Skyspective

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com

8 June 2015

Mr. James Williams

Unmanned Aircraft Systems Integration Office Federal Aviation Administration

800 Independence Ave, SW

Washington, DO 20591

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Rm W12-140 1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Mr. Williams,

SkySpective respectfully requests an exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.), specifically portions of 14 C.F.R. Parts 45 and 91, to permit the use of our small 

Unmanned Aerial Systems (UAS), the Tarot 810, for use in aerial survey of Oil and Gas Pipelines in rural 

areas of the United States. Granting an exemption is consistent with Congress’ intent, as reflected in Section 333 of the FAA Modernization and Reform Act of 2013, that states safe systems be permitted in the 

National Airspace (NAS) prior to the issuance of final regulations governing general use of these small 

unmanned aerial systems.

The Tarot 810 drone is an all-environment, electric powered, self-launched, small multirotor UAS that, depending on its payload, is capable of collecting airborne images and location information to a Ground Control Station (GAS). It can also conduct high resolution photogrammetry or perform Light Detection and 

Infrared data collection. If used for high resolution photographs or point cloud data, the Tarot 810 drone 

stores the photographs and imagery data onboard and makes it available for download after completion of 

the flight. The Tarot 810 drone, has a maximum weight of 15 pounds and a diameter of 40 inches, with a 

maximum crusing speed of 30 mph. It is battery powered, has a maximum flight time between 10 and 15 

minutes, and can operate in temperatures ranging from 10 degrees F to 120 degrees F. The Tarot 810 drone 

has two omni-directional antennas, a primary and a redundant back-up. The primary 2.4 Ghz antenna has a 

range of 2 miles, and the 5.8 Ghz back-up antenna has a range of 1.4 miles.

 
11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com

FAA Modernization and Reform Act of 2012, Section 333

Section 333 states that the FAA shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan and rulemaking required by Section 332”. Section 333 (b), then lists several factors that should be considered in determining which 

UASs would be eligible for expedited integration into the National Airspace System (NAS). Specifically, UASs that “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 the users of 

the national airspace system or the public, or pose a threat to national security”. If a UAS has met the 

criteria laid forth in Section 333 (b), Section 333 (c) then gives the FAA the authority to decide if an 

airworthiness certification as specified by Title 49 United States Code, Section 44704 is even required 

for operation. Section 333 (c) specifically states that the FAA can determine “whether a certificate 

of waiver, certificate of authorization, or airworthiness certification undersection 4704 of Title 49, 

United States Code, is required for the operation of unmanned aircraft systems”. Thus, the FAA has 

the ability to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the 

NAS without as airworthiness certificate as long as the UAS does not pose any hazard or threat to the 

NAS, public, and national security.

The primary function of the Tarot 810 drone is to provide aerial imagery using interchangeable georeferenced still/video cameras. High resolution data generated from these cameras offers a wide range 

of applications in agriculture and aerial survey. The resulting imagery data, along with post processing data analytics, helps the oil and gas industry, for example, monitor for leaks, benefitting the 

environment and the general public. The Tarot 810 drone can fly by remote control or autonomously 

with advanced mission planning, and is launched on-the-spot with no requirements for a runway. 

Once airborne, the Tarot 810 drone will fly at an altitude less than 400 ft Above Ground Level (AGL) 

over the designated plot. Prior to flight, the Pilot in Command (PIC) sets a designated flight area and 

flight parameters to ensure that the Tarot 810 drone will remain within the confines of the approved 

site, never exceeding 400 ft. AGL. If on board sensors detect a critical issue at any time, such as a low 

battery state or loss of GPS signal, the Tarot 810 drone will immediately execute pre-programmed 

safety procedures and automatically return to the launch site. The Tarot 810 drone’s small operational 

footprint and built-in safety protocol provide a much safer alternative for aerial survey and would 

pose a minimal hazard to the NAS or public.

