### - 1 - UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION Petition for Exemption 14 CFR 11.81 IN THE MATTER OF THE PETITION FOR EXEMPTION OF PROSKY STUDIO LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS PART 21 SUBPART H, 91.103(b), 91.105, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING C OMMERCIAL OPERATION OF CHEERSON CX- 20 AND 3DR SOLO UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112 - 95) Submitted on August 14, 2015 Michael Arnold 45049 Weaver Circle Callahan, FL 32011 9 04 - 583 - 6159 michaelrayarnold@gmail.com **TABLE OF CONTENTS** 1. SUMMARY 2. INTRODUCTION AND INTERESTS OF PETITIONER BACKGROUND 

### 3. THE SPECIFIC SECTIONS OF 14 C.F.R. PROSKY STUDIO LLC SEEKS EXEMPTION AND THE REASONS WHY GRANTING THIS EXEMPTION WO ULD NOT ADVERSELY AF FECT SAFETY 

### 4. THE REASONS WHY GRANTING PROSKY STUDIO LLC REQUEST WOULD BE IN THE PUBLIC INTEREST AND HOW IT WOULD BENEFIT THE PUBLIC AS A WHOLE 

### 5. HOW PROSKY STUDIO LLC PLANS TO OPERATE THE UAV IF THIS PETITION IS GRANTED 6. TECHNICAL SPECIFICATIONS OF THE CHEERSON CX- 20 AND 3DR SOLO UAVs 7. CONCLUSION 8. APPENDICIES

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**SUMMARY** Michael Arnold , an owner of ProSky Studio LLC, seeks exemption from the requirements of 14 C.F.R § 91.103(b), 91.105, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will allow ProSky Studio LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of real estate, special events, film sets, agricultural use land (farms) and construction sites within the United States only . **INTRODUCTION AND INTERESTS OF THE PETITIONER** ProSky Studio LLC is a professi onal photography and videography firm that serves Northeast Florida and Southeast Georgia . We provide design, photography and videography services for television, web and print media. One of the company owners , Michael Arnold, is a Private Pilot of over 10 years and has 5 years’ experience in flying remotely controlled aircraft. If this petition is granted, Michael Arnold will be the PIC directly responsible for the operation of the UAV. Michael Arnold has logged flight time in time in manned fi xed wing aircraft since 2005 . Additionally, Michael Arnold owns over 5 UAVs and has logged over 150 hours of UAV flight time for recreational use. This combination of experience and technical expertise makes the operator well versed in the technical and re gulatory aspects of UAV operations. **BACKGROUND** ProSky Studio LLC seeks an exemption to operate Cheerson and 3DR UAV systems for compensation or hire within the National Airspace System. ProSky Studio LLC desires to operate a Cheerson CX- 20 and 3DR Solo. These Unmanned Aerial Vehicle s are each a four bladed “quad” copter allowing for vertical takeoff and landing. Each unit is powered by a Lithium Polymer battery which supplies powe r to the four flight motors. Each craft is controlled wirelessly through a Ground Control Station allowing it to be operated using a remote radio transmitter and an electronic tablet or smart phone system. The Cheerson CX- 20 has a max speed of 22 MPH and a maximum gross weight of 1.92 pounds with dimensions of 7.87 in. tall, 11 i n. motor-to - motor . The 3DR Solo has a max speed of 55 MPH and a maximum gross w eight of approximately 3.3 pounds , with dimensions of 10 in. tall, 18 in. motor-to motor . The Cheerson CX- 20 and 3DR Solo both compl y with all FCC radio frequency regulations. ProSky Studio LLC can provide a FCC compliance letter upon request. If this petition is granted, the Cheerson CX - 20 and 3DR Solo that will be operated by ProSky Studio LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, an d 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. **THE SPECIFIC SECTIONS OF 14 C.F.R. PROSKY STUDIO LLC**  **SEEKS EXEMPTION AND THE REASONS WHY GRANTING THIS EXEMPTION WOULD NOT**  **ADVERSELY AFFECT SAFETY.** Petitioner, ProSky Studio LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the

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Cheerson CX- 20 and 3DR Solo in the National Airspace System (NAS), and for an exemption from the following requirements:

- 14 C.F.R. Part 21, Subpart H Based on the size, weight and sp eed of both UAVs, they meet the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. **The Reasons Why Granting t he Exemption Would Not Adversely Affect Safety:**  ProSky Studio LLC believes that safety will not be affected without an airworthiness certificate because the process of obtaining an airworthiness certificate is intended for the certification of manned aircraft and not small UAVs. Small UAVs, like the Cheerson CX- 20 and 3DR Solo are in a separate category of aircraft, as FMRA Section 333 recognizes.

