EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Skypics, LLC requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of the UAS System: 

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 

Systems, we request an experimental certificate be issued for the DJI Inspire 1, DJI 

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) Research 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 operations 

to show compliance with the airworthiness regulations including flights to show 

compliance for issuance of type and supplemental type certificates, flights to substantiate 

major design changes, and flights to show compliance with the function and reliability

requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial 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 that the UA will be at least as safe, if not safer, than 

a conventionally 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 certificate 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 photography 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 property 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 settings. 

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 always fly 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 fly 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 safety buffer 

for delays to landing. The UAS is battery operated and the maximum duration of flight 

from a single battery charge is approximately 15 minutes with an additional 25% reserve. 

Since the aircraft will never fly 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 of 

this paragraph. The PIC 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 airworthy 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 PIC 

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 airworthy 

condition prior to every flight and in addition conduct detailed inspections after every

two hours of flight. Maintenance performed by the PIC is limited to repairing small 
cracks, 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 PIC will document work 

performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Granting this request would be in the public’s interest because it could benefit the town. 

Pictures could be taken of various destinations around the town and could be used for 

marketing. Being in a historic shoreline town, marshes and watery places are not easily 

accessible by conventional means. Therefore, the drone can be used to take pictures of 

lighthouses etc. and can be used for search and rescue services that authorities cannot get 

to.

This exemption will not adversely affect safety because I am an experienced helicopter 

pilot and have knowledge of general aviation safety.