1

FROM: RYAN RUSH SKY VIEW U.A.S., L .L .C. 3545 RED PONTIAC DRIVE PORT ORANGE, FL 32129 Tel: 860
- 977
- 3181 Email: rush.ry an.c@gmail.com TO: DOCKET OPERATIONS ROOM W12
- 140 OF THE WEST BUILDING GROUND FLOOR 1200 NEW JE RSEY AVENUE, SE. WASHI NGTON, DC, 20590 REGULATORY DOCKET NO: _____________________________

PETI TI ON FOR EXEMPTI ON OF: SKY VIEW U.A.S., LLC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERALREGULATIONS PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATI ON OF DJ I IN SPIRE 1 PROFESSI ONALUNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112
- 95)

SUBMITTED ON JUNE 15, 20152

. TABLE OF CONTENTS GLOSSARY OF ABBREVIATIONS........................................................................................
.... .3 S UMMARY.......................................................................................................................
......... .... .4 IN TRODUCTION AND INTERESTS OF PETITIONER........................................................
.... .4 BACKGROUND
........................................................................................................................ .... .4 BASI S FOR PETITION...........................................................................................................
.. . ....6 NAME AND ADDRESS OF PETITIONER...............................................................................
.... 9 THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH SKY VIEW UAS, LLC SEEKS EXEMPTION......................................................
................................................................. ..... ......9 THE EXTENT OF RELIEF SKY VIEW UAS, LLC SEEKS AND THE REASON SKY VIEW UAS, LLC SEEKS THE RELIEF...........
. ........................................ .. 14 THE REASONS WHY GRANTING SKY VIEW UAS, LL C REQUEST WOULD BE IN THE PUBLIC INTEREST ..........................................................................
... .1 8 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY.....................
....................................................... .................... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER.........................
.. 38 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS CONCLUSION...................................
............................................................ ............................... 393 GLOSSARY OF ABBREVIATIONS AGL
- Above Ground Level AOI
- Area of Interest ATC
- Air Traffic Control ATO
- Air Traffic Organization AV
- Aerial Vehicl e CFR
- Code of Federal Regulations COA
- Certificate of Authorization FAA
- Federal Aviation Administration FAR
- Federal Aviation Regulation GCS
- Ground Control Station GPS
- Global Positioning Sy stem LOL
- Loss of Link NAS
- National Airspace Sy stem NOTAM
- Notice to Airman PI C
- Pilot In Command Section 333
- FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO
- Safet y Observer SOP
- Standard Operating Procedures UA
- Unmanned Aircraft UAS
- Unmanned Aircraft Sy stem VFR
- Visual Flight Rules VLOS
- Visual L ine of Site VMC
- Visual Meteorological Conditions VTOL
- Vertical Takeoff and Landing4

**SUMMARY** Sky View U.A.S., LL C (Ry an Rush) seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Sky View U.A.S., LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpo se of conducting aerial video, photograph y and data collection of Real Estate Properties (for homeowners, realtors, home builders, home contractors and/ or home insp ectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape, conducting water, electrical and oil utility structure inspections, aerial mapping, s urveying and search and rescue and similar operations throughout the United States of America. **INTRODUCTION AND INTERESTS OF THE PETITIONER** Sky View UAS, LLC is a data collection compan y based in Florida looking to conduct UAV operations for real estate videograph y, photography, music video production, special event production and film and television production for the purpose of industrial, agricultural and entertainment purposes. The owner (Ry an Rush) of Sky View UAS has extensive fixed
- wing aeronautica l experience, having been in the aviation industry for over ten years. The primary concerns of Sky

View UAS is safety

as well as complete cooperation with the FAA and other controlling agencies. The intentions of Sky View UAS, LLC is to establish and maint ain a mutually beneficial relations hip with the FAA and operate UA ’s within the NAS. The primary objective of Sky

View UAS is to conduct aerial photography , videograph y and data collection in5

order to provide high quality digital imaging and video content to its clients, in particular to homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate marketing and inspections of home exteriors, various agricultural applications as well as filming of special events, film sets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial mapping, surveying and search and rescue utilizing DJ I Inspire1 UAS platforms. More specifically , Sky View UAS, LLC operations will serve in the following areas:

 Aerial photograph y of houses / residential and commercial buildings, power lines and other infrastructure

 Aerial videograph y of houses / residential and commercial buildings, power lines and other infrastructure

 Aerial event photograph y

 Aerial event filming

 Aerial Film & Television production

 Aerial data collection for construction and agricultural applications

 Aerial search and rescue operations

 Aerial safet y inspections of houses / residential and commercial b uildings, power lines and other infrastructure

 In crease public knowledge of UAS and promote safe UAS operations.

