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November 22, 2015 Dock et Operations, M - 30 U.S. Department of T ra nsportation (DOT) 1200 New Jersey Avenue, SE Ro om W12 - 140, W est Building Ground Floor Washington, D.C. 20590 - 0001 **Subject: Petition to the F AA for Section 333 Ex**  **emption SkyNetW est U**  **nmann ed V**  **ehicle Services (UVS)** Dear Sir or Madam SkyNetW est U. V. S. hereby submits to the F ederal A viation Administration, pursuant to the FAA Moderniz ation and Reform Act of 2012, an ex emption petition, in accordance with Section 333 of the Act. SkyNetW est U. V. S. requests to operate commercially its small unmanned aircraft system (UAS) which is currently regulated by the Federal Aviation Administration. This letter provides requested information as listed in the FAA's "Public Guidance for P etitions for Exem ptions F iled under Section 333" as described as of this date at the FAA website at https://www .fa a.gov/uas/legislative programs/section 333 /how to file a petiti on/ SkyNetW est U. V. S. is an experienced aerial photographer in the State of Ariz ona. W e are experienced in flying hobby helicopters for recreational purposes. W e have flown small RC electric helicopters for over three (3) years without incident. Safety i s our commitment with each flight. An extensive pre - flight safety checklist is completed and each flight is logged by the operator and verified by our spotter . Our ex emption request would permit operation of ultra - light weight, unmanned (remote control ope rated) in tightly controlled and limited airspace. More company information can be viewed on the company website at www .SkyNetW est.com **Purpose for the Ex emption:**  SkyNetW est U. V. S. desired to utiliz e an unmanne d aircraft system (UAS), herein described, to accomplish aerial photograph y of industrial and commercial facilities.2

**Contact Information** : SkyNetW est PO BO X 1055 Chandler , Ariz ona 85244 Office: 480 - 71 8 - 1045 Cell: 480 - 364 - 8218 Email: noah.ruiz@sky netwest.com **List of Specific Sections of 14 CFR for which ex emption is sought**  : This listing matches the list on page 7 of the FAA's "Public Guidance for P etitions F iled under Section 333", R ev . 9/

25 /2 014 14 CFR 21, Subpart H - Airworthiness Certificates 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 14 CFR 91.7 (a), Airworthiness required for operation 14 CFR 91.103 (b) (2), Preflight action 14 CFR 91.105, Flight crewmembers at stations 14 CFR 91.109, Fligh t instruction 14 CFR 91.119 (c), Minimum safe altitudes 14 CFR 91.121, Altimeter settings 14 CFR 91.151, Fuel requirements for flights in VFR conditions 14 CFR 91.405 (a), Maintenance required 14 CFR 91.407 (a) (1), Oper ation after maintenance 14 CFR 91.409 (a) (2), Inspections 14 CFR 91.417 (a) and (b), Maintenance records (FURTHER DET

AILS ON P AGES 8 - 11)3

In accordance with the outline given in the FAA's "Public Guidance for P etitions F iled under Section 333", the f ollowing information is prov ided for each numbered item listed in that guidance: 1. **Aircraft Description** Design and Operational Characteristics: • SkyNetW est U. V. S. plans to operate a DJI Inspire 1 comprised of an unmanned aircraft and a tr ansportable ground station. This aircraft i s a quad - copter design with gross weight (battery and propellers included) of 2935 g (6.70 lbs.). • The Inspire 1 has Zenmuse X3 camera for capturing aerial still photographs and videos. • It is equipped with four rotors that are driven by battery - powere d electric motors. Maximum airspeed is 42 knots. • The Inspire 1 includes a F ailsaf e Function. It activates if the R emote Control is powered off , the Inspire 1 has flown outside effective control range, the signal between the Inspire 1 and the Remote Cont ro l is block ed, or if there is interference causing a signal problem. When activated, the Failsafe Function automatically flies the Inspire 1 back to the Home P oint (the start location) and lands it. If GPS mode is not active, the F ailsafe Function will ex ecute a con trolled descend and automatic landing. • Through the Inspire 1 Assistant software, each flight operation will be programmed with a maximum radius distance and maximum altitude from the Home P oint such that the flight control system will limit o per ations to within the confines of the property to be surveyed f

or SkyNetW est or SkyNetW est' Clients. These performance limitation requirements are included in the UAS Operating Procedure contained in Appendix A herein. Manufacturer's Documentation: De tailed manufacturer's design information (current to this date) is contained the in the fo llowing manuals in the appendices at the end of this document: • Appendix B - Inspire 1 Specifications • Appendix C - Inspire 1 Quick Start Guide4 • Appendix D - Ins pire 1 U ser ’s Manual • Appendix E - inspire 1 Pilot T ra ining Guide For ease of reference, the Inspire 1 is included in FAA Section 333 Ex emption No. 13512 granted on November 5, 2015 to Andrew W olfe.

