1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 1 

# Petition for Exemption Request

Exemption Request Section 333 of the FAA Modernization & Reform Act & Part 11 of the Federal Aviation Regulations

Prepared by :

Travis Ritchie Owner, SkyRAV Productions

October 23, 20151242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 2 Travis Ritchie Owner, SkyRAV Productions 1242 SW Pine Island Rd Suite #42

- 430 Cape Coral, FL 3399 1 , USA Phone: (866) 725

- 7070 E

- mail: ritchiet@skyrav.com

October 23 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR Part 21; 45.23(b); 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103 ; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Ref orm Act of 2012 (the Reform Act) and 14 CFR Part 11, SkyRAV Productions , a media and technology company, and operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography and videography, hereby applies for an exemption from th e 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

.

As described m ore fully below, the requested exemption , if granted, would permit SkyRAV Productions, to conduct commercial operations of small, unmanned and relatively inexpensive s UAS meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 3

The name and address of the petitioner is:

Travis Ritchie Owner, SkyRAV Productions Phone: ( 866 ) 725

- 7070 E

- mail: ritchiet@skyrav.com Address: 1242 SW Pine Island Rd, Suite #42

- 430, Cape Coral, FL 3399 1 , USA

SkyRAV Productions is a media and technology company that is planning to use the capabilities of sUASs to offer a multitude of specialized services, including, but not limited to the following:

 Aerial Surveying

 Remote Sensing

 Agricultural Support

 Real Esta te Photography and Videography

 Aerial Filmmaking and Photography

 Zone

- Site Inspections and Monitoring

 Wildlife and Forestry Monitoring

 Educational and Research Operations

Regulations from which the exemption is requested:

14 CFR Part 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CF R 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91. 407 (a) (1) 14 CFR 91. 409 (a) (2) 14 CFR 91.417 (a) & (b)1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 4

Statutory Authority

This exemption petition is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UAS’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight (VLOS) of the operator.

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333 (a) states t hat the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by Section 332 (b)(1) of this Act or the guidance required by Section 334 of this Act.” In Section 332 (b )( 1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations

.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under 40101 of the Act, which includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 44701(f) See also 49 USC 44711 (a); 49 USC 44704 ; 14 CFR 91.203 (a) (1).1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 5

Unmanned Aircraft System

The petitioner will only operate sUASs that are rotorcraft, weighting 55 lbs. or fewer, including payload , without combustible fuels or liquids, and carriers neit her a pilot nor
passenger . The sUASs will operate , under normal conditions at a speed of no more than 50 knots , have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate within a secured area or sufficien t distance from populated areas, and only in visual line of sight

. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public.”

The petitioner is requesting an exemption to enable SkyRAV Pro ductions to operate a DJI Phantom 3 and/or DJI Inspire 1 sUAS , these type of s UASs are equipped with three

- axis gimbals and High

- Def inition (HD) cameras, in addition to several built

- in safety features for controlling flight operations (e.g., Flight Contro ller modes such as Failsafe and Return to Home, Flight Modes utilizing sensors for stable s UAS flight positioning (GPS, Vision,
B arometer ) , Low Battery or Power senso rs activating safety features for Return to Home safe landing , and programmable flight altitude and radius controls based on the s UAS operator ’ s ground position ), excluding from Class B, C and D airspace , including no

- fly zone

measures

.

Petitioner Proposed Unmanned Aircraft System

DJI Phantom 3 Professional DJI Inspire 1

Petitioner Supplied Additional Information

Phantom Pilot Training Guide v1.2 Phantom 3 Professional U ser Manual v1.4 Inspire 1 U ser Manual v1.41242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 6

Aircraft and Equivalent Level of Safety

T he petitioner proposes that the requested exemption herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations and conditions to which SkyRAV Production agrees to be bound when conducting commercial operations under an FAA issued exemption include the following :

a) The sUAS will weigh less than 55 lbs

. , including payload

.

b) Flights will be operated within VLOS of a pilot and/or observer , and will have built

- in capability to limit flight altitude and radius from the sUAS operator ’s ground position

.

c) Observer and pilot wil l at all times be able to communicate by voice and/or text.

d) Maximum flight time for e ach operation will be 2 0 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 2 0 minute limit.

e) Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned.

f) Minimum of two (2) man crew for each sUAS operation will consist of the Pilot and Spotter / Observer. In most cases the third aircr ew member will serve as the Camera / Sensor Operator.

g) The sUAS pilot will be an FAA licensed airman with at least a sport/private pilot’s certificate and hold a current FAA airman medical certificate or valid U.S. driver’s license

. The Camera / Sensor Oper ator and Spotter (Observer) will hold at least an airman medial certificate or valid U.S. driver’s license.

h) The sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications , is also present during flights , that person can also be designated as PIC.

i) The sUASs will not be operated over densely populated areas, open

- air assembly of people, heavily tracked roads, or within 5 NM of an airport or heliport without prior permissio n.

j) The Operator will file a FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office (FSDO).1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 7

k) Written and/or oral permission from the relevant pro perty holders will be obtai ned, and a ll required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

l) Pilot, Camera Operator, and Spotter (Observer) will ha ve been trained in operation of sUAS generally and received up

- to

- date information on the particular sUAS to be operated as required by the vendor/manufacturer

.

m) If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre

- determined location within the “ Security Perimeter ” and land.

n) The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

o) Given the small size of the sUASs and the restricted “Sterile Environment” within which they will operate, the sUAS flight operations will adhere to the Reform Act’s safety requirements.

