Re:

The Law Office of Darrell J. Green, LLC

770 S. Willow Park Drive

Lehi, UT 84043

Telephone: (660) 624 -2181

Email : gr een.7 7 0 @comcast.net

October 24,2015

VIA ELECTRONIC SUBMISSION

Federal Docket Manasement Website

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE,

Washington, DC 20590

Request for Exemption pursuant to Section 333 of the FAA Modernization and Reform

Act of 2012 and 14. C.F.R. Part 11

Dear Sir or Madam:

SkyCandy Digital Cinema, LLC (SkyCandy) is an owner of small Unmanned Aircraft

(sUA) and is in the business of aerial data collectionr including aerial videography and

photography. This data collection is conducted for the motion picture and television industry,

media and advertising industries and other private and public entities, natural resource

videography, real estate and general videography and photography in pre-planned, controlled

access property, private and public areas.

SkyCandy is requesting regulatory and statutory relief pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11 to allow

commercial operations of its sUA. These operations will be conducted pursuant to the conditions

described within this request and in accordance with those established by the Federal Aviation

Administration (FAA) and as required by Section 333 of the Reform Act. Granting the requested

exemption would permit the operation of small, unmanned aircraft systems under controlled

conditions in airspace that is limited and predetermined over private, controlled access property

or public property where approved and will do so with the property owner's consent and

knowledge. Only people who have consented or otherwise agreed will be in the area where

videography and photography will take place. All permissions, authorizations, permits, grants or

other required authorizations would be secured prior to operation.

Granting this exemption would enhance the already safe operations in aerial videography

and photography in the aforementioned industries. This in tum fulfills the Secretary of

Transportation's (the FAA Administrator's) responsibilities to "...establish requirements for the

1 "Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples include imagery fuhotography, video, in&ared, etc.), electronic measurement (precision surveying, RF

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by

instruments aboard the UA." Federal Aviation Administration. (2015). Trileaf Corporation, Exemption No. 13212

Regulatory Docket No. FAA-20151165, p.2.
safe operation of such aircraft systems in the national airspace system" (The Reform Act, Section

333(c)).

The name and address of the applicant is:

SkyCandy Digital Cinema, LLC

Attn: Mr. Christopher Jordan

Telephone: (435)232-3633

Email: cj@flyskycandy.com

Address: 838 Majestic Drive

Logan, UT 84321

l. FAA authority for granting exemptions

Section 333 (a) through (c) of the Reform Act required the Secretary of Transportation

". . . . to determine if certain unmanned aircraft systems may operate safely in the national

airspace system before completion of the plan and rulemaking required by section 332 of this

Act or the guidance required by section 334 of this Act."

The Secretary is required to assess the UASs and determine if the UAS may safely

operate in the National Air Space (NAS) based upon the following criteria:

(1) . . their size, weight, speed, operational capability, proximity to airports and

populated oreas, and operation within visual line of sighr [emphasis added] do not create

ahazard to users of the national airspace system or the public or pose a threat to national

security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness

certification under section 44704 of title 49, United States Code, is required for the

operation of unmanned aircraft systems identified under paragraph (1).

The Secretary is then required to o'. 

. . establish requirements for the safe operation of

such aircraft systems in the national airspace system." Reform Act, Sec. 333 (c). Pursuant to this

requirement the Secretary may define conditions (through the Federal Aviation Administration)

for the safe operation of the UAS.

Granting this request for exemption would fulfill Congress' goal in passing Section

333(a) through (c) of the Reform Act and the Federal Aviation Act.

II. Request will benefit the public as a whole

The Administrator may grant an exemption from a requirement of a regulation prescribed

under Section 333 of the Reform Act if the Administrator flnds the exemption is in the public

interest.

SkyCandy's sUA are the DJI Spreading Wings S1000 and the Freefly ALTA weighing 55

pounds or less, including payload. SkyCandy's request fits the defined criteria as established by

Page 2 of 13
Congress and the FAA based upon the small size of the UA involved and the predetermined

environment within which it will operate. Due to the defined operational parameters there are no

national security issues. Based upon the intent and specific language as provided in Section 333

of the Reform Act and the authority of the FAA, there exist a significant public benefit for

granting this exemption.

