February 10, 2016

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE.

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from certain parts of the FARs. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Lloyd Wright dba Wright Aerospace Technologies (“Operator”, or the “Petitioner”), hereby 

applies for a summary exemption from the listed Federal Aviation Regulations (“FARs”) to allow it to 

operate small Unmanned Aircraft Systems (“sUAS”) for aerial data collection, , including, but not limited 

to aerial video and photography for corporate videography, real estate photography and videography, 

special events, documentaries, television production and landscape, commercials, music videos, events, 

construction site and building videos, and training in sUAS operations under the conditions and 

limitations set forth in this Petition. 

The requested exemption would permit the operation of small, unmanned and relatively inexpensive 

sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) would 

provide safety enhancements to the already safe operations presently using manned helicopters and 

airplanes. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator’s 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the 

national airspace system.” Section 333(c) of the Reform Act.

The name of the Petitioner and point of contact is:

Lloyd Wright dba Wright Aerospace Technologies

6105 Garwood Cir

Flower Mound, TX 75028

l.wright41@verizon.net

214-912-7306

Lloyd Wright has been a certificated pilot since 1988. He currently holds an Airline Transport Pilot rating 

(3077719) with multiple type ratings and approximately 12,000hrs flying experience. He also maintains 

currency as a Gold Seal Certificated Flight Instructor (3077719CFI) with single, multiengine land, and 

instrument ratings. Other FAA certifications include Flight Engineer, turbo jet and Ground Instructor, 

Instrument. In January 2015 Mr. Wright added FCC Technician radio license (KG5FLH) to his resume. Mr. 

Wright has conducted operations as an FAA designated check airman for a number of companies in a 

variety of aircraft and simulators. Lloyd Wright has been a member of the Academy of Model
Aeronautics since 2010. He is also a member of the Aircraft Owners and Pilots Association and a local 

leader in the Boy Scouts of America. Mr. Wright has built and flown many types of model rotary wing 

and fixed wing aircraft to include aerobatic helicopters and multi rotors. He holds safety in the highest 

priority in all operations and plans to conduct sUAS operations with the same high standards.

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, 

which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Administrator must determine 

which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system.” Id. § 333(c) (emphasis added). 

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory 

requirements for civil aircraft, a term defined under § 40101 of the Act, which includes sUASs. The 

Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds 

the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 

14 CFR §91.203 (a) (1).

Make and Model of Aircraft to be Operated:

Blade Chroma (formerly Blade QX3)

Cinestar 8

DJI Phantom 3

DJI Inspire

DJI Spreading Wings S800

DJI Spreading Wings S900

DJI Spreading Wings S1000/S1000+

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in reference to 49 

U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated 

with the aircraft and its operation, the Secretary of Transportation has determined that these aircraft 

meets the conditions of Section 333. Therefore, the FAA has found that relief from 14 CFR part 21, 

Certification procedures for products and parts, Subpart H—Airworthiness Certificates, and any 

associated noise certification and testing requirements of part 36, is not necessary. 
All of these vehicles have built in capability to limit the height they fly above the ground and limit the 

distance they fly from the operator. The vehicles also have the built-in capability to return to the 

launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the 

height, radius, or airspace limitations programmed into it. 

The FAA has granted section 333 exemptions for these and similar vehicles. See, e.g. Octocopter, LLC, 

Exemption No. 14666, Haaksman Media, Exemption No. 14661, First Flight Photography, LLC, Exemption 

No. 11260, Regulatory Docket No. FAA−2014−0736 (as amended 14 April 2015) (DJI Spreading Wings 

S1000; DJI Inspire). Blade QX3 Exemptions: 11737, 11879, 12646

Blade Chroma (Formerly Blade QX3) Features:

•Advanced SAFE® Plus technology

•Return Home function

•Uses GLONASS and U.S. GPS for greater accuracy and reliability

•Mast-mounted GPS antenna for superb signal reception

Blade Chroma Specifications:

Approx. Flying Time 30 minutes 

Battery 11.1V 3S 6300mAh Li-Po 

Motor to Motor Distance 400mm 

Height 9.50in (242mm) 

Weight 45.9oz (1.3kg) 

Motors 780Kv Brushless Outrunner 

Prop Diameter 260mm 

Flight Control Link 2.4GHz 

Video Link 5.8GHz 

Approx. Video Link Range 1,970ft (600m) 

GPS Receiver GLONASS and U.S. 

