205 W. Sophia St, Maumee, OH 43537

EiSkys@outlook.com 419-891-1183

Docket Management System

U.S. Dept. of Transportation

1200 New Jersey Ave., SE

Washington, D.C. 20590

February 4, 2016

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam,

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 

11, Eye in the Sky Surveyors, LLC, operator of Small Unmanned Aircraft Systems (sUASs) equipped to 

conduct aerial photography for the media and advertising industries for pre-planned, controlled area, 

photographic and surveying services, music videos, corporate videos, still photography, short range 

inspection, mapping, and agriculture and conservation-supporting scientific data collection services 

hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

operation of its sUASs, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by 

§333. 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive multirotor aircraft under controlled conditions in airspace that is 

1) contained 2) predetermined 3) has on-site safety personnel controlling access, and 4) would provide 

increased safety and enhancements to clients' business operations.

The name and address of the applicant is Eye in the Sky Surveyors, LLC 205 W. Sophia St, 

Maumee, Ohio 43537 Ph: 419-540-2520 Email: EiSkys@outlook.com

Eye in the Sky Surveyors, LLC will be utilizing the DLI Inspire 1 and DLI Phantom 3 Professional 

model UAS’s. 

Eye in the Sky Surveyors, LLC respectfully requests a grant of an exemption of the following 

sections of Title 14 of the Code of Federal Regulations:

 14 CFR 21;

 14 CFR 91, et seq.;

 14 CFR 45.23 (b);

 14 CFR 61.113 (a) & (b);

 14 CFR 407 (a)(l);
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 14 CFR 409 (a)(2);

 14CFR417(a)&(b).

Eye in the Sky Surveyors, LLC also respectfully requests an Exemption from Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation Regulations from:

• 14 CFR 45.23(b);

• 14 CFR Part 21;

• 14 CFR 61.1 13 (a) & (b);

• 91.7 (a);

• 91.9(b)(2);

• 91.103(b);

• 91.109;

• 91.119;

• 91.12 1;

• 91.151(a);

• 91.203(a) & (b);

• 91.405 (a);

• 91.407 (a) (1 );

• 91.409 (a) (2);

• 91.417 (a) & (b).

I. The Extent of Relief Eye in the Sky Surveyors, LLC Seeks and the Reason It Seeks Such Relief:

Eye in the Sky Surveyors, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 

§§331-334, seeking relief from any currently applicable federal aviation regulations FARs pertaining to 

UASs (unmanned aircraft systems) and operating to prevent Eye in the Sky Surveyors, LLC contemplated 

commercial photographic, mapping, and other flight operations within the U.S. national airspace 

system.

The Reform Act in §332 provides for such integration of civil UASs into our national airspace 

system as it is in the public's interest to do so. Eye in the Sky Surveyors, LLC's lightweight UASs meet the 

definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record 

in similar industries, Eye in the Sky Surveyors, LLC's light duty UASs are ideal recipients of exemption by 

the intent of the Reform Act.

Considerations for relief include a combination of sUAS physical characteristics, safety features, 

and safe practices identified in §333:

• sUAS weight,

• sUAS overall size,

• sUAS speed over ground,

• sUAS flight zone characteristics,
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o Non-operation near airports (civilian or military),

o Tightly controlled operation in populated areas,

• Operation of the UAS by VLOS.

• Coordination by a minimum of 2 persons, all staff members of Eye in the Sky Surveyors, LLC .

Specific consideration is outlined below.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1 ). Given the 

size and limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal 

Aviation Act (49 U.S.C.§4470 1 (f)) and §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 sUAS. In all cases, 

an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in 

the restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed.

The sUAS to be operated by Eye in the Sky Surveyors, LLC is less than 11kg. With maximum 

payload consisting of remote sensing instrumentation, carries no persons, carries no explosive or 

flammable materials including combustible fuels, and operates exclusively within a secured area. Unlike 

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

pilot (PIC), 'spotter' role designated to act as both the remote sensing controller and secondary monitor 

for safety issues, and a technician, which assists in matters related to maintaining the sUAS and also 

monitors for safety concerns and liaisons to the on-site safety officials. These enhancements to current 

safety practices and regulations, which already apply to civil aircraft, provide a greater degree of safety 

to the public and property owners than conventional aircraft operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to its 

size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load.

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

The regulation requires: 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.
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Even though the sUAS will have no airworthiness certificate, an exemption may be needed as 

the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" 

can be placed. Given the size of the sUAS, two-inch lettering will be impossible. 

The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size 

suitable for the available space.

