. , 

October 5, 2014 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

• ! ' 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 

To whom this matter applies: 

Greetings. We are contacting you as it relates to the FAA Modernization and Reform Act of 20 12 

(the "ReformAct") and the positions and/or procedures contained in 14 C.P.R. 11, to request that 

Somniaire, LLC, which has filed an application with the PA Department of State for doing business 

(DBA) as SkyePro Aerial Video Productions, be exempted from the Federal Aviation Regulations 

listed within the body of this letter so that SkyePro Video may operate small, low altitude (multirotor) unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal 

Aviation Administration. 

Our intent is to manage all such operations within and under the conditions outlined 

or as established by the FAA as required by Section 333. The conditions identified 

and proposed by the applicant are drawn from Order 8 900.1 CH G 0, Volume 3, Chapter 8: Issue 

a Certificate of Waiver 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 it relates 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 of the Academy of Model Aeronautics (AMA) and is well versed in the safe 

and responsible care and operation of multi-rotor as well as fixed wing model unmanned 

aircrafts. 

Our request would permit 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 of sight and ALWAYS with strict 300 ft. ceiling 

limit. We utilize teams of pilot and spotters in an effort to ensure safe control over the flight 

lines of our unmanned aircrafts. We make it a PRIORITY to maintain complete awareness 

of surroundings, including people, crowds, structures, wildlife and property, private, public 

or government owned. 

Our use of unmanned RC aircraft pilots requires they adhere to these safety outlines at all 

times. All flights are based on pre-production meetings which delineate and clarify all flight 

maneuvers prior to actual flight. Equipment is checked prior to flights to ensure a high level 

of safety 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 should be carefully considered and ultimately permitted, yet controlled for 

the sake of safety to all involved, either by choice or by chance. 

Somniaire, LLC (DBA) SkyePro Video Productions respectfully requests the grant of an 

exemption allowing it to operate lightweight, multi-rotor remote controlled UAS's for 

commercial uses. At present, we do not perform any flights for commercial purposes yet 

wish to with the FAA's permission. Our website maintains examples of aerial 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 of Title 14 (as they relate to the 

commercial use of unmanned aircraft systems (UASs)) of the Code ofFederal Regulations. 

SkyePro Video submits this application in accordance with the Refonn Act, 112 P.L. 95 §§ 

331-334, seeking relief from any applicable FARs operating to prevent 

SkyePro Video contemplated commercial use within the national airspace system. 

The Reform Act in Section 332 provides for such integration of civil unmanned aircraft 

systems into our national airspace system as it is in the public's interest to do so. SkyePro's 

lightweight UASs meet the definition of" small unmanned aircraft" as defined in Section 331. 

Therefore SkyePro Video is requesting permission to operate its lightweight UASs prior to 

the time period by which the Reform Act requires the FAA to promulgate rules governing 

such craft. 

The Refonn Act guides the Secretary in determining the types ofUASs that may operate 

safely in our national airspace system. Considerations include: 

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be 

operated near airports or populated areas; and, Whether the UAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). 

Each of these criteria help to rule in favor of an exemption for SkyePro Video. 

We operate only small quad-rotor and 8 rotor crafts that measure no more than 42" in 

diameter. Weight is limited to under 20 pounds, which includes the UAs and attached camera 

equipment. Speed is limited to no more than 40 mph however there is little need for this type 

of speed since we specialize in primarily slow hovering modes of operation. Other rules 

adhered to presently by SkyePro Video include: 

• We never fly over people, or crowds of people or animals, either in the wild or 

domestic environments. We always hover off to one side of our intended subject. 

• We only operate by In Line Sight. We never allow any UAS to disappear from the 

operator or spotter's view. 

• All SkyePro Video unmanned crafts utilize only Lithium Polymer (LiPo) batteries. 
There is never any combustible fuel used to operate our unmanned crafts. 

• We always use a spotter to manage and maintain visual contact with the UAS. 

• Typical battery life is 12-14 minutes. We use electronic monitoring to gauge battery 

life and will land our unmanned aircrafts when battery life approaches 20%. 

• Our Phantom brand UAS has built in GPS technology in the rare chance of a loss of 

communication. Should transmitter connections fail, the UAS will automatically return to the 

operator's location, flying at a height of approx. 60 feet and land safely. 

• We operate at altitudes of no more than 300 feet. Most operation is below 100 feet. 

• We will not fly within 5 miles of any public or private airport, airstrip, US military 

property, NASA property or any government property that engage in aeronautics or testing of 

military systems of any sort or properties which post restricted access warnings. 

• Should we receive an exemption as hoped, we would only fly a UAS after we and any 

client has predetermined safety and other related logistics to ensure safe use. We realize this 

is for the protection of people, 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 and privacy" of citizens and business properties. 

Summary- The FAA May Publish in the Federal Register: 

After review of sections 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals 

and The Like, we realize that as operators of very 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 our request for exemption be 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 of producing aerial video footage which could be used in motion pictures, 

corporate or television productions, 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. 

Our message and belief in the use ofUAS aircrafts is: "Safety first. Awesome footage second." 

We agree with the P AA that there needs to be strict guidelines and protocols in place when it 

comes to the safe commercial use ofunmanned aircrafts. The news is full of irresponsible people 

using unmanned crafts with little regard for safety. Therefore, we applaud your ongoing quest to 

keeping the skies safe. 
Thank you in advance for your considerations regarding this matter. We hope you will grant our 

request for exemption from the above listed regulations. We await your timely reply. 

Sincerely, 

Ridgely B. Francisco, Founder/CEO 

Somniaire, LLC. 

13 Lizbeth Lane 

Berwyn, PA 19312