### December 31, 2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 Re: Petition ofSkiris UAV for an ExemptionPursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 Director: Flight Standards Service: Pursuant to Section 333 ofthe FAAModernization and ReformAct of2012 ("Reform Act") and 14 C.F.R. Part 11, Skiris UAV (Skiris) hereby applies for an exemption from the FederalAviation Regulations ("FARs") identified belowto allow commercial operation ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose ofconducting aerial photography, videography, cinematography and inspection for the motionpicture, television, real estate and web industries. This petition for exemption is made based on information outlined in this Petition for Exemption, as well as the accompanying Skiris documents; I. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & 

### Manuals") 3. User Guide and; 4. Flight ManuaJl (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Skiris submits these supporting materials as confidential documents pursuant to 14 C.F.R. 

### § 11.35(b), as the materials contain confidential commercial and/orproprietary informationthat Skiris has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom ofinformationAct, 5 U.S.C. 

### § 552 et. seq. 

### NOTE: ALLATTACHMENTS SET FORTH IN SUPPORT OFTHIS LETTER OF PETITIONARE CONFIDENTIALAND SHALLNOT BE RELEASED TO THE PUBLIC WITHOUT WRITTENAUTHORIZATION FROM THE PETITIONER. For your convenience, this Petition is organized as follows:

1• The term "Manufacturer's Manualn also includes all relevant manufacturer publications, including, but not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation December 31, 2015 Page 2 

### I. Description ofPetitioner II. Description ofProposed Operations 

### A. Aerial Videography, Photography, Cinematography and Inspection 

### III. Relevant Statutory Authority IV. Skiris's Proposed UAS Operations Meet the Requirements of Section 333 ofthe Reform Act A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions SetForth in the Operations Manuals 

### V. Regulations From Which Exemption is Requested A. 14 C.F.R. Part 21, SubpartH -Airworthiness Certificates and 14 C.F.R. § 91.203(a)(l) B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraftFlight Manual intheAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration H. 14 C.F.R. 

### § 91.103: PreflightAction I. 14 C.F.R. 

### § 91.109(a): Flight Instruction 

### J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes K. 14 C.F.R. 

### § 91.121: Altimeter Settings 

### L. 14 C.F.R. 

### § 91.15l(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug and Alcohol Program VII. Public Interest VIII. Privacy IX. Federal Register Summary X. Conclusion I. DESCRIPTION OF PETITIONER Skiris is basedin Auburn, WA andprovides aerial photography, videography, cinematography, inspection for the film, television, real estate and web industries. The Company's Principal and ChiefPilot Ben Bainhas completed UAV flight training and is member ofAUVSI, UAVSA,U.S Department ofTransportation December 31, 20 15 Page 3 AMA and DP 

### A. He has been flying UAV Quadcopters as ahobby for more thantwo years without incident, logging hundreds ofhours flying. Upon the grant ofthe 333 Exemptionthe Company's business will specialize in aerial photography, videography, cinematography and inspection for the film, television, real estate and web industries. Skiris's staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in addition to any otherneeded on site assistance. All ofthe equipment owned by Skiris is ofthe highest quality gear and has been able to provide these services safely and without any claims orincident. Skiris's goal is to advise the perspective clientthat Skiris is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Skiris seeks an exemption to allow for aerial photography, videography, cinematography, inspection and otherrelated mediaproducts. The contact information for Petitioner is as follows: BenBain Skiris UAV 6804 Perry Ave., SE Auburn, WA 98092 Phone: 206-595-8882: Email: SkirisUAV@gmail.com 

### II. DESCRIPTION OF PROPOSED OPERATION Skiris seeks an exemptionpursuantto Section 333 ofthe ReformAct to operate the DJI Phantom 3 (referred to Skiris-UAS) (under 551bs) for the proposed operations discussed herein below. All UAS operations will occur under tightly controlled conditions onprivate property or approved locationwhere Skiris has received verifiable permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption and Skiris's Operations Manuals. As detailed in Skiris's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") ofthe operator, in uncontrolled airspace, and will occur at least 5 nm away from an airport reference point. Moreover, Skiris's Operations Manuals incorporate redundant safeguards to assure the aircraft does nottravel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. 

