June 5, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, 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.com
June 5, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, 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 applies 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 other 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 operation 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 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.” 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. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

I. STATUTORY AUTHORITY 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 subsection (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 Act 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 national 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 payload. 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 Congress 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 the 
proposed operations, and the significant 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 reduce the use of water in 

drought stricken areas like the southwest region of the United States, and can also 

catch crop disease early and prevent its spread. Sky Bridge Holdings, LLC ’s fixed wing 

UAS’s are also magnitudes more energy efficient than much larger, petroleum fueled 

aircraft traditionally used for similar purposes.

Additionally, sUAS could replace the use of helicopters 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. EQUIVALENT LEVEL OF SAFETY

Sky Bridge Holdings, LLC proposes that the exemption requested herein apply to sUAS 

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 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 limitations 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, and 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 planned sUAS operations prior to each 

day’s activities. It will be mandatory that all personnel 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 all persons who will be

allowed within 100 feet of the flight operation.

9. Pilot will have been trained in operation of UASs generally and received up-to-date 

information on the particular UAS to be operated.

10. Written and/or oral permission from the relevant property holders will be obtained.

11. All required permissions and permits will be obtained from territorial, state, county or 

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

governmental agencies.

12. The UAS has provisions for automatically returning to a predetermined safe site if 

direct ground control is lost.

III. DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR 61.113 (a) & (b): Private pilot 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 Pilot operating the 

aircraft to have (1) completed a sUAS flight training course and (2) a Sport Pilot 

certificate. The FAA has previously acknowledged in prior grants of exemption under 

Section 333 that a commercial pilot’s certificate was not necessary to operate 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 Pilot in command have 

the requisite training and understanding of the National Airspace System, and also 

ensures that the Pilot is registered 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 passengers, the sUAS is 

remotely controlled with no living thing 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 advance.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger 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, to 
provide security for the area of operation. 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 requested 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 Action

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

ensure the safety of flight. An exemption is needed from this requirement as the Pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery and fuel requirements and checking takeoff and landing distances. These 

actions will provide an equivalent level of safety.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation 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 a fixed wing aircraft, which will typically 

operate at altitudes of 200 AGL, so an exemption may be needed to allow such 

operations. The sUAS will never operate at altitude higher than 400 AGL and will be in a 

restricted area with 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 any onsite personnel, all affected individuals will be aware of the 

planned flight operations. In addition, the low-altitude operations 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: 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 by confirming the altitude 

of the launch site shown on the 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 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 sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Sky Bridge Holdings, LLC . Maintenance 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 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. The Pilot 

will ensure that the sUAS is in working order prior to initiating 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, subpart 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 unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operations of sUAS in agriculture 

enhances safety while reducing risk. Manned aircraft monitoring and surveying creates 

a greater risk because the craft are much larger and carry an onboard human pilot. In 

contrast, a sUAS weighing fewer than 55 lbs. eliminates virtually all of that risk given the 

reduced mass. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft flights.

The operation of small 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 the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

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

photography will take place.