P.O Box 788 • BEND, OR 97709 INFO@ELYLAW.COM • WWW.ELYLAW.COM

July 8, 2015

U.S. Department ofTransportation West Building Ground Floor, Room W12-140 1200 New JerseyAve., SE Washington DC 20590

Attn: Docket Operations 541-550-3026

RE: SKYCAM NW, LLC seeks Exemption RequestPursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations from: 14CFR 21 subpartH; 14CFR 45.23(b); 14 CFR 61.113(a)(b); 14 CFR 91.7(a); 14CFR 91.9(b)(2); 14CFR 91.103; 14 CFR 91.109; 14CFR 91.119(b)(c); 14 CFR 91.121; 14CFR 91.151(a); 14 CFR 91.203 (a)(b); 14CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) (2); 14CFR 91.417(a)(b)

Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11, SKYCAM NW, LLC, operator ofan Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation ofan UAS, as described will be equipped with camera(s) and sensors, would be operated in the following manner: 1. Aerial photography and/orvideo for public and/or private use including real estate, land survey, engineering, architecture and other related professional activities. 2. Aerial video and/or photographyfor public andjor private use including public events, news gathering and cinematography. 3. Aerial video/photography ofresidential and commercial structures under contract with owners ofprivate property or local government authority. 4. Aerial inspection ofresidential/commercial utility infrastructure including butnot limited to powerlines, cell towers, and wind turbines.

SKYCAM NW, LLC July 8, 2015 Page 1 of 105. Aerial video/photography assisting with search and rescue operations when local authorities or governmenthas requested. 6. The ability to offer trainingto persons individually or belongingto both private andjor public organizations that have interests in the use and application ofa UAS for the purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property.

As described in detail below, the requested exemption would permitthe operation ofa UAS under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industrypresentlyusing conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements for the safe operation of such aircraft systems in the national airspace system." Name and address ofapplicantis: SKYCAM NW, LLC Attn: Chandler P. Cocco, Director ofOperations 

### I ChiefPilot Ph: 925-595-8567 Email: chaddcocco@gmail.com Address: 61794 SE 27th Street, Bend, OR 97702 Regulations from which exemption is requested: 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (b) & (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) (1) & (2) 14 CFR 91.417 (a) & (b)

SKYCAM NW, LLC July 8, 20 IS Page 2 of 10SKYCAM NW, LLC will operate the DJI Inspire 1, Model T600, as well as the DJI Phantom 3 pro. The DJI Inspire 1 has a total weight of2935g or 6.47lbs. The dimensions ofthe DJI Inspire 1, Model T600 are 438mm x 451mm x 301mm or 17.24inch x 17.75 inch x 11.85 inch. Under calm air conditions maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJI Inspire 1 has the abilityto hover as well as move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6-cell4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345 will be in use. The DJI Inspire 1 will be controlled with the C1 remote controller using an operating frequency of 2.400GHz- 2.483GHz. The live video feed will have an operating frequency of5.728GHz5.850GHz. The applicantwill operatethe UAS in line ofsightwithin a closed offand predetermined area owned and/operated by the propertyrepresentative. SKYCAM NW, LLC will operatethe DJI Phantom 3 Professional which has a total weight of 1280gor 2.81lbs. The dimensions ofthe DJI Phantom 3 Professional are 400mm x 400mm x 270mm or 590mm diagonal including propellers. Under calm air conditions maximum speed is no more than 15.6m/s or 35 mph. The Phantom 3 Professional has the abilityto hover as well as move along a vertical orhorizontal plane simultaneously. The Phantom 3 Professional has 4 motors powered by a 4480mAh lithium polymer battery. There are four propellers, Propeller Model DJI 9450 will be in use. The Phantom 3 Professional will be controlled by Phantom 3 remote controller using operating frequency of2.400GHz2.483GHz. The live video feed will have an operating frequency of5.728GHz-5.850GHz. The applicant will operate the UAS in line ofsight within a closed offand predetermined area owned and/operated by the property representative. Given the small size ofthe UAS and the controlled environmentprovided the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including butnot limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or propertyusing conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as setforth in the Flight Operations Manual (FOM) include:

