US Department ofTransportation Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 ofthe Federal Aviation November 11,2015 U.S Department ofTransportation DocketManagement System 1200 NewJersey Ave., SEWashingtonDC 20590 Re: ExemptionRequest Pursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR91.7(a); 14 CFR91.9(bX2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(l) and (2); 14 CFR 91.417(a) and (b) Dear Sir orMadam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") And 14 CFRPart 11 ofUnmanned Aircraft Systems (UAS), DerrickWayne BlountHereby applies for ·an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofDesignated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. Thank you in advance foryour consideration.

DerrickWayne Blount 

### 8211 SW 

### 11th St. North Lauderdale, FL 33068 Blount247@gmail.com

1Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas: 1. ReaiEstate 2. PhotographyNideography 3. LandSurveying/Crops 4. Treelnspections 5. Filming. As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this documentunder controlled conditions in the NAS that would be a) limited b) controlled c)predetermined and d) safe. Approval ofthis exemption would increase public awareness ofUAS operations and enhance safety to aid in fulfilling the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

.... establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant is

DerrickWayne Blount 8211 SW 11th St. North Lauderdale, FL 33068 Blount247@gmail.com

From which the exemption is requested: 14 CFRPart 21 subpartH 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR91.203 (a) 14 CFR 91.405 (a) 14 CFR 91.407 (a) 14 CFR 91.409 (a) 14 CFR91.417 (a): Grants ofexemption in circumstances similar in all material respects, InGrants of ExemptionNos. 11062 to Astraeus Aerial (see DocketNo. FAA-2014-0352), 11109 to Clayco, Inc. (see DocketNo. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213 to Aeryon Labs, Inc. (see

2DocketNo. FAA-2014-0642), and 12645 to Allied Drones (see DocketNo. FAA- 2014-0804) ExemptionNos. 11062, 11109, 11112, 11213, and 12645; Nos. 11062, 11109, 11112, 11213, and 12645. DerrickWayne BlountWill operate one ormore ofthe Following model UAS Yuneec Q500 4K, Yuneec H920 Safety requirements. The approval ofthis application presents no national security issues. Regardingthe level ofsafety surroundingthe proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grant the requested exemption. AIRCRAFT AND EQUIVALENTLEVEL OF SAFETY The operation limitations proposed for an equivalent orhigher level ofsafety because operations will further enhance the safety ofthe persons and/orproperty using conventional aircraft. These limitations and conditions to whichthe applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. Itweighs less than 4 pounds with battery and camera. 2. The UAS, depending onthe model in operation, will have a maximum operating speed ofno more than 50mph. 3. Flightswill be operated within line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO). 4. Maximum flight time for each operational flight will be depending onthe UAS model in operation, butwill not exceed 30 minutes. Flights will be terminated at 25% battery powerreserve or 30 minutes offlight time whichever occurs first. 5. Flights will be operated at an altitude ofno more than 400 feet Above Ground

3Level (AGL) and not more than 200 feet above anelevated platform from which filming is planned. 6. Minimum crew for each operation will consistofthe UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO). 7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours onthe designated UAS. 8. A safety briefing will beperformedpriorto eachday's flights consisting ofall the days' Production activities. 9. All flight activities will be logged. 10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closerthan a 5 mile radius ofthe geographic center/ Airport Reference Point (ARP) ofa tower controlled or uncontrolled airport. 12. Flights will not be closerthan a S-mile radius ofthe geographic center/Airport. 13. The operator will do a pre check ofaircraft prior to each flight. And log each flight. 14. The operator will obtain verbal/written consent ofall persons involved with the planned operation and ensurethat only consenting persons will be allowed within 1

00 feet ofthe flight operation, and the radius may bereduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department of Transportation required underthe FOM. Withthe advanced permission ofthe FSDO, operations at closerrange may be approved. 15. The PIC and VOwill have been trained in operation ofUAS and receive up to date information for the particular UAS to be operated. 16. The PIC and VO will be able to communicate by voice and/or radio at all

4times. 17. The PIC will abide by all rules 18. Communications withthe remote controller and the UAS will have the capability to return to a predetermined location within a designated location and land autonomously. 19. The UAS will have the capability to abort a flight in case ofemergencies with an automated "Return Home and Land" function. 20. The UAS will have the capability to abort a flight in case ofunpredicted obstacles, weather, oremergencies such as low battery. 14 C.P.R. Part 21, Subpart H: Airworthiness Certificates 14 C.P.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) 

