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November 22, 2015 

Docket Operations, M-30 

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor

Washington, D.C. 20590-0001 

Subject: Petition to the FAA for Section 333 Exemption SkyNetWest Unmanned Vehicle Services (UVS) 

Dear Sir or Madam 

SkyNetWest U.V.S. hereby submits to the Federal Aviation Administration, pursuant to the FAA 

Modernization and Reform Act of 2012, an exemption petition, in accordance with Section 333 of the 

Act. SkyNetWest 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 Petitions for 

Exemptions Filed under Section 333" as described as of this date at the FAA website at 

https://www.faa.gov/uas/legislative programs/section 333/how to file a petition/

SkyNetWest U.V.S. is an experienced aerial photographer in the State of Arizona. We are experienced in 

flying hobby helicopters for recreational purposes. We have flown small RC electric helicopters for over 

three (3) years without incident. Safety is 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 

exemption request would permit operation of ultra-light weight, unmanned (remote control operated) in 

tightly controlled and limited airspace. More company information can be viewed on the company 

website at www.SkyNetWest.com

Purpose for the Exemption: 

SkyNetWest U.V.S. desired to utilize an unmanned aircraft system (UAS), herein described, to accomplish 

aerial photography of industrial and commercial facilities.
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Contact Information: 

SkyNetWest 

PO BOX 1055

Chandler, Arizona 85244

Office: 480-718-1045

Cell: 480-364-8218 

Email: noah.ruiz@skynetwest.com 

List of Specific Sections of 14 CFR for which exemption is sought: 

This listing matches the list on page 7 of the FAA's "Public Guidance for Petitions Filed under Section 

333", Rev. 9/25/2014

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, Flight 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), Operation after maintenance 14 CFR 91.409 (a) (2), Inspections 

14 CFR 91.417 (a) and (b), Maintenance records

(FURTHER DETAILS ON PAGES 8-11)
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In accordance with the outline given in the FAA's "Public Guidance for Petitions Filed under Section 333", 

the following information is provided for each numbered item listed in that guidance: 

1. Aircraft Description 

Design and Operational Characteristics:

• SkyNetWest U.V.S. plans to operate a DJI Inspire 1 comprised of an unmanned aircraft 

and a transportable ground station. This aircraft is 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-powered electric motors. 

Maximum airspeed is 42 knots.

• The Inspire 1 includes a Failsafe Function. It activates if the Remote Control is powered 

off, the Inspire 1 has flown outside effective control range, the signal between the 

Inspire 1 and the Remote Control is blocked, or if there is interference causing a signal 

problem. When activated, the Failsafe Function automatically flies the Inspire 1 back to 

the Home Point (the start location) and lands it. If GPS mode is not active, the Failsafe 

Function will execute a controlled 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 Point such that 

the flight control system will limit operations to within the confines of the property to be 

surveyed for SkyNetWest or SkyNetWest' Clients. These performance limitation 

requirements are included in the UAS Operating Procedure contained in Appendix A 

herein. 

Manufacturer's Documentation: 

Detailed manufacturer's design information (current to this date) is contained the in the 

following manuals in the appendices at the end of this document: 

• Appendix B- Inspire 1 Specifications

• Appendix C- Inspire 1 Quick Start Guide
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• Appendix D- Inspire 1 User’s Manual 

• Appendix E- inspire 1 Pilot Training Guide 

For ease of reference, the Inspire 1 is included in FAA Section 333 Exemption No. 13512 granted 

on November 5, 2015 to Andrew Wolfe.

2. Procedures for Ensuring UAS Is In a Condition Safe for Flight

Preflight Checks:

At a minimum, the following items will be checked prior to initiating any operation. (See 

Appendix A in this document for detailed procedures, SkyNetWest U.V.S., Operating 

Procedure V1.13.4.15) 

• Operations must be in daylight 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 marked. 

• Flight path is at least 500ft. from all non-participating persons, vessels, vehicles 

and structures unless protective barriers or structures are present, or permission 

is granted or such operations present no hazard to the Pilot in Command, the 

Visual Observer, trainees, and other essential persons.

• Flight plan and schedule has been reviewed with site leadership and 

communicated to all SkyNetWest U.V.S. and Client personnel in the area. 

• Remote control, smart battery, range extender, and ground station monitor are 

fully charged. 
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• Propellers are mounted correctly. 

• Damping absorbers are in good condition, not dry-rotted or worn. 

• Anti-drop kits have been mounted correctly. 

• Micro-SD card has been inserted.

• Gimbal is functioning as normal. 

• Compass has been calibrated. 

• Flight radius and altitude limits have been set with the Phantom 2 Assistant 

software, not to exceed 400ft. AGL altitude, and radius limited to the property 

boundaries of SkyNetWest or SkyNetWest Client site. 