SKYCAM NW, LLC July 8, 2015 Page 3 of 101. The UAS will weigh less than 55 lbs. 2. The UAS will have a maximum operating speed ofno more than 50mph. 3. Flights will be operated within line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO). 4. Maximum flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% battery powerreserve or 25 minutes offlight time whichever occurs first. 5. Flights will be operated at an altitude ofno more than 400 feet Above Ground Level (AGL) or not more than 200 feet above an elevated platform from which filming is planned. 6. Minimum crewfor each operation will consist ofthe UAS Pilot, the Visual Observer (VO) and may include butnotlimited to a Camera Operator. 7. The UAS pilotwill be a designated Pilot in Command (PIC) and hold atleast a Private Pilot's License along with a Second orhigher Class Medical Certificate. If the PIC feels another operatorto be qualified with the necessary skills to be PIC & possess atleast a Private Pilot's License along with a Second or higher Class Medical Certificate, thatperson may be designated PIC provided theyhave a minimum of20 hours offlight time with the UAS. 8. Abriefingwill be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities. 9. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only. 10. The flights will occur no closer than a 5 mile radius ofthe geographic center

### IAirport Reference Point (ARP) ofa tower controlled or uncontrolled airport. 11. Ifoperations will be within a 5 mile radius ofthe geographic center

### IAirport Reference Point (ARP) ofa tower controlled or uncontrolled airportthe respective airports will be contacted advising them ofthe estimated flight time, flight duration, elevation offlight and other pertinentinformation. 12. The operatorwill file FAA Form 7711-1, orits equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours butno less than 48 hours from planned operation.

SKYCAM NW, LLC July 8, 2015 Page 4 of 1013. The operatorwill obtain verbaljwritten consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalentlevel ofsafety determination, as required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved. 14. The PIC and VO will have beentrained in operation ofUAS and receive up-todate information for the particular UAS to be operated. 15. The PIC and VO will be able to communicatebyvoice, radio, and/or text at all times. 16.Written and/orverbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies. 17. Ifthe UAS loses communications with the remote controller orloses GPS signal, the UAS will have the capabilityto return to a pre-determined location within a designated location and land autonomously. 18. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles, weather, or emergencies.

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 ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalentlevel 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 aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas of the particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be atleast as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusivelywithin a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored byboth the operator and

SKYCAM NW, LLC July 8, 2015 Page 5 of 10under the requirements and in compliance with local public safety requirements. The FAA will have advance notice ofall operations. These safety enhancements provide a greater degree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Furthermore, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted orlight-sport category aircraft or experimental or provisionally certificated aircraft, the operatormust also display on that aircraftnear each entranceto the cabin, cockpit, or pilot station, in letters notless than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entranceto the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, twoinch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided byhaving the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others workingwith the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private PilotPrivileges and Limitations: Pilot in Command. Pursuantto 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft thatis carrying passengers or propertyfor compensation orhire. SKYCAM NW, LLC may achieve an equivalentlevel ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots, passengers, or property. The risks attendantto the operation ofUAS is far less than the risk levels inherentin the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will have at least a Private Pilot's License along with a current Second Class or higher Medical exceeding the current safetylevels in relation to 14 CFR 61.113 (a) & (b). Ifeel the operation and limitations setforth in the FOM will equate to the safe operation ofthe UAS. 14 C.F.R. §91.7(a): Civil AircraftAirworthiness. 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

