Sky360 Media, Kevin McKnight, 333 Exemption Petition 1

PETI TI ON FOR SECTION 333 EXEMPTION

– Sky 360 Media August 31 , 2015
U.S. Department of Transportation , Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey

Avenue, SE Washington, DC 20590
**Re: Petition of Sky360 Media**  **for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11**  Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Sky 360 Media he reby applies for an exemption from the Federal Aviation Regulations (“FARs”) identified below, to allow civil operation of small unmanned aerial sy stems (“sUAS” or “UAS”) as part of dail y business operations.
**TABLE OF CONTENTS** I. Description of Petitioner II. Description of Proposed Operation III. Sky 360 Media Proposed UAS Operations Meet the Requirements of Section 333 a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability b. Approval is Warranted Based on the Operational Re strictions Set Forth in the included UAS Standard Operating Guide IV

. Regulations From Which Exemption is Sought a. 1 4 C.F.R. Part 21, Subpart H: Airworthiness Certificates b. 14 C.F.R. Part 27: Airworthiness Standards fo r Normal Category Rotorcraft c. 14 C.F.R. §§ 45.23(b) and 45.27 (a): Marking of the Aircraft d. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Fli ght Manual in the Aircraft 2 f. 14 C.F.R. § 9 1.103: Preflight Actions g. 14 C.F.R. § 9 1.109(a): Flight Instruction h. 14 C.F.R. § 91 .119: Minimum Safe Altitudes i. 14 C.F.R. § 91.121: Altimeter Settings j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions k. 14 C.F.R. § 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections l. 14 C.F.R . Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilo t Privileges and L imitations V. Public Interest VI

. Privacy VII. Federal Register Summary VIII. APPENDIX A: Sky 360 Media UAS Standard Operating GuideSky360 Media, Kevin McKnight, 333 Exemption Petition 2

**I. Description of Petitioner**  Sky 360 Media , is owned by Kevin Brent McKnight. Kevin McKnight is a professional Pilot with an Ai rline Transport Pilot certificate and is a Certified Fl ight Instructor with 25 ye ars of flying experience . All UAV operations will be in accordance with Sky 360Media 's Standard Operating Procedures (SOPs) or as established b y the FAA. In accordance with 14 C.F.R. § 11.81(a), Sky 360 Media provides the following information in support of its Petition for Exemption. Name and Address for Petitioner: Sky 360 Media Attn: Kevin McKnight 112 Sagewood Rd Jamestown, NC 27282 Sky 360media@gmail.com 336

- 601

- 3945 Point of contact for this Petition and specific contact information is as follows: Kevin McKnight Owner 112 Sagewood Rd Jamestown, NC 27282
**II. Description of Proposed Operation**
S ky 360 Media proposes to conduct the operation of a UAS , specificall y the DJIPhantom 3 Professional , within the parameters of providing residential and commercial aerial photograph y and videography , such as real estate marketing, surveying, agricultural mapping and other flight operations that could be performed safel y and more cost effectivel y than a traditional manned aircraft. The Pilot in Command (“PI C”) for each operation will, at a minimum, be Kevin McKnight

. Sky 360 Media has adopted and incorporat ed man y of the AMA’s UAS Safet y Code (the “Code”) and Operating Guide’s (the “Guide”) procedures into its own safety code and guide, which sets forth the mandatory standard operating procedures for its proposed UAS operations as detailed herein. The except ion would be the location of operations that will take place at private residences with the authorization of the owner and not on propert y leased or owned b y the AMA. These procedures provide a baseline to ensure that the Phantom 3 Professional pilot posse ss sufficient knowledge of both airspace and the technology to operate safel y in the National Airspace S ys tem (“NAS”). Any other assistant or photographer will operate with Sky360 Media as the PI C in eachSky360 Media, Kevin McKnight, 333 Exemption Petition 3

operation and will meet the standards specified in the Guide, as well as an y other additional requirement the FAA requires under this application. **III. Proposed UAS Operations Meet the Requirements of Section 333** Proposed operations in this Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.

