Skycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington DC 20590 **Exemption Request Pursuant to Section 333 of the FAA Reform A** **ct and Part 11 of the Federal Aviation Regulations from: 14 CFR Part 21 Subpart H,**  **14 CFR 45.23 (b),**  **14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,**  **14 CFR 91.151, 14 C.F.R. 91.21**  **5 ,**  **14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417** 
To W hom It May Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Skycam Drones, Inc., an operator of Unmanned Aircraft Systems (“UASs”) for aerial photography and video graphy for real estate marketing , data collection , special events, residential and commercial construction inspection and news gathering, hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow co mmercial operation of its UASs. Skycam Drones, Inc.’s requested exemption would permit the operation of small, unmanned UAS under 55 pounds to conduct aerial video and photography under the Operational Control of an individual holding at least a Private Pilot certificate; under direct control of a Pilot in Command (PI C); wit hin Visual Line of Sight (VLOS) . As established by the exemptions already granted by the FAA, approval of Skycam Drones, Inc. exemption would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.
The name an d address of the applicant is: Skycam Drones, Inc. Attn: Patrick Manley PH: 786

- 877

- 6244 Email: pmanley@pagebuild.com Address: 1933 S. Oak Haven Circle, Miami, FL 33179Skycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

UASs operated by Skycam Drones, Inc. weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 87 knots, can hover, and can simultaneously move vertically and horizontally. Skycam Drones, Inc. will only operate its UASs in line of sight below 400 feet AGL and will operate under the operational control of (at minimum) an FAA certified private pilot. S uch operations will insure that the UAS will “not create a hazard to users of the national airspace system or the public.” Given the small size of Skycam Drones, Inc.’s UASs and the safety considerations proposed in this petition, Skycam Drones, Inc.’s U AS operations adhere to the Reform Act’s safety requirements. Additionally, due to the size of the UASs and the proposed use in which they will operate, approval of this application presents no national security issues. Based on the level of safety surroun ding the proposed operations, and the significant public benefit: Marketing and development of real estate, public awareness, reduction in environmental impacts by reduced emissions and noise, as well as an increase in revenue to the local economy through real estate development, t he grant of the requested exemption is in the public interest. Accordingly, Skycam Drones, Inc. , respectfully requests that the FAA grant the requested exemption.

**Ai rcraft**  **An d Equivalent Level Of Safety**  The operating limitat ions proposed by Skycam Drones, Inc. provide for at least an equivalent or higher level of safety than real estate, special event and news gathering operations using conventional aircraft.
**Sky cam Drones, Inc. Proposed limitations and conditions include:** 

• Operations authorized by this grant of exemption are limited to the DJI Phantom 2, DJI Phantom 3 , DJI Inspire 1 , and the Blade 350

- QX3

. All of these UASs are GPS enabled with safety features such as altitude hold, return to home functions , as well as programmable limitations for distance and altitude. • The UASs will weigh less than 55 pounds , including payload and attachments

. • Flights will be operated within line of sight of a pilot and/or observer. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. • Flights will be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an ele vated platform from which filming is planned.Skycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

• Flights speeds will not exceed 87 knots (100mph)

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• Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics will undergo a functional test flight prior to conducting further operations.

• Prior to each flight, the PIC will conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight.

• O perator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspectio n, and life limit requirements for the aircraft and aircraft components.

• UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).
• An FAA licensed airman with at least a private pilot’s certificate and third class medical ( and/or valid driver’s license ) will oversee all flight operations to ensure the highest degree of safety.

• Documents used by the operator to ensure the safe operation and flight of the UAS and any do cuments required under 14 CFR § 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforceme nt official upon request.

• The UA will remain clear and give way to all manned aviation operations and activities at all times.

• O perator will obtain consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 50 feet of the flight operation. • If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre

- determined location and land. The location will be clear of all persons or property during the duration of the flight. • The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

• The UAS will not be operated by the PIC from any moving device or vehicle.

