November 2, 2015 Robert Ravlin

President

SkyPics LLC

111 Sunset Circle

Underwood, IA 51576

(402) 630-9001

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Ave., SE, 

Washington, DC 10590 

Re: SkyPics LLC Petition for Exemption Pursuant to Section 333 of the FAA Reform Act & 14 CFR Part 11 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 CFR 

Part 11, SkyPics LLC (“SkyPics”) hereby petitions the FAA for exemption from certain Federal Aviation 

Regulations (FARs) to conductthe following high quality imaging for various private, public and 

commercial uses;specifically targeting:

Description of Proposed Operations 

High resolution aerial mapping, inspections and photography providing:

● Agricultural: Crop Health Monitoring, Mapping, and Crop Health Inspections

● Utility Monitoring & Inspection: Power Line, Bridge, Wind Tower, Solar, Pipeline

● Cinematography& Videography

● Insurance: Crop, Construction, Roof and Building Inspections

● Marketing: Real Estate, Advertising & Newsgathering

● Geological: Land Surveying, Mining

SkyPics, therefore, seeks exemption from the following FARs identified below, so long as such 

operations are in accordance with the conditions and limitations outlined by the FAA under Section 333: 

● 14 CFR Part 21, Subpart H: Airworthiness Certificates 

● 14 CFR 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

● 14 CFR 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport 

Pilot Medical Certificate, Privileges and Limitations 

● 14 CFR 91.7(a): Civil aircraft airworthiness

● 14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 CFR 91.203(a) & (b): Carrying 

Civil Aircraft Certification and Registration

● 14 CFR 91.103: Preflight Action

● 14 CFR 91.109: Flight instruction.

● 14 CFR 91.119(c): Minimum Safe Altitudes Over Other Than Congested Areas

● 14 CFR 91.121 Altimeter Settings

● 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

● 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 
I. Petitioner’s Description

SkyPics LLC consists of a team of sUAS enthusiasts and entrepreneurs, founded to revolutionize the 

monitoring and inspection process by providing faster, safer and cost-effectiveaerial solutions for 

commercial, public and private markets.

This section responds to the specific requirements of 14 CFR Sec 11.81 to provide mailing address and 

other contact information such as a fax number, telephone number, or email address copy. 

SkyPics LLC

Robert Ravlin

111 Sunset Circle

Underwood, IA 51576

Email: Bob@SkyPicsLLC.com

Phone: (402) 630-9001

II. Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the Reform Act. 

Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems 

into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is 

to permit unmanned aircraft systems to operate in the NAS where it is safe to do so based on the 

following considerations: 

● 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 the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) 

(permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) 

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing 

rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

III. Qualification for Approval under Section 333

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 

of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. The 

requested exemption would permit SkyPicsto perform commercial operations under controlled 

conditions in airspace that is 1) limited 2) predetermined 3) restricted, limited, or controlled as to access 

and 4) would provide safety enhancements to the already safe operations in these industries presently 

using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 
Secretary of Transportation’s responsibilities to “...establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. 

SkyPics sUAS’ include:

Rite Wing Drak, Zeta Science Phantom FX-61, Skywalker X5 & X8, Ehang’s Ghost Basic & Ghost Aerial, 

Yuneec Typhoon 4K, Yuneec Tornado H920, Aeryon Skyranger, senseFly eBee, PrecisionHawk Lancaster, 

DJI Inspire 1, DJI Phantom 2 Vision+, DJI Phantom 3, DJI Spreading Wings S900, DJI Spreading Wings 

S1000.

Each sUAS weighs 55 lb. or less, including payload. These sUAS’ operate under normal conditions at a 

speed of no more than 87 knots. SkyPicssUAS operations will be conducted below an altitude of 400 ft. 

AGL, within unpopulated and secured areas, either within Class G airspace or with the permission of 

ATC. sUAS operated by SkyPics will also be conducted within visual line of sight of the operator and 

observer. Such operations will ensure that the sUAS will “not create a hazard to users of the National 

Airspace System or the public” as per the FMRA 2012 Section 333. Given the size of the sUAS and the 

operating environment, this petition for exemption meets 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 and environment, approval of the application presents no 

national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit described herein, the grant of the requested exemptions is also in the public 

interest. 

