Robert S. Gittens

180 Waters Edge Drive

Lizella, Ga. 31052

478-390-9177

flyrobert1@gmail.com

January 14, 2016

U.S. Department of Transportation 

West Building Ground Floor 

Room w12-140 

1200 New Jersey Avenue, 

SE Washington, DC, 20590 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-95), 

(2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), Robert S.Gittens Dba Portrait Shoppe, (“Petitioner”) hereby petitions for 

exemptions listed below. 

14 CFR Part 21 H Requirements to Secure Airworthiness Certificate 

14 CFR. 45.23 b Size of display marks 

14 CFR § 61.113 a & b Private Pilot Privileges and limitations; Pilot in Command 

14 CFR. 91.7(a) Civil aircraft airworthiness 

14 CFR. 91.9 Civil aircraft flight manual, marking, and placard requirements 

14 CFR § 91.103 Preflight Action 

14 CFR § 91.109 a Flight Instruction 

14 CFR § 91.119 c Requirements for Minimum Safe Altitude for Civil Aircraft Operation 

14 CFR § 91.121 Altimeter Settings 

14 CFR § 91.151a1 Fuel Requirements for Flight in VFR Conditions 

14 CFR. § 91.203 a & b Carrying Civil Aircraft Certification and Registration 

14 CFR § 91.405 a Maintenance Required 

14 CFR § 91.407 a1 Maintenance, Preventive Maintenance, Rebuilding, or Alteration 

14 CFR § 91.409 a1&2 Inspections 

14 CFR § 91.417 a & b Maintenance Records 

The proposed exemptions, if granted, would allow Robert S. Gittens to commercially operate a small-unmanned aircraft system (“sUAS”), to shoot video and still photography used for web-based videos, real estate 

advertising, property inspections and personal fine-art projects. 

Along with this petition the following documents have been submitted: 

• Portrait Shoppe sUAS Standards Operation Manual.pdf 

• http://www.horizonhobby.com/pdf/BLH8620-Manual-EN.pdf

• http://www.horizonhobby.com/pdf/BLH8622-Manual-EN.pdf
BACKGROUND 

Robert S. Gittens seeks an exemption to operate Blade Chroma small-unmanned aircraft system (sUAS) 

equipped with a three-axis gimbal and CG03 camera system, for compensation or hire within the National 

Airspace System. 

Robert S. Gittens dba Portrait Shoppe , has provided clients with photography, video, and multimediarelated services for over 18 years. Robert S. Gittens hopes to offer aerial photography and cinematography 

services to provide a more affordable solution for areal imagery. Robert S. Gittens has been assembling and 

flying small RC Airplanes since 2007. He is active member of the Academy of Model Aeronautics (AMA) as 

well as a member of a local RC club Chartered by the (AMA) and for the last 2 years, has logged over 50

hours of flight time on a Blade Chroma Quadcopter, equipped with a three-axis gimbal and a CG03 camera, 

without incident. 

The Blade Chroma is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a maximum gross 

weight of approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 

16.4’fps and a maximum flying height of 400'. Blade Chroma is equipped with four main rotors, driven by 4 

Lithium Polymer battery powered electric motors. 

How this request would benefit the public as a whole: 

Robert S. Gittens use of a sUAS reduces the need to operate conventional aircraft lowering the overall cost to 

the consumer. sUAS can provide photos and video more quickly, accurately, economically, safely, and with 

reduced environmental impact. 

NAME AND ADDRESS OF PETITIONER /Registration N578MG / UAS Certificate Number FA39MEMPHE

Robert S. Gittens

Owner and sUAS Pilot/Operator 

Portrait Shoppe

180 Waters Edge Drive

Lizella, Ga. 31052

478-390-9177

flyrobert1@gmail.com
The specific sections of 14 CFR from which Robert S. Gittens is seeking an exemption as well as 

the reasons for the exemptions: 

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates

Robert S. Gittens requests an exemption because of size, speed, weight, and limited operating area of the 

Blade Chroma to meet the level of safety necessary for exemption under (49 U.S. Code § 44701 – “General 

requirements” (f)). In addition, considering the small size of a Blade Chroma, if flown in accordance with 

the sUAS Standard Operating Procedures Manual developed byRobert S. Gittens and flight procedures recommended by the Blade Chroma Manual, it provides at least an equivalent, and, most likely, superior level of 

safety to that of such operations being conducted with conventional aircraft. 