 Work to help integrate unmanned aerial s ys tems into FAA governed NAS6

**Unmanned Aircraft Systems: DJI Inspire 1 UAS** Sky View UAS, LLC (Ry an Rus h) seeks an exemption to operate DJ I sy stems DRONES for compensation or hire within the NAS. The DJ I Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The DJ I Inspire 1 UA have a maximum gross weight of approximately 6.5 pounds, while having a length of 17 inches width of 18 inches, height of 12 inches, and a maximum speed of approximately 42 knots. The DJIInspire 1 UA is equipped with four mai n rotors; driven b y Li thium Poly mer battery

powered electric motors. The DJI Inspire 1 UA that will be operated b y Sk y View UAS, LLC (trained professional), will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F. R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. **BASIS FOR PETITION** Petitioner, Sky

View UAS, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.6 1) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to commerciall y operate the DJIInspire 1 UA in the National Airspace Sy stem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.119(b) & (c), 91.121, 91.151(b), 91.203(2)(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limite d operating area associated with the unmanned aircraft and its operation, Sky View UAS, LLC operation of DJ I Inspire 1 UA meets7

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Par t 21, Subpart H. Accordingl y, Sk y View UAS, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness c ertificate. Sky View UAS, LLC submits that the requested relief is proper since an equivalent level of safety will be ensured and complied with. Sky

View UAS, LLC will use experienced and trained personnel or technicians to perform maintenance, alterations , or preventive maintenance on the UA using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermore, Sky View UAS, LLC will document and maintain all ma intenance and modification records for the DJ I Inspire 1 UA. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations : Pilot In Command, is requested by Sky View UAS, LL C to the extent necessary to a llow a Pilot in Command (PI C) to be any personnel listed under the company ’s list of
authorized operators, and that have demonstrated proficiency , and that the PI C is able to safely operate the DJ I Inspire 1 UA in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures not subject to inspections. Sky View UAS, LLC will maintain training records and proficiency

records of all authorized operators. Sky View UAS, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJ I Inspire 1 UA do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Sky View UAS, LLC submits that it will ensure that the DJ I8

Inspire 1 UA are in an airworthy condition, prior to every

flight, by determining that the UAS’s are in compliance with the operating documents (i.e., Monthly Maintenance L og, and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight in accordance with the manufacturer's’ operation s manuals. Sky View UAS, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJIInspire 1 UA will not have a conventional barometric altimeter installed onboard. However, altitude information of the D JIInspire 1 UA will be provided to the PI C via Global Positioning S ys tem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Sky View UAS, LLC’s operation of the DJ I Inspire 1 UA within visual line of sight (VLOS), as well as at or below 4 00 feet AGL or as required in the vicinity of structural inspection operations, not to exceed 100 feet above structure or 500 feet laterall y from base of structure, will ensure a level of safet y equivalent to Section 91.121. Sky View UAS, LLC believes additional exemption for altitudes in excess of 400 feet AGL is acceptable in the vicinity of structures subject to inspection due to the neglig ible effects that it will have on NAS operations. Aircraft operating in the NAS are required to maintain a minimum vertical and lateral separation of 500 to 1,000 feet verticall y and 1,000 to 2,000 feet horizontally from all structures depending on the con gestion of the area
. Additionally , Sky