The FAA has issued grants of exemption in circumstances similar in all material respects to those 

presented in this petition, specifically Exemptions No. 11062, 11109, 11112, 11213 and 11290; and we 

therefore request that our petition be granted without delay. 

IV. Description of Proposed Operations

SkyPics seeks an exemption pursuant to Section 333 of the Reform Act to use a number of different 

sUAS platforms for aerial data collection in support of its commercial operations. 

All of the sUAS platforms SkyPics intends to use have been approved for commercial use in other grants 

of exemption. The FAA has previously determined that these vehicles meet the criteria established in 

Section 333 of the Reform Act and are suitable platforms for performing aerial data collection.

SkyPics is committed to maintaining the highest standards of flight safety. All sUAS operations will be 

performed in accordance with the SkyPics operating documents, and in accordance with the 

requirements of an applicable COA. Among other things, and as detailed in the operating documents, all 

sUAS operations will occur in uncontrolled airspace, within visual line-of-sight (VLOS) of the pilot and 

visual observer, and will be limited to daytime VFR conditions. Moreover, SkyPics’ operating documents 

incorporate redundant safeguards to enhance safety.

The proposed operations in this Petition for Exemption are not new or novel to the FAA. The FAA has 

previously issued multiple grants of exemption to use small UAS for aerial data collection in support of 

similar commercial and research activities.
The low-risk UAS operations proposed by SkyPics in this Petition for Exemption fall squarely within the 

category of aerial data collection that has been subject to previous approval. 

As a sUAS / drone service provider, SkyPics needs to be able to conduct continuous RD&T flights to 

better our products, services and troubleshoot any issues discovered through our operations. 

● The sUAS will weigh less than 55 lbs. 

● Flights will be operated within line of sight of a pilot and/or observer. 

● Flights will occur during daylight hours. 

● Flights will occur during Visual Flight Rules Meteorological Conditions (VMC). 

● Flights will be operated at an altitude of no more than 400 feet AGL and within Class G airspace. 

Operations in controlled B, C, or D airspace will be conducted in coordination with the proper 

FSDO and ATC with prior permission. 

● Flights will be terminated at 25% battery power reserve or when voltage is less than 10.6V 

should that occur during the operation. SkyPics’ app will push notice and recommend returning 

at less than 30%. 

● All SkyPicssUAS used by the company will be U.S. registered and display marks either in 

accordance with 14 CFR Part 45, Subpart C or approved alternative markings. 

● Operations will only be conducted in confined areas and over property authorized for such use. 

Most operations will be conducted within the limitations of the blanket COA authorization, 

including below 200 feet AGL. 

● The operator will obtain the consent of all persons involved and ensure that only consenting 

persons will be allowed within close proximity to the flight operation.

● 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. 

● A briefing will be conducted prior to each day’s activities for all personnel who will be 

performing duties for these operations. 

● Minimum crew for each operation will consist of the sUAS Pilot and a Visual Observer. 

● 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 (i.e. the Visual Observer), that 

person can also be designated as the PIC. 

● The PIC must have passed at least a sport pilot certificate and hold a valid U.S. driver’s license 

unless changed by future sUAS FAA Regulations. 

● PIC and VO will have been trained in operation of SkyPicssUAS and have obtained all new 

required information on the particular UAS to be operated. 

● Observer and PIC will at all times be able to maintain verbal communication, either directly or 

through electronic means. 

● Operators will maintain the sUAS system in a condition for safe operation according to SkyPics

manuals, including pre-flight and post-flight inspections. 

● If the sUAS loses communications or loses its GPS signal, the UAS will have the capability to 

return to a pre-determined or safest location and land. 

