SUBMISSION – PART 2

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. 

Michael Smith submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Chroma 

“Blade” Camera Drone UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely 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. 11062); and the airmanship skills 

necessary to safely 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 FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). Michael Smith will not allow any PIC to operate 

the Chroma “Blade” Camera Drone UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements and the Chroma “Blade” Camera Drone UAS training and 

currency requirements, that the PIC 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 PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, 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 Administrator 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. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC 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-rotor UAS. Prior to 

operations under Exemption No. 11062, the PIC 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 FAA considers 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 PIC must accomplish 3 
takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight hour requirements in Exemption No. 11062 are appropriate to practice and 

build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. 

The FAA also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, 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 PIC is 

required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 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

PIC 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, vessels, vehicles and structures. 

CONCLUSION

Michael Smith 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 

Chroma “Blade” Camera Drone UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United 

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA 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 accordance 

with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, 

Section 333, Michael Smith respectfully requests that the Administrator grant this Petition for 

an exemption from the requirements of 14 C.F.R Sections 61.113(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 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States. 

Dated: November 30, 2015 

Respectfully Submitted by:

Michael Smith
APPENDIX – A

CHROMA “BLADE” CAMERA DRONE UAS: TECHNICAL SPECIFICATIONS

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 horizontal down range ). In addition, Horizon Hobby / Chroma software provides realtime altitude and location information to the PIC via the linked, screened monitor: ST–10+ Controller 

(SN: BLH8620 – FCC ID: 2ACS5–ST10 and IC: 11554B-ST10) 

Additional Chroma “Blade” Camera Drone UAS Technical Specifications have been provided by the 

manufacturer to the FAA Data Base. 

APPENDIX - B

CHROMA “BLADE” CAMERA DRONE

USER MANUAL

http://www.horizonhobby.com/media/chroma/BLH8675.html

http://www.horizonhobby.com/pdf/BLH8665-manual-EN.pdf

APPENDIX – C

 MONTHLY 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:
APPENDIX - 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 display, is built right in.

Large, 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 controls

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 

programmed to make smooth, steady image capture easy. In fact, it can make you look 

like a pro even if you’ve never flown a camera drone before! All flight modes feature selfleveling 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 function.

This version of the Chroma drone gives you the added benefit of Follow Me and Watch 

Me flight modes that let you focus on getting the shot while the drone does the flying.

Look like a Pro with SAFE Plus

Smart Mode

Perfect for first-time drone flyers.

Stick Relativity moves drone in whatever direction the control stick is pushed, no matter 

which 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 when 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 tracking shots look great

Auto-holds position and altitude when control sticks are released

Follow Me Mode
Your 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 camera 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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APPENDIX - F