1

Tuesday,	February	23,	2016

U.	S.	Department	of	Transportation	

Docket	Management	System

1200	New	Jersey	Ave.,	SE	

Washington	DC	20590

Regulatory	Docket	No.		__________________________

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:

RoboSkies	LLC

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF	TITLE	14	OF	THE	CODE	OF	

FEDERAL	REGULATIONS	SECTIONS:

Part	21	Subpart	H,	45.23	(b),	61.113(a)	&(b),	91.7	(a),	91.9	(b)	(2),	91.103,	91.109	(a),	91.119 (c),

91.121,	91.151	(a),	91.405	(a),	91.407	(a)(1),	91.409(a)(1)	&(a)(2),	AND	91.417(a)	&	(b)	

CONCERNING	COMMERCIAL	OPERATION	OF	ONE	(1) DJI	PHANTOM	3 VISION+	

AND	ONE	(1)	3DR	SOLO	UNMANNED	AIRCRAFT	SYSTEMS	PURSUANT	TO	SECTION	333	OF

THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112-95)
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RoboSkies	LLC

415	Market	Street,	Suite	207

Harrisburg,	PA	17101

Telephone: (717)	585-0076

Email:	creese@roboskies.com

February	18,	2016

U.S.	Department	of	Transportation

Docket	Management	System

West	Building	Ground	Floor,	Room	w12-140

1200	New	Jersey	Avenue,	SE

Washington	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam:

We	respectfully	request	exemption	under	Section	333	of	the	FAA	Reform	ACT	and	Part	11	of	the	

Federal Aviation	Regulations.

Petitioner:

RoboSkies	LLC

C/O	Chris	Reese

415	Market	Street,	Suite	207

Harrisburg,	PA	17101

Telephone:	(717.585.0076 )

Cell:	(717.829.7177 )

Email: creese@roboskies.com

RoboSkies LLC intends	to	incorporate	the	use	of small Unmanned	Aircraft	Systems (UAS)	for	

commercial	projects	that include:	project	and	construction	management,	inspection and	

monitoring;	environmental	review;	aerial surveying;	agricultural	monitoring;	education and	

research;	remote	sensing;	wildlife	and	forestry monitoring;	aerial	filmmaking;	event	photography;	

real	estate	photography and	search	and	rescue.
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Table	of	Contents

THE	EXTENT	OF	RELIEF	REQUESTED: ........................................................................................................ 4

REQUESTED	EXEMPTIONS FROM	REGULATION........................................................................................ 4

THE	PUBLIC	BENEFIT	DERIVED	BY	GRANTING	THIS	EXEMPTION ............................................................... 8

PROTECTION	OF	RIGHTS AND	PRIVACY.................................................................................................... 9

AN	EXEMPTION	WILL	PROMOTE	SAFETY	LEVELS	GREATER	THAN	OR	EQUAL	TO	THE	EXISTING	RULE........ 9

REGULATORY	COMPLIANCE....................................................................................................................10

GENERAL	INFORMATION	PERTAINING	TO	ALL	PROPOSED	UAS ...............................................................11

UNMANNED	AIRCRAFT	PILOT	IN	COMMAND	(PIC)..................................................................................12

PROPOSED	UAS	EQUIPMENT	AND	SPECIFICATIONS. ...............................................................................13

DJI PHANTOM	3 PROFESSIONAL	QUADCOPTER	WITH	4K CAMERA	AND	3-AXIS	GIMBAL .............................................13

3DR SOLO	QUADCOPTER	WITH	4K GOPRO	CAMERA	AND	3-AXIS	GIMBAL ...............................................................13

GLOSSARY	OF	ABBREVIATIONS...............................................................................................................14

CONCLUSION..........................................................................................................................................15
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The	Extent	of	Relief	Requested:

To	permit	commercial	operation of	small	Unmanned	Aircraft	Systems (UAS) by	RoboSkies LLC	for	

operations	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	established	

by	the	FAA	as	required	by	Section	333.

Said	exemptions	would	permit	the	operation	of	small	UAS under	controlled	conditions	in	limited,	

predetermined	and controlled	airspace.	Upon	granting	of	this	proposed	exemption	request,	

RoboSkies	would	conduct	commercial	operations	of	small	UAS meeting	or	exceeding	all	

operational	and	safety	requirements	per	Section	333.

