151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email:

greg@skyvueap.com

1 | P a g e November 24, 2015 To: From: Greg Gomes, President & CEO SkyVue LLC 151 Hamilton Rd Tinton Falls NJ US Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 (Submitted electronically to the Federal DocketManagementSystem-FDMS)
Re: Request for Exemption under section 333 of the FAA Reform Act SummaryofExemption Request
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, and the Federal Aviation Administration’s general exemption authority under Title 49, United States Code, Section 44701(f), SkyVue LLC. (“SkyVue”) hereby petitions for exemptions from the following Federal Aviation Regulations specified in Title 14 of the Code of Federal Regulations:
14 CFR Part 21, Subpart H 14 CFR 45.23(a) 14 CFR 61.113(a)(b) 14 CFR 61.133(a) 14 CFR 91.7(a) 14 CFR 91.109(a) 14 CFR 91.119(c) 14 CFR 91.9(b)(2) 14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.203(a)(b) 14 CFR 91.319(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1)(2) 14 CFR 91.417(a)(b) These proposed exemptions, ifgranted,will allow SkyVue to operate their Unmanned Aircraft System (“UAS”) and will benefit the following commercial applications: Aerial video and photography construction sites, real estate, special events, film sets,inspection phototgraphy,landscape motion picture, television, wedding video / photography, increase public knowledge of UAS and promote safe UAS operations and the content creation industry for scripted closed set filming.2 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com The MultiRotors SkyVue uses multiple, swappable onboard cameras to capture high definition imagery and video. SkyVue's use ofthe UAS will grant production companies, corporations, , and others an overall greater awareness, heightened dynamic imagery, safety, as well as negate the need for conventional aircraft assistance. This results in enhanced efficiency for any activity conducted, aswell as an immediate environmental benefit. Operation under the anticipated exemptionwill be subject to strict conditions and requirements, ensuring at minimum, an equivalent level ofsafety to currently authorized operating standards and procedures per FAA Regulations. Supplemental Information: The following information is to be submitted separately to assist the FAA in making an effective evaluation:
Part A: ProductionAcceptance &Technical Specifications ofthe DJI Unmanned Aerial Systems Part B: SkyVue LLC. Flight Operations and VLAUAS Guidelines Part C: Operator and Observer Training Standard and Certification Example Part D: MultiRotor Aircraft Logbook and Maintenance Reporting Part E: SkyVue Summary ofManned and Unmanned Experience & Certifications
BackgroundofApplicant SkyVue LLC. Attn: Gregory Gomes 151 Hamilton Rd Tinton Falls, New Jersey 07724 Phone: (732) 735 3160, Email: greg@skyvueap.com
SkyVue LLC, was formed in 2012 to fill a clear need in the UAS commercial market for remote imagery. SkyVue has assembled a group of professionals each with over 21 years ofworldwide UAS experience in safety, film making experiance and radio controlled flight operation, ; bringing an unparalleled level of professionalism and safety expertise to an emerging market. SkyVue is strictly a services provider, and will not sell any of its UAS components individually.3 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com Aircraft Overview SkyVue LLC seeks an exemption to operate DJI systems for compensation or hire. The DJI Phantom 3, DJI Inspire 1 and DJI S900 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 2.4 Ghz Radio systems and utilize electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight ofapproximately2 pounds 11 ounces, while having a length of16 inches width of16 inches, height of8 inches, and a maximum speed of approximately29 knots. The DJI Inspire 1 has a maximum gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of11.8 inches, and a maximum speed ofapproximately 42 knots. The DJI S900 maximum gross 18 pounds. DiagonalWheelbase of35.4 inches, height of 20 inches and a maximum speed of35knots .The DJI Phantom 3 and DJI Inspire 1 UAs are equipped with four main rotors while the S900 has six main rotors; all systems driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3 and DJI Inspire 1 and S900 UAs that will be operated by SkyVue will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. SkyVue will require at least one company-trained, FAA certified Operator and one company-trained Visual Safety Observer during operations in order to maintain positive physical and visual control of the aircraft at all times. Because the MultiRotor is equipped with navigation lighting it is clear that the unmanned aircraft is more clearlyvisible during night time conditions when compared to the ability to visually spot the vehicle during daylight hours. For this reason SkyVue believes that by operating its aircraft above 400 feet, near airports, or generally near populated areas inwhich people are not made
aware and consent to unmanned operationswill cause unacceptable safety risk and will not operate within these conditions. Ifgranted exemption, SkyVue will yield right-of- way to all manned operations, as well as file appropriate NOTAMs prior to any operations in the NAS. Aircraft Lighting:
Forward : Aft Right:
Below Aircraft: Green Red Flight status indication strobe4 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com Training UAS Operator SkyVue requires every Operator to be fully qualified on its MultiRotor UAS appropriately. As wella s hold an FAA pilots licence. Trainees are given demonstration in general skills such as; maintaining altitude, maintainingvisual line ofsight, general navigation principles, obstacle avoidance, air traffic de-confliction, and emergency procedures. Qualification as an Operator for the MultiRotor UAS requires the Operator trainee to show proficient levels ofall aforementioned skill areas, with special emphasis on emergency procedures. UAS Safety Observer SkyVue requires every personwho will be acting as a flight safety observer to be proficient in airspace knowledge, emergency procedures, aeronautical chart interpretation and airspace safety, ground operations, ATC radio frequency communication.Two-Way radio communication will be established between the UAS operator and safety observer(s) during flight operations. MultiRotor Level 1 operator certification is the minimum standard for safety observer qualification. Currency is maintained through monthly aircraft flights and instruction.
AuthorityforPetition Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a method for seeking expedited FAA authorization of safe, civil UAS operation in the National Airspace System (“NAS”).
Section 333(a) states that the Secretary ofTransportation “shall determine if certain Unmanned Aircraft Systems may operate safely in the National Airspace System before completion of the plan and rulemaking required by Section 332 of this Act or the guidance required by Section 334 of this Act.”
Section 333(b) outlines any factors the Secretary of Transportation must consider in order to determine whether commercial UAS operation should be approved. These factors include at minimum “[the UAS’s] size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the National Airspace System or the public or pose a threat to National Security [...]”
Section 333(c) states that should the Secretary determine a certain UAS may operate safely in the NAS, “the Secretary shall establish requirements for safe operation of such aircraft systems in the National Airspace System.”
Section 44701(f) of Title 49, United States Code, states that “The [FAA] Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any ofsections 44702-44716 ofthis title ifthe Administrator finds the exemption is in public interest.”151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email:

greg@skyvueap.com

5 | P a g e Explanations

14 CFR Part 21, Subpart H: Procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approvals
Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, 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 andweight ofthe MultiRotor aircraft (25 lbs) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate ofairworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.
Such an exemption meets the requirements ofan equivalent level of safety under Part 11 and Section 333 of the Reform Act.The Federal Aviation Act and Section 333 ofthe 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 UAS involved.
In this case, an analysis of these criteria demonstrates that the MultiRotor operatedwithout an airworthiness certificate, under the conditions proposed herein,will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate.The MultiRotor weighs 25 lbs fully configured. It will not carry a pilot or passenger,will not carry flammable fuel, and will operate exclusivelywithin an area pre-disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored byboth the operator, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the lack offlammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level ofsafety.

 Lightweight (<25lbs), small form factor aircraft

 Powered by sealed lithium polymer batteries, eliminating fuel spillage or risk offire

 Remote crew location, eliminating risk in the event of an incident

 Waypoint/Route programming capability, ensuring obstacle/obstruction avoidance

 Built in fail-safe modes (hover in place, return to home, autonomous landing) After consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, SkyVue believes exemption from 14 CFR Part 21 should be granted.6 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com
14 CFR 45.23(a): Display ofmarks; general
The MultiRotor does not have an entrance to a cabin, cockpit or pilot station in order to place required markings. Due to the size of the aircraft, 2 inch lettering is not possible. The MultiRotor will have a 1” marking denoting its tail numberwhich will achieve an equivalent level of safety as required by §45.29(f) in which the pilot, observer, and others ground crew personnel attending to work on the aircraft will see each aircraft with a specific marking to denote aircraft serial number. Aircraft to be flown will be registered in accordancewith 14 CFR part 47. SkyVue requests exemption be granted from 14 CFR Part 45.

14 CFR 61.113(a) and (b); 61.133(a): Private pilot privileges and limitations; Pilot in Command; Commercial Pilot Privileges and Limitations
UAI’s intent:

 Provide UAS services over property onlywith permission from landowner

 Display appropriatewarning signage on all borders ofproperty during operation

 Maintain high level UAS airmanship skillsetvia SkyVue specified currency &training requirements

 Ability to achieve equivalent level of safety required by current regulations

 As operation ofUAS is fundamentally different than manned aircraft, the current level ofair and ground instruction ofall aircraft operators (see Supplemental Information, Part E) is sufficient for safe UAV operations. A private pilot’s license does not apply to UAV operations and should not be considered as a minimal qualification to perform unmanned aircraft operations. Furthermore,
a commercial pilot certificate as prescribed in Part 61.133 is outside the scope ofthe proposed unmanned aircraft operations as no carrying of persons or propertywill be performed. SkyVue believes exemption from 14 CFR 61.113(a) and (b); 61.133(a) should be granted.

