May 22, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regu lations from 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b) and (c); 14 C.F.R. 121; 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 405 (a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernizatio n and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, SkyShot Productions, an operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to film and photograph real estate in rural areas in the state of California, applies for an exemption fr om the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Approv al of exemptions for SkyShot Productions will allow commercial operations of sUASs in suburban areas of Los Angeles, CA, for the purpose of real estate photography and videography. The requested exemption should be granted because the proposed operations o f the DJI Phantom 2, a small UASs that weighs 2.9 lbs., inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. The

l ightweight aircraft covered by the exemption are far safer than conventional operations conducted with manned helicopters and fixed

- wing aircraft weighing thousands of pounds, containing highly flammable fuel, and operating in close proximity to the ground and people, as a similar UAS has been previously approved in Exemption No. 11138, Douglas Trudeau, Realtor®. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capabili ty, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow speeds, close to the ground, far from airports and in a low risk, low population environment. In addition, the substantial experience of the PIC weighs heavily in favor of granting the exemption. Pursuant to 14 C.F.R. 11.35, SkyShot Productions requests confidential treatment for certain information provided with this request for exemption. Specifically, SkyShot Productions requests that information contained in its user manual, SkyShot Production’s operating procedures, not be made public due to the proprietary information that the application has not and will not shar e with others. Additionally, SkyShot Productions requests that personal information related to the PIC not be made public in order to protect his identity. These documents are not available to the public and are protected

from release under the Freedom of lnformation Act 5 U.S.C. 552 et seq.For your ease in reviewing this petition refer to the table of contents which begin on page three. If we can provide any additional information to assist your understanding or review of this document, please do not hes itate to contact us at 818

- 577

- 7036 or email us at

Paul.Gross@me.com

Thank You,

Paul Gross Owner/Operator SkyShot Productions

23371 Mullholland Drive

#270

Woodland Hills CA 91364

+1.8185777036 

### paul.gross@me.comExhibit List (Submitted Separately)

Exhibit 1: DJI Phantom 2 Manual

Exhibit 2: Phantom 2

– Features

Exhibit 3: Phantom 2

– Specs

Exhibit 4: Naza

- M V2 Quick Start Guide

Exhibit 5: 5.8G Video Link User Manual

Exhibit 6: iOSD mini User Manual Exhibit 7: DJI No Fly Zones

Exhibit!8:! Phantom!2

– Release! Notes

Exhibit !9:!Valid!California!Drivers!Li cense

I. Publishable Summary Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publ ication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)( 2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119(b) and (c); 14 C.F.R. 91.151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 405 (a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417. Approval of exemption s for SkyShot Productions will allow commercial operations of sUASs in suburban areas of Los Angeles, CA, for the purpose of real estate photography and videography. The requested exemption should be granted because proposed operation of the DJI Phantom 2, a small UASs weighing 2.9 lbs., inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial operations. The lightweight aircraft cov ered by the exemption are far safer than conventional operations conducted with helicopters and fixed

- wing aircraft operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when approving Section 333 ex emption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow spee ds, close to the ground, far from airports and in a low risk, low population environment. In addition, the substantial experience of the PIC weighs heavily in favor of granting the exemption.

II. Petitioner’s*Contact*Information* SkyShot Productions


### 2337 1 Mullholland Drive #270
Woodland Hills, Ca 91364

Tel: 818

- 577

- 7036 Email: paul.gross@me.com

III. SkyShot Productions *Operations*A. The sUAS The requested exemption will permit the operation of the DJI Phantom 2. The Phantom 2 is a small, unmanned mul tirotor aircraft, weighing 2.9 lbs. inclusive of batteries, the propeller guard, and technical payload. This rotorcraft can operate at a speed up to 29 knots, but SkyShot Productions will limit the speed to no more than 20 knots. The FAA has previously gra nted Exemption No. 11138, allowing commercial flight of a member of the DJI Phantom 2 family, the Phantom 2 Vision+. Exemption No. 11138 is attached to this petition as Exhibit 10. The sUAS will have the following specifications:

Airframe: DJI Phantom 2 Flight Control System: Naza

– M V2, which includes the main controller (MC), internal measurement unit (IMU) with built

- in internal sensor, barometric altimeter, which measures attitude and altitude, compass, GPS, and radio receiver (Rx). Transmitter (Tx): Futaba T14SG Receiver (Rx): Internal to DJI Phantom 2

Data Link: 2.4G Data Link

Video Link: DJI AVL 58

Gimbal: H3

- 3D Zenmuse Gimbal for GoPro Hero

Camera: Go Pro Hero 4 Black Batteries: 3S LiPo, 5200

- mAh, 11.1V iOSD: DJI iOSD mini, which allows live telem etry to be displayed on the video monitor, including the battery level, and altitude.

Please refer to Exhibits 1

- 8 for further information about the sUAS and transmitter.

