Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 1 

### August 31, 2015

U.S. Department of Transpor tation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012



### Name and Address of Petitioner

Keith Wheeler, Owner Sky Drone Georgia, LLC

3555 Southlake Court Cumming, GA 30041 (770) 844-0159 kwheeler@skydronegeorgia.com



### Introduction

As set forth herein, to commercially operate small Unmanned Aircraft Systems (UAS) safely and legally in the National Airspace System (NAS), Keith Whee ler of Sky Drone Georgia, LLC, Cumming, Georgia seeks an exemption from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA

Modernization and Reform Act of 2012.

Section 333 states that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, operational capa city, proximity to airports and populated areas, and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security. The grant of such an exemption is consistent with Congress’ intent, reflected in Section 333, that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of these systems.

Being “unmanned aircraft and associated elements, including communication links and the components

that control the unmanned aircraft that are required for the pilot in command to operate safely and efficiently in the national airspace system,” Sk y Drone Georgia, LLC’s UAS meet the Section 331

definition of “small unmanned aircraft.”

Section 332 provides for such integration of civ il unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. We would like to operate our small UAS(s) prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft, thereby providing direct experience and valuable information for formal regulation.

Sky Drone Georgia, LLC intends to use small UAS to provide aerial photography and videography services to businesses, organizations and community members. See the Public Benefit section of this

document for more details. More specifically, we intend to:

 Enable businesses to improve marketing and outre ach through the use of state-of-the-art aerial photography and videography to help to inspect buildings and structures, and map landscapes in a safe, cost-effective manner.

 Provide economic stimulus and public benefit by providing an effective means by which companies or individuals can use up-to-date, high-quality photos and videos to learn about properties, neighborhoods and communities.

 Help communities realize economic benefit by encouraging public participation and encouraging tourism; by showcasing community buildings and landscapes; and by documenting community events in low-cost ways not prev iously available to them increase awareness/knowledge of the amenities of a local area by the general public and by visiting tourists.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 2  Provide non-profit organizations as well as sc hools and universities and local municipalities ways to showcase facilities, document events, and educ ate the public.

 Aid in search and rescue operations and accident investigators.

We understand that we are entit led to submit a Petition for Exemption if we believe that f ollowing a rule will burden us, we can provide a level of safety at leas t equal to that provided by the rule, and our request is in the public interest. Therefore we seek relief from the followi ng sections of the current regulations:

14 CFR 21 subpart H - Certification proc edures; Airworthiness Certificates 14 CFR 45.23 - Display of Marks 14 CFR 61.113 (a) & (b) Private P ilot Privileges and Limitations 14 CFR 91.105 Flight crew members at stations 14 CFR 91.109 (a) Flight instruction 14 CFR 91.119 (c) Minimum safe altitudes 14 CFR 91.121 - Altimeter settings 14 CFR 91.151 (a) - Fuel Requirements for Flight in VFR Conditions 14 CFR 91.203 Carrying Civil Aircraft Certification and Registration 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required; Operation after maintenance, preventive maintenance, rebuilding or alteration 14 CFR 91.417 (a) & (b) Maintenance Records 14 CFR 91.7 (a) - Civil Aircraft Airworthiness 14 CFR 91.9 (b) Civil aircraft flight m anual, marking, and placard requirements.

This application is similar to many which have received FAA approval. As stated in Exemption #11639,

the FAA has found that the enhanced sa fety achieved using an UAS with t he specifications described by herein, and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammabl e fuel, gives the FAA good cause to find that such exemption is in the public interest. Since we are applying at a time when the FAA is using a “summary grant process” be informed that while developing th is request we reviewed, among others, exemptions #11636, #11639, #11595, #11596, #11564, #11569, and #11616.



### Extent of Relief and Reason for Seeking Relief; Why the Exemption would not Adversely Affect Safety, or Ho w the Exemption would Provide a Level of Safety Equal to Existing Rule

Part 21 Airworthiness Certification; Subpart H Ce rtification procedures for products and parts,
Airworthiness Certificates

This section outlines requirements for the issue of design and production approvals, airworthiness certificates, and other airworthiness approvals. We seek relief from this rule because the size, weight and enclosed operational area of our UAS, as described elsewhere in this document, permit exemption from Part 21 because our UAS meet and exceed an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness ce rtificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Therefore, relief from 14 CFR part 21, and any associated noise cert ification and testing requirements of part 36, is not necessary.