### A. Aerial Videography, Photography and Cinematography Skiris seeks to use small Skiris-UAS for thepurpose ofconducting aerial photography, videography, cinematography and inspection for the film, television, real estate and web industries. Skiris haspurposefullytailored its operations to meet the requirements establishedby the FAAin prior grants ofexemption authorizing commercial use ofUAS in the real estate industry, including:U.S Department ofTransportation December 31, 20I5 Page4 

## • • Astraeus Aerial (Exemption No. II062) • Aerial MOB, LLC (ExemptionNo. 11066) • Pictorvision, Inc. (ExemptionNo. 11067) • HeliVideo Productions, LLC (ExemptionNo. I1 065) • Snaproll Media, LLC (ExemptionNo. 11063) • RC Pro Productions Consulting, LLC d/b/a VortexAerial (ExemptionNo. 11064) • Flying-Cam, LLC (ExemptionNo. 11080) • Aerocine, LLC (Exemption No. 11150) • Team 5, LLC (Exemption No. 11158) • Alan D. Purwin (ExemptionNo. 11161) • HelinetAviation Services, LLC (ExemptionNo. 11160) • Picture Factory, Inc. (ExemptionNo. 11178) • Airshark (ExemptionNo. 11651) • Trudeau, Realtor® (ExemptionNo. 11138) • Alon Sicherman (ExemptionNo. 11728) All UAS photography, videography, cinematography and inspection operations will occur on private property or approved location in a controlled area away from spectators andpersons not involved in the recording process. In addition, the filming will be conducted between dawn and duskto ensure maximum safety for the public and those involved inthe manipulation and operation ofthe UAS; VFR conditions, at altitudes below400' above ground level ("AGL"). As set forth below, Skiris's operations provide an equivalent level ofsafety which is superior to performing the same work using conventional fixed-wing aircraft or helicopters. Small UAS recording operations is also saferthan traditional manned aircraft performing the same function. Videographer, photographers and inspectors also frequently need to climb roof tops, trees, ladders orotherwiseperform elevated work, which exposes them to the risk of dangerous falls, electrocution or otherwork related injuries. In addition, depending onthe nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk of exposure to hazardous conditions. The use ofSkiris-UAS mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most other types of recording operations. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations presentrisks associated with vehicles weighing tens ofthousands ofpounds (includingpayload) and carrying large amounts offuel which inherentlypresents significant fire hazards as well as exposure to other chemical contaminates. Itis importantto note the use of small UAS in this area will not only be safer and more cost effective to the perspective user or purchaser ofthe service, butthe quality and expanse ofacquired information will be far more robust giventhe low cost associated with its acquisition and otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. SmallU.S Department ofTransportation December 31, 2015 Page 5 UAS will also be capable ofaccessing and inspecting areas thatwould otherwise be inaccessible or highly dangerous using conventional aircraft or other inspectionmethods. III. RELEVANT STATUTORYAUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe FAA Modernization and ReformAct of2012 ("ReformAct"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 ofthe ReformAct, the FAAAdministrator is to permit unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe to do so based on the following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAAAdministratorhas general authority to grant exemptions from the agency's safety regulations and minimum standards whentheAdministrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(£) (defining the authority ofthe Administrator); 49 U.S.C. §44701(£) (permitting exemptions from§§ 4470l(a), (b) and §§ 44702-44716, et seq.). Aparty requesting an exemption must explainthe reasons why the exemption: (I)would benefit the public as a whole, and (2) would not adversely affect safety (or how it wouldprovide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). IV. SKIRIS'S PROPOSED SKIRIS-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The small Skiris-UAS operations proposed by Skiris as noted above inthis Petition for Exemption qualifY for expedited approval pursuant to Section 333 ofthe ReformAct as each of the statutory criteria and relevant factors are satisfied. A. Approval is Warranted Based on the VAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The Skiris-UAS utilized by Skiris has been approved for use inprior Section 333 Grants ofExemption from the FAA.'

