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June 22, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: 

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21; 

14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and (b); 14 

C.F.R. §§ 91.7(a); 14 C.F.R. §§ 91.9(b)(2); 14 C.F.R. §§ 91.103; 14 C.F.R. §§ 

91.109; 14 C.F.R.§ 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 

C.F.R. §§ 91.203(a)(b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 

C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Sky Camera Aerial Images ("SCAI"), a 

service provider of aerial imaging for real estate, industrial asset and power 

structure inspections, construction and agriculture surveying, and closed set 

filming, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation for its Small Unmanned 

Aircraft Systems ("sUASs") for safe, efficient and up-to-date aerial imaging within 

the National Airspace, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

As detailed in this document and the attached Flight Operations Manual (see 

Appendix A), the requested exemption would permit the operation of sUAS under 

acceptable conditions in airspace that is: limited, predetermined, controlled as to 

access, and would provide an increased level of safety to the best practices 

already demonstrated by SCAI at each of its sites. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation's (the 

FAA Administrator's) responsibilities to " ...establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

THE SMALL UNMANNED AIRCRAFT SYSTEM (sUAS) DETAILS: 

I. Manufacturer: 3D Robotics (see http://3drobotics.com/kb/x8/)

Model: X8+ octocopter 
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3D Robotics X8+ Specs 

Battery: 4S 14.8V 10,000 mAh 10C

Battery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 cm x 6.5 cm x 3.5 cm)

Battery Weight: 803 g

Autopilot Hardware: Pixhawk v2.4.5

Autopilot Firmware: ArduCopter 3.2

GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update)

Ground Station Radio: 3DR Radio v2 (915 MHz)

Motors: SunnySky V2216-12 KV800 II

Frame Type: X

Propellers: APC Propeller 11x4.7 SF (4)

APC Propeller 11x4.7 SFP (4)

Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm)

Payload Capacity: 800 g (1.7 lbs)

Vehicle Weight with Battery: 2.56 kg (5.6 lbs)

Maximum Altitude*: 100 m 

Range*: 300 m from launch point (1 km when geofence disabled)

Maximum Estimated Flight Time: 15 minutes

*While geofence enabled (default)

The sUAV will carry an on-board camera capable of capturing images in the form 

of full color, high definition still photos and videos. Equipped with an on-board 

flight computer sending flight data to the on-board 5.8GHz radio transmitter 

including altitude AGL, horizontal and vertical speed, battery level, compass 

direction of flight and direction back to a ground controller. 

3D Robotics X8+ Operation Manual

Flight Safety Checklist

The Name and Address of the applicant is: 

Sky Camera Aerial Images 

Attn: Darrell Richmond, Founder / President

Ph: (813) 421-4146

Email: drichmond@skycamerauav.com

Address: 154 W. Lathan Lane, Suite 101 

Citrus Springs, FL 34434
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Regulations from which the exemption is requested: 

 14 CFR Part 21 

 14 C.P.R. 45.23(b) 

 14 CFR 61.113 (a) & (b) 

 14 C.P.R. 91.7 (a) 

 14 CFR 91.9 (b)(2) 

 14 C.P.R. 91.103 

 14 C.P.R. 91.109 

 14 C.P.R. 91.119 

 14 C.P.R. 91.121 

 14 CFR 91.151 (a) 

 14 CFR 91.203 (a) & (b) 

 14 CFR 91.405 (a) 

 14 CFR 407 (a)(1) 

 14 CFR 409 (a) (2) 

 14 CFR 417 (a) & (b) 

1. Statutory Authority for Exemptions 

The Federal Aviation Act expressively grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, 

as the term is defined under section §40101 of the Act that includes sUASs, from 

the requirement that civil aircraft must have a current airworthiness certificate. 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of 

sUASs do not create a hazard to users of the NAS or the public or pose a threat 

to national security in light of the following: 

The sUASs size, weight, speed, and operational capability 

Operation of the sUAS in close proximity to airports and populated areas; and 

Operation of the sUAS within visual line of sight of the operator. 

