voice.

16. PIC, Visual Observer, and any additional required operational personnel will possess the 

required minimum skills and education applicable to safe and efficient operation of the 

sUASs.

17. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate governmental 

agencies.

18. If the sUAS loses communications signal, the sUAS will have the capability to return and 

land at a pre-determined location within the Mission Area. 

19. Contingency plans will be in place to safely terminate flights if there is a loss of 

communication between the PIC and the observer.

20. The sUAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

21. Blade Imaging, by following operational procedures and operating within the 

manufacturers recommended parameters, will assure no individual’s privacy is violated.

22. The PIC will contact the Air Traffic Control (ATC) facility or appropriate airspace 

controlling authority prior to operating in airspace other than Class G.

V. Regulations From Which Exemption is Requested

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in 

Command

B. 14 CFR § 91.103: Preflight Action
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C. 14 CFR § 91.109(a): Flight Instruction

D. 14 CFR § 91.113: Right-of-Way Rules

E. 14 CFR § 91.119(c): Minimum Safe Altitudes

F. 14 CFR § 91.121: Altimeter Settings 

G. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

H. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in 

Command

Section 61.113 (a) & (b) limit private pilots to non-commercial operations. Conventional aircraft 

carry a pilot, passengers, and cargo during their operations. Having this rule in place ensures the 

skill and competency of the pilots. However, the DJI sUASs are controlled remotely and do not 

carry any passengers or cargo. Blade Imaging respectfully proposes that the FAA take into account 

the characteristics and procedures of the particular UAS in reference to requirements for PIC. 

Blade Imaging proposes that their operations of the DJI sUAS in commercial use not require the 

Pilot to hold a commercial pilot certificate, but rather a private pilot certificate. Blade Imaging 

proposes the following requirements for a PIC:

1. The PIC must possess a Private Pilot’s Certificate and a valid third-class medical 

certificate.

2. The PIC must have accumulated and logged a minimum of 200 flights and 25 hours of 

total time as a UAS pilot and at least ten hours logged as a UAS pilot with a similar UAS 

type (fixed-wing or multi-rotor) and five hours in type of UAS aircraft he/she will operate 

(DJI primarily).

3. The PIC must have accumulated and logged a minimum of five hours as UAS pilot with 

the make and model of UAS to be utilized for operations under the exemption and three 

takeoffs and landings within the preceding 90 days.

4. The PIC must also meet the flight review requirements specified in 14 CFR Part 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate.

Equivalent Level of Safety

Blade Imaging utilizes both a PIC and a Visual Observer to increase safety during flight 

operations. While the PIC is concentrating on flying the UAS, the Visual Observer has the 

ability to oversee safety of the entire operation. The Visual Observer will always remain 

within 10 feet of the PIC when the UAS is airborne to quickly communicate any observations 

if an emergency should happen. Procedures developed by Blade Imaging far exceed the 

current safety requirements established by the FAA. Blade Imaging respectfully requests the 

option to use a PIC and Visual Observer crew and the second crewmember not having to 

possess a private pilot certificate. 

B. 14 CFR § 91.103: Preflight Action
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Blade Imaging requests an exemption from the preflight actions requirements of 14 CFR 91.113 

that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight.

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been advised 

by ATC;

(b) For any flights, runway lengths at airports of intended use, and the following takeoff 

and landing distance information:

(1) For civil aircraft for which an approved Airplane of Rotorcraft Flight Manual 

containing takeoff and landing distance date is required, the takeoff and landing 

distance data contained therein; and

(c) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature.

Equivalent Level of Safety

Blade Imaging will only operate under VFR conditions within line of sight of its designated takeoff 

and landing zones. Steps the PIC and additional personnel must follow to assure that the weather 

will be adequate to complete the mission under VFR conditions will be implemented. In addition, 

the PIC will adhere to all manufacture’s required preflight checks of the aircraft, review aircraft 

performance data, and become familiarized with their sterilized area of operations prior to 

conducting any flights.

C. 14 CFR 91.109(a): Flight Instruction

Blade Imaging requests an exemption from 14 CFR 91.109(a) Flight Instruction, in which “no 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls”. Small-unmanned aerial systems 

by design allow only a single remote to control the aircraft during flight. Should control need to be 

passed from one pilot to another during sUAS flight instructin, it would take place by physically 

handing off the remote control. Blade Imaging respectfully requests to conduct flight instruction 

with the use of a single handheld remote control.

Equivalent Level of Safety

Unlike manned aircraft that are used for pilot instruction, sUAS have an added level of safety due 

to their size, weight, and speed while not having to carry fuel or passengers. The flight of a sUAS 
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will only take place within the confines of a sterilized area of operation. During times of flight 

training, the sterilized area will contain no personnel other than the instructor pilot and student who 

will remain vigilant and side-by-side during all portions of flight. The sterilized area will be open 

and free of buildings or obstacles that could present hazards during times of instruction. Should the 

student begin to lose control, the instructor will be within reach to promptly take the remote control 

and right the aircraft. For an additional measure of safety, each aircraft Blade Imaging operates for 

flight instruction possesses a RTH(Return to Home) function that, when commanded, will instruct 

the aircraft to safely return to its takeoff point and land under its own control.

