November 24, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Avenue, N E 

Washington, DC 20590 

Filed in www .regulations.gov 

AKA Drones, LLC 

dba Blue SkEye Aerial Media 

David Mark Baumgartner 

M: 210.473.5673/0: 678.827.5758 

david@blueskeye.net 

Re: Petition for Exemption of AKA Drones LLC dba Blue SkEye Aerial Media under 

Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 44701(£), and 14 

C.F.R. Part 11 

On behalf of AKA Drones LLC dba Blue SkEye Aerial Media ("AKA Drones"), we hereby seek an 

exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 

333 of the FAA Modernization and Reform Act ("Section 333"), Sub Section 44701(f) of the 

Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation 

Regulations, to allow AKA Drones to operate the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional, DJIInspire One, to provide: 

• Aerial photography services 

• Aerial video services 

AKA Drones will comply with the same conditions and limitations as provided in numerous Section 

333 exemptions granted recently. Accordingly, we respectfully ask the FAA to grant this petition in 

summary fashion, and obviate Federal Register publication and public comment. 

AKA Drones is an Atlanta based, aerial video media company specializing in the utilization of 

Unmanned Aircraft Systems for capturing aerial photography and video. AKA Drones delivers a 

diverse product offering which provides its clients with the very best in creative aerial and 
Blue Skeye Aerial Media Petition for Exemption 

November 24,2015 

Page 2 of6 

multimedia marketing tools by leveraging state-of-the-art technologies in order to provide the 

aforementioned services at a fraction of traditional operating costs. This savings is at the heart of 

AKA Drones' mission focus, and the operation of UAS is integral to its relevance in the space 

described above. 

The name of the applicant is AKA Drones LLC dba Blue SkEye Aerial Media. The primary 

contact is Mr. David Baumgartner, 155 Lakestone Parkway; Woodstock, GA 30188. Telephone is 

678-827-5758. His email is david@blueskeye.net and AKA Drones web address is 

www.blueskeye.net. 

Exemptions requested 

14 C.F.R. Part 21 (airworthiness certification) 

14 C.F.R. Part 27 (normal category rotorcraft) 

14 C.F.R. 61.113 (a) and (b) (pilot certification and qualification) 

14 C.F.R. 91.7(a) (airworthiness) 

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 

14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions) 

14 C.F.R. 91.405 (a) and (b) (maintenance) 

14 C.F.R. 91.407(a)(l) (approval for return to service) 

14 C.F.R. 91.409( a) (annual and airworthiness certification inspection) 

14 C.F.R. 91.417(a) and (b) (maintenance records) 

Safety equivalence or no adverse effect on safety 

Unmanned Aerial Vehicles and Systems 

The DJI flight controller, the common control platform in the listed devices has a number of 

technological capabilities to demonstrate its airworthiness. In the event of a loss of GPS signal, the 

UAS will lock in its position and automatically go to A TTl mode and remain stable. Loss of 

connection to the remote control transmitter (or software navigation controller) causes the vehide 

to immediately achieve a preset altitude, and then return to its home point and land in a controlled 

way. 

All of the UASs intended for use contain a power storage monitoring system and fail-safe modes 

to force controlled landing before the power supply drops below operational levels. Should there 

be a loss of power, the UAVs are designed to perform a vertical hard landing with propellers 

providing stabilizing resistance during descent. 

If the UAV encounters an unexpected obstade, the pilot will either divert the flight or maintain 

the UAV in a safe hover position away from the obstacle. 

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758 
Blue Skeye Aerial Media Petition for Exemption 

November 24,2015 

Page 3 of6 

Given its small size, operational capabilities, and restricted area in which the UAS will operate, an 

exemption from Part 21, Subpart H, Airworthiness Certificates, and 14 C.P.R. 91.7(a), is 

warranted, as AKA Drones' UAS satisfies the equivalent level of safety as compared with manned 

aircraft and meets the criteria in section 333. Operating the UAS without an airworthiness 

certificate in the restricted environment over vacant private property under the conditions 

proposed will be safer than operating a manned helicopter operating with an airworthiness 

certificate and not subject to such conditions. 

Each UAV (with payload) is less than 55 pounds, carry no explosive materials or flammable 

liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. 

As the FAA has found in granting an exemption to Clayco, Exemption No. 11109, at page 10: 

The limited weight significanUy reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The 

risk to an onboard pilot and crew during an incident or accident is eliminated with 

the use of a UAS for the aerial operations. 

For the reasons ouUined above, AKA Drones also seeks an exemption from the certification 

requirements for normal category rotorcraft in Part 27. 

In support of AKA Drones' request for an exemption from 14 C.F.R. 91.405(a), 91.407(a)(l), 

91.409(a)(l) and (2), and 91.417(a) and (b), AKA Drones will adhere to the following 

inspection and maintenance program: AKA Drones will inspect the UAS before and after each 

operation, as well as perform daily, weekly, monthly, and annual inspections, as set forth in its 

operations manual. Before each flight, the pilot in command will inspect the UAS to ensure it is 

in a safe condition for flight. The preflight inspection will account for any discrepancy, such as 

an inoperable component, item, or equipment. AKA Drones will not initiate a flight if the inspection 

reveals a condition that adversely affects the safety of operations, and will not operate that UAS 

until it is found to be in a safe condition. Any UAS that has undergone maintenance or an 

alteration that affects the UAS's operation or flight characteristics will undergo a functional 

flight test before return to service. 