B. Flight Conditions The sUAS will be flown in airspace under 200 feet above grou nd level (“AGL”) and under controlled conditions in rural areas. The majority of flights will take place under 100 feet AGL. SkyShot Production’s operations will occur in suburban areas of Los Angeles focusing in the Thousand Oaks, Westlake Village, Agoura Hills and Calabasas areas of Los Angeles county and Ventura County. Skyshot Productions will avoid congested and densely populated areas and will work with local Flight Standard District Offices to determine safe areas to fly in. Skyshot Productions will only operate its sUAS in VMC, visual meteorological conditions: no less than 500 feet below and no less than 2,000 feet horizontally from a cloud or when visibility at least 3 statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no undue hazards are present.

C. Flight Operations Skyshot Production ’s flight operations require that the sUAS will always be in the line of sight of both a PIC and a mon itor specialist, who will also act as the visual observer (VO). Flights will b e at altitudes of no more than 2 00 feet AGL, and at speeds l ess than 20 knots. Despite the 2 00 ft. AGL limit, most flights will take place at an altitude of no

more than 100 ft. AGL. The PIC has over twenty years of experience with RC aircraft, and has over 200 hours flying sUAS as a hobbyist.The week of an operation, the flight crew will file a flight plan with the local FSDO and contact ATC. The day before an operation, the f light crew will visit and inspect for safety the area in which operations will take place. The flight crew will also contact any neighbors to notify them of the filming. The sUAS will only fly over land which it has permission from the landowner or landown er’s agent to fly above. The notification will consist of, at minimum, the time, place, and type of UAS operation being conducted. The flight crew will also conduct a safety briefing with the property owners. Operations will no t take place in congested an d the PIC will work with the local FSDO when planning operations. The flight crew will obtain all aeronautical and weather data information, as laid out in Section 6 of the Operations Manual. Exhibit 1. On the day of filming, the flight crew will wear flo rescent shirts or vests to increase visibility. Prior to departing for an operation, the flight crew will briefly turn on the sUAS to ensure that everything is connected and that the sUAS is in operational

condition. Upon arrival at a location for filming or photography, the flight crew will conduct an aerial and ground preflight inspection. The flight crew will then set out traffic cones to designate the aircraft’s “home area,” which will be a circle of approximately 20 feet in diameter to mark the sUAS take

- off and landing zone. Note: If the radio control link is broken during flight, the autopilot system will recognize this broken control link and cause the sUAS to automatically return to the home area as recorded by the GPS instrumentation. The fligh t crew will conduct a physical inspection of the aircraft

. The flight crew will then power on the sUAS and set up a laptop connected to the sUAS with the DJI AVL 58 video link. This laptop will display the telemetry information during the flight, and be

mo nitored by the VO. The VO will be able to see the images taken by the GoPro camera

in real time. At any time during the flight, should the aircraft lose connection with the remote control, the flight control system failsafe will be activated automatically , and the aircraft will to return to the previously

- set home area and land, in order to reduce injuries or damage. If any of the following 7 situations occur, the aircraft will not receive a signal, and enter

into this failsafe mode:

• The remote contro l is powered off;

• The aircraft has flown out of the effective communication range of the remote control, which is no greater than 1,000 meters (3,280 feet);

• There is an obstacle obstructing the signal between the remote control and the

aircraft , essentially reducing the distance the signal can travel; or

• There is interference causing a signal problem with the remote control. For further information regarding the DJI Phantom 2’s failsafe functions, please refer to Exhibit 1, the DJI User Ma nual, Section 6.4, beginning on page 25 of that document, and Exhibit 4, the Naza

- M V2 flight control guide, section on Advanced Functions, beginning on page 16 of that document. The DJI Phantom 2 also has “no fly zones” programmed into it, which will

pre vent flights in restricted zones. Although SkyShot Productions will take every precaution to avoid flying in airspace other than class G airspace, the preprogrammed “no fly zones” will add an additional level of safety to operations.For further informatio n regarding the DJI’s “no fly zones,” please refer to Exhibit 1, Section 6.7 of the DJI User Manual, beginning on page 28 of that document, and Exhibit 7. Other than this automated feature of the DJI Phantom 2, the PIC will always fly the sUAS manually. Th e PIC and VO have tested the sUAS in a variety of weather conditions, including on overcast days and in winds up to 15 knots. The PIC and VO will not fly the sUAS in heavy rainstorms, due to decreased visibility and the potential for water damage to the sU AS. The PIC and VO have also practiced emergency bailout procedures by having the sUAS return to home. In the event of an emergency, the PIC will release the joysticks. This will make the sUAS automatically hover in place and maintain its position and

alti tude, and the PIC and VO can determine if and when it is safe for the sUAS to

return to the home location. During flights, the PIC and the VO will be standing next to each other, in oral communication at all times at the ground station. The VO will observ e the telemetry data on the laptop and will monitor the images from the camera from the laptop. The VO will direct the PIC if she wishes to capture a different angle on the camera. The Go Pro Hero 4 Black camera will be filming or taking still images at in tervals during the entirety of the flight and is not controlled independently from the ground station, other than by the movement of the sUAS. Flights will be limited to 18 minutes, which is 75% of the total battery life of the

DJI Phantom 2. Once the sUA S has landed, the PIC will conduct a post

- flight checklist as set out in Appendix D of the Operations Manual.