• All Flight operations will be conducted at least 500 feet from all nonparticipatingSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediate ly in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operatin g closer to those objects and determined that it does not present an undue hazard. • All operations will be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. • The UASs will operate on the following frequencies, which are all FCC compliant and do not require specific licenses when transmit power is limited to 1 watt: 902 to 928 MHz, 2.400 to 2.4835 GHz, and 5.725 to 5.875 GHz

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• The UASs will not operate within 5 miles of airports , unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA, prior to any flight

. **Regulations from which the exemption is requested:** 14 CFR Part 21 Subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.215, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417 **14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates** Given the size and limited operating area associated with the UASs to be utilized by Skycam Drones, Inc., this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal AviationSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt the UASs from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UASs. In all cases, an a nalysis of these criteria demonstrates that a UAS operated without an airworthiness certificate, in a restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) opera ting with an airworthiness certificate without the restrictions and conditions proposed. **14 C.F.R. § 45.2**  **3 (b): Display**  **of marks, General** Display of marks Sections 45.2 3 (b) requires the Operator to “ 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,’’ ‘‘lightsport,’’ ‘‘experimental,’’ or ‘‘provisional,’’ as applicable. ” As there is no cockpit or pilot station on the UAS, we ask that we be exempted from this requirement. **14 C.F.R. § 61.113(a) an d (b): Private Pilot Privileges and Limitation**  Pilot in Command Sections 61.113 (a) and (b) limit private pilots to noncommercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve an equivalent level of safety of current operations by requiring all operations to be supervised by (at minimum) an individual holding private pilot’s license rather than requiring that individual to hold a commercial pilot’s license to operate a small UAS. Unlike conventional manned aircraft, a ground

- based operator remotely controls a UAS. The operational area is limited, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a UAS are far lower from those associated with commercial operations contemplated by Part 61. Allow ing operational control of a UAS by a private pilot exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). **14 C.F.R. § 91.103: Preflight A ction**  Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including reviewing weather, airspace, NOTAMS, TFRs , flight b attery requirements, and performance data beforeSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

commencement of flight. Additionally all UAS will be checked for security of attached components prior to every flight. **14 C.F.R. § 91.109: Flight Instruction** Section 91.109 states, “No 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.” The proposed UASs will be operated utilizing an autopilot to maintain controlled flight, and all UASs are p rogrammed to return to a level attitude and hover when the controls are returned to a neutral position. Because of these built in safety features, dual control is not necessary in order to maintain an equivalent level of safety proposed by section 91.109 d uring training. All training will be conducted in a controlled environment as to not cause undue harm or damage to persons or property.
**14 C.F.R. §91.119: Minimum Safe A** **ltitudes** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes... (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.” Because Skycam Drones, Inc. requests authority to operate at altitudes only up to 400 AGL, and not more than 200 above an elevated platform from which filming is planned, an exemption is needed to allow such operations. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. All affected individuals will be informed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of flammable fuel, any risk as sociated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between a UAS and conventional aircraft. **14 C.F.R. §91.121 A ltimeter**  **Settings** Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As a UAS may not have a barometric altimeter, but instead reference a GPS altitude, an exemption is needed. The operator will achieve an equivalent level of safety, confirming the altitude of the launch site shown on the GPS altitude indicatorSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

before flight. **14 C.F.R. §91.151: Fuel Requirements for Flight in VFR Condition** Section 91.151(a) prohibits an individual from beginning “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

– (1) During the day, to fly after that for at least 30 minutes. . . .” The battery powering the proposed UASs provides approximately 30 minutes of powered flight. Therefore the UAS cannot meet the 30

- minute reserve requirement in 14 CFR §91.151. In lieu of this requirement the UAS flights will be terminated at approximately 25% remaining battery life or better. S kycam Drones, Inc. believes that an equivalent level of safety can be achieved by limiting flights to 25% of battery power, this restriction would be more than adequate to return the UAS to its pre

- determined landing zone from anywhere in its limited operating range. Skycam Drones, Inc. is not seeking an exemption for night

-time UAS operations. **14 C.F.R. §91.21 5:**  **AT C Transponder Requirements** 
Section 91.215 requires all aircraft to have an operational transponder with altitude report ing capabilities. As a UAS may not have the room nor carrying capacity for a transponder , an exemption is needed. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the limited location where it is operated.

