HenryJ Peraza d/b/a SkyView Photoworks 4995 University Drive Coral Gables, FL 33146

July 2, 2015

U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Amended Section 333 Exemption Request Original Request No. 29534 CommentTracking No. 1jz-8ifr-1gs0

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part II ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b): 14 C.F.R. Part 21: 14 C.F.R. Part 61.113 (a) & (b): 91.7 (a): 91.9 (b) (2): 91.103 (b): 91.109: 119:91.121:91.151 (a) & (b): 91.405 (a): 91.407 (a) (I): 91.409 (a) (2): 91.417 (a) & (b).
Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R Part 11, HenryJ Peraza d/b/a SkyView Photoworks, operator ofSmall Unmanned Aircraft Systems ("sUAS'), hereby applies for an exemption from the above listed Federal Aviation Regulations (FAR's") to allow commercial operations ofits sUAS. All operations will be conducted in a safe manner and in full accordance with all FAA regulations. Proposed commercial operations are as follows:
1. Aerial Photography and Videography for the commercial and residential real estate industry. 2. Aerial Photographyand Videography for the marine industry.

1 '3. sUAS flight training. 4. Aerial inspection ofpublic and private facilities and structures. The applicant for this exemption holds a current Private Pilot Certificate with approximately 500 hours ofPIC experience. Applicant has extensive knowledge ofthe airspace system. In addition, applicant has extensive sUAS operations experience having logged more than 100 hours offlight time in the lastyear. How the granting ofthis exemption would benefitthe public interest as a whole: The use ofa battery operated sUAS aircraftwould present a minimal impactto the environment. The use ofa sUAS to produce videos and still photographs for the real estate and marine industrywould enhance the economic activity, productivity and efficiency ofthe aforementioned industries. The use ofsUAS to inspect facilities such as cell towers, television towers and other similar structures, would significantly enhance the safety of said inspections since the unmanned sUAS replaces the need in manyinstances to use human individuals to perform these types ofdangerous inspections. Training others to operate sUAS bya certificated Private Pilot with significant sUAS flight experience will further serve the public interestby ensuringthat newpilots operate their sUAS in a safe and responsible manner.

The name and address ofthe applicantis:
Henry

### JPeraza d/b/a SkyView Photoworks Phone: 305-299-3574 Email: henry@skyviewphotoworks.com Address: 4995 University Drive, Coral Gables, FL 33146 Regulations from which the exemption is requested:
14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

' 214 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b) The sUAS operated by applicantweigh significantly less than 55 lbs. All aircraft operate at speeds not exceeding 55kts. All operations are conducted in line ofsight ofPIC. All training will be conducted with dual controllers to ensure safe operations.
Due to the small size ofthe sUAS used by applicant, and the fact that all operations will be conducted in controlled airspace by a certificated Private Pilot with extensive flying experience, the proposed operations will adhere to the Reform Act's safety requirements.

Aircraft and Equivalent Level ofSafety Limitations and conditions to which applicant agrees to adhere to when conducting commercial operations:
1. All flights will be conducted within line ofsight ofthe PIC and/or observer. 2. All flights will be conducted at an altitude notto exceed 400 feet above ground level (AGL). 3. The sUAS used will have built in safety features that alertthe pilot in command of any restricted airspace incursions as well as a return-to-home feature that autonomously causes the aircraftto return to its designated point oftakeoffin the event ofa breakdown ofcommunications betweenthe aircraft's receiver and ground transmitter

### andfor loss ofGPS signal. 4. The PIC will ensure that a pretakeoffchecklist is performed before every flight in orderto ensure thatthe aircraftis in proper operating condition.

' 35. The PIC will ensure that all commercial operations are conducted in a safe and responsible mannerwith particular attention paid to the safety ofpersons and property. 6. The PIC will ensure that all operations in controlled airspace adhere to all current restrictions and regulations. 7. Minimum crew for each operation will consist ofthe PIC, the Visual Observer (VO) and when required a camera operator. 8. Abriefing ofthe planned flight will be conducted before each flight. 9. When required, all necessary permits will be obtained from territorial, state, county or city departments, including law enforcement, fire or othergovernment agencies. 10. Maximum flight time will bethirtyminutes and terminated at 25% ofremaining batterypower.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) SubpartH, entitledAirworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203 (a) (1). Because ofthe size and limited operating area associated with the aircraft to be utilized byApplicant, an exemption from Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed operational capability, and proximityto airports and populated areas ofthe particular sUAS. Safety considerations in mind, the operation ofthe applicant's sUAS aircraft in the mannerproposed, will be as safe or safer, than conventional aircraft. The sUAS to be operated is significantly less than 55 lbs. fully loaded, carriers neither a pilot nor passenger, carries no hazardous explosive orflammable materials such as fuel, and will operate only within secure and designated areas. Furthermore, given the size limitations, speed, restricted flight areas, and lack ofexplosive or flammable materials, Applicants sUAS poses no threatto national security.
14 C.F.R. § 45.23 (b). Marking oftheAircraft

' 4The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted orlight sport category aircraft, the operator must also display on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters no less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable.
Even though the sUAS will have no airworthiness certificate, an exemption maybe needed as the sUAS will have no entrance to the cabin, cockpit orpilot station on which the word "experimental" can be placed. Given the size ofthe sUAS, two inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29. The equivalent level ofsafety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the PIC, observer and anyone else working with the sUAS will see the identification ofthe sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. § 61.113 (a): Private PilotPrivileges and Limitations: Pilot in Command
Pursuantto 14 CFR 61.113 9a), no person who holds a private pilot certificate may act as a pilot in command ofan aircraftthat is carryingpassengers orpropertyfor compensation orhire. Applicants' sUAS will not carrypassengers or propertytherefore an exemption to 14 CFR 61.113 is requested. The operatingprocedures put forth by applicant in this 333 Exemption Request should be sufficientto ensure that an equivalent level ofsafety is achieved. 14 C.F.R. § 91.7 (a): Civil AircraftAirworthiness. CFR § 91.7 (a) requires that no person may operate a civil aircraftunless itis in airworthy condition. Since there will be no airworthy certificates for the sUAS, no FAA regulatory standard will exist for deterring airworthiness. The use ofa preflight checklistto ensure thatthe aircraftis proper operating condition priorto each flight will ensure an equivalentlevel ofsafety.
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft.

