UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**ANDREW RICARD FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF** 

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 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) CONCERNING COMMERCIAL OPERATION**  **OF BLADE 350 QX3 UNMANNED AIRCRAFT SYSTEMS** 

**PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012** 

**(PUBLIC LAW 112**

**- 95)** 

**Submitted on June 4th, 2015** Andrew Ricard 2045 Clubview Dr. Highland, MI 48356 (248) 892

- 2639

andrew.m.ricard@gmail .com**TABLE OF CONTENTS** Page

GLOSSARY OF ABBREVIATIONS...................................................................................3 SUMMARY...................................................................................................................... .....4
IN TRODUCTION AND INTERESTS OF PETITIONER....................................................4 BACKGROUND.................. ..................................................................................................4 BASI S FOR PETITION.........................................................................................................5 NAME AND ADDRESS OF PETITIONE R.......................................... ...............................6 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH ANDREW RI CARD SEEKS EXEMPTI ON................................................................. ...............................6
THE E XTENT OF RELIEF ANDREW RI CARD SEEKS AND THE REASON ANDREW RI CARD SEEKS THE RELIEF......................... ................................10 THE REASONS WHY GRANTING ANDREW RI CARD’S REQUEST WOULD BE IN THE PUBLIC IN TEREST ........................................... ..............................12 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY.................................................... ......................14 SUMMARY THAT CAN BE PUBLISHED IN THE FEDE RAL REGI STER..................2 7 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT ANDREW RICARD’S REQUEST......

................................ ........... ....28 CONCLUSION....................................................................................... .............................28 APPENDI CES ........................................................................................29**GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations
COA Certificat e of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System LOL Loss of Link
NAS National Airspace Sy stem NOTAM Notice to Airman
PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules
VLOS Visual L ine of Site VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing**SUMMARY**

ANDREW RI CARD seeks exemption from the requirements of 14 C.F.R §§ 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), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit ANDREW RI CARD to operate an Unmanned Aircraft S ys tem (UAS) for the commercial purpose of conduct ing aerial photograph y, aerial videograph y and cinematograph y, aerial filming and photograph y for real estate, aerial mapping, and aerial photography and videograph y for special events to include but not limited to weddings, private or public parties/event s, business advertisement(s), promotional events, environmental studies, and sports events.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** ANDREW RI CARD provides his clients with expertise and knowledge in advanced technologies and solutions to increase effi ciency , productivity and effectiveness. ANDREW RI CARD has hundreds of hours fl yi ng experience. The objective of ANDREW RI CARD and his aerial operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifical ly targeting:

• Construction sites before and after

• Appraisals

• Real

- estate marketing

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and private structures.

• Search and Rescue operations

• B usiness advertisement

• P romotional events

**BACKGROUND** Unmanned Aircraft Sy stems: Blade 350 QX3 AP Combo
ANDREW RI CARD seeks an exemption to operate a Blade 350 QX3 AP Combo system for compensation or hire within the NAS. The Blade 350 QX3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA ) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The Blade 350 QX3 has a maximum gross weight of approximately

2 pounds 2 ounces, while having a length of 18.3 inches width of 8.3 inches, height of 7.48 inches, and a maximum speed of approximately 34 knots. The Blade 350 QX3 UA is equipped with four main rotors; driven by L ithium Poly

mer battery powered electric motors.The Blade 350 QX3 UAS that will be operated by ANDREW RI CARD will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR PETITION** Petitioner, ANDREW RICARD, pursuant to the provis ions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y operate the Blade 350 QX3 UAS in the National Airspace Sy stem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 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). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, ANDREW RICARD operation of Blade 350 QX3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance w ith 14 C.F.R. Part 21, Subpart H. Accordingl y, ANDREW RI CARD requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an ai rworthiness certificate.
ANDREW RI CARD submits that the requested relief is proper since an equivalent level of safet y will be ensured. ANDREW RI CARD will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintena nce on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Lo g, and Blade 350 QX3 Instruction Manual). Furthermore, ANDREW RI CARD will document and maintain all maintenance records for the B lade 350 QX3 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by ANDREW RICARD to the extent necessary