**14 C.F.R. §91.405: Maintenance Inspections** These regulations require that an aircraft operator or owner shall “have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Skycam Drones, Inc. operations. Maintenance will be accomplished by the operator in accordance with the manufacturers recommen ded procedures . An equivalent level of safety will be achieved because the UASs are limited in size, will carry a small payload and operate only for limited periods of time. A preflight inspection will be performed prior to every flight to ensure no mechan ical issues are present. If mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to flight, andSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

perform any required maintenance. Moreo ver, the operator is the person most familiar with the UAS and best suited to maintain it in an airworthy condition

. **14 C.F.R. §91.407: Operation after Maintenance** Functional check flights will be conducted away from people or property after any maintena nce has been accomplished on the UAS. The UAS may be returned to service once it has been determined safe for flight. **14 C.F.R. §91.409: Inspections** Due to the small size of the UASs that will be operated by Skycam Drones, Inc. and limited components, we request that the UASs be exempt from regularly scheduled inspections. To meet an equivalent level of safety sought by 14CFR 91.409, all UASs will be thoroughly inspected prior to flight. Since the UASs will have limited components, a thorough inspection can be accomplished before each flight, eliminating the need for periodic, time based, or flight

- hour based inspection cycles. **14 C.F.R. §91.417: Maintenance Records** As previously described **,** the UASs proposed si ze and use significantly limits the amount of maintenance required. The UASs that will be operated by Skycam Drones, Inc. are designed by the manufacturer for the average hobbyist to purchase and fly with minimal assembly, regular preventative maintenance is limited to security of attached components and proper storage of, and charging of batteries. As such, Skycam Drones, Inc. requests an exemption from maintaining maintenance records as pre scribed by 14CFR 91.417. However, in order to operate as safely as possible, Skycam Drones, Inc. will keep a running log of all maintenance performed on each UAS, and any anomalies noted during operation in order to diagnose and prevent problems with the U AS. **Summary**

**for Publication** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Skycam Drones, Inc. seeks an exemption from the following rules: 14 CFR Part 21 Subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.215, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, and 14 CFR 417 to operate commercially small unmanned vehicles (55 pounds or less) for aerial photography and videography for real estate marketing, dataSkycam	Drones,	Inc. 1933	S.	Oak	Haven	Circle Miami,	FL.	3 3179 pmanley@pagebuild.com

collection, special events, residential and commercial construction inspection and news gathering

. As established by the UAS exemptions already granted by the FAA, allowing commercial operations of UASs in real estate inspections and news gathering will enhance safety by reducing risk. Conventional photography and videography operations, using turbine aircraft, operate at low altitudes and present t he risks associated with aircraft that weigh thousands of pounds, and carry large amounts of fuel. Such aircraft must also fly to and from the film ing location. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries virtually eliminates all of that risk given the small size and lack of combustible fuel. The UAS is carried, and not flown, to a film location. In this regard, the UAS carries no passengers or crew, therefore will not expose anyone to the risks associated with manned flights. The operation of UASs conducted in accordance with this request will provide an equivalent level of safety supporting the grant of the exemption requested herein. The UASs operate at slow speeds, close to the ground, and within a limited range. As a result , they are far safer than conventional operations conducted with turbine helicopters carrying fuel and flying near the ground and people. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, operating capabi lities, proximity to airports and populated areas and operation within visual line of sight and national security) provide more than adequate justification to grant Skycam Drones, Inc. ’ s requested exemption, allowing for Skycam Drones, Inc.’s UAS commercia l operations.
Sincerely, Patrick Manley , President/Owner Skycam Drones, Inc.