AKA Drones will follow the manufacturer's UAS requirements relating to components, 

maintenance, overhaul, replacement, inspection and life limits. AKA Drones will record all 

maintenance, alterations, and the functional flight test in the UAS logbook, induding total flight 

hours, description of work accomplished, and the signature of the UAS technician who returned 

the UAS to service. 

AKA Drones' UASs are equipped with an altimeter that provides the pilot with real-time 

telemetry data in addition to a constant digital display of altitude, speed, and UAS proximity. 

Moreover, the UASs will be operated within the visual line of sight of the pilot in command and 

observer and below 400 feet AGL. In addition, the flight controllers are programmed not to 

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758 
Blue Skeye Aerial Media Petition for Exemption 

November 24,2015 

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allow the aircraft to exceed the 400 feet ceiling, even if the pilot command input is in-conflict, or if 

communication with the remote control transmitter fails. Accordingly, AKA Drones does 

not believe an exemption from 14 C.F.R. 91.121 is required. 

In support of AKA Drones' request for an exemption from fuel requirements in 14 C.F.R. 

91.151(a) and (b), we note that its UAS is battery-powered and is operated for brief periods of 

time, within the battery capacity of the UAS. 

The remote control transmitter/receiver combinations will work within the 2.4 GHz and 5.8 Ghz 

FCC-approved ranges. 

UAV and UAS Operator Qualifications and Training 

In support of AKA Drones' request for an exemption from the pilot certification and qualifications 

requirements in 14 C.F.R. 61.113(a) and (a), AKA Drones asserts that an equivalent level of 

safety is achieved by the UAS-specific experience of its pilots. Each AKA Drones pilot, before 

conducting a commercial operation under the requested exemption, will have successfully 

completed an aeronautical knowledge test, performed at least 20 takeoffs and landings of the 

particular UAV, and flown the particular UAV for at least 10 hours. In addition, any pilot will hold a 

valid airman certificate, either a private pilot, recreational pilot, or sport pilot certificate. 

UAV and UAS Operating Parameters 

AKA Drones will operate its UASs in full compliance with the applicable manufacturer 

manual. AKA Drones' typical flight will be operated under 400 feet AGL and within 2 km of 

the operator. 

All flights will be conducted within the visual line of sight of the pilot in command, within 

noncontrolled airspace, with the consent of any property owner and/or developer. Although the 

UAS may be operated in a metropolitan area, it will be controlled and monitored only by 

authorized personnel, and be flown below 400 feet AGL. 

AKA Drones will also notify the appropriate Flight Standards District Office "("FSDO") and 

Air Traffic Control for any operation within five miles of an airport. 

AKA Drones will conduct a briefing before each day's operations, which all personnel participating 

in the operations must attend. AKA Drones will obtain written consent of any owner of private 

property where operations are to take place or the organizer of any event on that property. AKA 

Drones will provide notice to any adjacent buildings or structures. AKA Drones will limit its 

operations to daytime Visual Flight Rules (" VFR"). 

AKA Drones seeks an exemption from the requirement in 14 C.F.R. 91.119, subsection (b), 

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758 
Blue Skeye Aerial Media Petition for Exemption 

November 24,2015 

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that an aircraft must remain at least 1 ,000 feet above any congested area or open air assembly of 

persons, and subsection {c), that an aircraft must remain at least 500 feet above any person or 

structure in an area other than populated or congested, and not doser than 500 feet to any 

person, vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft 

operations in mind. While AKA Drones may operate its UASs in a metropolitan area, the 

operations will be carefully pre-planned to minimize risk to persons or property, avoid intrusion 

into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a 

highly-congested area or open air assembly of persons. 

AKA Drones will make every reasonable effort to ensure that no unauthorized person will be 

on the land over which the UASs will be operated, and will provide notice to adjacent buildings 

and furnish proctors as may be necessary to ensure that unauthorized persons do not come within 

the narrow parameters in which the UASs will be operated. Combined with the technological 

capabilities of the UASs and that the UASs will be operated within the visual line of sight of the 

pilot and an observer, AKA Drones submits that its operational limitations provides an 

equivalent level of safety to that provided in section 91.119. 

Public interest 

AKA Drones' UAS operations will substantially benefit public and private organizations which 

have an interest in gathering critical information- atmospheric, situational, etc. - to support their 

operations. Depending on the use-case, these scenarios may indude: 

• aerial cinematography or photography {in support of government, commercial, or nonprofit 

organizations), 

• traffic or construction monitoring, 

• ecological, agricultural, or land management surveying, 

• infrastructure surveying, inspection, and improvement 

Operating UASs under the limitations proposed by AKA Drones will avoid any risk of harm to 

pilots as well as persons and people on the ground that would be present during the operation of 

manned helicopters. UAS operations will also require a much smaller energy footprint than with 

manned helicopters. 

Operations limited to the United States 

Under the requested exemption, AKA Drones will operate its UASs within the United States, 

induding over the territorial waters of the United States, and over the high seas provided it will 

remain within the U.S.-controlled Flight Information Region. 

Summary for Federal Register 

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758 
Blue Skeye Aerial Media Petition for Exemption 

November 24,2015 

Page 6 of6 

Should the FAA determine that publication of a summary is required, AKA Drones submits the 

following summary to be included in the Federal Register: 

AKA Drones dba Blue SkEye Aerial Media seeks an exemption to operate the DJI 

Phantom 2 Vision+, DJI Phantom 3, DJI Inspire One unmanned aircraft systems to 

perform commercial services. 

Sincerely, 

David Baumgartner 

Copy to: Todd Grondzki 

David Baumgartner 1155 Lakestone Parkway I Woodstock, GA 30188 1678.827.5758