**a. Approval is Warranted Based on the UAS’s Size, Weight, Speed, and**  **Operational Capability** Sky 360 Media will employ the DJ I Phantom 3 Professional for the operations described in this Petition for Exemption. The UAS is classified as a small drone or hobby craft and is lawfully

used for recreational operations. The DJ I Phantom 3 Professional has a maximum take

- off weight of less than 5 pounds . The flight speed is limited to a maximum of 30 mph and it will not be flown at an altitude that exceeds 200 feet AGL. All flights will be managed in such a way that they can be safely terminated with a reserve battery power of 25% of the battery 's maximum charge. The DJ I Phantom 3 Professional does not carry any flammable propellant or fuel. It also has an integrated GPS sy stem that calculates the UAS's position and height and relay s that information via a secure connection to the operator. Through use of this GPS sy stem and the installed firmware, the user is able to set maximum height and radius in relation to a pre

- determined home point, restricting flight to a zone that is both approved b y the FAA and the owner of the property being photographed. Addit ionally , the UAS contains a failsafe mode if its connection to the remote control is lost, and this sy stem permits the UAS to return to a predetermined location and land without injury

or damage.
**b. Approval is Warranted Based on the Operational Restriction**  **s Set Forth in the UAS Standard Operating Guide**  The DJ I Phantom 3 Professional’s User Manual contain s all of the procedures and limitations necessary

to successfull y perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Sky 360 Media ’s proposed operations, below is a summary of operational limitations and conditions which will ensure an equivalent or higher level of safety to operations conducted under current regulatory

guidelines: 1. The DJ I Phantom 3 Professional weighs less than 5 pounds 2. Flights will be operated within the VL OS of the PI C and or an observer, at a minimum. 3. Maximum total flight time for each operational flight will be limited to 25% reserve battery

power remaining. 4. Flights will be operated at an altitude of no more than 200 feet AGL. 5. All operations will be conducted in class G airspace.Sky360 Media, Kevin McKnight, 333 Exemption Petition 4 6. Flights will be restricted to pre

- determined areas of the owner/clients property , which will always be located outside o f 5

- mile radius from an airport of any size or the necessary

NOTAM will be filed for safe operation in advance of operations. 7. Flight zones will be located at the maximum distance away from persons, inhabited structures, and vehicles that is possible gi ven the layout of the property . The flight zone in which operations occurs will be assigned based on the real time traffic, activi ties, and weather conditions. 8. Flights will be limited to a speed of 30 mph and vertical asce nt will be limited to 1 5 mph

. 9. The UAS will be operated and maintained in accordance with the requirements of the DJ I Phantom 3 Professional User Manual and any manufacturer Safet y Bulletins. 10. Prior to the operation, the flights will be full y preplanned and briefed, including possible contingencies and emergency procedures. 11. The UAS will have the capability to abort flight in the case of unpredicted obstacles or emergencies. 12. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 13. All UAS operations will occur in daylight, Visual Flight Rules ("VF R") conditions. Instrument flight rules flights are prohibited and no flights will occur at night, or in adverse weather conditions. 14. The UAS will be controlled by the DJ I Phantom 3 Professional Remote Control Sy stem and the radio frequency spectrum us ed for operation and control of the UA shall comply

with the Federal Communications Commission ("FCC") or other appropriate government oversight agency requirements. **IV. Regulations From Which Exemption is Sought** The Federal Aviation Act expressly grant s the FAA the authority to issue exemptions. This statutory

authorit y, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, including UASs, from its safety regulations and minimum standards when the Administrato r decides a requested exemption is in the public interest. Sky 360 Media seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using UAS. Listed below are: (1) the sp ecific sections of 14 C.F.R. for which exemption is sought, and; (2) reasons why the exemption would not adversel y affect safet y or provide a level of safety equivalent to the rule, including any operating procedures and safeguards that Sky 360 Media has ad opted which will ensure a level of safet y better than or equal to the rules from which exemption is sought.