• The Visual Observer (VO) is stationed at the required initial observation point 

according to the flight plan and in view of the Pilot in Command (PIC) and has 

means for continual verbal communication. 

• There are no inoperable components. 

• All site required safety permits are approved in in possession of the PIC. 

• Motors can start and function as normal. 

• Flight Indicator Lights on the aircraft verify that the Home Point is set to 

current location. 

• Record the Preflight Check, date and sign, and file it in the Equipment 

Inspection and Maintenance Record Book. 

3. Radio Frequency (RF) Spectrum for Control

The Remote 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 (875 yds.) 

Operating Frequency 5.728 GHz-5.85 GHz

Communication Distance (Open area) FCC Compliance: 800m
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Receiver Sensitivity (1%PER) -93dBm

Transmitter Power FCC Compliance: lOO mW

Working Voltage 120 mA@3.7V

Built-in LiPo Battery Working Current/Capacity 22.2V, 4500mAh

4. Qualifications for The Pilot in Command (PIC) 

Logged Hours:

The PIC will have accumulated and logged a minimum of 25 hours of total time as a UAS 

rotorcraft pilot with a multi-rotor UAS prior to operations. The PIC will have also 

accumulated and logged a minimum of 5 hours as UAS pilot specifically operating the 

Phantom 2, prior to operations. The PIC will have accomplished, during dedicated 

training sessions, 3 take-offs and landings in the preceding 30 days. Training, proficiency, 

and experience-building flights in dedicated training sessions will be included in the 

accumulated and logged hours.

Emergency and Evasive Maneuvers: 

The PIC will have demonstrated the ability to safely operate the Phantom 2 in a manner 

consistent with how it will be operated in surveying SkyNetWests’ Client properties, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. The logged hours referenced above will 

document this.

5. Description of Intended UAS Operations

• Operations will be restricted to Class G airspace. 

• No operations will occur within 5 miles of a non-towered 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 Waiver or Operation 

(COA). 
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• The Inspire 1 will be utilized to survey industrial and commercial facilities. The use of 

small unmanned aircraft 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 for workers 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 restrict the operation to SkyNetWest Client property. 

The Failsafe Function integral with the inspire 1 will assure this aircraft stays within the 

area deemed safe for operation.

• Industrial facilities of the type mentioned above have strict safety procedures which 

must be satisfied. SkyNetWests' respect for compliance with these procedures is vital to 

assuring positive Client relationships and continuing business. All safety procedures for 

personnel will be strictly adhered to as well as all laws and regulations.

6. Proposed Speed, Altitude, Visibility and Distances 

Speed: 

The Inspire 1 is capable of a maximum speed of 22m/s (42.7 knots). In order to 

conserve power, and thereby maximize 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 traversing a section of the property of no interest and not included in a given 

study.

Altitude: 

Altitudes below 400ft. AGL are adequate for 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 Control System will be set to limit the radial distance from the Home 

Point (point of flight commencement) such that the Inspire 1 will stay within the 

boundary of the property lines. The PIC will operate the equipment to assure those 

limits are not reached and will maneuver the Inspire 1 to follow the preplanned flight 

path within the property boundaries. 
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The Inspire 1 will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud when visibility is less than 3 statute miles from 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 SkyNetWest Client property and not taken into public areas. SkyNetWest and Client 

personnel on the site will be made fully aware of the operation prior to commencement of 

operations. 

8. Proximity of Airports 

Operations will be restricted to Class G airspace. 

No operations will occur within 5 miles of a non-towered 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 Waiver or Operation (COA). 

9. Operation within Visual Line-of-Sight (VLOS)

In addition to the PIC, all operations will include a Visual 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 all times utilizing two-way radios 

available at SkyNetWest 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 for Ensuring UAS Is In a Condition 
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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 satisfactory 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 than 72 hours in advance 

and not less than 48 hours prior to an operation. In addition, any notifications required by the 

FAA Flight Standards District Office will be made.

12. Certificate of Waiver or Authorization (COA) 

Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Operation (COA) will be obtained for each aircraft. Services will start with one aircraft, with 

additional units added as needs for operations increase over time. Each Phantom 2 aircraft will 

be identified with its serial number, registered in accordance with 14 CFR part 47, 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 Exemption 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 for various aircraft types. Small unmanned 

aircraft systems are not specifically called out and addressed in these rules. SkyNetWest will, 

in lieu of airworthiness certification by aforementioned rule, if exemption is granted, ensure 

that the Inspire 1 system is in compliance with its operating documents as described herein. 
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The PIC will assure 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 size, weight, speed, and limited operating area associated with 

SkyNetWest’s proposed Inspire 1, we believe it will not create a hazard to users of the 

National Airspace System (NAS) or the public. Therefore, a request is made for exemption 

from 14 CFR part 21, and any associated noise certification 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 compensation, unless the flight is only incidental to that business or 

employment. SkyNetWest believes that due to the size, weight, speed, and limited operating 

area associated with SkyNetWests’ proposed Inspire 1 operation, a PIC possessing the 

aforementioned training and logged hours, would ensure safety and prevent creating any 

hazard to users of the National Airspace System (NAS) or the public. We therefore request 

an exemption from these parts of 14 CFR.