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the Blade 350 QX3 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
ANDREW RI CARD seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Blade 350 QX3 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, ANDREW RI CARD submits that he will ensure that the Blade 350 QX3 UAS is in an airworth y condition, prior to every flight, by determining that the UAS is in compliance with the operatingdocuments (i.e., Monthly Maintenance Lo g, and Blade 350 QX3 Instruction Manual), and

that the aircraft are in a condition for safe flight.
ANDREW RI CARD also seeks an exemption from the requi rements of Section 91.121, entitled Altimeter Settings , as the Blade 350 QX3 UA will not have a typical barometric altimeter onboard. However, altitude information of the Blade 350 QX3 UA will be provided to the PI C via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with ANDREW RI CARD’s operation of the Blade 350 QX3 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , ANDREW RI CARD seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . ANDREW RI CARD submits that safety

will not be affected by

operation of the Blade 350 QX3 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fl y for a total duration of approximately 10 minutes to the f irst point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, ANDREW RI CARD provides the following information in support of its petition for exemption:

**A. Name And A**  **ddress Of The Petitioner.** The name and address of the Petitioner and point of contact is:
ANDREW RI CARD 2045 Clubview Dr. Highland, MI 48356 (248) 892

- 2639 andrew.m.ricard@gmail.com

**B. The Specific Sections Of 14 C.F.R. From Which ANDREW RICARD Seeks Exe**  **mption.**

**1. ANDREW RICARD Seeks Exemption From The Requirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:(a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A privat e pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensati on or hire. **2. ANDREW RICARD Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy con dition.
**3. ANDREW RICARD Seeks Exemption From The Requirements Of**  **Section 91.121.**

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
**4. ANDREW RICARD Seeks Exemption From The Requirements Of**  **Section 91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection(b), states the following:

(b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising s peed, to fly after that for at least 20 minutes.
**5. ANDREW RICARD Seeks Exemption From The Requirement Of**  **Section 91.405(a).** Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. ANDREW RICARD Seeks Exemption From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.] **7. ANDREW RICARD Seeks Exemption From The Requireme nts Of**  **Sections 91.409(a)(1) And 91.409(a)(2).** Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. ANDREW RICARD Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).** Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work perf

ormed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and record s of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (o r reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records co ntaining the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retain ed and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
**C. The Extent Of Relief ANDREW RICARD Seeks And The Reason ANDREW RICARD Seeks The Relief.** 

**1. Extent Of Relief ANDREW RICARD Seeks And The Reason ANDREW RICARD Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met cert ain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hi re, act as PI C of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more full y below, ANDREW RI CARD submits that an equivalent level of safet y will be maintained because no PIC will be allowed to operate the Blade 350 QX3 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PI C is able to safely operate the Blade 350 QX3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, ANDREW RI CARD submits that all flights of the Blade 350 QX3 UAS, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to ANDREW RI CARD’s business; and (2) will not carry passengers or property

for compensation or hire.

**2. Extent Of Relief ANDREW RICARD Seeks And The Reason ANDREW RICARD Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent

required to allow ANDREW RI CARD to determine that the Blade 350 QX3 UAS is in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the ANDREW RI CARD Aerial Operations Manual, Monthly Maintenance Log, and Blade 350 QX3 Instruction Manual).
ANDREW RI CARD seeks the requested relief because the Blade 350 QX3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, ANDREW RICARD will ensure that the Blade 350 QX3 UAS is in airworthy conditi on based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and Blade 350 QX3 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions an d limitations below.

**3. Extent Of Relief ANDREW RICARD Seeks And The Reason ANDREW RICARD Seeks Relief From Section 91.121.** 

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the Blade 350 QX3 UAS, whic h utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerni ng UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), ANDREW RI CARD seeks the requested relief because the Blade 350 QX3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric press ure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more fully set fo rth herein, an equivalent level of safet y will be maintained since the Blade 350 QX3 UA are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each fli ght, and limits (geo

- fences) will also be preset and established prior to each flight.