● The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. SkyPics drones are able to see real time flight data including settings, flight mode, 

bluetooth, “heartbeat”, number of satellites, battery level, flight distance, altitude, speed, and 

flight time allowing the pilot to have situational awareness of any issues. 
V. Regulations from Which Exemption is Requested 

14 CFR Part 21, Subpart H: Airworthiness Certificates

Given the size and limited operating area associated with the aircraft to be utilized, 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 (49U.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 a 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 are less than 55 lb. fully loaded, carry neither a pilot nor passenger, 

carry no explosive materials or flammable liquid fuels, and operate within a controlled area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

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

provide security for the area of operation as is now done with conventional aircraft. These safety 

enhancements, which already apply to civil aircraft operated in connection with related applications, 

provide a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national security posed by the 

sUAS, 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. 

14 CFR 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

SkyPics seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard Requirements, provides 

that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

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. 

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 
Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by § 45.23. 

In prior grants of exemption under Section 333 of the Reform Act, the FAA determined that exemption 

from these requirements was warranted provided that the aircraft "have identification (NNumber) 

markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable. (FAA 

Docket No. FAA-2014-0352) All UAS flown by UI will bear N-number markings that are as large as 

practicable in accordance with 14 C.F.R. Part 45, Subpart C (See, e.g., FAA Docket No. FAA-2014-0352, at 

14). 

14 CFR 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport 

Pilot Medical Certificate, Privileges and Limitations 

SkyPics seeks exemption from these sections, which restricts private, recreational or sport pilot 

certificate holders from flying aircraft for compensation or hire, and would also require a second 

class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of 

any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications 

if the private pilot is carrying passengers or cargo for hire. In this case, while the UAS will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. 

In the Grant of Exemption No. 11062 to Astraeus Aerial (FAA Docket No. FAA-2014-0352), the 

FAA determined that the unique characteristics of UAS operation outside of controlled airspace 

did not warrant the additional cost and restrictions attendant with requiring the PIC to have a 

Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment of the additional 

requirements for a private pilot to become qualified as a commercial pilot would not lead to any 

additional safety benefits when UAS operations are involved.

More recently, the FAA determined that holders of recreational and sport pilot certificates would 

also have adequate aeronautical knowledge to pilot a UAS. Accordingly, because these 

individuals would also be subject to security screening by the Department of Homeland Security 

(DHS), the FAA determined that holders of recreational and sport pilot certificates would be 

qualified to serve as the PIC for UAS operations (SeeGrant of Exemption No. 11213 to Aeryon 

Labs, Inc. (Docket No. FAA-2014-0642 at pgs. 8-9).

The restrictions Petitioner has placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial and other operators in more recently granted exemptions 

under Section 333 of the FAA Reform Act. SkyPics will operate away from persons and property 

that is not the subject matter of the flight. SkyPics will also require all PICs to be thoroughly 

trained in the unique aspects of UAS flight. As set forth in the operating documents, pilots will 

have experience not only in UAS operations generally but have logged flight time in the specific 

make and model used for the operations before they are permitted to participate in commercial 

flights on behalf of SkyPics. The pilot qualification, training, and currency requirements in the 

operating documents ensure that SkyPics’ pilots are competent and proficient in the UAS they 

are operating. The Petitioner's training and qualification requirements are consistent with those 

contained in prior FAA-issued grants of exemption, and will provide a higher level of competency 

and proficiency for its pilots and will ensure at least an equivalent level of safety. 
14 CFR 91.7(a): Civil aircraft airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS, SkyPicsseeks an exemption 

from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be operated. 

While the petitioner’s UAS will not have an airworthiness certificate, the FAA has determined that for 

the purposes of this exemption the pilot may determine the aircraft is in an airworthy condition prior to 

flight. The operating documents contain procedures which allow the PIC to determine whether the 

aircraft is in a condition safe for flight, and an exemption from § 91.7(a) is therefore warranted. 

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 CFR 91.203(a) &

(b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft –... 

(2) For which an Airplane or Rotorcraft Flight Manual is 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. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(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. 

Given the small size and configuration of the UAS, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and 

the UAS has no cabin or cockpit. 

