February 7, 2016

U.S. Department of Transportation

Docket Management System

Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Subject: Exemption request under Section 333 of the FAA Reform Act 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(1); and (2); 14 CFR 91.417(a) and 

(b)

Dear Sir:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 SkyHigh ATL, a Limited 

Liability company and the operator of small Unmanned Aircraft Systems (UAS), seeks an exemption from 

the Federal Aviation Regulations (FARs) 14 CFR 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow SkyHigh ATL to operate a UAS to perform aerial 

imagery and data collection.

You will find that my request is similar to relief previously requested, and the UAS proposed by SkyHigh 

ATL, including the DJI Phantom 3, has been approved in multiple Grant of Exemptions. The requested 

exemption would permit SkyHigh ATL to commercially operate UAS for the following purposes:

1. Real Estate Promotion & Property Inspection

2. Emergency Services and Disaster Recovery - Assistance with search and rescue operations in cases of 

an emergency or natural disaster or when otherwise approved by local authorities, government or other 

agency in charge.

3. Public events, private events (e.g. reunions, weddings, etc.), tourism promotion, and news gathering.

4. Inspection and marketing of private facilities (e.g. golf courses, resorts, corporate facilities, etc.

5. Infrastructure & Utility Aerial Inspection

6. Construction Monitoring

The SkyHigh ATL mission, under the expertise and guidance of Jason L Miller, is to assist other industries 

and municipalities by providing safe and efficient UAS support. The uses of UAS to perform airborne 

photography and videography, as well as aerial inspections and surveying, have two major benefits. 

First, small UAS are considerably safer than using manned aircraft in the previously mentioned tasks, 

and also reduces the fall risk of workers. Second, UAS allows the completion of many tasks at a fraction 

of the cost using traditional methods.

Granting this exemption is in the public interest because it will dramatically enhance safety, lower aerial 
inspection costs by making it more efficient and effective versus alternatives. SkyHigh ATL will conduct 

operations using the using the following UAS: DJI Phantom 3. The listed UAS is small, weighs less than 25 

pounds, and has advanced navigation systems, along with automated control features that enhance 

safety including redundant failsafe settings, a Return-to-Home feature and battery voltage fail safes. The 

UAS that will be used with this exemption has been previously approved in other Section 333 exemption 

requests.

The Pilot in Charge (PIC) and owner of SkyHigh ATL, Jason Miller, is a licensed private pilot – Certificate 

number #3659559 with over 250 hours in a Cessna 172SP. Mr. Miller also has experience building and 

flying radio controlled fixed-wing aircraft and multi rotors for hobby purposes utilizing the same style of 

controllers currently utilized to operate UAS.

All SkyHigh ATL UAS operations will strictly adhere to FAA regulations with safety being the number one 

priority. All operations will be conducted via unaided visual line-of-sight, below 400 feet AGL and 5 

nautical miles outside of any controlled airspace unless the controlling agency gives express permission. 

Additionally, SkyHigh ATL will not fly the UAS within 3 nautical miles of a non-controlled airport with 

instrument flight procedures, 2 nautical miles for a non-controlled airport without instrument flight 

procedures and within 2 nautical miles of a Heliport with published flight procedures. Flights will be 

daylight only and maintain speeds less than 100 mph and VFR weather conditions of at least 3 miles of 

visibility from the ground control station.

SkyHigh ATL respectfully submits a Section 333 Exemption Request, and believes it is in the public's best 

interest because the use of small UAS, in lieu of comparatively more expensive and hazardous rotary 

and fixed wing aircraft or other conventional manned methods of photography, video and inspection, 

greatly enhances operational efficiency and achieves a level of safety that is significantly higher with less 

liability.

Furthermore, SkyHigh ATL will assist other industries in the safe application of UAS and promote the 

benefits of safe UAS operations. Approval of this exemption will enhance safety and fulfill the Secretary 

of Transportation's responsibility under the section 333(c) of the FAA Modernization and Reform Act of 

2012 to establish requirements for the safe operation of such UAS in the national airspace system.

Name and address of the applicant:

Jason Miller, SkyHigh ATL, llc

404-388-2024

Email: imjmiller74@gmail.com

904 Masons Creek Circle

Atlanta, GA 30350