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

Further markings include the use of flashing LED illumination on the underside of the sUAS 

frame which stands at contrast against a blue or white sky.

14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

§61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a 

pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring a ground crew member operator to have an sport pilot, recreational pilot , 

private, commercial or airline transport pilots license rather than a just a commercial pilot's license to

operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no persons on board. The area of operation is controlled and restricted, and all 

flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are 

so diminished from the level of risk associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations as requested with a sport pilot certificate or better in the ground 

crew exceeds the present level of safety achieved by 14 C.P.R. §61.1 13 (a) & (b).

14 C.P.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, 

a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be 

provided.

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

§91.9 (b) (2) provides: No person may 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.

The sUAS, given its size and configuration has no ability to carry a physical flight manual on the 

aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the 
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following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565, 95658, 

10167, 10167A, 10602,32827, and 10700.

14 C.F.R. §91.103: Preflight action

This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight. Further, we have 

proprietary manuals created with the help of sUAS experts, the manufacturer, the regional sUAS vendor 

and policy holding insurer and continue to work with these organizations to ensure best safe practices 

are adhered to.

14 C.P.R. §91.1 09: Flight instruction

§91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely 

piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The 

equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inherent in the 

remote controls utilizing digital communications which is paired to the sUAS making it nearly impossible 

to unintentionally or intentionally have the control communications interrupted.

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

§91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that 

closely mimics the behavior of a helicopter, and the exemption requests authority to operate at 

altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, the 

UAS will never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is 

closer. It will however be operated in a restricted area with security officials tasked with ensuring public 

safety, and where buildings and people will not be exposed to operations without their pre-obtained 

consent and training.

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

the location where it is operated. No flight operation will be taken without the permission of the 

property owner in the case of private property or local officials in the case of public property or private 

property with public interests. Because of the advance notice to the property owner and participants in 

the remote sensing activity, all affected individuals will be aware of the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 11kg of 
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Eye in the Sky Surveyors, LLC's sUASs proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small- UAS operations and the operations of conventional aircraft that must 

comply with §91.119.

14 C.F.R. §91. 121 Altimeter Settings

§91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS 

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

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

The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee 

accurate detection of height.

14 C.F.R. §91.15l (a): Fuel Requirements for Flight in VFR Conditions

§91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes:' The battery powering the sUAS 

provides approximately 15 minutes of powered flight in hover mode without payload. Eye in the Sky 

Surveyors, LLC's sUAS will not be able to meet the 30 minute reserve requirement in 14 CPR §91.15 1. 

Operating the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve power, 

does not engender the type of risks that Section 9l.l51(a) was intended to alleviate given the size and 

speed of the small UAS. Eye in the Sky Surveyors, LLC believes that an equivalent level of safety can be 

achieved by limiting flights to » 10 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate to return the sUAS toils planned landing zone from anywhere

in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

14 C.P.R. §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91. 715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew.
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The sUAS fully loaded weighs no more than 11kg and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them on 

the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 

10700.

14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 4 17(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ;' and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An 

equivalent level of safety will be achieved because these small UASs are very limited in size and will 

carry a small payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The 

operator will ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

An exemption granted to Eye in the Sky Surveyors, LLC would permit its operation of 

lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited 

airspace. Eye in the Sky Surveyors, LLC utilizes local business' safety officers in specifically determined 

areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goals. 

Technical enhancements to current safety controls will allow Eye in the Sky Surveyors, LLC to operate 

exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the 

FAA and Department of Transportation. Further, Eye in the Sky Surveyors, LLC conducts its operations in 

compliance with protocols described herein or as otherwise established by the FAA.

II. Commercial and Public Benefits

We at Eye in the Sky Surveyors, LLC believe that granting this exemption request furthers the public 

interest by providing safe (by way of an unmanned system) and efficient means to meet technical 

problems solvable by elevated data collection instruments. Eye in the Sky Surveyors, LLC's client base 

are typically be small to medium sized business' looking to increase their awareness of structures or 

landscape on their respective properties through data collection by photographic, videographic or LIDAR

based surveying. By moving these functions onto sUAS based aircraft, the potential for loss of life or 

property is diminished due to the greater control in a smaller and safer aircraft that holds no persons. 

Second, there are no reactive or combustible materials on board the sUAS and thus the potential for fire 

or explosions is greatly diminished. Third, the small size and extreme maneuverability of Eye in the Sky 
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Surveyors, LLCs UASs allow the PIC to avoid hazards. Lastly, due to the nature of the remote sensing 

instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and the

object(s) undergoing scrutiny. Accordingly, Eye in the Sky Surveyors, LLC's UASs will operate at and 

above current safety levels.