IV. Privacy There is little concern that the proposed flights will cause invasions of privacy because all flights will occur over rural proper ty with the property owner’s prior knowledge and consent. The only people and/or property to be filmed will have requested and hired SkyShot Productions for the express purpose of filming and photographing the people and/or property with the sUAS.

No atte mpt will be made to identify any individuals filmed or photographed during the flights who have not consented to be filmed or photographed, except in cases where they are trespassing upon or damaging customer property, or interfering with the applicant’s o r its customers’ operations

V. Aircraft and Equivalent Level of Safety SkyShot Productions proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These

limi tations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure. These limitations and conditions to which SkyShot Productions agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh significantly less than fifty (50) lbs. The DJI Phantom 2 weighs 2.9 lbs., inclusive of battery and payload.

2. Flights will be operated within line of sight of a pilot and VO.3. Maximum total flight time for eac h operational flight will be 75% of battery life. Flights will be terminated once the battery reaches a 25% level. This data will be available through telemetry data submitted to the transmitter and monitor.

4. The sUAS will remain clear and yield the right of way to all other manned operations and activities at all times.

5. Flights will be operated at an altitude of no more than 200 feet AGL. Despite this limitation, the majority of flights are anticipated to operate at no more than 100

feet AGL.

6. Minimum cre w for each operation will consist of the sUAS PIC and VO.

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties in connection with the op erations be present for this briefing.

8. The operator will obtain a FAA UAS Civil COA prior to conducting any operations under this grant of exemption.

9. The operator will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less tha n 48 hours prior to the operation.

10. At least three days before scheduled filming, the operator of the sUAS will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming.

11. The PIC and VO have practiced the DJ I Phantom 2 for ap proximately 120 minutes a day for 2 months , translating to at least 200 hours of flight on this model. Practice flights have been in a variety of weather conditions, including in winds up to 15 knots and on overcast days. Practice flights have also included using the DJI Phantom 2’s emergency return

- to

- home features. 13. The PIC and VO will at all times be able to communicate by voice and be stationed next to each other at the ground station.

14. Written and/or oral permission from th e landowner or authorized agent, of the land over which the sUAS will be flying.

15. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate gover nmental agencies.

16. The sUAS will have the capability to abort a flight in case of unexpected obstacles or emergencies. The PIC and VO have practiced the emergency failsafe procedures, as described above on pages 6

- 7.

17. If the multirotor and its controller d isconnects during flight, the system’s failsafe protection will come to the rescue and the multirotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown

location. For more information on the failsafe procedures, please refer to Exhibits

1

- 5. This condition is similar to one granted in Exemption No. 11138, attached to this petition as Exhibit 8.

VI. Public Interest and Safety Use of the sUAS will increase ground safety by eliminating the need to have a manned, aircraft take the videos or photographs. As the FAA recognized in the Douglas Trudeau, Realtor® Exemption, No. 11138:“Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or dama ge to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a (iv) (v) within Class G airspace; and outside of 5 statute miles from any airport, heliport, seapla ne base, spaceport, or other

location with aviation activities.” [sUAS] for the proposed operation.” Exhibit 10 at 11

- 12. As in the cited exemption, SkyShot Productions will use a member of the DJI Phantom family, the DJI Phantom 2. This sUAS also weighs 2.9 lbs., inclusive of battery and payload. During SkyShot Production’s operations, the PIC and VO will similarly be safely on the ground, directing the DJI Phantom 2 at altitudes no higher than 400 feet AGL. SkyShot Productions will not fly over congest ed or densely populated locations, and will work with local FSDO when planning operations. SkyShot Production’s flight crew will make a safety assessment prior to each operation, and will only operate when there are no

undue risks. The small weight, 2.9 l bs., is less than the size envisioned in Section 334(c)(2)(C) of the FAA Modernization and Reform Act of 2012, which allows government agencies “to operate unmanned aircraft weighing 4.4 pounds or less, if operated

–
1. (i) within the line of sight of the o perator;

2. (ii) less than 200 feet above the ground;

3. (iii) during daylight conditions; Congress’s determination that government agencies should be allowed to operate such aircraft in these situations, with no further restrictions on location, population density, or pilot experience and training, indicates that Congress did not believe that aircraft of this size and weight warranted additional attention.

