1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 33991

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, 2015
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 33992

Travis Ritchie

Owner, SkyRAV Productions

1242 SW Pine Island Rd

Suite #42-430

Cape Coral, FL 33991, 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 Reform 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 the 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 more fully below, the requested exemption, if granted, would permit SkyRAV 

Productions, to conduct commercial operations of small, unmanned and relatively 

inexpensive sUAS meeting or exceeding all of the operational and safety requirements 

Congress has set forth in Section 333.
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 33993

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 33991, 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 Estate 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 CFR 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 #42-430, CAPE CORAL, FL 33994

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 that 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 #42-430, CAPE CORAL, FL 33995

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 neither 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 sufficient 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 Productions to operate a DJI 

Phantom 3 and/or DJI Inspire 1 sUAS, these type of sUASs are equipped with three-axis 

gimbals and High-Definition (HD) cameras, in addition to several built-in safety features for

controlling flight operations (e.g., Flight Controller modes such as Failsafe and Return to 

Home, Flight Modes utilizing sensors for stable sUAS flight positioning (GPS, Vision, 

Barometer), Low Battery or Power sensors activating safety features for Return to Home

safe landing, and programmable flight altitude and radius controls based on the sUAS 

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 User Manual v1.4

Inspire 1 User Manual v1.4
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 33996

Aircraft and Equivalent Level of Safety

The 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 will at all times be able to communicate by voice and/or text.

d) Maximum flight time for each operation will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 20 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 aircrew 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 Operator 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 

permission. 

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 #42-430, CAPE CORAL, FL 33997

k) Written and/or oral permission from the relevant property holders will be obtained, 

and all 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 have 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 restricted “Sterile Environment” within 

which they will operate, the petitioner falls squarely within that zone of safety (i.e., an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UASs to 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 presents 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, reduction 

in environmental impacts, including reduced emissions associated sUASs, 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 #42-430, CAPE CORAL, FL 33998

Exemption Request and Equivalent Level of Safety

The petitioner requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operations of the petitioner’s usage 

of sUASs:

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 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 and 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 operation, lack of explosive materials or flammable 

liquid fuels, and inability to carry a substantial external load. 
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 33999

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

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

When 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 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," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness 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 “Experimental” 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 

the 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 compensation 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, the 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 #42-430, CAPE CORAL, FL 339910

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 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness, 

this regulation is inapplicable. 

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

Section 91.9 (b) (2) provides that no 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 ground 

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 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. sUASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. 

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 that 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 #42-430, CAPE CORAL, FL 339911

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows 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 

exemption 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 in 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 level 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 property 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 flammable 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 ensure separation between these sUAS operations 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 that is available within 100 NM of the aircraft (i.e., to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure). As the sUAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight 

and maintaining UAS flight operations below 400 AGL. 

14 C.F.R. 91.151(a): Fuel Requirements for 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 landing, 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 #42-430, CAPE CORAL, FL 339912

The battery powering the sUASs provides approximately 18 minutes of powered flight with 

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 predetermined area, sUAS 

flight operations will meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS 

flights would be limited to approximately 15-18 minutes in length. 

Applicant believes that an exemption from 14 CFR 91.151(a) falls within the scope of prior 

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 have 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 15 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 10 

minutes or 25% of battery power whichever happens first. This restriction would be more 

than 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 cockpit 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 them on the sUAS. 
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 339913

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

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 section and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the petitioner. 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 restricted 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 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. 

*********
1242 SW PINE ISLAND RD, SUITE #42-430, CAPE CORAL, FL 339914

Summary - 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 unmanned 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 amounts 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, weighting 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 allowing 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 

the 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 evolution 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 #42-430, CAPE CORAL, FL 339915

Privacy 

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Filming 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 grant of this exemption request will provide improved safety in the use of UAS 

operations, and 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 for the grant of the requested exemptions allowing commercial operation of 

petitioners UASs in the media and technology industry. SkyRAV Productions 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