Regulations from which relief is requested:

14 CFR § 61.23 (a) and (c)

14 CFR § 61.101 (e) (4) and (5)

14 CFR § 61.113 (a)

14 CFR § 61.315 (a)

14 CFR § 91.7 (a) 

14 CFR § 91.119 (c)

14 CFR § 91.121 

14 CFR § 91.151 (a)(1)

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (1) and (2) 

14 CFR § 417 (a) and (b)
Relief is requested to the extent necessary to allow the petitioner to operate sUAS to perform aerial 

data collection. This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations

Wright Aerospace Technologies will operate its vehicles on aerial data collection, aerial photography and 

videography, and training missions only under the following circumstances: 

1. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the UA 

be operated at airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

2. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude 

will be reported in feet AGL. 

3. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use 

human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license. 

4. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight 

(VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the 

PIC always maintains VLOS capability. The VO and PIC will be able to communicate orally at all times; 

electronic messaging or texting will not occur during flight operations. The PIC will be designated before 

the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure 

that the VO can perform the duties required of the VO. 

5. The requested exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations of the requested grant of exemption are hereinafter 

referred to as the operating documents. The operating documents will be accessible during UAS 

operations and will be made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the operating 

documents, the conditions and limitations will take precedence and be followed. Otherwise, the 

operator will follow the procedures as outlined in its operating documents. The operator may update or 

revise its operating documents, and track such revisions and present updated and revised documents to 

the Administrator or any law enforcement official upon request. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the requested exemption, the 

operator will petition for an amendment to its grant of exemption. 

6. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior 

to conducting further operations under the requested exemption. Functional test flights will only be 

conducted by a PIC with a VO and will remain at least 500 feet from other people. The functional test 

flight will be conducted in such a manner so as not to pose an undue hazard to persons and property. 

7. The operator will maintain and inspect the UAS to ensure that it is in a condition for safe operation. 
8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g. inoperable 

components, items, or equipment. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft will not be operated until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

9. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components. 

10. Each UAS operated under the requested exemption will comply with all manufacturer safety 

bulletins. 

11. All PICs will hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

12. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to operate 

the UAS safely in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability safely to operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption will occur under 

the terms of the requested exemption. Training operations will only be conducted during dedicated 

training sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

13. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) 

are not authorized. 

14. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management will be made available to the 

Administrator or any law enforcement official upon request. 

15. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 

16. If the UAS loses communications or loses its GPS signal, the operator will cause the UA to return to a 

predetermined location within the private or controlled access property. 

17. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 
18. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough available power for the UA to conduct the intended operation and to operate after that for at 

least five minutes or with the reserve power recommended by the manufacturer if greater. 

19. All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder will 

apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the COA attached to the requested exemption. 

20. All aircraft operated in accordance with this exemption will be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 

CFR part 45, Subpart C. Markings will be as large as practicable. 

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control 

Station of the UAS any time the aircraft is operating. These documents will be made available to the 

Administrator or any law enforcement official upon request. 

23. The UA will remain clear and give way to all manned aviation operations and activities at all times. 

24. The UAS will not be operated by the PIC from any moving device or vehicle. 

25. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the 

safety of nonparticipating persons’ and

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of operating 

closer to those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees, or essential persons are not considered nonparticipating persons 

under the requested exemption. 

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

according to instructions contained on the NTSB Web site: www.ntsb.gov. 