VII. Regulations from Which Exemption is Requested A. 14 C.F.R. 21(h):

Airworthiness Certificates

S kyShot Productions requests an exemption from 14 C.F.R. 21(h). This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 based on the small size, light weight, relatively slow speed, and use in controlled environments on private land, as described previously in this petition. In Exemption No. 11138, the FAA stated that the Secretary of Transportation has determined that a member of the DJI Phantom 2 family, the Phantom 2 Vision+ meets the statutory conditions of Section 333, considering the size, weight, speed, and limited operating area associated with the aircraft and its operation. See Exhibit 10 at 11. Equivalent level of safety: SkyShot Production ’s proposed exemption meets the requirements for an equivalent level of safety of this section, pursuant to Section 333, based on the following factors:

• Small size: the DJI Phantom 2 has a diagonal length of 350 millimeters, 13.77

inches.

• Light weight: 2.9 lbs.• Relatively slow speed: the PIC will limit the sUAS’s speed to 20 knots (23

miles per hour).

• Operational capacity: currently, t he DJI Phantom 2 can operate for 25 minutes. Flights will be terminated when 25% of the battery life remains. The DJI Phantom 2 can travel no more than 1,000 meters, 3280.84 feet, from the receiver.

• Proximity to airports: SkyShot Productions will on ly operate in Class G airspace, and will notify ATC and the local FSDO prior to operations, as described previously.

• Proximity to populated areas SkyShot Productions will work with the local Flight Standards District Offices to determine which areas t o avoid during flights. Local FSDO may carve out areas indicated as yellow in the sectional chart and

allow SkyShot Productions to fly in these specifically designated carve

- out areas.

• Operation within visual line of sight: The PIC will always fly the sUAS within

its line of sight.

• Location: SkyShot Productions will operate in rural, suburban, with low population density

.

• Alt itude: no more than 2 00 feet AGL, but the majority of flights are anticipated

at no more than 100 feet AGL.

Restri cted area in which the sUAS will be operated: as described above, prior to the day of filming, the flight crew will visit with neighbors to inform them of the filming over the consenting landowner’s property. During filming, which will

occur in rural area s, the flight crew will set out cones to mark the “home area” for the sUAS, and will monitor the area to make sure no one comes into the flight area. Should any nonparticipating individual enter the flight area, operations will immediately cease. See Exhib it 10 at 19.

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. SkyShot Productio ns requests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for

return t o service. As described previously, SkyShot Productions ’s flight crew will be capable to repair and maintain the DJI Phantom 2 to meet an equivalent level of safety of

this section. Equivalent level of safety: The nature of the sUAS is that of a model air craft, and the operators of SkyShot Productions who will maintain and when necessary repair the sUAS will conduct inspections and maintenance based on maintenance guidelines provided by the manufacturer of the sUAS, DJI. See Exhibits 1

- 5. The capabilities of these operators to maintain and repair the sUAS will be listed in the operator’s manual and meet the requirements for an equivalent level of safety pursuant to Section 333 for the type of sUAS, its intended use, and the rural operating environment.

C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.SkyShot Productions requests an exemption from 14 C.F.R. 43.11. This part provides, inter alia, th at maintenance record entries be maintained and for the listing of discrepancies and placards by inspectors. The sUAS, due to its small size, does not have room for placards to be placed in or on it and no inspections for sUAS have been certified by FAA at the present time. Equivalent level of safety: SkyShot Productions will keep log books of all maintenance and repairs at the ground station, as envisioned in the FAA Memorandum subject, “Interpretation regarding whether certain required documents may be k ept at an unmanned aircraft’s control station,” dated August 8, 2014. See Exhibit 8. This request provides an equivalent level of safety as 14 C.F.R. 43.11 because the documentation will be at the ground station with the PIC, where it will be useable in ca se of an emergency, rather than with the sUAS which could be up to 1,000 meters from the operator. D. 14 C.F.R. 45.11: Marking of products. SkyShot Productions requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the manufactu rers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an approved fireproof identification plate. The sUAS, due to its small size, does not have room for fireproof placards to be placed in it. Any required placards could be come hazardous, due to the additional weight and strain placed on the sUAS. Any additional weight or placards on the 2.9 lbs. sUAS could create a risk, due to the very small size and nature of the DJI Phantom 2. Equivalent level of safety: SkyShot Product ion ’s PIC and VO will keep information related to the DJI Phantom 2, including the user manual, at the ground control station and

affix its N

- Number, once obtained from the FAA Registration Office, on the “arms” of the sUAS as large as practicably possible . This exemption provides an equivalent level of safety to 14 C.F.R. 45.11 because the relevant documentation containing the serial number will be at the ground station with the PIC, where it will be useable in case of an emergency, rather than with the sU AS. In addition, the fuselage is marked with “DJI,” the

manufacturer of the sUAS. E. 14 C.F.R. 45.27: Location of marks; nonfixed

- wing aircraft SkyShot Productions requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each oper ator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The sUAS, due to its small size, does not have a cabin, fuselage, boom or tail to display the marks requi red by §45.23. Equivalent level of safety: Once SkyShot Productions receives its N