**a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates**  Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness certificates. Sky 360 Media requests exemption from this subpart to operate the DJ I Phantom 3 Professional without the requirement for an airworthiness certificate. Based on the proposed UAS being limited in size,Sky360 Media, Kevin McKnight, 333 Exemption Petition 5 weight, speed, operating capabilities, and operating within VLOS, Sky 360 Media believes that an airworthiness certificate is not necessary to ensure an equivalent level of safety

to manned aircraft operations. Equ ivalent Level of Safety The UAS indicated is safe when taking into account its size, weight, speed, and operational capability . As set forth above, the DJ I Phantom 3 Professional weigh s less than 5 pounds and will be flown at no more than 30 mph and completely outside controlled airspace. Additionally , neither craft carries pilots nor passengers, carries no explosive materials and or flammable liquid fuels, and operates exclusively

within the parameters stated in the Guide. Operations conducted under this exemption will be closel y controlled and monitored by

the PIC and will be conducted in compliance with local public safet y requirements, to provide security for the area of operation. In all cases, the UAS operated under the proposed conditions , will be at least as safe as, or safer than conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions of the proposed UAS operations. Further, the DJ I Phantom 3 Professional does not need a means to communicate with other aircraft or ATC, because those capabilities will be possessed by the PI C and Observer, who are not onboard the UAS. See Grant of Exemption, Docket FAA

- 2014

- 0352 at 13. In addition, the UAS will be operated at all times in visual line

- of

- sight and in VFR conditions. Id.
**b. 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft**  Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent Sky360 Media UAS would otherwise require certification under Part 27, it seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

**c. 14 C.F.R. §§ 45.23(b) and 4**  **5.27(a): Marking of the Aircraft** Sky 360 Media seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 45.23(b) and 45.27(a). 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include onl y the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to th e cabin, cockpit, or pilot station, in lettersSky360 Media, Kevin McKnight, 333 Exemption Petition 6 not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable. 14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y § 45.23. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the DJ I Phantom 3 Professional is by definition “unmanned” and so has no entrance to a cabin, cockpit, or pilot station on which the above stated words can be placed. Given the size of the UAV, two

- inch lettering may be impossible. The word “Exempt” can be pl aced on the fuselage in compliance with 14 C.F.R. § 45.29(f). Equivalent Level of Safety The equivalent level of safety will be provided b y having the DJ I Phantom 3 Professional marked on its fuselage as required b y 14 C.F.R. § 45.29(f) where the pilot, observer and others working with the UAS will see the identification of the DJIPhantom 3 Professional as “Exempt” if so desired. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
**d. 14 C.F.R.**  **§ 91.7(a): Civil Aircraft Airworthiness** The regulation requires that no person may operate a civil aircraft unless it is in airworth y condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no F AA regulatory standard will exist for determining airworthiness. Given the size of the DJ I Phantom 3 Professional the description of proposed operations above, an equivalent level of safety will be provided.

**e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Ci** **vil Aircraft Flight Manual in the Aircraft**  14 C.F.R. § 91.9(b)(2) states: (b) No person may

operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is required b y § 21.5 of this chapter, unless there is availa ble in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. 14 C.F.R. § 91.203(a) and (b) state:Sky360 Media, Kevin McKnight, 333 Exemption Petition 7 (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (b) No person may

operate a civil aircraft unless the airworthiness certificate required b y paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is l egible to passengers or crew. Given the small size and configuration of the DJ I Phantom 3 Professional , it would be impossible to keep airworthiness documents and other aircraft manuals on board the UAS because there is simply no room. Also the UAS has no cabin or cockpit. Equivalent Level of Safety In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, Attorney , AGC

- 220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from which he or she is operating the aircraft. As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access to these key

documents during flight. Therefore, an equivalent level of safety will be achieved be ensuring that the pilot has access to the documents at the ground control station or point of control from which he or she is piloting the DJ I Phantom 3 Professional.
**f. 14 C.F.R. § 91.103: Prefli**  **ght Actions** This regulation requires each pilot in command to take certain actions before flight to ensure the safety of flight. As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Equivalent Level of Safet

y An equivalent level of safety will be provided through the PIC following the procedures set forth in the Guide and Manufacturer’s User Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff d istances and aircraft performance data before initiation of flight. The PI C will account for all relevant site