View UAS, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Sky View UAS, LLC submits that safet y will not be affected b y operation of the DJ I Inspire 1 UA during daylight hours maintaining visual contact with the UAS, with enough battery power to fly for a total duration of9

approximately

10 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that fo r at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Sky View UAS, LLC provides the following information in support of its petition for exemption: A. Name and Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: Ry an Rush Sky View UAS, LLC 3545 Red Pontiac Drive Port Orange, FL 32129 Tel: 860
- 977
- 3181 Email: rush.ry an.c@gmail.com B. The Specific Sections of 14 C.F.R. From W hich Sky View UAS, LLC Seeks Exemption. 1. Sky View UAS, LL C Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; n or may that person, for compensation or hire, act as PI C of an aircraft. (b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.10

2 . Sky View UAS, LL C Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. 3 . Sky View UAS, LL C Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the follow ing, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating
-- (1) Below 18,000 feet MSL , to -- (i) The current repo rted altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate avai lable station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. Sky View UAS, LLC for Exemption Page 10 4 . Sky View UAS, LL C Seeks Exemp tion From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may

begin a flight in a rotorcraft 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, to fl y after that for at least 20 minutes.11

5
. Sky View UAS, LL C Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft i nspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 6 . Sky View UAS, LL C Seeks Exemption Fro m The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless
-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]
7 . Sky View UAS, LL C Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

– (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.12

8 . Sky View UAS, LL C Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance w ith §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100
- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include
-- (i) A description (or reference to data a cceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the followin g information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life
- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft an d its appliances are maintained.13

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safet y directive inv olves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b ) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retain ed and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent Of Relief Sky View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks The Relief. 1. Extent Of Relief Sky

View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks Relief From Section 61.113(a) And (b). Relief from Sectio n 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a Pilot in Command (PI C) to mean any operator listed under the compan y’s list of authorized operators, an d has demonstrat ed proficiency

and currency requirements, and that the PI C is able to safel y operate the DJ I Inspire14

1 UA in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehi cles and structures not subject to inspections. PI C shall maintain, at a minimum, a current and valid third
- class airman medical certificate, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitat ions set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ ment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry

passengers or propert y for compensation or hire. As set forth more full y below, Sky

View UAS, LLC submits that an equivalent level of safet y will be maintained because no PIC will be allowed to operate the DJ I Inspire 1 UA unless th at PI C has met certain proficiency

requirements, demonstrating that the PI C is able to safely operate the DJ I Inspire 1 UA in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Sky View UAS, LLC submits that all flights of the DJ I Inspire 1 UA conducted b y the PI C pursuant to the grant of this Petition: (1) will be incidental to S ky

View UAS, LLC business; and (2) will not carry passengers or propert y for compensation or hire. Sky View UAS, LLC believes that though UAS are not traditional aircrafts, a PIC operating the UA must have adequate knowledge of airman rules, basic airspace knowledge and be able to comply with all the rules proposed by the FAA. However, considering the fact that a UA is similar in nature to a to y, weighing very little and risks associated with their operations are drastically less, the PI C may be exempt from obtaining a Private Pilot Certificate, a Sports Certificate, or a Recreational Certificate, considering these certificates require extensive15

flight training in aircraft that far exceed complexity of operations and grossly outweigh that of a UA. Lastl y, Sk y View UAS, LLC PICs will operate the UAS no higher than 4 00 feet unless in the vicinity of structures under inspection, not to exceed 100 feet above the highest point of the structure and not exceeding a lateral limitation of 500 feet from the b ase of the structure, consequentl y causing no danger to an y other aircraft in the NAS. However, Sky View UAS, LLC Proposes that all authorized operators acting as PIC must demonstrate proficiency and a minimum requirement of successfull y completed private pilot knowledge examination within 24 calendar months. Sky

View UAS, LLC will maintain training records and proficiency records of all named operators. 2. Extent of Relief Sky

View UAS, LL C Seeks and the Reason Sky View UAS, LLC Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Sky View UAS, LLC to determine that the DJ I Inspire 1 UA are in airworth y condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Sky View UAS, LLC Aerial Operations Manual, Monthly maintenance Log, and DJ I Inspire 1 UA Instruction Manual). Sky View UAS, LLC seeks the requested relief because the DJ I Inspire 1 UA do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Sky View UAS, LLC will ensure that the DJ I Inspire 1 UA are in airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJ I Inspire 1 UA Instruction Manual) prior to every flight, and16

further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.
3. Extent Of Relief Sky