Instead of following this requiremen t, we will as outlined in this document, as per our Flight Operations and Procedures Manual and Training Manual (currently in development), Sky Drone Georgia, LLC seeks to uphold the same level or exceeded level of safety as described in Part 21 of 14 C.F.R. Therefore this exemption will not adversely affect safety or will pr ovide a level of safety equal to the existing rule.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 3 14 CFR 45.23 Display of Marks

This section outlines regulations requiring specific loca tion(s) and size of aircraft marks. We seek relief from this rule because, given the size of our UAS, and the lack of cabin, cockpit or pilot station, two-inch lettering is difficult to place on such small aircraft. Instead of following this requirement, we will mark the UAS in lettering that is as large as practicable by placing an N number registered with the FAA on its fuselage so that the PIC, VO, or ot her observers will see the markings . This exemption will therefore not adversely affect safety or will provide a level of safety equal to the existing rule.

14 CFR 61.113 (a) & (b) Private P ilot Privileges and Limitations

This section describes regulations conc erning certification of pilots. We se ek relief from this rule because the risks associated with the operat ion of a UAS are lesser than and often uncorrelated with the risks

associated with the commercial and private aircraft operations contem plated by Part 61 when drafted. The skills required to fly large, m anned aircraft are substantially diffe rent from the skills required to remotely operate a small UAS. Also, manned aerial vehicles weighing significantly more than small drones (such as ultralight vehicl es) as well as small UAS legally oper ated by hobbyists, operate without the need for pilot certification. Re quiring a private or commercial pi lot certificate would provide no appreciable safety benefit and would needlessly impose an undue burden of time and cost on Sky Drone Georgia, LLC, most particularly in light of the F AA’s Small UAS Notice of Proposed Rulemaking which proposes that small UAS pilots be considered ‘opera tors’ required to meet certain requirements that do not include pilot’s license. Instead of following this requirement, to minimize risk and maximize safety, all UAS operations will be controlled and limited, and all flights will be planned and coordinated prior to operations:

 Prior to operations, Sky Drone Georgia, LLC’s PIC(s) will go through a documented process of dedicated ground school and flight lessons in acco rdance with manufacturer and industry guides.

 All PIC’s will only operate the UAS as stated in th is document and in our Flight Operations and Procedures Manual, flying at altit udes well below the permissible lim its for other civil aircraft, and within a geographical envelope under the control of Sky Drone Georgia, LLC clients.

 The PIC will be designated before a flight and will not tr ansfer control at any time during a flight.

 Sky Drone Georgia, LLC PICs will comply with upcoming FAA Operator Certification and Responsibilities once they are final ized. This exemption will theref ore not adversely affect safety or will provide a level of safety equal to the exis ting rule. More information about pilot safety can

be found in the Operation of the Unmanned Aircraft to Mi nimize Risk to the NAS, People and Property section of this document.

14 CFR 91.105 Flight crewmembers at stations This section outlines regulations for flight crewmember s inside an aircraft. We seek relief from this rule because there is no flight crew onboard a small UAS. Instead of following this requirement, in keeping with the direction of the regulati on, the PIC of the UAS and VO will be at their respective crewmember stations on the ground during takeoff and landing as well as the complete duration of the flight. By instituting this procedure this exempt ion will therefore not adversely affect safety or will provide a level of safety equal to the existing rule.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 4 14 CFR 91.109 (a) Flight Instruction

This section provides that no perso n may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unle ss that aircraft has fully functioning dual controls. We seek relief from this rule because UAS do not have fully functioning d ual controls. Instead, flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fu lly functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. This exemption will therefore not adverse ly affect safety or will provide a level of safe ty equal to the existing rule.

