**“ SkyHound LLP** **”**

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SkyHound LLP. 101 Sky Flower Circle Daytona Beach, FL 32117 (862) 214

- 1247

Owners and operators are as followed: (Henze Gustave; Koree Dusenbury; Alain Desnoyers; Joshua Lorenzo; Mackynzie Woodform; Jacob Yates; Joshua Pye)

Dear Sir or Madam: In pursuit of Section 333 of the FAA Modernization and Reform Act of 2012, and 14 C.F.R Part 11, the individuals listed above have obtained substantial learning and training from Embry

- Riddle Aeronautical University and are now in pursuit of obtaining an e xemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) for commercial use in the National Airspace (NAS) regulated by the FAA as long as such operations are conducted within and un der the conditions outlined and required by Section 333. The requested exemption would permit the above individuals exemption to pursue commercial interest in providing various services to clients using a sUAV. Such areas of commercial interest includes b ut not limited to: Marine Life, Animal Wildlife, Real Estate, Marketing, Land Management/Surveying, Agriculture, Construction and Product Distribution. All flights conducted by the operators listed above will occur over private or controlled property with the consent of the property owner and others that may be within the UAS’ radius during it’s’ operation. All operators has demonstrated safe operations and effective flying using variou s sUAV systems. Our primary sUAV for operations will be a **Blade Chroma** s ystem for all commercial and private purposes. The operators comply with local ordinances and laws regarding the proper use of sUAV and adheres to all weather and environmental limitations and restrictions in reference to our operations. We are aware of st ate and local laws regarding privacy and we will adhere to all. **SkyHound LLP.** , is seeking the exemption because we are committed with complying and to adhere to all the rules, guidelines, limitation, and possible future legislation set by the FAA. We agr ee to properly follow and conduct all operations in the manner described above and for the purposes we have set forth. Without the exemption being granted, we would not be able to properly, effectively and safely execute our business process or model. Our intention is to comply with the FAA and obtain the proper exemption in order to become a pioneer in this new and thriving industry. We also believe the safe and proper use of sUAV will enable the best perception by the public for a safe transition into thi s new innovative industry. The following contains a list of regulations from which we are seeking exempt from, and a list of responsibilities we will assume as operators . We’ve also included information about the aircraft, benefit and safety features.**“ SkyHound LLP** **”**

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Regulations from which exemption is requested:

**14 C.F.R. 45.23 :**  **Identification and registration markings** Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) fol lowed by the registration number of the aircraft. Each letter used in the marks displayed must als o be a Roman capital letter. When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft n ear each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Even though the UAS will have no ai rworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two

- inch lettering will be impossible. The equivalent le vel of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.”
**14 C.F.R. 61.113 :**  **PRIVATE PILOT PRIVILE GES AN** **D LIMITATIONS: PILOT IN COMMAND**
Sub

- sections 61.113(a) limit private pilots to non

- commercial operations. The UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requi ring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living th ing on board. All safety precautions are followed in order to ensure safe flights.

**14 C.F.R. 91.7(a) CIVIL AIRCRAFT AIRWORTHINESS**  Exemption # 11313 previously determined that a Blade Chroma should not be required to have an airworthiness certificate based upon the authority of Section 333 of the FAA Modernization and Reform Act of 2012.

**14 C.F.R. 91.9(b) Civil Aircraft Flight Manual in the Aircraft** 

N o person may operate a civil aircraft wi thout complying with the operating limitations specified in the approved Airplane or Rotorcr aft Flight Manual, markings, placards, or as otherwise prescribed by the certificating authority of the country of registry. No person may operate a U.S

. - registered civil aircraft unless there is an available , in the aircraft , current and approved Airplane or Rotorcraft Flight Manual or the man ual provided for in §121.141(b). No person may operate a U.S.

- registered civil aircraft unless that aircraft is identi fied in accordance with part 45 . The sUAV, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the a ircraft. The equivalent level of safety for sUAS operations will be by keeping the flight manual at the ground control where the PIC will**“ SkyHound LLP** **”**

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have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737 , 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

**14 C.F.R. 91.109 :**  **Flig ht I** **nstruction** No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throw

- over control wheel that controls the elevator and ailerons, in place of fixed, dual controls , if and only if, t h e instructor has determined that the flight can be conducted safely and t he person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. An airplane equipped with a single, functioning throw

- over co ntrol wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by, or to obtain recent flight experience or an instrument proficiency check required by §61.57 , wh en — (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and (4) The pilot in command and the instructor have determined the flight can b e conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless

— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighter

-than

- air airc raft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when

— (i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft. Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully funct ioning dual controls. s UAV s ’ and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio frequency communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instructi on in experimental aircraft (e xemption Nos.5778K & 9862A ) . The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft, flight training may be conducted safely.**“ SkyHound LLP** **”**

4 **14 C.F.R. 91.119 :**  **MINIMUM SAFE ALTITUDES** Section 91.119 establishes safe altitudes for operation of civil aircraft. This allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. With the lack of flammable fuel, any risk associ ated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