View UAS, LLC Seeks And The Reason S ky View UAS, LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Inspire 1 UA which utilize a barometric pressure sensor, GPS equipment, and a radio communic ations telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above gr ound level (AGL), Sk y View UAS, LLC seeks the requested relief because the DJ I Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited alti tude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safet y will be maintained since the D JIInspire 1 UA are not equipped with a barometric pressure sensor rather GPS equipment, and provides the PI C with altitude information of the UA on the heads
- up display of the GCS.17

4. Extent Of Relief Sky

View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the batte ry powered DJ I Inspire 1 UA during daylight hours in visual meteorological conditions (VMC), for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Sky

View UAS, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Inspire 1 UA will severel y constrain the practicality of any aerial video or still photo flight operations that Sky View UAS, LLC proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UA operating documents, and Sky View UAS, LLC proposed operating limitations, ensure that Sky View UAS, LLC will safel y operate the battery powered DJ I Inspire 1 UA , during daylight hours in visual meteorological conditions (VMC), with enough battery power to fl y for a total duration of no less than 10 minutes to the first point of intended landing and, assumin g normal cruising speed, to fl y after that for at least 4.5 minutes. 5. Extent Of Relief Sky

View UAS, LLC Seeks And The Reason Sky View UAS, LLC Seeks Relief From Section 91.405(a), 91.407(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y appl y to aircraft with an airworthiness certificate, Sky View UAS, LLC requests relief from these Sections because the DJ I Inspire 1 UA does not require airworthiness certificates. As set forth18

more fully

below, the DJI Inspire 1 UA meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Sky View UAS, LLC will use trained technicians to perform maintenance, alterations, or preventative maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e. the Sky View UAS, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJIInspire 1 UA Instruction Manual). Furthermore, Sky View UAS, LLC will document and maintain all maintenance records for the DJ I Inspire 1 UA. D. The Reasons Why Granting Sky View UAS, LLC Request Would Be In The Public Interest; That Is, How It W

ould Benefit The Public As A W hole. Granting the present Petition will furth er the public interest b y allowing Sky View UAS, LLC to safel y, efficientl y, and economically perform aerial video, photograph y and data collection of real estate, special events, film sets, and landscape throughout the United States. Additionally , use of the DJ I Inspire 1 UA will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notabl y, the benefits of Sky View UAS, LLC’s proposed operation of the DJ I Inspire 1 UA will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJ I Inspire 1 UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Inspire 1 UA would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground.19

Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJ I Inspire 1 UA do not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.
2. The Public Will Benefit From The Safet y And Efficiency Of The DJ I In spire 1 UAS. Conducting aerial acquisitions with the DJIInspire 1 UA instead of manned aircraft, will greatl y benefit the public b y drastically reducing the levels of air and noise pollution generated during traditional aerial video and still pho tograph y flight operations. By using battery power and electric motors, the DJ I Inspire 1 UA produce no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, internal combustion engine aircraft that are t ypicall y utilized for aerial video and photography , while burning approximately 10
- 30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UA while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 UA to perform aerial data collection, the substantial risk to life and property in the air and on the ground, which is usually associated with tradit ional manned aircraft flight operations, will be substantially

reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Inspire 1 UA (weighing approximately 6.5 pounds, at their maximum gross weights with lengths of 17 inches, widths of 18 inches, and with no combustible fuel on board), has less ph ys ical potential for collateral damage to life and20

propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 4,000 pounds and a significantly higher fuel capacity). Additionally , expressed public concern over the safet y and stability of lithium ion/ LIPO batteries is negligible in comparison to the risk associated with the same battery t ypes being present and allowable onboard commercial airliners. 3. Performing Aerial Video, Photograph y and Data Collection Operations With The DJI Inspire 1 UA Will Benefit The Economy
. In addition to the increase safet y to the public and effic iency of the operations, the DJ I Inspire 1 UA is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UA will allow United States based companies, like Sky

View UAS, LLC, to r emain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and the Environmental Protection Agency