- Number, it will display these marks on the “arms” of the aircraft as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the

sUAS will be traceable to SkyShot Productions

. 13

F. 14 C.F.R. 45.29: Size of marks SkyShot Productions requests an exemption from 14 C.F.R. 45 .27. This part provides, inter alia, at subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. The sUAS, due to its small size, does not have any surface area large enough to display marks anywhere near 12 inches high.Equ ivalent level of safety: SkyShot Productions will affix its registration number as large as practicably possible on its “arms” once it obtains the N

- Number. This exemption provides an equivalent level of safety to 14 C.F.R. 45.29 because the sUAS will be

r egistered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS

will be traceable to SkyShot Productions

. G. 14 C.F.R. 91.7(a): Civil aircraft airworthiness. The FAA has previously stated that no exemption is required for a member of the DJI Phantom 2 family. Exhibit 8 at 17. SkyShot Productions requests the same determination

to be made for its DJI Phantom 2. Alternatively, SkyShot Productions requests an exemption from 14 C.F.R. 91.7(a). The regulation requires that no person ma y operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft should this exemption be granted, no standard will exist for determining airworthiness. Equivalent level of safety: SkySh ot Productions will keep the DJI Phantom 2’s maintenance and safety information at the ground station, where it will be readily accessible to the PIC and VO before, during, and after operations. This exemption provides an equivalent level of safety as 14 C .F.R. 91.7(a) because the PIC will be able to make the determination of whether the sUAS is in an airworthy mechanical and electrical condition, in accordance with 14 C.F.R. 91.7(b). H. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and plac ard requirements. The FAA has previously stated that no exemption is required for a member of the DJI Phantom 2 family. Exhibit 10 at 17. SkyShot Productions requests the same

determination to be made for its DJI Phantom 2.

Alternatively, SkyShot Produc tions requests an exemption from 14 C.F.R. 91.9(b)(2). This part provides: "(b) No person may operate a U.S.

- registered civil aircraft... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is avai lable in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination

thereof." First, there does not currently exist a method of approving manuals for sUAS. Second, given the s ize and configuration of the sUAS, there is no space to carry such a flight manual on the aircraft. In addition, carrying the manual on the aircraft would be pointless, since there is no pilot or other person on board who could read or use it. On August 8, 2014, the FAA issued a memorandum entitled “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station.” This document stated, in part “maintaining these documents at the pilot’s control

station would meet the intent of the rule as the pilot would be able to produce the documents for his or her own information or to an FAA inspector.” See Exhibit 9. Equivalent level of safety: SkyShot Productions will keep its flight manual at the ground station, wher e both the PIC and VO can access it. An equivalent level of safety to 14 C.F.R. 91.9(b)(2) is provided because the intent of this rule

– the pilot having access to this material during flight

– is met.I. 14 C.F.R. 91.9(c): Civil aircraft flight manual, m arking, and placard requirements. SkyShot Productions requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapt er." As stated above, SkyShot Productions will obtain an N

- Number from the FAA Registration Office and the sUAS, due to its small size, does not have room to contain fireproof placard or to display aircraft marks in a conventional size. However, once SkyS hot Productions obtains an N

- Number, it will place the number on the “arms” of the aircraft as large as practicably possible. Equivalent level of safety: SkyShot Productions will obtain its N

- Number from the FAA Registration Office and affix it to the “ar ms” of the aircraft as large as practicably possible. An equivalent level of safety to 14 C.F.R. 91.9(c) is met because the sUAS will be registered with the FAA and identifiable in the event of an incident. J. 14 C.F.R. 91.103(b)(2): Preflight action.

Sk yShot Productions requests an exemption from 14 C.F.R. 91.103(b)(2) to the extent that is applicable. This part provides: "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— ... (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: ... (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliab le information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature." SkyShot Production ’s PIC in fact will, before beginning a flight, b ecome familiar with all available information concerning that flight, including the aircraft performance under expected elevations, the gross weight of the aircraft (which will be no more than 2.9 lbs.), and the wind and temperature. As the flights of the sUAS will not be at airports the information required of Part 91.103(b)(2) does not apply. Equivalent level of safety: SkyShot Productions shall perform preflight operations as outlined previously in this petition, and flights will not be at airports. An equivalent level of safety to 14

15 C.F.R. 91.103(b)(2) will be met because the PIC will become familiar with the conditions prior to the flight, including the aircraft performance under expected elevations, the gross weight of the aircraft (which will b e no more than 2.9 lbs), and the wind and temperature. K. 14 C.F.R. 91.105: Flight crewmembers at stations. SkyShot Productions requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the sUAS carrying no flight crewmembers. Equivalent level of safety: SkyShot Productions will not operate the aircraft unless someone is at the controls at all times, and each flight will be manually flown, with the exception of the DJI Phantom 2’s automated safety features. This will provide an equivalent level of safety to 14 C.F.R. 91.105 because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft but on the ground. L. 14 C.F.R. 91.113(b): Right

- of

- way rules: Except water operatio ns.SkyShot Productions requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to overhead aircraft operating at or above 500 feet AGL as the sUAS will be operating no higher than 400 feet AGL. This part provides: “(b): General. When w eather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft.

