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March 2, 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 CFR part 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b) 

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

91.417(a) & (b).

Dear Sir or Madam:

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

C.F.R. Part 11, Skycam Video, a newly formed aerial video firm, hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned 

Aircraft Systems (“sUAS’”) for aerial photography and videography for mapping, inspections of drainage 

ways, detention ponds, utilities, construction industries and real estate properties and other flight 

operations that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. National Airspace System as compared to manned aircraft. Operations would be 

performed only at the request of and with the authorization and permission of clients or their 

authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of sUAS’s 

so long as such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

Exhibits: 

Due to size of files please go to: www.dji.com/product/inspire-1/spec to review the following DJIInspire 1 Manuals and Safety Guidelines. Once website opens click on “Downloads”. Then under 

Documents and Manuals open the following PDF files to review:

1.) Inspire 1 Quick Start Guide (EN) v1.0

2.) Inspire 1 User Manual (EN) v1.0

3.) Inspire 1 Safety Guidelines v 1.0

4.) Inspire 1 Intelligent Flight Battery Safety Guidelines

5.) 1345 Propeller Locks Quick Start Guide

6.) Inspire 1 Maintenance Manual v 1.0

Other Inspire 1 Informational Data:

 Please refer to the following DJI Inspire 1 tutorial videos listed at www.dji.com/product/inspire1/video 

1.) DJI Inspire 1 – Unboxing and Preparing for Safe Flight

2.) DJI Inspire 1 Tutorial “Pilot App”

3.) DJI Inspire 1 Tutorial “Updating the Firmware”

4.) DJI Inspire 1 Tutorial “Dual Operator”

5.) DJI Inspire 1 Tutorial “How to Fly”

6.) DJI Inspire 1 Quick Start Guide
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7.) DJI Inspire 1 Set Up & Demo Inc. Overview of Features of the App

8.) DJI Inspire 1 Flight Simulator for Apple App introduction

As detailed in this document and the referenced DJI Publications and tutorials, the requested exemption 

would permit the operation of sUAS under controlled conditions in airspace that is a.) limited b.) 

predetermined c.) controlled to access and d.) would provide safety enhancements to the already 

regulated safety practices presently followed by manned aircraft as governed by the FAA. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibility to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.

Applicant Contact Information:

Skycam Video 

Robert Syme, Owner (Private Pilot)

7662 Matchlock Heights

Colorado Springs, CO. 80923

PH: 719-499-4060

Email: rnsyme@msn.com

A. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including 

sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702 – 44716 of this title if the Administrator finds 

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 

CFR §91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the 

National Airspace System without creating a hazard to the user, the public, or a threat to national 

security. In making this determination, the Secretary must consider:

a.) The sUAS’s size, weight, speed and operational capability

b.) Whether the sUAS operates within the visual line of sight of the operator

c.) Whether the sUAS operates outside of highly populated areas and away from close proximity to 

airports

Reform Act §333(a). If the Secretary determines that a sUAS “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. §333(c).
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Skycam Video will be using a quad copter manufactured by DJI. The model being used is the Inspire 1. 

The Inspire 1 weighs less than 8 pounds, including payload. The Inspire 1, operating under normal 

conditions, (no wind) travels at a maximum speed of 49 knots and has the capability to hover and move 

in the vertical and horizontal plane simultaneously. The Inspire 1 will operate only in the pilot’s visual 

line of sight at all times and will operate only within the limits of the area required to be videoed or 

photographed. Such operations will insure that the Inspire 1 will “not to create a hazard to users of the 

national airspace system or the public.” Reform Act Section 333(b).

Given the small size of the Inspire 1 and the restricted and predetermined environment within which it 

will operate, this application falls squarely within the zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to 

commence immediately.

Also due to the small size of the Inspire 1 and the low altitudes and restricted areas in which it will 

operate, approval of the application presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, 

and the significant public benefit, including enhanced safety, grant of the requested exemptions is in the 

public interest. Accordingly, Skycam Video respectfully requests that the FAA grant the requested 

exemption without delay.

B. PUBLIC INTEREST

This exemption application is expressly submitted to fulfill Congress’s goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the National Airspace System before 

completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption 

the FAA will fulfill Congress’s intent of allowing UAS to operate with significant safety precautions in low 

risk environments.

The use of sUAS for videoing or photographing drainage ways, detention ponds and survey mapping can 

reduce the risk of injuries to workers attempting to walk in very dangerous/difficult terrain found in 

waterways, detention ponds and surveying areas as well as reduce environmental impacts to wetland 

areas that are very sensitive for wildlife. Use of sUASs on construction sites can significantly reduce the 

risk to workers of falls while inspecting, surveying or monitoring site progress. sUASs can inspect, 

photograph and collect data on hard to get to areas that otherwise would require worker inspection. 