(“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered DJ I Inspire 1 UA is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexib ility without the high operational cost of a traditional manned aircraft. By operating the DJ I Inspire 1 UA companies such as Sky View UAS, LLC, can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractor s, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S. companies, through commercial use of the DJ I Inspire 1 UA provides a stable workforce that increases consumer spending; improves local, state, and fed eral tax revenues; and allows companies to21

invest in research and development in order to remain competitive both in the United States and abroad. 4. There Are No Privacy

I ssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Sky View UAS, LLC proposed operation of the DJIInspire 1 UA will not implicate any privacy issues. Specificall y, the DJIInspire 1 UA will be operated onl y in compliance with operating documents (i.e., the Sky View UAS, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJ I Inspire 1 UA Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum alt itude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Sky View UAS, LLC Seeks Exemption. 1. Reasons Why

The DJ I In spire 1 UA M eet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Sky View UAS, LLC, operation of the DJ I Inspire 1 UA meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a22

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y. Specifically, FMRA Section 333 states the following, in part: (a) In General.
-- Notwithstanding an y other requirement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem before completion of the plan and rule
- making required by section 332 of this Act or the guidance required b y Section 334 of this Act. (b) Assessment of Unmanned Aircraft S ys tems. -- In making the determination under subsection (a), the Secretary

shall determine, at a minimum
-- (1) which t ypes of unmanned aircraft s ys tems, if any , as a result of their size, weight, speed, operational capability , proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national a irspace s ys tem or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft s ys tems identified under paragraph (1). (c) Requirements for Safe Operation.
-- If the Secretary determines under this section that certain unmanned aircraft s ys tems may operate safel y in the national airspace s ys tem, the Secretary shall establish requirements for the safe operation of such aircra ft s ys tems in the national airspace sy stem. In seeking this exemption, Sky View UAS, LL C submits that the DJ I Inspire 1 UA, can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated b y: (a) the characteristics of the DJ I Inspire 1 UA ;23

(b) the pilot certification requirement; and (c) the specific operating limitations.
**a. The Specifications Of The DJI Inspire 1 UA Demonstrate Its Safe Characteristics.** The DJ I Inspire 1 UA does not create a hazard to users of the NAS or the public, o r otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability. i. Technical Specifications Of The DJ I Inspire 1 UAS. The technical specifications of the DJ I Inspire 1 UA is set forth b y the DJI Inspire 1 UA Specifications and Data Sheet, attached hereto as Exhibit A. ii. The DJ I Inspire 1 UA Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area based on United States governments Global Positioning Sy stem. The DJ I Inspire 1 UA may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Inspire 1 UA is provided at pages 12
- 17 of the DJ I In spire 1 UA User Manual
. Autonomous operations allow operators to apply forethought and plan operations more strategically to minimize potential for conflicts. iii. The DJIInspire 1 UA Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Li nk Or Navigation. When the Control L ink is lost, the DJIInspire 1 UA will remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 UA does not reacquire control link data from the GCS, the UAS will assume that the C ontrol L ink is lost and the UA will return to the24

home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the D JIInspire 1 UA are set forth
on page 15 of the D JIInspire 1 UA User Manual. iv. The DJ I Inspire 1 UA GCS And Its Operation. A complete description of the operation and specifications of the DJ I Inspire 1 UA, and flight control software is provided at pages 32 through 43 of the DJ I Inspire 1 UA User Manual. DJ I Inspire 1 UA User Manual is attached hereto as Exhibit B & D. **b. Flight Operations Of DJI Inspire 1 UA Are Limited To The Line Of Sight Of A Certificated Pilot in Command.**  Sky View UAS, LLC will only allow authorized operators to operate the UA by visual reference not to exceed line
- of