14 CFR 91.119 (c) Minimum safe altitudes: General.

This section establishes minimum altitudes for operati on of civil aircraft. We seek relief from this rule because the services we intend to provide for the public good may require photo or video images captured from an altitude of less than 500 feet. Inst ead of following this requir ement, all UAS flights will be conducted with within visual line of sight and with prior permission from the owner of the property or municipality. All persons, vessels, vehicles, not di rectly involved with the operation will be notified and cleared of the area where UAS operat ions will be conducted. Given our policies of advance notice and access restricted area, and given the size, weight, maneuverability and speed of our UAS, we will maintain an equivalent or higher level of safety of that described in this rule.

14 CFR 91.121 Altimeter settings

This section defines regulations for altimeter settings. We seek relief from this rule concerning altimeter settings because: our UAS has no altimeter settings. Instead, electronic GPS downlinks telemetry data in real time to the PIC’s ground-based on-screen disp lay as to the altitude (AGL) of the UAS above the takeoff location. This exemption will not adversely affect safety, as our PIC will provide a level of safety equal to the existing rule by confirming the altitude of the launch site shown on the GPS altitude indicator prior to each flight.

14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginni ng “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions ) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at l east 45 minutes.” We seek relief from this rule because our UAS runs on battery instead of fuel, most of our UAS flights last less than the 30 minute reserve requirement, and we do not fly at night. Instead of followi ng this requirement, an equivalent level of safety will be achieved by following the UAS manufacturer’s operating documents with r egard to battery voltage. To ensure safety and maintain adequate communication between radio control and the UAS, our PIC will not begin a flight with a battery holding less than 75% charge; and will not begin a flight unless (considering wind and forecast weather conditions) ther e is enough power to fly to the intended landing point at normal cruising speed and land the UAS wi th no less than 30% of battery power. A landing sequence will be initiated at the 30% warning and the UAS automatica lly initiates landing sequence at 15% charge while still under PIC control. Through implementation of these pr ocedures, this exemption will not adversely affect safety or will provi de a level of safety equal to the existing rule.

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certificat ion within an aircraft. We seek relief from this rule because our small UAS each weigh less than 10 pounds, and are operated without an onboard pilot. There are no passengers or crew; and no cabin or co ckpit entrance upon which to display certificates. An equivalent level of safety will be achieved by keeping these documents at the ground control point where
the PIC will have immediate ac cess to them, and be able to provide them upon request.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 5 14 CFR 91.405 (a) Maintenance required; 14 CFR 91.407 (a) (1) Operation after maintenance, preventive maintenance, rebuilding, or altera tion; 14 CFR 91.409 (a) (2) Inspections; and 14 CFR 91.417 (a) & (b) Maintenance records

We seek relief from these 4 rules because these regul ations only apply to aircraft with an airworthiness certificate, and will not, t herefore, apply to Sky Drone Georgia, LL C’s UAS. We seek relief also because the FAA has not developed maintenance standards for UAS that would allow a UAS operator to meet the part 91 maintenance requirements. In particular, t here are no individuals authorized by the FAA to approve a UAS for return to service or to conduct t he initial airworthiness and annual return to service inspections as required. Instead of following these requirements, we will:

 Perform preventative and required maintenance on each aircraft as per the owner’s manuals.

 Inspect our UAS before and after each flight as per our Flight Operations and Procedures Manual to ensure that the UAS is in a condition for safe flight.

 Will conduct a test f light on each aircraft following any major repairs.

 Will properly note all discr epancies, maintenance, and alterations in a Maintenance Log.

Therefore this exemption would not adversely affect sa fety or would provide a level of safety equal to the existing rule. More information about maintenan ce procedures can be found in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this document.

14 CFR 91.7 (a) Civil aircraft airworthiness

This section states that “no pers on may operate a civil aircraft unless it is in an airworthy condition.” We

seek relief from this rule based on the fact t hat Sky Drone Georgia, LLC’s UAS will not require an

airworthiness certificate in acco rdance with 14 CFR part 21, Subpar t H. Based on the fact that an

airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary. An equivalent level of safety will be achieved through the gui dance from our Flig ht Operations and Procedures Manual, pilot training, and operat ional risk management for each activity.