Falls are the leading source of workplace fatality and injury on construction sites1, and reducing falls 

through sUASs use for site imaging could save workers lives. Aerial videography for real estate 

marketing has been around for years through manned fixed wing aircraft and helicopters. For small 

budget real estate companies and average homeowners the expense of such aerial videography is cost 

prohibitive. Only large companies and high end realtors or luxury homeowners can afford to absorb 

such expense, depriving non-luxury homeowners and lower budget realtors from a valuable marketing 

 

1

“Commonly Used Statistics”, Occupational Safety & Health Administration. Available at: https://www.osha.gov/oshstats/commonstats.html
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tool. Manned aircraft pose a threat to the public through potential catastrophic crashes resulting in loss 

of life due to the potential combustible fuel that can explode and burn on impact. sUASs pose no such 

threat since size and lack of combustible fuel alleviates any potential threat to the public.

Finally, sUASs reduce the environmental impact by dramatically decreasing the energy used for aerial 

imaging. The Inspire 1 uses rechargeable lithium ion batteries, as opposed to fossil fuels burned in 

operation of small aircraft and helicopters that are hundreds or thousands of times heavier.

C. EQUUIVALENT LEVEL OF SAFETY

Skycam Video proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe operations 

conducted with helicopters and other conventional aircraft.

Skycam Video will be bound by the following limitations when conducting its sUAS operations under an 

FAA issued exemption:

1.) The sUAS will be less than 8 pounds.

2.) Flights will be operated within visual line of sight of the pilot.

3.) Maximum total flight time for each operational flight will be 14 minutes. The Inspire 1

calculates battery reserve in real time, and will return to its ground station with at least 20% 

battery reserve should that occur prior to the 14 minute limit. 

4.) Flights will be operated normally at approximately 150 feet AGL, never exceeding 400 feet AGL.

5.) Horizontal flight speed will not exceed 42 knots.

6.) Crew for each operation will consist of the sUAS Pilot who will keep the sUAS within his/her 

visual line of sight at all times and a Visual Observer who will also keep the aircraft within line of 

sight as well as watch for other aircraft or personnel that might enter the operations area.

7.) Pilot and Visual Observer will keep in constant verbal contact throughout the duration of each 

flight. If conventional aircraft or unauthorized personnel enter the flight operations area 

unexpectantly the flight will be terminated immediately.

8.) The sUAS pilot will be trained in flight, operations, checklists and safety procedures as detailed 

in the DJI Inspire 1 Manuals found at www.dji.com/product/inspire-1/spec and DJI Inspire 1 

Tutorials found at www.dji.com/product/inspire-1/video.

9.) The sUAS will only operate in a confined predetermined area around which a security perimeter

will be established for flight operations.

10.)Warning signs will be posted in the flight operations area indicating to remain clear of the area.

11.)A briefing will be conducted in regard to the planned sUAS operations prior to each flight. It will 

be mandatory that all personnel who will be present within the boundaries of the safety 

perimeter be present for this briefing.

12.)All personnel will consent to the UAS flyover on site by waiver, and the operator will obtain 

additional verbal or written consent of all persons who will be allowed within 100 feet of the 

flight operation.

13.)Written and/or oral permission from the relevant property holders will be obtained.
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14.)All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies 

when required.

15.)The pilot will take all actions including reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight.

16.) The pilot will have a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotocraft 

pilot and at least 10 hours of sUAS as pilot with the DJI Inspire 1 to be utilized for operations 

under the exemption. 

17.)The pilot will have a Private Pilot’s license and a Class III medical.

18.)The pilot will perform a minimum of 3 takeoffs and landings within the preceding 90 days with 

the Inspire 1 sUAS.

19.)If the Inspire 1 loses communications or loses its GPS signal, it will automatically return to a predetermined location within the security perimeter and land. Please refer to the DJI Inspire 1 

User Manual pages 13-16.

20.)The pilot will abort a flight (return to home) in case of unpredicted obstacles or emergencies 

with the push of a button. Please refer to DJI Inspire 1 User Manual page 28.

21.)Single family residential and commercial properties to be videoed will be limited to a minimum 

of one acre parcels, in size, which would allow the sUAS to be maneuvered around the 

perimeter of the structure without over flying the structure being videoed as well as any

structures on adjacent properties thus allowing an emergency landing, if a power failure occurs, 

without any undue hazard to persons or property on the surface.

22.)sUAS will not be flown within 5 miles of airports as shown on current FAA-published 

aeronautical charts unless authorization has been granted by the controlling ATC facility 

governing that airport.

23.)Pilot will preflight/inspect sUAS for airworthiness prior to each flight including the Ground 

Control station.

24.)Pilot will maintain the Inspire 1 and properly document all maintenance and alterations in the 

Inspire 1 records.

25.)Pilot will conduct a functional test flight after all maintenance prior to the next operational flight 

and record this flight in the Inspire 1 records/ flight log.

26.)All flights will be flown only during daylight hours under visual meteorological conditions (VMC).

D. DESCRIPTION OF SPECIFIC REGULATIONS REQUESTING EXEMPTION FROM:

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by Skycam Video, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 V.S.C.§44701 (t) and Section 333 of the Reform Act both authorize the FAA to

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

sUAS. Our small UAS will be operated at low speed in a controlled environment, at least five miles from 

an airport and more than three miles from any densely populated area. An analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and 

conditions proposed.
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The DJI Inspire 1 to be operated hereunder is less than 8 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by the operator and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation. 