D. 14 CFR 91.113: Right-of-Way Rules

Blade Imaging requests an exemption from 14 CFR 91.113 Right-of-Way rules, requiring vigilance 

by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this 

section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not 

pass over, under, or ahead of it unless well clear. Blade Imaging operates pilotless sUASs and 

cannot comply with these rules as they have been written.

Equivalent Level of Safety

Blade Imaging operates sUASs at or below an altitude of 500 feet AGL; well below the normal 

operating altitude of other, larger aircraft. Blade Imaging’s Operations Manual specifies that a PIC 

with experience will oversee each mission and has knowledge of the see-and-avoid rules. A Visual 

Observer will assist the PIC in loking for aircraft entering the operations area. It is the 

responsibility of the PIC to cease operations and land the sUAS immediately whenever an aircraft 

comes into the vicinity creating a potential threat. Operations cannot resume until the threat is 

clear. 

E. 14 CFR 91.119: Minimum Safe Altitudes

Blade Imaging requests an exemption from the minimum safe altitude requirements of 14 CFR 

91.119 that details the minimum safe altitudes under which aircraft may operate:

 Over any congested area of 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.

 Over other than congested areas at 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.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can 

be operated “without hazard to persons or property on the surface”, provided that “each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters 

by the FAA”. With Blade Imaging’s intended operations, the sUAS is normally operated at or below 

500 feet AGL. Additionally, due to the nature of the proposed operations, the sUAS will maintain a 

lateral distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and 

from people not associated with the operation. 
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Equivalent of Safety

Compared to the flight of normal aircraft, Blade Imaging’s sUAS aircraft weigh less than 25 pounds, 

and, given the lack of flammable fuel, pose far less risk to persons or property than with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the sUAS, 

as well as the location where it is operated. As set forth in the Operations Manual, the sUAS will be 

operated in a sterile area, where buildings and people will not be exposed to operations without their 

pre-obtained consent. Because of the advance notice to the property owners and participants, all 

knowingly affected individuals will be well aware of the planned flight operations as set forth in the 

Operations Manual. Furthermore, operating at low altitudes, the sUAS will not interfere with aircraft 

that are subject to the minimum safe altitude regulations. Finally, the sUAS that Pinnacle operates 

has safeguards built into its design that warns pilots when approaching areas designated by the 

manufacturer as “no fly zones”. This causes the sUAS to initiate a descent to safe altitude or landing.

F. 14 CFR 91.121: Altimeter Settings

Blade Imaging is seeking an exemption from 14 CFR 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the 

sUASs have GPD altitude readouts as opposed to barometric altimeters.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in Blade 

Imaging’s Operations Manual during the pre-flight routine. Prior to operations, Blade Imaging will 

confirm the altitude of the launch site shown on the GPS altitude indicator. Moreover, the PIC will 

use the GPS altitude indicator to constantly monitor the sUASs height, thus ensuring operation at 

safe altitudes. 

G. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Blade Imaging requests an exemption from 14 CFR 91.151(a)’s fuel requirements for flight in VFR 

conditions. Section 91.151 states:

(a) 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 25 minutes; or

2. At night, to fly after that for at least 45 minutes.

The batteries powering Blade Imaging’s sUASs provide approximately 18 minutes of powered flight 

for the DJI airframes. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS flight 

could not be conducted. Given the limitations on the sUASs proposed flight area and the location of 

its proposed operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed.
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Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to terminate with no less 

than 20% reserve battery power still available. This restriction would be more than adequate to safely 

return the sUAS to its planned landing zone from anywhere in the area of operation. The fuel 

requirement guidelines of Section 91.151(a) were intended to alleviate risks for larger manned 

aircraft that could operate great distances from suitable landing areas. Due to the limited distance the 

sUASs can fly, the small size of the operations area, and all operations being conducted within visual 

line-of-site, the sUASs maintain the ability to quickly return to their point-of-origin when necessary.

H. 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Blade Imaging is seeking an exemption from the maintenance inspection requirements contained in 

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(1) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) states that 

each owner or operator of an aircraft “shall have the aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections... have discrepancies repaired as prescribed in part 

43 of this chapter”. Part 43 and these sections only apply to aircraft with an airworthiness certificate; 

therefore an exemption to these regulations is needed, as the sUASs Pinnacle operates will not 

possess an airworthiness certificate.

Equivalent Level of Safety

Maintenance and inspections will be performed in accordance with the Blade Imaging Operations 

Manual and the sUASs User’s Manuals, therefore ensuring an equivalent level of safety. As provided 

in the Operations Manual, Blade Imaging will perform required maintenance, keep a log of any 

maintenance performed, and the operator will confirm that the sUAS is in working order prior to 

initiating flight. The operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. Due to the sUASs size 

and carrying capacity, and the fact that flight operations will only take place in restricted areas for 

limited periods of time, if a mechanical issue arises it creates less risk than that associated with 

conventional aircraft performing the same operation.