- sight. All authorized operators will possess, at minimum, a current and valid third
- class airman medical certificate to act as a pilot in command (PIC) of the DJ I Inspire 1 UA. **c. Flights Of DJI Inspire 1 UA Will Be Conducted Pursuant To Specific Operating**  **Limitations.** In seeking this exemption, Sky View UAS, LL C proposes to commercially operate DJ I Inspire 1 UA for the special purpose of conducting aerial video , photograph y and data collection throughout the United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum25

gross weight: DJ I Inspire 1 UAS. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant of exemption. 2. UAS operations under this exemption will be limited to conducting operations f or the purpose of aerial video, photography and d ata collection for homeowners, r ealtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspectio ns. Additionally , aerial video, photograph y and data collection may be conduct ed for film and television sets, special events and landscape photography , conducting power line and infrastructure inspection, aerial mapping, surveying as deemed necessary
. 3. The UAS may

not be flown at an indicated airspeed exceeding 42 knots. 4. T he UAS must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless in the vicinity of structural inspection operations, not to exceed 100 feet above structure or 500 feet laterally from base of structure. If inspected structures are within a 5 nautical mile radius of an airport, Sky View UAS, LLC will seek issuance of a NOTAM and will maintain contact with any controlling facility , advising of commencement and completion of operations. All altitudes must be reported to ATC within a 5 nautical mile radius from center point of an y controlled airport. Altitudes must be reported in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA
- issued airman medical certificate.26

6. The use of first person view (FPV) b y the PI C or safet y observer ( SO) is not permitted for navigation purposes. Use of FPV will only be to aid in situational awareness. 7. All operations may

utilize a safet y observer (SO) if deemed appropriate to meet the needs of the operation and ensure safet y. The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . The SO and PI C must be able to communicate verball y at all times. Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties bey ond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and a cop y of the grant of exemption must be accessible during UAS operations and made available to the Administrator or law enforcement upon request. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the pr ocedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator m ay update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitio ns for extension or amendment to the grant of exemption. If the operator determines that an y update or revision would affect the basis upon27

which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS
- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspectio n reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be inc luded in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre
- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s airc raft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspectio n, alterations, and status of28

replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must be listed on the company record as an authorized operator and must have on
their
- person at least a current third
- class medical certificate while operating a UAS. Authorized operators must have, at a minimum, successfully completed private pilot groun d school. Additionally , authorized operators not holding, at a minimum, a current FAA private pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months. 18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification and currency must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the o perator’s PICs are permitted under the terms of the exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience
- building flights, all persons not essential29

for flight operat ions are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may

not be conducted during night time , as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual conditions. If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. 20. The UA may

not operate within 3 nautical miles of an airport reference point as denoted on a current FAA
- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the air port management must be made available to the Administrator upon request. 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredic ted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended lan ding point and land the UA with 25% battery power remaining.30

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 2 6 . Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 27 . The documents required in accor dance with 14 C.F.R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 2 8 . The UAS must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 29 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator tr ainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparti cipating persons remain under such protection. If a situation arises where nonparticipating persons leave31

such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicl es or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, an d; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 3 0 . All operations shall be conducted over private or controlled
- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 3 1 . Any incident, accident, or flight operation that transgresses the lateral or vertic al boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS
- 80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained o n the NTSB Web site: www.ntsb.gov
. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  Sky View UAS, LLC submits that the equivalent level of safety estab lished by

Section 61.113(a)32

and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UA unless that PI C has demonstrated, by meeting proficiency and currency requirements, that the PI C is able to safely

operate the DJ I Inspir e 1 UA in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Sk y View UAS, LLC proposed area of operations, and the operating l imitations set forth
- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the DJ I Inspire 1 UA , Sk y View UAS, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary

for Sky View UAS, LLC specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 1115 8, 11159, 11160, 11161). **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safet y established b y Section 91.7(a) will be maintained because prior to every flight, Sky

View UAS, LLC will ensure that the DJ I Inspire 1 UAS is in an airworth y condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally , the FAA has previousl y granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those33

presented herein (e.g. Exemption Nos. 11062, 1 1063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent l evel of safet y established b y Section 91.121 will be maintained because the altitude information of the DJ I Inspire 1 UA will be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS fo r active monitoring of the flight path and altitude. This altitude information, combined with Sky View UAS, LLC’s operation of the DJ I Inspire 1 UAS within vis ual line of sight, at or below 4 00 feet AGL, excluding structures subject to inspections, will en sure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established b y the UAS at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 111 50, 11153, 11156, 11157, 11158, 11159, 11160, 11161).34

