January 9, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

To whom itmay concern,
In pursuantwith Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, OpenSky Drones LLC (OpenSky), an operator ofa small Unmanned Aircraft System (sUAS) for inspections and analysis in the Electrical Power Supply and Distribution industry, seeks an exemptionfrom the Federal Aviation Regulations (FARs) to allow commercial operations ofits sUAS. OpenSky's requested exemption would permitthe operation ofa sUAS under controlled conditions in power easements and around power poles thatis: (i) limited, (ii) predetermined, (iii) subjectto controlled access through our customers, and (iv) provides greater safety in connection with aircraft operations in. OpenSky believes that an exemption in the Electrical Power Supply and Distribution industry would enhance safety ofthe inspection crew and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to establish safe operations ofsUAS. Currently the Power companies are over inundated with excess inventory ofpower line towers. No updated current inventory existtherefore these companies spendtheir time in reactively in responses ofemergencies. Although mostthe currentmandate is to place powerlines underground, the majority ofthe infrastructure is still overhead and poses great dangers to workers as well as the public. In orderto assess the problems, climbers must get close to dangerous components for observation and measurements. The inspectors face manyhazards which include not only electrocution but falling from high elevations. OpenSky intends to provide a supportteamto collect data required for these assessments in the air to minimize the dangers necessaryfrom the ground and relay itwith minimal risk. Through mounted equipment onthe sUAS, we will be able to observe, analyze and acquire valuable data withoutthe risk. Therefore, the purpose ofthis petition is to improve safety for inspectors obtainingvisual assessments. OpenSky is an engineering companyin both Civil/Structural as well as RF disciplines specializing in remote sensing services to major wireless providers across the continental United States. OpenSky's sUAS flights canbe flown to achieve an aerial view, video recording, signal analysis, laser measurement ofstructures and property.

Data captured from the flights will assist in determining not only the physical condition ofthe power line equipment and information gather can provide indication ofstructural damage and hazards.

Information Supportingthis Petition as Specified in 14 C.F.R. §11.81(a) Your name and mailing address and, ifyou wish, other contactinformation such as a fax number, telephone number, or e-mail address; OpenSky Drones, LLC. Dan 

### QPham, P.E. 12453 NW 44th St Coral Springs, FL 33095 (954) 918-3888 Email: dan@OpenSkydrones.com
(b) The specific section or sections of 14 C.F.R. from which OpenSky seeks an exemption

· 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates

· 45.23- Display ofmarks; general

61.113- Private pilotprivileges and limitations: Pilotin command 91.103 -PreflightActions 91.105- Flight crewmembers at stations 91.109- Flightinstruction; Simulated instrumentflight and certain flight tests 91.119 -Minimum safe altitudes: General 91.121- Altimeter settings 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 91.203 -Civil aircraft: certification required 91.405- Maintenance required 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration

· 91.409- Inspections

· 91.417

- Maintenance records

We believe an exemption from the above regulations will allow OpenSky to conductthe needed work
as described above.
(c) The extent ofreliefOpenSky seeks, and the reason OpenSky seeks the relief OpenSky seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent to operate small UASs around issured properties.

14 C.F.R. 21

- Subpart H Certification procedures for products and parts, Airworthiness Certificates OpenSky seeks exemption from 14 C.F.R. 21, Subpart Hwhich states the certification procedures for products and parts as well as airworthiness certificates. Due to the limited airspace that OpenSky will be using atpowerline tower locations across the country, we are seeking exemption to the airworthiness certification process. OpenSky has developed our owntraining procedures and regulations to promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) ofthis petition. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set outin the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the Manual's requirements, and under the requirements and in compliance with local public safetyrequirements, to provide security for the area ofoperation.

14 C.F.R. § 45.23 (b). Marking oftheAircraft OpenSky seeks exemption from 14 C.F.R. 45.23,which discusses the display ofmarks. Specifically, section 45.23 states, "(a) each operator ofan aircraft must display on that aircraftmarks consisting of the Roman capital letter "N" (denoting United States registration) followed bythe registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capitalletter (b) when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable". OpenSky will need exemption from this regulation due to the small size ofthe aircraft and thatthere is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" can be placed onthe fuselage in compliance with §45.29 (f) wherethe pilot, observer and others workingwiththe sUAV will see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. OpenSky seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitations for the Pilot in command (PIC). OpenSky is seeking exemption from this regulation, because OpenSky believes thatthere is inconclusive evidence that a person with a private pilot certificate can successfully maneuver a sUAS without first hand flight experience withthe particular sUAS. In fact, having a private pilot license does not automatically ensure competence atflying an sUAS in 3rd personview as required to properly operate an sUAS within the required line ofsight. However, we believe thatthe PIC and our FOVO (Field Operation Visual Observer) mustbe able to understand and correctly interactwiththe general aviation community. Therefore, we believe our own flight trainingwith the sUAS will be
more than satisfactory. Our PIC and FOVO will be both certified in Ground School trainingto be able to properly interactwith General Aviation protocols. Theywill also actively pursue a private pilot's license as well have the necessary medical qualifications.