• The Skiris-UAS weighs less than 55 pounds, includingpayload

2See e.g., Grant ofExemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant ofExemptionto VDOS Global, LLC (ExemptionNo. 11112); Grant ofExemptionto LowCountryRC, Corp. (Exemption No. 11184); Grant ofExemption to Alan Purwin (Exemption No. 11161); Grant ofExemption to HelinetAviation Services (Exemption No. 11160); Grant ofExemptionto Total Safety U.S., Inc. (ExemptionNo. 11156)

..U.S Department ofTransportation December 31, 2015 Page 6

• The Skiris-UAS will not be flown at a ground speed in excess of50 knots. The exemptionholder may use either groundspeed or calibrated airspeedto determine compliance with the 50 knot speed restriction

• Altitude information will be generated byequipment onboardthe UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot viatelemetric data feed.

• The Skiris-UAS will have system redundancies and independent functionality to ensure the overall safety andpredictability ofthe system. Ifconnection to the remote control or ground control station is lost, failsafe systems will permit the UAS to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control ofthe Skiris-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the SkirisUAS is 2.4 and 5.8 GHz frequency bands. Ifthe same operations were conductedusing a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference inweight between the SkirisUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property inthe event ofan unintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated. 

### B. Approval is Warranted Based on the Operational Restrictions Set Forth in Skiris's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected Skiris-UAS will containall theprocedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA in making a safety assessment of Skiris's proposed operations, below is a summary ofoperational limitations and conditions that Skiris will adhere to, and which will ensure an equivalent orhigher level ofsafety to operations conducted under current regulatory guidelines: I. The Skiris-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UAS operated under the Grant ofExemptionwill be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings will be as large as practicable.

### U.S Department ofTransportation December 31, 2015 Page 74. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe Skiris-UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a private, recreational, or sportpilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issuedby a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meetthe flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or herpilot certificate. 6. The Skiris-UAS shall be operated withinVLOS ofthe PIC and Observer at all times. The PIC mustuse human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging or texting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption shall be added to the Skiris's Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in the Grant ofExemption and Skiris's Operations Manuals, the conditions and limitations inthe Grant ofExemption shall take precedence and must be followed. Otherwise, Skiris shall follow the procedures outlined in their Operations Manuals. 10. Skiris may update or revise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will beprovided to the Administrator upon request. Skiris will also present an updated and revised Operations Manuals ifit petitions for extension or amendment to its Grant ofExemption. Ifan update orrevision would affect the basis upon which the FAA grants the exemption, Skiris will seek an amendment to its Grant ofExemption. Skiris will contact the FAA'sUAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Skiris Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the Skiris-UAS is operating. 12. The PIC is prohibited from beginning a Skiris-UAS flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly to the first intended point oflanding, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximum total flight time for each operational flight using the Skiris-UAS will be limited to 40 minutes orthe amount oftime the UAS canbe flown and still maintain a reserve batterypower ofno less than 25%, whichever occurs first.U.S Department ofTransportation December 31, 2015 Page 8 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enternavigable controlled airspace without timely prior written authorization and approval from the FAA. In the event the structure being inspected exceeds 400 feet AGL, the UAS will not be operatedmore than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons otherthan the PIC, VO, operatortrainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientlyprotectnonparticipating persons from the UAand/or debris inthe event ofan accident. The operator must ensure that nonparticipatingpersons remain under suchprotection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearerto the PIC, VO, operatortrainees or essential persons do not present an undue hazard to thosepersons per§ 91.119(a). 16. The Skiris-UAS 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 PIC. 17. The Skiris-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Skiris COA. The letter ofagreement withthe airport management will be made available to the Administrator upon request. 18. Priorto each flight the PIC shall inspect the Skiris-UAS to confirm that it is in a condition safe for flight. The pre-flight inspectionwill account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operating documents as well as equipment updates. The PIC shall not operate any Skiris-UAS ifthe inspection reveals a conditionthat affects the safe operation ofthe Skiris-UAS until the necessary maintenance has beenperformed and the Skiris-UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflight inspection.All maintenance and alternations must be properly documented in the UAS's records as required by Skiris's Operations Manuals. 19. Skiris will timely carry out its maintenance, inspections, and record keeping requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the Skiris-UAS records, including total time inU.S Department ofTransportation December 31, 2015 Page 9 service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning the Skiris-UAS to service. 20. Any Skiris-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Skiris's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraftrecords ofthe flight. The requirements and procedures for a functional test flight and Skiris-UAS record entry shall be included inthe Skiris's Operations Manuals. 21. The Skiris-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on Skiris's Operations Manuals. 23. Skiris will obtain anAirTraffic Organization ("ATO") issued Certificate ofWaiver or Authorization, otherwise known as a COA, priorto conducting any operations under this Grant ofExemption. ANOT AM will be issued as required by the COA. All operations will be conducted in accordance with airspace requirements intheATO issued COAincluding class ofairspace, altitude level andpotential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local lawenforcement, fire or other appropriate governmental agencies. 25. Ifthe Skiris-UAS loses communication withthe PIC, itwill have the capabilityto safely return to a pre-determined locationwithinthe operational area and land safely. 26. Contingency plans will be inplace to safely terminate flight ifthere is a loss of communication between the PIC and the Observer. 27. The Skiris-UAS will have the capability to safely abort flight in the case of unpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued withinthe United States. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraftpilot and at least 10 hours logged as a UAS pilot with a similar Skiris-UAS type platform. This requirement can be achieved by flights conducted and logged as a hobbyist. 30. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51(b), a minimum ofhours pursuantto 54 CFR 