The Tarot 810 drone will only operate over Oil and Gas easements for the purpose of collecting 

aerial imagery. There are multiple rural sites over which the Tarot 810 drone will be flown. All sites 

are owned and operated by Oil and Gas rights owners who have granted approval to Skyspective to 

conduct flights over their property. There are a few small office buildings and maintenance buildings located amongst the Platform or pipeline areas and Skyspective will ensure all operations avoid 

overflight of these structures. In addition, these are no airports within 5 NM of the sites, meaning the 

operations are within the FAA guidelines. By operating at low altitudes over privately owned areas 

of interest, the Tarot 810 drone will pose no threat to individuals or structures on the ground and will 

remain well clear of any and all air traffic.
Skyspective has established the following operational limitations for Tarot 810 drone over the 

intended survey sites:

 l The Tarot 810 drone flights are permitted over privately owned Oil and Gas Platforms

 and Pipelines

 l The Tarot 810 drone will operate below 400 ft AGL and not within 5 NM of an airport

 l The Tarot 810 drone will operate within 1 NM and within VLOS of the PIC and Safety

 Observer

 l The Safety Observer will be located next to the PIC and will ensure the aircraft remains

 within VLOS and assist in spotting potential hazards

 l The Tarot 810 drone will operate in accordance with Day Visual Flight Rules and only in

 Visual Meteorological Conditions during daylight hours

 l The duration of each Tarot 810 drone flight shall not exceed 25 minutes

 l All takeoffs and landings will occur on-site

 l The Tarot 810 drone flights will avoid direct overflight of any office or maintenance

 buildings located on-site

 l All Skyspective employees working on-site will be thoroughly briefed on Skyspective

 operations prior to operations commencing

 l Skyspective operations will be conducted by a commercially certified pilot who has

 completed Skyspective training

 l Skyspective flights will be cancelled in the event that any aircraft or ground control

 station equipment is found to be inoperative or not fully functional

 l IF the PIC or Safety Observer spots a potential hazard, such as a manned aircraft within 

 close proximity to the designated flight area, the PIC will immediately land the Tarot 810

 drone and operations will only resume after the hazard is clear of the area

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com
 l All Skyspective maintenance will be accomplished in accordance with the Skyspective

 Inspection and Maintenance Requirements

 l Only one Skyspective drone will be airborne at any given time for each designated site

 l The PIC will file a NOTAM for Skyspective flights at each site, providing at a minimum

 radial/DME, radius, and date/time group

 Skyspective will be bound by these limitations for commercial flights after the FAA approval of the 

exemptions laid forth in this petition. Skyspective will also follow any guidance for the FAA in accordance with Sec 333 (c) which states that after determining if UAS meet criteria for safe operation that 

the FAA “shall [also] establish requirements for the safe operation of the” UAS in the NAS.

Specific Sections of 14 CFR from which Skyspective Seeks Exemption

Below are the sections from which Skyspective seeks exemption, with specifics on the extent of relief 

sought, reason for relief, and why exemption would not adversely affect safety.

a. Part 21 Subpart H - Airworthiness Certification

 Part 21 Subpart H establishes the requirement for the issuance of an airworthiness certificate. Skyspective seeks complete exemption from Part 21 Subpart H pursuant with Section 333, which authorizes the FAA to exempt a UAS from the requirements of an airworthiness certificate based on consideration of the following size, weight, speed, and operational capability, proximity to airports and 

populated areas, and operation within VLOS.

 An equal level of safety will be achieved with the operational limitation established in the document 

for all Skyspective, Tarot 810 flights. Specifically that all flights will occur within VLOS of the PIC 

and Safety Observer, at an altitude of less than 400 ft. AGL, and only over designated Oil and Gas or 

areas of interest. As a result Skyspective can safely operate without creating a hazard to any other aircraft, people, or structures on the ground. The combination of Skyspective’s safe operational history 

in the United States, and small lightweight design, in conjunction with Skyspective’s safety requirements and operating limitations, results in a safer alternative for aerial imagery collection.

b. 91.7 (a) - Civil Aircraft Airworthiness

91.7 (a) states that “no person may operate a civil aircraft unless it is in an airworthy condition”. Skyspective is already seeking exemption for airworthiness certification and thus no FAA standard will 

exist for determining airworthiness. As a result, Skyspective seeks full exemption from this regulation. Skyspective will achieve an equal level of safety by using Skyspective User Manual and Inspection and Maintenance Requirements. Our documentation contains pre-flight protocols for each flight, 

safety checks, and comprehensive maintenance procedures.