Reform Act Section 333 (a). Lastly, if the Secretary determines that such 

operations "may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft in the national 

airspace system." Id. §333( c). 

SCAI’s sUASs are multirotor vehicles that are electricity powered, weighing less 

than 10lbs. including payload. The sUAS operate under normal conditions at 

speeds of no more than 30 knots and have the capability to hover, and move in 
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the vertical and horizontal plane simultaneously. The sUAS will operate only in 

the line of sight at all times and will operate only within the sterile area described 

and pre-established before all flights as outlined in the Flight Operation Manual. 

Such operations will insure that the sUAS will "not create a hazard to users of the 

national airspace system or the public." Reform Act Section 333 (b). 

Given the small size of the sUASs involved and the restricted environment within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUAS to commence immediately. 

Also due to the size of the sUAS and the restricted areas in which the relevant 

sUAS will operate, approval of the application presents no national security 

issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed operations, and the significant public benefit, 

including reliable and up-to-date aerial imagery along with enhanced safety for 

person’s on the ground. Exemptions associated with allowing the commercial use 

of sUAS is in the public interest. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay. 

2. Public Interest 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before 

completion of the rule-making required under Section 332 of the Reform Act. By 

granting an exemption the FAA will fulfill Congress’ intent of allowing sUAS to 

operate with significant safety precautions in low risk environments. 

The use of sUASs in aerial imaging can significantly increase the quality and 

accuracy of construction site surveys, inspections of industrial assets, power 

infrastructure and agriculture, real estate marketing and on closed-set film 

productions, while reducing the cost compared to conventional methods of aerial 

imaging. Larger more conventional aircraft are potentially hazardous due to their 

size, combustible fuel, and emission of hazardous pollutants whereas the use of 

sUASs would increase the safety of workers and the public in general. 

Additionally, the use of sUASs would allow for greater precision in imagery that 

would require an AGL too low for conventional aircrafts. 

Lastly, use of sUASs at controlled sites and under-development sites can reduce 

the risk of injury by eliminating the need for a large number of workers in a 

potentially hazardous environment. There are innumerable risks in almost every 

work place, and especially in the construction and industrial industries. The 

implementation of sUAS's can reduce the number of injuries and fatalities on 

these hazardous sites. 
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3. Equivalent Level of Safety 

SCAI puts forth that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed 

operations represent a safety enhancement to the already safe protocols 

followed on construction sites, power utility sites and film production operations 

conducted with helicopters and other conventional aircraft. 

SCAI will be bound by the following limitations when conducting its sUAS 

operation under an FAA issued exemption: 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of the Pilot. 

3. Flights will be operated at an altitude of no more than 400 feet AGL. 

4. Maximum total flight time for each operational flight will be 15 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 15 

minute limit. 

5. Minimum crew for each operation will consist of the sUAS Operator who will 

maintain VLOS with the sUAS at all times. 

6. sUAS operators will be trained in flight, operations, and safety procedures as 

detailed in the Flight Operations Manual (“FOM”). 

7. The operator will have been trained in the operation of sUAS generally and 

received up-to-date information on the particular sUAS to be operated.

8. The sUAS will only operate within a confined "sterile area" as defined in the 

“FOM”. It requires the establishment of a "Security Perimeter" for the flight 

operations area. 

9. The operator will submit a written Plan of Activities for each site.

10. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day's production activities. It will be mandatory that all personnel that will be 

performing duties within boundaries of the safety perimeter be present for this 

briefing.

11. All onsite personnel will consent to the sUAS flyover on site by waiver, and 

the operator will obtain additional verbal or written consent of all persons who will 

be allowed within 100ft of the flight operation. 
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12. Written and/or oral permission from the relevant property holders will be 

obtained. 

13. All required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other 

appropriate government agencies. 

14. If the sUAS loses communications or it loses its GPS signal, the sUAS will 

have capability to return to a pre-determined location within the Security 

Perimeter and land. 

15. The sUAS will have capability to abort flight in case of unpredictable 

obstacles or emergencies. 

