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 - 3/2/16Summary

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