Petition for Exemption concerning operation of Colorado Rocks, LLC Unmanned 

Aircraft Systems in accordance with Section 333 of the FAA Modernization and Reform 

Act of 2012 to allow commercial use of small unmanned aircraft systems (“sUAS”) for 

the purposes of: aerial photography and videography, cinematography, videography, 

mapping, crop surveying, real estate, inspections, and other flight operations that could be 

performed safely with the use of a sUAS. 

Name and Address of Applicant: 

Colorado Rocks, LLC 

Attn: Nick Paslay 

26451 Nanton Street 

Madison Heights, MI 48071 

Exemptions requested per 14 C.F.R and how the operator will maintain an 

equivalent level of safety or no adverse impact to safety: 

a. § 91.7(a) Civil Aircraft Airworthiness: No person shall operate a civil aircraft 

unless it is in an airworthy condition. Applicant seeks an exemption from this rule by 

ensuring that the sUAS is in an airworthy condition based on compliance with the 

operating documents of the makes and models identified prior to every flight. 

b. § 91.109 (a) Flight Instruction: 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 makes and models identified do not have dual 

controls. When flights are performed, no pilots will be on the aircraft. 

c. § 91.113 See and Avoid: Method for See-and-Avoid (§ 91.113). When weather 

conditions permit, regardless of whether an operation is conducted under 

instrument flight rules or visual flight rules, vigilance shall be maintained by 

each person operating an aircraft so as to see and avoid other aircraft. The sUAS is 

strictly line of sight and will always be in constant contact with the operator and visual 

observer. See and Avoid will be conducted by the operator and vigilance shall 

be maintained by each operator so as to “see and avoid” any other aircraft. There will 

be no adverse impact to the public because the visual observer will have constant eye 

contact with the sUAS at all times. 

d. § 91.119 Minimum Safe Altitudes, no person may operate an aircraft below the 

following altitudes: Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. Operations 

will never be conducted higher than 400ft AGL and will avoid congested or populated 

areas and will pose no risk to the public. The PIC will always operate the UA an 

appropriate distance from nonparticipants as required by § 91.119 and because of this 

will not adversely affect safety.

e. § 91.121 Altimeter settings: Each person operating an aircraft shall maintain the 
cruising altitude or fight level of that aircraft, as the case may be, by reference 

to an altimeter that is set to the appropriate station. The make and models identified 

use barometric altitude pressure but does not program in an altimeter setting. This 

exemption will benefit the public because the visual observer and operator are visual line 

of sight at all times, and will not pose any risk to the public and provide a level of safety 

required by this exemption. 

f. § 91.151 (b) Fuel requirements for flight in VFR conditions: No person may 

begin a flight in a rotorcraft under VFR conditions unless there is enough fuel to 

fly to the first point on intended landing and, assuming normal cruising speed, 

to fly that for at least 20 minutes. The sUAS is battery operated with a maximum 

flying time of 18-23 minutes. However, this poses no safety risk because the take-off 

point is near the landing point and will cause no safety hazard to the public. 

The PIC will ensure that there is enough power to conduct the operations. 

g. § 91.207 Emergency Locator Transmitters: No person may operate a U.S.- 

registered civil airplane unless there is attached to the airplane an approved 

automatic type emergency locator transmitter. The sUAS does not use an ELT, all 

operations are VFR and in line of sight with a visual observer. This exemption will 

benefit the public because the visual observer and operator are line of sight at all times 

with the sUAS.

Inspection and Maintenance. (14 C.F.R § 91.405, 91.407, 91.409). Applicant seeks an 

exemption from this rule by ensuring that the UAS is in an airworthy condition based on 

compliance with the operating documents of the makes and models identified. 

Pilot Qualifications (14 CFR 61.3, Requirement for certificates, ratings, and 

authorizations, and 14 CFR 61.5, Certificates and ratings issued under this part). 

a. Pilot Qualifications: All PIC will be current rated pilots with current medical. They

will hold either an airline, transport, commercial, private, recreation, or sport pilot

certificate and the PIC will hold a current FAA airman medical certificate.

9. Flight areas 

a. Operations will be conducted under VFR of no more than 400 feet AGL. The sUAS will 

be operated within visual line of sight at all times 

 

Make and model of the aircraft for proposed operations: 

DJI Phantom Series 

DJI Inspire Series 

Granting the exemption would be in the public interest and benefit the public as a 

whole: 

Small unmanned aircraft systems (“sUAS”) can provide similar services as full size 

manned aircraft at lower cost and with greater safety, providing exceptional value to 

Colorado Rock’s customers. In addition, there are several services that a sUAS can 
provide that would be impossible or unsafe with full size manned aircraft, such as certain 

angles/elevations for real estate photos and video. The small sUAS being utilized in this 

application will pose no threat to the public given its small size and lack of combustible 

fuel when compared to larger manned aircraft and will promote economic growth. 

Thank you for your time, and please direct all questions and concerns to Mr. Nick 

Paslay at Colorado Rocks, LLC: nick@gmail.com.