2. **Procedures for Ensuring U AS Is In a Condition Sa**  **fe for Flight** Preflight Checks: At a minimum, the following items will be check ed prior to initiating an y oper at ion. (See Appendix A in this document for detailed procedures, SkyNetW est U. V. S., Operating Pr ocedure V1.13.4.15) • Operations must be in d ay light hours and under visual meteorological conditions (VMC). • Area to be surveyed is defined on a plot plan drawing with path of flight and altitudes for each leg of the flight clearly mark ed. • Flight path is at least 500ft. from all non - participati ng persons, vessels, vehicles and structures unless protective barriers or structures are present, or permission is gr anted or such operations present no hazard to the Pilot in Command, the Vi sual Observer

, tr ainees, and other essential persons. • Flight plan and schedule has been reviewed with site leadership and communicated to all SkyNetW est U. V. S. and Client personnel in the area. • R emote control, smart battery , r ange extender

, and ground station monitor are fully charged.5 • Propellers are mounted c orrectly . • Damping absorbers are in good condition, not dry - rotted or worn. • Anti - drop kits have been mounted correctly . • Micr o - SD card has been inserted. • Gimbal is functioning as normal. • Compass has been calibrated. • Flight radius and altitu de limits have been set with the Phantom 2 Assistant software, not to ex ceed 400ft. AGL altitude, and radius limited to the property boundaries of SkyNetW est or SkyNetW est Client site. • The V isual Observer (VO) is stationed at the required initial observ ation point according to the flight plan and in view of the Pilot in Command (PIC) and has means for c ontinual verbal communication. • Ther e ar e no inoperable components. • All site required safety permits are approved in in possession of the PIC. • Mot or s can start and function as normal. • Flight Indicator Lights on the aircraft verify that the Home P oint is set to current location. • R ecord the Preflight Check, date and sign, and file it in the Equipment Inspection and Maintenance Record Book.

3. **Ra dio Frequency (RF) Spectrum for Control**  The R emote Control ground station operating frequency is 5.278 - 5.85 GHz and is FCC compliant with communication distance in an open area of 800 m (8 75 yds.) Operating Frequency 5.728 GHz - 5.85 GHz Communicati on Distance (Open area) FCC Compliance: 800m6 Re ceiver Sensitivity (1%PER) - 93dBm

Tr ansmitter P ower FCC Compliance: lOO mW Wo rking Voltage 120 mA@3.7V Built - in LiPo Battery W orking Current/Capacity 22.2V , 4500mAh **4. Qualifications**  **for The Pilot in Command (PIC)** Logged Hours: The PIC will ha ve accumulated and logged a minimum of 25 hours of total time as a UAS ro to rcraft pilot with a multi - ro tor UAS prior to operations. The PIC will have also accumulated and logged a minimum of 5 h our s as UAS pilot specifically operating the Phantom 2, prior to operations. The PIC will have accomplished, during dedicated tr aining sessions, 3 tak e - offs and landings in the preceding 30 days. T ra ining, proficiency , and experience - building flights in de dicated training sessions will be included in the accumulated and logged hours. Emergency and E vasive Maneuvers: The PIC will ha ve demonstr ated the ability to safely operate the Phantom 2 in a manner consistent with how it will be operated in surveying Sk yNetW ests’ Client properties, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. The logg ed hours referenced above will document this. 5. **Description of Intended U AS Operations** 

