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 Transportation, 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 Wheeler 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 capacity, 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,” Sky Drone Georgia, LLC’s UAS meet the Section 331 

definition of “small unmanned aircraft.” 

Section 332 provides for such integration of civil 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 outreach 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 previously available to them increase awareness/knowledge of the 

amenities of a local area by the general public and by visiting tourists. 
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Sky Drone Georgia - Page 2

 Provide non-profit organizations as well as schools and universities and local municipalities ways 

to showcase facilities, document events, and educate the public. 

 Aid in search and rescue operations and accident investigators. 

We understand that we are entitled to submit a Petition for Exemption if we believe that following a rule 

will burden us, we can provide a level of safety at least equal to that provided by the rule, and our request 

is in the public interest. Therefore we seek relief from the following sections of the current regulations: 

14 CFR 21 subpart H - Certification procedures; 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 crewmembers 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 manual, 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 safety achieved using an UAS with the specifications described by 

herein, and carrying no passengers or crew, rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable 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 this 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 How the Exemption would Provide a Level of Safety Equal to 

Existing Rule 

Part 21 Airworthiness Certification; Subpart H Certification 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 certificate 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 certification and testing requirements of part 36, is not necessary. 

Instead of following this requirement, 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 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 3

14 CFR 45.23 Display of Marks 

This section outlines regulations requiring specific location(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 other 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 Pilot Privileges and Limitations 

This section describes regulations concerning certification of pilots. We seek relief from this rule because 

the risks associated with the operation of a UAS are lesser than and often uncorrelated with the risks 

associated with the commercial and private aircraft operations contemplated by Part 61 when drafted. 

The skills required to fly large, manned aircraft are substantially different from the skills required to 

remotely operate a small UAS. Also, manned aerial vehicles weighing significantly more than small 

drones (such as ultralight vehicles) as well as small UAS legally operated by hobbyists, operate without 

the need for pilot certification. Requiring a private or commercial pilot 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 FAA’s Small UAS Notice of Proposed Rulemaking which 

proposes that small UAS pilots be considered ‘operators’ 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 accordance with manufacturer and industry guides. 

 All PIC’s will only operate the UAS as stated in this document and in our Flight Operations and 

Procedures Manual, flying at altitudes well below the permissible limits 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 transfer control at any time during a flight. 

 Sky Drone Georgia, LLC PICs will comply with upcoming FAA Operator Certification and 

Responsibilities once they are finalized. This exemption will therefore not adversely affect safety 

or will provide a level of safety equal to the existing rule. More information about pilot safety 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 91.105 Flight crewmembers at stations 

This section outlines regulations for flight crewmembers 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 regulation, 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 exemption 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 person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. We seek relief from 

this rule because UAS do not have fully functioning dual 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 fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircraft. This exemption will therefore not adversely affect safety 

or will provide a level of safety equal to the existing rule. 

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

This section establishes minimum altitudes for operation 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. Instead of following this requirement, 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 directly involved with the operation will be notified and 

cleared of the area where UAS operations 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 display 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 beginning “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 least 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 following this requirement, an equivalent level of safety 

will be achieved by following the UAS manufacturer’s operating documents with regard 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) there is enough power to fly to the intended landing 

point at normal cruising speed and land the UAS with no less than 30% of battery power. A landing 

sequence will be initiated at the 30% warning and the UAS automatically initiates landing sequence at 

15% charge while still under PIC control. Through implementation of these procedures, this exemption 

will not adversely affect safety or will provide 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 certification 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 cockpit 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 access 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 alteration; 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 regulations only apply to aircraft with an airworthiness 

certificate, and will not, therefore, apply to Sky Drone Georgia, LLC’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, there are no individuals authorized by the FAA to 

approve a UAS for return to service or to conduct the 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 flight on each aircraft following any major repairs. 

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

Therefore this exemption would not adversely affect safety or would provide a level of safety equal to the 

existing rule. More information about maintenance 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 person may operate a civil aircraft unless it is in an airworthy condition.” We 

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

airworthiness certificate in accordance with 14 CFR part 21, Subpart 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 guidance from our Flight Operations and 

Procedures Manual, pilot training, and operational risk management for each activity. 

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

This section requires an aircraft flight manual in the aircraft. We seek relief from this rule based on the 

small size of our UAS and the fact that our UAS carries 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 equivalent level of compliance will be achieved by keeping our versions of 

these documents at the ground control 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 Georgia, LLC the ability to operate small UAS safely and legally in the National 

Airspace System will have the following positive economic 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 map 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 schools and universities and local municipalities ways 

to showcase facilities, document events, and educate the public. 