- 14 C.F.R 91.103 (b) ProSky Studio LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.103(b) entitled Preflight Action. If this petition is grante d, ProSky Studio LLC will be operating a Cheerson CX - 20 and 3DR Solo which do not require a runway. The C heerson CX- 20 and 3DR Solo take off vertically without a runway. Therefore , it is not necessary for the PIC to calculate runway takeoff and landing distances. **Re asons Why a**  **n Exemption from**  **The Requirements of**  **Section 14 C.F.R. 91.103(b) Wo uld Not**  **Adversely Affect Safety:** ProSky Studio LLC believes that safety wil l be enhanced without the need of a runway. Additionally, the size and weight of the Cheers on CX- 20 and 3DR Solo is so minimal, that any takeoff or landing accident would cause minimal damage to persons or property when compared to manned aircraft takeoff and landing accidents.

- 14 C.F.R 91.105 ProSky Studio LLC seeks an exemption from the req uirement of Section 14 C.F.R. 91.105, entitled flight crew members at stations. Because this is an Unmanned Aerial Vehicle, it is operated from the ground. Therefore, the operator has no need to wear seat belts while flying. ProSky Studio LLC believes the UAV can be safely operated from the Ground Station and still maintain safety of flight. **Reasons Why an**  **Exemption from**  **The Requirements of**  **Section 14 C.F.R. 91.105 Wo uld Not Adversely**  **Affect Safety:** ProSky Studio LLC believes that UAVs are much safer than manned aircraft because the PIC is safely on the ground. Any inflight turbulence does not affect the safety of the PIC. In the event of a crash, the PIC risks significantly less physical damage from the Cheerson CX - 20 and 3DR Solo than he or she woul d inside a manned aircraft during a crash. ProSky Studio LLC believes that safety is improved by operating a UAV in lieu of a larger, manned aircraft.

- 14 C.F.R 91.109

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ProSky Studio LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled Flight Instruction; Simulated instrument flight and certain flight tests. ProSky Studio LLC believes that all forms of flight instruction given on the UAV can safely be given using a dual operator ground station. Using two remotes, the instructor has the ability to override the student if needed, ensuring the instructor has full control over the UAV at all times while given flight instruction. Without this exemption, it would be impossible for ProSky Studio LLC to give any type of UAV flight instr uction. **Reasons Why an Exemption From The Requirements Of Section 14 C.F.R. 91.105 Wo uld Not Adversely**  **Affect Safety:** ProSky Studio LLC believe s that the same level of safety will be maintained during flight instruction because the instructor has full control at all times while giving flight lessons. In the event that the student begins the lose control, the instructor can take over, exactly as is done in manned aircraft.

- 14 C.F.R 91.121 ProSky Studio LLC also seeks an exemption from the requirements of Section 14 C.F.R. 91.121, entitled Altimeter Settings, as the Cheerson CX- 20 and 3DR Solo does not have a barometric altimeter. The Cheerson CX- 20 and 3DR Solo altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Altitude information is provided to the Pilot in Command via the telemetry data link. This information is displayed to the Pilot in Command via the ground station tablet or display interface. This altitude information, combined with visual line of sight will ensure a level of safety equivalent to that of Section 14 C.F. R. 91.121. **Reasons Why an**  **Exemption from**  **The Requirements of**  **Section 14 C.F.R. 91.105 Wo uld Not Adversely**  **Affect Safety:** ProSky Studio LLC holds that safety will be maintained because the PIC still has altitude information available to him or her at all times during the flight. This, combin ed with line of sight, attitude and ground speed information keeps the PIC completely aware of the UAV and its surroundings.

