Blue-Chip Unmanned Aerial Solutions Inc.

Clint P. Stevens

1965 South Beech St.

Wichita, KS 67207

316-305-5498

bluechipuas@gmail.com

September 30, 2014

U.S. Department of Transportation

Docket Operations 

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft 

Systems Operations Allowed by Section 333 of the FAA Modernization and Reform 

Act of 2012 Through the Exemption Process Identified Under 14 C.F.R. Section 

11.81

Dear Sir/Madam,

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform 

Act of 2012” or “The Reform Act”, Blue-Chip Unmanned Aerial Solutions Inc. (d/b/a Blue-Chip 

UAS), hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) 

operations for the agriculture, oil and gas, aerial photography and wildlife preservation 

industries, within the United States National Airspace System (NAS); within Class G and

occasionally E airspace, along with additional restrictions identified herein.

This request is separate from any and all Certificate of Authorization/Waiver (COA) requests 

submitted by public agencies identifying, Blue-Chip UAS (or its affiliates), as their UAS 

contract service provider authorized under Sec. 334 of the “Reform Act.”

This request does not pertain to any and all activities conducted under the guidance of the 

Department of Defense while operating over restricted military airspace during military exercises 

in which, Blue-Chip UAS (or its affiliates), has been identified as a participant in providing UAS 

operations and support.

Table of Contents

I. Company Background

II. Training & Operations

III. Regulations – Exemptions Requested

a. 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

b. 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

c. 14 C.F.R. § 61.113 (a) & (b) and § 61.133(a)(1) – Private and Commercial 

Pilot Privilege and Limitations

d. 14 C.F.R. § 91.7(a) – Civil Aircraft Airworthiness

e. 14 C.F.R. § 91.103 – Preflight Action

f. 14 C.F.R. § 91.109 – Flight Instruction

g. 14 C.F.R. § 91.119 – Minimum Safe Altitudes

h. 14 C.F.R. § 91.121 – Altimeter Settings

i. 14 C.F.R. § 91.151(a) – Fuel Requirements for Flight in VFR Conditions

j. 14 C.F.R. § 91.405(a), § 91.407(a)(1), § 91.409(a)(2) and § 91.417(a) & 

(b) – Maintenance Inspections

IV. Public Interest

V. Privacy Concerns

VI. FAA Collaboration

Summary ~ Federal Register

Additional Documentation:

• Flight Planning Document (Proprietary - provided as secondary document)

• Magpie UAS Operations Manual (Proprietary - provided as secondary document upon request)

• Blue-Chip UAS Operations Manual (Proprietary - provided as secondary document upon request)

• Founder Biographies (Confidential - Available upon request)
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I. Company Background

Blue-Chip Unmanned Aerial Solutions Inc., was founded in 2014 by four members of the United 

States Air Force as their transition from the military to the civilian job market. Over the past 

decade, the “Blue-Chips” have amassed an astonishing 75,000+ hours of operational experience 

in the unmanned aerial systems (UAS) industry. Conducting operational mission sets both stateside and forward deployed in support of Operations ENDURING FREEDOM, IRAQI 

FREEDOM and NEW DAWN along with other worldwide contingencies; the “Blue-Chips”

have built a resume unparalleled when it comes to UAS operational experience.

Furthermore, the “Blue-Chips” have more than a decade of military and civilian flight and

aircraft maintenance experience. From B-1B weapons systems to flight operations training for a 

large airline emergency procedures department to flying heavy military aircraft, globally; the 

experience and diversity the “Blue-Chips” bring to the United States civilian UAS operations 

industry is second to none and therefore “...in the public’s best interest...” for the Secretary to

approve this exemption request.

NOTE: Confidential biographies available upon request

II. Training & Operations

Section 333 of “The Reform Act” states:

“...the Secretary of Transportation shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system...In making the determination under 

subsection (a), the Secretary shall determine, at a minimum— (1) which types of 

unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or pose 

a threat to national security...”