When a rule of this se ction gives another aircraft the right

- of

- way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear." For example, if another aircraft is operating overhead at 10,000 feet AGL there is no danger posed to that other aircraft if the sUAS is operating under it or ahead of it at or beneath 400 feet AGL. Despite this, should another aircraft enter the area in which SkyShot Productions is operation, because the flight will be within his line of sight, the

PIC w ill be able to give right of way to that aircraft. Equivalent level of safety: SkyShot Productions will operate its sUAS to see and avoid and give way to other aircraft that should enter airspace at or below 400 feet AGL, and will give right

- of

- way to man ned aircraft. All flights will be in class G airspace and the majority of flights will be at no more than 100 feet AGL, which will create a very slim

chance that SkyShot Production’s operations will interfere with a manned aircraft’s flight. This will prov ide an equivalent level of safety to 14 C.F.R. 91.113(b) because the sUAS has significantly greater mobility than a much larger, manned aircraft. As a result, the PIC will be able to react and respond much more quickly than the other pilot.

M. 14 C.F.R. 9 1.119(c): Minimum safe altitudes: General. SkyShot Productions requests an exemption from 14 C.F.R. 91.119 subpart (c). This regulation provides: "Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitud es...

(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.” SkyShot Productions will not op erate the sUAS any higher than 2 00 feet AGL. Equivalent level of safety: SkyShot Productions will operate the sUAS no higher than 400 feet AGL, and it is anticipated that the majority of operations will be no higher than

1 00 feet AGL. SkyShot Productions will not operate in congested areas, and will work with the local FSDO when planning operations. SkyShot Production ’s flight crew will make a safety assessment prior to each operation, and only operate after it determines t hat there is no undue hazard present. Exhibit 8 at 19. The 400 feet AGL maximum will provide an equivalent level of safety to 14 C.F.R. 91.119(c) because, since 1981 with AC 91

- 57, this height has been an operating standard

for model aircraft. Additionall y, in Section 334(c)(2)(C), Congress determined that sUAS operated by public agencies flying sUAS the size of and larger than SkyShot

Production’s DJI Phantom 2 could fly up to 400 feet AGL. N. 14 C.F.R. 91.121: Altimeter Settings SkyShot Productions req uests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for altimeter use in maintaining the cruising altitude or flight level of the

aircraft. SkyShot Productions is not requesting a general exemption from the requirementthat its sUAS hav e an Altimeter. The DJI Phantom 2’s flight controller will have an internal measurement unit (“IMU”). The IMU has a built

- in internal sensor and a barometric altimeter that measures both attitude and altitude. See Exhibit 1, Appendix B, page 5. Rather, Sky Shot Productions requests an exemption from the requirement to set its altimeter to a station along the route, of out of an airport, because the DJI Phantom 2 is not traveling point

- to

- point and is limited in the distance it can travel from the PIC.

Additi onally, SkyShot Productions will not be flying into or out of an airport. Equivalent level of safety: The requested exemption provides an equivalent level of safety to 14 C.F.R 91.121 because SkyShot Productions will not operate the sUAS above

400 feet AG L in a sustained cruising flight mode such as a manned aircraft will typically fly. The PIC will at all times be controlling the maximum height of the sUAS through the telemetry features of the DJI controller. Additionally, the sUAS will be operated within the line of sight of the PIC. The FAA has previously granted this exemption for similar proposed operations. See Exhibit 10. O. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions.

The sUAS SkyShot Productions will fly is powered by electri city, using lithium polymer batteries that currently have a flight limit of approximately no more than 25 minutes. (See Exhibits 1 and 10). Therefore, due to the limitations of the batteries, it is currently impossible to comply with Part 91.151. However, the sUAS will be operated in a manner with at least the equivalent level of safety as that of a manned aircraft complying with