14 CFR 91.9 (b) Civil aircraft flight ma nual, marking, and placard requirements

This section requires an aircraft fli ght manual in the aircraft. We seek relief from this rule based on the
small size of our UAS and the fact that our UAS ca rries no onboard pilots or passengers. Given its size and configuration there is no room or capacity in our UAS to carry such an item. This regulation is therefore inapplicable. An equival ent level of compliance will be achi eved by keeping our versions of these documents at the ground contro l point where the PIC will have immediate access to them, and be able to provide them upon request.

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### Public Benefit: how our request would benefit the public as a whole

Granting Sky Drone Georgi a, LLC the ability to operate small U AS safely and legally in the National Airspace System will have the following positive ec onomic and societal impacts on local communities, businesses, organizations and community members:

 Benefit local business marketing by offering state-of-the-art aerial photography and videography.

 Help to inspect buildings and structures, and m ap landscapes in a safe, cost-effective manner.

 Provide economic stimulus and public benefit by providing an effective means by which companies or individuals looking to relocate to an area can use up-to-date, high-quality photos and videos of real estate properties to learn about properties, neighborhoods and communities.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 6  Help communities realize economic benefit by encouraging public participation and encouraging tourism by showcasing community buildings and landscapes and by documenting community events in low-cost ways not previously available to them.

 Increase awareness/knowledge of the amenities of a local area by the general public and by visiting tourists.

 Provide non-profit organizations as well as sc hools and universities and local municipalities ways to showcase facilities, document events, and educ ate the public.

 Aid in search and rescue operations and accident investigators.

All of the above services are ot herwise unavailable to the public, given the UAS’s the ability to:

 Safely capture images from 0 to 400 feet.

 Create images that are more up-to-date and more closely defined than Google Earth-type satellite images.

 Create images at prices lower than that of traditional helicopter and airplane photography and videography.

 Increase safety of and reduce risk to the public and the NAS by: - Replacing large manned helicopter and airpla ne flights with small UAS flights, thereby reducing air and noise pollution as well as the dangers inherent in flying aircraft loaded with crewmembers and combustible fuel close to people and property. - Offering safer ways to inspect tall structures and remote locations, e.g. removing the physical risk of climbing on a roof or structure to inspect it. - Reduce environmental pollution and reliance on foss il fuels by replacing fueled aircraft flights with battery-operated UAS flights.

Operation of the Unmanned Aircraft to Mini mize Risk to the NAS, People and Property

Concerning our commercial UAS flight operations, we take seriously our obligation to clearly define operational borders, and implement operational risk m anagement procedures to ensure the public safety of persons and property both in the air and on the ground. While Sky Drone Georgia, LLC currently provides photography and videography serv ices in the state of Georgia, we may at times contract with clients throughout the U.S. Our ar ea of intended operations include a range of population areas, from urban to rural, with some areas, especially coas tal ones, experiencing seasonal increases and decreases in activity from both people and aircraft. Our operatio ns will take into account these variations in populations and activities. Meeting or exceeding COA requirements to perform commercial operations in low-risk, controlled environment s, our UAS will be operated:

 During daytime Visual Flight Rules (VFR) conditi ons and visual meteorological conditions (VMC).

 Within visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual Observer (VO), in

accordance with the statutor y Section 333(b)(1) mandate.

 In such a manner that the PIC and VO are able to communicate verbally at all times; and that the VO can assist the PIC with seeing and avoi ding other air traffic and other ground-based

obstacles/obstructions.

We will not operate our UAS:

 At altitudes exceeding 400 feet AGL

 In winds exceeding 25 knots.

 From any moving vehicle or device.

 At airspeeds greater than the maxi mum recommended by the manufacturer.

 Less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less
than 3 statute miles from the PIC.

 Unless (considering wind and forecast weather conditions) there is enough available power for the UAS to conduct the intended operation and to oper ate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 7  Near areas where general public is within 200 fee t; or directly over any person except authorized Sky Drone Georgia, LLC personnel and consenting inspection personnel, unless operations nearer to the PIC do not present an undue hazard to those persons; or unless the owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safe ty assessment of the ri sk of operating closer to those objects and determined that it does not present an undue hazard.

