1

February 12 , 2016

U.S. Department of Transportation Docket Operations, M

- 30

1 200 New Jersey Avenue, SE

Room W12

- 140, West Building Ground Floor Washington, DC 20590

- 0001

Re: Petition of Skygear Solutions, Inc. for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Skygear Solutions hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the following

aircraft:

- DJI S1000 +

- DJI S900

- DJI Inspire 1 Pro

- DJI Phantom 3 Professional

- DJI Matrice 100

- Yune ec Q500 Typhoon 4K

This petition incorporates the ma terial contained in the user manual s of each of the above listed aircraft, referred to hereafter, together, as the "Manuals."

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Skygear Solutions requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);2

 14 C.F.R § 91.103;

 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;

 14 C.F.R § 91.121;

 14 C.F.R § 91.151(a) & (b)

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 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 operation of an unmanned aircraft system where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national security based on the following consideratio ns:

 The size, weight, speed and operational capability;

 Operation in proximity to airports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authorit y 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), 44701

- 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. 14 C.F.R. § 11.81.

III. DESCRIPTION OF SKYGEAR SOLUTIONS

Skygear Solutions is a consulting and training firm which also operates an informational website and online retail store for unmanned aircraft systems and components. Skygear Solutions maintains an impeccable record of upstanding business practices while adherin g to the letter of the law. Training courses offered by Skygear start with classroom understanding of FAA regulations and advisories, progress through safety and equipment teachings, and culminate in

hands

- on flight training of UAS. The student departs w ith a detailed knowledge of the industry, the law, and how to safely fly their UA. The company is headquartered in Wilmington,

Delaware and currently maintains clients across the Eastern seaboard of the United States.

Skygear shares the interests of the FAA regarding safety of the National Airspace System and

look s to set a new standard, ensur ing every UAS operator gains the same level of knowledge, training, and respect for the airspace as a typical certificated, manned aircraft pilot

.3

The contact information for the peti tioner, Skygear Solutions , is as follows:

Daniel Herbert

Chief Executive Officer Skygear Solutions , Inc. 4536 Kirkwood Highway Wilmington, Delaware 19808 ( 302 ) 200

- 7223

Daniel.Herbert @ S kygear S olutions.com

IV. DESCRIPTION OF PROPOSED OPERATIONS

Skygear Solutions is requesting exemption from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Modernization and Reform Act to perform the following:

o Aerial Photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering, television, public events, cinematography, news gathering and other related professional activities

o Aerial inspection/photography of residential/commercial structures under contract

with the owner(s) or local government authority

o Aerial video/photography for the purpose of assistance with search and rescue operations in cases of emergency or natural disaster in coordination with and with

authorization from the Incident Commander or other suit able official

o Individual or group UAS flight training for public/private entities in an effort to enhance the safety of the National Airspace System as well as for the protection of persons and property

o UAS product flight demonstrations for clients desirin g to purchase aircraft models identical to the above named aircraft belonging to petitioner

Skygear Solutions recognizes the enormous potential of UAS but also recognizes the need for due diligence and responsibility on the part of the persons that will f ly the UA to ensure the safety of the National Airspace with respect to manned aircraft and persons/property on the ground. Skygear Solutions will assist with the integration of UAS into the NAS by educating users on this new technology. Skygear Solutions is seeking this exemption to help ensure that

both recreational user s and public entity operators have a reasonable option for obtaining UAS flight and safety training.

A. UNMANNED AIRCRAFT SYSTEMS

Skygear Solutions will utilize the following Unmanned Aircraft Systems for non

- recreatio nal flight operations:

o DJI S1000+

Please see Attachment A for this aircraft manual4 o DJI S900

Please see Attachment B for this aircraft manual

o DJI Inspire 1 Pro

Please see Attachment C for this aircraft manual

o DJI Phantom 3 Professional

Please see Attachment D for this aircraft manual

o DJI Matrice 100

Please see Attachment E for this aircraft manual

o Yuneec Q500 Typhoon 4K

Please see Attachment F for this aircraft manual

The inherent safety features, sophistication , programmability, GPS navigation, Return To Home

c apability, Geofenced flight location restrictions, and restricted altitude feature s , as well as differentiating radio frequency ( RF ) for aircraft controller/receiver and for the camera make all

of these in credibly safe and reliable UAs for the purposes of this petition and the use of Skygear

Solutions.

B

. PROPOSED OPERATIONS DEMONSTRATE EQUIVALENT LEVEL OF SAFETY

General Description of Proposed Flight Operations

Skygear Solutions proposes to operate wit hin the limitations and performance specifications

listed in the Manuals provided by the manufacturer s . These limitations provide for at least an equivalent, or higher, level of safety for operations under the current regulatory structure because the proposed operations represent a safety enhancement to the existing protocols.