Given the small size of the sUASs involved and the res tricted “S terile E nvironment ” within which they will operate, the petitioner falls squarely within that zone of safety ( i.e., an

e quivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs t o commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will operate (non

- Class B, C, and D airspace, including no fly

- zones) , approval of the petitioner presen ts no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, red uction in environmental impacts, including reduced emissions associated s UASs , the grant of the requested exemptions is in the public interest.

Accordingly, the petitioner respectfully requests that the FAA grant the requested exemption without delay.1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 8

Exemption Request and Equivalent Level of Safety

The petitioner requests an exemption from the following regulations as well as any additional regulations that may technic ally apply to the operations of the petitioner’s usage of s UASs:

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). G iven 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 are as 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 conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS 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 area.

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored , by both the operator and the under the requirements an d in compliance with local public safety requirements, to provide ensured security and safety for all areas of operation. 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 oper ation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 9

14 C.F.R. 45.23 (b) : Marking of the Aircraft

The regulation requires that each aircraft must display the Roman capital letter “N” :

W hen marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft nea r 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," "light

- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no ai rworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experi mental” will be placed on the fuselage in compliance with 45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working with the sUAV will see th e identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges & Limitations: Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no on board passengers or property for compens ation or hire . The area of operation is controlled and restricted, and all flights are planned and coordinated in advance.

The petitioner will require that the PIC must hold at least a Private Pilot License issued by the FAA and since the aircraft cannot carry passengers or property, t he risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. 61.113 (a) & (b).1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 10

14 C.F.R. 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condi tion. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exis t for determining airworthiness, this regulation is inapplicable.

14 C.F.R. 91.9 (b) (2): Civil Aircraft Fli ght Manual in the Aircraft

Section 91.9 (b) (2) provides that n o person may operate a U.S. registered civil aircraft unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the grou nd control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R . 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. 91.109: Flight instruction:

Section 91.103 provides that no p erson 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. sUASs and remotely piloted aircraft, by their design do not have fully functional dual con trols. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communicati ons.

The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact th at neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 11

14 C.F.R. 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allow s helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exempti on requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated i n the Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent leve l of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the prop erty owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammab le fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the sUAS will ensur e separation between these s UAS operatio ns and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.121 : Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter setting tha t is available within 100 NM of the aircraft (i.e., t o the elevation of the departure airport or an appropriate altimeter sett ing available before departure). As the sUAS may not have a barometric altimeter, but instead a GPS altitude read ou t, an exemptio n may be needed. An equivalent level of safety will be achieved by confirming the altitude of the launch site shown on the GPS a ltitude indicator before flight and maintaining UAS flight operations below 400 AGL.

14 C.F.R. 91.151(a): Fuel Requirements f or Flight in VFR Conditions

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 landi ng, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 12

The battery powering the sUAS s provides approximately 18 minutes of powered flight wi th 20% reserve . The max distance or operating area of sUAS flight operations will be less than 1/8 NM from the point of intended landing. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predeterm ined area, sUAS flight operations will meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS flights would be limited to approximately 1 5

- 18 minutes in length.

Applicant believes that an exemption from 14 CFR 91.151(a) falls within the scope of p rior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who hav e signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 1 5 minutes would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 1 0 minutes or 25% of battery power whichever happens first. This restriction would be more t han adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent 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. . . .

(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 cock pit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display th em on the sUAS.1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 13

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. 91.405 (a); 407 (a) ( 1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

Thes e 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 section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the pe titioner . Maintenance will be accomplished by the operator as defined by the Pilot Training Guide. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricte d areas for limited periods 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 main tenance, 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.

*********1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 14

S ummary - Publication for Federal Register

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:

Petitioner seeks an exemption from the following rules : 14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 61.113(a) & (b); 91.7 (a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.409(a)(2) and 91.417(a) & (b) to operate commercially a small unman ned vehicle (55lbs

. or less) in media and technology operations.

Safety and Benefits of the UAS

Approval of exemptions allowing commercial operations of sUASs will enhance safety by reducing risk. Conventional aerial film operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amount s of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, we ighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the petitioner from the requirements of Part 21 and allowi ng commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to
t he ground and people.

The primary market of interest for SkyRAV Productions is the Real Estate and Property Appraisal industry, in addition to visual inspections of construction and industrial sites , and other sUAS type applications needing aerial photography and videography

. These type of UAS applications will lead to increased economic revenues promoted through improved property and land values, higher sales volumes, and overall generalized community safety. UASs will shape the future and next evo lution of real estate marketing (e.g., aerial views of property and land, neighborhood and surrounding areas, home proximity to amenities, civic developments, and localized improvements in districts, property maps and surveys).1242 SW PINE ISLAND RD, SUITE #4 2

- 430, CAPE CORAL, FL 3399 15

Privacy

All flights wi ll occur over private or controlled access property with the property owner’s prior consent and knowledge. F ilming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place.

The gra nt of this exemption request will provide improved safety in the use of UAS operations , and s atisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weight, speed, operating capabilities, proximity to airports and populated are as and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of petitioners UAS s in the media and technology industry. SkyRAV Productio ns is eagerly standing by to support the FAA and sUAS community in its quest to establish proper regulations for the safety of the national airspace and the public.

Sincerely,

Travis Ritchie Owner, SkyRAV Productions