### § 61.5l(b) as UAS pilot operating the make and model ofSkiris-UAS to beU.S Department ofTransportation December 31, 2015 Page 10 utilized for operations underthe exemption and three take-offs and three landing in the preceding 90 days. 31. Operations shall occur during daytime VFR Meteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted. 32. The Skiris-UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. Skiris-UAS Operations under Instrument Flight Rules, at night, orbeyond VLOS are prohibited. 34. The UAS will not be operated from an elevated platform unless designed and engineered specifically for suchpurposes and be in compliance with the general restrictions imposed by the applicable regulations. Additionally no PIC will provide any film-flight operations while inmotion from atop any elevatedplatform vehicle or device. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe Skiris-UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The FederalAviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is definedunder § 40101 oftheAct, including UASs, from its safety regulations and minimum standards whenthe Administratordecides a requested exemption is in thepublic interest.3 Skiris seeks an exemption from several interrelatedprovisions ofTitle 14 ofthe Code ofFederal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconductingthe requested operations using Skiris-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operatingprocedures and safeguards that Petitionerhas established which will ensure a level ofsafety better than or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.P.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.P.R. §91.203(a)(1) 349 U.S.C. §44701(1) (authorizing the grant ofexemptions from requirements ofregulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § 11.8l(e), whichrequires a petition for exemptionto include: The reasons why granting the exemption would not adversely affect safety, orhowthe exemption wouldprovide a level ofsafety at least equal to that provided bythe rule from which you seek exemption.U.S Department ofTransportation December 31, 2015 Page 11 The FAAhas stated that no exemption is needed from this section ifa finding is made under the ReformAct that the UAS selected provides an equivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and in point offact exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines thatthere are some characteristics ofthe chosen UAS that fail to meetthe requirements ofthe ReformAct, an exemption is requested. EquivalentLevelof Safety Skiris's use ofthe Skiris-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth inthe description ofproposed operations in Section IV(A), the Skiris-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of50 knots. The Skiris-UAS is also equipped with safety features which will allowPetitionerto operate the Skiris-UAS safely after experiencing certain in-flight contingencies or failures as noted below. 6 7 Additionally, the Skiris-UAS carries neitherpilots nor passengers, carries no explosive materials orflammable liquid fuels, or other elements identified by Homeland Security as beingprohibitive and operate exclusively within the parameters stated in Skiris's Operations Manuals. Operations conducted under this exemption will be closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. Skids will also provide the FAAwith advance notice ofall operations viaNOTAMs as required bythe applicable CO

### A. In all cases, operation ofthe SkirisUAS underthe proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operatingwith an airworthiness certificate. Lastly, the Skiris-UAS do not need a means

5 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-20 14-0352 at pgs. 13-14, 22).

