July 17, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Petition of SkyVista Aerials for Exemption Pursuant to Section 333 of FAA

Modernization and Reform Act of 2012.

SkyVista Aerials

John C. Adams

1906 Lake Forest Dr.

Huron, OH 44839

419-239-3429

skyvistaaerials@gmail.com

To Whom it may concern:

SkyVista Aerials (SA) hereby applies for an exemption from Federal Aviation

Regulations (FAR) outlined below, to allow commercial use and operations of small

unmanned aerial systems (UAS) pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 and 14 CFR Part 11.

This exemption is in accordance with protocols outlined in this petition for exemption.

SA respectfully requests a waiver on the 45-day comment period, as this application is

identical in description to other Section 333 Exemptions that have already been granted.

This exemption would permit commercial operations by SA, to use the DJI Phantom 3

and the DJI Inspire 1, which meet the definition of “small unmanned aircraft” as defined

in Section 331, to conduct aerial photography and videography, agricultural assessment

of crops and data collection, news gathering, training and education, support services

for public entities, inspections and assessments of structures, real estate photography

and videography. SA’s operation under the exemption will be subject to the specific

operating guidelines and requirements set forth in the regulations, as required by the

FAA in Section 333.

The use of the DJI aerial photography/video equipment, with its state of the art avionics

and electronics, allows the operator full remote control of the aircraft and camera. In the

event of signal loss, the UAS will return to a preset position and land. In the event of a

low battery situation, the aircraft automatically performs a return to a preset position and
lands. Both aircrafts, weighing below 7 pounds, are well within the 55 pound limitation

and operate at speed well below 50 knots.

Public Benefit:

Due to the progress, trustworthiness and safety of UAS’s, the use of the aforementioned

aircraft allow SA to provide and high value lower cost method of acquiring high definition

photography and videography. Due to the small size and lack of combustible fuel, when

compared to manned aircraft, this operation will pose no threat to the public.

Request: An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.40(a), 91.407(a)(1),

91.409(a)(2), and (b) of Title 14, Code of Federal Regulations (14 CFR) was granted to

Ralph J. Apel in Exemption No. 11410.

Petition: I request an exemption from TITLE 14 OF THE CODE OF FEDERAL

REGULATIONS SECTIONS 61.113 (a) and (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b).

The extent of relief that SA seeks regarding:

Section 61.113 (a) and (b) - To allow a Pilot in Command (PIC) to operate the

aforementioned aircraft accompanied by a Visual Observer (VO) who, along with the

PIC, will maintain visual line of sight with the aircraft at all times. The aforementioned

aircraft are not able to carry passengers.

Section 91.7 (a) To allow SA to determine airworthiness of the aforementioned aircraft

by:

1. Prior to flights, the PIC will inspect the UA to ensure it is in a condition that will

be conducive for safe flight.

2. Follow the DJI aircraft/component maintenance, overhaul, replacement,

inspection and life limit requirements.

3. Comply with all DJI manufacturer safety bulletins.

Section 91.119 To allow SA to operate the aforementioned aircraft at altitudes not to

exceed 400’ AGL over private property at a distance at or greater than 5NM from

operational/active airports.

Safety

The aforementioned aircraft will not be operated at a speed to exceed 50 knots. SA’s

sole proprietor, John C. Adams has experience with various models of DJI quadcopters

and is proficient in their operations, limitations and safety with over 50 hours of flight

time.

Section 91.121 Relief is requested due to the fact that the aforementioned aircraft utilize

electronic GPS with a barometric sensor. To maintain the level of safety that 91.121

requires, the PIC of SA will abort the flight in the event that the UA loses communication

with the GPS signal.
Section 91.151(b) To allow SA to operate the aforementioned aircraft up to a point

(considering wind and forecast weather conditions) that there is enough power to fly at

normal cruising speed to the intended landing point and land the UA with 30% battery

remaining.

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), 91417(a) and (b) These are

all associated with an Airworthiness Certificate. Relief is requested to the extent that

allows SA to operate the aforementioned aircraft as necessary. These sections are

related to airworthiness certificates of aircraft. Since there is not an airworthiness

certificate for small UAS’s, SA would comply in full to any conditions and limitations the

Administrator would place in order to receive an approved Grant of Exemption.

Conclusion:

SA seeks exemption to the aforementioned Sections and Regulations to provide an

aerial photography/video service, in compliance with Section 333, to businesses and

individuals that before the advent of small UAS’s, was, for the most part, cost

prohibitive.

Signed:

John C. Adams

SkyVista Aerials

1906 Lake Forest Dr.

Huron, OH 44839