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com
 

c. 91.9 (b) - Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate a civil aircraft unless there is a current approved flight manual for the aircraft onboard. The tarot 810 small and lightweight design is not capable of carrying an 

aircraft flight manual on board. In addition, the Tarot 810 is unmanned, and the PIC is located at the 

ground control station. Skyspective thus seeks exemption from the requirement to carry the aircraft 

flight manual onboard. Skyspective instead proposes that the Skyspective User Manual and Justification of Airworthiness Document, which contains information normally found in aircraft flight manual, 

be kept at the ground control station where it is readily accessable to the PIC and Safety Observer for 

reference.

d. 91.103 - Preflight Action

91.103 requires that the PIC be familiar with specific information before each flight such as weather, 

forecast, and fuel requirements. In addition to this the PIC must be familiar with information found 

within the approved flight manual relating to aircraft performance and takeoff and landing distances. 

Due to the fact that Tarot 810 has no FAA approved flight manual, Skyspective seeks to exemption 

from this regulation. Skyspective proposes to use the Skyspective User Manual and Justification of 

Airworthiness Document in lieu of an FAA approved flight manual. These two Skyspective publications have extensive pre-flight checklists that include reviewing weather, power/battery requirements 

takeoff and landing, and aircraft performance data. The information found in the Skyspective User 

Manual and Justification for Airworthiness Document is comparable to the information found in an 

FAA approved flight manual, to include a comprehensive step-by-step pre-flight checklist. As a result 

an equal level of safety will be maintained by the PIC using these two publications, which address the 

items listed in 91.103.

e. 91.119 - Minimum Safe Altitude

91.119 establishes the minimum altitude that civil aircraft may safely operate. 91.119 (c) specifically 

states that over “other than congested areas” a civil aircraft cannot operate below an altitude of 500 

ft above the surface, except over open water or sparsely populated areas (and) in those cases, the 

aircraft may not be operated closer than 400 ft to any person, vessel, vehicle, or structure”. The sole 

function of the Tarot 810 drone is to fly at low altitudes over Oil and Gas Platforms and construction sites which can be categorized as “other than congested areas”. Small UASs, like the Tarot 810 

drone are, by design, flown at altitudes of less than 400 ft. AGL. Skyspective has established operating limitations to achieve the highest level of safety, specifically that the Tarot 810 drone will remain 

within VLOS of the PIC and Safety Observer. For these reasons Skyspective seeks exemption form 

this regulation. An equivalent level of safety will be maintained by only operating the Tarot 810 drone 

over designated areas of interest.

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com
 

f. 91.121 - Altimeter Settings

91.121 requires aircraft to maintain a cruising level or flight level in reference to a current

reported altimeter setting. The Tarot 810 drone is not equipped with an altimeter setting. The Tarot 

810 drone is not equipped with a programmable altimeter but rather determines location and altitude 

via an onboard GPS and barometer. Since the Tarot 810 drone will be operating below 400 ft AGL, 

there is no need to maintain hemispherical cruising altitudes for de- confliction with manned aircraft. 

For these reasons the Tarot 810 drone seeks exemption for this regulation. An equal level of safety 

will be achieved through the Tarot 810 drones GPS and barometer which provide altitude and location 

data to the PIC via the ground control station. An automatic pre-flight test is done to verify functionality of the GPS and barometer prior to operations. If at any time during flight there is a failure of the 

GPS or barometer, the Tarot 810 drone will initiate an emergency procedure to return to its original 

takeoff location. By operating below 400 ft AGL, the Tarot 810 drone will not create a hazard to any 

manned aircraft maintaining hemispheric cruising altitudes based on a current altimeter setting.

g. 91.151 (a) - Fuel Requirements for Flight in VFR Conditions

91.151 (a) states that no person may begin a flight in Day VFR conditions unless there is enough fuel 

to fly to the intended landing point and fly for 30 minutes after that point is reached. The Tarot 810 

drone is battery operated and does not carry fuel. It has a maximum flight time of 20 minutes on a 

fully charged battery. The Tarot 810 is unable to fly for 30 minutes. Skyspective seeks full exemption 

from this regulation due to the fact that the risk of danger associated with failing to reach a safe landing point with 15 minutes of extra “fuel” does not exist with the Tarot 810 drone. The Tarot 810 drone 

does not have to return to a “landing point” but rather can be safely put down anywhere over the point 

of interest. An equal level of safety will be maintained simply by the fact that the Tarot 810 drone is 

designed to safely land anywhere over the area of interest in the event that the battery is exhausted. 