**5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJ I Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the loc ation of the proposed flight operations. Accordingly , Sky View UAS, LLC will ensure that it will safel y operate the battery powered DJ I Inspire 1 UA during daylight hours in visual conditions, with enough battery power to fly for a total duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I Inspire 1 UA ; the limitations on the proposed flight oper ations; and the location of the proposed operations, will ensure an equivalent level of safet y established by

14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Inspire 1 UA provide audible and visual warnings to the PI C at the GCS when the UAS experiences low battery

voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery

power. At the criticall y low battery level, the DJ I Inspire 1 UAS will descend and lan d automaticall y. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all
material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042,35

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption F rom The Requirements Of Sections 91.405(a),**  **91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.** In seeking this exemption, Sky View UAS, LL C submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Sky View UAS, LLC will use trained technicians to perform maintenance, alterations, or preventive maint enance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Sky View UAS, LLC Aerial Operations Manual, Monthly Maintenance Lo g, and DJIInspire 1 UA Instruction Manual). Furthermore, Sky View UAS, LLC wi ll document and maintain all maintenance records for the DJ I Inspire 1 UAS. Since the DJ I Inspire 1 UA will be inspected as prescribed b y the operating documents, Sky View UAS, LLC will maintain the equivalent level of safet y established by Sections 91.405 (a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversel y affect safety because Sky View UAS, LLC, will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techni ques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJIInspire 1 UA will be perfo rmed b y trained technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log. Significantly , previous exemptions granted by the FAA36

concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Sk y View UAS, LLC proposed operating limitations, the operating documents, and the technical aspect s of the DJ I In spire 1 UAS, Sky View UAS, LLC submits that safet y will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previousl y granted relief sp ecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Sky View UAS, LLC requests that the FAA prescribe s pecial conditions for the intended operation of the DJ I Inspire 1 UAS, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photograph y and data c ollection throughout the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national37

securit y; and further , provides the authority for such UAS to operate without airworthiness certification in accordance with an y requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pur suant to 14 C.F.R. § 21.16, for operation of the DJ I Inspire 1 UA , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y standards, due to the novel or unusual design features of the aircraft. Section 21.16 , entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safet y standards for an aircraft, aircraft engine, or propeller because of a novel or
unusua l design feature of the aircraft, aircraft engine or propeller, the FAA may prescribe special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safet y standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safet y equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Sky View UAS, LLC’s intended operation of the DJ I Inspire 1 UA , which contain such safet y standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).38

**F. A Summary That Can Be Published In The Federal Register, stating: The Rules From**  **Which Sky View UAS, LLC Seeks Exemption:** Sky View UAS, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Sky View UAS, LLC Seeks: This exemption will permit Sky View UAS, LLC to commerciall y operate an Unmanned Aircraft Sy stem (UAS) for the purpose of conducting aerial video and photograph y and data collection throughout the United States. **G. Any Additional Information, Views, Or Arguments Available To Support Sky View UAS, LLC Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Se ction 333, which directs the Secretary of Transportation to determine if certain UAS may operate safel y in the NAS. As such, Sky View UAS, LLC, request for exemption may be granted pursuant to the authority

of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security ; and further, provides the authorit y for such UAS to operate wi thout airworthiness certification. As discussed in detail above, Sky

View UAS, LLC will operate the DJ I Inspire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y.39

**CONCLUS ION**  As set forth herein, Sky

View UAS, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Inspire 1 UAS commercially , without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y and data collection over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Mod ernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Sky

View UAS, LLC, to safel y, efficientl y, and economically

operate the DJ I Inspire 1 UA commercially within the NAS. WHEREFORE, in accordance with the Federa l Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Sky View UAS, LL C respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 9 1.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Sky View UAS, LLC to operate the DJIInspire 1 UAS commerciall y for the purpose of conducting aerial video and photograph y of Real Estate Properties (for home owners, realtors, home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape as well as conduct ing power line inspection, aerial mapping, surveying and search and rescue over certain areas of the United States.40

Dated: June 15 , 2015 Respectfully

submitted by , Ry an Rush Sky View UAS, LLC 3545 Red Pontiac Drive Port Orange, FL 32129 Tel: 860
- 977
- 3181 Email: rush.ry an.c@gmail.com