Kevin E. Coles | Co-founder | Skyclad AP, LLC | kevin@skycladap.com | 434.960.0334

July 7, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

This petition is being submitted on our own behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Skyclad AP, LLC hereby applies for an exemption from the Federal Aviation Regulations 

(FARs) listed below to allow operation of our Unmanned Aircraft Systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) 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 allow Skyclad AP, LLC to pursue its commercial interests in providing 

services to consumers interested aerial data capture using small advanced UAS comprised of the DJI 

Phantom 2, 3 and the DJI Inspire 1 in the following areas:

 Real Estate Photography

 Marketing/Advertising

 Land Development

 Insurance Claims

 Golf Course Planning

 Construction

 Inspections

 Land Appraisal

 Resort/Recreation

 Wedding Photography/Video

 Surveying

 Agriculture

 Special Events

 Vineyard/Winery

Skyclad AP, LLC states that all UAS flights that will occur over private or controlled access property, will 

do so with the property owner's prior consent and knowledge and that only people who have consented 

or otherwise have agreed to be in the area where filming will take place will be filmed.
Kevin E. Coles | Co-founder | Skyclad AP, LLC | kevin@skycladap.com | 434.960.0334

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 Systems

We are petitioning for exemption to enable Skyclad AP, LLC to operate a DJI Phantom 2, 3 and DJI Inspire 

1 equipped with a GoPro 3+ Camera & built-in camera combinations. These UAS have a built-in 

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

operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Phantom 

also has the failsafe function of the Naza-M autopilot system which means when the communication 

between the Main Controller and the transmitter is disconnected, the outputs of all command sticks 

from controller will go to the center position. If the GPS signal is good enough, the system will 

automatically trigger Return to Home and will land safely. Also, since the UAS will be carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, operators of the DJI should not be required to hold a commercial or private 

pilot certification.

The UAS of Skyclad AP, LLC will be operated in the field of view with both a Pilot in Command (PIC) and a 

ground-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions:

• All UAS will weigh less than 55 pounds including payload.

• The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour). The use of 

either groundspeed or calibrated airspeed will be used for compliance. 

• All operations will occur in Class G airspace (below 400' AGL).

• The UAS will be operated within Visual Line of Sight (VLOS) of the Pilot in Command (PIC) at all 

times.

• While the UAS are airborne, the visual observer (VO) will be positioned within voice distance to 

PIC.

• All UAS will be maintained and inspected to ensure that it is in a condition for safe operation.
Kevin E. Coles | Co-founder | Skyclad AP, LLC | kevin@skycladap.com | 434.960.0334

• Before each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight.

• Operations will be operated over private property, commercial property, or property (not

federal or state) with permission of the land owner.

• The UAS will not operate within 5 NM of any airport or heliport (unless well-coordinated with

the FAA and airport/heliport (detailed flight plans))

• Operations will be limited to day, visual meteorological conditions

UAS Pilot in Command (PIC}

Skyclad AP, LLC will not allow the PIC to fly any aircraft without at least 40 hours of training flight time 

with the exact aircraft used for the business. The company has private testing areas that are in a remote 

locations with no vertical obstructions. This allows the PICs for Skyclad AP, LLC to test all the systems 

and understand fail safe features to the fullest extent before conducting business with the UAS.

Skyclad AP, LLC Contacts

Matteus Frankovich

Founder, Operations & Logistics

matteus@skycladap.com

Kevin E. Coles

Co-Founder, Sales & Business Development

kevin@skycladap.com