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 It May 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 the motion picture and television industry, seeks an exemption from the Federal Aviation Regulations (FARs) to allow commercial operations ofits sUAS. Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established bythe FAA as required by Section 333.
As described more fully below, the requested exemption would permitthe operation ofsmall, unmanned and relatively inexpensive sUAS under controlled conditions in airspace thatis limited, predetermined, controlled as to access and would provide safety enhancements to the already safe operations in the film and television industrypresentlyusing conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system." Section 333(c) ofthe Reform Act.
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: Pilot in command • 91.103- PreflightActions • 91.105- Flight crewmembers at stations • 91.109- Flight instruction; Simulated instrument flight and certain flight tests . f)• 91.119- Minimum safe altitudes: General • 91.121-Altimetersettings • 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 (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 to record aerial video for cinematographic purposes. This exemption application is expressly submittedto fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the SecretaryofTransportationto consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In makingthis determination, the Secretary is required to determine whichtypes ofUASs do not create a hazard to users ofthe NAS orthe public orpose a threatto national securityin light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraftinthe national airspace system"
The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authoritybyits terms includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, thatincludes sUASs, from the requirementthat all civil aircraft musthave a current airworthiness certificate.
The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14CFR§91.203 (a) (1).



### 14 C.F.R. 21
- Subpart H Certification proceduresfor 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. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 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 under this exemption will be tightly controlled and monitored byboth the operator, pursuantto the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityfor the area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already applyto civil aircraft operated in connection with motion picture and television production, provide a greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed bythe UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load. OpenSky has developed our owntraining procedures and regulations to promote and provide safe flying experiences for our PIC(s) which canbe viewed in section (e) ofthis petition. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitoredbyboththe operator, pursuantto the Manual's requirements, and under the requirements and in compliance with local public safety requirements, 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 onthat aircraft marks 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 capital letter (b) when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted orlight-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display onthat aircraft near each entranceto 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, orpilot station for the aircraft. The words "Experimental" has been placed onthe fuselage in compliance with §45.29 (f) where the pilot, observer and others workingwith the sUAV will seethe identification ofthe UAS as "Experimental." The FAA has issuedthe following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.



### 14 C.F.R. § 

### 61.113 (a) & 

### (b): Private PilotPrivileges and Limitations: Pilotin Command. OpenSky seeks exemption from 14 C.F.R. 61.113, which discusses private pilotprivileges 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 withoutfirst hand flight experience with the particular sUAS. In fact, having a private pilot license does not automatically ensure competence at flying an sUAS in 3rct person view as required to properly operate an sUAS within the required line ofsight. However, we believe thatthe PIC and our FOVO (Field OperationVisual Observer) mustbe able to understand and correctly interact with the general aviation community. Therefore, we believe our ownflight training with 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 pilotin command shall, before beginning a flight, become familiar with all available information concerningthat flight. This information mustinclude: (a) For a flight under IFR or a flight not in 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 pilotin command has been advised byATC; actions, including reviewingweather, 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 at stations OpenSky seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 91.105 states "(a) During takeoffand landing, and while en route, each required flight crewmember shall (1) Be atthe crewmember station unless the absence is necessaryto perform duties in connection withthe 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 orher shoulderharness 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 shoulderharness; or (2) The crewmemberwould be unable to perform required duties withthe shoulderharness fastened. OpenSky will need exemption from this regulation due to the fact thatthe sUAS will nothave a flight crew or crew stations otherthan the PIC and a FOVO. The PIC will also not have to be restrained into a seatvia shoulder harness or safety belt atthe time ofthe flight.
14 

### C.F.R. 91.109- 

### Flight instruction; Simulated instrumentflight and certain flight tests OpenSky seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrumentflight, and certain flight tests. Specifically, 91.109 states "(a) No personmay operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane thatis 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 canbe conducted safely; and (2) The person manipulating the controls has atleast a 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 may be used for flight instruction to conduct a 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 rudderpedals atboth pilot stations; (2) The pilot manipulatingthe controls is qualified to serve and serves as pilotin command during the entire flight; (3) The instructor is current and qualified to serve as pilotin 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 pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other control seat is occupied by a safety pilotwho possesses atleast a private pilot certificate with category and class ratings appropriate to the aircraftbeing flown. (2) The safety pilot has adequate vision forward and to each side ofthe aircraft, or a competentobserver in 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 instrumentflight maybe conducted in a single-engine airplane, equippedwith 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 transport pilot certificate or a class ortype rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated atthe controls, otherthan the pilot being checked, is fully qualified to act as pilot in command ofthe aircraft". Again, Except when necessary for takeoffor landing, no person may operate an aircraftbelowthe following altitudes: (a) Anywhere. An altitude allowing, ifa powerunit fails, an emergency landing without undue hazard to 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 of50Q feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may notbe operated closerthan 500 feet to anyperson, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conducted withouthazard to persons or property on the surface- (1) Ahelicopter may be operated atless than the minimums prescribed

### in paragraph (b) or (c) ofthis section, provided each person operatingthe helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe FAA; and (2) A 

### powered parachute orweight-shift-control aircraft maybe operated at less than the 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 maybe, by reference 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 stationwithin the area prescribed in paragraph (a)(1)(i) ofthis section, the currentreported 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 lowest usable 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 personwith a private pilot certificate or license can successfully maneuver ortrain someone to use an sUAS withoutfirst hand flight experience with the particular sUAS. Flying in 3rd 

