November 24, 2015 United States Department ofTransportation 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 ofAKA Drones LLC dba Blue SkEye Aerial Media under Section 333 ofthe FAA Modernization and Reform Act, 49 U.S.C. 44701(£), and 14 C.F.R. Part 11

On behalfofAKA 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 ofthe FAA Modernization and Reform Act ("Section 333"), Sub Section 44701(f) ofthe Federal Aviation Act, and pursuant to the procedures setforth in Part 11 ofthe 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 FAAto grant this petition in summaryfashion, 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 Systemsfor capturing aerial photography and video. AKA Drones delivers a diverse product offering which provides its clients with the very best in creative aerial andBlue Skeye Aerial Media Petition for Exemption November24,2015 Page 2 of6
multimedia marketing tools by leveraging state-of-the-arttechnologies in orderto provide the aforementioned services ata fraction oftraditional operating costs. This savings is atthe heart of AKA Drones' mission focus, and the operation of UAS is integral to its relevance in the space described above. The name ofthe applicant isAKA 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 Dronesweb address is www.blueskeye.net.
Exemptions requested 14 C.F.R. Part21 (airworthiness certification) 14 C.F.R. Part27 (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)


### Safetyequivalence orno adverse effecton 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 ofa loss ofGPS signal, the UASwill lock in its position and automatically gotoATTl mode and remain stable. Loss of connection to the remote control transmitter (orsoftware 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 ofthe UASs intended for use contain a powerstorage monitoring system and fail-safe modes to force controlled landing before the powersupply drops below operational levels. Should there be a loss ofpower, the UAVs are designed to perform a vertical hard landing with propellers providing stabilizing resistance during descent. Ifthe UAV encounters an unexpected obstade, the pilotwill either diverttheflight or maintain the UAV in a safe hover position awayfrom the obstacle.

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758Blue Skeye Aerial Media Petition for Exemption November24,2015 Page 3 of6
Given its small size, operational capabilities, and restricted area in which the UASwill operate, an exemption from Part21, Subpart H, Airworthiness Certificates, and 14 C.P.R. 91.7(a), is warranted, asAKA Drones' UAS satisfies the equivalent level ofsafety as compared with manned aircraft and meets the criteria in section 333. Operating the UAS without an airworthiness certificate in the restricted environment overvacant private property underthe conditions proposed will be saferthan operating a manned helicopter operating with an airworthiness certificate and notsubject to such conditions. Each UAV (with payload) is less than 55 pounds, carry no explosive materials orflammable liquid fuels, and would operate outside controlled airspace, with no passengers orcrew on board. Asthe 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 ofan incident or accident. The risk to an onboard pilot and crew during an incident oraccident is eliminated with the use ofa UAS for the aerial operations. Forthe reasons ouUined above, AKA Drones also seeks an exemption from the certification requirements for normal category rotorcraft in Part27.
In support ofAKA 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 Droneswill adhereto the following inspection and maintenance program: AKA Droneswill inspectthe UAS before and after each operation, as well as perform daily, weekly, monthly, and annual inspections, as setforth in its operations manual. Before each flight, the pilot in command will inspectthe UAS to ensure it is in a safe condition forflight. The preflight inspection will account for anydiscrepancy, such as an inoperable component, item, orequipment. AKA Droneswill not initiate a flight ifthe inspection reveals a condition that adversely affects the safety ofoperations, and will notoperate 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 orflight characteristics will undergo a functional flight test before return to service.
AKA Droneswill follow the manufacturer's UAS requirements relating to components, maintenance, overhaul, replacement, inspection and life limits. AKA Droneswill record all maintenance, alterations, and the functional flight test in the UAS logbook, induding total flight hours, description ofworkaccomplished, and the signature 

### ofthe UAS technician who returned the UASto service.
AKA Drones' UASs are equipped with an altimeterthat provides the pilotwith real-time telemetry data in addition to a constant digital display ofaltitude, speed, and UAS proximity. Moreover, the UASswill be operated within the visual line ofsight 

### ofthe pilot in command and observer and below 400 feet AGL. In addition, the flight controllers are programmed notto

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758Blue Skeye Aerial Media Petition for Exemption November24,2015 Page 4 of6
allow the aircraftto exceed the 400 feet ceiling, even ifthe pilot command input is in-conflict, or if communication with the remote control transmitterfails. Accordingly, AKA Drones does not believe an exemption from 14 C.F.R. 91.121 is required. In support ofAKA 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 ofthe UAS. The remote control transmitter/receiver combinationswill workwithin the 2.4 GHzand 5.8 Ghz FCC-approved ranges.