• O per ations will be restricted to Class G airspace. • No oper ations will occur within 5 miles of a non - to wered airport ref erence point as denoted on a current FAA - published aeronautical chart, unless a letter agreement with the airport's management is obtai ned, and the operation is conducted in accordance with a Notice to Airman (NOT AM) as required by the Certificate of W aiver or Operation (COA).7 • The Inspire 1 will be utiliz ed to survey industrial and commercial facilities. The use of small unmanned airc raft systems provides more immediate and thorough information than is presently available by other means. Expense for scaffolding, rental of manned aircraft, rental of equipment, and lost time is saved. Safety is improved by reducing fall risk f or work er s and reducing potential for manned aircraft accidents. • As described in "2. Procedures for Ensuring UAS Is in a Condition Safe for Flight", altitude and distance limits will be entered into the Inspire 1 Assistant software prior to commencement of flight. This will r estrict the operation to SkyNetW est Client property . The F ailsaf e Function integr al with the inspire 1 will assure this aircraft stays within the area deemed safe f or oper ation. • Industrial facilities of the type mentioned above have strict s afety procedures which must be satisfied. SkyNetW ests' respect for compliance with these procedures is vital to assuring positive Client relationships and continuing business. All saf ety procedures f or per sonnel will be strictly adhered to as well as all l aws and regulations. 6. **Proposed Speed, Altitude, V isi**  **bility and Distance s**  Speed: The Inspire 1 is capable of a maximum speed of 22m/ s (42.7 knots). In order to conserve power

, and thereby maximiz e flight time, and to assure good quality still photographs and video, the Inspire 1 will be operated at a slow speed along the flight path, typically 2m/s (3.9 knots) or below . Higher speeds may be used from time to time when tr aversing a section of the property of no interest and not included in a given study . A ltitude: Altitudes below 400ft. AGL are adequate f or the complete range of facilities and structures to be surveyed. The integral Flight Control System will be set to limit the altitude to always be below that level. Distance: The integral Flight Contro l System will be set to limit the radial distance from the Home Po int (point of flight commencement) such that the Inspire 1 will sta y within the boundary of the property lines. The PIC will operate the equipment to assure those limits ar e not reached and will maneuver the Inspire 1 to follow the preplanned flight path within the property boundaries.8 The Inspire 1 will not be operated less than 500 feet below or less than 2,000 feet horiz ontally from a cloud when visibility is less than 3 statute miles fr om the PIC. Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. Safe descent and landing procedures will be followed in accordance with operating documents. 7. **Description of the Area of Intended Operations** As described in "5. Description of Intended UAS Operations", the Inspire 1 operation will be restricted to SkyNetW est Client property and not tak en into public areas. SkyNetW est and Client per sonnel on the site will be made fully aware of the operation prior to c ommencement of oper ations. 8. **Pro ximity of Airports**  Operations will be restricted to Class G airspace. No oper ations will occur within 5 miles of a non - to wered airport reference point as denoted on a current FAA - published aeronautical chart, unless a letter agreement with the airport's management is obtained, and the operation is conducted in accordance with a Notice to Airman (NOT AM) as required by the Certificate of W aiver or Operation (COA). 9. **Operation within V isual Line**  **- of**  **- Sight (VLOS)**  In add ition to the PIC, all operations will include a V isual Observer (VO). The VO will assure that the Inspire 1 is always within their visual line - of- sight (VLOS), as well as the PIC's, at all times. The VO and the PIC will be able to communicate verbally at a ll times utilizing two - way radios available at SkyNetW est Client sites. 10. **Procedures for Preflight Safety Assessment** Prior to each flight, the PIC will inspect the Inspire 1, including the ground control station, in accordance with the Preflight Checklist (see "2. Procedures f or Ensuring UAS Is In a Condition9 Safe for Flight"). If the Preflight Check indicates any unsafe conditions or a non - functioning

safety - critical part, the flight will not commence until the needed maintenance is performed and a satisf actory Preflight Check can be completed. All maintenance and alterations performed will be documented and filed in the Equipment Inspection and Maintenance Record Book. 11. **Notifications** As required, a Notice to Airmen (NOT AM) will be requested not more t han 7 2 hours in advance and not less than 48 hours prior to an operation. In addition, an y notifications required by the FA A Flight Standards District O ffice will be made. 12. **Certificate of W aiver or Authorization (COA)**  Prior to conducting an y operations, an Air T raffic Organization (A TO ) issued Certificate of W aiver or Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with additional units added as needs for oper ations increase over time. Each Phantom 2 aircraft wil l be identified with its serial number , r egistered in accordance with 14 CFR part 4 7, and have identification (N - Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as Iarge as practicable.

