**SUBMISSION**
**– PA**  **RT 2** 

**2. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 61.1 13(a)**  **And (b) Wo**  **uld Not Adversely**  **Affect Safety**

**.** Michael Smith submits that the equivalent level of safety established by Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the Chroma “Blade” Camera Drone UAS unless that PI C has demonstrated, by meeting minimum flight hour and currency

requirements, that the PI C is able to safel y operate the Chroma “Blade” Camera Drone UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Michael Smith’ s proposed area of operations, and the operating limitations set forth - above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 1 1062); and the ai rmanship skills necessary to safel y operate the Chroma “Blade” Camera Drone UAS, Michael Smith submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Michael Smith’ s specific proposed flight operations. The F AA has previously

granted relief from Section 61.1 13(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11 062, 1 1063, 1 1064, 1 1 065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 1 11 60, 1 11 61). Michael Smith will not allow any PIC to operate the Chroma “Blade” Camera Drone UAS unless that PI C has demonstrated, by meeting minimum flight - hour requirements and the Chroma “Blade” Camera Drone UAS training and currency requirements, that the PI C is able to safely operate the Chroma “Blade” Camera Drone UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically

, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency p urposes). As in Exemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Michael Smith’ s proposed operations. The Administr ator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpo se of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi - rot or UAS. Prior to operations under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the F AA cons iders these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi - rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PI C must accomplish 3takeof fs and landings in the preceding 90 day s (for currency purposes). The F

AA finds that at a minimum, the flight hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency

i n the skills necessary

to safel y conduct the petitioner ’s proposed operations. The F AA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr aining, proficiency , and experience - building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience - building flights the PI C is required to operate the UA with appropriate distances in accord ance with 14 C.F .R 91.1 19. Exemption No. 1 11 38 at page 15. Accordingly

, Michael Smith will ensure safe operations by not allowing any

PIC to operate the Chroma “Blade” Camera Drone UAS. Therefore, Michael Smith will be the only PI C to operate the Chroma “ Blade” Camera Drone UAS with a SO present. This will ensure that the Chroma “Blade” Camera Drone UAS will be operated in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, v essels, vehicles and structures. **CONCLUSION** Michael Smith seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Chroma “Blade” Camera Drone UAS c ommercially , without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y over certain areas of the United States. By granting this Petition, the F AA A dministrator will be fulfilling the Congressional mandate of the F

AA Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Michael Smith to safely , efficiently

, and economically

operate the Chroma “Blade” Camera Drone UAS commercially within the NAS. Therefore, in accord ance with the Federal Av iation Regulations and the F AA Modernization and Reform Act of 2012, Section 333, Michael Smith respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91. 405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), and permit Smith Inspection Services, LLC to operate the Chroma “Blade” Camera Drone UAS commerciall y for the purpose of conducting aerial video and phot ograph y over certain areas of the United States. Dated: November 30, 2015 Respectfully Submitted by : Michael Smith**APPENDIX**
**– A** 

**CHROMA**

**“BLADE” CAMERA**

**DRONE UAS: TECHNICAL**  **SPECIFICA**

**TIONS** Michael Smith will only

utilize safe and reliable UASs. Horizon Hobby / Chroma is an industry

leader in small UAS production. Horizon Hobby / Chroma UASs are loaded with software enabling the user to set parameters which will not allow flight outside of specific flight operations. Therefore, Parameters can be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. ( Note: In no case will flight operations extend above 500 feet AGL nor 1500 feet horiz ontal down range ). In addition, Horizon Hobby / Chroma software provides real time altitude and location information to the PI C via the linked, screened monitor: ST

– 10+ Controller (SN: BLH8620

– FCC ID: 2ACS5

– ST10 and I C: 1 1554B - ST10) Additional Chrom a “Blade” Camera Drone UAS T echnical Specifications have been provided b y the manufacturer to the F

AA Data Base.

**APPENDIX -**  **B CHROMA** 

**“BLADE” CAMERA**

**DRONE U**  **S E**  **R MA N**  **UA L**  http://www.horizonhobby .com/media/chroma/BLH8675.html http://www.horizonhobby .com/pdf/BLH8665 - manual - EN.pdf **APPENDIX**
**– C**  **MONTHL Y MAINTENANCE LOG** 

: **:$** Date(Issue) Discovered Date(Issue)

Addressed Issue – Description – Maintenance Conducted Maintenance Performed By: Print & Sign Software - Updates Airframe( Engines Propellers Camera (Gimbal) Landing Gear Vibration Dampening Other:**AP PENDIX**  **- D** **APPENDIX**
**– E** 



### Blade Chroma Drone RTF w**/ ST -**  **10+ Camera** Everything in One Box Flight - Ready Chroma Drone with Stabilized CGO3 4K Camera • ST - 10+ Controller with Touch - Screen Display • Long - Lasting 5400mAh LiPo Flight Battery • Flight Battery Charger • USB Programmer Cable Video Overview Everything at Your Fingertips. You don’t need a separate smart device with the ST - 10+ controller. Everything you need, including the camera controls and a touch - screen video d isplay, is built right in. Larg e, 5 1⁄2 inch touch - screen display with intuitive Android interface Displays live video and real - time telemetry info like speed, altitude and battery voltage Clearly marked switches and buttons Super- simple flight and camera c ontrols Slider switch for adjusting camera tilt Slider switch for adjusting drone speed Look Like a Pro. SAFE Plus technology gives you several flight modes that have been specially prog rammed to make smooth, steady image capture easy. In fact, it can mak e you look like a pro even if you’ve never flown a camera drone before! All flight modes feature selfleve ling and use GPS and altitude sensors to precisely hold position. SAFE Plus technology will even land the aircraft for you if you activate the Return Home f unction. This version of the Chroma drone gives you the added benefit of Follow Me and W atch Me f light modes that let you f ocus on getting the shot while the drone does the flying. Look like a Pro with SAFE Plus Smart Mode Perf ect for first - time d rone flyers. Stick Relativity moves drone in whatever direction the control stick is pushed, no matter wh ich way the nose is pointed Creates a SAFE CircleTM barrier that prevents the aircraft from flying too close to you Auto - holds position and altitude wh en control sticks are released AP Mode For more experienced drone pilots. Responds like a conventional drone without Stick Relativity Gives you greater control authority by turning off the SAFE Circle Keeps control response smooth so panning and track ing shots look great Auto - holds position and altitude when control sticks are released Follo w Me ModeYo ur built - in copilot. Frees you to focus on lining up the perfect shot Pan and tilt the camera while the drone follows Drone follows at an altitude and distance you set

Tracking Mode Be the Star. Drone follows and keeps the c amera pointed at whoever holds the ST10+ controller Drone follows at an altitude and distance you set Resume full control at any time Return Home Safe landings with the flip of a switch. Returns the drone to its start - up point and lands it for you Great for first - time flyers who aren’t ready to land themselves Easy way to regain visual contact if you lose sight in flight

Resume full control at any time Activates automatically if controller signal is lost

Adjustable Flight Boundaries Stay legal. Stay safe. Fly responsibly. Keeps the drone within altitude and distance limits you define Easily adjusted using the Chroma programmer Helps you avoid sensitive airspace ...and neighbors

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