TO: U.S. Department of Transportation July 6, 2015

 Docket Management System

 1200 New Jersey Ave., SE

 Washington, DC 20590

FROM: CREATED FROM ABOVE

 C/O Gary D. Rose

 4100 N. Hwy 97

 Klamath Falls, OR 97601

 (541) 274-1045

 gary@createdfromabove.com

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

 Attachments:

 1. Blade Chroma 1080P Owners Manuel.

 2. Flight Log (will be immediately implemented)

 References:

 1. FAA Exemption No. 11138, Regulatory Docket No. FAA20140481

 in the matter of the petition of DOUGLAS TRUDEAU

 2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in

 the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

 3. FAA Exemption No. 11080 Regulatory Docket No. FAA20140355

 in the matter of the petition of FLYING CAM INC

 4. FAA Exemption No. 11437 Regulatory Docket No. FAA20150221

 in the matter of the petition of MARCUS D MELHUS

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012, I Gary D. Rose doing 

business as “Created From Above” hereafter as the petitioner, request exemption from 

the following sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude 

within the U.S. national airspace system as compared to a manned aircraft. 

Operations will be in support of local fire departments and related emergency service 

agencies such as Search and Rescue, focusing on pre-incident planning and imaging that

would form the basis for incident action plans in the event of a real emergency. 
Operations will be performed only at the request of and with the authorization and 

permission of clients (municipalities) or their authorized agents in order to improve 

incident pre-planning and raise awareness of the beneficial uses of small unmanned air 

systems for use within the fire service to improve their ability to respond in the event of a 

real incident. 

The exemption would also be used in special events, sporting events and land 

surveillance, real estate, commercial inspections and commercial maintenance over 

certain areas of these United States with permission of the landowner or agent.

So long as such all operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The conditions 

identified and proposed by the petitioner are drawn from references 1-3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an experienced UAS

operator with the addition of a trained observer. All pre-flight inspection, maintenance 

and flight logs will be saved and made available to the FAA and Secretary of 

Transportation (SoT) for review; with the purpose of safely integrating civil UAS 

operation in the National Airspace System.

91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer

than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the 

terms “congested areas” and “densely populated”. The petitioner requests waiver for this 

condition to allow reasonable and responsible operations in areas of subdivisions and 

neighborhoods if required. The petitioner will primarily operate the UAS between 

ground level and 200 feet. The UAS will be operated over designated properties with the 

consent of the local municipality, land owner or their designated agent and while 

maintaining a safe distance from persons. The petitioner will compile flight data from the 

logs. This data may assist the FAA in development of regulations for commercial 

operations in low-risk, controlled environments.

91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric 

sensor for altitude information.

91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior

relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS 

specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, 

VFR conditions. The UAS provides battery power remaining in percent to the PIC. The 
UA batteries provide approximately 25 minutes of powered flight. Information provided 

in the operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a 

landing procedure when battery remaining reaches a specified level. Given the limitations 

on proposed operations and the location of those proposed operations, The FAA found 

that a reduced minimum power reserve for flight in daytime VFR conditions was 

reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to

inspect and ensure that the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the requirements for 

maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected.

The UAS

The Blade Chroma 1080P is a highly successful consumer grade small rotorcraft in

the quad copter configuration with an advertised weight of less than 44 Ounces (1242g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum

speed of less than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per 

minute (6 m/s). It is powered by four electric motors with a distance between motors of 

less than 14 inches (350mm). It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted 

back to a ground control station allowing the operator and/or PIC to monitor battery

level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and 

control camera angle. It has failsafe modes of operation for either loss of RC or

GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry

and external lighting cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when the battery reaches a predetermined low state. 

It is anticipated that flights will usually last less than 12 minutes. More information is 

available in attachment 1.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist will be developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure prone components. These documents will be made available to the FAA and SoT 

to assist in future implementation of safety standards and regulations. The petitioner will 

only operate the UAS over designated properties with the clients consent. Flight plans 
will be predetermined to limit the UASs flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight obstacles prior 

to operating the UAS. UAS operation will always be within VLOS of the PIC and the 

observer.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. With the ability to easily and 

cost effectively gain a perspective of complex and possibly high risk environments, fire 

departments can more effectively develop pre-plans to mitigate any situations that arise. 

Moreover, the ability to periodically review building roof modifications and loads 

significantly improves situational awareness and improves the safety of both firefighters 

and occupants. Additionally, effective use of this technology will allow smaller fire 

departments to maximize their resources on mitigating actual issues as opposed to 

wasting precious time getting a “big picture” perspective in a real incident. Operations for 

this petition will enable fire departments to gain an enhanced perspective for 

characteristics, exposures and hazards associated with a particular property that

cannot be gained through ground level inspection. Aerial surveying and inspections can 

increase planning efficiency, improve resource estimations, and reduce risks to personnel 

and property. The petitioner will provide clients with photographic data for these 

purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will 

be utilized. Flight data including UA flight time, Control Unit operation time, incident, 

accident, and details concerning any deviations from normal operations will be available 

to FAA for use in collecting data regarding the use of UAS as part of this application. 

This data may be submitted to FAA via traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, inspections and other flight operations”. The reason for 

such a general and broad based request is that the petitioner wishes to provide services to 

fire departments and other emergency service providers, the public and commercially 

licensed realtors that can only be provided through the quick deployment and cost 

effective operations provided by a UAS. 

It is believed that these services will allow clients to significantly improve their preplanning and situational awareness which in turn will lead to more efficient mitigation of 

incidents, thereby reducing property loss and improved the safety of both building 

occupants and emergency services personnel. The petitioner's business model is based on 

the idea of offering ad hoc small UAS services to clients who wish to employ these 

services as a safe, effective, and legal option to enhance their operations and businesses. 

By providing this service to multiple clients, the petitioner can ensure adherence to

standards and protocols and can develop and refine generally applicable safety guidelines 

and processes. The petitioner has refrained from engaging in commercial use of the UAS. 

The primary purpose of seeking this exemption is to obtain the capability to offer those 
services while remaining in compliance. The petitioner has 40 years of experience in the 

radio control model aircraft hobby. In addition, the petitioner has more than 15 years of 

general aviation ASEL experience and holds a current Private Pilot certificate 

(541769182).

Respectfully submitted, 

Gary D. Rose

“Created From Above”