David Wallis DBA Skyview Aerial Images
2261 NW 52nd Street Oklahoma City, OK 73112 U.S. Dept. of Transportation, Docket Operations
We st Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE.,
Wa shington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM Re: Exemption Request under Section 333 of the FAA Reform Act a nd

Part 11 of the Federal Aviation Regulations Dear Sir or Madam Pursuant to Sec tion 333 of the FAA Modernization and Reform Act of 2012 (the "R eform Act") and 14 C.F. R. Part 11, Sk yview Aerial Images , seeks an exemption from Federal Aviation Regulations ("FARs") detaile d below for the following described Unmanned Aerial System called in th is application the ME System, which includes an Unmanned Aircraft (UA) and ground station -b ased equipment and crew: THE UNMANNED AIRCRAFT (UA):
A lightweight ( 3.75 lb gros s weight with all on -b oard equipment), manufactured by Yuneec Typhoon Q500 4Kthat includes the following equipment in flight;
An on -b oard flight computer with GPS navigation and loc ation ability that receives signals for flight controls from a ground -b ased transmitter/controller;

on -b oard camera capable of capturing imagery in the form of full color, high definition still photos and video;
A 10-channel 2.4GHz with 5.8GHz video downlinklive video from the on

board camera.THE GROUD STATION

- BASED PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight ope ration from beginning to end and who controls the UA while in the air;
5.8 GHz radio transmitter/controller operated by the PIC to control th e UA while in flight;
A radio receiv er receiving liv e video and flight data from the on

- board camera and computer projects it all together onto a sc reen for the PIC to v iew during flight; A Visual Obs erver (VO) is a pers on who provides a second pair of eyes to visually track the UA while in flight. A Pilot in Command in visual line of sight at all times and NOT flying with any FPV System

.

The requested exemption would support an application for a comm erc ial Certificate of Authorization to use the above described ME Sy stem to s upport Production of promotional materials (v ideo and/or still images) for Real Estate sales Production of promotional materials, (video and/or still images ) for Travel and Tourism industries Production of promotional materials, (video and/or still images ) for commercial busi nesses, Photography and videography of social ev ents, s uch as weddings never operating over persons not directly inv olved with the ME system. The UA, powered by batteries, is smaller, lighter and more mane uverable than larger aircraft running on combustible fuel, it operates a t lower altitudes with no people on board and will thereby reduce curre nt risk levels and thereby enhance safety and diminish the likelihood o f death or serious bodilyinjury. With a small payload and maximum flight time of only 18 mi nutes, this is offers little or no risk to national security.
Low -l evel oblique photos and video from sev eral angles are far more effec tive than ground

- bas ed imageryfor displaying the charac teristics of large, complex properties with several buildings a nd large trees. The alternative c ould be to charter a full -s ized helicopter for this purpos e, which has proven more costly than many potential clients are able to afford. The benefits of reduc ed c ost and improv ed quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and

marine property. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so. The ME System will be operated in the field with both a PIC and 

### a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; d) Operation s will be restricted to flights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcra ft pilot and at least ten hours logged as a UA pilot with a similar UA type; f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not be operated over densely populated areas; h) The ME System w ill not be operated at air shows; i) The ME System will not be operated over any open

- air assembly of people; j) The ME System will not be operated over heavily trafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location; n) No flight may be made without a Pre

- Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight (see Appendix A). PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and st rict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that theoperation will have an equivalent or greater level of safety than manned

aircraft perform ing the same mission. The name and contact information of the applicant are:
David Wallis DBA Skyview Aerial Images
Ph: 405-922-1395
Email skyviewaerialimages@outlook.com 2261NW 52nd Street, Oklahoma City, OK 73112 The regulations from which the exemption is requested are liste d below. Beside each regulation number is the page of the attached Adden dum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 .................................Addendum Page 1

- 14 CFR 91.203.................................Addendum Page 1

- 14 CFR 45.23, 45.29..........................Addendum Page 2

- 14 CFR 91.9....................................Addendum Page 2

- 14 CFR 61.113, 61.133.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 .............. Addendum Page 3

- 14 CFR 91.151 .................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417) ......Addendum Page 3 - FAA Po licy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) ...Addendum 1

We are prepared to modify or amend any part of this request to sat isfy the need for an equivalent level of safety. Please contact us at an y time if you require additional information or clarification. W e look forward to working with your office.

