Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

pmanley@pagebuild.com

US Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Exemption Request Pursuant to Section 333 of the FAA Reform Act 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. 91.215, 14 CFR 

91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417

To Whom 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 videography 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 commercial 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 (PIC); within 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 and 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 33179
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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. Such 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 UAS 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 

surrounding 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, the grant of

the requested exemption is in the public interest. Accordingly, Skycam Drones, 

Inc., respectfully requests that the FAA grant the requested exemption. 

Aircraft And Equivalent Level Of Safety

The operating limitations 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. 

Skycam 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 elevated platform from which filming is planned.
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

pmanley@pagebuild.com

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

• 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. 

• Operator will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, 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 documents 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 enforcement official upon request. 

• The UA will remain clear and give way to all manned aviation operations and 

activities at all times.

• Operator 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 nonparticipating 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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 immediately 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 operating 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.

• 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: Airworthiness 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 Aviation 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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 

analysis 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) operating with an airworthiness certificate without the restrictions 

and conditions proposed.

14 C.F.R. § 45.23 (b): Display of marks, General

Display of marks Sections 45.23 (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) and (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. Allowing 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 Action

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 battery requirements, and performance data before 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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 programmed 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 during 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 Altitudes

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 associated 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 Altimeter 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 indicator 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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.

Skycam 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. §91.215: ATC Transponder Requirements

Section 91.215 requires all aircraft to have an operational transponder with 

altitude reporting 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 

recommended 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 mechanical 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, and 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

pmanley@pagebuild.com

perform any required maintenance. Moreover, 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

maintenance 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 size 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 prescribed 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 UAS.

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, data 
Skycam	Drones,	Inc.

1933	S.	Oak	Haven	Circle

Miami,	FL.	33179

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 the risks associated with aircraft that weigh thousands of pounds, and 

carry large amounts of fuel. Such aircraft must also fly to and from the filming 

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 capabilities, 

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 

commercial operations. 

Sincerely,

Patrick Manley, President/Owner

Skycam Drones, Inc.