14 C.F.R. 45.23(b); Size of display marks

Robert S. Gittens requests an exemption from 45.23(b); "Marking of the aircraft" because the Blade Chroma

sUAS does not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally, 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. 

If required by the FAA, Robert S. Gittens will mark the sUAS with the largest possible lettering if 

assigned a number or name (based on a request or ruling by the FAA on its fuselage). 

14 CFR § 61.113 (a) and (b) - Private Pilot Privileges and Limitations; Pilot in Command

Under §61.113 (a) and (b) private pilots are limited to non-commercial operations, however Robert S. Gittens

can achieve an equivalent level of safety as achieved by current regulations. Allowing operations of the sUAS 

exceeds the present level of safety achieved by 14 CFR 61.113 (a) and (b) since there will be no human beings 

on board the sUAS and the sUAS will be operated in an environment to minimize risk while in the air. In order to 

ensure a high level of safety Robert S. Gittens has developed a sUAS Standard Operating Procedures Manual 

that will help ensure safe flights. 

14 C.F.R. 91.7(a); Civil aircraft airworthiness

Robert S. Gittens is seeking relive of from section 91.7(a) because the Blade Chroma sUAS does not require 

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Robert S. Gittens will 

ensure that the Blade Chroma sUAS is in airworthy condition based upon its compliance with the operating 

documents 

(i.e., Maintenance Log, Standard Operating Manual, Checklists and Blade Chroma’s Manual) prior to every 

flight. 

14 C.F.R. 91.9 Civil aircraft flight manual, marking, and placard requirements

Robert S. Gittens seeks an exemption from C.F.R. 91.9 because the size and configuration of the Blade 

Chroma has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot 

on board but because there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be achieved by keeping the sUAS Standard Operating Procedures Manual 

and Blade Chroma Manual at the ground control point where the PIC will have immediate access to them. 

14 CFR § 91.103 - Preflight Action

Robert S. Gittens will perform preflight inspections in accordance with the manufacturer's recommendations 

and the Portrait Shoppe sUAS Standard Operating Procedures Manual. Preflight inspections will also include 

weather and wind checks before flight and assessment of potential surrounding hazards such as power lines, 

trees, bushes, etc. 

14 CFR § 91.109 (a) - Flight Instruction

Robert S. Gittens seeks an exemption from 91.1 09(a), which provides that "no person may operate a civil aircraft (except a manned balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls." sUAS and remotely piloted aircraft do not have functional dual controls. sUAS flight control is 

accomplished through the use of a device that communicates with the aircraft via radio communication. 

14 CFR § 91.119 (c) - Requirements for Minimum Safe Altitude for Civil Aircraft Operation

Robert S. Gittens sUAS will be operated below the 400 feet Above Ground Level (AGL). Given the size, weight 

(less than 3 pounds) and speed of the sUAS, equivalent levels of safety will be achieved. 
14 CFR § 91.121 - Altimeter Settings

Robert S. Gittens requests an exception from 91.121 because the Blade Chroma uses a barometric altimeter 

that is automatically reset before each flight. The operator can achieve equivalent safety as the sUAS uses 

AGL height from its initialization or launch point. Moreover, the UAV will not require current reported altimeter 

setting of a station along the sUAS’s flight path because the sUAS will be flown within a horizontal range of 

1000 feet or less to maintain VLOS. Lastly, if the altimeter displays a discrepancy in the AGL of more than +/- 

3.5 meters the flight will be canceled. 