Any risk associated with battery duration (fuel) in relationship to flight time is mitigated by the fact 

that the Tarot 810 drone has the ability to land anywhere and at any given time.

h. 91.203 (a) & (b) - Civil Aircraft: Certifications Requirements

91.203 requires all civil aircraft to have “within it.... An appropriate and current airworthiness certificate” that must be “displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew”. Skyspective is already seeking exemption for the airworthiness certificate regulation and thus 

requires an exemption from this regulation. In addition the Tarot 810 drone due to its size and design 

has no cabin or cockpit, and therefore does not have the ability to carry certification or registration 

documents. Furthermore the Tarot 810 drone does not carry any passengers or crew for whom the 

certificate is required to be displayed. Skyspective proposes that any FAA required documents be 

kept at the ground control station and that a small placard be affixed to the Tarot 810 drone airframe 

with manufacturer, registration, and contact information. An equal level of safety will be achieved by 

having any FAA related documents located at the ground control station where it will be readily accessible to the PIC and any other agencies that may require information.

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com
Granting an Exemption that is in the Public Interest

The Tarot 810 drone is a safe, efficient, and economical alternative to manned, fixed-wing aircraft that 

are currently being used to conduct aerial imaging of areas of interst. Using the Tarot 810 drone in lieu 

of a traditional manned, fixed wing aircraft will result in the overall reduction of low-flying manned 

aircraft in the NAS, easing the burden on Air Traffic Controllers. Because the Tarot 810 drone can 

take off and land on-site and operate at an altitude under 400 ft AGL within VLOS of the PIC, there 

is no need for the ATC to provide coordination during ground movement, takeoff, departure, transit, 

arrival, or landing phase of flight. As the skies over the United States get busier and busier, any efforts 

that ease the stress on the Air Traffic Control system is of benefit to the public.

The Tarot 810 drone is electrically powered, which decreases air pollution and noise. The electric motor will be exponentially quieter than a twin-engine combustion motor on passenger aircraft typically 

used to conduct aerial imaging. A manned aircraft typically burns 20-30 lbs of aviation fuel per hour, 

polluting the air not only over the site but over the path of transit and around the airport. Conducting 

aerial imaging with the Tarot 810 drone in lieu of manned aircraft would thus reduce both air pollution and noise pollution, which is of great benefit to the public.

Using the Tarot 810 drone would also greatly reduce risk to life and property on the ground. The Tarot 

810 drone’s small size, reduced weight, lightweight construction pose little hazard to people or structures on the ground as compared to a manned twin engine aircraft, which has a much greater potential 

for damage to life and property in the event of an accident. The Tarot 810 drone is unmanned and as 

a result poses essentially no risk associated with piloting an aircraft. Overall, the Tarot 810 drone provides a much safer alternative to manned, fixed-wing aircraft operations for the purpose of collecting 

aerial imagery.

Lastly, using the Tarot 810 drone to provide aerial imagery would result in better monitoring of the oil 

and gas infrastructure and minimize potential environmental hazards. High resolution data generated 

from thee Tarot 810 drone flights would provide operators with invaluable information on volumization, tank failure containment, and leak detection. By analyzing this data operators can make modifications to a wide range of variables that will minimize environmental impact and increase efficiency, 

which in turn would be of great benefit to the public.

In accordance with the procedural requirements of 14 C.F.R 11.81, Skyspective Inc. provides the following information regarding our point of contact:

Chris Burford, CEO 

11541 W 66th Place 

Arvada, Co 80004 

(303) 881-2327

Please contact me with any questions with regards to this request for exemption. 

Sincerely,

Chris Burford

CEO 

11541 w. 66th Pl Arvada, CO 80004 Skyspectivemedia.com