4. Description of Specific Regulations 

14 C.F.R. Part 21, Subpart H: Air worthiness certificates 14 C.F.R. Section 

91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 

Section 91.203 (a) (1). Given the size and limited operating area associated with 

aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, proximity to airports and populated areas of 

the particular sUAS. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in a restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional aircraft 

(fixed wing or rotorcraft) operating with an airworthiness certificate without the 

retractions and conditions proposed. 

The sUAS to be operated here under is less than 10 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable 

materials liquid fuels, and operates exclusively within a secured area as set out 

in the Flight Operations Manual. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, pursuant to 

the Flight Operations Manual’s requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area 

of operation as is currently done on active construction and industrial sites. The 

FAA will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in 

connection to motion picture and television production, provide a greater degree 
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of safety to public and property owners than conventional operations conducted 

with airworthiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to its size, speed of operation, location 

of operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load. 

14 C.F .R. Section 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter ''N" and the registration of the 

number is displayed on limited, restricted or in a light-sport category aircraft or 

experimental or provisionally certified aircraft, the operator must also display on 

the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not 

less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 

"light spot," "experimental," or "provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, and exemption may 

be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station 

on which the word "experimental" can be placed. Given the size of the sUAS, the 

two inch lettering will be impossible. The word "experimental" will be placed on 

the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on it 

fuselage as required by §45.29 (f) where the operator, observer and others 

working with the sUAS will see the identification of the sUAS as "Experimental." 

The FAA has issued the following exemptions to this regulation to exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private pilots Privileges and Limitations: Pilot 

in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

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

can achieve the equivalent level of safety of current operations by requiring the 

PIC operating the aircraft to have logged 50 hours of flight experience along with 

200 take-offs and 200 landings with a sUAS before flying at a site, rather than 

have a commercial pilot’s license to operate this small sUAS. Unlike a 

conventional aircraft that carries a pilot and passengers, the sUAS is remotely 

controlled with no living thing onboard. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of 

safety provided by the requirements included in the Flight Operations Manual 

exceeds that provided by a single individual holding a commercial pilot's 

certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with the 

operation of a commercial operations contemplated with Part 61 when drafted, 
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that allowing operations of the sUAS as requested with a pilot who has met the 

minimum requirements outlined in the Flight Operations Manual and has logged 

a sufficient number of flights exceeds the present level of safety achieved by 14 

C.P.R. §61,113 (a) & (b). 

14 C.P.R. §91.7 (a): Civil Aircraft Airworthiness. 

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 manual for maintenance and use of safety check lists prior to 

each flight, as set forth in the manual and equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual, marking and placard in 

the Aircraft 

The sUAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot onboard, 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 operator flying the sUAS will have access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of the flight. An exemption is needed from this 

requirement as the pilot will take all actions including reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance 

data and all other actions outlined in the Flight Operations Manual (“FOM”), 

before initiation of flight. These actions will provide an equivalent level of safety. 

14 C.F.R. §91.109: 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. 

sUASs and remotely controlled aircraft, by their design do not have fully 

functioning 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 exemptions for flight training without fully functioning dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. 
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See exemption Nos.5778K & 9862A. The equivalent level of safety provided by 

that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operations of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums 

prescribed provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. This exemption is for the sUAS 

that flies similarly to a helicopter and the exemption requests authority to operate 

at altitudes of up to 400 AGL, or not more than 200 above an elevated platform 

from which filming is planned, an exemption is may be needed to allow such 

operations. As set forth by herein, except for the limited conditions stated in the 

Flight Operations Manual, the sUAS will never operate higher than 400 AGL. It 

will however be operated in a restricted area with a security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, speed of 

the sUAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner or local officials. Because of the 

advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations as set forth in 

the Flight Operations Manual. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the maximum 55lbs. proposed herein and the 

lack of flammable fuel, any risk of associated with these operations is far less 

than those presently presented with conventional aircraft operating at or below 

500 AGL in the construction surveying and industrial inspection industries. In 

addition, the low-altitude operations of the sUAS will ensure separation between 

these small sUAS operations and the operations of conventional aircraft that 

must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

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

airport or an appropriate altimeter setting available before departure." As the 

sUAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by 

the operator, pursuant to the Flight Operations Manual and Safety Checklist, 

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

before flight. 
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14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits and individual from beginning "a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and assuming 

normal cruising speed -(1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 15 minutes of powered 

flight. To meet the 15 minute reserve requirement in 14 CFR §91.151, UAS 

flights would be limited to approximately 4 minutes in length. Given the limitations 

on the UAS's proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or night 

VFR conditions is reasonable.