A. The costs and benefits of your proposed action to society in general and specific groups within 

society

As described above, Eye in the Sky Surveyors, LLC's customers will be small to medium business seeking 

a remote sensing solution to specific issues before a larger effort on their part would come underway. 

Examples include construction efforts that sought elevated photographic imagery of specific landforms 

to minimize cost of efforts to develop, a regional park service that wanted to quantify the changing 

lifecycle of its flora by way of measuring leaf health through gradual chlorophyll depletion, or a local 

cities' Dept. of Public Works that seeks to collect images and 30 structural data by way of Lidar sensing 

en masse of its bridges to serve as a supplement to its routine repair and planning documentation.

The impact to society, financial and otherwise, would be extremely minimal. Indeed, it's been 

demonstrated that sUASs have the ability to drastically increase the information available to 

policymakers at a fraction of the cost of measuring this data by terrestrial means. One such impact 

would be inconvenience to directly proximal and non-essential personnel that would be displaced from 

public or business owned property if it is deemed to be unsafe. In this case we relay our needs for a 

flight zone with the requirement that it be safe from casual intrusions and allow the business time to 

shift operations in order to minimize potential safety issues. This is best performed with the aid of safety 

personnel that actively steer non-essential persons around the flight zone.

1. The effect of an exemption for Eye in the Sky Surveyors, LLC on the quality of the natural and social 

environments

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an on 

board pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight 

paths to local civilian or military airports, and detrimental effects to the environment caused by 

operating a combustible fuel based, large scale aircraft, with restrictions on the proximity to the target 

for remote sensing.

Ill. Flight Capabilities and Characteristics of Eye in the Sky Surveyors, LLC’s sUASs

Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and

Characteristics of the sUAS. 

Eye in the Sky Surveyors, LLC UASs utilizes four (4) counter-rotating propellers paired oppositely 

to each other for balance, control and stability. The total span of the sUAS is ""'1.2m allowing for stable 

flight or landing even with the sudden onset of detrimental environmental conditions. The sUAS's have a 

maximal unit+ payload mass of 11kg, including cinematic/photographic or other surveying equipment. 
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Eye in the Sky Surveyors, LLC's sUAS is designed to primarily hover in place to capture photographic data 

and then operate at less than a 35 knot maximum speed to the next point of interest. They are capable 

of vertical and horizontal operations but, in practice, are operated only within unaided VLOS of the PIC. 

In addition to the PIC, Eye in the Sky Surveyors, LLC employs a spotter (VOS role) and a technician 

(secondary VOS and on-site personnel liaison) which are within unaided verbal communication range. 

These personnel will be supplemented by safety officials provided by the client (when needed) who are 

instructed to cordon off and otherwise minimize pedestrian access in the flight zone of the client's 

grounds. In the event of loss of visual of the UAS, the PIC can change flight controls from cartesian 

(X,Y,Z) based controls to radial (r,a ,h) based controls which allows the PIC to utilize one controller axis 

to recall the VAS to the PIC's position without concern to the current heading of the sUAS. In the event 

of loss of sight of the sUAS into an area containing hazards or possible hazards, the spotter has a headsup-display containing a live video feed which can be used to locate the UAS while it maintains its 

position in hover mode. The sUAS has demonstrated its ability to maintain its position by GPS 

coordinates in hover mode in "-'2Skph wind gusts at rv25 feet representing an extreme environmental 

condition beyond the range of conditions within the scope for sUAS operation.

All of Eye in the Sky Surveyors, LLC's sUASs utilize LiPo (lithium polymer) battery based power 

sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times 

generally last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per 

phase. The maximum flight time is 23 minutes, however practical safe operation limits this to 18 to give 

ample time to control the sUAS to a safe landing zone. Eye in the Sky Surveyors, LLC further restricts 

flight time by not operating its sUASs with less than thirty percent battery capacity. Further safety 

management systems in place include a GPS mode that allows Eye in the Sky Surveyors, LLC sUASs to 

hover in place if communication with the PIC is lost and optionally follow a set of waypoints at a set 

speed and height to a 'home base' predesignated safe landing zone. In the event of unforeseen motor(s) 

failure, the system will enter into a controlled descent while allowing full use of all UAS flight controls by 

the PIC. All commands sent via remote controller received during a controlled descent are translated to 

an 'as meant' paradigm meaning the flight control package will use its real time 3 dimensional position 

and compensate rotors control the sUAS regardless of spin velocity. Landing gear is also programmed to 

deploy based on sensing of range to ground from non-GPS based sources. This assures that if one 

system is compensated a safe and successful landing can still occur.