14 CFR § 91.151 (a) (1) - Fuel Requirements for Flight in VFR Conditions

The sUAS flown by Robert S. Gittens has a short flight time, 18-22 minutes maximum per flight and will be 

operated well below the 400 foot AGL ceiling under controlled conditions as defined by the Portrait Shoppe

sUAS Standard Operating Procedures Manual. The sUAS will be flown up to the maximum of 18 minutes or 

until 25 percent of battery life remains, whichever comes first. Blade Chroma Quadcopters have a built-in 

safety feature that is achieved through battery monitoring. The aircraft system is built to alert the PIC of low 

battery life and will automatically return the unit to its takeoff location before battery capacity is depleted. The 

FAA has previously issued exemptions for fuel requirements in VFR conditions. Previous exemption numbers 

include 10808, 5745, 2689F, & 10673. Given the small size and operational purposes of the sUAS, it does not 

bear the same risks associated with this section's requirements. 

14 C.F.R. § 91.203 (a) & (b) - Carrying Civil Aircraft Certification and Registration

Robert S. Gittens seeks an exemption from 91.203 (a) & (b) because there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board 

the aircraft. 

An equivalent level of safety will be achieved by keeping any required certifications and or special flight 

authorization documentation with the PIC. 

14 CFR § 91.405 (a) - Maintenance Required

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore, these sections will not 

apply. Maintenance, preventative maintenance, rebuilding and alteration will be accomplished pursuant to the 

manufacturer's recommendations and the, “sUAS Standard Operating Procedures Manual” developed by 

Robert S. Gittens. The sUAS shall be free of mechanical issues and discrepancies prior to flight. If mechanical 

issues arise, the flight will be terminated immediately. This standard exceeds that of a manned aircraft, which 

allows possible flight despite minor discrepancies that do not impair safety. 

Robert S. Gittens , along with guidance from the manufacturer, shall be the most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The 

Portrait Shoppe sUAS Standard Operating Procedures Manual outlines how to log flights and maintenance 

information. An equivalent level of safety will be achieved because Robert S. Gittens operates its sUAS far 

below its maximum height of 400 feet AGL, in controlled areas. In addition, the UAV will not carry any significant payload besides a CG03 camera and if a mechanical issue occurs the sUAS can land immediately. 

14 CFR § 91.407 (a) (1) - Maintenance, Preventive Maintenance, Rebuilding, or Alteration

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore, these sections will not 

apply. In the absence of regulatory provisions dealing with sUAS operations, maintenance, preventive maintenance, rebuilding and alteration, Robert S. Gittens has developed operational standards to address this 

topic.Robert S. Gittens will perform maintenance pursuant to the manufacturer's recommendations and its own 

operational standards. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished Robert S. Gittens or by trained personnel. Robert S. Gittens sUAS will be discrepancy-free prior 

to initiating flight and will be grounded if mechanical issues are discovered while in flight. Robert S. Gittens will 

consult the manufacturer regarding any discrepancies or damages to the sUAS. 

Robert S. Gittens shall be the most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. Furthermore, Robert S. Gittens sUAS will fly below 

the 400 feet AGL, which will add an equivalent level of safety. Maintenance schedules and logs will be 

documented 

by Robert S. Gittens . 

14 CFR § 91.409 (a) (1) and (2) - Inspections

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore, these sections will not 

apply. In the absence of regulatory recommendations, Robert S. Gittens has developed operation standards 

to address this topic. Pre-flight and post-flight inspections will be accomplished by Robert S. Gittens pursuant 

to the 
manufacturer's recommendations and the Portrait Shoppe sUAS Standard Operating Procedures 

Manual. Robert S. Gittens sUAS will be flown free of discrepancies and if mechanical issues arise during 

flight, the sUAS will be grounded immediately. Flights will be executed under 400 feet AGL and logged 

according to the Portrait Shoppes sUAS Standard Operating Procedures Manual. 

14 CFR § 91.417 (a) and (b) - Maintenance Records

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore, these sections will not 

apply. In the absence of regulatory recommendations, Robert S. Gittens has developed operation standards to 

address this topic. The Portrait Shoppes sUAS “Standard Operating Procedures Manual” will detail how to log 

scheduled maintenance or flights that are performed. Maintenance will be accomplished by Robert S. Gittens 

and/or by trained personnel pursuant to the manufacturer's recommendations and Portrait Shoppe’s operational

standards. The sUAS will be free of discrepancies prior to initiating flight. If mechanical issues arise during 

flight of the sUAS, the PIC will land the unit safely. Robert S. Gittens shall be the most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

CONCLUSION 

As set forth herein, Robert S. Gittens seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Blade

Chroma commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video 

and photography over certain areas of the United States. 

