**EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY**

Sky pics, LLC requests an exemption from the following regulations as well as any additional regulations that may technicall y appl y t o the operation of the UAS Sy stem: **14 CFR Part 21, Airworthiness Certificates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Sy stems, we request an experimental ce rtificate be issued for the DJ I Inspire 1, DJ I Phantom Vision 2, and the Turbo Ace Matrix S, under either, or both, of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: **(a) Resea rch and development.**  Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations.** Conducting flight tests and other operatio ns to show compliance with the airworthiness regulations including flights to show compliance for issuance of ty pe and supplemental ty

pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliab ility requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market survey s, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our comme rcial purpose as well. The aircraft will not carry persons or property , will not carry fuel, and will only

fly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we propose th at the UA will be at least as safe, if not safer, than a conventionall y certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

**14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.**  As no such ce rtificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.**91.119 Minimum safe altitudes: General.**

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be photograph y or survey of persons, vessels, vehicles or structures it would, at times, be necessary to operate closer than 500 feet to the items listed. Operations will only

be flown over propert y or persons where permission has been obtained and careful pre

- planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property

on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
**CFR 91.121 Altimeter settin gs.**  The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UAS will alway s fl y below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.
**14 CFR 91.151 Fuel requirements for flight in VFR conditions.**  The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fly after that for at least 30 minutes and night

- VFR conditions an additional 45 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safet y buffer for delay s to landing. The UAS is battery operated and the maximum duration of flight from a si ngle battery

charge is approximately

15 minutes with an additional 25% reserve. Since the aircraft will never fl y more than 1/2 NM from the point of intended landing, a full battery

charge at launch will ensure that we meet the reserve energy requirement o f this paragraph. The PI C has a visual reference to the remaining battery energy level and an estimated “return to home” energy requirement. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy ".
**14 CFR Subpart E 91.401** 

**- 91.417** 

**- Maintenance, Preventive Maintenance,**  **Alterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworth y condition, including compliance with part 39 and 43. Paragraphs 91 .407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworth y condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed b y the PI C is limited to r epairing smallcracks, replacing a propeller, checking electrical connections and updating software and

firmware for the on

- board computer. The manufacturer or a manufacturer

- designated repair facility

will perform all other maintenance . The PI C will docum ent work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PI C can ensure an equivalent level of safety. Granting this request would be in the public’s interest because it could benefit th e town. Pictures could be taken of various destinations around the town and could be used for marketin g. Being in a historic shoreline town, marshes and watery places are not easil y accessible by

conventional means. Therefore, the drone can be used to t ake pictures of lighthouses etc. and can be used for search and rescu e services that authorities cannot get to. This exemption will not adversel y a ffect safet y because I am an experienced helicopter pilot and have knowledge of general aviation safety
.