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 Secti on 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 conduct the following high qualit y imaging for various private, public and commercial uses; specifically targeting : Description of Proposed Operations High resolution a erial mapping, inspections and photography providing :

● Agricultural: Crop Health Monitoring, Mapping , and Crop H ealth I nspections

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

● Cinematography & Videography

● I nsurance : Crop, Construction, Roof and Building I nspections

● 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: Airwo rthiness 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 Airc raft 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 Set tings

● 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 InspectionsI. Petitioner’s Description

SkyPics LLC consists of a team of sUAS enthusiasts and entrepreneurs, founded to revolutionize the monitoring and inspection proce ss by providing faster, safer and cost

- effective aerial 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 @ SkyPics LLC .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 airsp ace 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 cap ability;

● Operation of the UAS in close proximity to air ports 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 t he 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 Ac t. Each of the statutory criteria and other potentially relevant factors are satisfied. The requested exemption would permit SkyPics to 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 theSecretary of Tra nsportation’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.

E ach sUAS weighs 55 lb. or less, including payload. These sUAS ’ operate under normal conditions at a speed of no more than 87 knots. SkyPics sUAS operations will be conducted below an altitude of 400 ft. AGL, within unpopu lated 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 ha zard 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 witho ut 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 commer cial 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 per forming 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 app licable 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. More over, SkyPics’ operating documents incorporate redundan t 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 comm ercial 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 a pproval.

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 SkyPics sUAS used by the company will be U.S. registered and display marks either in accordance with 14 CFR Part 45, Subpart C or approve d 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 w ill 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 jurisdictio ns, 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 SkyPics sUAS and have obta ined 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 s afe 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 w ill 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, a ltitude, 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, Subpar t 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 (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

popu lated 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,

car ry 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 complian ce 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 thre at 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): Airc raft 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 P lacard 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 mor e 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 thes e 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

- numbe r 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 C ertificate, 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 ce rtificate. 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 ca se, 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 adequa te 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 b e qualified to serve as the PIC for UAS operations ( See Grant 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 impos ed on Astraeus Aerial and other operators in more recently granted exemptions
under Sectio n 333 of the FAA Reform Act. SkyPics will operate away from persons and property
that is not the s ubject 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 co mmercial flights on behalf of SkyPics . The pilot qualification, training, and currency requirements in the operating documents ensure t hat 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, SkyPics seeks 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 exe mption 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) i s 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 combin ation 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 o perate 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, registrat ion 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 Flig ht 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 equivale nt 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 placardrequirements 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 th at 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 a reas

— 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 fl ight 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 U AS, 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 environmen t. 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 PI C 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 fuelwith the UAS, any risk associated with t hese 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 or der 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 lea st 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 saf ety 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). Adher ence 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 re layed in real time to the operator at a ground

- based on

screen 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 p erforming 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 appr opriate.



### 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 f ly 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 t hose 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

u nless (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 V FR conditions is therefore appropriate.



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

SkyP ics seeks 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 inspect ed 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 airc raft 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 docu ments 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 compo nents. 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 con dition 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 aircr aft 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 procedu res 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 inspectionprocedures r equired 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

Con gress' 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 be tter 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 Exe mption.

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 1 4 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 CF R 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 r espects to those presented by SkyPics in this Petition for Exemption. In con sideration 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 Your s,

Robert J. Ravlin
President SkyPics LLC