VI. Public Interest

Public interest is furthered with granting Blade Imaging’s exemption request. Congress’s national 

policy favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those proposed in this petition. Blade Imaging’s goals are to help facilitate and 

promote the safe integration of sUASs into the NAS, while providing education and awareness of 

sUAS operations and capabilities. The following is not an exhaustive list of areas of interest:

 Movies and Videography
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Small-unmanned aerial systems provide unparalleled capability in their ability to quickly 

adapt to any situation. Unlike traditional filming methods that can require excessive amounts 

of time to change camera angles for different views, sUASs are light, stabilized platforms that 

can quickly maneuver through the air into position for capturing every angle in high definition 

video.

 Newsgathering

Helicopters have been utilized in newsgathering for many years. They have provided the 

ability to easily maneuver into positions that allow for multiple viewing angles of a scene. 

However, the technology has now progressed to allow for much smaller, cost effective sUAS 

aircraft to capture breaking news with much less risk to persons or property. Since sUAS are 

dramatically smaller in size and weight in comparison to manned aircraft, carry no fuel, and 

operate within sterilized areas, they provide an increased margin of safety that is unrivaled.

 Real Estate

Real estate is an area that sUAS platforms have grown in popularity. Whether the real estate 

professional is listing commercial or residential properties, the sUAS enables them to capture 

dramatic shots for each property that would otherwise require costly and noisy helicopter 

operations. In addition to being able to being able to capture spectacular exterior photos and 

videos, Blade Imaging’s sUAS platforms possess internal sensors for stabilization while 

operating in areas where a GPS signal is not available. This adaptability gives real estate 

professionals a high quality, cost effective, safe, and simple solution to an otherwise costly 

and neighborhood-disrupting endeavor.

 Search and Rescue/First Responders

Search and rescue/first responder personnel will also benefit from sUASs capabilities of realtime video and surveys that Blade Imaging provides. The sUASs ability to inspect dangerous 

or unstable areas without placing personnel at risk is monumental in saving lives. In addition, 

the sUASs can survey large areas of land to identify areas of interest at an expedited rate when 

compared to search and rescue personnel on foot. The sUAS excels over traditional manned 

aircraft during these instances in both cost and the safety of personnel on the ground.

 Law Enforcement

Small-unmanned aerial systems are designed for rapid deployment and covering specific areas 

of interest; these are key components for law enforcement officers. Recent developments in 

sUAS platforms are allowing for easy transition between HD photos and video. Utilizing a 

sUAS would prove useful by increasing officer safety when identifying areas of interests with 

potential threats as well as accident scene investigations and monitoring undercover 

operations from greater distances. 

 Agriculture and Conservation
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Blade Imaging will demonstrate to farmers the advancements in agriculture analysis that a 

sUAS can provide in soil property and moisture analysis, plant counting, crop stress analysis, 

erosion analysis, 3D mapping, and other areas of agricultural land management. The sUAS 

can fly pre-programmed missions that allow the operator to gather precise data. While the 

sUAS is in flight, the pilot can assume full control to inspect areas of interest. Once it has been 

examined, the sUAS will resume its flight plan from the last point analyzed. Equipped with an 

IR camera, the sUAS can also provide farmers with real time video of locations of wildlife 

that potentially threaten their crops. 

VII. Privacy

All flights will be conducted in accordance with any state, federal, or local laws regarding privacy. 

Blade Imaging has inserted a section into its Operations Manual to protect the public privacy. There is 

great concern to maintain an expected level of public privacy during the use of sUASs. Guidelines in 

the Operations Manual outline Blade Imaging’s policy in notification of residential property owners, 

businesses, and other organizations when sUAS operations will be conducted in their area.

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be deemed that publication is needed:

Blade Imaging, LLC, seeks an exemption from the following rules:

14 CR Part 61.113 (a) and (b); 14 CFR 91.103; 14 CFR 109(a); 14 CFR 91.113; 14 CFR 91.119; 14 

CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(2); 14 

CFR 91.417 (a) and (b).

IX. Conclusion 

In meeting the criteria provided in Section 333 of the Reform Act of 2012, considering the size, speed, 

capabilities, utilization of visual line-of-sight, and operating constraints around controlled airspace 

and populated areas, Blade Imaging has demonstrated justification for the grant of the requested 

exemptions to operate sUASs in the defined areas. Approval of this exemption request will allow 

Blade Imaging, LLC, to conduct commercial operations with small-unmanned aerial systems. Due to 

each of the sUASs size, weight, lack of flammable fuel, and lack of passengers or crew on board, the 

risk to the general public and property owners are virtually eliminated.

If you have any questions or require any additional information, please do not hesitate to call.
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Regards,

Arin Hanohano, President 

Blade Imaging, LLC

Cell Phone: 541-508-6065

Email: Hano2746@Gmail.com

Attachments:

*Pursuant to Section 333 Petition Guidance & Checklist PDF file located on FAA website, aircraft 

manufacturer manuals have been withheld in accordance with the statement “aircraft manuals are not 

necessary”. 

The above are submitted as Confidential Documents under 14 CFR 11.35(b) and exempt from 

disclosure under the Freedom of Information Act, 5 U.S.C. 552 et seq., and any other requirements 

established by the FAA pursuant to Section 333 of the Reform Act. 
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