The ability to gather the images of nature for publication, not otherwise available to

capture, will allow states to promote tourism. This in turn will increase state and local

economies in a more economic and safe basis preserving wildlife environments. These images

can be captured with a reduction in the environmental impact as set forth in the next section of

this request. The ability to video and photograph images for the motion picture and television

industry and the media and advertising industry will allow for greater dexterity resulting in a

superior product which in turn increases revenue but with a decreased expenditure.

The ability to video and photograph images for the real estate, media and advertising

industry will enhance community awareness and augment real estate listings and advertisements.

Granting this exemption further benefits the public by improving safety and reducing risk " . . .

by alleviating human exposure to danger associated with current aerial survey and inspection

methods, namely, full size helicopters. Manned helicopters performing photography or

videography have experienced an exceedingly high number of accidents and fatalities. Helicopter

crashes have taken more lives on film sets than any other type of accident in modem times. Since

1980, 33 film and TV workers 

- 

nearly one a year 

- 

have been killed in helicopter accidents

around the world, 14 in the U.S. and 15 more for American companies shooting abroad. The

public's interest is fuithered by reducing human exposure to death or serious injury associated

with manned aircraft performing these services" Jeffrey Hug dba jefftrug360, Exemption No.

1143I, Regulatory Docket No. FAA-2015-0169.

The use of UAS technology to obtain imagery, information and data currently obtained

by use of manned flight or manual methods: (1) reduces statistical risk to human life due to

manned aircraft accidents and due to other dangerous activities that can be avoided (e.g.,

scaffoldinglfigging failures during stack); (2) reduces the cost of obtaining such information,

which benefits consumers and the economy; (3) reduces environmental impact by eliminating

sources of hydrocarbon emissions from manned aircraft; (4) preserve wildlife environments; and

(5) increase the state and local economies via the introduction of new technological equipment

utilized by start-up companies.

ilI. Aircraft and Equivalent Level of Safet),

SkyCandy asserts that the exemption requested applies to civil aircraft. (sUA) described

within this application. The enhanced safety (set forth in detail below) is coupled with a

reduction in environmental impacts such as reduced emissions as compared to a full scale

aircraft", less expensive personnel and equipment costs, and reduced noise. 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 aerial video, photography and aerial data collections operations conducted with

conventional aircraft.

Page 3 of 13
A. DJI Spreading Winss 51000

The DJI Spreading Wings S1000 small UA is manufactured commercially by DJI and

available for purchase in the United States weighing less than 55 pounds. This professionally

designed sUA with integrated stabilization, retractable landing gear, vibration dampers, small

frame arm incline and minimalized gimbal mount, integrated power hub with patented coaxial

connectors, builrin-high speed ESCs and high efficiency propellers provide dynamic stability

with maximized power efficiency provides the equivalent level of safety required by the

Administrator.' It is modular in design consisting of eight (8) motors which will utilize a DJI 42

Multi-Rotor stabllization controller (Flight Controller) for commercial, industrial and

professional multi-rotor platforms. The DJI S 1000 will be assembled and operated in accordance

with manufacturers' specifications and SkyCandy's Operational procedures including failsafe

procedures set forth in the attached manufacturer's documentation.

1. DJI S1000 Release Notes (Attachment A)

2. DJI S1000 User Manual vl.l0 (Attachment B)

3. A2 Flight Control System User Manual,vl.22, May 15,2015 Revision (Attachment

c).

4. ,{2 Product Release Notes (Attachment D)

5. Tabular specifications for the DJI Spreading Wings series (Attachment E) -

proprietary document and will be emailed to: 3-1-lexemptiansrlgltha.g*y.

6. SkyCandy S1000 Operational Procedures (Attachment F)

B. Freefly ALTA

Freefly ALTA is a professional multi-rotor aircraft with a maximum weight of 13.6

kilograms (approximately 30 pounds) designed for professional cinematic, television, and

photographic applications. The Freefly ALTA has an integrated GPS and flight control software

utilizing a SYNAPSE flight controller. The ALTA's is designed to operate in multiple flight

modes including manual, height mode, position mode, return-to-home, and auto land. These

built-in fail safe procedures provide the additional equivalent level of safety required by the

Administrator. The Freefly ALTA will be assembled and operated in accordance with

manufacturers' specifi cations and SkyCandy' s Operational Procedures.

l. ALTA User Manual, Revision B (Attachment G).