14 CFR 91.7(a): Civil aircraft airworthiness This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there is no published standard forvalidating airworthiness condition ofthe MultiRotor aircraft, SkyVue will abide by internal company process documentation to validate operational functionality which will achieve an equivalent level of safetyby ensuring compliancewith all maintenance and inspection manuals (Supplemental Information, Part D). SkyVue believes exemption from 14 CFR 91.7(a) should be granted.7 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com
14 CFR 91.119(c): Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to anyperson, vessel, vehicle, or structure. An equivalent level of safetywill be achieved given the size,weight, speed, and material with which the MultiRotor is built. Flight operations will not occur without the permission ofthe land owner/authorized agent or thosewho control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe unmanned flight operations. Compared to aerial survey operations conducted with aircraft or rotorcraft carrying flammable fuel, any risk associatedwith these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. The low-altitude operations of the UAS will maintain separation between these small-UAS operations and the operations of conventional aircraft that must complywith Section 91.119.
The ideal altitude for the projects proposed within this requestwill be at or below 400 feet above ground level and standard operational procedureswill provide for a constant airspace awareness to allow for maximum separation between small UAS operations and operations ofconventional manned aircraft. Additionally, SkyVue operators and observerswill display appropriatewarning signage on all perimeters of surrounding propertywhile UAV operations are in progress. SkyVue believes exemption from 14 CFR 91.119(c) should be granted, as an equivalent level of safety will be achieved.

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft
The regulation requires that any person to operate a U.S.-registered civil aircraft “[...] (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, 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.”
Given the size ofthe MultiRotor, it 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 achieved by keeping the flight manual (Supplemental Information, Part A) at the ground control pointwhere the pilot flying the UAS will have immediate access to required flight manual documentation. SkyVue believes exemption from 14 CFR 91.9(b)(2) should be granted, as an equivalent level ofmarking and documentation will be achieved.8 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email: greg@skyvueap.com
14 CFR 91.109(a) &91.319(a)(1): Flight Instruction These regulations provide 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. In operational configuration, the MultiRotor is a remotely piloted aircraft and does not have fully functional dual controls. Flight control is accomplished through the use of a control box or ground control station that communicates with the aircraftvia line-of -sight radio communications. The flight plan is pre-programmed into the autopilot before or during flight and may also receive manual pilot input control functions to alter the pre-programmed flight. If instruction is accomplished through a training program, as set forth in Part C ofthe Supplemental Information, an equivalent level ofsafety will be assured. The FAA has approved exemptions for flight trainingwithout fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft (5778K &9862A). The equivalent level ofsafetywill be achieved by the manufacturer providing the training and through the use of experienced and qualified pilots familiarwith the MultiRotor. SkyVue believes exemption from 14 CFR 91.109(a) &91.319(a)(1) should be granted.

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a) [...] no person may operate a civil aircraft unless it has [...] 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 MultiRotor when fully configured for flight operationsweighs no more than 25 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot on board the aircraft.
An equivalent level of safetywill be achieved by keeping these documents at the ground control point where the pilot flying the UASwill have immediate access to them.The FAA has issued numerous exemptions to this regulation. SkyVue believes exemption from 14 CFR 91.203 (a) & (b) should be granted, as the regulation is not applicable to its MultiRotor UAS.9 | P a g e 151 Hamilton Rd, Tinton Falls, New Jersey 07724-9718 Phone: 732 735 3160 • Email:

greg@skyvueap.com 14 CFR 91.121: Altimeter settings
Section 91.121 requires aircraft operators to maintain cruising altitude or flight level by reference to an altimeter. As the MultiRotor UAS utilizes Global Positioning System and internal redundant barometric altimeters flight levelwill be determined using this type ofinstrumentation. SkyVue believes exemption from 14 CFR 91.121 should be granted, as the regulation is not applicable.

14 CFR 91.151(a)(1): Fuel requirements for flight in VFR conditions
Due to the MultiRotor UAS being battery powered, SkyVue believes exemption from 14 CFR 91.151(a) (1) should be granted, as the regulation is not applicable.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)(b): Maintenance Requirements Section 91.405(a) requires 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 [...]” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. SkyVue has prescribed a specific process and inspection standard that will allow an equivalent level of safety to be achieved as a result ofdiligent and consistently applied maintenance practices. The aircraft operator is responsible for accurate status upkeep ofthe maintenance record to include the battery maintenance log, ensuring the UAS is in safe condition for flight operations, and ensuring all software is current prior to aircraft operation.Through this, SkyVue believes exemption from the listed regulations should be granted.
Summary SkyVue believes that approval from the FAA will enhance efficiency and safety in any operation its MultiRotor UAS conducts, due to reducing the need for manned aircraft. Due to its camera-only payload capability, lack of cargo, fuel or combustible materials in general, aircraft size,weight, and limited operating area, the MultiRotor UAS presents no major risk to individuals, nor poses any threat to National Security.While adhering to at least an equivalent level of safety ofall current regulations, SkyVue firmlybelieves exemptions to the listed regulations should be granted, and operation ofits MultiRotor UAS commercially should be permitted.