14 C.F.R. 91.103- PreflightActions OpenSky seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning a flight, become familiar with all available information concerningthatflight. This information must include: (a) For a flight under IFR or a flight notin the vicinity ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised by ATC; actions, including reviewing weather, flight battery requirements, landing and takeoffdistances, and aircraft performance databefore starting a flight. OpenSky's will be operating our sUAS in VFR. Our operations manual already includes preflight procedures directly pertainingto our sUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review ofany possible flight path ofgeneral aviation, our mission flight path and weather conditions amongst other parameters required to complete the mission.

14 C.F.R. 91.105 -Flightcrewmembers atstations OpenSky seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 91.105 states "(a) Duringtakeoffand landing, and while en route, each required flight crewmember shall (1) Be atthe crewmember station unless the absence is necessaryto perform duties in connection with the operation ofthe aircraft or in connection with physiological needs; and (2) Keep the safetybeltfastened while atthe crewmember station. (b) Each required flight crewmember ofa U.S.-registered civil aircraft shall, during takeoffand landing, keep his or her shoulder harness fastened while athis or her assigned duty station. This paragraph does not apply if (1) The seat atthe crewmember's station is not equipped with a shoulder harness; or (2) The crewmemberwould be unable to perform required duties withthe shoulder harness fastened.OpenSky will need exemption from this regulation due to the fact thatthe sUAS will nothave a flight
crew orcrew stations otherthan the PIC and a FOVO. The PIC will also nothave to be restrained into
a seatvia shoulder harness or safety belt atthe time ofthe flight.



### 14 C.F.R. 91.109 -Flightinstruction; Simulated instrumentflight and certain flight tests OpenSky seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No personmay operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrumentflight instruction maybe given in an airplane that is equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls, when (1) The instructorhas determined that the flight can be conducted safely; and (2) The person manipulating the controls has atleasta private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls maybe used for flight instructionto conducta flight review required by §61.56 ofthis chapter, orto obtain recentflight experience or an instrumentproficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals atboth pilot stations; (2) The pilot manipulatingthe controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command ofthe airplane, meets the requirements of§61.195(b), and has logged atleast 25 hours ofpilot-in-command flight time in the make and model ofairplane; and ( 4) The pilotin command andthe instructorhave determined the flight canbe conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other control seatis occupied by a safety pilotwho possesses at least a private pilot certificate with category and class ratings appropriate to the aircraftbeing flown. (2) The safety pilothas adequate vision forward and to each side ofthe aircraft, or a competentobserverin the aircraft adequately supplements the vision ofthe safety pilot; and (3) Except in the case oflighterthan-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight maybe conducted in a single-engine airplane, equipped with a single, functioning, throw over control wheel, in place offixed, dual controls ofthe elevator and ailerons, when (i) The safety pilot has determined thatthe flight canbe conducted safely; and (ii) The person manipulating the controls has atleast a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraftthatis being used for a flight testfor an airline transportpilot certificate or a class ortype rating on that certificate, orfor a part 121 proficiency flight test, unless the pilot seated atthe controls, otherthan the pilotbeing checked, is fully qualified to act as pilotin command ofthe aircraft". Again, Except when necessary for takeofforlanding, no person may operate an aircraft belowthe following altitudes: (a) Anywhere. An altitude allowing, ifa powerunit fails, an emergency landingwithout undue hazardto persons or property onthe surface. (b) Over congested areas. Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet ofthe aircraft. (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may notbe operated closer than 500 feet to anyperson, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conducted withouthazardto persons or property onthe surface- (1) Ahelicopter maybe operated atless thanthe minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operatingthe helicopter complies with anyroutes or altitudes specifically prescribed for helicopters bythe FAA; and (2) Apowered parachute orweight-shift-control aircraft maybe operated atless thanthe minimums prescribed in paragraph (c) ofthis section (a) Each person operating an aircraft shall maintain the cruising altitude
orflight level ofthat aircraft, as the case may be, byreference to an altimeterthatis set, when operating-(1) Below 18,000 feet MSL, to-(i) The currentreported altimeter setting ofa station alongthe route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure; or(2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowestusable flight level is determined bythe atmospheric pressure in the area ofoperation as shown in the following table: OpenSky believes thatthere is inconclusive evidence that a person with a private pilot certificate or license can successfully maneuver ortrain someone to use an sUAS withoutfirst hand flight experience withthe particular sUAS. Flying in 3rd person orientation requires built-up experience in thatform offlying for many years. Therefore, we believe our own flight training, pilotprotocols and first hand experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds the requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will be operated by a remote control, which will only require a single person operator and dual controls will notbe necessary.