Blue-Chip UAS will utilize the Sensurion Magpie air vehicle(s) to conduct operations for the

agriculture, oil and gas, aerial photography and wildlife preservation industries. The Magpie

meets the requirements for determination for exemption in the fact it has a 6’ wingspan, 

maximum weight of 10.5 lbs, maximum/cruise/stall speeds of 60/35/10 knots respectively and 

flies for less than two hours (battery limited). Operating within visual line of sight (VLOS) and 

remaining below 400 ft AGL are standard operating procedures for Blue-Chip UAS and will 

remain so until further advances in safety of flight are introduced to the market and regulated by 

the FAA. As described below, all operations will be confined to those areas no closer than one 

statue mile of any airfield and the proper authorities will be notified with any operations within 

five statue miles. Furthermore, when it comes to national security concerns, the “Blue-Chips” 

have spent a combined 50+ years defending our country as military members ensuring national 

security is of the utmost priority in any activities they partake in.
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The Aircraft: Magpie UAS

Design: The Magpie UAS is built from a variety of durable, lightweight and modular 

components that aid in its capability to be on mission in a variety of conditions. As well, 

the modularity of construction allows for easy exchange of structural, propulsion or 

sensor components – in the field. ~ As defined by Sensurion

Aircraft Performance/Specifications:

• Aircraft Composition: Carbon Fiber

• Flight Controls:

o Primary: GPS Guided Autopilot (Ground Control Station)

o Backup: Standard Flight Controls (RC Transmitter)

• Power Supply: Electric Motor / NextGen Battery Technology

• Wingspan: 72” / 6 ft

• Speed knots: Max: 60 / Cruise: 35 / Stall: 10

• Empty Weight: 5.5 lbs

• Max Payload: 5 lbs

• Launch (Take Off): Hand-launchable

• Recovery (Landing): Skid Recoverable (belly landing)

Operator Training: All initial Magpie flight operations and maintenance training will be 

conducted by Sensurion through their initial certification process. Once an operator is certified

by Sensurion they will enter into Blue-Chip UAS operations qualification training which 

includes FAA authorized ground school training and a class III medical examination. Upon 

successful completion, the operator will earn their Co-Operator/Observer rating. CoOperators/Observers will be required to conduct 50 operational hours to be considered for 

Operator in Command qualification testing. The operator will then be required to complete a 

written test and “check ride” in-which upon successful completion, the operator will receive their

Operator in Command rating.

NOTE: Ground School Training will be conducted by FAA certified instructors

Initial certification training requirements instructed by Sensurion include:

Pre-Flight Training:

• Unpacking and assembly

• Power requirements, set-up and connectivity

• System end-to-end set-up and test / inspections

• Preflight, run-up and system checks

Flight Operations Training:

• Proper Handling

• Motor Operations
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• GCS Flight Programming and Test

• Launch

• Basic Flight (climb, cruise, descent, landing)

• Maneuvering

• Airspace and Landing Zone Operations

• Flight Reprogramming

• Flight Monitoring

• In-Flight Emergency Procedures

Post Flight:

• Shut Down Procedures

• Data Retrieval and Storage

• End-to-End Test and Maintenance Logs

• Disassembly

• Packing, Storage and Transportation

Co-Operator/Observer qualification training requirements instructed by Blue-Chip UAS include:

• Understanding FAA Rules / Regulations

• Collection Requirements

• Operational Planning

• Flight Planning

• Area of Operations ~ Hazard Mitigation

• Daily Flight and Inspection Log Completion

• Proper Authority Notification Process

Operator in Command qualification testing requirements instructed by Blue-Chip UAS include:

• Written Exam consisting of 60 questions with a pass rate of 70% following the 

guidelines set forth by the FAA Airman Knowledge Testing requirements

• “Check Ride” and Oral exam consisting of:

o Airport Operations

o Maintenance Inspections

o Flight Plan Development

o Area of Operations Hazard Mitigation

o Weather Hazard Mitigation

o Emergency Procedures

o Pre-Flight Operations

o Flight Operations

o Post-Filght Operations
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Operations Execution:

Given the fact commercial UAS operations are restricted due to the lack of regulations, a logical 

and safe solution is to utilize the safety guidance provided for hobbyist use of sUAS and other 

model aircraft as identified by Advisory Circular 91-57 and Section 336 of the “Reform Act”.

Blue-Chip UAS operations will be conducted in a methodical, efficient and most importantly,

safe manner adhering to strict guidelines which address safety concerns with proximity to 

airports and populated areas in the interim of official guidance from the FAA as the rules and 

regulations are being further developed.