6 See e.g., Grant ofExemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI SIOOO] has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) ora lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing asimilar operation.u

7 See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-20 14-0382 at pgs. 4-5): "The Skiris-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The Skiris-UAS canbe operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the Skiris-UAS to detect a system fault while in the air and automatically fly backto its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceedingpre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commanding the systemto move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as windthresholds are not exceeded.Also a flight termination link -toprevent a 'fly away' orotherpotentially dangerous situation- is available to the operator."U.S Department ofTransportation December 31, 2015 Page 12

to communicate with other aircraft orATC, becausethose capabilities will be solelypossessed by the PIC and Observer, who are not onboard the Skiris-UAS. 8 In addition, no sense-and-avoid technology is necessary for the Skiris-UAS because they will be operated at all times inVFR conditions and within VLOS ofthe PIC and Operator.' B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft Title 14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Skiris's small Skiris-UAS would otherwise require certification underPart 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.P.R. R. Part 21, Subpart 

### H, supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements Skiris seeks an exemption from the aircraft marking and identificationrequirements contained in 14 C.P.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.P.R.§ 91.9(c), CivilAircraft Flight Manual, Marking and Placard requirements, provides that: No personmay operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.P.R.§ 45.23(b), Markings ofthe Aircraft, states: When marks include only the Roman capital letter "N" and the registration numberis displayed on limited, restricted or light-sport category aircraft or experimental 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.

• 14 C.P.R. §45.27(a), Rotorcraft, states: Each operatorofa rotorcraft must display onthat rotorcrafthorizontally onboth surfaces ofthe cabin, fuselage, boom, or tail the marks requiredby § 45.23.

8 See Grant ofExemption No. 11062 toAstraeus Aerial (FAA-2014-0352 at pg. 13).

9• ldU.S Department ofTransportation December 31,2015 Page 13 In a previous Grant ofExemption, the FAAdeterminedthat exemption from these requirements was warrantedprovided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 

### EquivalentLevelof Safety All Skiris-UAS flown by Skiris will bearN-numbermarkings that are as large as practicable in accordance with 14 C.P.R. Part 45, Subpart C. 11 

### D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections Skiris seeks an exemption from the maintenance inspectionrequirements contained in 14 C.P.R. 

### § 91.405(a), 91.407(a) (1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. 

### § 91.405(a) (stating that each owner or operatorofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption from these regulations is needed because Part 43 andthese sections only apply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption will not have. (Emphasis added) 

### EquivalentLevelof Safety An equivalent level ofsafety will be achieved or exceededbecause maintenance and inspections will be timelyperformed in accordance withthe Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Skiris's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe Skiris-UAS and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verifiedto address any conditions potentiallyaffecting safe operation ofthe Skiris-UAS and no flights will occur unless, and until, all flight critical components ofthe Skiris-UAS have been found to be airworthy and in a condition safe for operation. Afunctional test flight will be conducted following the replacement ofany flight-critical components. As required by Skiris's Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe Skiris-UAS aircraft records ofthe flight. Skiris's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Skiris's Operations Manuals also include procedures to document and maintain a record ofthe Skiris-UAS's maintenance, preventative maintenance, alterations, status of replacement /overhaul componentparts, and the total time in service ofthe Skiris-UAS used under this Grant ofExemption. As a whole, the maintenance and inspectionprocedures required

10. FAA Docket No. FAA-2014-0352. II. See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation December 31,2015 Page 14 in Skiris's Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved. PILOT-IN-COMMAND OFTHE VAS E. 14 C.F.R. 

