January 9, 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 and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) 

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 

(a) (2);91.417 (a) & (b). 

To whom it may concern, 

In pursuant with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, 

OpenSky Drones LLC (OpenSky), an operator of a small Unmanned Aircraft System (sUAS) for 

agricultural industry, seeks an exemption from the Federal Aviation Regulations (FARs) to allow 

commercial operations of its sUAS. 

OpenSky's requested exemption would permit the operation of a sUAS under controlled conditions 

private agricultural property that is: (i) limited, (ii) predetermined, (iii) subject to controlled access 

through our customers, and (iv) provides greater safety in connection with aircraft operations in. 

OpenSky believes that an exemption in the Agricultural would enhance safety of the field staff and 

fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to establish safe 

operations of sUAS. 

The agricultural industry currently consist of many acres of private land difficult to access quickly. 

Task which are required to manage and maintain crop health and viability become arduous chores 

due to time and coverage constraints. From the need to locating irrigation problems to tracking 

nuisance species and insect infestation becomes quite the undertaking. OpenSky intends to provide a 

support team to collect data required for these assessments in the air to not only accelerate these 

task but make them economically feasible from the ground with minimal time and risk. Through 

mounted equipment on the sUAS, we will be able to observe, analyze and acquire valuable data for 

the farmer and land owner. Therefore, the purpose of this petition is to improve crop management 

over private agricultural lands. 

OpenSky is an engineering company in both Civil/Structural as well as RF disciplines specializing in 

remote sensing services to major wireless providers across the continental United States. OpenSky's 

sUAS flights can be flown to achieve an aerial view, video recording, signal analysis, laser 

measurement of structures and property. 

Data captured from the flights will assist in providing up-to-date usable data for planning and 

mitigation of crops and land usage. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address; 
OpenSky Drones, LLC. 

Dan Q Pham, P.E. 

12453 NW 44th St 

Coral Springs, FL 33095 

(954) 918-3888 

Email: dan@OpenSkydrones.com 

(b) The specific section or sections of 14 C.F.R. from which OpenSky seeks an exemption 

· 21- Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

45.23- Display of marks; general 

61.113 -Private pilot privileges and limitations: Pilot in command 

91.103- Preflight Actions 

91.10 5 - Flight crewmem bers at stations 

91.109- Flight instruction; Simulated instrument flight and certain flight tests 

91.119- Minimum safe altitudes: General 

91.121- Altimeter settings 

91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

91.203 -Civil aircraft: certification required 

91.405- Maintenance required 

91.407 -Operation after maintenance, preventative maintenance, rebuilding, and 

alteration 

91.409 -Inspections 

· 91.417 - Maintenance records 

We believe an exemption from the above regulations will allow OpenSky to conduct the needed work 

as described above. 

(c) The extent of relief OpenSky seeks, and the reason OpenSky seeks the relief 

OpenSky seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent 

to operate small UASs around agricultural properties. 

14 C.F .R. 21 - Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

OpenSky seeks exemption from 14 C.F.R. 21, Subpart H which states the certification procedures for 

products and parts as well as airworthiness certificates. Due to the limited airspace that OpenSky will 

be using at cellular locations across the country, we are seeking exemption to the airworthiness 

certification process. OpenSky has developed our own training procedures and regulations to 

promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) of this 

petition. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's 

requirements, and under the requirements and in compliance with local public safety requirements, 

to provide security for the area of operation. 

14 C.F.R. § 45.23 (b). Marking ofthe Aircraft 

OpenSky seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. Specifically, 

section 45.23 states, "(a) each operator of an aircraft must display on that aircraft marks consisting of 

the Roman capital letter "N" (denoting United States registration) followed by the registration 

number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital 

letter (b) 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 near 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". 

OpenSky will need exemption from this regulation due to the small size of the aircraft and that there 

is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" can be placed on the 

fuselage in compliance with §45.29 (f) where the pilot, observer and others working with the sUAV 

will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions 

to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

OpenSky seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and 

limitations for the Pilot in command (PIC). 

OpenSky is seeking exemption from this regulation, because OpenSky believes that there is 

inconclusive evidence that a person with a private pilot certificate can successfully maneuver a sUAS 

without first hand flight experience with the particular sUAS. In fact, having a private pilot license 

does not automatically ensure competence at flying an sUAS in 3rct person view as required to 

properly operate an sUAS within the required line of sight. However, we believe that the PIC and our 

FOVO (Field Operation Visual Observer) must be able to understand and correctly interact with the 

general aviation community. Therefore, we believe our own flight training with the sUAS will be 

more than satisfactory. Our PIC and FOVO will be both certified in Ground School training to be able 

to properly interact with General Aviation protocols. They will also actively pursue a private pilot's 

license as well have the necessary medical qualifications. 

14 C.F.R. 91.103- Preflight Actions 

OpenSky seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, 

before beginning a flight, become familiar with all available information concerning that flight. This 

information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, 

weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot 

be completed, and any known traffic delays of which the pilot in command has been advised by ATC; 

actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and 

aircraft performance data before starting a flight. 