- specific conditions in the preflight procedures. The FAA has granted exemption from this regulation to other small UAS operators. See Exemption N o. 11109. Additionally , the PI C, Kevin McKnight , also being a licensed pilot, understands the importance of being prepared to fl y as an airman and will always adhere to the same IAMSAFE checklist followed when fl yi ng manned aircraft.Sky360 Media, Kevin McKnight, 333 Exemption Petition 8 **g. 14 C.F.R. § 91.109**  **(a): Flight Instruction** Sky 360 Media seeks an exemption from flight instruction requirements contained within 14 C.F.R. § 91.109(a). This section provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has ful ly functioning dual controls. Equivalent Safety Protocol For student training purposes the PI C and student may use a "buddy box" system that utilizes two transmitters when applicable. The transmitter of the student is connected b y a trainer cab le to another transmitter (master transmitter) controlled by the PIC instructor. The PI C Instructor is able to control the UAS with his or her transmitter then flip a switch to turn control over to the student and flip the switch again to reclaim control. Inthis way , the PIC Instructor can easil y demonstrate how to fl y the UAS or rescue the UAS if the student makes a poor aeronautical decision without passing the same transmitter back and forth to preserve safety

to the NAS and manned aircraft operations. Given the size and speed of the UAS that Sky 360 Media intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required b y the Guide, all persons will be a safe distance away in the event that any

difficulties during flight instruction occurs. Moreover, Petitioner will conduct training in a controlled and sterile environment. As required b y the Guide, training and instruction will be conducted in a sterile area on propert y that is owned and controlled by Sky 360 Media . These facilities will not be open to the public during UAS operations, and access will be restricted to authorized business personnel involved with the compan y. **h. 14 C.F.R. § 91.119: Minimum S**  **afe Altitudes** Sky 360 Media requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away

f rom any person, vessel, vehicle, or structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed UAS operations will occur at under 200 feet AGL. Furth er, while the DJ I Phantom 3 Professional will never be flown in or over congested areas, due to the nature and location of the proposedSky360 Media, Kevin McKnight, 333 Exemption Petition 9 operations, the PI C, Observer(s), Instructors and/or Students may at times be less than 200 feet away from the UAS. Equivalent Safety Protocol Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel onboard the DJ I Phantom 3 Professional , any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safet y will be achieved given the size, weight, and 10 speed of the DJ I Phantom 3 Professional , as well as the controlled and sterile location where the operations will occur. In order to avoid an y risk to manned aircraft, flight operations will be restricted to 200 feet AGL or below. As set forth in the Guide, the DJ I Phantom 3 Professional flight height and radius restrictions will be set according to each operato r’s level of experience which will be judged b y the PI C. The DJ I Phantom 3 Professional will be operated in an area that is owned by the client and closed to the public when in use. These restrictions will ensure that the proposed UAS operations are perfor med in a manner that protects the safety of participants, nonparticipants, the UAS, and other property. **i. 14 C.F.R. § 91.121: Altimeter Settings**  This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level b y reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the DJIPhantom 3 Professional does not have a barometric altimeter, but rather a GPS altitude read out. Equivalent Safety Protocol The Guide requires compass calibration prior to each operation of the DJ I P hantom 3 Professional to ensure the GPS functions correctly . The DJ I Phantom 3 Professional User Manuel contains instructions for achieving this and the manufacturer, DJ I, will provide additional support if necessary. **j. 14 C.F.R. § 91.151(a): Fuel Requirem**  **ents for Flight in VFR Conditions** Sky 360 Media requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person may

begin a flight in an airplane under VFR conditions unless (consideri ng wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

– i. During the day , to fl y after that for at least 25 minutes; orSky360 Media, Kevin McKnight, 333 Exemption Petition 10 ii. At night, to fly

after that for at least 45 m inutes. Here, the technological limitations on the energy capabilities of the Intelligent Flight Battery