### 14 C.F.R. 91.119- Minimum safe altitudes: General OpenSky seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Since Power line towers are much less than 500ft and our flight ceiling will be below400ft, this would not pertainto our sUAS operations



### 14 C.F.R. 91.121- Altimeter settings OpenSky seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowestusable flight level. C.F.R. 91.121 states, Current altimeter setting Lowest usable flight level 29.92 (orhigher) 180

29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent ofthe minimum altitude in feet and add the appropriate b ff: 

### · db 

### 1 d. th t rt d 

### 1r t tt. " num ero eet specrre e ow, accor mgto e curren repo e a rme er se mg: Current altimeter setting Adjustment factor 29.92 (orhigher) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000
OpenSky's sUAS uses both GPS altitude andbarometric sensors and relays that information to our ground station. However, this data is used help the sUAS to automatically maintain position hold at the required elevation and therefore this code is notpertinentthe functionality ofthis sUAS.



### 14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions OpenSky seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight inVFR conditions. Specifically, 91.151 states "(a) No person may begin a flight in an airplane underVFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly tothe first point ofintended landing and, assuming normal cruising speed- (1) During the day, to fly after that for atleast 30 minutes; or (2) At night, to fly after thatfor at least45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly afterthatfor atleast 20 minutes". OpenSky's sUAS has a typical mission time ofless than 15 minutes with maximum flight time of 25 minutes. Since this amount less than the 30 minute reserve minimum, this reserve minimum would not even make sense in allowing the sUAS a chance to fly. According to OpenSky's aircraft flight manual, the PIC is instructedto maintain flight until batterypower reaches 25%, or 1st level warning. At this level, landing procedures will be intiated. Once the sUAS reads 20%, 2nd level warning, the flight control system automaticallytake over and initiates safe landing sequence atthe logged in takeoffpoint. OpenSkj policy outlined in our operating flight manual achieves a satisfactory safety standards.

14 C.P.R. 91.203- Civil aircraft: certification required OpenSky seeks exemption from 14 C.P.R. 91.203, which discusses states:
(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit,
a copy ofthe applicable operations specifications issued under §21.197(c) ofthis chapter, appropriate sections ofthe air carrier manual requiredby parts 121 and 135 ofthis chapter containingthatportion ofthe operations specifications issued under §21.197(c), or an authorization under §91.611) must have on itthe registration number assigned to the aircraft under part47 ofthis chapter. However, the airworthiness certificate need not have on itan assigned special identification numberbefore 10 days after that number is first affixed to the aircraft. Arevised airworthiness certificate having on it an assigned special identification number, thathas been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, for operation withinthe United States, the second copy ofthe Aircraft registrationApplication as provided for in §47.31 (c), or a registration certification issued underthe laws ofa foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required byparagraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so thatitis legible to passengers or crew. (c) No person may operate an aircraftwith a fuel tankinstalled within the passenger compartment or a baggage compartmentunless the installation was accomplished pursuantto part 43 ofthis chapter, and a copy ofFAA Form 337 authorizingthatinstallation is onboardthe aircraft. (d) No person may operate a civil airplane (domestic orforeign) into or outofan airportin the United States unless it complies withthe fuel venting and exhaust emissions requirements ofpart 34 ofthis chapter". certifications. Specifically, 91.203 states" OpenSky believes that an appropriate and current airworthiness certificate would not be necessary to fly a sUAS given the size ofthe aircraft and the necessarylevel ofskill neededto operate the aircraft. Before puttingin to service, each ofour sUAS goes through our own airworthiness proceedures ofmiminum testflight and reliability checks. Also, our sUAS are recalibrated each atthe site location before each flight to ensure that all systems functions as designed. OpenSky seeks exemption from this regulation because we believe this rule was not meantfor a sUAS and operators.

