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 

Docket Management System-FDMS)

Re: Request for Exemption under section 333 of the FAA Reform Act 

Summary of Exemption Request 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 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, if granted, 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 of the 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, as well as an immediate 

environmental benefit. 

Operation under the anticipated exemption will be subject to strict conditions and requirements, ensuring 

at minimum, an equivalent level of safety 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: Production Acceptance & Technical Specifications of the 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 of Manned and Unmanned Experience & Certifications

Background of Applicant 

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 of worldwide 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 of approximately 2 pounds 11 ounces, while 

having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of 

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length 

of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 

knots. The DJI S900 maximum gross 18 pounds. Diagonal Wheelbase of 35.4 inches, height of 20 

inches and a maximum speed of 35knots .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 of Aircraft, 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 clearly visible 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 in which people are not made 

aware and consent to unmanned operations will cause unacceptable safety risk and will not operate 

within these conditions. If granted 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 strobe
4 | 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, 

maintaining visual line of sight, 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 of all aforementioned skill areas, with special emphasis on emergency 

procedures. 

UAS Safety Observer

SkyVue requires every person who 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. 

Authority for Petition

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 of Transportation “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 of a regulation prescribed under subsection (a) or (b) of this section or any 

of sections 44702-44716 of this title if the 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 and weight of the 

MultiRotor aircraft (25 lbs) and the limited operating area associated with its utilization, it is unnecessary 

to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed 

current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act 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 UAS 

involved. 

In this case, an analysis of these criteria demonstrates that the MultiRotor operated without 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 exclusively within an area pre-disclosed and in compliance with conditions set forth herein. 

Operations under this exemption will be tightly controlled and monitored by both 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 of flammable fuel, and the fact that the aircraft is carried to the 

location and not flown there all establish the equivalent level of safety. 

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

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

 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 of marks; 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 number which 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 accordance with 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 only with permission from landowner

 Display appropriate warning signage on all borders of property during operation

 Maintain high level UAS airmanship skillset via SkyVue specified currency & training 

requirements

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

 As operation of UAS is fundamentally different than manned aircraft, the current level of air and 

ground instruction of all 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 of the proposed 

unmanned aircraft operations as no carrying of persons or property will 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 for validating airworthiness condition of the MultiRotor aircraft, 

SkyVue will abide by internal company process documentation to validate operational functionality 

which will achieve an equivalent level of safety by ensuring compliance with 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 

any person, vessel, vehicle, or structure. 

An equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

MultiRotor is built. Flight operations will not occur without the permission of the land owner/authorized 

agent or those who control the land. Because of the advance notice to the landowner, all affected 

individuals will be aware of the unmanned flight operations. Compared to aerial survey operations 

conducted with aircraft or rotorcraft carrying flammable fuel, any risk associated with 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 comply with Section 91.119. 

The ideal altitude for the projects proposed within this request will be at or below 400 feet above ground 

level and standard operational procedures will provide for a constant airspace awareness to allow for 

maximum separation between small UAS operations and operations of conventional manned aircraft. 

Additionally, SkyVue operators and observers will display appropriate warning signage on all perimeters of 

surrounding property while 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) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 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 of the 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 point where 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 of marking 

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 aircraft via 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 of the Supplemental Information, an equivalent level of safety 

will be assured. 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 (5778K & 9862A). 

The equivalent level of safety will be achieved by the manufacturer providing the training and through 

the use of experienced and qualified pilots familiar with 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 operations weighs 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 safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will 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 level will be determined using this type of instrumentation. 

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 of an air worthiness 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 of diligent and consistently applied maintenance practices. The aircraft 

operator is responsible for accurate status upkeep of the 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 of all current regulations, 

SkyVue firmly believes exemptions to the listed regulations should be granted, and operation of its 

MultiRotor UAS commercially should be permitted.