The proposed operations do not create any hazard to users of the national airspace system or pose

a t hreat to national security. Each UA is a battery operated multirotor with a maximum flight

time of approximately 25 minutes. Each UA has a weight of less than 1 0 pounds and none have a groundspeed surpassing 50 m iles per hour.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. None

of the UA in this petition carry any fuel , and therefore the risk of fire following an incident or

accident du e to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated by the petitioner reduces the risk to participating persons and property in close proximity to the aircraft due to the limited size, weight, operating cond itions, a nd design safety

features of each UA.

The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology, is mitigated by placing limits on alt itude, requiring stand

- off distance from clouds, permitting daytime operations only, and requiring that the aircraft be operated within visual line of sight and5

yield right of way to all other manned operations. Additionally, the operator will request a

NO TAM prior to all operations to alert other users of the NAS.

Each UA has the capability to operate safely after experiencing certain in

- flight failures

. All are also able to respond to a lost

- link event with a pre

- coordinated, predict able, automated flight maneuver, which returns the aircraft to a pre

- determined and safe location.

1. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will operate, the procedures listed below, a nd pilot certificati on requirements, Skygear Solutions' proposed operations using unmanned aircraft would “not create a hazard to users of the national airspace system or the public or pose a threat to national security.” Reform A ct Section 333(b)(1).

1. Eac h aircraft weighs less than ten (10) pounds.

2. Each aircraft will be identified by serial number, registered with the FAA, and

have identification (N

- Number) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by PIC.

5. Maximum flight time for ea ch operational flight will be 20 minutes.

6. The aircraft will be safely landed with no less than the gre ater of (a) 25 % battery life remaining or (b) five minutes of flight time remaining.

7. The aircraft will be operated during daylight and in VFR conditions.

8. Flights will not exceed 4 00 feet AGL

. 9. Flights will be operated at a lateral distance of at least 10 0 f eet from any persons or property not associated with the operation having not given prior permission.

10. Flights will be limited to a groundspeed of 3 5 mph.

11. Minimum crew for each flight will consist of a PIC and an Observer.

12. The PIC will possess at least a sport pilot certificate, private pilot certificate, or have held a US Army Military Occupational Specialty (MOS)15W Unmanned Aerial Vehicle Operator, USMC MOS 7314/7316

-- Unmanned Aerial Vehicle (UAV) Air Vehicle Operator, and/or 150U Tactical Unmanned Ae rial Systems (TUAS) Operations Technician, Navy MOS NEC 8362, NEC 8363, NEC 8364, NEC 8366, NEC 8367, and NEC 8368. Pilots with this training are considered trained and currently fly throughout the United States for the United States military. Pilots with military training will be required to hold a security clearance. Having a government furnished security clearance ameliorates security concerns over civil UAS operations conducted in accordance with Section 333.

13. Prior to the flight, a Missio n Plan will be created setting forth the limitations for the flight as well as contact information for the PIC.

14. The flight operations will always and under all circumstances, yield the right of way to other manned aircraft operations.

15. Skygear Solutions wil l provide NOTAM details to the FAA 24 hours prior to each flight operation

.6

16. All required permissions and permits will be obtained from territory, state, county or city jurisdictions prior to flight.

17. Prior to commencing operations, Skygear Solutions will ob tain a Certificate of Waiver or Authorization (COA) from the FAA.

18. If the aircraft loses communications, it will have the capability to return to a pre

determined location within the operational area and land.

19. If the aircraft loses its GPS signal it will ha ve the capability of being flown manually to a predetermined location within the operational area and land.

20. The flight will be aborted in case of unpredicted obstacles or emergencies or other

environmental condition deemed unsafe

. 21. Each flight will be recor ded in an Operations Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

2. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are documented abov e, and

are more fu lly documented in the Manuals (See Attachment s A, B, C, D, E, and F )

.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Skygear Solutions seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations using the unmanned aircraft

shown above . Listed below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Skygear Solutions has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. Part 21, Subpart H

– Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated th at no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met, and therefore no

ex emption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014

- 0352 at 13

- 14, 22. If, however, the FAA determines that there are some characteristics of either

UA that fail to meet the requirements of the Reform Act, an exemption is req uested.