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, 

Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met 

if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and 

other required documents from the ground control station from which he or she is operating the aircraft 

(Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-

0352 at 16-18.). As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure 

the pilot has access to these key documents during flight. Therefore, an equivalent level of safety will 

be achieved by ensuring that the pilot has access to the documents at the ground control station from 

which he or she is piloting the UAS. See also Exemption No. 11213 to Aeryon Labs, Inc. at pg. 11: The 

petitioner requested relief from 14 CFR § 91.9(b)(2): Civil aircraft flight manual, marking, and placard 
requirements and § 91.203(a) and (b): Civil aircraft: Certifications required. The FAA has previously 

determined that relief from these sections is not necessary. See Exemption No. 11062. Relevant 

materials may be kept in a location accessible to the PIC in compliance with the regulations. 

14 CFR 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is 

required. 

Adherence to the requirements in the operating documents will ensure that the UAS is in an airworthy 

condition prior to flight. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components, which cover pre-flight, take-off, landing and post-flight procedures. The PIC 

will also be required to review weather, flight requirements, battery charge, landing and takeoff 

distance, UA performance data, and contingency landing areas—before initiation of flight. Petitioner's 

operating documents will be kept at the ground control station and will be accessible to the PIC at all 

times while operating the UAS. 

14 CFR 91.109: Flight instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

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." UAS and remotely pi loted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through the 

use of a device that communicates with the aircraft via radio communications. Accordingly, an 

exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a). 

Given the size and speed of the UAS that Petitioner intends to use, an equivalent level of safe training 

can still be achieved without dual controls because no pilot or passengers are aboard the UAS, and as 

required by the operating documents, all persons will be a safe distance away in the event that the UAS 

experiences any difficulties during flight instruction. Moreover, all flight training will be conducted in 

controlled and sterile environment. As a whole, the procedures provided for in the operating 

documents ensure that UAS flight instruction can be performed safely. 

14 CFR 91.119(c): Minimum Safe Altitudes Over Other Than Congested Areas

UI requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). 

An exemption is required because the proposed UAS operations will normally need to occur below 400 

feet AGL. Additionally, due to the nature of the proposed operations, the PIC and/or Observers may 

need to be less than 500 feet away from the UAS. Compared to flight operations with rotorcraft 

weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel 
with the UAS, any risk associated with these operations is far less than those that presently exist with 

conventional aircraft. 

An equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well the 

controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight 

operations will be restricted to below 400 feet AGL. As set forth in the operating documents, the UAS 

will be operated in a controlled environment, and all flights will occur at a lateral distance of at least 500 

feet from nonparticipating persons, unless that person is in a position where he or she is shielded from 

the UAS and any possible debris resulting from UAS failure. Procedures will be in place to ensure flight 

operations can be safely terminated if a nonparticipating person within 500 feet of the UAS leaves a 

shielded position. Further, UAS operations will occur at least 500 feet away from vehicles or structures 

unless the property owner/controller has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects, and operations near the PIC or Observer will not present 

an undue hazard per § 91.119(a). Adherence to these restrictions in SkyPics’ operating documents will 

ensure the proposed operations can be conducted without compromising safety to persons or property 

on the ground. 

14 CFR 91.121: Altimeter Settings

To the extent necessary for SkyPics to conduct the proposed operations, Petitioner requests an 

exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising 

altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. 

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be 

achieved in circumstances where: (1) the UAS will be operated 400 feet AGL or below, (2) within VLOS, 

(3) where GPS based altitude information is relayed in real time to the operator at a ground-based onscreen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC 

to confirm accuracy of the onboard GPS. 

The UAS that Petitioner intends to use for performing the proposed operations meet all these 

operational characteristics. Moreover, the operating documents require the PIC to calibrate the 

aircraft's GPS compass prior to each flight operation. As the FAA has determined in circumstances 

similar to this Petition for Exemption, Petitioner's UAS and the safety mitigation procedures contained in 

the operating documents, ensure that an equivalent level of safety will be achieved, and a grant of 

exemption to the requirements of § 191.121 is therefore appropriate. 