Sincerely ,David Wallis DBA Skyview Aerial Images

Addendum containing Exemption Requests and Equivalent Level of Safety Appendix 

### A

- Flight Manual's Appendix B

- Owner's Manual for UA

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Skyview Aerial Images reques ts an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the ME Sy stem:14 CFR Part 21, Subpart H: Airworthiness Certificates This part establish es the procedures for the issuance of an airworthiness certific ate. Wh ile the FAA continues to work to develop airworthiness standard s for Unmanned Aerial Systems, we reques t an experimental certificate be issued for the ME System under either or both of t he following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes : (a) Research and development. Testing new airc raft design concepts, new airc raft equipment, new aircraft installations , new aircra ft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to sh ow compliance with the airworthiness regulations including flights to show compliance for issuance of type and s up plemental type certificates, flights to substantiate major design changes, and flights to show compl iance with the function and reliability requirements of the regulations. S ince the experimental certificate can be us ed for c ommercial purpos es such as marke t surv eys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commerc ial purpose as well. The aircraft will not carry persons or property, will not carryfuel, and will only fly under stric t operational requirements. Combined with the UA's light weight, being constructed primarily of c arbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conv entionally certific ated aircraft performing the same mission

. If an experimental airworthines s certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Su bpart H, and the requirement for an airworthiness certific ate in general, citing the equivalent level of safetyoutli ned in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. T he regulation provides that an airworthiness certific ate, with the registration number assigned to the aircraftand a registration certificate must be aboar d the airc raft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at th e cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gros s weight of 3.75 pounds, the UA is too small to carry do cumentation, does not have an entrance, and is not capable of carryingpassengers or crew. To obtain an equivalent level of safety and meet the

intent of 91.203, we propose that doc uments deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground c ontrol station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthines s and registration certificates be permanently affixed to the aircraf t v ia placar d containing the following information plus the word "EXPERIMENTA L" to satisfy the requirement of 14 CFR 45.23, which follows immediat ely after the propos ed placard description below:

Appendix A
EXPERIMENTAL Manufacturer: YUNEEC AMERICAS (USA) 5555 Ontario Mills Parkway Ontario CA 91764 USA Tel : +1 855 284 8888

. , 14 CFR 45.23 Displayof marks; general and 45.29 Size of marks. These regulations provide that each aircraft must displa y 11 N'' and the aircraft's registration number in letters at least 3 inches high. Addition ally, the airc raft mus t display the word 11 EXPERIMENTAL 11 in letters at least 2 inc hes high near the entrance to the cabin, cockpit, or pilot s tation. The UA does n ot have an entrance in which the word 11 EXPERIMENTAL 11 c an be placed, and may not have a registration number assigned to it b y the FAA.
We propose to achieve an equivalent level of safety by including t he word

11 EXPERIMENTAL 11 in the plac ard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the airc raft while it is preparing for launch will be able to see the designation. Addit ionally, we feel that the permanent placard disc uss ed in the previous paragraph will pr ovide the airc raft's regis tration information at the ground station. Finally, we will display at the ground station a high contrast flag or b anner that c ontains the words Aircraft Ground Station 11 in letters 3 inc hes high or greater. Since the aircraft wil l operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircra ft and choos es to investigate its point of origin. 14 CFR 91.9 Civil aircraft flight manual, mar k ing, and placard requirements. This regulation p rovides that no pers on may operate an airc raft unless a current, approv ed flight manual is in the aircraft. W eassume that the intent of this requirement is to ensure that flight manual

information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9 , we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight. 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.1 33 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in co mmand of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require t hat the PIC must either 1. Hold a Sport Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) 11 0perations without a pilot in which the PIC is requi red to complete 11 FAA private pilot ground and pass 11 the FAA Private Pilot written Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition Appendix A to completing the privat e pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that 11 No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fullyfunctioning dual controls."

The ME System ground

- based control station consists of a small hand

held radio transmitter and while it does not offer a second set of 11 Controls 11 will, operate the single set of controls simultaneously. W ith both student and instructor having 11 hands

- O n 11 the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. 14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission of the owner of the property flown over. The aircraft will not be operated over congested areas or over any open - air assembly of persons. The property owner will be briefed on the expec ted route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other air craft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after Therefore we maintain that due to the small s ize of the UA, the hazard to persons, vehicles and structures isminimal compared to manned aircraft, which should be considered in

granting the exemption. 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising alt itudes by reference to an altimeter setting available within 100 NM of the aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimet er measurement above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation p rovides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

Therefore we maintain that due to the small size of the UA, the hazard to persons , vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff poi nt is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a f light in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffe r for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20°/o reserve. Since the aircraft will never fly more than 314 NM from the point of intended landing, a full battery ch arge at launch will ensure that we meet the reserve energy requirement of this paragraph. W e request anexemption to the word "fuel" and ask for an equivalent interpretation with

the word "energy". 14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Parag raphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorize d to approve the aircraft for return to service." As provided in the Pre

- Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two h ours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. W e feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 8900.227 Paragraph 1 6(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is m edically qualified to operate a much larger vehicle.APPENDIX 

### A

- FLIGHT MANUAL

FLIGHT RESTRICTIONS a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restri cted to flights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be oper ated at air shows; i) The ME System will not be operated over any open

- air assembly of people; j) The ME System will not be operated over heavily trafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalent to VFR; m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre

- Flight Ins pection by the PIC before each operation to ascertain that the UA is in a condition safe for flight. PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly.
3. Mic ro - SO card has been inserted if necessary.4. Gimbal is functioning as normal.

5. Motors can start and are functioning as normal.
6. Yuneec a pp connected to the aircraft. TO REGAIN CONTROL AFTER LOST RADIO CONTACT
7. Nuts and bolts are snug and tigh t and no sharp edges anywhere. If radio contact is los t and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV back to the PIC