Requested	Exemptions	from Regulation

14	C.F.R	Part	21 Subpart	H	– Airworthiness	Certificates.

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“The FAA believes that treating small UAS as a single category without airworthiness 

certification would accommodate a large majority of small UAS businesses and other 

non-recreational users of UAS. The operational limits in this proposed rule would

mitigate risk associated with small UAS operations in a way that would provide an 

equivalent level of safety to the NAS with the least amount of burden to business and

other non-recreational users of even the smallest UAS.”

-Pages 53-54

14	C.F.R.	45.23 (b) – Display	of	marks;	general.

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“The FAA acknowledges thatsome small unmanned aircraft may be too small to 

comply with the minimum-display-size requirements of part 45. However, as 

mentioned previously, part 45 already contains a provision, § 45.29(f), that would 

address this issue by allowing the too-small aircraft to simply display its registration 

number in as large a manner as practicable. Accordingly, the size of the small 

unmanned aircraft would not be a barrier to compliance with the provisions of 

SubpartCof part 45.”

14	C.F.R.	61.113 (a)	and	(b) – Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“The FAA proposes to require that applicants for an unmanned aircraft operator 

certificate with a small UAS rating pass an initial knowledge test to demonstrate that 
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they have sufficient aeronautical knowledge to safely operate a small UAS. The FAA 

proposes a knowledge test rather than a required training course in order to provide 

applicants with flexibility as to the method that they use to acquire aeronautical 

knowledge.”

-Page 103

Because the UAS will not carry a pilot or passengers, the proposed operations can

achieve the equivalent level of safety of current operations and applicable knowledge

level by requiring the PIC operating the UAS to have at minimum a sport pilot’s

certification rather than a commercial pilot’slicense to operate a sUAS. Unlike a 

conventional manned aircraft, a UAS is remotely controlled by a ground-based 

operator. The operational area is controlled and restricted, and all flights are planned 

and coordinated in advance. The level of safety exceeds that provided by a single 

individual holding a commercial pilot’s certificate operating a conventional aircraft.

The risks associated with the use of a UAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 allowing sUAS use by a

sport pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. §61.113

14	C.F.R.	91.7 (a) – Civil	aircraft	airworthiness.

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“FAA noted that, as mentioned previously, due to their light weight, small unmanned

aircraft generally pose a significantly lower risk to people and property on the ground

than manned aircraft. This relatively low risk is mitigated even further by the see-andavoid and loss-of-positive-control provisions of this proposed rule, which are discussed

above. Accordingly, based on existing information, the FAA believesthat requiring 

small UAS operators to conduct inspection and maintenance of the small UAS 

pursuant to the existing regulations of part 43, or to obtain a PTO, would not result in 

significant safety benefits. As a result, this proposed rule would not require small

UAS compliance with part 43 or the application for, or issuance of, a PTO.

Instead, this proposed rule would require, in § 107.21(b), that prior to each flight, the

operator must inspect the small UAS to ensure that it is in a condition for safe

operation. The operator could do this by, for example, performing a

manufacturer-recommended preflight inspection or performing an on-the-ground test 

of the small UAS to determine whether safety-critical systems and components are 

working properly.”

-Page 90

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size of the aircraft and the requirements 

contained in the UAS User and Maintenance manuals, for maintenance and use of 

safety check lists prior to each flight, as set forth in RoboSkies’ FOPM, an equivalent

level ofsafety will be provided.
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14	C.F.R.	91.9 (b)(2) – Civil	Aircraft	Flight	Manual	in	Aircraft.

Section 91.9 (b)(2) states that no person may operate a U.S.-registered civil aircraft 

...unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight

Manual.

The proposed UAS(s) in consideration, given their size and configuration have no ability

or place to carry such a flight manual on the aircraft, not only because there is no pilot 

on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the UAS will have immediate access to it.

14	C.F.R.	91.109 (a)	– Flight	Instruction.

Section 91.103 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. UAS and remotely piloted aircraft, by their design do not

have fully functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The FAA

has approved exemptionsfor flight training without fully functional dual controls for a

number of aircraft and for flight instruction in experimental aircraft.

14	C.F.R.	91.119 (c)		- Minimum	safe	altitudes:	General.

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“With regard to the vertical boundary, the FAA proposes, in § 107.51(b), to set an altitude 

ceiling of 500 feet above ground level (AGL) for small UAS operations that would be 

subject to this proposed rule. The FAA chose to propose 500 feet as the vertical area-ofoperation boundary because most manned aircraft operations take place above 500 feet. 