### (1). Giventhe size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal AviationAct (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate in the restricted environment and underthe conditions proposed will be at least as safe,

or safer, than a conventional aircraft (fixed wing orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilotnor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by boththe operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree ofsafety to the public and property owners than



### 5conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part21, Subpart H. Lastly, application ofthese same criteriademonstrates thatthere is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft Theregulationrequires: Whenmarks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entranceto the cabin, cockpit, orpilot station, inletters not less than 2 inches nor more than 6 inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable 14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft. The operatormust also display onthat aircraft near each entrance to the cabin, cockpit, orpilot 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. Even thoughthe UAS will have no airworthiness certificate, an exemption may be needed, as the UAS will have no entrance to the cabin, cockpit orpilot station on whichthe word lettering will be impossible. The word "Experimental" will be placed onthe fuselage in compliance with §45.29 

### (f). US Department ofTransportation February 20, 2015. The equivalent level ofsafety will be provided by having the UAS marked "Experimental" canbe placed. Given the size ofthe UAS, two inch on its fuselage as required by §45.29 

### (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.P.R. §61.113 (a) and (b The proposed UAS operations may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots orpassengers nor property. The risks attendant to the 

### It is believed that the

6operation and limitations setforth in the FOMwill equate to the safe operation of theUAS. 14 C.F.R. §91.7{a): Civil AircraftAirworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Giventhe size ofthe aircraft for maintenance and use ofsafety checklists prior to each flight, an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane

orRotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof The UAS, given its size and configuration has no ability orplace to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, but because there is no room orcapacity to carry such an item onthe aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate access to it. 14 C.F.R. § 91.103: PreflightAction. This regulation requires eachpilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 underNormal Procedures including butnot limited to reviewing weather, flight battery requirements, landing andtakeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and

7for flight instruction in experimental aircraft. The equivalent level ofsafety is provided by the fact thatneither a pilotnor passengers will becarried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less thanthe minimums prescribed, provided the person operating the helicopter complies with any route oraltitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, ornot more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey orphotograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point onthe structure. 

### Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheirpre obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken withoutthe permission ofthe property owner orlocal officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraft weighting far more thanthe maximum SSibs. Proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low altitude operations of the UAS will ensure separation between these UAS operations and the operations ofconventional aircraft thatmust comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set 11

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 11 As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S.

8exemption may beneeded. An equivalent level ofsafety will be achieved by the operator, pursuanttothe safety checklist and live flight datamonitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicator before flight. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly afterthat for at least45 minutes." The applicant believes that an exemption from 14 CFR §91.151(a)falls withinthe scope ofprior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does not engenderthe type ofrisks that Section 91.151(a) was intended to alleviate giventhe size and speed ofthe small UAS. The applicantbelieves that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbattery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulationprovides inpertinent part: (a) Except as provided in§ 91.715, no personmay operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed 

### 55 lb limit and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them onthe UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall

9betweenrequired inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part4 3 ofthis chapter

..," and others shall inspect ormaintain the aircraft in compliance with Part 43. Given that these sections and Part43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuantto the flight manual and operating handbook. Anequivalent level ofsafety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operator will ensurethatthe UAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy conditionto providethe equivalent level ofsafety. Anequivalent level ofsafety will be achieved because maintenance and inspections will beperformed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, and a link on last page, the operator will ensure thatthe UAS is in working order priorto initiating flight and perform required maintenance needed. Authority contained in 49 U.S.C. 106(f), 40113, and 44701 Additional Information. The applicant DerrickWayne Blount believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of2012, providing sufficientjustification for the granting of commercial operations ofthe applicant's UAS. The applicant, DerrickWayne Blount requests yourrespective approval ofthis Section 333 exemption petitionrequest. And believes itwould be in the public Interest on my exemptionto further educate and the safety offlying UA Vs. Thankyoufor your attention in this matter. Please notify DerrickWayne Blount Ofyour actions, and orapprovals. Thankyou, for your interest inthis request.**Sin5~rely,** 

### /IlL Y**lJ~** 

## w: 'IJCJWIO DerrickWayne Blount



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