Sky Optics LLC

 Mike Lombardo, Owner 

 1444 Basin View Circle 

 Las Vegas, NV 89123 

 702-610-8599 

March 9, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

To Whom it May Concern, 

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

and 14 C.F.R. Part II, Sky Optics LLC seeks exemption from the Federal Aviation Regulations 

below to allow for commercial operation of an unmanned aircraft system for the purposes of real 

estate, architecture, construction and more. Sky Optics LLC is a real estate photography 

company, established in 2016, that seeks to operate legally, offering aerial photography, among 

other services, to real estate agents, architects, builders, property owners and other companies, 

organizations and institutions. 

Extent of Relief 

14 CFR Part 21 subpart H

I request exemption based on the size, weight, speed, and limited operating area associated 

with the aircraft. It carries neither pilot nor passenger and no explosive materials or flammable 

liquids. In the restricted environment and under the conditions proposed, operation will be as 

safe, or safer, than a conventional aircraft. 

14 CFR 91.7 (a)

No FAA regulatory standard currently exists for determining airworthiness of this aircraft. Nor is 

there an appropriate airworthiness certificate. With exemption, the pilot in command will be 

responsible for determining whether the aircraft is in condition for safe flight. 
14 CFR 91.9 (b) (2)

Given its size, the aircraft does not have the ability to carry a flight manual, nor does it carry any 

pilot or passenger to reference one. An equivalent level of safety will be maintained by keeping 

the flight manual at ground control where the pilot in command will have immediate access to it. 

14 CFR 91.103

Exemption is requested because FAA-approved flight manuals are not available for the aircraft. 

Standard pre-flight procedures will include: aircraft inspection, review of weather forecasts, 

assessment of aircraft battery level, inspection of takeoff/landing locations and more. 

14 CFR 91.105

Exemption requested: does not apply because the aircraft does not carry crew-members. 

14 CFR 91.109

Exemption is requested because the UAS does not have fully functional dual controls. Flight 

control is achieved through the use of a remote controller that communicates with the aircraft via 

radio communication. The equivalent level of safety is ensured because the aircraft carries 

neither pilot nor passengers. 

14 CFR 91.119 (c)

Exemption is requested because the aircraft will not fly above 400 feet and will not fly over 

highly populated areas. 

14 CFR 91.121

The aircraft uses electronic GPS with a barometric sensor for altitude readings. Exemption is 

requested because it does not have an altimeter. 

14 CFR 91.151

Exemption requested: does not apply because the aircraft does not run on fuel. 

14 CFR 91.203 (a) and (b)

Given its size, the aircraft does not have the ability to carry registration documents, nor does it 

carry any pilot or passenger to reference one. An equivalent level of safety will be maintained by 

keeping these documents, to the extent that they are applicable, at ground control where the 

operator will have immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Given these sections only apply to aircraft with an airworthiness certificate, they not apply to this 

applicant. For safety, standard pre-flight inspections/procedures will be performed before each 

flight. 
 

The Unmanned Aircraft System 

The Aircraft: A Phantom III Professional, manufactured by DJI.

 A Phantom 4 , manufactured by DJI 

 An Inspire 1, manufactured by DJI 

All 3 of these aircrafts have these features in common: 

● A flight computer with GPS navigation that receives flight control signals from a 

 ground-based transmitter/controller. The computer has the ability to send flight data to 

 the on-board radio transmitter including altitude, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site. 

 ● A camera capable of capturing images in the form of full color, 4K definition video and 

still photo images. 

 ● A 2.483 GHz on-board radio transmitter that transmits live video from the on-board 

camera to the ground station, as well as flight data including altitude, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site. 

The Ground Station: A 2.483 GHz radio receiver/controller, operated by the pilot in 

command to control the aircraft from launch to landing. 

 ● All 3 Aircraft have an emergency button on the remote controller that sends a signal 

 to the aircraft to return to the takeoff point and land autonomously. 

Public Interest 

Granting this exemption is in the public’s best interest in the following ways: 

 ● Use of the UAS will support local commerce, leading to economic growth. 

Safe, efficient, affordable aerial photography allows property owners and real 

estate agents greater perspectives on private and commercial properties, thereby 

greatly enhancing their marketing tools. 
 ● Use of the UAS for aerial photography, will enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft, carrying a crew and flammable fuel. 

 ● Aerial inspections of construction/building sites will increase work site 

efficiency, reduce risk and improve workplace safety. 

Safety 

The DJI Phantom III Professional, The DJI Phantom 4 and The DJI Inspire 1 meet the 

definition of "small unmanned aircraft" found in section 331 of The Reform Act. Standard 

safety precautions may include, but are not limited to: 

 ● regular performance of preflight safety inspections/procedures 

 ● maintaining records of flight information (flight logs) 

 ● The aircraft will be operated within visual line-of-sight at all times 

 ● no operations within 5 miles of an airport, unless proper permission has been

 obtained. 

 ● areas to be flown/photographed are predetermined, allowing time for careful 

 inspection of the terrain before take-off 

 ● all operations to take place during daylight hours 

 ● built in GPS allows for automatic “return-to-home” in the event of low battery or 

 loss of communication.

 ● all operations to occur in FAA Class G airspace at no more than 400ft. 

We Currently have liability insurance. 

 U.S. Specialty Insurance Company

 5601 Granite Parkway, Suite 1100 Plano, TX 75024 (469) 633-7400 

 Policy Number: AC3007100-00 Inception date - 3/2/16 
Summary 

 Sky Optics LLC is seeking relief from the Federal Aviation Regulations above to allow 

commercial operation of an unmanned aircraft system for purposes of real estate, 

architecture, construction and more. Given the size, weight, speed, and limited operating 

area associated with the aircraft I find this exception to be safe and reasonable. 

Please let me know if you need further information. 

Sincerely, 

Michael A Lombardo Jr. 

Sky Optics LLC