Specifically, most manned aircraft operations conducted over uncongested areas must be 

flown at an altitude above 500 feet AGL, while most manned aircraft operations 

conducted over congested areas must be flown at an even higher altitude. Thus, a 500-

foot altitude ceiling for small UAS operations would create a buffer between a small 

unmanned aircraft and most manned aircraft flying in the NAS.

...Even though some manned aircraft operations take place at an altitude below 500 feet, 

there is significantly less air traffic at or below 500 feet than there is above 500 feet 

altitude. As a result of this difference in air-traffic density, the FAA has determined that 

small UAS operations would not pose a significant risk to manned aircraft operations 

taking place below 500 feet altitude if proper precautions are taken by the small UAS

operator.”
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14	C.F.R.	91.121 – Altimeter	settings.

Section 91.121 requires that each person operating an aircraft shall maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimetersetting available before departure.” As a sUAS may 

not have a barometric altimeter, but instead GPS altitude data, an exemption is 

needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

FOPM, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight.

14	C.F.R.	91.151(a) – Fuel	requirements	for	flight	in	VFT	conditions.

Section 91.151(a) 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 . . .. ”

Proposed relief would be that RoboSkies be prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is enough available power 

for the sUAS to conduct the intended operation and to operate after that for at least 5 

minutes or with the reserve power equal to or greater than that recommended by the 

manufacturer.

14	C.F.R.	91.405 (a);	407 (a) (1);	409 (a) (2);	417 (a);	417 (b)	– Maintenance	Inspections

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015]

“FAA noted that, as mentioned previously, due to their light weight, small unmanned

aircraft generally pose a significantly lower risk to people and property on the ground

than manned aircraft. This relatively low risk is mitigated even further by the see-andavoid and loss-of-positive-control provisions of this proposed rule, which are discussed

above. Accordingly, based on existing information, the FAA believesthat requiring 

small UAS operators to conduct inspection and maintenance of the small UAS 

pursuant to the existing regulations of part 43, or to obtain a PTO, would not result in 

significant safety benefits. As a result, this proposed rule would not require small

UAS compliance with part 43 or the application for, or issuance of, a PTO.

Instead, this proposed rule would require, in § 107.21(b), that prior to each flight, the

operator must inspect the small UAS to ensure that it is in a condition for safe

operation. The operator could do this by, for example, performing a

manufacturer-recommended preflight inspection or performing an on-the-ground test 

of the small UAS to determine whether safety-critical systems and components are 

working properly.”

-Page 90

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply. Maintenance will be accomplished by the
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operator. An equivalent level of safety will be achieved because the UASs are limited in

size, will carry a small payload and operate only in controlled access areas for limited

periods of time. If mechanical issues arise, the sUAS can land immediately and will be

operating from no higher than 500 feet AGL. As provided in the FOPM, the operator

will ensure that the s UAS is in working order prior to flight, perform any required

maintenance, and keep a log of any maintenance performed. Moreover, the operator is

the person most familiar with the UAS and best suited to maintain its airworthiness.

The	Public	Benefit Derived	by	Granting	this	Exemption

The	following	public	benefits	can be	derived	by	granting	this	exemption:

1. Project	and	construction	management,	inspections	and	monitoring:	 The	use	of	(UAS)	on	

construction	sites may	improve	the	safety	of	workers,	local	residents	and	general	public	by	

assessing	potential	dangerous situations.	Falls	and	injuries	will	be eliminated	through	a	

more	thorough	review	of	the	construction sites.	In	some	cases,	a	(UAS)	reduces the	

reliance	of	helicopters	or	small	aircraft	to	monitor	said	sites.	This	may improve	safety	as	

well	as	reduce	environmental	impact	by	reducing	pollution	discharge	and	energy	usage.

2. Environmental	Review	projects:	The	use	of	(UAS) as	required	by	24 C.F.R.	50.4,	58.5	and	

58.6	would	provide	a	more	in-depth	Environmental	Review	of	the	identified	project	sites

as	well	as the	surrounding	areas.	Reliance	on helicopters	or	small	aircraft	may	be	

eliminated.