27. Further to protect the interests of the operators of other aircraft and of persons and property on the 

ground, Petitioner will maintain liability insurance coverage for all of its sUAS operations.
Granting the petition would be in the public interest because: 

1. The Congress of the United States has determined that early accommodation of sUAS into the 

National Airspace System advances the public interest. The Committee Report leading the House to 

adopted H.R. 658 said: 

"The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) 

can support more than 23,000 high-paying jobs in the United States. . . . The absence of a plan to 

integrate UASs into the NAS is a barrier to such job creation . . . ." 

Granting the Petition represents a step toward such integration, in the absence of a comprehensive 

regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest. 

2. Granting the Petition would facilitate the creation, display, and public distribution of art, long 

recognized as advancing the public interest. They are at the core of the activities that the First 

Amendment to the United States Constitution seeks to promote and to protect from governmental 

restrictions. 

Creative photography and video art fall well within the First Amendment’s protections. "Entertainment, 

as well as political and ideological speech, is protected; motion pictures, programs broadcast by radio 

and television, and live entertainment, such as musical and dramatic works fall within the First 

Amendment guarantee."

3. Granting the petition would enable Petitioner to demonstrate the commercial viability of creating art 

with new aeronautical technology Commercial creative art is protected as well as non-commercial art. 

The Patents and Copyrights Clause of the United States Constitution and the copyright statute’s 

protection of visual art and audiovisual works embody the proposition that more creative effort with 

respect to these kinds of work will be exerted when the creators are allowed to be paid for their works, 

thus increasing the production of artistic works. 

4. Granting the petition will allow the petitioner to respond to economic incentives to increase its 

creative production. The result will be an increase in the stock of artistic photography, including video 

for public enjoyment. 

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies 

advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging 

and developing civil aeronautics, including new aviation technology." Granting the Petition will enhance 

FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the 

United States because of the rapid pace of innovation in aeronautical and associated technologies, 

followed by their commercialization and their introduction of the marketplace. The drone technology 

that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technology. 

Preventing it from using this in air commerce subverts achievement of the goal. 

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into 

the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, 

specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS 

technologies. It mandated several steps by the FAA to accelerate the availability of these technologies in 

the National Airspace System, thereby representing a congressional determination that the public 

interest is served by making these technologies more widely available at the earliest practicable date. 
The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional 

mandate and meeting its obligation to enhance the public interest by making new technologies available 

by allowing the use of sUAS technologies in a manner that protects the public and the rest of the 

aviation community from significant risk. 

8. The commercial activities by Petitioner proposed in the Petition represent contributions to new forms 

of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act. 9. Granting the 

Petition will enhance aviation safety, thereby advancing the public interest. The Petitioner has 

committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the 

National Airspace System and to persons and property on the ground. Many others are flying sUAS 

without regard to these hazards. Granting the Petition will offer the Petitioner up as an example of how 

the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations 

to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS 

operations. 

Users of the National Airspace System are confronted by mushrooming threats from sUAS flown in 

defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe 

operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying 

the hazards to manned aircraft and to persons and property on the ground. 

Equivalent Level of Safety

All FARs from which relief has been requested have been addressed under Conditions and Limitations. 

This list has been compiled from existing exemptions and has been shown to have an equivalent level of 

safety with the FAR or does not apply to sUAS operations.

The Petition to use a UAS for aerial data collection and its proposed limitations are similar in all material 

respects to those approved by the FAA. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see 

11109 to Clayco, Inc. (see see 11213 to Aeryon Labs, Inc. (see Docket No. , and 12645 to Allied Drones

(see Docket No. FAA-2014-0804), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, 

rather than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in 

the public interest. 

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, and 11645 also 

apply to the situation presented by this Petition.
The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act 

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security. The Petition justifies grant of the requested 

exemptions allow the Petitioner to obtain aerial photography with its sUAS.

Respectfully,

Lloyd Wright

Wright Aerospace Technologies

6105 Garwood Cir

Flower Mound, TX 75028

l.wright41@verizon.net

214-912-7306