If there are any areas that have not been addressed, please contact me for supplemental information. 

Sincerely, 

Robert S. Gittens 

180 Waters Edge Drive

Lizella, Ga. 32052

flyrobert1@gmail.com

478-390-9177
sUAS Technical Specifications

Blade Chroma

Weight (Battery & Propellers Included) 1000g 

Motor to Motor Distance: 15.7 in (400mm)

Rotor Type: Quadcopter

Prop Diameter: 10.0 in (253mm)

Approximate Flight Time: 30 minutes

Battery: 11.1V 3S 6300mAh Li-Po

Height: 9.50 in (242mm)

Weight: 45.9 oz (1.3 kg)

Motor Type: 4 × 780Kv Brushless Outrunner

Control Link: 2.4GHz, 2.4GHz

Video Link: 5.8GHz

Video Link Range: 1,970 ft (600m)

Satellite Navigation System: GPS, GLONASS

Completion Level: Ready-to-Fly

Length: 12.8 in (325mm)

http://www.horizonhobby.com/pdf/BLH8620-Manual-EN.pdf

Lipo Battery

Type 3S LiPo 

Capacity 6000mAh, 11.1V 

Charging Environment Range 0°C to 40°C 

Discharging Environment Range -20cto 

50°C

2.4GHz Remote Control

Operating Frequency 2.4GHz ISM 

Communication Distance (Open Area) 1000m 

Receiver Sensitivity (1%PER) -97dBm 

Working Current/Voltage 120 mA@3.7V 

Built-In LiPo Battery Working Current/Capacity 3.7V, 2200mAh

CGO3 Camera

Gimbal Operating Current Static current: 400mA (@12V) Dynamic current: 600mA (@12V) 

Gimbal Input Power 3S~6S (12V ~ 26V) 

Operating Temperature -0°C ~ 40°C 

Gimbal Weight 200g (camera excluded) 

Gimbal Dimensions (With Damping Unit) 97mm X 95mm X 73mm 

GCU Weight 22g 

GCU Dimensions 42 mm X 32 mm X 9.3 mm 

Regulatory Approvals FCC (USA): Yes; CE (EU): Yes; RoHS (EU): Yes 

FCC Compliant 5.8GHz 7-Channel Cased A/V Transmitter

Frequency: 5.8GHz RF band. 

Channels: Seven (5740, 5760, 5780, 5800, 5820, 5840, 5860 MHz). 

RF Field Strength: Approximately 90dBuV/m @ 3m (<1mW RF Power). 

Operating Distance: 100 meters in ideal line-of-sight environments. 
Terms and Abbreviations

AGL - Above Ground Level - An altitude measured with respect to the underlying ground surface. 

Aircraft - Any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United States Code 

(49 USC) § 40102). 

AMA - Academy of Model Aeronautics - A US based, non-profit organization dedicated to the promotion of 

model aviation as a recognized sport as well as a recreational activity. It is the largest organization of its kind 

with a current membership of more than 140,000 members. 

Anemometer - An instrument to measure the velocity of the wind in the Area of Operations. 

AO - Air Traffic Organization 

AOI - Area of Interest 

Area of Operations - Defined as the area where sUAS operations will be carried out for a specific flight or series 

of flights on a given mission. 

ATC - Air Traffic Control 

CFR - Code of Federal Regulations 

Checklists - Procedural checklists used by the PIC to verify proper and safe procedures during all phases of 

sUAS operations. 

COA - Certificate of Authorization - Exemption with a civil Certificate of Waiver or Authorization for civil aircraft 

to perform commercial operations in low-risk, controlled environments. 

Designated Safety Zone - Defined and marked area of ground operations used for safe takeoffs and landings of 

the sUAS at a given Area of Operations. 

FAA - Federal Aviation Administration 

FAA - Modernization and Reform Act of 2012 (FMRA) 

FAR - Federal Aviation Regulation 

Flight Control Systems - The combination of telemetry, PIC operated controls, and on board control 

mechanisms that are employed to control the flight of the sUAS. 