Part 91.151. Operation of an sUAS with less than 30 minutes of reserve fuel does not engender the type of risks that Section 91. 151(a) was intended to alleviate. During the entire flight, the PIC will always have a visual line of sight of the sUAS and the VO will be monitoring the battery life via t he telemetry display on the laptop at the ground station. The sUAS will always have enough power to land safely, given the minimum level of reserve capacity of the batteries. SkyShot Productions will limit flights to 75% of battery capacity. With the battery SkyShot Productions currently uses, the 75% point occurs at 18 minutes, leaving 7 minutes for the sUAS to reach the planned landing zone. This amount of time will be more than sufficient for the PIC to safely return to and land in the “home area.” As battery power increases, the number of minutes the sUAS can operate before reaching t he 75% mark will also increase. As new batteries are obtained and put into use, SkyShot

Productions will continue to terminate flights after 75% of battery power has been used. Applicant believes that an exemption from 14 CFR §91.151(a) is consistent with the scope of similar exemptions already granted to other operations. Exhibit 10. Equivalent level of safety: SkyShot Productions will limit flights 75% of battery power. The proposed exemption meets an equivalent level of safety to 14 C.F.R. 91.151 becau se, given the limitations on SkyShot Production’s proposed operations and the location of those operations, a reduced minimum power reserve for flight in daylight VFR conditions

is reasonable. P. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required. The FAA has previously determined that exemption from 14 C.F.R. 91.203(a) and (b) is not necessary. See Exhibit 10 at 17. Alternatively, SkyShot Productions requests an exemption from 14 C.F.R. 91.203(a) and (b). This section provides in part:“(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (2) An effective U.S. registration certificate issued to its owner... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 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.” First, there are currently no procedures in effect for providing airworthiness certificates for sUAS. However, as a condition to the approval of exemption, SkyShot Productions will display its N

- Number, once received, on the sUAS, and the operator will have, at the ground station, the user manual for the DJI Phantom 2. Second, the sUAS SkyShot Productions will use the DJI Phantom 2, which has an equivalent level of safety as a manned aircraft with an airworthiness certificate. Please

refer to Exhi bit 10, Exemption No. 11138, as SkyShot Production’s DJI Phantom 2 is in the same sUAS family as the DJI Phantom 2 Vision+, which was the subject of that exemption. This sUAS provides a number of safety features, including the automatic

return to home fail safe discussed in detail above.

Because of the use of GPS with the sUAS, the operator will set the initial location of flight takeoff ("home position") and if the radio control link is broken, the autopilot system will recognize this broken control link and cause the sUAS to automatically return to the home position as recorded by the GPS instrumentation. Exhibits 1

- 7. Additionally, because the sUAS team will mark off an area with traffic cones that has a 20 ft. radius, approximately 30 ft. from the opera tors that will be used as the “home position” for the sUAS to return, no one will be standing in the way of the path. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted wit h airworthiness certificates issued under Subpart H. Application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive mater ials or flammable liquid fuels, and inability to carry a substantial payload. In the restricted environment and under the conditions proposed, operation of the sUAS will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating w ith an airworthiness certificate but without the restrictions and conditions proposed. SkyShot

Productions will not accept assignments from clients that would take place in Class B, C, D, or E airspace. SkyShot Productions will avoid flying over congested and populated areas and will work with local FSDO to avoid these areas when planning operations. Equivalent level of safety: The sUAS to be operated hereunder is 2.9 lbs. inclusive of batteries and technical payload, carries neither a pilot nor passengers , and carries no explosive materials or flammable liquid fuels. The sUASs operating under this exemption will be tightly controlled and monitored by the operator and the observer, and in compliance with local public safety requirements, to provide security for the area of operation. The FAA will have advance notice of all operations because SkyShot

Productions will notify both ATC and the local FSDO prior to operations, as described previously in this petition. Granting the proposed exemption will achieve a n equivalent level of safety to 14 C.F.R. 91.203(a) and (b) because of the small size of the sUAS and the operational limits set out above.Q. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use This section requires that installed Air Traffic Control (ATC) transponder equipment must meet specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder. There are presently no known commercially available ATC transpon ders that meet the payload requirements of a sUAS and are available at reasonable cost. However, because the sUASs used by SkyShot Productions will not be flying into or near airport s, and will fly no higher than 2 00 feet AGL, there is very low risk of col lision with any manned aircraft. In addition, because there will be no need to have contemporaneous communication with ATC Control, due to the short distances, short flight times, and restricted altitude the sUASs will operate within, SkyShot Productions r equests an exemption from this section. Additionally, the sUAS is too small to contain ATC transponder equipment in any form factor that is known to be available commercially. Equivalent level of safety: An equivalent level of safety to 14 C.F.R. 91.215 w ill be met

because SkyShot Productions will not fly its sUAS into or near airports, an d all operations will be below 2 00 feet AGL, so there is very low risk of collision with any

manned aircraft. SkyShot Productions will contact local ATC before operations to issue a NOTAM, and the local FSDO with its flight plan, as described previously in this petition. SkyShot Productions also give right of way to any manned aircraft that do appear.