### UAVand UAS Operator Qualifications and Training In support ofAKA Drones' request for an exemption from the pilot certification and qualifications requirements in 14 C.F.R. 61.113(a) and (a), AKA Drones assertsthat an equivalent level of safety is achieved bythe UAS-specificexperience of its pilots. Each AKA Drones pilot, before conducting a commercial operation underthe requested exemption, will have successfully completed an aeronautical knowledge test, performed at least20takeoffs and landings ofthe particular UAV, and flown the particular UAVfor at least 10 hours. In addition, any pilotwill hold a valid airman certificate, either a private pilot, recreational pilot, orsport pilot certificate.



### UAVand UAS Operating Parameters AKA Droneswill operate its UASs in full compliance with the applicable manufacturer manual. AKA Drones' typical flight will be operated under400 feetAGL and within 2 km of the operator. All flights will be conducted within the visual line ofsight ofthe pilot in command, within noncontrolled airspace, with the consent ofany property ownerand/or developer. Although the UAS maybe operated in a metropolitan area, it will be controlled and monitored only by authorized personnel, and beflown below 400 feetAGL.
AKA Droneswill also notifythe appropriate Flight Standards District Office "("FSDO") and AirTraffic Control for anyoperation within five miles ofan airport.
AKA Droneswill conduct a briefing before each day's operations, which all personnel participating in the operations must attend. AKA Droneswill obtain written consent 

### ofanyownerofprivate propertywhere operations are to take place orthe organizer ofany event on that property. AKA Droneswill provide notice to anyadjacent buildings orstructures. AKA Droneswill limit its operations to daytimeVisual 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 1678.827.5758Blue Skeye Aerial Media Petition for Exemption November24,2015 Page 5 of6 

### 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 otherthan populated or congested, and not doserthan 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 riskto persons or property, avoid intrusion into unauthorized airspace, and avoid a public annoyance. Its UASswill not be operated over a highly-congested area oropen air assembly of persons. AKA Drones will make every reasonable effortto ensure that no unauthorized person will be on the land overwhich the UASswill be operated, and will provide notice to adjacent buildings and furnish proctors as may be necessaryto ensure that unauthorized persons do not come within the narrow parameters in which the UASswill be operated. Combined with the technological capabilities ofthe UASs and that the UASs will be operated within the visual line ofsight ofthe pilot and an observer, AKA Drones submits that its operational limitations provides an equivalent level ofsafetyto 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 cinematographyor photography {in support of

### government, commercial, or nonprofit organizations), • traffic orconstruction monitoring, • ecological, agricultural, or land management surveying, • infrastructure surveying, inspection, and improvement Operating UASs underthe limitations proposed byAKA Drones will avoid any riskofharm 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 

### Underthe requested exemption, AKA Drones will operate its UASswithin the United States, induding overthe territorial waters ofthe United States, and overthe high seas provided it will remain within the U.S.-controlled Flight Information Region.

Summaryfor Federal Register

David Baumgartner 1155 Lakestone Parkway 1 Woodstock, GA 30188 1678.827.5758Blue SkeyeAerial Media PetitionforExemption November24,2015 Page 6 of6
Should the FAAdeterminethat publication ofa summary is required, AKA Drones submitsthe following summaryto be included in the Federal Register: AKA Drones dba Blue SkEyeAerial Media seeks an exemption to operatethe DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire One unmanned aircraft systems to perform commercial services.

Sincerely,

David Baumgartner

Copyto: Todd Grondzki

David Baumgartner 1155 Lakestone Parkway

### IWoodstock, GA30188 1678.827.5758