2. ALTA Setup Guide (Attachment H)

3. SkyCandy Freefly ALTA Operational Procedures (Attachment I)

The Administrator previously approved three (3) Section 333 exemptions for operation of the

Freefly Alta:

1. Copeland RED, LLC - July 21,2015, Exemption No. 12103, Regulatory Docket No.

FAA-20r5--0956

2 Spreading Wings S1000 UserManual, Vl.t0, 2014.11,P. 3. Retrieved from: http:/idownload.djiinnovations.com/downloads/s 1000/erlS I 000 User_Manual_vl . I O_en.pdf

Page 4 of 13
2.

a

J.

Samuel Fleishman - August 6, 2015,

FAA-201 5-1624

4th Dimension Sight & Sound, Inc. -

Docket No. FAA-201 5-1945

Exemption No. 12362, Regulatory Docket No.

August | 1, 201 5, Exemption No. 1 2428, Regulatory

SkyCandy asserts that the aforementioned exemptions already granted by the Administrator

for operation of a Freefly ALTA are similar in all respects to the instant request of SkyCandy.

C. Transmitter

The DJI Spreading Wings 51000 and the Freefly ALTA small UA will be operated with

Futaba Model 14SG which is FCC compliant.

1. The general specifications for the Futaba SGl4 are:

A 14-channel system with2.4 GHz FASSTest technology compatible with Futaba FASST

and S-FHSS protocols. The 14SG can transmit and receive telemetry data. When utilizing this

transmitter with any of the Spreading Wing series UA, operations will be in accordance with the

Futaba 14SG Instruction Manual which includes detailed specifications (see Attachment J,

Futaba 14SG Instruction Manual).

Summary

The DJI Spreading Wings S1000 and the Freefly ALTA will be operated in accordance with

all conditions and limitations as stated within the respective User Manuals and will be operated

and maintained in conformance with all manufacturers' documentation as required in the

aforementioned documents and SkyCandy' s Operational Procedures.

To provide an equivalent level of safety, SkyCandy agrees to be bound by the

following limitations and conditions when conducting commercial operations under an FAA

issued exemption:

1. Operations limited to the DJI S1000 and the Freefly ALTA series aircraft which weigh

less than 55 pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming will not be

conducted without an FAA approved Motion Picture and Television and Operations

manual (MPTOM). Sk)rCand), is not submitting a Motion Picture Television and

Operations Manual with this Request for Exemption and requests that the Administrator

process this request without a MPTOM.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no

case will the UA be operated at airspeeds greater than the maximum UA operating

airspeed recommended by the aircraft manufacturer. (see Attachments).

Page 5 of 13
4.

5.

6.

Maximum total flight time for each operational flight will be 30 minutes. Flights will be

terminated at 25o/o battery power reserve should that occur prior to the 30 minute

Iimit.

The UA's will be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitudes will be reported in feet AGL.

The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or

U.S. driver's license.

All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The

VO and PIC will be able to communicate verbally at all times. Electronic messaging or

texting will not be permitted during flight operations. The PIC will be designated before

the flight and will not transfer his or her designation for the duration of the flight. The

PIC will ensure that the VO can perform the duties required of the VO.

All documents needed to operate the UAS and conduct its operations in accordance with

the conditions and limitations in a grant of exemption (hereinafter referred to as the

operating documents) will be accessible during UAS operations and made available to the

Administrator upon request.

The UA will operate only in predetermined private, controlled access or public property

where approved and will do so with the property owner's consent and knowledge and that

only people who have consented or otherwise have agreed will be in the area where aerial

videography and photography will take place. All permissions, authorizations, permits,

grants or other required authorizations will be secured prior to operation.

10. Any UAS that have undergone maintenance or alterations that affect the UAS operation

or flight characteristics, e.g., replacement of a flight critical component, will undergo a

functional test flight prior to conducting further operations. Functional test flights will

only be conducted by a PIC with a VO and will remain at least 500 feet from other

people. The functional test flight will be conducted in such a manner so as to not pose an

undue hazard to persons and property.

I 1. SkyCandy is responsible for maintaining and inspecting the UAS to ensure that it is in a

condition for safe operation.

12. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is

in a condition for safe flight. The pre-flight inspection will account for all potential

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals

a condition that affects the safe operation of the UAS, the afucraft. will not be operated

until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. (see Attachments).

7.

8.

9.

Page 6 of 13
13. SkyCandy will follow the UAS manufacturer's maintenance, overhaul, replacement,

inspection, and life limit requirements for the aftcraft and aircraft components.

14. Each UAS operated under the exemption will comply with all manufacturer safety

bulletins.

15. The PIC will hold either an airline transport, commercial, private, recreational, or sport

pilot certificate. The PIC will also hold a current FAA airman medical certificate or a

valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a

territory, a possession, or the Federal government. The PIC will also meet the flight

review requirements specified in 14 CFR $ 61.56 in an aircraft in which the PIC is rated

on his or her pilot certificate.

16. SkyCandy will not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under

the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from persons, vessels, vehicles and structures. PIC qualification flight hours

and currency will be logged in a manner consistent with 14 CFR $ 61.51(b). Flights for

the purposes of training the operator's PICs and VOs (training, proficiency, and

experience-building) and determining the PIC's ability to safely operate the UAS in a

manner consistent with how the UAS will be operated under the terms of the exemption.

Training operations will only be conducted during dedicated training sessions. During

training, proficiency, and experience-building flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC will operate the UA with

appropriate distance from nonparticipants in accordance with 14 CFR $ 91.119.

17.UAS operations will not be conducted during night, as defined in 14 CFR $ 1.1. All

operations will be conducted under visual meteorological conditions (VMC).

18. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted

with an ARP, the center of the airport symbol as denoted on the current FAA-published

aeronautical chart, unless a letter of agreement with that airport's management is

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of

agreement with the airport management will be made available to the Administrator or

any law enforcement official upon request.

19. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

20.1f the IJA loses communications or loses its GPS signal, the UA will return to a predetermined location within the private, controlled-access or public property.

21 . The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

Page 7 of 13
22.The PIC will not begin a flight unless (considering wind and forecast weather conditions)

there is enough available power for the UA to conduct the intended operation and to

operate after that for at least five minutes or with the reserve power recommended by the

manufacturer if greater.

23. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be conducted in accordance with an ATO-issued COA. The exemption

holder may apply for a new or amended COA if it intends to conduct operations that

cannot be conducted under the terms of the granted COA.

24. All aircraft operated in accordance with the proposed exemption will be identified by

serial number, registered in accordance with 14 CFR part 47, and have identification

(N-Number) markings in accordance with 14 CFR part45, Subpart C. Markings will be

as large as practicable.

25. Documents used by SkyCandy to ensure the safe operation and flight of the UA and any

documents required under 1 4 CFR $ $ 91 .9 and 9l .203 will be available to the PIC at the

Ground Control Station of the UAS any time the aircraft is operating. These documents

will be made available to the Administrator or any law enforcement official upon request.

26.The UA will remain clear and give way to all manned aviation operations and activities at

all times.

27.The UA will not be operated by the PIC from any moving device or vehicle.

28. All Flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator will ensure

that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations will cease immediately in a manner ensuring the safety

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not present

an undue hazard. The PIC, VO, operator trainees or essential persons will not

considered nonparticipating persons under a proposed exemption.

79. All operations will be conducted over private, controlled-access or public property with

permission from the property owner/controller or authorized representative. Permission

from property owner/controller or authorized representative will be obtained for each

flight to be conducted.

Page 8 of13
30. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: www.ntsb.gov.

31. If the exemption permits operations for the purpose of closed-set motion picture and

television filming and production, SkyCandy:

a. Must have a motion picture and television operations manual (MPTOM) as

approved by the Federal Aviation Administration.

b. At least 3 days before aerial filming, the operator of the UAS affected by the

proposed exemption must submit a written Plan of Activities to the local Flight

Standards District Office (FSDO) with jurisdiction over the area of proposed

filming. The 3-day notification may be waived with the concurrence of the FSDO.

The plan of activities must include at least the following:

i.

ii.

iii.

