## ., October 5, 2014 United States Department ofTransportation Docket Management System 1200 New Jersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590 • ! '

Re: Exemption RequestPursuant To Section 333 ofthe FAA Reform Act of2012

To whom this matter applies: Greetings. We are contacting you as itrelates to the FAA Modernization and Reform Act of20 12 (the "ReformAct") and the positions and/orprocedures contained in 14 C.P.R. 11, to requestthat Somniaire, LLC, which has filed an application with the PA Department ofState for doing business (DBA) as SkyePro Aerial Video Productions, be exempted from the Federal Aviation Regulations listedwithin the body ofthis letter so that SkyePro Video may operate small, low altitude (multirotor) unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation Administration. Ourintentis to manage all such operations within and underthe conditions outlined or as establishedby the FAA as required by Section 333. The conditions identified andproposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8: Issue a Certificate ofWaiver for Motion Picture and Television Filming, and which also includes video production for other commercial use and purposes. Ridgely Francisco, founder and President ofSomniaire, LLC (PA) has over 35 years of marketing and Art Direction experience as itrelates to consumer and business-to-business advertising and marketing. It is simply our intent and hope to include low altitude video production with our other design and present video/film production services. Ridgely Francisco is also a member ofthe Academy ofModel Aeronautics (AMA) and is well versed inthe safe and responsible care and operation ofmulti-rotor as well as fixed wing model unmanned aircrafts. 

### Ourrequest wouldpermit SkyePro Video Productions to operate small, lightweight, unmanned remote controlled (RC) UASs in strictly controlled and limited airspace. As safety is a priority when addressing this matter, our own guidelines demand that any and all umanned crafts are to be ALWAYS in line ofsight and ALWAYS with strict 300 ft. ceiling limit. We utilize teams ofpilot and spotters in an effort to ensure safe control over the flight lines ofour unmanned aircrafts. We make it a PRIORITY to maintain complete awareness ofsurroundings, including people, crowds, structures, wildlife and property, private, public or government owned. Our use ofunmannedRC aircraft pilots requires they adhere to these safety outlines at all times. All flights are based onpre-production meetings which delineate and clarify all flight maneuvers priorto actual flight. Equipment is checkedprior to flights to ensure a high level ofsafety as well.Granting SkyePro's request for exemption helps to realize and integrate UASs into the national airspace. And we agree with the FAA that any and all uses ofUASs on a commercial level shouldbe carefully considered andultimately permitted, yetcontrolled for the sake ofsafety to all involved, eitherby choice orby chance. Somniaire, LLC (DBA) SkyePro Video Productions respectfully requests the grant ofan exemption allowing itto operate lightweight, multi-rotor remote controlledUAS's for commercial uses. Atpresent, we do notperform any flights for commercial purposes yet wishto withthe FAA's permission. Our website maintains examples ofaerial videos produced as artisitic portfolio presentation only. We state that only non-commercial uses of any and all aerial videography are considered. We are requesting exemptions on all Specific Sections ofTitle 14 (as they relate to the commercial use ofunmanned aircraft systems (UASs)) ofthe Code ofFederalRegulations. SkyePro Video submits this application in accordance withthe RefonnAct, 112 P.L. 95 §§ 331-334, seeking relieffrom any applicable FARs operating to prevent SkyePro Video contemplated commercial use within the national airspace system. TheReformAct in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is inthe public's interestto do so. SkyePro's lightweight UASs meetthe definition of"small unmanned aircraft" as defined in Section 331. Therefore SkyePro Video is requesting permissionto operate its lightweightUASs priorto the time periodby which the Reform Actrequires theFAA to promulgate rules governing such craft. The RefonnActguides the Secretary in determining the types ofUASsthatmay operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS; WhethertheUAS will be operated near airports orpopulated areas; and, Whether the UAS will be operatedby line of sight. 112 P.L. 95 § 333 (a). Each ofthese criteriahelp to rule in favor ofan exemption for SkyePro Video. We operate only small quad-rotor and 8 rotor crafts that measure no more than42" in diameter. Weight is limitedto under 20 pounds, which includes the UAs and attached camera equipment. Speed is limitedto no more than 40 mph howeverthere is little need for this type ofspeed since we specialize in primarily slow hovering modes ofoperation. Other rules adhered to presently by SkyePro Video include:

• We never fly overpeople, or crowds ofpeople or animals, either in the wild or domestic environments. We always hover offto one side ofour intended subject. • We only operate by InLine Sight. We never allow any UAS to disappear from the operator or spotter's view. • All SkyePro Video unmanned crafts utilize only LithiumPolymer (LiPo) batteries.

### There is never any combustible fuel usedto operate ourunmanned crafts. • We always use a spotter to manage and maintain visual contact withthe UAS. • Typical battery life is 12-14 minutes. We use electronic monitoring to gauge battery life and will land our unmanned aircrafts whenbattery life approaches 20%. • OurPhantombrandUAS has built in GPS technology inthe rare chance ofa loss of communication. Should transmitter connections fail, the UAS will automatically return to the operator's location, flying at a height ofapprox. 60 feet and land safely. • We operate at altitudes ofno more than 300 feet. Most operation is below 100 feet. • We will not fly within 5 miles ofany public orprivate airport, airstrip, US military property, NASA property or any government property that engage in aeronautics ortesting of military systems ofany sort orproperties which postrestricted access warnings. • Should we receive an exemption as hoped, we would only fly a UAS after we and any clienthas predetermined safety and otherrelated logistics to ensure safe use. We realize this is for the protection ofpeople, animals, natural habitats and any nearby property. • SkyePro would also obtain all necessary permits and/or permissions prior to any flights. We always respect the "space andprivacy" ofcitizens and business properties.
Summary- TheFAAMay Publish inthe Federal Register: Afterreview ofsections 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like, werealize that as operators ofvery small, unmanned aircrafts, these regulations do not apply to the operation of UAS aircrafts. These Regulations only apply to aircraft with an airworthiness certificate. They will not therefore, apply to SkyePro Video should ourrequest for exemptionbe granted. IN CONCLUSION SOMNIAIRE, LLC, D/B/A SKYEPRO VIDEO requests an exemption from the following Regulations: 14 C.P.R.21, subpartH; 14 C.P.R. 45.23(b); 14 C.P.R.§§ 61.113 (a) & (b); 14 C.P.R.§ 91.7 (a); 14 C.P.R.§ 91.9 (b)(2); 14 C.P.R.§ 91.103(b); 14 C.P.R.§ 91.109; 14 C.P.R. §91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.P.R.§§ 91.203(a) and (b); 14 C.P.R.§ 91.405 (a); 14 C.P.R.§ 91.407 (a)(l); 14 C.P.R. § 91.409 (a)(2); 14 C.P.R.§ 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) & (b) to commercially operate its small unmanned, lightweight aircraft vehicles for the benefit ofproducing aerial video footage which could be used in motion pictures, corporate or televisionproductions, to produce, edit and utilize aerial footage from our UAS aircrafts for marketing purposes for both business to business as well as business to consumer uses. We also contemplate other uses such as instructional uses, working with local and regional government or law enforcement agencies and/or using footage for training or surveying purposes. Ourmessage and beliefin the use ofUAS aircrafts is: "Safety first. Awesome footage second." We agree with the P AA thatthere needs to be strict guidelines and protocols in place when it comes to the safe commercial use ofunmanned aircrafts. The news is full ofirresponsible people using unmanned crafts with little regard for safety. Therefore, we applaud your ongoing questto keeping the skies safe.Thankyou in advance for your considerations regarding this matter. We hope you will grant our request for exemption from the above listed regulations. We awaityour timely reply.



### Sincerely,

Ridgely B. Francisco, Founder/CEO Somniaire, LLC. 13 LizbethLane Berwyn, PA 19312