Equivalent Level of Safety: All unmanned aircraft in this petition are s afe when taking into

account their size, weight, speed, and operational capability. Each weigh less than ten (10) pounds a nd wil l be flown at speeds less than 3 5 miles per hour, in visual line of sight of the operator, and in designated safe locations

. None of these aircraft carr y pilots, passengers, explosive materials, or flammable liquid fuels and each will be operated within the parameters of

the Manuals.7

Sk ygear Solutions will also provide the FAA with advance notice of all operations via NOTAM and coordination with the local FSDO. The proposed operations will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness cert ificate without the

restriction s and conditions proposed here.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. T o the extent the UA in this petition would otherwise require certification under Part 27, Skygear Solutions seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpa rt H.

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements

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 m ore than 6 inches high, the words “limited,” “restricted,” “light

- sport, “experimental ,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. 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.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exempt ion No. 11062, Docket No. FAA 2014

- 0352, at p. 14.

Equivalent Level of Safety: Skygear Solutions will mark all unmanned aircraft with their respective N

- Number in a prominent spot on the fuselage with markings that are as large as practicable.8 D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Skygear Solutions seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate. The p urpose 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 pilot is carrying passengers or cargo for hire.

While the unmanned aircraft in this petition will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA

- 2014

- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled

airs pace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot.

The PIC will possess at least a sport pilot certificate, private pilot certificate, a third class

medical certificate or valid Driver's License

, or have held a US Army Military Occupational Specialty (MOS)15W Unmanned Aerial Vehicle Operator, USMC MOS 7314/7316

-- Unmanned Aerial Vehicle (UAV) Air Vehicle Operator, and/or 150U Tactical Unmanned Aerial Systems (TUAS) Operations Technician, Navy MOS NEC 8362, NEC 8363, NEC 8364, NEC 8366, NEC 8367, and N EC 8368

.

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through UAS

- specific flight cycles, flight time, a nd specific make and model experience, culminating in verification through testing.” See Exemption No. 11062, Docket No.

FAA 2014

- 0352, at p. 18. The proposed operations can achieve an equivalent level of safety by requiring the knowledge and experience in unmanned aircraft operations described above.

Furthermore, the security screening conducted by the Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a

threat to nat ional security.

The restrictions Skygear Solutions has placed on its UA operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA

- 2014

- 0352. Skygear

Solutions will operate in restricted areas aw ay from persons and property not involved in the operation. The aircraft will be f lown based on VLOS at or below 4 00 feet AGL. A NOTAM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the applicable FS DO.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Skygear Solutions seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the ex tent that the requirements of Part 21 are waived or found inapplicable.9

Accordingly, Skygear Solutions requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

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

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

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b)No person may operate a U.S.

- registered civil aircraft

-

...

(2)For w hich 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 ther eof.

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 cu rrent 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.

Skygear Solutions do es not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the cont rol station with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19

- 20, and Grant of Exemption No. 86 07.

G. 14 C.F.R. § 91.103: Preflight Action

Skygear Solutions 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. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements , landing and takeoff distances and aircraft performance data before initiation of flight. Un der these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAA

approved Flight Manual is required.10

Equivalent Level of Safety: An equivalent level of safety will be provided by following the Manuals. The PIC will take all required preflight actions

- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas

- before initiation of flight. The Manuals will be kept at the ground station with the operator at all times.

H. 14 C.F.R. § 91.109(a): Flight Instruction

Skygear Solutions seeks an exemption from 14 C.F.R. § 91.109(a), which provides 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.” UASs and remotely piloted aircraft, by their design, do not ha ve functional dual controls.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the aircraft

and the Ground Control Station will be a safe distance from the aircraft and the public, causin g

no safety hazard. Given the s ize and speed of all unmanned aircraft in this petition , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event tha t the aircraft experiences any difficulties during flight instruction. In addition, Skygear Solutions will conduct flight training at a secure location away from non

- involved property or spectators and will comply with the provisions in the Manuals. Accor dingly, Skygear Solutions' proposed method of operation provides superior levels of safety.

I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Skygear Solutions requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in areas with similar flight restrictions as those imposed by Skygear Solutions

. See Grant of Exemption No. 11062, p. 20

- 21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far less than those that presently exist with conventional

aircraf t. An equivalent level of safety will be achieved given the size, weight, and speed of the

UA

, as well as the locati ons where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 4 00 feet AGL or below. As set fort h in the Manuals and herein,

all unmanned aircraft will be operated away from persons or structures not involved in the operation. All persons who are not involved with Skygear Solutions ' operations wi ll be required

to be at least 100 feet from the trainin g perimeter.

J. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks 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. The unmanned aircraft in this petition use both barometric11

pressure sensors and GPS to determine altitude but does not have the abilit y to input a current
altimeter setting. An exemption is required to the extent that each UA does not have a barometric altimeter setting. The al titude of the air craft is monitored by the PIC using the Ground Control Station and by the Visual O bserver.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be achieved if the aircraft will be operated at or below 400 feet AGL and within visual line

- of

- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20

- 21. Each UA will be operated at or below 400 feet AGL and comply with the limitations in th e Grant of Exemption No. 11062.

