I would like to be considered under the new 'blanket' COA for flights at or below 200 feet, within 

VLOS and safe separation from airports or heliports. Unmanned Aircraft System (UAS) usage for for 

aerial photography, real estate, architectural, engineering, construction industry sites, agricultural , 

motion picture and television operations. I have been a UAV pilot for over 30 years, am in good health 

and have logged many thousands of hours of UAV experience as a hobbyist. Additionally I have built 

UAV air frames for 20 years. I also currently product UAV airframes for multi-rotors and winged 

aircraft, and have had the privilege of working in almost every area of this industry.

With regard to my initial Section 333 request. I will be using a AME WindWalker, a AME RidgeRacer, 

AME CamBot, and an AME AgBot multicopters. All of these airframes have been extensively tested 

for durability and all electronics are commercially available from respected vendors, with the flight 

controllers coming from 3dRobotics. Most of these models have been flying for more then 12 months 

and hundreds of hours with no incidents. As part of the application process, we will going forward 

keep detailed flight and maintenance logs of all equipment and pilots, as well as detailed incident 

reports should any be needed.

In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC 

44704, and in consideration of the size, weight, speed, all aircraft meet the conditions of Section 333. 

- Manned aircraft conducting aerial photography operations can weigh thousands of pounds or more, 

are operated by an on board pilot and may carry other on board crew members, as well as carry large 

quantities of fuel. The petitioners unmanned aircraft (UA) weighs between 2 and 8 pounds of flight 

weight. The pilot and crew will be remotely located from the aircraft. The limited weight and 

construction reduces the potential for harm to persons or damage to property in the event of an incident 

or accident. The risk to an on board pilot and crew during an incident or accident is eliminated with the 

use of a UAS for the proposed operation.- Manned aircraft are at risk of fuel spillage and fire in the 

event of an incident or accident. 

Both UAS have the capability to operate safely after experiencing certain in-flight contingencies or 

failures and uses an auto-pilot system to maintain UAS stability and control. Both UAS are also able to 

respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver. These safety features

provide an equivalent level of safety compared to a manned aircraft holding a restricted airworthiness 

certificate performing a similar operation. Both UAS being under 10 lbs., will provide me with the 

ability to provide aerial vistas for my customers, without resorting to the high cost, or risk to the public,

thereby providing public benefit with limited impact. Manned aircraft are at risk of fuel spillage and 

fire in the event of an incident or accident. 

Request relief from 14 CFR 91.405(a) Maintenance required, 91.407(a)(1) Operation after 

maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(2) Inspections, and 91.417(a)

and (b) Maintenance records. Operating documents contain preflight and post flight checks for the 

UAS. Request relief from 91.409(a)(1) because of alternate inspection requirements of 91.409(a)(2). 

Operating documents, as should be sufficient to ensure that safety is not adversely affected. 

Requested relief from 14 CFR 61.113(a) and (b), Private pilot privileges and limitations. I plan to 

operate in uncontrolled airspace and over private property with controlled access. Given: 1) the similar 

nature of the petitioners proposed operating environment to that of Astraeus, 2) the parallel nature of 

private pilot aeronautical knowledge requirements to those of commercial requirements as discussed in 

Exemption No. 11062, and 3) the limited airmanship skills necessary to operate the UAS, the FAA 

found that the additional manned airmanship experience of a commercially certificated pilot, would not

correlate to the airmanship skills necessary for the petitioners specific proposed operations. Further 
operation of a Small UAV is not entirely analogous of a manned aircraft and the assumption that they 

are the same could lead to increased risk.

As the PIC, I will enroll in appropriate training for fixed wing aircraft, if required. I will operate the 

UAS in a manner consistent with and including evasive and emergency maneuvers while maintaining 

appropriate distances from people, vessels, vehicles, and structures. 

Request Relief from 14 CFR 91.121 Both UAS uses information generated from GPS to transmit 

altitude information to the PIC. 

Requested relief from 91.151(a) Fuel requirements. No fuel required. Requested relief from 91.151(a) 

Fuel requirements. No fuel required. 

This serves as a summary which you may publish in the Federal Register.