UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Prairie SkyCam

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on March 5, 2016

Prairie SkyCam

2698 E. 400 North Rd

Pana, IL 62557
Prairie SkyCam 217-562-7222 2

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, Anthony Ambrose 

of Prairie SkyCam, operator of an Unmanned Aircraft System (UAS), hereby applies for 

an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities.

• Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and news gathering.

• Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local government authority.

• Aerial inspection/photography of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers.

• Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the 

local authorities or government has requested it by contract or donation.

• The ability to offer training to persons individually or belonging to both private 

and/or public organizations that have interests in the use and application of a 

UAS for the purpose of the safe operation of a UAS to enhance the safety of the 

National Airspace System (NAS) as well as for the protection of the persons and 

property.

As described fully below, the requested exemption would permit the operation of a 

UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) 

would provide safety enhancements in the fields in which it will operate, which now 

depend upon conventional aircraft or humans climbing high on dangerous structures or 

working adjacent to treacherous infrastructure. Approval of this exemption would 

thereby 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.
Prairie SkyCam 217-562-7222 3

Petitioner Name and Address:

Prairie SkyCam

Attn: Anthony Ambrose (Owner & Pilot)

2698 E. 400 North Rd

Pana, IL 62557

Phone: 217-562-7222

Email: info@prairieskycam.com

Background:

The Petitioner, Prairie SkyCam is under Anthony Ambrose’s direction. Anthony is a 

highly accomplished, capable, experienced, and trusted professional.

Prairie SkyCam is a Midwest-region aerial photography and video company with more 

than 10 years of professional UAS experience serving a wide variety of clients with

photography (aerial & ground), videography (aerial & ground), 360°x180° panoramas 

and virtual tours (aerial & ground) in the following areas: recurring construction

progress, site planning, industrial, commercial, residential, engineering, manufacturing, 

agriculture, and more.

Prairie SkyCam provides photography and video services for clients across the 

Midwest and has always been fully insured from inception.

Expertise & Experience:

For more than 25 years, Anthony has been a professional computer software engineer

involved in the building and piloting of various types of remote controlled aircraft and 

ultralight aircraft. Also, as a result of more than 10 years in the Aerial Photography and 

Video business, Anthony, has an in-depth understanding of the capabilities and safety 

concerns involved in using this technology as an asset to the community. Anthony has 

also held an FAA Private Pilot Airplane Single Engine Land Certificate since 1997 (FAA 

Certificate Number 3826214) which adds an additional level of understanding of the 

safety concerns involved.

Safety Record:

As a result of its adherence to detailed safety procedures before, during, and after all 

operations, Prairie SkyCam has a zero incidence safety record during its 10+ years of 

operation.
Prairie SkyCam 217-562-7222 4

Description of Type, Make and Model of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate a DJI Inspire 1, Model 

T600, with a total weight of 2935g or 6.47lbs. The dimensions are 438mm x 451mm x 

301mm or 17.24inch x 17.75inch x 11.85inch. Under still air the maximum speed is no 

more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJI Inspire 1 

has the ability to hover and move along a vertical and horizontal plane simultaneously. 

The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6-cell 

4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller 

Model DJI 1345, in use. The DJI Inspire 1 will be controlled with the C1 remote 

controller with an operating frequency of 2.400GHz –2.483GHz. The live video feed will 

have an operating frequency of 5.728GHz –5.850GHz. The applicant will operate the 

UAS in line of sight within a predetermined area owned and/operated by the property 

representative. Given the small size of the UAS and the controlled environment 

provided the proposed operations will adhere to the Reform Act’s safety requirements. 

The approval of this application presents no national security issues. Manuals related 

to the DJI Inspire 1 aircraft can be found in appendices A to D.

The FAA has already granted several exemptions for the use of the DJI Inspire 1. 

A few examples include:

• Exemption 12030 to American Family Mutual Insurance Company

(Docket No. FAA–2015–1380)

• Exemption 11789 to Legend Creative Group

(Docket No. FAA–2015–1004)

• Exemption 12002 to Advanced Aviation Solutions LLC

(Docket No. FAA–2015–1226)

• Exemption 12046 to AerOptix, LLC

(Docket No FAA–2015–1534); 

• Exemption 12302 to Brad G. Beshaw

(Docket No. FAA–2015–1527)

• Exemption 11760 to Brian L. Short

(Docket No. FAA–2015–0992)

• Exemption 11814 to Alert5 International, LLC

(Docket No. FAA–2015–1142)

• Exemption 12496 to 360 Delaware Orbit Tours

(Docket No. FAA–2015–0705)

• Exemption 11788 to Bird’s Eye Aerial Photography, Inc.