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Skygear Solutions 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 afte r that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the battery power of each UA in this petition means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve.

Each aircraft is battery powered with a maximum flight time of 2 5 minutes. Skygear Solutions proposes that the maximum flight time for each operationa l flight will be 20 minutes. The aircraft will be safely landed with no less than the greater of (a) 2 5 % battery life remaining or (b) five minutes of flight time remaining.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21

- 22. Skygear Solutions will be providing an equivalen t level of safety by safely landing with no less than the greater of (a) 25 % battery life remaining or (b) five minutes of flight time remaining and otherwise complying with the flight restrictions above.

L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2) ; 91.417(a) and (b): Maintenance Inspections

Skygear Solutions seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and ins pection 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 between12

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 neither UA in this petition will have

.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, and inspection requirements for each aircraft and procedures to document

and maintain maintenance records for each aircraft. This also includes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014

- 0352, at p. 14

- 15.

Flights will not be conducted unless a flight ope rations checklist is performed that includes all of the aircraft’s components. Requirements are in place for maintenance log books and record keeping as well as routine and post

- flight maintenance. Annual and preventative maintenance procedures are also in place with all of Skygear Solutions' aircraft.

VI. PUBLIC INTEREST

Granting Skygear Solutions' petition for exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the NAS in controlled, safe working

envi ronments such as the environments proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act.

Moreover, use of unmanned aircraft operations will improve awareness of FAA regulations and provide a standard level of training for all unmanned aircraft pilots . The use of the UA in this petition will also decrease safety

- related incidents involving new users of unmanned aircraft

.

Thus, the use proposed here will allow Skygear Solutions to determine the efficacy of the UA in this petition for increasing public safety. Each unmanned aircraft weighs less than ten (10) pounds, carries no passengers or crew, and has no flammable fuel, as opposed to larger and more powerful h elicopters and small airplanes. This program may prevent accidents and injuries, and there is a strong public interest in making these operations mo re safe and e ffective through the

use of UAS

.

VII. PRIVACY

All flights will occur over designated areas cleared with property owners

. All flights will be conducted in accordance with any applicable federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

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:Skygear Solutions, Inc. seeks an exemption from the following rules for the commercial

operation of small unmanned aircraft systems to perform Aerial Photo and Video Service, Inspection, Equipment Demonstration, Emergency Response Assistance, and UAS Flight Training: 14 C.F.R Part21, Subpart H; 14 C.F.R Part27; 

### l4 C.F.R $ a5.23(b); 14 C.F.R. $ 45.27(a);14 C.F.R $ 61.1t3; t4 C.F.R $ 91.7(a); 14 C.F.R $ 91.9(bX2); 14 C.F.R $ e1.9(c); 1a
C.F.R $ 91.103; 14 C.F.R $ 91.109(a); 

### l4 C.F.R $ 91.119; 14 C.F.R $ 91.121; 

### l4 C.F.R $ 91.151(a) 

### & (b) 14 C.F.R $ 91.203 (a) 

### & (b); 

### l4 C.F.R $ 91.a0s(a); 14 C.F.R $ e1.a07(a)(l); 1a

C.F.R $ 91.409(a)(T; ru C.F.R $ e1.417 (a) 

### & (b).

The exemption 

### will enhance safety by reducing risk to the operator, the general public and
property owners.



## IX. ATTACHMENTS

Attachment 

### A: DJI S1000+ User Manualvl.4

Attachment 

### B: DJI 5900 User Manual 

### vl.4

Attachment 

### C: DJI INSPIRE 1 PRO User Manual v1.0

Attachment 

### D: DJI PHANTOM 3 PROFESSIONAL User Manual v1.6

Attachment 

### E: DJI MATRICE 100 User Manual 

### vl.4

Attachrnent 

### F: YUNEEC Q500 TYPHOON 4K User Manual



## X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, operating capabilities, proximity to airports and populated areas. operation within visual line 

### of

sight, and national security considerations - provides more than adequate justification for the
grant of the requested exemptions to permit Skygear Solutions to operate the aforementioned

unmanned aircraft within the National Airspace System.

Granting the requested exemption 

### will benefit the public interest as a whole in many ways, including (1) signihcantly improving safety and reducing risk by alleviating human exposure to
danger; (2) improving the quality of services Skygear Solutions can provide to its clients; and (3)

decreasing the risks of unmanned aircraft interfering with manned aircraft.

Daniel Herbert

Chief Executive Officer
Skygear Solutions, Inc.

13 Respectfully submitted,