IV. Reasons Why an Exemption to Eye in the Sky Surveyors, LLC Will Not Adversely Affect Safety 

Standards

Eye in the Sky Surveyors, LLC's contends that operation of its sUASs will not "create a hazard to users of 

the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size 

and weight of Eye in the Sky Surveyors, LLC's sUASs, combined with their operation in cordoned off and 

well-controlled areas, Eye in the Sky Surveyors, LLC's sUASs falls within Congress's contemplated safety 

zone. Eye in the Sky Surveyors, LLC sUASs have an established safety record bolstered by multi-point 

preflight checklist, awareness of their surroundings and intimate knowledge of the behavior of the sUAS 
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platform in many weather conditions. TI1is safety record and implemented operational practices

demonstrate an awareness of public safety.

Eye in the Sky Surveyors, LLC operations routinely provide a level of safety at least equal to 

existing rules, and in nearly every instance, exceeds existing rules. Eye in the Sky Surveyors, LLC has 

worked very closely with the regional vendors and support for this unit to create a tightly integrated and 

highly fault tolerant platform that has been tested thoroughly by a vendor with a proven record for 

safety and solid designs.

Though it does not mitigate safety it is of note that as of Nov 2014 there are few companies that 

will insure sUAS operations and sUAS based companies. The sUAS of use at Eye in the Sky Surveyors, LLC

is one of two models (by current awareness) that qualify for protection against damages or injury. Eye in 

the Sky Surveyors, LLC attained the maximal level of insurance to rectify accidental damage or injury. 

Eye in the Sky Surveyors, LLC also continues to work closely with this organization to identify and 

mitigate sUAS platform risk due to their expertise in several industries closely related to the aviation and 

transportation.

Eye in the Sky Surveyors, LLC will not operate its UASs on or near airports and generally will only

operate its fleet on private grounds with cordoned off areas or areas under the control of the property 

owner I client with assistance by safety officials employed by the business. Eye in the Sky Surveyors, LLC

determines the areas needed to fulfill the clients' goals and will only operate its UASs in these flight 

zones and only in compliance with well-regarded safety protocols set forth initially by the RC UAS trade 

and hobby groups and recently codified by relevant FARs.

Eye in the Sky Surveyors, LLC standardized on the following practices to ensure safe operation of its

UASs:

• Work with on-site personnel to plan the flight goals,

• Work with on-site personnel to restrict access to non-essential persons,

• Operation by unaided VLOS operation only,

• Operation in phases 10 minutes in length,

• Operation to minimal 25% battery power,

• Operation of device to GPS aided readout to 300ft at maximum,

• Numerous pre-programmed fail -safes that ensure specific behavior per issue,

• Two main roles supplemented by on-site safety personnel,

• Employ controlled lifecycle management of components to guard against multiple failures,

• Preform a site check day(s) before flight to identify potential issues,

• Subscribe to relevant local weather and safety alerts,

• Expertly choose data collection instruments and accessories to minimize flight requirements or

expertise,

Eye in the Sky Surveyors, LLC has experience in similar fields and has adapted this experience in its

use of UASs to increase safety. In combination to the ever expanding knowledge repositories from 
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hobbyists and experts alike, Eye in the Sky Surveyors, LLC is constantly evolving its practices when there 

is a clear benefit to operations or increased safety element.

A. 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:

Eye in the Sky Surveyors, LLC {applicant) seeks an exemption from the following rules: 14 C.P.R. 

§21, subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 91.103{b); 91.109; 

91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91.409 (a) {2) and 

91.417 (a) & (b) to operate commercially a small unmanned vehicle (11kg or less) in elevated 

photographic and remote sensing operations.

Approval of exemptions allowing commercial operations of sUASs in the media industry will 

enhance safety by reducing risk associated with conventional aircraft operations and other means of 

elevated remote sensing involving persons. The public benefit served by approval of this petition is 

increased awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than 1lkg and 

powered by sealed batteries eliminates virtually all associated risk inherent in operating conventional 

aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they 

would be able to collect needed data.

The operation of small UASs, weighting less than 55lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations.

As identified and described herein, Eye in the Sky Surveyors, LLC, is an experienced, recognized 

media services professional in the various photographic industries. Eye in the Sky Surveyors, LLC have 

been producing and delivering media and technical solutions for the media service industry for ten ( 10) 

years with a spotless safety record.

The FAA has been given the authority to issue the exemption to Eye in the Sky Surveyors, LLC

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your 

consideration and approval of this petition.