(PH3

- 4480mAh

- 15.2V) used in the DJIPhantom 3 Professional means that no meaningful flight operations can be conducted with the DJIPhantom 3 Professional while still maintaining a 30

- minute battery reserve . An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Equivalent Safety Protocol The battery powering the DJIPhantom 3 Professional provide s approximately 25 minutes of flight time. Training operations will be limited to a minimum voltage to ensure appropriate reserve battery to maintain an equivalent level of safet y at all times. The UAS will notify

the operator when they

are approaching and they are required to land at their home point and either switch out the battery or pause operations for recharging. If both the operator and PI C fail to land the UAS prior to the allotted minimum voltage, the UAS will autonomously return to its original launch position.
**k. 14 C.F.R. §§ 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections**  Sky 360 Media seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R., sections 91.405, 91.407, 91.409, and 91.417. These rules specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405( a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired as described in part 43 of this chapter.”) Exemption fro m these rules is requested because these sections of Title 14 require the aircraft to be maintained and inspected in accordance with Part 43, which only applies to aircraft with an airworthiness certificate. Therefore, based on the exemptions sought, these sections do not apply to Sky360 Media proposed UAS operations. Equivalent Safety Protocol Maintenance will be accomplished by authorized operators, staff, and/or contracted labor pursuant to the Guide and the Manufacturer’s User Manual. An equivalent level of safet y will be achieved because a UAS like the DJ I Phantom 3 Professional or like craft and its platform are very limited in size, will carry a small payload, and will operate onl y in defined areas for limited periods of time. If mechanical issues arise the DJ I Phantom 3 Professional will be able to land immediately

on propert y owned b y the client and or owner of the craft to receive immediate maintenance. As provided in the Guide and Manufacturer’s User Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and will keep a log of an y maintenance performed.Sky360 Media, Kevin McKnight, 333 Exemption Petition 11 **l. 14 C.F.R. Part 61, 14 C.F.R. §§ 61.3, 61.113: Private Pilot Privileges and**  **Limitations** Sky 360 Media will serve as the PI C for all flight operations and the instructor/coinstructor of any course including an element of drone flight. This should qualify

persons with a private pilot’s certificate, among other qualifications, to instruct drone operation education when necessary . However, as is the nature of the proposed operations, introductory flight instructi on using the DJIPhantom 3 Professional UAS will be provided to staff who will likely not have a private, or an y typ e of, pilot’s license. Accordingl y, Sky 360 Media seeks exemption from 14 CFR Part 61, including 14 CFR § 61.3 to the extent that these regul ations are inter

preted as requiring a student receiving UAS operation instruction to have a private pilot's certificate. All student instruction flights will be conducted under closely controlled circumstances, outside of navigable airspace and away

from p ersons or propert y not involved in the instruction. In addition, the student instruction flights will be conducted under the close supervision of an instructor acting as PIC. In addition, to the extent that Sky 360 Media may be employing persons with a private pilot’s license to operate its UAS, an exemption is also sought from 14 C.F.R § 61.113, which restricts private pilot certificate holders from fl yi ng aircraft for compensation or hire, and which would also require a second class medical certificate. The purpose of this section is to ensure the skill and competency

of any PI C where the aircraft is carryingpassengers or cargo for hire. In this case, while instructors acting as PI C during UAS operations will be doing so for educational purposes as part of Sky 360 Media staff, the DJ I Phantom 3 Professional or like craft carries neither passengers nor cargo. Moreover, in the Astraeus Aerial Grant of Exemption (FAA Docket No. FAA

- 2014

- 0352), the FAA determined that the unique characteristics of UAS operatio n outside of controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PI C to have a Commercial Pilot Certificate and Class I or II Medical Certificate. Equivalent Level of Safety Sky 360 Media will ensure an equivalent level of safety to the regulatory requirements of 14 C.F.R. Part 61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safet y procedures provided in the Guide. In addition to training and experience requirements and limitat ions, Sky360 Media has placed additional restrictions on its proposed UAS operations to ensure an extra margin of safety

