July 17, 2015

U.S. Department ofTransportation Docket Management System 1200 New JerseyAve. SE Washington, DC 20590
Petition of SkyVista Aerials for Exemption Pursuant to Section 333 of FAA Modernization and Reform Act of2012. 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 ofsmall unmanned aerial systems (UAS) pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 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 ofstructures, real estate photography and videography. SA’s operation underthe 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 ofthe DJI aerial photography/video equipment, with its state ofthe art avionics and electronics, allows the operatorfull remote control ofthe aircraft and camera. In the event ofsignal loss, the UAS will return to a preset position and land. In the event ofa low battery situation, the aircraft automatically performs a return to a preset position andlands. 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 ofthe aforementioned aircraft allow SA to provide and high value lower cost method ofacquiring 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) ofTitle 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 reliefthat 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 ofsight 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 ofthe aforementioned aircraft by: 1. Priorto flights, the PIC will inspect the UAto 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. Complywith 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 greaterthan 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 safetywith over 50 hours offlight 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 ofsafety that 91.121 requires, the PIC of SAwill 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 powerto fly at normal cruising speed to the intended landing point and land the UAwith 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 ofaircraft. Since there is not an airworthiness certificate for small UAS’s, SAwould comply in full to any conditions and limitations the Administratorwould place in orderto 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 ofsmall UAS’s, was, forthe most part, cost prohibitive. Signed:
John C. Adams SkyVista Aerials 1906 Lake Forest Dr. Huron, OH 44839