**4. Extent Of Relief ANDREW RICARD Seeks And The Reason ANDREW RICARD Seeks Relief From Section 91.151(b).** 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered Blade 350 QX3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. ANDREW RI CARD seeks the requested relief because without an exemption from Section 91.151(b),the flight time duration of the battery powere d Blade 350 QX3 UA will severel y constrain the practicality

of any aerial video or still photo flight operations that ANDREW RI CARD proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the Blade 350 QX3 UAS, the Blade 350 QX3 operating documents, and ANDREW RI CARD’s proposed operating limitations, ensure that ANDREW RI CARD will safel y operate the battery powered Blade 350 QX3 UA during daylight hours in visual meteorological conditions (VMC), und er visual flight rules (VFR), with enough battery power to fl y for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

**5. Extent Of Relief ANDREW RICARD Seek s And The Reason ANDREW**  **RICARD Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).** 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, ANDREW RI CARD requests relief from these Sections because the Blade 350 QX3 UAS does not require an airworthiness certificate. As set forth more full y below, Blade 350 QX3 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, ANDREW RI CARD will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the A NDREW RI CARD Aerial Operations Manual, Monthly Maintenance Log, and Blade 350 QX3 Instruction Manual). Furthermore, ANDREW RI CARD will document and maintain all maintenance records for the Blade 350 QX3 UAS.
**D. The Reasons Why Granting ANDREW RICARD’S Request Would Be In The**  **Public Interest; That Is, How It Would Benefit The Public As A Whole.**

Granting the present Petition will further the public interest b y allowing ANDREW RI CARD to safely , efficiently , and econo mically perform aerial photography , aerial videograph y and cinematograph y, aerial filming and photograph y for real estate, aerial mapping, and aerial photograph y and videograph y for special events to include but not limited to weddings, private or public p arties/events, business advertisement(s), promotional events, environmental studies, and sports events over certain areas of the United States.

. Additionally , use of the Blade 350 QX3 UAS will decrease congestion of the NAS, reduce pollution, and provide s ignificant benefits to the economy . Notably , the benefits of ANDREW RI CARD’s proposed operation of the Blade 350 QX3 UAS will be realized without implicating any

privacy issues.**1. The Public Will Benefit From Decreased Congestion Of The NAS.**

The Blade 350 QX3 UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Blade 350 QX3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Blade 350 QX3 UA do es not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial v ideo and photograph y missions would result in fewer aircraft that must be handled by

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of T he**  **Blade 350 QX3 UAS.** 

Conducting aerial acquisitions with the Blade 350 QX3 UAS, instead of manned aircraft, will greatly

benefit the public by

drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photograph y flight operations. By using battery power and electric motors, Blade 350 QX3 UAS produce s no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are t ypically utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The Blade 350 QX3 UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine. By using the Blade 350 QX3 UAS to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associat ed with traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the Blade 350 QX3 UA (weighing approximately 2 pounds 2 ounces at its maximum gross weights with lengths of 18.3 inches, widths of 18.3 inches, and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty pically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing Aerial Video and Photography Operations With The Blade 350 QX3**  **UAS Will Benefit The**  **Economy.**In addition to being safe and efficient, the Blade 350 QX3 UAS is also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the Blade 350 QX3 UAS will allow United States based companies, like ANDREW RI CARD , to remain competitive and contribute to growth of the U.S. economy

. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned an d operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered Blade 350 QX3 UAS is one such technology that not onl y allows companies greater operational flexibility compared to manned aircraft , but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the Blade 350 QX3 UAS, companies such as ANDREW RI CARD , can remain competitive and profitable, and therefore, provide greater job stability to emplo ye es and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the Blade 350 QX3 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and ab road. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, ANDREW RI CARD ’s proposed operation of the Blade 350 QX3 UAS will not implicate any

privacy issues. Specificall y, the Bl ade 350 QX3 UAS will be operated onl y in compliance with operating documents (i.e., the ANDREW RI CARD Aerial Operations Manual, Monthly

Maintenance Log, and Blade 350 QX3 Instruction Manual) which requires property owner involvement as well as local law en forcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Pro**  **vide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  **ANDREW RICARD Seeks Exemption.** 