 Near power lines, wind turbines, or elevated lights; or within areas of airspace restrictions such as the one imposed by the National Park Service.

 Near airports, heliports, or m ilitary bases; more specifically:

 I n accordance with the statutory Section 333 mandate rega rding proximity to airports, we will stay certain distances away from airports or helip orts: 5 NM from an airport having an operational control tower; or 3 NM from airport w/ a publis hed instrument flight procedure, but not operational tower; or 2 NM from an airport w/out published instrument flight proc edure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure.

 We will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA- published aeronautical chart, unless a letter of agreement with that airport’s management is obtai ned or otherwise permitted by a COA issued to the exemption holder. The letter of agreem ent with the airport management will be made available to the Administrator or any law enforcement official upon request.

 If we intend to conduct operations in controll ed airspaces which have existing requirements to notify Flight Standards Dist rict Offices (FSDOs) prior to operat ions – such as motion picture and television filming, or pipeline and powerline patrol – we will cont act the local FSDO and comply with their procedures, such as filing a NOTAM as per their request.

Our Flight Operations an d Procedures Manual, will in clude procedures for:

 Conducting a preflight safety risk assessment to det ermine that the UAS is in a condition for safe flight, i.e. completing a preflight inspection checklist to ensure the UAS’s airworthiness. If the inspection reveals a condition that affects t he safe operation of the UAS and/or the Ground Control Station, the aircraft w ill be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

 Maintaining a Flight Log (noting UAS flight time , Control Unit operation time, incident reports, etc.); and making said Log avail able to the FAA if requested.

 Conducting initial and ongoing training of PICs and VOs, to include classroom training, and training, proficiency and experience-building fli ghts; all persons not essential for flight

 Operations will be considered non participants, and the PI C will operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR 91.119.

 Evaluating the operational abilities of PICs and VOs on a regular basis.

Maintaining and repairing the aircraft to ensure t hat it is in a condition for safe operation by:

 Following the UAS manufacturer’s maintenance, overhaul,replacement inspection, and life limit requirements and safety bulletins for the aircraft and its components.

 Installing firmware updates provided by the manufacturer.

 Keeping a Maintenance Log noting all maintenanc e, inspection, alterations, and status of replacement/overhaul component parts in the aircra ft records, including total time in service, description of work, and signature of the authorized person return ing the UAS to service; and making said Log available to the FAA if requested.

 Verifying condition of flight batteries and calib rating the Inertial Measurement Unit (IMU) using

manufacturer software.

 Conducting a functional test flight on any UAS that has undergone maintenance or alterations that affect the UAS operation; said functional te st flight will be conducted by a PIC with a VO and so as to not pose an undue hazard to persons and property; and recorded in the aircraft records.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 8 Procedures that ensure that the planned oper ation can be completed safely, such as:

 Checking local sectional (air) charts, notam ( notice to airmen), etc. prior to the flight.

 Conducting a pre-flight visual su rvey of the area to consider characteristics of the area of intended operation(s) and the as sociated potential hazards regarding proximity to populated

areas.

 Remaining clear and giving way to all manned av iation operations and activities at all times.

 Aborting a flight and landing the UAS at the nearest and safest ground point in the event of safety breaches, potential danger, unpredicted obstacles or emergencies.

 Using a fresh, fully-charged battery with each fli ght as a safety precaution, to ensure safety and maintain adequate communication between radi o control and the UAS; and not operating our UAS at or below manufacturer recommend minimum charge levels for operation.

Also:

 Flight operations will be pe rformed only at the request of and with the authorization and permission of clients (property owner/cont roller) or their authori zed representatives.

 Caution signs will be placed at the site of aeria l operations to warn people that aircraft operations are in progress.

 Our Client Agreements will rese rve us the right to decline a phot o shoot if conditions of the location (e.g. proximity of power lines) may ca use unacceptable risk; and to reschedule a photo shoot if weather conditions such as pr ecipitation or wind speed become a factor.

 The operating documents for our UAS, and any revisions, will be ac cessible during UAS operations and made available to the Administra tor or law enforcement official upon request.

