June 5, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590

Dear Sir or Madam:
Attached please find Sky Bridge Holdings, LLC’s request for an exemption from the listed Federal Aviation Regulations to allow for the completion of development and commercial operation of its Small Unmanned Aircraft Systems (“sUASs”) for aerial imaging and remote sensing for a variety of applications including, but not limited to, agriculture. This exemption request is exclusively for the UAS manufactured by Sky Bridge Holdings, LLC, a Greenville, South Caroline based company.
Thank you for your time and consideration, and please let me know if you have any questions.

Sincerely, 

## M.L. Henderson

Michael L. Henderson Chief Executive Officer Sky Bridge Holdings, LLC

1110 W . Butler Rd, Suite i Greenville, SC 29607 PH: 864

- 641

- 7780 Email: mhenderson@skybridgeuas.comJune 5 , 2015

U. S. Department of Transportation
Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119; 91.121; 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (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 Bridge Holdings, LLC , a commercial UAS manufacturer, hereby ap plies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned Aircraft Systems (“sUAS”) for aerial imaging and sensing for a variety of applications, such as evaluating crop health and othe r agricultural use cases, 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 the requested exemption would permit the operat ion of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already best practices safety protocols followed by Sky Bridge Holdings, LLC . Approval of t his 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.” Section 333( c) of the Reform Act.
The name and address of the applicant is: Sky Bridge Holdings, LLC 1110 W . Butler Rd, Suite i Greenville, SC 29607 PH: 864

- 641

- 7780 Email: mhenderson@skybridgeuas.com
Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 (a) & (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 14 C.F.R. 91.121 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.40 5 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)

**I. STA** **TUTORY AUT**  **HORITY FOR EXEMPTIONS**
The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsecti on (a) or (b) of this section or any sections 44702

-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).
Section 333(b) of the Reform A ct assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security. If the Secretary determines that a sUAS “may operate safely in the n ational airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id

. §333(c).
Sky Bridge Holdings, LLC ’s sUAS are fixed wing aircraft, weighing 55 or fewer lbs. including payloa d. They operate under normal conditions at a speed of no more than 50 knots. The sUAS will operate only in the Pilot’s visual line of sight at all times. 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 sUAS involved and the restricted environment within which they will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which C ongress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also due to the small size of the sUAS and the low altitudes and restricted areas in which the 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 theproposed operations, and the significan t public benefit, including enhanced safety, the

grant of the requested exemptions is in the public interest. Accordingly, Sky Bridge Holdings, LLC respectfully requests that the FAA grant the requested exemption without delay.

**II. 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 NAS before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill Congress’s intent of allowing UAS to operate with significant safety precautions in low risk environments. The use of sUAS on crops, vineyards and ranches can significantly reduce the use of natural resources and the environmental impact of agriculture across the United States. The data collected with these UAVs will be used to greatly red uce the use of water in drought stricken areas like the southwest region of the United States , and can also catch crop diseas e early and prevent its spread. Sky Bridge Holdings, LLC ’ s fixed wing UAS’s are also magnitudes more ene rgy efficient than much larger, petroleum fueled aircraft tradi tionally used for similar purposes.
Additionally, sUAS could replace the use of he licopters and small aircraft to monitor sites. Shifting to sUAS from helicopters presents a marked safety increase for our workers and the public.
Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and data collection as compared with manned systems that are currently used for these types of applications.

**II. EQUIVA**  **LENT LEVEL OF SA FETY** 
Sky Bridge Holdings, LLC proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate with the limitations l isted herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the c urrent regulatory structure because the propose d operations represent a safety enhancement to the already safe protocols followed for agricultural aplications and imaging and surveying operations conducted with helicopters and other conventional aircraft.
Sky Bridge Holdings, LLC will be bound by the following limit ations when conducting its sUAS operations under an FAA issued exemption: 1. The sUAS will be less than 55 pounds. 2 Visual line

- of

- sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer. 3. Operations will only be conducted during daylight. 4. Flights will never exceed 400 feet AGL.5 . The sUAS Pilot will be trained in flight, operations, an d safety procedures

.

6 . The sUAS will only operate within a confined area. Access to the flight area will be controlled during flight operations. 7 . A briefing will be conducted in regard to the planne d sUAS operations prior to each day’ s activities. It will be mandatory that all perso nnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 8 . All onsite personnel will consent to the UAS flyover on site by waiver, and the operator will obtain additional verbal or written consent of a ll persons who will be allowed within 100 feet of the flight operation. 9 . Pilot will have been trained in operation of UASs ge nerally and received up

- to

- date information on th e particular UAS to be operated

. 1 0

. Wr itten and/or oral permission from the rel evant property holders will be obtained. 1 1 . All required permissions and permits will be obtained fro m territorial, state, county or city jurisdictions, including local law enforcem ent, fire, or other appropriate governmental agencies. 1 2

. The UAS has provisions for automatically returning to a predetermined safe site if direct ground control is lost.