OpenSky's will be operating our sUAS in VFR. Our operations manual already includes preflight 

procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning 

details regarding weather conditions, review of any possible flight path of general aviation, our 

mission flight path and weather conditions amongst other parameters required to complete the 

mission. 

14 C.F.R. 91.105 -Flight crewmembers at stations 

OpenSky seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. 

Specifically, 91.105 states "(a) During takeoff and landing, and while en route, each required flight 

crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform 

duties in connection with the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight 

crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her 

shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if 

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The 

crewmember would be unable to perform required duties with the shoulder harness fastened. 

OpenSky will need exemption from this regulation due to the fact that the sUAS will not have a flight 

crew or crew stations other than the PIC and a FOVO. The PIC will also not have to be restrained into 

a seat via shoulder harness or safety belt at the time of the flight. 
14 C.F.R. 91.109 -Flight instruction; Simulated instrument flight and certain flight tests 

OpenSky seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated 

instrument flight, and certain flight tests. Specifically, 91.109 states "(a) 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, when (1) The instructor has determined that 

the flight can be conducted safely; and (2) The person manipulating the controls has at least a private 

pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, 

functioning throw over control 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 §61.56 of this 

chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57 

when (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 be 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 lighterthan-air aircraft, 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". Again, Except when necessary for takeoff or landing, no person may 

operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit 

fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over 

congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered 

parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons 

or property on the surface- (1) A helicopter may be operated at less than the minimums prescribed 

in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with 

any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered 

parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in 

paragraph (c) of this section (a) Each person operating an aircraft shall maintain the cruising altitude 

or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating-(1) Below 18,000 feet MSL, to-(i) The current reported altimeter setting of a station 

along the route and within 100 nautical miles of the aircraft; (ii) Ifthere is no station within the area 

prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or (iii) In 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 

(2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is determined by the 

atmospheric pressure in the area of operation as shown in the following table: 

OpenSky believes that there is inconclusive evidence that a person with a private pilot certificate or 

license can successfully maneuver or train someone to use an sUAS without first hand flight 
experience with the particular sUAS. Flying in 3rct person orientation requires built-up experience in 

that form of flying for many years. Therefore, we believe our own flight training, pilot protocols and 

first hand experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds 

the requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will 

be operated by a remote control, which will only require a single person operator and dual controls 

will not be necessary. 

14 C.F.R. 91.119 -Minimum safe altitudes: General 

OpenSky seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Since Cell 

towers are much less than 500ft and our flight ceiling will be below 400ft, this would not pertain to 

our sUAS operations 

14 C.F.R. 91.121- Altimeter settings 

OpenSky seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest usable 

flight level. 

C ... F R 91121 states ' 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 

(c) 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 

num b ero H eet speci fidbl ·e e ow, accor d h ing tot e 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 

OpenSky's sUAS uses both GPS altitude and barometric sensors and relays that information to our 

ground station. However, this data is used help the sUAS to automatically maintain position hold at 

the required elevation and therefore this code is not pertinent the functionality of this sUAS. 

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

OpenSky seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in VFR 

conditions. Specifically, 91.151 states "(a) No person may begin 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. (b) No person may 

begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes". 
OpenSky's sUAS has a typical mission time ofless than 15 minutes with maximum flight time of 25 

minutes. Since this amount less than the 30 minute reserve minimum, this reserve minimum would 

not even make sense in allowing the sUAS a chance to fly. According to OpenSky's aircraft flight 

manual, the PIC is instructed to maintain flight until battery power reaches 25%, or 1st level warning. 

At this level, landing procedures will be intiated. Once the sUAS reads 20%, 2nd level warning, the 

flight control system automatically take over and initiates safe landing sequence at the logged in 

takeoff point. OpenSky policy outlined in our operating flight manual achieves satisfactory safety 

standards. 

14 C.F.R. 91.203 -Civil aircraft: certification required 

OpenSky seeks exemption from 14 C.F.R. 91.203, which discusses states: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the 

following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, 

a copy of the applicable operations specifications issued under §21.197( c) of this chapter, 

appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter 

containing that portion of the operations specifications issued under §21.19 7 (c), or an authorization 

under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this 

chapter. 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 revised airworthiness 

certificate having on it an assigned special identification number, that has been affixed to an aircraft, 

may only be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the second copy 

of the Aircraft registration Application as provided for in §4 7.31 (c), or a registration certification 

issued under the laws of a foreign country. (b) No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers 

or crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger 

compartment or a baggage compartment unless the installation was accomplished pursuant to part 

43 of this chapter, and a copy ofF AA Form 3 3 7 authorizing that installation is on board the aircraft. 