### § 61.113: Private Pilot Privileges and Limitations Skiris seeks exemption from 14 CFR 

### § 61.113, whichrestricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers orcargo for hire. In this case, while the Skiris-UAS will be operated as part ofa commercial operation, they carry neitherpassengers nor cargo. In the Grant of Exemptionto Astraeus Aerial, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrantthe additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safetybenefits whenUAS operations are involved. EquivalentLevelof Safety The restrictions Skiris has placed on its Skiris-UAS operations meet or exceed the restrictions similarly imposed onAstraeusAerial. Skiris will operate onprivate property or approved location away from persons and property not involved in the operation. Skiris will also obtain an ATO issued COApriorto conducting any operations underthis Grant ofExemption.All operations will be conducted in accordance with airspace requirements intheATO issued COA including class ofairspace, altitude level and potential transponder requirements. A NOTAM will also be issued as required by the applicable COA. In additionto these flight restrictions, Skiris will further ensure safe operation byrequiring that any PIC be thoroughly versed not only in airspace and communication issues pertainingto all aircraft operators but also inthe unique aspects ofSkiris-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in Skiris-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights onbehalfofSkiris. The pilot qualification, training, and currency requirements inthe Operations Manuals ensure that Skiris pilots are competent and proficient in the Skiris-UAS they are operating. Skiris'straining and qualification requirements are consistent with those contained in priorFAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafetyto the public. OPERATING PARAMETERS OFTHE VAS F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness

12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352).U.S Department ofTransportation December 31, 2015 Page 15 Inasmuch as there will be no airworthiness certificate issued for the UAS, Skiris seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAAhas statedthatno exemption is required for 14 C.F.R. § 91.7(a) to the extentthatthe requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with SectionV (A), supra. G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraft Flight Manual in theAircraft and 14 C.F.R. 

### § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuantto 14 C.F.R. § 91.9(b) (2): (b) No person may operate a U.S.-registered civil aircraft- (2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 ofthis chapter, unless there is available inthe aircraft a current approved Airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no personmay operate a civil aircraft unless it has within itthe following: (1)An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Giventhe small size and configuration ofthe Skiris-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboard the Skiris-UAS becausethere is simplyno room and the Skiris-UAS has no cabin or cockpit. As a way to comply with the code Skiris will maintain the documents with the PIC and make them available for inspection. EquivalentLevelof Safety In anFAA Office ofChiefCounsel's Opinion datedAugust 8, 2014, andprepared byDean E. Griffith, Attorney, AGC-220, it was acknowledgedthat the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot oftheunmanned 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 operatingthe aircraft. 14 As this FAA Office ofChiefCounsel Opinion

13 See !d. at 13-14, 22.

14 Memorandum from MarkBury, FAAAssistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.U.S Department ofTransportation December 31, 2015 Page 16 clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilot has access to the documents at the ground control station from which he or she is piloting the UAS. 

### H. 14 C.F.R. 

### § 91.103: PreflightAction Skiris seeks an exemption from 14 C.F.R. 

### § 91.103, whichrequires a PIC to become familiar with specific information before each flight, including informationcontained inthe FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessaryto safely conduct the flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required. EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the Skiris's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance withthe Skiris's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, 

### VAperformance data, and contingency landing areas-before initiation offlight. Skiris's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS. 

### I. 14 C.F.R. 

### § 91.109(a): FlightInstruction Skiris seeks an exemption from 14 C.F.R. 

### § 91.109(a), whichprovides inpertinent partthat "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotelypiloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished throughthe use ofa device that communicates with the aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of

### 14 C.F.R. 

### § 91.109(a). EquivalentLevelof Safety Giventhe size and speed ofthe UASs that Skiris intends to use, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required by the Skiris's Operations Manuals, all persons will be a safe distance away inthe eventthat the UAS experiences any difficulties during flight instruction. Moreover, as required by the Skiris's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safetyprocedures provided for in Skiris's Operations Manuals ensure that the proposed UAS operations provide an equivalent orhigher level ofsafety than thatprovided bythe flight instruction regulations.U.S Department ofTransportation December 31, 2015 Page 17 J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes Skiris requests an exemption from the minimum safe altitude requirements of 14 C.P.R. 

### § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.P.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 hazardto persons or property on the surface," provided that "each person operating the helicopter complies with anyroutes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because the proposed Skiris-UAS operationwill normally needto occur below 400 feet AGL. 