5 'Section 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 notrequired by §21.5 ofthis 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 has no pilot on board, any room to store a flight manual, placards, markings, or any combination thereof. The flight operations manual will always be in the possession ofthe PIC while operatingthe sUAS thereby ensuringthe same level ofsafety.
14 C.F.R. § 91.103: PreflightAction. This regulation requires thatthe PIC perform a thorough preflight inspection and other related actions to ensure the safety ofthe flight. An FAA approved rotorcraft flight manual will notbe provided for the aircraft; therefore an exemption will be needed. The preflight checklist as setwill set an equivalentlevel ofsafetyforth in the Flight Operations Manual. The PIC will take all necessary actions to include landing and takeoff distances; weather reports; alternate landing locations in the event ofa power or GPS failure; flight batteryrequirements, and aircraftperformance data. 14 C.F.R. § 91.109: Flight Instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned balloon) thatis being used for flight instruction unless that aircrafthas fully functioning dual controls. The FAA has approved exemptions for flight trainingwithout fully functional dual controls for a number ofaircraft. The equivalent level ofsafety can be provided bythe fact that neither a pilot nor passengerwill be carried in the aircraft and bythe size and speed ofthe aircraft. When practical however, applicant will utilize dual remote control transmitters for hands on flight training operations further enhancing safety.
14 C.F.R. § 91.119: Minimum SafeAltitudes. Section 91.119 establishes safe altitudes for operations ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated atless than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a sUAS thatis a helicopter and the exemption requests authorityto operate to altitudes up to 400 feet AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. The sUAS will never operate higherthan 400 AGL exceptin circumstances where the sUAS is used to inspect, survey orphotograph a structure whose height exceeds 400 feet AGL, the sUAS will notbe operated more than

6 '100 feet above the highest point ofthe structure. All operations will take place in a restricted securityperimeterwhere people will notbe exposed to operations without prior approval and knowledge ofsaid operations. The lack ofhazardous materials, gross weight less than 55 lbs., relatively slow speeds, and low altitudes, make sUAS operations far less riskythan that offixed wing and rotorcraft aircraft. In addition, the low altitudes atwhich the sUAS operate, ensures separation between sUAS and conventional aircraftthatmust complywith Section 91.119.
14 C.F.R. § 91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitudes by reference to an altitude altimeterthat is set "to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." Since the sUAS utilizes a GPS readout instead ofa barometric altimeter to indicate altitude, an exemption may be needed. The same level ofsafety can be achieved bythe use oftelemetry from the sUAS to the ground station indicating currentaltitude atthe launch site and during all phases offlight.
14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions. This section 91.151 (a) prohibits from beginning "a flight in an airplane underVFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed (1) Duringthe day, to fly afterthat for atleast 30 minutes; or (2) At night, to fly at least45 minutes." The battery ofthe typical sUAS provides on average approximately 30 minutes offlight time. To meetthe 30-minute reserve requirement sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the sUAS's its proposed operations within a predetermined area, a longertime frame for flight in daylight or twilightVFR conditions is required. Applicantbelieves that an exemption from 14 CFR § 91.151 (a) falls within the scope of prior exemptions. Operating a sUAS 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 ofreserve fuel, does not engenderthe type ofrisks that Section 91.151 (a) was intended to alleviate given the size and speed ofthe sUAS. Additionally,

7 'limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalentlevel ofsafety can be achieved bylimiting flights to 30 minutes or 25°/o ofbatterywhichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. 

### 14 C.F.R. § 

### 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The regulation states: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within itthe following: (1) an appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraftunless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed atthe cabin or cockpit entrance so it is legible to passengers or crew. The sUAS fully loaded weighs less than 55 lbs., and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the sUAS.
An equivalentlevel ofsafety can be achieved bykeeping all documents prescribed by §91.715 (a) and (b) in the possession ofthe PIC during all flight operations. 

### 14 C.F.R. § 

### 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & 

### (b): Maintenance Inspections. These regulations require that an aircraft operator or owner**~~shall** have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph ( c ) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

....," and others shall inspect or maintain the aircraft in compliance with Part43. Given thatthese sections and Part43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished by the operatorpursuantto the flight manual and operatinghandbook. An

8 'equivalentlevel ofsafety will be achieved due to the fact these sUAS's are small in size and weight, and will operate only in restricted areas for limited periods oftime. The PIC will ensure thatthe sUAS is in properworking condition priorto each flight, and maintain the sUAS in accordance with the sUAS's manufacturer's manual. Operatorwill keep a maintenance log at all times. Summary. The Applicant is an FAA licensed Private Pilot with 500 hours ofPIC experience. Based on the satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012, Applicant believes there is more than adequatejustification for grantingthe requested exemption.

Henry

### JPeraza

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