3. 14 CFR 91.7 (a), Airworthiness required for operation 

If the exemption from 14 CFR 21, Subpart H (item 1 above) is granted, no airworthiness 

certificate will be required. On this basis, exemption from 14 CFR 91.7 (a) is requested, 

presuming that airworthy condition by definition in the rule means having an airworthiness 

certificate. SkyNetWest 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 performance under 

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 not 
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applicable. On this basis and on the basis that the operating documents cover requirements 

for 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 not 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 

with logged 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 is 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 safety procedures, we believe there will be no increased hazard to 

users 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 altimeter settings for cruising altitude and flight 

level of aircraft and speaks of altimeter stations along the route and the elevation of the 
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departure airport. In lieu of these specific requirements, most suitable for manned 

airplanes, the Inspire 1 has barometric altimeter and GPS derived altitude limitations. All 

altitudes reported to Air Traffic Control (ATC) 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 Visual 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, assuming normal cruising speed, during the 

day, to fly after that for at least 30 minutes, or at night, to fly after that for at least 45 

minutes. The Inspire 1 has a built-in Low Battery Level Warning Function: 

(1) If the smart battery is depleted to the point that may affect the safe return of the 

aircraft, the low battery level warning notifies the PIC to take action. 

(2) The thresholds for these warnings are automatically determined based on the 

current aircraft altitude and its distance from the Home Point. 

(3) A color 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 procedure, the PIC will immediately 

return the Inspire 1 to the Home Point 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 this rule is requested.

10. 14 CFR 91.405 (a), Maintenance required 

Please see exemption request explanation in item 15 below (14 CFR 91.417). 

11. 14 CFR 91.407 (a) (1), Operation after maintenance 

Please see exemption request explanation in item 15 below (14 CFR 91.417). 
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12. 14 CFR 91.409 (a) (2), Inspections 

Please see exemption 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), contain requirements 

for maintenance of larger aircraft. In lieu of adapting these rules for the Inspire 1, 

SkyNetWests 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 beginning any operation. We propose 

that adherence to the operating documents describing the requirements for maintenance, 

inspection, and record keeping, are sufficient to ensure that safety is not adversely affected. 

PUBLIC BENEFIT Granting this Section 333 Exemption would benefit the public in the 

following ways: 

• Public Safety:

Common practice for industrial facility construction projects and periodic sitewide industrial facility visual assessment involves utilization 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 fixed wing aircraft. 

• Industrial Safety: 

In order to accomplish inspections of difficult to access areas at high elevations 

requires either erection of scaffolding or lifting personnel by crane in protective 

enclosures to view the subject of interest. Fall protection gear and compliance 

with OSHA rules governing such work is crucial for life safety. The ultimate 

protection, however, would be to not involve personnel in such activity and 

instead complete this work with an unmanned aircraft system. 

• Energy Savings and Environmental Protection:

Reduction of frequency of manned aircraft used to do aerial photography and 

surveys for construction sites and industrial facilities results in burning less fuel 

thereby saving energy and reducing emissions of combustion gases. 
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REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE 

The key features of the proposed Inspire 1 unmanned aircraft system that assure that safety to 

the public and safety of the National Airspace System (NAS) is not adversely affected are the 

following: 

 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 

operations is achieved. 

 The built-in Flight Control System, which includes a Failsafe Function, assures immediate 

return to the Home Point and safe landing under failure scenarios, thereby preventing 

injury or damage. 

 Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual Observer (VO), 

and their ability to communicate verbally at all times, assures full operational control. 

 Detailed operations and maintenance procedures, including a Preflight Checklist, provide 

assurance of mechanical integrity and full functioning of Inspire 1 unmanned aircraft 

system prior to commencement of any operation. 
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SUMMARY FOR PUBLICATION IN FEDERAL REGISTER 

Petition for Exemption 

Docket No.: FAA-2015-xxxx Petitioner: SkyNetWest Unmanned 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 utilize an unmanned 

aircraft system (UAS) to accomplish aerial photography, surveys and assessments of industrial 

and commercial facilities.

Respectfully Submitted,

Noah Ruiz

Owner

SkyNetWest UVS