### person orientation requires built-up experience in that form offlying for many years. Therefore, we believe our own flight training, pilotprotocols and first hand experiences with the sUAS as laid outin our Flight Operations Manual meets and exceeds the requirements necessaryto 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. As this exemption is for a sUAS thatis a helicopter andthe exemption requests authority to operate at altitudes up to 400 AGL, ornotmore than 200 above an elevated platform from which filming is planned, an exemption may be neededto allow such operations. As setforth herein, except for the limited conditions stated in the Manual, the UAS will never operate athigher than 400 AGL. It will howeverbe operated in a restricted area with security perimeter, where buildings and people will notbe exposed to operations withouttheirpre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will betaken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations as setforth in the Manual. Compared to flight operations with aircraft or rotorcraftweighting far more thanthe maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated withthese operations is far less thanthose presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations andthe operations ofconventional aircraftthat must comply with Section 91.119. 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. 91121 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_l

(c) To convertminimum 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 

### H "f db I d' h d I . " num ero eet spec1 1e e ow, accor mgtot e current reporte a t1meter settmg: Current altimeter setting Adjustment factor 29.92 (or higher) 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 and barometric sensors and relays thatinformation 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 not pertinentthe 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 in VFR conditions. Specifically, 91.151 states "(a) No person maybegin a flight in an airplane 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- (1) During the day, to fly after thatfor atleast 30 minutes; or (2) At night, to fly afterthatfor atleast45 minutes. (b) No person maybegin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first pointofintended landing and, assuming normal cruising speed, to fly afterthatfor at least 20 minutes". OpenSky's sUAS has a typical mission time ofless than 15 minutes with maximum flight time of25 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 instructed to maintain flight until battery power reaches 25%, or 1stlevel warning. At this level, landingprocedures will be intiated. Once the sUAS reads 20%, 2nd level warning, the flight control system automatically take over and initiates safe landing sequence at the logged in takeoffpoint. OpenSky policy outlined in our Flight Operations Manual achieves satisfactory safety standards. OpenSky believes that an appropriate and current airworthiness certificate would notbe necessary to fly a sUAS given the size ofthe aircraft and the necessary level ofskill neededto operate the aircraft. Before puttinginto service, each ofour sUAS goes through our own airworthiness proceedures ofmiminum test flight 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 91.417 OpenSky 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 itnecessaryto grantthis request. (d) The reasons why granting OpenSky's requestwould be in the public interest; thatis, how it would

### benefitthe public as a whole. OpenSky is classified as an engineering companyby the U.S. Department ofTransportation and provides services to aerial support for commercial interest. OpenSky's use ofa sUAS can assist in making task safer and minimize human exposure to being at dangerous elevations. OpenSky's sUAS usage in the aerial photography and cinematographywill also reduce the time required to captured the needed scenes as comparedto convention helicopters or airplanes. Ultimately, the resultis quick completion oftask an reduction ofdangerous elevation perspective needs. (e) The reasons why grantingthe exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at least equal to thatprovided bythe rule from which OpenSky seeks exemption Our Engineering departmentwill provide a level ofsafety that 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:

• Our Squadron Leader /ChiefPilot in Charge is an engineerwho 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 includingtraining ortesting ofsUAS. • The flight area ofthe sUAS will be observed for besttake offand landing locations. Desired conditions include: flat and level surfaces clear ofdebris, at least 15ftfrom power lines 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 heavywinds. All flights will take place during daylight hours with no evening orlate night flights. • The PIC(s) ofthe sUAS will at leasthave 12 training hours or 24 flights accrued beforebeing designated workingflights. • All batteries mustbe charged completely before each flight and each flight must end when the battery has a 30% power level remaining. • Avisual safety inspection will occur before each flight, testingpropellertightness, security mount ofcamera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and FOVO. • The sUAS will be flown under a height of500 ft AGL. • No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so as to ensure thatthe sUAS is in a condition for safe flight operation and in a configuration appropriate for the purpose ofthe intended flight. • Ifthere is more thanjustan 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 operationto 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-point location. Ifthe communication link is reconnected during fail-safe mode, control ofthe sUAS can be regained before landing occurs atthe home-point location. • There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk ofexplosion ifa crash occurs with the sUAS. • The sUAS will feature a builtin compass that will be recalibrated atevery site to maintain accurate directional readings. The compass will also help in keepingthe 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 20 lbs

. The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 1.5mrespectfully. With a maximum wind resistance of 18m ph. The typical aircraftwheelbase will be less than 1OOOmm in length

. The aircraft runs offa Li-Po battery

. (f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; and (2) A briefdescription ofthe nature ofthe exemptionyou seek
Petitioner: OpenSky Drones, LLC. Sections of 14 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 Cinematographic filming subjectto operatingprocedures that meet or exceed those that FAA requires. (g) Any additional information, views or arguments available to supportyour request Please see the introductionto this exemption request. (h) Ifyou wantto exercise the privileges ofyour exemption outside ofthe United States, the reason whyyou need to do so The Operations described inthis exemption requestwill be conducted whollywithin the United States.
Attached hereto, and submitted as a 

### confidential document, is our Field Operations Manual. We respectfully submitthat good cause exists so that this confidential manual does not need to be published in the Federal Register. Please do nothesitate to contactme via email at dan@OpenSkydrones.com ifyou have any questions

Dan 

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