Frequency Analyzer - A device used to scan the Area of Operations for possible interference from radio waves. 

GCS - Ground Control Station 

GPS - Global Positioning System 

Handheld Radio - A radio transceiver capable of communication with other Pilots or FAA personnel in the Area 

of Operations. 

Return To Home - A default recovery mode the DJI Phantom goes into when communications are lost from the 

PIC. 

LOL - Loss of Link 

Maintenance Recommendations - Periodic maintenance recommendations for each of the sUAS components 

that have a usable life. 

Manual - This flight manual that combines the Operator specific procedures with the sUAS manufacturers' 
manual. 

Manufacturers Recommendations - Written recommendations provided by the manufacturers of the various 

components of the sUAS. 

NAS - National Airspace System - The common network of U.S. airspace; air navigation facilities, equipment 

and services, airports or landing areas; aeronautical charts, information and services; rules, regulations and 

procedures, technical information, and manpower and material 

Non-Participants - Persons who have not agreed to participate in sUAS operations. 

NOTAM or NoTAM - A Notice to Airmen - A notice filed with an aviation authority to alert aircraft pilots of 

potential hazards along a flight route or at a location that could affect the safety of the flight. 

Operational Control - With respect to a flight, this means the exercise of authority over initiating, conducting or 

terminating a flight (14 CFR § 1.1). 

Operator - The entity submitting as the applicant on this waiver request to the FAA who will be responsible for 

all sUAS operations and procedures. 

Participants - Persons who have agreed to participate in sUAS operations 

PIC - Pilot In Command - Person who will fly the UA during sUAS operations and who is responsible for all 

safety related or operational decisions under the direction of the Operator in accordance with this Manual and 

FAA requirements. 

SO - Safety Observer 

SOP - Standard Operating Procedures 

sUAS - Small Unmanned Aircraft Systems as contemplated under the FAA guidelines, not to exceed 55 pounds 

in weight or 100 miles per hour in speed. 

Telemetry - Electronically transmitted data that provides control and information transmissions to and from the 

PIC and the sUAS. 

The FAA's sUAS Integration Office (AFS-80) - The Agency's single point of contact for everything sUAS. It was 

established in 2013 with a vision for safe, timely, and efficient integration of sUAS into the National Airspace 

System (NAS). The sUAS Integration Office collaboratively develops operating concepts, policies, 

requirements, criteria, and procedures for new system evaluations, integration, and implementation of emerging 

sUAS technologies. 

UA - Unmanned aircraft - Any aircraft that is operated without the possibility of direct human intervention from 

within or on the aircraft (P.L. 112-95, Section 331). 

UAS - Unmanned Aircraft System - An unmanned aircraft and associated elements, including communication 

links and the components that control the unmanned aircraft, that are required for the pilot in command to 

operate safely and efficiently in the national airspace system (P.L. 112-95, Section 331). 

VFR - Visual Flight Rules - A set of regulations under which a pilot operates an aircraft in weather conditions 

generally clear enough to allow the pilot to see where the aircraft is going. 

VLOS - Visual Line of Sight - Unaided (corrective lenses and/or sunglasses excepted) visual contact between a 

pilot in command and an unmanned aircraft sufficient to maintain safe operational control of the aircraft, know 

its location, and be able to scan the airspace in which it is operating to see and avoid other air traffic or objects 

aloft or on the ground. 

VMC - Visual Flight Rules Meteorological Conditions - Conditions in which pilots have sufficient visibility to fly 

the aircraft maintaining visual separation from terrain and other aircraft. 
VMC - Visual Meteorological Conditions - An aviation flight category in which visual flight rules (VFR) flight is 

permitted—that is, conditions in which pilots have sufficient visibility to fly the aircraft maintaining visual 

separation from terrain and other aircraft. 

VO - Visual Observer - An individual who is designated to observe flight operations and to maintain visual 

contact with the UA during flight operations while maintaining communications and coordination with the PIC. 

VTOL - Vertical Takeoff and Landing