Skyward Photography & Solutions

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Exemption Request Section 333 of FAA reform act

To whom it may concern:

This petition is being submitted without legal counsel or consultation.

This is a request of exemption for commercial use of UAS under section 333 including the following 

F.A.R.s as defined by the F.A.A.

14 CFR Part 21 Subpart h

14 CFR Section 45.23(b) 

14 CFR Section 61.113(a) and (b)

14 CFR Section 91.7(a) 

14 CFR Section 91.9(b)(2) 

14 CFR Section 91.103 

14 CFR Section 91.109 

14 CFR Section 91.119 

14 CFR Section 91.121 

14 CFR Section 91.151(a)

14 CFR Section 91.405(a) 

14 CFR Section 91.407(a)(1) 

14 CFR Section 91.409(a)(1) and (2)

14 CFR Section 91.417(a) and (b)

The exemption requested would allow Skyward Photography & Solutions the ability to provide a 

variety of photography and videography services for both profit and non-profit organizations. These 

include the following:

Construction inspection

Insurance appraisal

Real estate 

Nature, event, and legal Photography/Videography

Marketing

Law enforcement/search and rescue photography

Closed set production
All photography will take place on public land, or private property with prior consent from the owner of 

the property. All commercial videography and photography will be done with the consent or agreement 

of those in the video or edited to protect identities of individuals, as in the case that consent cannot be 

obtained. 

U.A.S. 

The U.A.S. in question is a DJI inspire one. DJI as one of the primer U.A.S. developers have tested designs 

that provide many safety features. The Inspire One can use GPS signal to return home in the event of 

signal loss from the remote control, low battery indicator, and can be activated manually. The low 

battery indicator is adjustable to provide maximum safety based on the distance and conditions. The 

U.A.S. in question meets the F.A.A.’s requirements for size, weight, speed and fuel; and does not carry 

any crew, passengers, combustible fuel or cargo payload.

Due to the size, weight and speed; the use of such an U.A.S would greatly benefit the 

community by providing a lower cost alternative to other aircraft, giving opportunities to individuals or

companies that can’t afford the more expensive options. It also decreases the likelihood of significant 

damage or loss to pilot, crew, and civilians or property, than other aircraft. Noise and other pollutions 

are reduced by using rechargeable batteries and a small/lightweight craft. 

P.I.C. 

The pilot in charge or P.I.C considers safety as the primary concern with all flights and operations. The 

U.A.S is inspected, as per DJI’s recommendation, prior to every launch/landing. This includes checks on 

both motors and rotors, primary chassis, gimbal security, and position camera. Battery power for both 

the craft and controller are monitored during flight to ensure a safe return flight. Weather conditions 

are monitored prior to flight to guarantee safe conditions. The Safe Operating Guidelines for U.A.S. have

been reviewed and are agreed to by myself, Scott Salyer. The P.I.C. will maintain V.F.R. flight, not breech 

the 400 ft ceiling AGL or fly within a 5 mile radius of an airport unless A.T.F. is notified and cleared the 

flight plan prior to the flight. Regulations of private property lines will be observed and a reasonable 

expectation of privacy will be maintained.

The P.I.C. (Scott Salyer RN, General Partner of Skyward Photography & Solutions), is an 

upstanding citizen of Kern County with no criminal record and a preexisting state licensure. Currently 

P.I.C. flies recreationally and has not created a nuisance or had a complaint filed against himself. If 

requested for assistance by law enforcement, P.I.C. will follow all directions given so long as they do not 

endanger the public or breech F.A.A. regulations of U.A.S. flight. Other exemptions granted similar to 

this one Ex: 12795, 12801, 12756, 12711 are provided in support of my request. 

The following is a link to the DJI Inspire 1 Download page where the User manual, safety guidelines, and 

maintenance manual used by P.I.C. is found, for your review. Inspire One Download Link

Sincerely Yours,

Scott Salyer RN (General Partner, Skyward Photography & Solutions)