**U.S. Department of Transportation Docket Management System**  **1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12**

**- 140**  **Washington, DC 20590** January 20, 201 6

**Peti tioner:**  Skypoint Films, LLC Wes Hoffman , Managing Director 5103 S. Sheridan #523 Tulsa , OK 74145 Tel.: 918.995.0900 Fax: 800

. 591.4590 Email: wes@ skypointfilms.com

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 11.81, Skypoint Films, LLC

. , hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operatio n of its small, unmanned aircraft for photography, videography, advertising, inspection, and analyses. All operations will be conducted within and under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals. 1. Sections from which exemptions are sought: Application is hereby made for exemption from:
**A**
**.** 14 CFR Part 21, subpart H **B**
**.** 14 CFR Part 61.113(a) and (b) **C**
**.** 14 CFT Part 91: **I**
**.** 91.103(b)(2) **II**
**.** 91.105 **III**
**.** 91.109 **IV**
**.** 91.119 **V**
**.** 91.121 **VI** . 91.151 **VII**
**.** 91.405 **VIII**
**.** 91.407 **IX**
**.** 91.409 **X**
**.** 91.417**2. Relief Sought:**
**A**
**.** Skypoint Films, LLC

. wishes to operate small Unmanned Aircraft Systems (sUAS ) for commercial purposes to include (but not be limited to) photography, videography, advertising, inspection, and analyses.

**B**
**.** This relief is sought because commercial use of sUAS is currently prohibited by law unless performed under an exemption.
**C**
**.** This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including payload and energy sources:

I . DJI Inspire 1 (see www.dji.com/product/inspire

- 1 )

II . DJI Phantom 3 (see www.dji.com/product/phantom

- 3 )

III . O ther models to be added by future amendment to this exemption.
**3. Public Benefit:**
**A.** Use of sUAS technology to obtain imagery, information and data currently obtained by use of manned flight or manual methods:
**I**
**.** Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).
**II**
**.** Reduces the cost of obtaining such information, which benefits consumers and the economy.
**III**
**.** Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft.

**B**
**.** Skypoint Films, LLC

. will instruct and advise others interested in flying UASs to do so safely and legally in the NAS.
**4. Safety Not Adversely Affected:** 
**A** . Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C.

**B** . Aircraft will comply with maintenance and inspectio n requirements of the manufacturer and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft.**C**
**.** All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal communication capability with each other at all times during the flight, and who will remain stationary on the ground during the flight operations:
**I.** A Pilot In Command (PIC) who possess the following credentials:
**1.** An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA.
**2.** A Third Class medical certificate issued under 14 CFR 67.
**3.** A bi

- annual flight review under 14 CFR 61.56.
**4.** Successful completion of a UAS knowledge test i n a specified form.
**5.** At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from pers ons in accordance with 14 CFR 91.119.
**II**
**.** A Visual Observer as necessary.

**D**
**.** All flight operations will be conducted in accordance with valid Certificates of Authorization.
**E**
**.** All flight operations will comply with the following:
**I**
**.** The manufacturers’ user manuals.
**II**

. Skypoint Film ’ s Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) which include lost communication and other emergency and safety procedures.
**III**
**.** Conducted in VMC conditions during daylight hours.
**IV**
**.** sUAS will maintain VLOC at all times.
**V**
**.** PIC and VO will maintain VLOS at all times.
**VI**
**.** Pre

- flight inspections (including ground control station, if any) and safety risk assessments will be con ducted prior to each flight.**VII**
**.** Flig ht altitudes will remain below 4 00 feet above ground level.
**VIII**
**.** Flight ground speeds will not exceed 50 knots.
**IX**
**.** Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place withi n 5 nautical miles of an airport.
**X**
**.** Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground without their prior permission.
**XI**
**.** Each flight will be logged in both the PIC’s logbook and the aircraft logbook.
**XII**
**.** Any inc idents will be reported within 24 hours of occurrence.
**XIII**
**.** Skypoint Films, LLC

. will maintain liability i nsurance of at least $1,000,000.
**XIV**
**.** Any applicable local FS DO requirements.
**XV**
**.** All other applicable regulations concerned with the operation of aircraft.

**F**
**.** Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well

- defined and tested lost link procedures. Please advise us of any additional information or changes that may be required. Sincerely,

Wes Hoffman Managing Director

- Skypoint Films, LLC.