**1. Reasons Why The Blade 350 QX3**  **UA Meet**  **s The Conditions Of The FAA**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**

In consideration o f the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, ANDREW RICARD ’s operation of the Blade 350 QX3 UAS meet s the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or oth erwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a ) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, ANDREW RI CARD submits that the Blade 350 QX3 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the Blade 350 QX3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The Blade 350 QX3**  **UAS Demonstrate Its Safe Characteristics.** The Blade 350 QX3 UAS do not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The Blade 350 QX3**  **UAS.**

The technical specificat ions of the Blade 350 QX3 UAS are set forth b y the Blade 350 QX3 User Manual , attached hereto as Appendix A.

**ii. The Blade 350 QX3**  **UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational**  **Area.**

The Blade 350 QX3 UA S may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the Blade 350 QX3 UAS is provided at pages 9

- 12 of the Blade 350 QX3 User Manual, attached hereto as Appendix A.
**iii. The Bl**  **ade 350 QX3 UAS**  **Is Designed For Automatic Return To** 

**Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.** 

When the Control L ink is lost, the Blade 350 QX3 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seco nds, the Blade 350 QX3 UA do not reacquire control link data from the GCS, the UA will assume that the Control L ink is lost and the UAs will return to the home position (i.e., Return to Home ) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the Blade 350 QX3 UAS are set forth at pages 11

- 13 of the Blade 350 QX3 User Manual , attached hereto as Appendix A.

**iv. The Blade 350 QX3**  **GCS And Its Operation.**

A complete description of the operation and specifications of the Blade 350 QX3 GCS and flight control s oftware is provided at pages 11

- 12 of the Blade 350 QX3 User Manual. The Blade 350 QX3 User Manual is attached hereto as Appendix A

.

**b. Flight Operatio ns Of**  **The Blade 350 QX3**  **UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety**  **Observer.**ANDREW RI CARD will be the only person to act as a pilot in command (PIC) of Blade 350 QX3 UAS. Additionally , a safet y observer will assist him during flight time.

**c. Flights Of The**  **Blade 350 QX3 UAS**  **Will Be Conducted Pursuant To Specific Operating Limitations.** 

In seeking this exemption, ANDREW RI CARD proposes to commercially operate the Bla de 350 QX3 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the foll owing aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: Blade 350 QX3 AP Combo Unmanned Aircraft Sy stem . Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y.

3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The SO and PIC mus t be able to communicate verbally at all times.Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not p ermitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and l imitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedur es as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PI C must inspect the UAS to ensure th at it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a conditio n for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records.12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against dis crepancies discovered between inspections.

17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate.

18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qua lification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations m ay only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distanc e from nonparticipants in accordance with 14 C.F.R. § 91.119.19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is requir ed, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport man agement must be made available to the Administrator upon request.

21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.

22. If the UA lose s communications or loses its GPS signal, it must return to a pre - determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PI C must abort the flight in the event of unpredicted ob stacles or emergencies in accordance with the operating documents.

24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing p oint and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including clas s of airspace, altitude level and potential transponder requirements.26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) mar kings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request.

29. The UA must rem ain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may

not be operated b y the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparti cipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediate ly and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the risk ofoperating closer to those object s and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over priv ate or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident , or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

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

ANDREW RI CARD 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 Blade 350 QX3 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the Blade 350 QX3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering ANDREW RI CARD ’s proposed area of ope rations, 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 safel y operate the Blade 350 QX3 UAS, ANDREW RI CARD submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for ANDREW RI CARD ’s specific proposed flight operations. The FAA has prev iously

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, 111 50, 11153, 11156, 11158, 11159, 11160, 11161).ANDREW RI CARD will not allow any PIC to operate the Blade 350 QX3 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the Blade 350 QX3 UAS training and currency requirements, that the PI C is able to safely operate the Blade 350 QX3 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C 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 an d model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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 safet y during ANDREW RI CARD ’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
a ccumulated 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 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 FAA considers these minimum hour requirements to be inclusive rather than additiv e; 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 3 takeoffs and landings in the preceding 90 day s (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 operat ions. 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 exe mption 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 accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.Accordingl y , ANDREW RI CARD will ensure safe operations b y not allowing an y P IC to

operate the Blade 350 QX3 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safel y operate the Blade 350 QX3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.**3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**