R. 14 C.F.R. 91.403: General This section requires that the owner or o perator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition. SkyShot Productions will adhere to this requirement. However, this Section also limits maintenance to that “prescribed in this subpart and other applic able regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 requested above, SkyShot

Productions requests an exemption from this Section. This exemption meets the requirements for an equiva lent level of safety pursuant to Section 333 based on the small size, light weight, relatively slow speed, and use in controlled rural environments on private, secured land, as described previously in this petition. Equivalent level of safety: To achieve an equivalent level of safety to 14 C.F.R. 91.403, SkyShot Productions will maintain its sUAS in an airworthy condition and adhere to all manufacturer requirements for inspecting and maintaining the DJI Phantom 2. SkyShot

Productions will keep records of m aintenance to the sUAS, and these records will be available to the PIC and VO before, during, and after operations of the sUAS. S. 14 C.F.R. 91.405 (a) and (d): Maintenance Required This section requires that aircraft be inspected as prescribed by Sectio n E, 14 C.F.R. §§91.401

- 91.421. As shown below, SkyShot Productions is applying for an exemption for these sections, due to the fact that its operators will inspect the sUAS prior to each flight and keep maintenance records of all parts that are replaced, in accordance with

DJI’s instructions. Because the Sections discussed below are concerned with manned aircraft, and as such have inspection requirements designed for the safety of passengers, they are inapplicable to SkyShot Productions

. SkyShot Productio ns is also applying for an exemption to subpart (d) of this section, which requires a placard to be installed and references §43.11. As noted previously,SkyShot Productions requests an exemption to the placard requirement, because, due to

the small size o f the sUAS, there is no room to place the placard. Despite the requested exemption from subparts (a) and (d) of this section, SkyShot

Productions will follow subparts (b) and (c) of this subpart. Equivalent level of safety: To achieve an equivalent level of safety to 14 C.F.R. 91.405(a) and (b), SkyShot Productions will keep logbooks detailing all maintenance and repairs to the sUAS. The logbooks will be available to the PIC and VO before, during, and after sUAS operation. Prior to conducting post

- maintena nce operations, the flight crew will conduct a test flight to ensure that the sUAS functions properly. The FAA has previously determined that following the manufacturer’s requirements for maintenance, inspection, and record keeping are sufficient to ensure that safety is not adversely

affected. Exhibit 10 at 13.

20 T. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or alteration This section requires that any aircraft which “has undergone maintenance, preventative

maint enance, rebuilding, or alteration unless . . . [i]t has been approved for return to service by a person authorized under § 43.7 of this chapter . . ..”
However, SkyShot Productions has requested an exemption from §§ 43.7 and 43.11 as described previously. The capability of the operators to maintain and repair the sUAS meets the requirements for an equivalent level of safety pursuant to Section 333 for both the type of sUAS, its intended use, and the rural operating environment. Additionally,

due to the sma ll size of the sUAS, there is no room to place inspection placards. Therefore, because SkyShot Productions has requested an exemption from 43.7 and 43.11, SkyShot Productions respectfully requests an exemption from 91.407. The PIC,

who holds a commercial pilot’s certificate, will conduct maintenance on the sUAS and keep logs of the battery cycle and repairs needed on the body or the propellers of the DJI

Phantom 2. Equivalent level of safety: The proposed exemption will meet an equivalent level of safety to 14 C.F.R. 91.407 because SkyShot Productions will regularly inspect and maintain its sUASs in accordance with the DJI operator manual, and keep detailed inspection and maintenance records that will be available to the PIC and VO before, during, and afte r operations. Prior to conducting post

- maintenance operations, SkyShot

Productions will conduct a test flight to ensure that the sUAS functions properly. U. 14 C.F.R. 91.409: Inspections This section lays out specific requirements for inspections of airc raft. SkyShot

Productions respectfully requests an exemption from these requirements because they are intended to maintain the safety of manned aircraft significantly larger and capable of significantly longer flights than is sUAS. SkyShot Production’s pre

- flight and post

- flight inspections meet or exceed the level of safety achieved by adherence to 14 C.F.R. 91.409. Equivalent level of safety: As discussed above and in Appendix D, SkyShot Productions has an inspection procedure that provides an equivalent level of safety to 14 C.F.R. 91.409. Before and after each flight, the flight crew will conduct an inspection of the sUAS as described previously.

V. 14 C.F.R. 91.417: Maintenance recordsSkyShot Productions respectfully requests an exemption from this Section, as it is only applicable for aircraft with an airworthiness certificate. Because SkyShot Productions will not have an airworthiness certificate, this Section is inapplicable. Equivalent level of safety: The requested exemption will meet an equiva lent level of safety to 14 C.F.R. 91.417 because SkyShot Productions will keep detailed maintenance records on every part as it is replaced, including but not limited to propellers, batteries, and electrical components. The detailed maintenance records wil l be accessible to the PIC and the VO before, during, and after operations.