Matthew Anello

Blu Skye Media, Inc.

P.O. Box 41038

San Jose, CA 95160

US Department Of Transportation

Federal Aviation Administration

800 Independence Ave SW 

Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and CFR Part 

11; I, Matthew Anello, owner and operator of Small Unmanned Aircraft Systems (UASs), request to be 

exempted from the Federal Aviation Regulations (FAR) listed below so that I, Matthew Anello may 

operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted

within and under the conditions outlined herein or as maybe established by the FAA as required by 

Section 333.

I, Matthew Anello, am owner of Blu Skye Media, Inc. a real estate marketing company. I am requesting 

exemption from regulations listed below to perform aerial photography and videography of Real Estate 

and Landscape. All operations will be performed with the public's safety and right to privacy safe 

guarded at all times.

Matthew Anello's UASs is a rotorcraft weighing less than 55 pounds including payload (The DJI Phantom 

3 Vision Quad Copter). It operates at a speed less than 50 knots and has the capability to hover and 

move in the vertical and horizontal plane simultaneously. It has an auto return to launch point when 

battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area 

as described below and at 200 feet AGL or less with an observer located close at hand as to make voice 

communication possible. These operations will not create a hazard to users of the nation’s airspace, 

public nor the environment.

I, Matthew Anello, respectfully request the grant of an exception to the following specific sections of the 

Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 

91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

I, Matthew Anello submit this application in accordance with the Reform Act ,112 P.L. 95 331-334, 

seeking relief from any currently applicable FAR'S operating to prevent Matthew Anello future 

commercial use of small UASs to operate in the national airspace system as described below. The reform 

Act section 332 provides for such integration of civil unmanned aircraft into our national airspace 

system as it is in the public's interest to do so. Matthew Anello's UASs meet the definition of "small 

unmanned aircraft" as defined in Section 331 and therefor the integration of these UASs are expressly 

contemplated by the Reform Act. I, Matthew Anello, would like to operate its light weight UASs prior to 

the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.
The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in national airspace before completion of the rule making required under 

Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required 

to determine which UASs do create a hazard to users of the national airspace system or the public or 

pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in National 

Airspace System, the secretary shall establish requirements for the safe operation in national airspace.

DJI Phantom 3s are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots 

and have the capability to operate in the vertical and horizontal plane simultaneously. The UASs will 

operate only within the line of sight of the operator within a protected flight area and at 200 feet AGL or 

less. These will not present a hazard to the national airspace nor the public.

The very small nature of these UASs combined with the safe guards presented below, will allow for the 

safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow 

commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas 

and altitudes they will operate approval of this exception presents no national security issues and 

absolutely minimal safety concerns which have been mitigated through our rigorous risk management 

process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions 

utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of 

aerial photography thereby benefiting the greater public's interest. Accordingly, the applicant requests 

that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of Matthew Anello,

1. Flights will only occur in the day time hours,

2. Flights will be operated in the line of sight of the operator (PIC) and Observer, (VSO)

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by

manufacturers recommendations,

4. The UASs will weigh less that 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew will be at a minimum of operator( PIC) and an observer and/or camera operator(VSO),

7. Operator and crew will remain in contact during the flight operation,

8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons 

in the area,
9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce 

the chance of violating anyone's privacy.

10. All required FAA clearances, will be obtained and distances from airports strictly observed.

11. All UASs will have the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working.

12. Flights will only operate in VFR conditions.

14. UASs have a function on the control to tell operator the distance away from the operator and its 

battery power remaining.

15. Flight team will communicate by voice and the use of two-way radio if the area is too big to hear 

voice from all team members.

16. When operating over or near water the UASs will be equipped with flotation devices so that 

recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Matthew 

Anello's UASs flights permits exception from Part 21 because they meet an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in 

consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Matthew Anello's USAs meets or exceeds each of these elements.

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights at or 

under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Because the SUAs in 

unmanned and will not carry a pilot or passengers, the proposed operations can achieve a high level of 

safety of operation without the required pilot license.

14 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and registrations. These are 

inapplicable for the same reasons stated above.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable.

14 CFR 91.9 (b) (2) Civil Aircraft Flight Manual in Aircraft

14 CFR 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Blu Skye Media, Inc. operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No's 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.
14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Blu Skye Media, Inc. will only operate 

its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully 

reviewed for hazards and minimizes the presence of any persons not essential for these operations. 

Flights will only be over private property that the owner has consented and all persons within this video 

area also give consent for this filming. Compared to flight operations of conventional and traditional 

aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs 

operations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial 

photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. 

Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of 

populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery operated 

and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or 

almost erased. The granting of the use of these small UASs by Matthew Anello will give potential sellers 

of Real Estate a competitive edge in the market place.

Granting Matthew Anello the above exemption will allow for the expansion of UAS systems into the 

future for the safe conduct of free enterprise and the enjoyment of the masses.

I, Matthew Anello, respectfully requests the FAA grant its exception without delay. The FAA has the 

authority to issue the exemption sought by Matthew Anello pursuant to the Federal Aviation Act, 85 P.L. 

726 (1958) as amended (the ACT).

Sincerely

Matthew Anello

Owner/Operator