3. Aerial	surveying:	The	use	of	(UAS)	in	connection	with	aerial	surveying	of	smaller	areas	may	

eliminate	the	use of	helicopters	or	aircraft.	This	provides a more	cost	effective,	safer	and	

more	energy	efficient	result.

4. Agricultural,	Wildlife	and	Forestry	projects: The	use	of	(UAS)	could	assist	with	surveying	

within agricultural,	wildlife	and	forestry	projects	by	providing	information	when	fire	or	

safety	problems	are	reported,	vermin infestation is	discovered or existing fire	hazards are	

suspected.

5. Remote	Sensing	projects: The	use	of	(UAS)	provides views	and collects information	for	

remote	and	otherwise	inaccessible areas.	This	promotes worker	safety	and reduces the	

reliance	on	larger	commercial aircraft.

6. Educational	and	Research	projects: The	use	of	(UAS)	could	provide	information	for	said	

projects	in	a	safer,	cost effective	and	efficient	manner	than	other	available	options.

7. Aerial	filmmaking,	photography	and	real	estate	purposes: The	use	of	(UAS)	may	provide	a	

point	of	view previously	unavailable	through	other	means.	This	would	be	more	cost	

effective,	efficient	and	safer	than helicopters	and	aircraft.
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8. Search	and	rescue: The	use	of	(UAS)	may	provide	assistance	to	local	law	enforcement	

organizations	during	search	and rescue	missions.	(UAS)	may	reach	areas	unattainable	or	

outside	the	viewing	range of	helicopters	and	commercial	aircraft.	A	(UAS)	search	and	

rescue	may	also	be implemented	quicker;	time is	of	the	essence	during	search	and	rescue	

operations.

Protection	of	Rights	and	Privacy

All	persons involved	in	flight	a	mission	will observe	the	privacy	rights	and expectations	of	the	

public.	Any	person	involved	in	any	unlawful	flights	that	may	jeopardize	someone's	privacy	right	or	

expectations	will be	reprimanded	and	held	accountable	for	their	actions.

An	Exemption	Will Promote	Safety	Levels Greater	Than	or	Equal to	the	

Existing	Rule.

Proposed	operations	using	(UAS)	provide	increased	safety	enhancement	especially	when	

compared	with helicopters	and	aircraft	for	the	following	reasons:

1. The	(UAS)	will	weigh	less	than	ten	(10)	pounds.

2. Flights	will	be	operated	within	the	visual	line	of	sight (VLOS) of	the	pilot	during	daylight	

only	(official	sunrise	to	official	sunset,	local	time).	Minimum	weather	visibility	of	3	miles	

from	control	station	will	be	established.

3. The	UAS	will	not	be	operated	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	control	station.	

4. Maximum	total	flight	time	for	each	operational	flight	will	be	thirty	(30)	minutes.	Flight	

times	may	be	less	than thirty	(30)	minutes	as	the	(UAS)	will	continuously	monitor	battery	

reserve	and	return	to	the	ground	station	with at	least	20%	battery	power	reserved.

5. Flights	will	never	exceed	400	feet	AGL.

6. The	minimum	crew for	each	operation	will	consist	of	the	UAS pilot	(PIC)	and	a	Visual	

Observer (VO). No	person	may	act	as	PIC	or	VO	for	more	than	one	UAS	at	a	time.

7. A	briefing	will	be	conducted	daily	by	all	personnel	working	with	said	(UAS). A	thorough	

preflight	check,	made	by	the	PIC,	will	ensure	safe	operation.	

8. All	onsite	personnel	and	client	employees	will	be	required	to	execute	a	waiver.	

Verbal/written	consent	will	be required	of	all	persons	within	100	feet	of	flight	operation.
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9. Written	and/or	oral	permission	from	relative	property	owners	will	be	obtained	prior	to	

operating	the	(UAS).

10. All	permits,	permissions,	etc.	will	be	obtained	from	local	government	offices	as	required.

11. The	(UAS)	operated	will	weigh	less	than	55	pounds	including payload	(camera,	lens,	

gimbal,	etc.).

12. The	(UAS)	will	operate	at	speeds	less	than	50	mph	(44	knots),	hover	and	simultaneously	

move	vertically	and horizontally.

13. The	(UAS)	will	have	the	capability	to	return	and	land	at	the	pre-determined	location	with	

the	Security Perimeter	should	the	(UAS)	lose communication	or	GPS	signal	during	any	

operations.