Dates and times for all flights;

Name and phone number of the operator for the UAS aerial

filming conducted under this grant of exemption;

Name and phone number of the person responsible for the onscene operation of the UAS;

Make, model, and serial or N-Number of UAS to be used;

Name and certificate number of UAS PICs involved in the aerial

filming;

A statement that the operator has obtained permission from

property owners andlor local officials to conduct the filming

production event; the list of those who gave permission must be

made available to the inspector upon request;

Signature of exemption holder or representative; and

A description of the flight activity, including maps or diagrams of

any area, city, town, county, and,/or state over which filming will

be conducted and the altitudes essential to accomplish the

operation.

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32. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

operator MPTOM, if the Operator has submitted an approved MPTOM.

IV. Regulations from which the exemption is requested

14 C.F.R. Part 21. Subpart H: Airworthiness Certificates 14 C.F.R. $91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR $91.203 (a) (t).The Federal

Aviation Act (49 U.S.C.$44701 (0) and Section 333 of the Reform Act both authorize the

Page 9 of 13
FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the particular UAS.

Part 2l prescribes, in pertinent part, the procedural requirements for issuing and

changing design approvals, production approvals, airworthiness certificates, and airworthiness

approvals.

Part27 sets forth airworthiness standards for normal category rotorcraft

14 C.F.R. 861.23 (d & (c) prescribes, in pertinent part Operations requiring a medical

certificate and holding and possessing either a medical certificate issued under part 67 of this

chapter or a U.S. driver's license under certain conditions

14 C.F.R. $61.101 (a) (b) & (e) prescribes in pertinent part the prohibition of a

recreational pilot acting as a PIC for compensation or hire and in furtherance of a business

14 C.F.R. $61.113 (a) & &) prescribes in pertinent part the prohibition that no person

who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying

passengers or property for compensation or hire; nor may that person, for compensation or

hire, act as pilot in command of an aircraft.

14 C.F.R. $61.315 (a): $61.3l5prescribes in pertinent part the privileges and limits

of a sport pilot certificate.

14 C.F.R. S 91.7(a) prescribes, in pertinent part, that no person may operate a civil

aircraft unless it is in an airworthy condition,

14 C.F.R. $ 91.9[b] (2) prohibits operation of U.S. registered civil aircraft unless there is

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof.

14 C.F.R. $ 91.103[bl states, in pertinent part, that each pilot in command shall,

before beginning a flight, become familiar with all available information concerning that flight, to

include, "For any flight, runway lengths at airports of intended use, and the following takeoff and

landing distance information;... For civil aircraft for which an approved Airplane or Rotorcraft

Flight Manual containing takeoff and landing distance data is required, the takeoff and landing

distance data contained therein."

14 C.F.R. $ 91.109(a) provides that "no person may operate a civil aircraft (except a

manned free balloon) that is being used for flight instruction unless that afucraft has fully

functioning dual controls."

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no

person may operate an aircraft below the following altitudes: "Over other than congested areas.

An altitude of 500 feet above the surface, except over open water or sparsely populated areas.

In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel,

vehicle, or structure."

Page 10 of 13
14 C.F.R. S 91.121 requires, in pertinent part, 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."

14 C.F.R. $ 91.151(a) prescribes that no person may begin a flight in an airplane under

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel

to fly to the first point of intended landing and, assuming normal cruising speed, (1) during

the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45

minutes.

14 C.F.R. $ 91.203 prohibits, in subpart (a), anyperson from operatingacivil aircraft

unless it has within it (l) an appropriate and current airworthiness certificate; and (2) an

effective U.S. registration certificate issued to its owner or, for operation within the United

States, the second copy of the Aircraft Registration Application as provided for in $ 47,31(c].

Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless an

airworthiness certificate or a special flight authorization issued under $ 91.715 legible to

passengers or crew is displayed at the cabin or cockpit entrance.

14 C.F.R. $ 91.405 la] requires, in pertinent part,that an aircraft operator or owner shall

have the aircraft inspected as prescribed in subpart E of the same part and shall, between

required inspections, except as provided in paragraph (c) of the same section, have

discrepancies repaired as prescribed in Part 43 ofthe chapter.

14 C.F.R. $ 91.4071a]H prohibits, in pertinent part, any person from operating an

aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration

unless it has been approved for return to service by a person authorized under S 43.7 of the

same chapter.

