April 13, 2015

U.	S.	Department	of	Transportation	

Docket	Management	System

1200	New	Jersey	Ave.	SE	

Washington,	DC	20590

RE:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Modernization	and	

Reform	Act	of	2012	

Dear	Sir	or	Madam:

The	subject	petition	is	being	submitted	without	consulting	or	legal	services	as	

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography	is	a	start-up	small	

business.		 I	also	hold	a	Private	Pilot	Certificate	and	Instrument	Rating.	

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

Reform	Act),	and	14	C.F.R.	Part	11,	SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	

Brown	Photography	wishes	to	operate small	Unmanned	Aircraft	System	(UAS)	

equipped	to	conduct	aerial	photography	and	survey	for	various	industries and

hereby	applies	for	an	exemption	from	the	Federal	Aviation Regulations	(FARs)	

listed	below to	allow	operation	of	our	UAS	commercially	in	the	National	Airspace	

System	(NAS)	so	long	as	such	operations	are	conducted	with	and	under	the	

conditions outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	

Section	333.

The	requested	exemption	would	permit	SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	

Brown	Photography	to	pursue	its	commercial	interests	in	providing	services	to	

consumers	interested	in	aerial	photograph	using	a	small,	commercial-off-the-shelf	

(COTS)	UAS	in	the	following	areas:

• Motion Picture Filming

• Fine Art and Real Estate Photography

• Agricultural and Construction Monitoring

• UAS Operator Training

• Promoting the Safe and Effective Use of Small UAS Technology

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography	UAS	operations	will	

only	occur	in	areas	approved	for	use	with	prior	verbal	or	written	consent.		Flight

operations	will	not	be	conducted	under	any	circumstances	within	the	Washington,	
DC	Special	Flight	Rules	Area	(SFRA)	or	the	Washington,	DC	Flight	Restricted	Zone	

(FRZ).

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography’s UAS	flights	will	be	

piloted	by	individuals	who	hold, at	a	minimum, Private	Pilot	Certificates and	if	

observers	are	not	qualified	pilots,	they	will	be	trained	by	to	understand	the	proper	

roles	of	an	observer,	communication	procedures,	proper	visual	scan	techniques,	

operations	at	non-towered	airports,	and	appropriate	sections	of	the	Aeronautical

Information	Manual	(AIM).		Proper	training	and	safety	is	of	upmost	importance.	

Regulations from which the exemption is requested:

14	C.F.R.	Part	21

14	C.F.R.	45.23	(b)

14	C.F.R.	61.113(a)	and	(b)

14	C.F.R.	91.7	(a)

14	C.F.R.	91.9	(b)	(2)

14	C.F.R.	91.109

14	C.F.R	.	91.119

14	C.F.R.	91.121

14	C.F.R.	91.151(a)

14	C.F.R.	91.203	(a)	&	(b)

14	C.F.R.	91.205	(b)

14	C.F.R.	91.215

14	C.F.R.	(91.401	- 91.417)

Unmanned Aircraft System

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography requests to operate

DJI Phantom 2 Vision Plus, Phantom 3, and Inspire 1 multi-rotor UAS’ equipped with a 

three-axis gimbaled camera. The UAS weighs less than 25 lbs, have a built-in capability 

to limit the height the UAS flies above the ground, to limit the radius of the distance it 

flies from the operator and to exclude it from Class A, B, C and D airspace including a no 

fly zones. Each system also has the failsafe function of the autopilot system, which means 

when the communication between the main controller and the transmitter is lost, the

system will automatically “return to home” and will land safely. These UAS are 

considered COTS products and will not be altered or modified in any way. 

The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and

will operate at sites that are a safe distance from populated areas. UAS operators will 

insure that the UAS will create a nuisance or hazard for users of the NAS, the general 

public, livestock, pets, or wildlife. 