14. The	(UAS)	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.

15. Operations	will	not	be	conducted	over	people	not	involved	in	flight	operations,	densely	

populated	areas	or	heavily	traffic	highways.

16. Operations	will	not	be	conducted	within	five	(5)	nautical	miles	(NM)	of	an	airport	or	

heliport	unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained	or	

otherwise	permitted	by	a	COA.

Regulatory	Compliance

RoboSkies will	abide	by	all	regulations	including	the	following:

1. 14	C.F.R.	Part	21,	Certification	Procedures	for	Products	and	Parts.	Airworthiness	Certificates.

2. 14	C.F.R.	45.23 Display	of	marks;	general	and	45.29	Size	of	marks.

3. 14	C.F.R.	61.113 (a) &	(b) Private	pilot	privileges	and	limitations:	Pilot	in	Command	and	61.133

Commercial	pilot privileges	and	limitations.

4. 14	C.F.R.	91.7 Civil	aircraft	airworthiness.

5. 14	C.F.R.	91.9 Civil	aircraft	flight	manual,	marking	and	placard	requirements.

6. 14	C.F.R.	91.103 Preflight	Action

7. 14	C.F.R.	91.109 Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests.

8. 14	C.F.R.	91.119 Minimum	safe	altitudes:	general.
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9. 14	C.F.R.	91.121 Altimeter	settings.

10. 14	C.F.R.	91.151 (a) Fuel	requirements	for	flight	in	VFR	conditions.

11. 14	C.F.R.	91.203 Civil	aircraft:	Certifications	required.

12. 14	C.F.R.	91.205 Powered	civil	aircraft	with	standard	category	U.S.	airworthiness	certificates:	

Instrument	and equipment	requirements.

13. 14	C.F.R.	91.215 ATC	transponder	and	altitude	reporting	equipment	and	use.

14. 14	C.F.R.	91.401 Applicability.

15. 14	C.F.R.	91.403 General.

16. 14	C.F.R.	91.405 Maintenance	required.

17. 14	C.F.R.	91.407 Operation	after	maintenance,	preventive	maintenance,	rebuilding	or	alteration.

18. 14	C.F.R.	91.409 Inspections.

19. 14	C.F.R.	91.411 Altimeter	system	and	altitude	reporting	equipment	tests	and	inspections.

20. 14	C.F.R.	91.413 ATC	transponder	tests	and	inspections.

21. 14	C.F.R.	91.415 Changes	to	aircraft	inspection	programs.

22. 14	C.F.R.	91.417 Maintenance	records.

General	Information	Pertaining	to	All	Proposed	UAS	

RoboSkies	will	operate	UAS	weighing	less	than	55	pounds	(with	payloads),	for	project	and	

construction	management,	inspection	and	monitoring;	environmental	review;	aerial	surveying;	

agricultural	monitoring;	education	and	research;	remote	sensing;	wildlife	and	forestry	monitoring;	

aerial	filmmaking;	event	photography;	real	estate	photography	and	search	and	rescue

Prior	to	each	flight	the	Pilot	in	Command	(PIC)	shall	inspect	the UAS	to	ensure	in	is	in	a	condition	

for	safe	flight.	If	this	inspection	reveals	a	condition	that	affects	the	safe	operations	of	the	UAS,	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.	A	Ground	Control	Station	will	also	be	

included	in	preflight	inspections.	Maintenance	and	alterations	must	be	properly	documented	as	

described	in	the	FOPM	(pg.	6).
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Any	maintenance	or	alterations	made	to	a	UAS	must	be	documented	in	the	appropriate	logbook,	

and	the	UAS	must	undergo	a	functional	test	flight	prior	to	it	being	returned	to	service.	Any	repairs	

or	alterations	must	meet	the	manufacturer’s	guidelines,	with	particular	attention	to	flight	critical	

components	that	may	not	be	addressed	in	the	manufacturer’s	manuals.	Only	personnel	who	are	

authorized	shall	perform	such	operations.

RoboSkies	will	follow	all	UAS	manufacturer’s	maintenance,	overhaul,	replacement,	inspection,	

and	life	limit	requirements for	the	aircraft and	aircraft	components.	All	maintenance,	inspections,	

and	record	keeping	will	be	done	in	accordance	with	the	operator’s	manual,	and	will	be	noted	in	

the	appropriate	RoboSkies	flight	and	maintenance	logbook.