The following list provides specific rules and guidelines all Blue-Chip UAS operations will 

adhere to too ensure at least an equivalent or higher level of safety when compared to manned 

aircraft performing the same functions as outlined within 14 C.F.R.:

1) All flight crews will:

• Be comprised of a minimum of three certified operators; one serving as 

Operator in Command (OIC) and the others as Co-Operator/Observers

• Consist of one certified air vehicle maintenance technician to conduct pre and 

post flight inspections

NOTE: OIC/Observer may also fill the role of the maintenance technician

• Attend pre and post flight mission briefs which will consist of weather 

information, flight information to include operational area and mission 

objectives, hazard mitigation actions and most importantly emergency and 

abort procedures; also included will be any NOTAMs or improvements to 

standard operating procedures through further refinements in operations

• Sign applicable documentation verifying their attendance to mandatory briefs 

as well as produce daily pre and post flight inspections and flight logs

2) All flight operations will:

• At no time fly within one statute mile of any operational airfield

• Provide prior notification to airfield operator and airfield air traffic control 

tower (when applicable) when operating within five statute miles of any active 

airfield; no later than 24 hours prior to air operations

• Provide prior written notification to local/county sheriff and fire departments 

in the event assistance is required to include: flight plans, type and capabilities 

of air vehicle(s) operated and operator’s contact information; no later than 24 

hours prior to operations

• Be conducted using sUAS as defined by the FAA weighing less than 55 lbs;

all operations authorized through this exemption request will be done with the 

Magpie UAS (future aircraft will be presented to FAA for approval prior to 

operational use)

• Be conducted in Class G and occasionally E airspace and shall not exceed 400 

ft above ground level (AGL)
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• Be conducted within visual line of sight (VLOS) of the qualified OIC and CoOperator/Observers

• Give right-of-way to and avoid flying near manned aircraft at all times

• Be conducted in rural environments and outside of city limits

• Be conducted with prior written consent from land owner

• Ensure air vehicles do not encroach within 250 ft of any improved road, 

person, vehicle or structure that is not associated with operations

• Abort/Cancel in the event of detrimental weather to include wind speeds 

exceeding the allowable limits as defined within operations manual

3) Emergency Procedures:

• In the event the air vehicle losses GPS signal, automated landing will 

immediately commence. The flight plan is built in such a way that hazards are 

identified prior to launch and an immediate landing within the flight plan will 

ensure all hazards are avoided. (This safety feature is inherent to sUAS and no 

further assistance from the OIC is necessary; however, the OIC will retain 

option for manual control at all times)

• In the event the OIC loses signal with the air vehicle, automated landing will 

immediately commence. The flight plan is built in such a way that hazards are 

identified prior to launch and an immediate landing within the flight plan will 

ensure all hazards are avoided. (This safety feature is inherent to the sUAS and 

with operations being conducted in the rural environment as previously 

stated, there are no concerns to personnel, vehicles or structures with an 

autonomous landing)

• In the event hazardous weather unexpectedly approaches and may affect 

operations, the OIC will immediately abort the operation and conduct landing 

activities

• In the event an in-flight emergency occurs, (ie. air vehicle maintenance 

issues), the OIC will immediately abort flight and conduct landing activities; 

air vehicle inspection will immediately be achieved and the air vehicle will 

not return to service without proper authorization from certified maintenance 

technicians

• In a “significant” event (ie. air vehicle crashes and outside assistance is 

needed), OIC will conduct notification procedures to include county sheriff

and fire departments, airfield operator/tower if applicable and any other 

authority required to mitigate situation

o A “significant” event report will be generated by the OIC, verified by 

the Co/Observer and maintenance technician and immediately 

provided to the Director of Operations

NOTE: Notification will be made to the FAA to assist in future prevention 

techniques
Page 9

By following these strict, mostly self imposed guidelines; Blue-Chip UAS, will achieve a 

safety level greater than that directed by the rules in which they seek exemption, 

especially true when you compare the same operating procedures against a manned 

aircraft. SUAS are inherently safer in all facets due to the fact that they are much smaller, 

fly at much lower speeds, there are no human operators on board and there is zero fuel to 

be concerned with in the event of a crash. As processes are further refined, the operations 

will only add to an already higher level of safety compared to manned flight operations in 

which serves the public’s best interest in the FAA’s endeavor to integrate UAS into the 

NAS.

III. Regulations – Exemption Requested

Pursuant to 14 C.F.R. § 11.81(e), Blue-Chip UAS seeks exemption from the below mentioned 

regulations and provides reason as to why the exemption should be approved based on the level 

of safety at least equal to that of which the rules require.