**Specific Regulations for Which Ex e**  **mption is Sought:** 1. **14 CFR 21, Subpart H -**  **Airworthiness Certificates** 14 CFR 21 covers the certification procedures for products and parts. Subpart H specifies requirements for Airworthiness Certificates f or various aircraft types. Small unmanned aircraft systems are not specifically called out and addressed in these rules. SkyNetW est will, in lieu of airworthiness certification by aforementioned rule, if ex emption is granted, ensure that the Inspire 1 system is in compliance with its oper ating documents as described herein.10 The PIC will assur e that all Preflight Checks are completed and documented and the Inspire 1 is in full compliance with all manufacturers' operation and maintenance documents. Due to consideration of the siz e, weight, speed, and limited operating area associated with SkyNetW est ’s pr oposed Inspire 1, we believe it will not create a haz ard to users of the National Airspace System (NAS) or the public. Therefore, a request is made f or ex emption from 14 CFR part 21, and an y associa ted noise c ertification and testing requirements of part 36. 2. **14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors** 14 CFR 61.113 (a) and (b) prohibit private pilots from fulfilling the role of PIC if the aircraft is carrying property for c ompensation, unless the flight is only incidental to that business or employment. SkyNetW est believes that due to the size, weight, speed, and limited operating area associated with SkyNetW ests’ proposed Inspire 1 operation, a PIC possessing the afo rementioned training and logged hours, would ensure safety and prevent creating any hazard to users of the National Airspace System (NAS) or the public. W e theref or e request an exemption from these parts of 14 CFR. 3. **14 CFR 91.7 (a), Airworthiness re quired for operation**  If the ex emption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness certificate will be required. On this basis, ex emption from 14 CFR 91.7 (a) is requested, presuming that airworth y c ondition by definition in the rule means ha ving an airworthiness certificate. SkyNetW est will, in lieu of airworthiness certification by 14 CFR 21, ensure that the Inspire 1 system is in compliance with its operating documents as described herein. The PIC will assure that all Preflight Checks are completed and documented and execute full compliance with all manufacturer's operation and maintenance documents. 4. **14 CFR 91.103 (b) (2), Preflight action** 14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft perf ormance und er expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. Since the Inspire 1 will not be operating out of airports this rule is not11 applicable. On this basis and on the basis that the operating documents c ov er r equirements fo r operation safety

, an exemption from this rule is requested. 5. **14 CFR 91.105, Flight crewmembers at stations** This part requires certain actions by on board crewmembers. Since the Inspire 1 is unmanned, an exemption from this rule is requested. 6. **14 CFR 91.109, Flight instruction** 14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used for flight instruction have fully functioning dual controls. The details pertain to manned airplanes and are no t applicable to a small unmanned aircraft system such as the Phantom 2. Flight training will be required for the Inspire 1 pilot as detailed on page 5 herein, "4. Qualifications for the Pilot in Command (PIC)." Compliance with these training requirements w ith logg ed hours assures that the required competency for safely operating the Inspire 1 will be maintained. On this basis an exemption from this rule is requested. 7. **14 CFR 91.119 (c), Minimum safe altitudes** 14 CFR 91.119 (c) requires that no operation i s permitted below 500 feet above the surface, except over open water and sparsely populated areas. The proposed use of the Inspire 1 is specifically for altitudes that range from the surface to maximum 400 feet AGL. On the basis of the aforementioned safet y pr ocedures, we believe there will be no increased hazard to user s of the National Airspace System (NAS) or the public will be created by the Inspire 1 as detailed here. 8. **14 CFR 91.121, Altimeter settings** 14 CFR 91.121 provides specific rules for altim et er settings for cruising altitude and flight level of aircraft and speaks of altimeter stations along the route and the elevation of the12 departure airport. In lieu of these specific requirements, most suitable for manned airplanes, the Inspire 1 has baro metric altimeter and GPS derived altitude limitations. All altitudes reported to Air T ra ffic Control (A TC) will be in feet above ground level (AGL). On this basis, an exemption from this rule is requested. 9. **14 CFR 91.151, Fuel requirements for flights in VFR conditions**  14 CFR 91.151(a) requires that no person may begin a flight under V isual Flight Rule (VFR) conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumin g normal cruising speed, during the day , to fly after that f