14 C.F.R. 91.405, 91.407, 91.409, and 91.417OpenSky seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and maintenance records. In OpenSky's aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. OpenSky believes these regulations
are meantfor manned operated aircrafts and notunmanned systems, therefore making them unnecessary.
Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it necessaryto grantthis request. (d) The reasons why granting OpenSky's requestwould be in the public interest; thatis, howitwould benefit the public as a whole. OpenSky is classified as an engineering companybythe U.S. Department ofTransportation and provides services to aerial supportfor commercial interest. OpenSky's use ofa sUAS can assist in makingtask safer and minimize human exposure to being at dangerous elevations. OpenSky's sUAS usage will also reduce the time required to capture the needed imaging or data to convention helicopters or airplanes. Ultimately, the resultis quick completion oftask an reduction ofdangerous elevation perspective needs.
(e) The reasons why granting the exemption would not adversely affect safety, orhow the exemption would provide a level ofsafety at least equal to thatprovided by the rule from which OpenSky seeks exemption Our Engineering departmentwill provide a level ofsafetythat exceeds the level ofsafety required by the FAA for its use on sUAS. The following are OpenSky's safety procedures, features, regulations, and operating specifications for our sUAS:



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### • Our Squadron LeaderjChiefPilot in Charge is an engineer who has 10 years ofRC Model building and flight experience with over 1000 flight hours in Fixed-wing, Helicopter and Multi-Rotor 3rd person flight. He has been involved with flight design, experimentation and system optimization for model industry since 2008 though SAPAC, Inc. models. Our staffincludes an FAA-rated commercial flight instructor (ret) who coordinates our FOVO team in integration with general aviation. The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will be required to wear hard hats, safety vests, and safety glasses to protectthe head and eyes from potential mishaps during given operational flights including training ortesting ofsUAS. The flight area ofthe sUAS will be observed for besttake offand landing locations. Desired conditions include: flat and level surfaces clear ofdebris, atleast 15ftfrom powerlines and structures, and a minimum distance of 12ftfrom the PIC and observers. The sUAS will also be in the Visual Line ofSight (VLOS) to boththe PIC and FOVO during all flights. Flights musttake place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no evening or late night flights. The PIC(s) ofthe sUAS will atleast have 12 traininghours or 24 flights accrued before being designated working flights. All batteries mustbe charged completely before each flight and each flight must end when the battery has a 30% powerlevel remaining. Avisual safetyinspection will occur before each flight, testing propellertightness, security mount ofcamera/detection equipment, remote range test, and proper safety equipmentis adorned to PIC and FOVO. The sUAS will be flown under a height of500ftAGL

. No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so as to ensurethatthe sUAS is in a condition for safe flight operation and in a configuration appropriate for the purpose ofthe intended flight.• Ifthere is more thanjust an operator at a site during a flight, the PIC operator and observer
or FOVO will maintain two-way communication with each other during all operations; if unable to maintain two-way communications, or ifany condition occurs that may otherwise
cause the operation to be unsafe, the operatorwill immediately conclude the operation.
• Ifthe communication link is lost, the sUAS will go into fail-safe mode and safely descend to its designated home-pointlocation. Ifthe communication link is reconnected during fail-safe mode, control ofthe sUAS canbe regained before landing occurs atthe home-point location.
• There is no fuel orpayload to the sUAS, therefore there will be no potential explosives or risk ofexplosion ifa crash occurs with the sUAS.
• The sUAS will feature a built in compass that will be recalibrated at every siteto maintain accurate directional readings. The compass will also help in keeping the sUAS stable during flights.
• The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum of6 satellites will activate the Ready to Fly status.
• The weight ofthe sUAS is less than 10 lbs. with a maximum ascent speed of6 

### mjs and a descent speed of2 

### mjs. The aircrafts maximum flight speed is 15 

### mjs.
• The aircrafts vertical and horizontal aspect concerning hovering accuracy is 0.8m and 2.Sm respectfully. The typical aircraftwheelbase will be less than 600mm in length.
• The aircraftruns offa Li-Po battery.

(f) A summary FAA can publish inthe FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; and (2) Abriefdescription ofthe nature ofthe exemptionyou seek

Petitioner: OpenSky Drones, LLC.

Sections of14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 Description ofReliefSought: Petitioner seeks relieffrom the requirements of 14 C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct aerial inspection for power supply and distribution industry and their properties and subjectto operating procedures that meet or exceed those that FAA requires. (g) Any additional information, views or arguments available to supportyour request

Please seethe introduction to this exemption request. (h) Ifyou want to exercise the privileges ofyour exemption outside ofthe United States, the reason whyyou need to do so
The Operations described in this exemption requestwill be conducted wholly within the United States.

Attached hereto, and submitted as a 

### confidential document, is our Field Operations Manual. We respectfully submitthat good cause exists so thatthis confidential manual does not need to be published in the Federal Register.

Please do not hesitate to contact me via email at dan@OpenSkydrones.com ifyou have any questions
or concerns.Dan 

### QPham, P.E. Vice President, OpenSky Drones, LLC