• 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

 Establishes: The procedural requirements for the issuance of airworthiness certificates as 

required by 14 C.F.R. § 91.203(a)(1)

Given the small size of the UAS, the limited operating areas and meticulous procedures 

defined within the training and operations section (re-iterated below), an exemption from 

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the “Reform Act” with consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular 

UAS.”

 sUAS Size: 6’ wingspan

 sUAS Weight: 10.5lbs

 sUAS Speed (knots): Max – 60; Cruise – 35

 sUAS Capes: 2 hour battery limited flight time (No fuel on board)

 No operations within one statute mile; Prior notice given to ATC 

tower/Airport Operator w/in five statute miles

 No operations within city limits; Rural areas only with a minimum 

distance of 250 ft from persons, structures, roads and vehicles

 Operations will be contained within one square mile as indicated by the 

flight plan provided as a secondary proprietary document

NOTE: The FAA has recently set precedence to this regulation within like given parameters and an 

exemption should be approved on this basis. See exemption approvals for Astraeus Aerial, Aerial MOB, 

HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision.
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• 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot 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.

Blue-Chip UAS will ensure compliance with § 45.29(f) to meet the intent of the 

regulation by placing the word “experimental” on the fuselage of the air vehicle(s).

NOTE: The FAA has set precedence to this regulation within like given parameters and an exemption 

should be approved on this basis along with previous exemptions: Nos. 10700, 10167 and 10167A. Also, 

see most recent exemption approvals for Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro 

Productions, Snaproll Media and Pictorvision for further justification of approval.

• 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) – Private and Commercial Pilot Privilege 

and Limitations

 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no 

person who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, 

act as pilot in command of an aircraft in connection with any business or employment if:

 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a commercial pilot 

certificate may act as pilot in command of an aircraft – (ii) For compensation or hire, provided 

the person is qualified in accordance with this part and with the applicable parts of this chapter 

that apply to the operation.

Currently, there are no applicable areas identified for sUAS in either the private or 

commercial sector and therefore an exemption is required to conduct commercial

operations. As flight operations will be conducted in a restricted environment as 

described in the operations section, these strict guidelines will achieve an equivalent level 

of safety for each individual flight especially when compared to commercial flights 

identified in Part 61 when originally developed. In addition, with the Magpie primary 

control system utilizing GPS waypoints for guidance and control, Blue-Chip UAS flight 

operations will be conducted by qualified Magpie operators with ground school 

certification and a class III medical.

NOTE: Operators may or may not hold a private pilot license.

Due to the fact not all operators will be rated pilots, all flight operations will be overseen 

and directed by an FAA certified commercial pilot with advanced ground school 

instructor certification, leading to at least an equivalent level of safety.
Page 11

• 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

 States: No person may operate a civil aircraft unless it is in an airworthy condition.

Currently there is no airworthiness certificate for the Magpie UAS, however, the 

manufacturer is in the process of obtaining said certificate. In the interim, daily pre and 

post flight inspections will be accomplished in accordance with manufactures 

maintenance manual(s) and guidance. During flight, the OIC will adhere to § 91.7(b) and 

abort air operations immediately upon identification of an in flight emergency. Any 

maintenance performed will be conducted by certified maintenance technicians and/or the 

manufacturer themselves. By applying the prescribed operations, inspection and 

maintenance procedures within the operations section, an equivalent level of safety will 

be achieved.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.7(a): Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. Also, see most recent 

exemption approvals for Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, 

Snaproll Media and Pictorvision for further justification of approval.

• 14 C.F.R. 91.103 – Preflight Action

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

information concerning that flight. This information must include- (paragraphs a, b, 1 and 2)

A pre-flight mission brief must be attended by all crew members. This “PMB” will 

contain weather and all flight information including emergency and abort procedures. A 

signature will be required by all crew members indicating they have received the PMB 

and have read any NOTAMs or other procedural updates which may have impact to 

standard operating procedures. In addition, the OIC will verify air vehicle is ready for 

flight by coordinating with the maintenance technician during pre-flight inspection.

The exemption requested for this section is specifically addressed toward the 

requirements which do not apply to sUAS operations such as runways and air traffic 

control integration.

NOTE: As previously stated, air traffic control and airport operator will be notified prior to any 

operations being executed within five statute miles

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Astraeus Aerial, 

Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision.

• 14 C.F.R. 91.109(a) – Flight Instruction

 States: 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.

The majority of sUAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints programmed before or during flight in 

addition to the use of a single hand held transmitter or control station controlled by the 
Page 12

OIC. The design does not allow for dual controls during flight training and therefore the 

exemption is requested to qualify/certify operators as required by the manufacturer along 

with specific operations training and procedures identified above within section II.