(d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the 

United States unless it complies with the fuel venting and exhaust emissions requirements of part 34 

of this chapter". 

certifications. Specifically, 91.203 states" 

OpenSky believes that an appropriate and current airworthiness certificate would not be necessary 

to fly a sUAS given the size of the aircraft and the necessary level of skill needed to operate the 

aircraft. Before putting in to service, each of our sUAS goes through our own airworthiness 

proceedures of miminum test flight and reliability checks. Also, our sUAS are recalibrated each at the 

site location before each flight to ensure that all systems functions as designed. OpenSky seeks 

exemption from this regulation because we believe this rule was not meant for a sUAS and operators. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 

OpenSky seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses 

required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or 

alteration, inspections, and maintenance records. In OpenSky's aircraft flight manual, maintenance 

and inspection procedures have been established for the aircraft. OpenSky believes these regulations 

are meant for manned operated aircrafts and not unmanned systems, therefore making them 

unnecessary. 
Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it 

necessary to grant this request. 

(d) The reasons why granting OpenSky's request would be in the public interest; that is, how it would 

benefit the public as a whole. 

OpenSky is classified as an engineering company by the U.S. Department of Transportation and 

provides services to aerial support for commercial interest. OpenSky's use of a sUAS can assist in 

making task safer and minimize human exposure to being at dangerous elevations. OpenSky's sUAS 

usage will also reduce the time required to capture the needed imaging or data to convention 

helicopters or airplanes. Ultimately, the result is quick completion of task an reduction of dangerous 

elevation perspective needs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which OpenSky seeks 

exemption Our Engineering department will provide a level of safety that exceeds the level of safety 

required by the FAA for its use on sUAS. The following are OpenSky's safety procedures, features, 

regulations, and operating specifications for our sUAS: 

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Our Squadron Leader /Chief Pilot in Charge is an engineer who has 10 years of RC Model 

building and flight experience with over 1000 flight hours in Fixed-wing, Helicopter and 

Multi-Rotor 3rd person flight. He has been involved with flight design, experimentation and 

system optimization for model industry since 2008 though SAPAC, Inc. models. 

Our staff includes an FAA-rated commercial flight instructor (ret) who coordinates our FOVO 

team in integration with general aviation. 

The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will be required 

to wear hard hats, safety vests, and safety glasses to protect the head and eyes from potential 

mishaps during given operational flights including training or testing of sUAS. 

The flight area of the sUAS will be observed for best take off and landing locations. Desired 

conditions include: flat and level surfaces clear of debris, at least 15ft from power lines and 

structures, and a minimum distance of 12ft from the PIC and observers. 

The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all 

flights. 

Flights must take place during good weather conditions with no rain, low laying clouds, or 

heavy winds. All flights will take place during daylight hours with no evening or late night 

flights. 

The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being 

designated working flights. 

All batteries must be charged completely before each flight and each flight must end when 

the battery has a 30% power level remaining. 

A visual safety inspection will occur before each flight, testing propeller tightness, security 

mount of camera/detection equipment, remote range test, and proper safety equipment is 

adorned to PIC and FOVO. 

The sUAS will be flown under a height of 500 ft AGL . 

No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical 

phase of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a 

configuration appropriate for the purpose of the intended flight. 

If there is more than just an operator at a site during a flight, the PIC operator and observer 

or FOVO will maintain two-way communication with each other during all operations; if 

unable to maintain two-way communications, or if any condition occurs that may otherwise 

cause the operation to be unsafe, the operator will immediately conclude the operation. 

If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to 

its designated home-point location. If the communication link is reconnected during fail-safe 

mode, control of the sUAS can be regained before landing occurs at the home-point location. 
• There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk 

of explosion if a crash occurs with the sUAS. 

• The sUAS will feature a built in compass that will be recalibrated at every site to maintain 

accurate directional readings. The compass will also help in keeping the sUAS stable during 

flights. 

• The sUAS will record GPS location data once Ready to Fly status has been obtained. A 

minimum of 6 satellites will activate the Ready to Fly status. 

• The weight of the sUAS is less than 20 lbs. with a maximum ascent speed of 6 mjs and a 

descent speed of 2 mjs. The aircrafts maximum flight speed is 15 mjs. 

• The aircrafts vertical and horizontal aspect concerning hovering accuracy is 0.5m and 1.5m 

respectfully. 

• The typical aircraft wheelbase will be less than 1000mm in length. 

• The aircraft runs off a Li-Po battery. 

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek 

the exemption; and (2) A brief description of the nature of the exemption you seek 

Petitioner: OpenSky Drones, LLC. 

Sections of14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 

Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 

91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct aerial inspection for 

agricultural industry and their properties and subject to operating procedures that meet or 

exceed those that FAA requires. 

(g) Any additional information, views or arguments available to support your request 

Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United States, the reason 

why you need to do so 

The Operations described in this exemption request will be conducted wholly within the 

United States. 

Attached hereto, and submitted as a confidential document, is our Field Operations Manual. We 

respectfully submit that good cause exists so that this confidential manual does not need to be 

published in the Federal Register. 

Please do not hesitate to contact me via email at dan@OpenSkydrones.com if you have any questions 

or concerns. 

Dan Q Pham, P.E. 

Vice President, 

OpenSky Drones, LLC