14 C.F.R. $ 91.a09 (a) tll& l2l prescribes, in pertinentpart, that no person may

operate an aircraft unless, within the preceding 12 calendar months, It has had an inspection for

the issuance of an airworlhiness certificate in accordance with part2l of this chapter.

14 C.F.R. I 91.417[a) and tbl

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.

14 C.F.R. $45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the

registration number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display on that aircraft

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable.

Page I 1 of13
Even though the UAS will have no airworthiness certificate, afl exemption may be needed as the

UAS will have no entrance to the cabin, cockpit or pilot station on which the "Experimental" can

be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word

"Experimental" will be placed on the frame in compliance with 545.29 (f) at a size suitable for

the available space. The equivalent level of safety will be provided by having the sUAS marked

on its fuselage as required by $45.29 (f) where the pilot, observer and others working with the

sUAV will see the identification of the UAS as "Experimental." The FAA has issued the

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

V. Unnecessarlu to Publish Request for Exemption in the Federal Register

The Administrator has stated that it may:

" . . . issue a summary grant when it finds it has already granted a previous

exemption similar to the new request. Summary grants are far more efficient

because they don't need to repeat the analysis performed for the original

exemption on which they are based. Summary grants are a tool the FAA can use

in all exemption areas, not just UAS.

The FAA's experience in reviewing the Section 333 petitions shows they

generally fall into two categories: film/television production and aerial data

collection. Most exemptions in these categories will likely be handled through the

summary grant process. For unique requests, the agency will still publish the

petition in the Federal Register for public comment and will conduct a detailed

analysis."

Federal Aviation Administration. (2015). Petition for Exemption or Rulemaking

Retrieved March 8,2015, from:

http:/rvrrvn.faa.gov/regulations policieslrulemaking/petitioni#exemotions

It is the position of SkyCandy that this request for exemption is similar in all material

respects to relief previously requested in Grant of Exemption Nos. 12103, 12428, 12362, T1062,

11109, 11110, llll2,11158, 11160, 11189 and 11213 and that the reasons for granting the

request also apply to the present situation and a grant of exemption is in the public interest.

Therefore, SkyCandy requests the Administrator issue a summary grant of exemption in the

instant request.

Page 12 of13
VI. Summarv Language if Necessary to Publish Request for Exemption in the Federal

Reqister

Should the Administrator determine that this Request for Exemption must be published in

the Federal Register, SkyCandy provides the following summary for the publication:

SkyCandy Digital Cinema, LLC, applicant seeks an exemption from the following rules:

14 C.F.R. $21, subpart H; 14 C.F.R a5.23(b); 14 C.F.R 61.23(a) and (c); 14 CFR

61.101(e)(a) and (5); 14 C.F.R. S$ 61.113( a) and (b); 14 CFR 61.315(a); 14 C.F.R. 91.7

@); ru C.F.R. 91.9 (b) (\; A C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 9t.LI9; t4

C.F.R. 9t.r2l: 14 C.F.R. 91.151(a); 14 C.F.R. 9r.203(a) and (b); 14 C.F.R. 91.405 (a);

14 C.F.R. 9t.407 (a) (1); 14 C.F.R. 9t.409 (aX1) & (2);14 C.F.R. 91.409 (a) (2) and t4

C.F.R. 91.417 (a) & (b) for the purpose of conducting aerial videography and

photography for the motion picture and television industry, media and advertising

industries and other private and public entities, natural resource videography, real estate

and photography in pre-planned, controlled access property, private and public areas

utilizing a small unmanned vehicle (551bs or less).

SkyCandy Digital Cinema, LLC

Attachments:

Attachment A - DJI S1000 Release Notes

Attachment B - DJI 51000 User Manual v1.10

Attachment C - A2 Flight Control System User Manual,vl.22, May 15, 2015 Revision

Attachment D - A2 Product Release Notes

Attachment E - Tabular specifications for the DJI Spreading Wings series (Proprietary via email)

Attachment F - Skycandy S1000 Operational Procedures (Proprietary via email)

Attachment G- ALTA USER MANUAL, Revision B

Attachment H - ALTA Setup Guide

Attachment I - Skycandy Freefly Alta Operational Procedures (Proprietary via email)

Attachment J - Futaba 14SG Instruction Manual

Law Office of Darrell J. Green, LLC

y Digital Cinema, LLC

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