SKYCAM NW, LLC July 8, 20 IS Page 6 of 10airworthiness. Given the size ofthe aircraft for maintenance and use ofsafety check lists prior to each flight an equivalent level ofsafety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft. 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 UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not onlybecause there is no pilot on board, butbecause there is no room or capacityto carry such an item on the aircraft. The equivalentlevel ofsafetywill be maintained bykeepingthe flight manual atthe ground control pointwhere the pilotflying the UAS will have immediate access to it. 14 C.F.R. § 91.103: PreflightAction. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures includingbut notlimited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14 C.F.R. §91.109: Flight Instruction. Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) thatis beingused for flight instruction unless that aircrafthas fully functioning dual controls. UAS and remotely piloted aircraft, by their design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight trainingwithout fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalentlevel ofsafetyprovided by the fact that neither a pilotnor passengers will be carried in the aircraft andbythe size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS thatis a helicopter and the exemption requests authorityto operate ataltitudes up to 400 AGL, ornot more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the UAS will never operate athigher than 400

SKYCAM NW, LLC July 8, 20 I5 Page 7 of 10AGL with the exception that in circumstances where the UAS is used to survey or photograph a structurewhose height exceeds 400 feet AGL, the UAS will notbe operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted areawith securityperimeter, wherebuildings and people will notbe exposed to operations withouttheir pre-obtained consent. The equivalentlevel ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe permission of the property owner orlocal officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraftweightingfar more than the maximum 55lbs proposed herein and the lack offlammable fuel, anyrisk associated with these operations is far less than those presentlypresented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure."As the UAS may nothave a barometric altimeter, butinstead a GPS altitude read 

### out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the safety check list and live flight data monitoring, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 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) During the day, to fly after thatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least45 minutes." The batterypoweringthe UAS provides approximately 30 minutes ofpowered flight. To meetthe 30 minute reserve requirementin 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer time frame for flight in daylight ortwilightVFR conditions is reasonable. Applicant believes thatan exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled areawhere only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender the type ofrisks that Section

SKYCAM NW, LLC July 8, 20 IS Page 8 of 1091.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes thatan equivalent level ofsafety can be achieved by limiting flights to 30 minutes or 25% ofbatterypower- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operatingarea. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinentpart: (a) Except as provided in§ 91.715, no person may operate a civil aircraftunless ithas within itthe following: (1) An appropriate and current airworthiness certificate

.... (a) 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 thatit is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated withoutan onboard pilot. As such, there is no ability orplace to carry certification and registration documents or to display them on the UAS. An equivalentlevel ofsafetywill be achieved by keeping these documents at the ground control pointwhere the pilot flying the UAS will have immediate access to them, to the extentthey are applicable to the UAS.

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 E ofthis partand 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 that these section and Part43 apply only to aircraftwith an airworthiness certificate, these sections will not apply to the applicant. The operatorwill Maintenance will be accomplished by the operator pursuantto the flight manual and operatinghandbook. An equivalentlevel ofsafetywill be achieved because the UAS is verylimited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operatorwill ensure thatthe UAS is in working order priorto SKYCAM NW, LLC July 8, 20 IS Page 9 of 10initiating flight, perform required maintenance, and keep a log ofany 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 equivalentlevel of safety. An equivalentlevel ofsafetywill be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operatorwill ensurethatthe UAS is in working orderpriorto initiating flight and perform required maintenance needed. Additional Information Chandler P. Cocco, Director ofOperations and ChiefPilot ofSKYCAM NW, LLC is a current rotorcraft CFII with a current znct class medical. In addition, Mr. Cocco has been involved in the piloting ofremote controlled aircraft as a hobby for 4 years. Satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provide more than adequatejustification for the grant ofthe requested exemptions allowing the commercial operation ofthe applicant's UAS. Please do not hesitate to contact my office with any questions regarding this filing.

Dated: July 8, 2015 Respectfully submitted,

Sims Ely Attorney at Law

Counsel for Petitioner Sims Ely Ely Law Pro Corp P.O Box 788 Bend, OR 97709 (541) 550-3026 sims@elylaw.com Name andAddress ofPetitioner SKYCAM NW, LLC Attn: Chandler P. Cocco Director ofOperations / ChiefPilot 61794 SE 27th St. Bend, OR 97702 (925) 595-8567 chaddcocco@gmail.com

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