**III. DESCRIPTION OF SPECIFIC REGULA** **TIONS**
**14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command** Sections 61.113 (a) & (b) limit private pilots to non

- com mercial 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 re quiring the Pilot operating the aircraft to have (1) complete d a sUAS flight training course and (2) a Sport Pilot certificate. The FAA has previously acknowledged in prior grants of exe mption under Section 333 that a commercial pilot’s certificate was not necessary to o perate a sUAS, but that the FAA could not waive the requirement for an FAA

- issued pilot’ s license. A Sport Pilot certificate addresses the FAA’s requirement that the Pilo t in command have the requisite training and understanding of the National Airspace System, and also ensures that the Pilot is regis tered with the FAA and will not pose a risk to national security. The Sport Pilot certificate also does not require the Pilot to undertake the additional cost and time of additional manned aviation flight time that the Private Pilot’ s license requires and which will not translate to skill or competency operating the sUAS.
Unlike a conventional aircraft that carries the pilot and p assengers, the sUAS is remotely controlled with no living t hing or cargo on board. Sky Bridge Holdings, LLC ’ s sUAS is also operated by an autopilot, which greatly reduces the danger of human error. The area of operation is controlled and restricted , and all flights are planned and coordinated in ad vance

. The sUAS to be op erated hereunder is less than 55 lbs. fully loaded, carries neit her a pilot nor pass enger and operates exclusively within a secured. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator

, and under the requirements and in compliance with local public safety requirements, toprovide security for the area of operati on . The FAA will have advance notice of all

operations.
The risks associated with the operation of the sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations of the sUAS as request ed with a Pilot who has met the minimum requirements previously defined achieves the level of safety contemplated by 14 C.F.R. §61.113 (a) & (b).

**14 C .F.R. 91.103: Preflight A** **ction** This regulation requires each pilot in command take c ertain actions before flight to ensure the safety of flight. An exemption is needed from thi s requirement as the Pilot will take separate preflight actions, including check ing for weather conditions, checking flight battery and fuel requirements and checking takeoff and landing distance s . These actions will provide an equivalent level of safety.

**14 C.F. R. 91.119: Minimum Safe A ltitudes**  Section 91.119 establishes safe altit udes for operation of civ il aircraft. Section 91.119 (d) allows helicopters to be operated at less than the mi nimums prescribed, provided the person operating the helicopter complies with any route or al titudes prescribed for helicopters by the FAA. This e xemption is for a fixed wing aircraft, which will typically operate at altitudes of 200 AGL, so an exempt ion may be needed to allow such operations. The sUAS will never operate at altitude higher than 40 0 AGL and will be in a restricted area with security perimeter, where buildings an d people will not be exposed to operations without their pre

- obtained consent.
The equivalent level of safety will be achieved given the s ize, weight, speed of the sUAS as well as the location where it is operated. No flight w ill be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and any onsite personnel , a ll affected individuals will be aware of the planned flight o perations. In addition, the low

- altitude ope rations of the sUAS will ensure separation between sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. 91.121: A ltimeter 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 ha ve a barometric altimeter, but instead a GPS a ltitude read out, an exemption may be needed. An equivalent level of safety wi ll be achieved by the operator by confirming the altitude of the launch site shown on th e GPS altitude indicator before flight.
**14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections**  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 inspe ctions, except as provided in paragraph (c) of this section, have discrepancies repaired asprescribed in part 43 of this chapter...,” and others shall insp ect or maintain the aircraft

in compliance with Part 43.
Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate , these sections will not apply to Sky Bridge Holdings, LLC

. M aintenance will be accomplished by the operator . An equivalent level of safety will be achieved because these small sUAS are very limited in size and will carry a small payload and opera te onl y in restricted areas for limited periods of time. If mechanical issues arise th e sUAS can land immediately and will be operating from no higher than 400 feet A GL. The Pilot will ensure that the sUAS is in working order prior to init iating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Pilot 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, subpa rt H; 14 C.F.R 45.23(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); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unm anned vehicle (55lbs or less)

. Approval of exemptions allowing commercial operations of sUAS in agriculture enhances safety while reducing risk. Manned aircraft mon itoring and surveying creates
a greater risk because the craft are muc h larger and carry an onboard human pilot. In contras t, a sUAS weighing fewer than 55 lbs. eliminates virtually all of that risk given the reduced mass . The sUAS will c arry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of s mall sUAS, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from th e requirements of Part 21 and allowing commercial operati ons. These lightweight aircraft operate at slow speeds, close to the ground, and in a steril e environment and, as a result, are far safer than conventional operations conducted with turbine helicop te rs operating in close proximity to the ground and people.
**Privacy** All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to bei ng filmed or otherwise have agreed to be in the area where aerial photography will take place.