When conducting UAS flights within 3 miles of an airport, airport operators will be 

notified and the UAS operator will give the right-of-way to avoid flying in the proximity 

of full-scale aircraft.
The maximum flight time for each operational flight will not exceed 60 minutes.

Flights will be terminated at 25% battery power reserve should that occur prior to the 60

minute limit.

The UAS will be programmed so that it will not be operated at an altitude of no more 

than 600 feet AGL.

The UAS operator will be an FAA licensed airman holding, at a minimum an FAA 

Private Pilot Certificate.

The UAS proposed by the petitioner weighs less than 55 pounds, including the payload

(i.e. camera, lens, and gimbal).

The UAS will operate at speeds not to exceed 55 knots.

Given the small size of the UAS and the restricted environment within which they

operate, the proposed UAS operations adhere to the Reform Act's safety requirements.

All UAS operators will be appropriately trained in small UAS operations including 

familiarization with all applicable regulations and guidance documents; local area charts, 

current NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human 

Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather 

factors; Airmanship and Decision-making and Safe Operating Procedures.

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography requests exemption 

under Section 333 to enable to operate safe, low-risk commercial small UAV operations 

for the activities summarized in this request.

Sincerely, 

Travis J. Brown

Chief Operating Officer

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography

Alexandria, VA 22314

travis@travisjaybrown.com

(571) 344-3554

Attachments:

A. Exemption Requests and Equivalent Level of Safety

B. Maintenance Log

C. Flight Log
ATTACHMENT A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography requests an 

exemption from the following regulations as well as any additional regulations that may 

apply to the operation of the UAS:

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 Phantom 2 Vision 

Plus, Phantom 3, and Inspire 1 UAS.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The small UAS does not have an entrance in which the 

word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by 

including the word "EXPERIMENTAL" in the placard on the top of the UAS.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as 

Pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as Pilot in Command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire. Our proposed 

operations require that the PIC must hold at least a Private Pilot Certificate issued by the 

FAA and since the aircraft cannot carry passengers or property, we feel we meet the 

intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct 

a business.

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.
14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We 

request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved UAS Flight Manual must be available to the crew at the 

ground station at all times.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests

The regulation states "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls." The UAS System 

ground-based control station consists of a small hand-held radio transmitter and while it 

does not offer a second set of "controls", both the student and instructor can, and will, 

operate the single set of controls simultaneously. With both student and instructor having 

"hands-on" the controls during flight, we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety.

14 CFR 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 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 either 

verbally or in writing. The aircraft will be operated at a low altitude allowing, if there is a 

loss of propulsion, 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.

14 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 

600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An AGL altimeter measurement above the takeoff point is transmitted 

via radio from the UAS on-board computer to the display screen held by the UAS 

operator, 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. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The UAS are battery operated 

and the maximum duration of flight from a single battery charge is 12-45 (depending on 

which UAS) minutes with a 20% 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. We also request exemption from 

the 30 min reserve and ask that our reserve will be to fly the mission to the point of 

intended landing and have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." A small UAS is 

too small to carry documentation, does not have an entrance, and is not capable of 

carrying passengers or crew. To obtain an equivalent level of safety and meet the intent

of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA 

will be collocated with the crew at the ground control station and available for inspection 

upon request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via 

placard containing the following information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23.

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 UAS operator 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 UAS operator is limited to 

repairing small cracks, replacing a propeller, checking electrical and updating software 

and firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The UAS operator will document work

performed in accordance with 91.417 in the attached Maintenance Log. 
ATTACHMENT B

MAINTENANCE LOG

MODEL: _______________________ SERIAL NUMBER: __________________

DATE SUMMARY OF MAINTENANCE SIGNATURE RETURN

TO SERVICE
ATTACHMENT B

FLIGHT LOG

DATE LOCATIO

N

OPERATOR & 

OBSERVER

NAME

CUSTOMER MISSION

DO VFR 

CONDITIONS 

EXIST

AIRSAPCE 

STATUS NOTES