SCAI believes that an exemption from 14 CFR (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151(a)). Operating the small sUAS, in a 

tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risk that Section 91.151 

(a) was intended to alleviate given the size speed of the small sUAS. 

Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for 

which the exemption will be granted. 

SCAI believes that an equivalent level of safety can be achieved by limiting 

flights to 12 minutes or 20% of battery power, whichever happens first. This 

restriction would be more than adequate to return the sUAS to its landing zone 

from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration 

The regulation provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it 

has within it the following: 

(1) An appropriate and current airworthiness certificate ... 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under §91.715 is displayed at the cockpit entrance so that it is legible to 

passengers or crew. 
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The sUAS fully loaded weighs no more than 10lbs and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access 

to them; to the extent they are applicable to the sUAS. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other 

exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9816A, 

10700. 

14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (b) 

These regulations require that an aircraft operator or owner "shall have that 

aircraft inspected 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. .. ," and others 

shall inspect or maintain the aircraft in compliance with part 43. 

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

certificate, these sections will not apply to SCAI. Maintenance will be 

accomplished by the operator as referenced in the Flight Operations Manual. An

equivalent level of safety will be achieved because these small sUAS are very 

limited in size and will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise the sUAS can land 

immediately and will be operating from no higher than 400 feet AGL. As provided 

in the Flight Operations Manual, the operator will ensure that the sUAS is in 

working order prior to initiating flight, perform required maintenance, and keep a 

log of any maintenance preformed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

Pursuant to 14 C.F.R Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 91.7 

(a); 91.9 (b) (2);91.103 (b); 91.109; 91.119;91.121;91.151 (a); 91.203 (a) and (b); 

91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate 

commercially a small unmanned vehicle (10 lbs or less) in the Industrial and 

Agriculture Inspection, Construction Surveying, Real Estate Marketing and 

Closed-Set Filming operations.

Approval of exemptions allowing commercial operations of sUASs in the 

Industrial and Agriculture Inspection, Construction Surveying, Real Estate 

Marketing and Closed-Set Filming operations will enhance safety by reducing 
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risk. Conventional operations using jet or piston aircraft operate at extremely low 

altitudes just feet from the equipment and structures; and present the risks 

associated with vehicles that weigh in the neighborhood of 3,000-5,000 lbs., 

carrying large amounts of jet A or other fuel in most cases helicopters operating 

with 140 gallon fuel tanks. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operations of small sUASs, weighing less than 55 lbs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety 

supporting the grant of the Part 21 and allowing commercial operations. These 

lightweight sUASs operate at slow speeds, close to the ground and in a restricted 

environment, as a result, are far safer than conventional operations conducted 

with a piston and or turbine aircraft operating close to the ground. 

Public Acknowledgement/Privacy

All Flights will occur only once the property owner has authorized operations to 

be conducted. Images taken will be of individuals who have also consented to 

being filmed or otherwise have agreed to be in the area where aerial 

photography will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-

size, weight, speed, operating capabilities, proximity to populated areas and or 

close proximity to airports and operations within visual line of sight provides more 

than adequate justification for the grant of the requested exemptions allowing 

commercial operation of applicant's sUAS in the Industrial and Agriculture 

Inspection, Construction Surveying, Real Estate Marketing and Closed-Set 

Filming operations.

Sincerely, 

Darrell Richmond

Founder / President

Sky Camera Aerial Images 

Ph: (813) 421-4146

Email: drichmond@skycamerauav.com

Address: 154 W. Lathan Lane, Suite 101 

Citrus Springs, FL 34434