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

SkyPics requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: 

(a) No person may begin 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. 

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required. 

The FAA has previously granted relief from the fuel requirements of § 91.151(a) for flight in daytime VFR 

conditions in circumstances similar to those presented in this Petition for Exemption (See e.g., 

Exemption Nos. 8811, 10808, and 10673). In Exemption No. 11213 to Aeryon Labs, Inc., (Docket No. 

FAA-2014-0642) the FAA determined that a requirement prohibiting the PIC from beginning a UAS flight 

unless (considering wind and forecast weather conditions) there was enough available power for UAS to 

operate for the intended operational time and to operate after that for at least five minutes or with the 

reserve power recommended by the manufacturer if greater, would ensure an equivalent level of safety

to the fuel requirements of § 91.151(a) (Exemption No. 11213 at pg. 12). Petitioner's operating 

documents impose this same requirement and an exemption from § 91.151(a)'s fuel requirements for 

flight in VFR conditions is therefore appropriate. 

14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

SkyPicsseeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. Part 43-See, e.g., 14 C.F.R. § 91.405(a) (stating that 

each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 

of this chapter."). An exemption from these regulations is needed because Part 43 and these sections 

only apply to aircraft with an airworthiness certificate, which the UAS to be operated under this grant of 

exemption will not have. 

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

in accordance with the operating documents and any required manufacturer Safety or Service Bulletins. 

Further, as required by the operating documents, the PIC will conduct a pre-flight inspection of the UAS 

and all associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe 

operation of the UAS and no flights will occur unless, and until, all flight critical components of the UAS 

have been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight-critical components. As required by the operating 

documents, the PIC who conducts the functional test flight will make an entry in the UAS aircraft records 

of the flight. 

The operating documents also include requirements to follow the UAS manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 

Moreover, the operating documents also include procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of Petitioner's UAS. As a whole, the maintenance and inspection 
procedures required by Petitioner's operating documents ensure that an equivalent or higher level of 

safety will be achieved. 

VI. Public Interest

The public interest will be served by granting SkyPics’ Petition for Exemption. Congress has established 

a national policy that favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking. 

Beyond increased levels of safety, the public stands to benefit enormously from the commercial, 

programs supported by the proposed operations in this Petition for Exemption. Whether it is studying 

the best ways to monitor our aging infrastructure, or researching ways for farmers to produce better 

crops in a more sustainable and environmentally conscious manner, the public as a whole will benefit 

from the information gathered and studied as part of the education and research programs supported 

by the proposed operations in this Petition for Exemption. 

VII. Privacy

The proposed operations will be conducted in accordance with applicable federal, state, or local laws 

regarding privacy. All flights will occur over private, limited, or controlled access areas with the property 

owner’s prior consent and knowledge. Operations will be conducted by trained personnel and all other 

individuals will either be a part of the operation or consent to be present at the time of operations. 

VIII. Federal Register Summary 

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 in Title 14 of the Code of Federal Regulations:

 

14 CFR Part 21, Subpart H: 14 CFR 91.9(c), 45.23(b) and 45.27(a): 14 CFR 61.23(a) and (c), 61.113, 

61.101(e)(4) and (5), 61.315; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); CFR 91.203(a) & (b); 14 CFR 91.103; 14 

CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405 (a); 407 (a) (1); 409 (a) 

(2); 417(a) & (b)

IX. Conclusion

The proposed operations in this Petition for Exemption satisfy the criteria articulated in Section 333 of 

the Reform Act and the FAA has issued grants of exemption in circumstances similar in all respects to 

those presented by SkyPicsin this Petition for Exemption. In consideration of the foregoing, SkyPics 

respectfully submits that this Petition for Exemption qualifies for expedited approval via the FAA's 

summary grant process.
We thank you for your prompt consideration of our requested exemptions. Should you have any 

questions, or if you need additional information to support the requested exemptions, please do not 

hesitate to contact us.

Very Respectfully Yours, 

Robert J. Ravlin

President

SkyPics LLC