### Incircumstances where the Skiris-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the Skiris-UAS will not be operated morethan 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the Skiris-UAS. EquivalentLevelof Safety Comparedto flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel with the above noted UASs, any risk associated withthese operations is far less than those which presently existwith conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe Skiris-UAS, as well as the controlled location where the operations will occur. In orderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highestpoint on that structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals, the Skiris-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless thatperson is in aposition where he or she is shielded from the Skiris-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe Skiris-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and, operations nearthe PIC or Observerwill notpresent an undue hazard per§ 91.119(a). Adherence to these restrictions in Skiris's Operations Manuals will ensure operations can be conducted without compromising

15 Relieffrom § 91.119(a) will notbe necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons orproperty on the ground in the event ofa failure. Petitioner's proposedUAS operations will not occur over congested areas, and therefore an exemption from §91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dbaLike on a treeAerial (FAA-2014-0534 at 15).U.S Department ofTransportation December 31, 2015 Page 18 public safety. 16 K. 14 C.F.R. 

### § 91.121: Altimeter Settings Skiris seeks an exemption from 14 C.P.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent thatthe UASs do nothave a barometric altimeter, but rather a GPS altitude read out. EquivalentLevelof Safety The FAAhas statedthat an equivalent level ofsafety to the requirements of 14 C.P.R. §91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or below17

, (2) withinVLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS. 18 The Skiris-UAS that Skiris intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Skiris's Operations Manuals, the PIC will berequired to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants ofExemption, the Skiris-UAS Skiris intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemption to the requirements of§ 191.121 is therefore appropriate. L. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions Skiris requests an exemption from 14 C.P.R. 

### § 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 (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

-

16 See e.g., Grant ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are present that can sufficientlyprotect nonparticipating persons from the UA or debris in the event ofan accident, then the UAmayoperate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When consideringhow to immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does not present an undue**hazard.~~** 17 Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point onthe structure.

18 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S Department ofTransportation December 31,2015 Page 19 (I) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly afterthat for at least 45 minutes. Here, the technological limitations on UAS battery powermeans that no meaningful flight operations can be conducted 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. Moreover, it is not Skiris's intentionto fly the Skiris-UAS at night. 

### EquivalentLevelof Safety In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafetyto the fuel requirements for flight in VFRconditions could be achieved by prohibiting the PIC from beginning a Skiris-UAS flight unless (considering wind and forecast weather conditions) there was enough powerto fly to the first intendedpoint oflanding and, assuming normal cruising speed, to fly after that for at least I0 minutes. In reaching this conclusion, the FAA considered that the UAS batteries for the Skiris-UAS provide approximately 50 minutes ofpowered flight (withpayload) and provided battery level and batterytime remaining in minutes and seconds to the PIC. 19 The FAA also considered the fact the Skiris-UAS operatingmanual states: "start every flight with a fully charged battery inthe aerial vehicle", and that inthe event thatthe Skiris-UAS should run lowonpower, the PIC will be alerted and can safely land the- Skiris-UAS as soon as possible. Like the VDOS Grant of Exemption, Skiris's use ofthe Skiris-UAS, combined withthe requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and in fact exceeded. Similarly, in the Grant ofExemption to Alan Purwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved byprohibiting the PIC from beginning a flight withthe UAunless (considering wind and forecast weather conditions), there was enough powerto safely fly at normal cruising speed to the intended landingpoint and land the UAwith 25% battery power remaining. Skiris will adhere to this limitation for its Skiris-UAS flights. The Skiris-UAS includes a low battery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the Skiris-UAS to a ground-based-on-screen display. 20 As required by Skiris's Operations Manuals, the PIC will promptly fly the Skiris-UAS back to the home launch location orpredetermined abort location where itmay safely land, while still maintaining a minimum of25% reserve batterypower. Skiris submits thatthe procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirementthat flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within VLOS ofthe PIC and Observer(s), ensure that the proposed operation will provide an equivalent

19. Grant ofExemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20. The Skiris-UAS ground control station displays, the UASs position, navigationroute, tail number, altitude, heading, north seeking arrow, range to targets, calculatedtargetposition, date/time, and sensor heading and orientation relative to the UASU.S Department ofTransportation December 31,2015 Page 20

or higher level ofsafety to the public to thatprovided by the regulations from which exemption is sought. 