An equivalent level of safety will be ensured during training operations by utilizing the 

same flight planning process for normal operations. As identified in the flight planning 

document, all ground hazards will be identified and mitigation techniques will be enacted 

to ensure flights stay outside of 250 ft of any improved roads, vehicles, persons or 

structures. All training operations will be conducted within a confined space on private 

land in-which permission has been obtained by land owner prior to the execution of

training.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.109(a): Exemption 

Nos. 5778K and 9862A. Also, see most recent exemption approvals for Astraeus Aerial, Aerial 

MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision for further 

justification of approval.

• 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

 States: Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: (c) Over other than congested areas. 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.

All Blue-Chip UAS operations will be conducted at 400 ft AGL or below in uncontrolled 

Class G and occasionally E airspace. As sUAS are inherently safer than traditional 

aircraft due to their small size, light weight, battery operated vice fuel and no human onboard; Blue-Chip UAS will not operate within 250 ft to any improved roads, vehicles 

persons or structures (other than those being inspected as part of the flight operation). In 

addition, objects/hazards will be identified and geo-located prior to flight to be utilized

within the flight planning stages to ensure this objective is met.

NOTE: See Flight Planning Document

• 14 C.F.R. 91.121 – Altimeter Settings

 States: Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating...

SUAS are equipped with Global Positioning System (GPS) which provide altitude and 

geo-location data to the operator vice utilizing an altimeter. Due to this fact, an 

exemption is required for this system to be utilized in flight. GPS are precise within a few 

feet and therefore meet a safety level equal to if not higher than regulatory guidance.

As described in the emergency procedures section; in the event the air vehicle losses GPS 

signal, automated landing will immediately commence. The flight plan is built in such a 

way that hazards are identified prior to launch and an immediate landing within the flight 

plan will ensure all hazards are avoided.
Page 13

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Astraeus Aerial, 

Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision.

• 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

 States: 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 30 

minutes;

This regulation is written based on the capabilities of a traditional aircraft which have 

flight times of several hours or greater; therefore, with the majority of sUAS which have 

flight times of only an hour or less, this regulation would effectively deny the ability of 

the air vehicle to operate.

Using a Cessna 182 as an example, approximately 8% remaining fuel is required to meet 

the 30 minute flight time directed by this regulation. To meet the intent, Blue-Chip UAS, 

will operate its air vehicles to no less than 10% remaining battery power to ensure safe 

landing and retrieval of the air vehicle. This 10% buffer is greater than the Cessna 182 

and the ability to quickly and safely land sUAS in non-traditional environments ensures 

at least an equal level of safety.

NOTE: The FAA has set precedent by previously issuing exemptions for § 91.151(a): Exemption 

Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption approvals for 

Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and 

Pictorvision for further justification of approval.

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections

 91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—(1) It has been approved for return to 

service by a person authorized under § 43.7 of this chapter

 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may 

operate an aircraft unless, within the preceding 12 calendar months, it has had—(2) An inspection 

for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No 

inspection performed under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance records.

 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: (paragraphs 1 (i – iii), 2 (i – vi)); (b) The owner or operator shall 

retain the following records for the periods prescribed: (paragraphs 1 – 3)
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Due to the fact the Magpie UAS at present does not have an airworthiness certificate, 

these regulations do not apply and therefore an exemption is required. Pre/Post and 

routine inspections (not to exceed 50 flight hours) and maintenance will be conducted in 

accordance with the manufacturer’s guidance as stated in the operations manual. In 

addition, to meet the intent of these regulations, Blue-Chip UAS, will maintain daily logs 

of pre and post flight inspections and have maintenance performed by certified 

technicians and/or the manufacturer themselves. In the event maintenance is required, 

certified technicians will verify the air vehicle is in flight readiness status prior to 

releasing to OIC for use in operations.

Unscheduled maintenance will be accomplished in the event of a mechanical or structural 

failure during flight. Upon completion of unscheduled maintenance, documentation will 

be provided to the Director of Operations to sign off and verify that the air vehicle is once 

again ready for flight and accept the level of risk associated with returning the air vehicle 

to flight status. At no time will there be changes made to the air vehicle which would 

impact the structural integrity of the air frame without the manufacturer making such 

changes and verifying the flight its air worthiness.