Each	UAS	operated	under	the	proposed	exemption shall	comply	with	each manufacturer’s

System	and	Safety	Bulletins.

Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	and	control	of	

the	UAS	shall	comply	with	Federal	Communications	Commission	(FCC)	or	other	appropriate	

government	oversight	agency	requirements.

Unmanned	Aircraft	Pilot	in	Command	(PIC)

RoboSkies’	flight	crew,	including	PIC	and	Visual	Observer	(VO),	will	be	qualified	as	directed	by	the	

RoboSkies’	FOPM	(pg.	7,	“Operators”).

All	flight	crew	members,	including	PIC	and	VO,	will	have	demonstrated	and understanding	of,	and	

comply	with,	Title	14	Code	of	Federal	Regulations	(CFR),	and/or	FAA	directives	and	regulations,	

applicable	to	airspace	where	the	UAS	will	operate.	Specifically, all	flight	crew	members	will	

receive	instruction on	the	rules	and	responsibilities	described	in	14	CFR	Part	91,	Sections	91.111,	

91.113,	and	91.115.

All	flight	operations	will	utilize	at	least	one	VO.	The	VO	may	be	used	to	satisfy	the	Visual	Line	of	

Sight	(VLOS)	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	PIC	will	

communicate	verbally	at	all	times.	This	condition	and	limitation	is	consistent	with	all	FAA	

approved	Exemptions.
13

Proposed	UAS Equipment	and	Specifications.

RoboSkies	utilizes	the	DJI	Phantom	3	and	3DR	Solo	UAS	platforms	in	it’s	commercial	operations.	

Equipment	specifications	for	each	product	type	are:	

DJI	Phantom	3	Professional	Quadcopter	with	4K	Camera	and	3-Axis	Gimbal

(previously	granted	exemption	#12657A)

• Flight	Time:	23	minutes	

• Video	Onboard:	HD	video	streaming	to	mobile flight	controller

• Top	speed:	12	mph,	16	meters/second

• Max	Altitude:	400 ft.,	per	FAA	regulations

• Wet	Weight:	2.7	lbs. including	battery	and	propellers

• GPS	equipped:	yes

• Communication	Distance:	up	to	6500	feet @	altitude	of	120	meters

• Detached	Controller	with	color	screen	and	live	flight	data

3DR	Solo	Quadcopter	with	4K	GoPro	Camera	and	3-Axis	Gimbal

• Flight	Time:	25	minutes	standard;	20	minutes	with	payload

• Video	Onboard:	HD	video	streaming	to	mobile	flight	controller

• Top	speed:	35 mph	

• Max	Altitude:	400	ft.,	per	FAA	regulations

• Wet	Weight:	3.9	lbs.	with	camera	and	Gimbel

• Max	Payload:	420	grams

• GPS	equipped:	yes

• Communication	Distance:	up	to	6500	feet

• Detached	Controller	with	color	screen	and	live	flight	data
14

Glossary	of	Abbreviations

The	following	abbreviations/terms	have	been	used	in	this	document	and	a	summary	is	provided	

for	reference	purposes:

AGL Above	Ground	Level

ATC Air	Traffic	Control

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

FOPM Flight	Operations	&	Procedures	Manual

MAAP Mid	Atlantic	Aviation	Partnership

NAS National	Airspace	System

PIC Pilot	in	Command

UAS Unmanned	Aircraft	Systems

VFR Visual	Flight	Rules

VMC Visual	Meteorological	Conditions

VO Visual	Observer

VLOS Visual	Line	of	Sight
15

Conclusion

RoboSkies	is	committed	to	supporting	and	promoting	the	safe	and	responsible	implementation	of	UAS	

within our	National	Airspace	System	(NAS).	RoboSkies	will perform	safe,	efficient,	and	responsible	UAS	

flight	operations;	promote legal	flight	operations	solutions	to	ensure	greater	public	safety	and	discourage

unlawful	use, lessening	the	risk	to	pilots,	property,	and	civilians.

Please	contact	our	office	should	you	have	any	additional	questions	or	comments.	Thank	you	for	your

cooperation	with	this	matter.

Sincerely,

Chris	Reese

President	&	CEO

RoboSkies	LLP

creese@roboskies.com

(717)	585-0076