### VI. DRUGAND ALCOHOL PROGRAM Skiris will have policies inplace to ensure thatno personmay participate in Skiris-UAS flight operations ifthey are underthe influence ofalcohol or any drug. 

### VII. PUBLIC INTEREST The public interest will be served by granting Skiris's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed inthis Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-the FAAAdministrator's assessment ofwhether certain UAS may operate safely in the NAS before completion ofthe statutorily required rulemaking. The proposed Skiris-UAS operations in this Petition for Exemption significantlyimproves the safety and reduces risk ofharm, physical injury andproperty damage to the public at large, the property owners from whom permission was granted for use byPetitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be inthe local vicinity. Traditional methods ofproviding surveillance and mapping services location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neithertrained nor equipped to perform, which exposesthem to unnecessaryrisk ofserious physical injury from dangerous falls or otherphysical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and otherhazards associated with identifying specific locations for potential recording sites to be used in the end product. The use ofsmall UAS can eliminate these hazards and ultimately create a much safermethod ofperforming these types ofinspections creating a safer environment for the public as well as Skiris employees. The use ofsmall UAS also enhances safety and reduces riskto the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in additionto flammable fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of an accident, Skiris's small batterypowered Skiris-UAS presents significantly less danger to persons onthe ground when compared to operations by conventional manned aircraft.21 As Petitioner's Skiris-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraftperforming in the same

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboardpilot, in addition to other onboard crewmembers, as necessary. Thepetitioner's UAs will weigh less than 55 pounds with no onboardpilot orcrew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals orproperty in the event ofan incident or accident. Risk to an onboardpilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation. uU.S Department ofTransportation December 31,2015 Page 21 functions proposed herein. Air quality will naturally be improved with the reduction offuel powered vehicles. Lastly, as recognized by the FAA inprior Section 333 Grants ofExemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft. 22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additionaljobs as the cost of providing the neededproduct is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, given the lower cost, owner/operators and others in the relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All Skiris-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate or controlled-access property withpermission from the land owner/controller or authorized representative. Permission from land owner/controlleror authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY Pursuantto 14 C.F.R. Part II, the following summary is provided for publication inthe FEDERAL REGISTER, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules in Title 14 ofthe Code ofFederal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.15l(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or othermethods. 

### X. CONCLUSION Skiris's Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximityto airports andpopulated areas; operationwithin VLOS and national security. The proposed Skiris-UAS operations will benefitthe public as a whole by improving safety and reducing risk by alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for

22See e.g., Grant ofExemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation December 31,2015 Page 22 the finished product. In consideration ofthe foregoing, this Petition for Exemptionprovides the FAA withmore than adequatejustificationfor granting the requested exemptions allowing Skiris to use small Skiris-UAS inthe recorded production ofits product. We thank you for your prompt considerationofourrequested exemptions. 

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BenBain Skiris UAV 6804 Perry Ave., SE Auburn, WA 98092 Phone: 206-595-8882: Email: SkirisUAV@gmail.com (The following attached items containproprietary and commercial information exempt from disclosure under the Freedom ofInformationAct, 5 U.S.C. 

### § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. 

### § 11.35(b)). Attachments: I. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. Transmitter Protocols 8. Preflight Checklist 9. Post Flight Checklist I0. Equipment Checklist II. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals PETITIONERREQUESTS THAT GOOD CAUSE EXISTS TO EXEMPTANYPART OF THIS PETITION FROM BEING PUBLISHED IN THE FEDERAL REGISTERPUBLIC FORUMBECAUSE THE REQUESTED EXEMPTION WOULD NOT SETA PRECEDENT,ANDANYDELAY INACTING ON THIS PETITIONWOULD BE DETRIMENTALTO THE PETITIONER.