**14 C.F.R. 91.121 :**  **ALTIMETER SETTINGS** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the s UAV ma y not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the user’s manual. Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by referen ce to an altimeter that is set. W hen op erating below 18,000 feet MSL, t he current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft shall be used. If there is no station within the area the current reported altimeter setting of an a ppropriate available station; or, i n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or a t or above 18,000 feet MSL, to 29.92 ʺ Hg. The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table: **Current altimeter setting Lowest usable flight level**  **29.92 (or higher)** 180 **29.91 through 29.42** 185 **29.41 through 28.92** 190 **28.91 through 28.42** 195 **28.41 through 27.92** 200 **27.91 through 27.42** 205 **27.41 through 26.92** 210 To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting: **Current altimeter setting Adjustment factor**  **29.92 (or higher)** None **29.91 through 29.42** 500 **29.41 through 28.92** 1,000 **28.91 through 28.42** 1,500 **28.41 through 27.92** 2,000 **27.91 through 27.42** 2,500 **27.41 through 26.92** 3,000**“ SkyHound LLP** **”**

5 **14 C.F.R. 91.151(a) :**  **FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS**
Section 91.151 prohibits an individual from beginning "a flight in an airplane under 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

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

**14 C.F.R. 91.2 03(a) & (b)**  **: Civil aircraft: Certifications required**  Except as provided in §91.715, no person may operate a civil aircraft unless it h as within it the following: An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate use d must have on it the registration number assigned to the aircraft under part 47. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revi sed airworthiness certificate having on it an assigned special identification number, which has been affixed to an aircraft, may only be obtained upon application to an FAA Fligh t Standards district office. An effective U.S. registration certificate is iss ued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application, or a registration certification issued under t he laws of a foreign country. No person may operate a civil aircraft unless the airworthine ss certificate required is displayed at the cabin or cockpit entrance so that it is le gible to passengers or crew. No person may operate an aircraft with a fuel tank installed within the passenger compartment or a baggage compartment unless the installatio n was accomplished pursuant to part 43 , and a copy of FAA Form 337 authorizing that installati on is on board the aircraft. No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United States unless it complies with t he fuel venting and exhaust emissions requir ements of part 34 . The UAS fully loaded weighs no more than 55 lbs. and is operated w ithout an onboard pilot; therefore , there is no ability or place to carry certification and registration document s or to displa y them on the sUAV . An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAV wil l have immediate access to them . The FAA has issued numerous exemptions to this regulation. A repre sentative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
**14 C.F.R. 91.401**
**- 91.417**  **Maintenance records** Except for work performed in accordance with §§91.411 and 91.413, each registered owner or o perator shall keep the following records for the periods specified: (1) Records of the maintenance, preventive maintenance, and alt eration and records of the 100

- hour, annual, progressive, and other requi red or approved inspections for each aircraft . This includes the airframe and each engine, propeller, rotor, and appliance of an aircra ft. The records must include a description (or reference to data acceptable to the Administrator) of t he work performed, t he date of c ompletion of the work performed, and t he signature, and certificate number of the person approving the aircraft for return to service. Records must contain the following information; the total time in service of the airframe, each engine, each propeller, and each rotor. The current status of l ife for parts of each airframe, engine, propell er, rotor, and appliance. Also, t he time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. The current inspection status of the aircraft, including the**“ SkyHound LLP** **”**

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time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. The current status of applicable airworthiness directives (AD) and safety directives including, for each, the metho d of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when th e next action is required. Must have c opies of the forms prescribed by §43.9(d) for each major alteratio n to the airframe and currently installed engines, rotors, propellers, and appliances. The owner or operator shall retain the following reco rds for the periods prescribed above. If an owner or operator decides to sell the sUAV, all records shall be retaine d and transferred with the aircraft at th e time the aircraft is sold. A list of defects furnished to a registered owner or operator under §43.11 shall be retained until the defects are repaired and the aircraft is ap proved for return to service. The owner or operator shall make all maintenance records required to be kept by this section available for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). A ddition ally, the owner or operator shall present Form 337 described above for inspection upon request of a ny law enforcement officer. When a fuel tank is installed within the passenger compartment or a baggage compartment pur suant to part 43 , a copy of FAA Form 337 shall be kept on board the modi fied aircraft by the owner or operator. These regulations require that an aircraft operator or owner “shall have that aircraft inspected and shall , between required inspections, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the sUAV

. An equivalent level of safety will be achie ved because these s UAV’ s are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AG L. As provided in the Manual, the operator will ensure that the s UAV is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the airc raft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

**WE ASSUME THE FOLLOWING RESPONSIBILITIES**  1. Operations authorized by this grant of exemption are limited to the Blade Chroma when weighing l ess than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds g reater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.**“ SkyHound LLP** **”**

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6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO an d PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are herein after referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its ope rating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it pe titions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exempti on. The FAA’s UAS Integration Office (AFS −80) may be contacted if quesons arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from oth er people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. T he pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the n ecessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraf t components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. Th e PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirem ents specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 5**“ SkyHound LLP** **”**

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14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with h ow the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consist ent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operat ed under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for fli ght operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operati ons must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA A irport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permi tted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less tha n 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access prope rty. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 6 22. All aircraft operated in accordance with this exemp tion must be identified by 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 must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground**“ SkyHound LLP** **”**

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Control Station of the UAS any time the aircraft is operating. These documents must be made available t o the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediate ly in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operatin g closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the Naonal Tr ansportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

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To conclude, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, We respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a),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 0, 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. 91.401

- 91.417, and permit the company to conduct commercial operations within certain states in the United States using a sUAS Blade Chroma.**“ SkyHound LLP** **”**

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Appendices: A

– Link to Blade Chroma User Manual and below is a partial screenshots. http://www.horizonhobby.com/pdf/BLH8680

- manual

- EN.pdf