 We carry comprehensive general liability insura nce coverage and an additional insurance policy specifically covering our UAS.

Summary for Federal Register

Keith Wheeler of Sky Drone Georgia, LLC, Cumming, Georgia, seeks exemption from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012 for the purpose of commercially operating small Unmanned Aircraft Systems (UAS) safely and legally in the National Airspace System. Specifically, Sky Drone Geor gia, LLC seeks relief from the following sections of the current regulations: 14 CFR 21 subpart H - Certification proc edures; Airworthiness Certificates; 14 CFR 45.23 - Display of Marks; 14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations; 14 CFR 91.105 Flight crew members at stations; 14 CFR 91.109 (a) Flight instruction; 14 CFR 91.119 (c) Minimum safe altitudes; 14 CFR 91.121 - Altimeter settings; 14 CFR 91.151 (a) - Fuel Requirements for Flight in VFR Conditions; 14 CFR 91.203 Carrying Civil Aircraft Certification and Registration; 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91. 409 (a) (2) Maintenance required; Operation after maintenance, preventive maintena nce, rebuilding or alteration; 14 CFR 91.417 (a)&(b) Maintenance Records; 14 CFR 91.7 (a) - Civil Aircraft Airworthiness; 14 CFR 91.9 (b) Civil aircraft flight m anual, marking, and placard requirements.Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – Sky Drone Georgia - Page 9 Sky Drone Georgia, LLC intends to use small UAS to provide aerial photography and videography services to businesses, organizations and community members. More specifically, we intend to:

 Enable businesses to benefit through the use of state-of-the-art visual marketing materials.

 Help to inspect buildings and structures, and m ap landscapes in a safe, cost-effective manner

 Provide economic stimulus and public benefit by providing an effective means by which companies or individuals can use up-to-date, high-quality photos and videos to learn about properties, neighborhoods and communities

 Help communities realize economic benefit by encouraging public participation and encouraging tourism; by showcasing community buildings and landscapes; and by documenting community events in low-cost ways not previously available to them.

 Increase awareness/knowledge of the amenities of a local area by the general public and by visiting tourists.

 provide non-profit organizations as well as scho ols and universities and local municipalities ways to showcase facilities, document events, and educ ate the public

 Aid in search and rescue operations and accident investigators.

The enhanced safety achieved using an UAS with t he specifications described herein, and carrying no passengers or crew, rather than a manned aircraft of si gnificantly greater proportions, carrying crew in addition to flammable fuel, should give the FAA good ca use to find that such exemption is in the public

interest. By granting this request for exem ption, the FAA will facilitate the smooth integration of UAS into

the NAS.

Additional Information Design Characteristics, Aircraft Performance and Perf ormance Limitations, and Conditions of UAS to be Operated

UAS described below:

 Utilize 4 counter-rotating propellers for balance, control and stability.

 Are equipped with GPS to maintain geospatial orientation and position.

 Use Return Home safety technology and Auto Landing feature if UAS loses transmitter signal.

 Are controlled primarily through FCC approved RF spectrum transmitter/controller/receivers; and FCC approved RF spectrum EIRP with transmitting power of 100 mW for dedicated Wi-Fi transmitter/receiver between sUAS, Range Extende r attached to transmitter and mobile viewing device displaying operational telemetr y and video/photography functions.

 Send real time video and telemetry information is transmitted back to a ground control station, allowing PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle.

 Have failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum al titude can be preprogrammed by the PIC.

 Have audible and visual sequential low battery warnings set at 30% charge and 15% charge remaining. The sUAS automatically initiates landi ng sequence at 15% char ge while still under PIC control. The onboard flight cont roller will warn the pilot via tele metry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state.

 DJI Phantom 3 Professional

 Gross weight of less than 3 pounds including camera and battery

 Cruising speed of 15 knots, with a maximum speed of 31 knots and maximum altitude of 6000m

 Maximum flight time of 23 minutes

 FCC compliant Radio Frequency (RF) spectrum 2.400 GHz2.483 GHz



### Full Manual and Specification Sheet are attached.