(Docket No. FAA–2015–1003)
Prairie SkyCam 217-562-7222 5

• Exemption 11289A to Bird’s Eye Solutions, LLC

(Docket No. FAA-2014-0944)

• Exemption 11993 to BUNGEE LLC

(Docket No. FAA–2015–1511)

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge 

inspections, flare stack inspections, utility-power generation system inspections and 

patrolling, aerial inspections, photography and videography of residential and 

commercial real estate, weddings, photography and videography of utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with onboard sensors, wildlife and forestry 

monitoring, aerial surveying, construction site inspection and monitoring, aerial imaging 

for safety, monitoring and comparing work efforts and completion percentages, and 

security of controlled environment of various sites, 360°x180° aerial panoramas and 

virtual tours, aerial video and live video feed to assist with search and rescue

operations under the authority and support of local authority officials, aerial video and 

photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering, aerial mapping, training to persons 

individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS, 

special events including high schools, colleges, professional sports, open air events 

and fairs, research, risk management and assessment, motion picture production, 

surface mining, closed set filming, disasters, and catastrophic events.

Aircraft and Equivalent Level of Safety:

Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. 

Accordingly the applicant requests that the FAA grant the requested exemption with 

minimum delay.

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using 

conventional aircraft. These limitations and conditions to which the applicant agrees to 

adhere to when conducting commercial operations under the FAA issued exemption as 

set forth in the Flight Operations Manual (FOM) include:
Prairie SkyCam 217-562-7222 6

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed of no more than 50mph.

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or 

Visual Observer (VO).

• Flights will be terminated at 25% battery power.

• Flights will be operated at an altitude of no more than 400 feet Above Ground 

Level (AGL) and not more than 200 feet above an elevated platform from which 

filming is planned.

• Minimum crew for each operation will consist of the UAS Pilot, the Visual 

Observer (VO) and may include but not limited to a Camera Operator.

• The UAS pilot will be a designated Pilot in Command (PIC) and hold a Private

Pilot’s License along with a valid United States Driver’s License.

• A briefing will be performed regarding the planned UAS operations prior to each 

flight.

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) 

only.

• The flights will occur no closer than a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport.

• The operator will file FAA Form 7711-1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate local Flight Standards District 

Office (FSDO) no more than 72 hours but no less than 48 hours from planned 

operation.

• The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed 

within 100 feet of the flight operation, and the radius may be reduced to 30 feet 

based upon an equivalent level of safety determination, as required under the 

FOM. With the advanced permission of the FSDO, operations at closer range 

may be approved.

• The PIC and VO will have been trained in operation of UAS and receive up-todate information for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice or radio at all times.

• Written and/or verbal permission and permits will be obtained from territorial, 

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies.

• If the UAS loses communications with the remote controller or loses GPS signal, 

the UAS will have the capability to return to a pre-determined location within a 

designated location and land autonomously.
Prairie SkyCam 217-562-7222 7

• The UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft 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 UAS. In all cases, an analysis of these 

criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

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. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety 

requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly,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 materials or flammable liquid fuels, 

and inability to carry a substantial external load.

Specific Uses Public Benefits:

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel. It operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and 

diminish the likelihood of death or serious bodily injury. With a small payload and 

maximum flight time of only 20 minutes, there is little or no risk to national security.

Low level oblique photos, 360°x180° panoramas, and video from several angles are far 

more effective than ground based imagery for displaying the characteristics of large, 
Prairie SkyCam 217-562-7222 8

complex properties. The benefits of reduced cost and improved quality of presentation 

from the UAS will be valuable to many clients in a wide variety of applications.

Additionally, Prairie SkyCam requests that they be allowed to use the UAS to benefit 

first responders (firefighters, police, sherriff, et al.) who may desire assistance while 

remaining subject to all limitations cited in this application as they do so.

Prairie SkyCam respectfully submits that using UAS to perform the aforementioned 

operations offers a net safety benefit and will achieve an enhanced level of safety, as

mandated under Section 333(c) of the Reform Act. Approval of this application also will 

benefit many clients in various areas of the United States economy.

Maintenance:

Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is 

very limited in size and will carry a small payload and operate only in restricted areas 

for a limited period of time. 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 initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the UAS Manufacturer's User Manual. As 

provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed.

Satisfaction of criteria provided in Section 333 of the Reform Act provide more than 

adequate justification for the grant of the requested exemptions allowing the 

commercial operation of the applicant’s UAS.

Respectfully submitted,

Anthony Ambrose

Prairie SkyCam

2698 E. 400 North Rd

Pana, IL 62557