All inspection and maintenance will be documented and maintained in-house. These 

actions will meet the intent of the regulation exemption is being requested and lead to the 

equivalent level of safety.

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Astraeus Aerial, 

Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision.

IV. Public Interest

The public’s best interest is achieved by the safe integration of UAS into the NAS. With the 

ongoing exemption process, the FAA has to identify those exemption requests with the public’s 

best interest in mind and select the companies who will be able to achieve this in a safe and 

responsible manner. Two of the main problems the public has with UAS are the fear of what they 

will be used for and whether or not they are safe to fly within the same airspace as commercial

airliners. Blue-Chip UAS is more than willing to help with public education and that starts with 

conducting operations within strict operating environments and then providing the results to the 

public to start to sway opinion in a positive light.

With the experience this team has built from UAS operations, manned flight operations and 

training and aircraft maintenance; the FAA will provide a great service to the American public 

by approving Blue-Chip UAS’s exemption request herein. Blue-Chip UAS will provide any 

additional information requested and will diligently work with the FAA to make this approval a 

reality as it is in the best interest and safety of the public as directed by Congress.
Page 15

V. Privacy Concerns

As previously stated, one of the main concerns the public has with the integration of UAS into 

the NAS is privacy and spying; especially as of recent with the “disclosure” of the NSA’s 

communication programs. The media has also placed a negative light on UAS when it comes to 

privacy; showing only how the military has used this technology to conduct combat operations

through the use of the visual and infrared sensors they carry.

Fortunately with this matter, Blue-Chip UAS is well versed in the privacy and oversight 

concerns which are addressed by federal government regulations: Executive Order 12333, DoD

Directive 5240.1-R and AFI 14-104. Although the regulations do not apply to private 

commercial entities, our knowledge and experience in working within these regulations will 

assist and ensure any and all privacy concerns will be minimal and immediately mitigated.

In addition, the most efficient and successful avenue to combat these concerns is to educate the 

public in how UAS technology will be used to exponentially improve all of our lives as 

Americans and place emphasize on how we should embrace the technology instead of fearing it. 

In these regards, Blue-Chip UAS, will look at actions we can take to move forward with this 

endeavor and assist the FAA and all UAS employment companies as a whole to better public 

perception and create a cohesive environment we all can operate in safely.

VI. FAA Collaboration

Blue-Chip UAS is committed to the safe integration of UAS into the NAS and will provide any 

and all information on its flight operations to the FAA to assist in the rules making process. As 

stated in the operations section, post flight logs will be required to be completed to produce 

monthly flight summaries which will include both positive and negative reporting placing 

emphasize on any issues which may arise during any segment of the operations. Blue-Chip UAS 

offers the monthly summaries to the FAA as input and flight data to ensure accurate information 

is utilized along with offering our expertise and knowledge in the rule making process.
Summary ~ Federal Register

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform 

Act of 2012” or “The Reform Act”, Blue-Chip Unmanned Aerial Solutions Inc. (d/b/a Blue-Chip 

UAS), hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) 

operations for the agriculture, oil and gas, aerial photography and wildlife preservation 

industries, within the United States National Airspace System (NAS); within Class G and 

occasionally E airspace.

Rules in which Blue-Chip UAS seeks exemption:

• 14 C.F.R. Part 21 Subpart H

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 45.23(b)

• 14 C.F.R. § 61.113 and 61.133(a)(1)(ii)

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. § 91.103

• 14 C.F.R. § 91.109(a)

• 14 C.F.R. § 91.119

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(2)

• 14 C.F.R. § 91.417(a) & (b)

Throughout this exemption request, Blue-Chip UAS has shown how their expertise and 

knowledge with UAS technology will ensure the public’s best interest is at hand and assist the 

FAA with their charge to: “...safely accelerate the integration of civil unmanned aircraft systems 

into the national airspace system...” as directed by Congress. They have also shown how the 

approval of this request will meet and exceed “...at least an equivalent level of safety...” for the 

regulations they seek exemption.

At each level through process refinement, Blue-Chip UAS, will capture and document the best 

practices to develop proven tactics, techniques and procedures and provide that information to 

the FAA to incorporate into the UAS integration process.

When it comes to the public and what is in their best interest you will be hard pressed to find a 

team more qualified for an exemption under Section 333 than Blue-Chip UAS. It will be a great 

service to the country and in the “public’s best interest” to include this team in the UAS 

integration endeavor in-which an equivalent level of safety will be ensured by operations being 

conducted by the undisputed experts they are.