or at least 30 minutes, or at night, to fly after that for at least 45 minutes. The Inspire 1 has a built - in Low Ba ttery Level W arning Function: (1) If the smart battery is depleted to the point th at may affect the safe return of the aircraft, the low battery level warning notifies the PIC to tak e action. (2) The thr esholds for these warnings are automatically determined based on the current aircraft altitude and its distance from the Home P oint. (3) A c olor coded battery level indicator shows battery level, and an estimated remaining flight time in minutes is displayed. (4) When the critical battery level warning activates, the aircraft will gradually descend and land automatically . As standard operating pro cedure, the PIC will immediately return the Inspire 1 to the Home P oint for a battery swap when the battery level reaches 25%. On the basis of these specific safety features of battery power level monitoring, and operating procedures, an exemption from thi s rule is requested. 10. **14 CFR 91.405 (a), Maintenance required** Please see ex emption request explanation in item 15 below (14 CFR 91.417). 11. **14 CFR 91.407 (a) (1), Oper ation after maintenance**  Please see ex emption request explanation in item 15 below (14 CFR 91.417).13 12. **14 CFR 91.409 (a) (2), Inspections** Please see ex emption request explanation in item 15 below (14 CFR 91.417). 13. **14 CFR 91.417 (a) and (b), Maintenance records** Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), cont ain requirements fo r maintenance of larger aircraft. In lieu of adapting these rules for the Inspire 1, SkyNetW ests is requesting an exemption on the basis that it will inspect the Inspire 1 and ensures that it is in a condition for safe flight prior to be ginning an y oper ation. W e propose that adherence to the oper ating documents describing the requirements for maintenance, inspection, and record k eeping, are sufficient to ensure that safety is not adversely affected. PUBLIC BENEFIT Granting this Section 33 3 Exemption would benefit the public in the fo llowing wa ys: • Public Safety: Common pr actice for industrial facility construction projects and periodic site wide industrial facility visual assessment in volves utiliz ation of manned aircraft. The potential risk to life and property is order of magnitudes less for use of a small unmanned aircraft system as compared to conventional aerial photography by manned fix ed wing aircraft. • Industrial Safety: In order to accomplish inspections of difficult to acces s areas at high elevations requires either erection of scaffolding or lifting personnel by crane in protective enclosur es to view the subject of interest. Fall protection gear and compliance with OSHA rules governing such work is crucial for lif e safety . T he ultimate protection, however

, would be to not in vo lve personnel in such activity and instead complete this work with an unmanned aircraft system. • Energy Savings and En vironmental Protection: Reduction of frequency of manned aircraft used to do aeria l photography and surveys f or c onstruction sites and industrial facilities results in burning less fuel thereby sa ving energy and reducing emissions of combustion g ases.14 REASONS SAFETY NOT ADVERSEL Y AFFECTED AND IS A

T LEAST EQUIV

ALENT T O EXISTING RULE Th e k ey f eatures of the proposed Inspire 1 unmanned aircraft system that assure that safety to the public and safety of the National Airspace S ystem (NAS) is not adversely affected are the fo llowing:

 Credentials and training for the Pilot in Command (PIC), along with detailed operating procedures, assure that the level of competency required for successful and safe flight oper ations is achieved.

 The built - in Flight Control S ystem, which includes a F ailsafe Function, assures immediate return to the Home Po int and safe landing under failure scenarios, thereby preventing injury or damage.

 Vi sual Line - of- Sight (VL OS) operation provided by the PIC and the V isual Observer (VO), and their ability to communicate verbally at all times, assures full operational co nt rol.

 Detailed operations and maintenance procedures, including a Preflight Checklist, provide assurance of mechanical in tegrity and full functioning of Inspire 1 unmanned aircraft system prior to commencement of any operation.15 **SUMMARY F OR PUBLICA**  **TION IN FEDERAL REGISTER** Petition for Exemption Dock et No.: FAA - 2015 - xxxx Petitioner: SkyNetW est U nmanned Vehicle Services (U .V. S.) Section of 14 CFR 14 CFR 21 Subpart H, 61.113{a) and {b), 91.7 (a), 91.103 (b) {2), 91.105, 91.109, 91.119 (c ), 91.121, 91.151, 91.405 (a), 91.407 (a) {1), 91.409 (a) {2), 91.417 (a) and (b). Description of Relief Sought: The petitioner is seeking an exemption to utiliz e an unmanned aircraft system (UAS) to accomplish aerial photography , surveys and assessments of industrial and commercial facilities.
Respectfully Submitted,

Noah Ruiz Ow ner SkyNetW est U VS