. The UAS will only

operate in a controlled and sterile area away from persons and propert y not involved in the operation. It will be fl own based on VLOS at no more than 200 feet AGL. Collectively , these procedures ensure that the proposed UAS operations can be conducted safely

. **V. Public Interest**Sky360 Media, Kevin McKnight, 333 Exemption Petition 12 Because the technology

to provide photographs and video graph y that can better facilitate clients’ needs to a degree that is not possible from traditional photograph y the public will be well served b y offering aerial photographs and video that can better produce the desired results. Some of which include the depiction of the beauty and aestheti cs of a property for marketing purposes or the location of a propert y to surrounding adverse conditions that may affect the various decision process es
. **VI. Privacy** All of Sky 360 Media UAS operations shall be conducted in accordance with applicable federal, state, or local laws regarding privacy

. Sky 360 Media will not conduct flight operations over property that it does not own or control without the prior consent and knowledge of the p ropert y owner. Moreover, Sky 360 Media will not capture or use images from restricted areas requiring privacy and or confidentiality

under an y circumstance. This does not mean, however, that images may not be taken that are permitted by law and do not requi re a level of privacy that is an exception to the norm. **VII. Federal Register Summary** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, should it be determined that publication is needed: Petiti oner seeks an exemption from the following sections in Title 14 of the Code of Federal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.3; 61.113; 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405 (a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b). The exemption will enhance safety b y reducing risk to the general public and property owners b y (a) ensuring that the operations of the UAS described above are recognized by the FAA in the form of an exemption (b) how to safel y operate small UAS in furtherance of career objectives and to the benefit of public safety while providing a valuable photography and videograph y service b y Sky 360 Media to provide flight operations that can be performed safel y and more cost effectivel y than a traditional manned aircraft

. Sincerel y,

Kevin McKnightSky360 Media, Kevin McKnight, 333 Exemption Petition 13

Sky 360 Media 112 Sagewood Rd Jamestown, NC 27282Sky360 Media, Kevin McKnight, 333 Exemption Petition 14 **APPENDIX A Sky360 Media**  **UAS Standard Operating Guide** ▫ Any UAS in operation must weigh less than 55 pounds at its maximum take

- off weight. ▫ Flights will be operated within the VL OS of the PI C and an observer, at a minimum. ▫ Maximum total flight time for each operational flight will be limited to 25% reserve battery power remaining. ▫ Flights will be operated at an altitude of no more than 200 feet AGL. ▫ Radius and altitude limitations will be set according to an assessment of the experience level of the operator for each flight. ▫ All operations will be conducted in class G airspace. ▫ Flights will be restricted to pre

- determined areas of the client/owners property

. ▫ Flight zones will be located at the maximum distance away from persons, inhabited structures, and vehicles that is possible given the layout of the propert y. The flight zone in which oper ations occurs will be assigned based on surface and air traffic, activities, and weather conditions. ▫ Flights will be limited to a speed of 30 mph and vertical ascent will be limited to 15 mph. ▫ The UAS will be operated and maintained in accordance with the requirements of the DJ I Phantom 3 Professional User Manual and an y manufacturer Safety Bulletins. ▫ Prior to the operation, the flights will be full y preplanned and briefed, including possible contingencies and emergency procedures. ▫ The UAS will have the capability to abort flight in the case of unpredicted obstacles or emergencies. ▫ All required permissions, NOTAM’s and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement , fire or other appropriate governmental agencies. ▫ All UAS operations will occur in daylight, Visual Flight Rules ("VFR") conditions. Instrument flight rules flights are prohibited and no flights will occur at night, or in adverse weather conditions.

▫ The UAS will be controlled by the DJ I Phantom 3 Professional Remote Control Sy stem or like sy stem and the radio frequency spectrum used for operation and control of the UA shall compl y with the Federal Communications Commission ("FCC") or other appropriat e government oversight agency

requirements.