These safety enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and ability to carry an external load no greater than two 

pounds .

14 C.F.R. 45.23(b): Marking of the Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport

category aircraft to be marked with letters between 2 inches and 6 inches high “limited,” “restricted,”

“light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit, or pilot station.

Even though the sUAS will have no airworthiness certificate, an exemption would be needed as the sUAS

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the sUAS, two-inch lettering would be impossible. 

The FAA has issued an exemption to this regulation: Exemption No. 11109.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the pilot operating the sUAS to have completed sUAS flight training by reviewing 

each of the three DJI Inspire 1 manuals (attached to this document), review all DJI Inspire 1 tutorial 

videos listed at www.dji.com/product/inspire-1/video. The pilot would also perform a minimum of 200 

flight cycles, 25 hours of total time as a sUAS rotocraft pilot and a minimum of 10 hours of piloting the 

Inspire 1 before performing the first “operational flight” under this exemption. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or 

cargo on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested with a pilot who has met the minimum requirements stated above 

exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 
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requirements contained in the DJI Inspire 1 Manuals, DJI Inspire 1 tutorials and the use of a preflight 

checklist prior to each flight an equivalent level of safety will be provided.

14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The sUAS, 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 aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the sUAS will 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. 91.103(b): Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of 

flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, 

including checking for weather conditions, checking flight battery requirements, checking takeoff and 

landing distances, and all other actions in the Preflight Checklist in the DJI Inspire 1 Manuals. These 

actions will provide an equivalent level of safety.

14 C.F.R. 91.109: Flight Instruction

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 functioning dual controls.

By design, sUASs and remotely piloted aircraft 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 

communications. The FAA has previously approved exemptions for aircraft without fully functional dual 

controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via

radio signals from the controller, and by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 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. This exemption is 

for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which 

will typically operate at altitudes of 150 AGL, so an exemption may be needed to allow such operations. 

The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. 
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The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and any onsite personnel all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighing far more than the maximum 8 lbs. proposed herein and carrying 

flammable fuel, any risk associated with our operations is far less than those presently

presented with helicopters and other conventional aircraft operating at or below 500 AGL. In addition, 

the low-altitude operations of the sUAS will ensure separation between these sUAS operations and the 

operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The Inspire 1 is 

limited to operations in predetermined and controlled environments, and has a limited range and flight 

time which require an exemption from 14 CFR 91.151(a).

The battery powering the Inspire 1 provides approximately 18 minutes of powered flight. To meet the 

30 minute reserve requirement in 14 CFR §91.151, DJI Inspire 1 flights would not be possible. Given the 

limitations on the DJI Inspire 1 proposed flight area and the location of its proposed operations within a 

predetermined area, a time frame of 14 minutes for flight in daylight VFR conditions is reasonable.

Skycam Video believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the DJI Inspire 1, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, with 

less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the Inspire 1. Additionally, limiting Inspire 1 flights to

less than 14 minutes would greatly reduce the utility for which the exemption will be granted.

An equivalent level of safety can be achieved by limiting flights to 14 minutes, or enough battery reserve 

to ensure that the Inspire 1 lands at the ground station with at least 20% of battery power (as 

determined by the onboard monitoring system and the pilot), whichever happens first. This restriction 

would be more than adequate to return the Inspire 1 to its planned landing zone from anywhere in its 

limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The regulation provides in part:

(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 ....
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(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.

The DJI Inspire 1 fully loaded weighs no more than 8 lbs. and is operated without an onboard pilot. 

Therefore there is no ability or place to carry certification and registration documents or to display them 

on the DJI Inspire 1.

An equivalent level of safety will be achieved by keeping these documents at the ground flight control 

point where the pilot flying the sUAS will have immediate access to them; to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700.

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, 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 sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Skycam Video. Maintenance will be accomplished by the operator. An 

equivalent level of safety will be achieved because the DJI Inspire 1 is 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 DJI Inspire 1 can land immediately and will be operating from no higher than 400 feet AGL. The 

operator will ensure that the DJI Inspire 1 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 aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 

C.F.R. §§ 61.113( a) & (b);91.7(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.151(a);91.203(a) and (b); 

91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (8 lbs. or less) in aerial photography and videography for mapping, inspections of drainage ways, 
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detention ponds, utilities, construction industries and real estate properties and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low altitude 

within the U.S. National Airspace System as compared to manned aircraft. 

Approval of exemptions allowing commercial operations of sUASs enhances safety while reducing risk. 

Manned aircraft create a greater risk because the craft are much larger, have combustible fuel, and 

carry an onboard human pilot. In contrast, a sUAS weighing fewer than 8 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. 

The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated 

with manned aircraft flights.

The operation of small UASs, weighing less than 8 lbs., conducted in the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile 

environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. Images taken will be of individuals who have also consented to being filmed or 

otherwise have agreed to be in the area where aerial photography will take place. 

********

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of Skycam Video’s sUAS in above referenced services 

pursuant to the DJI Manuals attached hereto.

Thank you for considering this exemption request.

Sincerely,

Robert Syme

Skycam Videos

Owner (Private Pilot)