**Would Not Adversel y Affect Safety.** 

The equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, ANDREW RI CARD will ensure that Blade 350 QX3 UAS is in an airworth y condition based upon the UAS’s compliance with its operat ing documents and as stated in the conditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption N os. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.** 

The e quivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the Blade 350 QX3 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with ANDREW RI CARD ’s operation of the Blade 350 QX3 UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Se ction 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously

granted relief from Section 91.121 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, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.** A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Blade 350 QX3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, ANDREW RI CARD will ensure that it will safely operate the battery

powered Blad e 350 QX3 UA during daylight hours in VFR conditions, with enough battery

power to fl y for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in E xemption No. 11109, the technical specifications of the Blade 350 QX3 UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the Blade 350 QX3 UAS provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at app roximately

10% remaining battery

power. At the criticall y low battery level, the Blade 350 QX3 UAS will descend and land automatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would**  **Not Adversely Affect Safety.**

In seeking this exemption, ANDREW RI CARD submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because ANDREW RI CARD will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the ANDREW RI CARD Aerial Operations Manual, Monthly Maintenance Log, and Blade 350 QX3 Instruction Manual). Furthermore, ANDREW RI CARD will document and maintain all maintenance records for the Blade 350 QX3 UAS

. Since the Blade 350 QX3 UAS will be inspected as prescribed b y the operating documents, ANDREW RI CARD will maintain the equivalent level of safety established by Sections91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Blade 350 QX3 User Manual is

attached hereto as Appendi x A; a copy of the Blade 350 QX3 UAS Maintenance LOG is attached hereto as Appendix B

. Likewise, the exemption sought will not adversel y affect safety because ANDREW RI CARD will use trained technicians to perform maintenance, alterations or preventive mai ntenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all mai ntenance of the Blade 350 QX3 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of ANDREW RI CARD ’s proposed operating limitations, the operating documents, and the technical aspects of the Blade 350 QX3 UASs, ANDREW RI CARD submits that safety

will not be adversely

affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b ). The FAA has previousl y granted relief 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, 11 156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , ANDREW RICARD requests that the FAA prescribe special conditions for the intended operation of the Blade 350 QX3 UAS , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C. F.R. Part 21, Subpart H, and 14 C.F.R §§ 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). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may p rescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the Blade 350 QX3 UAS , since the airworthiness regulations of14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propell er because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 1 4 C.F.R. § 21.16, the FAA may prescribe special conditions for Ricard and Associates LL C ’s intended operation of the Blade 350 QX3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 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).

**A Summary That Can Be Published In The Federal Register, stating: The Rules**  **From Which ANDREW RICARD**  **Seeks Exemption:**

ANDREW RICARD seeks 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).

**A Brief Description Of The Nature Of The Exemption ANDREW RICARD**  **Seeks:**

This exemption will permit ANDREW RICARD to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.**Any Additional Information, Views, Or Arguments Available To Support ANDREW** 

**RICARD ’s**  **Request.**

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, ANDREW RI CARD ’s request for exemption may

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.
As discussed in detail above, ANDREW RI CARD will operate the Blade 350 QX3 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, ANDREW RI CARD see ks 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 Blade 350 QX3 UAS commerciall y, 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 mandat e of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, b y allowing ANDREW RICARD to safel y, efficientl y, and economically operate the Blade 350 QX3 UAS commerciall y within the NAS.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, ANDREW RI CARD respectfull y 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 Ricard and Associates LLC, to operate the Blade 350 QX3 UAS commercially for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: June 4th , 2015Respectfully submitted,

ANDREW RI CARD

_________________________ ANDREW RI CARD 2045 Clubview Dr. Highland, MI 48356 (248) 892

- 2639

Appendices :

A

– Blade 350 QX3 Manual:
B

– Monthly

Maintenance L og