 Aid in search and rescue operations and accident investigators. 

All of the above services are otherwise 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 airplane 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 fossil fuels by replacing fueled aircraft flights 

with battery-operated UAS flights. 

Operation of the Unmanned Aircraft to Minimize 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 management 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 services in the state of Georgia, we may at times contract with 

clients throughout the U.S. Our area of intended operations include a range of population areas, from 

urban to rural, with some areas, especially coastal ones, experiencing seasonal increases and decreases 

in activity from both people and aircraft. Our operations will take into account these variations in 

populations and activities. Meeting or exceeding COA requirements to perform commercial operations in 

low-risk, controlled environments, our UAS will be operated: 

 During daytime Visual Flight Rules (VFR) conditions 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 statutory 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 avoiding 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 maximum 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 operate after that for at least 5 minutes or with 

the reserve power recommended by the manufacturer if greater. 
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Sky Drone Georgia - Page 7

 Near areas where general public is within 200 feet; 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 safety assessment of the risk 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 military bases; more specifically: 

 In accordance with the statutory Section 333 mandate regarding proximity to airports, we will stay 

certain distances away from airports or heliports: 5 NM from an airport having an operational 

control tower; or 3 NM from airport w/ a published instrument flight procedure, but not operational 

tower; or 2 NM from an airport w/out published instrument flight procedure 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 obtained or otherwise permitted by a COA issued to 

the exemption holder. The letter of agreement 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 controlled airspaces which have existing requirements to 

notify Flight Standards District Offices (FSDOs) prior to operations – such as motion picture and 

television filming, or pipeline and powerline patrol – we will contact the local FSDO and comply 

with their procedures, such as filing a NOTAM as per their request. 

Our Flight Operations and Procedures Manual, will include procedures for: 

 Conducting a preflight safety risk assessment to determine 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 the safe operation of the UAS and/or the Ground 

Control Station, the aircraft will 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 available to the FAA if requested. 

 Conducting initial and ongoing training of PICs and VOs, to include classroom training, and 

training, proficiency and experience-building flights; all persons not essential for flight 

 Operations will be considered nonparticipants, and the PIC 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 that 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 maintenance, inspection, alterations, and status of 

replacement/overhaul component parts in the aircraft records, including total time in service, 

description of work, and signature of the authorized person returning the UAS to service; and 

making said Log available to the FAA if requested. 

 Verifying condition of flight batteries and calibrating 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 test 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 operation 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 survey of the area to consider characteristics of the area of 

intended operation(s) and the associated potential hazards regarding proximity to populated 

areas. 

 Remaining clear and giving way to all manned aviation 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 flight as a safety precaution, to ensure safety and 

maintain adequate communication between radio control and the UAS; and not operating our 

UAS at or below manufacturer recommend minimum charge levels for operation. 

Also: 

 Flight operations will be performed only at the request of and with the authorization and 

permission of clients (property owner/controller) or their authorized representatives. 

 Caution signs will be placed at the site of aerial operations to warn people that aircraft operations 

are in progress. 

 Our Client Agreements will reserve us the right to decline a photo shoot if conditions of the 

location (e.g. proximity of power lines) may cause unacceptable risk; and to reschedule a photo 

shoot if weather conditions such as precipitation or wind speed become a factor. 

 The operating documents for our UAS, and any revisions, will be accessible during UAS 

operations and made available to the Administrator or law enforcement official upon request. 

 We carry comprehensive general liability insurance 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 Georgia, LLC seeks relief from the following sections 

of the current regulations: 

14 CFR 21 subpart H - Certification procedures; 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 crewmembers 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 manual, marking, and placard requirements. 
Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012 – 

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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 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 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 schools and universities and local municipalities ways 

to showcase facilities, document events, and educate the public 

 Aid in search and rescue operations and accident investigators. 

The enhanced safety achieved using an UAS with the specifications described herein, and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, should give the FAA good cause to find that such exemption is in the public 

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

the NAS. 

Additional Information 

Design Characteristics, Aircraft Performance and Performance 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 Extender attached to transmitter and mobile viewing 

device displaying operational telemetry 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 altitude 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 landing sequence at 15% charge while still under PIC 

control. The onboard flight controller will warn the pilot via telemetry 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.