- 14 C.F.R 91.151(b) ProSky Studio LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.151(b), entitled Fuel requ irements for flight in VFR conditions. ProSky Studio LLC believes that the standard Lithium Polymer batteries that power the Cheerson CX- 20 and 3DR Solo will be adequate for t he short flights needed for our operation s . The Cheerson CX- 20 has enough battery power to fly for a total duration of approximately 6 minutes with an additional 2 minutes of reserve power for additional flying at normal speed and 3DR Solo has enough battery power to fly for a total duration of approximately 15 minutes with an addition al 5 minutes of reserve power for additional flying at normal speed. ProSky Studio LLC seeks the requested relief because without an exemption from Section 91.151(b), it would not be poss ible to fly a Cheerson CX - 20 or 3DR Solo. This would severely constra in the practicality of any aerial video or still photo flight operations that ProSky Studio LLC proposes to conduct pursuant to this Petition. Furthermore, safety will be ensured as the Cheerson CX- 20 and 3DR Solo UAV provide audible and visual warnings t o the PIC at the ground station when the UAV experiences low battery voltage, the first

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warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the cr itically low battery level, both UAVs d escribed herein will descend and land automatically. **Reasons Why an**  **Exemption from the Requirements o** **f Section 14 C.F.R. 91.105 Would Not Adversely Affect Safety**  **:** ProSky Studio LLC believes that safety will still be maintained because the Cheerson CX - 20 and 3DR Solo would always be flown within line of sight. This ensures that a landing can immediately be made within 1 minute . Additionally, the ability to takeoff or land vertically allows the Cheerson CX- 20 and 3DR Solo to land on virtually any flat surface. This ensures that the Cheerson CX - 20 and 3DR Solo will have adequate battery reserves allowing each UAV to always be able to safely land after a flight.

- 14 C.F.R 91.405(a), 91. 407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b). ProSky Studio LLC requests relief from these sections as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. ProSky Studio LLC requests rel ief from these Sections because neither the Cheerson CX- 20 nor the 3DR Solo require airworthiness certificates as set forth in the conditions of FMRA Section 333. A maintenance logbook will be developed to record all maintenance, alterations or repairs ma de on the UAV. Prior to any revenue flight, the PIC will be required to determine the flight readiness of the Cheerson CX- 20 and 3DR Solo UAV in a manner consistent with this exemption. ProSky Studio LLC will use trained technicians to perform maintenance , alterations, or preventive maintenance on the UAVs using the methods, techniques, and practices prescribed in the UAV operating documents (Monthly Maintenance Log, and Cheerson CX - 20 and 3DR Solo Instruction Manual). Furthermore, ProSky Studio LLC will d ocument and maintain all maintenance records for the Cheerson CX- 20 and 3DR Solo. ProSky Studio LLC submits that it will ensure that the Cheerson CX - 20 and 3DR Solo UAV are in an airworthy condition, prior to every flight, by determining that the UAVs are in compliance with the operating documents (Maintenance Log, and Cheerson CX- 20 and 3DR Solo Instruction Manual), and that the aircraft is in a condition for safe flight. **Reasons Why an Exemption from the Requirements o f Section 14 C.F.R. 91.105 Would No** **t Adversely Affect Safety**  **:** ProSky Studio LLC will carefully and meticulously operate the Cheerson CX - 20 and 3DR Solo in accordance with the manufacturer’s operating manual. The exemption sought will not adversely affect safety because ProSky Studio LLC wil l use trained technicians to perform maintenance, alterations or preventive maintenance on the UAV using the methods, techniques, and practices prescribed by the operating documents. ProSky Studio LLC believes that safety will not be affected because the p rocedures established above ensure the the Cheerson CX- 20 and 3DR Solo will always be maintained and operated in a structured, organized and consistent manner. Using the procedures above ensures that each flight is taken with the utmost care.

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**The Reasons Why Granting ProSky Studio LLC** **’s Request Would Be i n t**  **he Public Int erest AND How It**  **Would Benefit the Public of the United States:** Reason #1. Expanding the availability of affordable aerial photos for industry Granting this petition will furt her the public interest by expanding the availability of economically affordable aerial cinematography and photography. Historically, the public has used aerial photos for a variety of reasons. These aerial photos and videos have been obtained using manned aircraft, costing hundreds and thousands of dollars per hour to operate. Granting this petition will increase the quality of aerial photography services, while at the same time decreasing the price. This service will allow for the following:

- E nhanced an d dynamic real estate marketing, benefiting property owners and real estate agents .

- C rop surveying for the agricultural industry (field drainage monitoring, crop insurance documenta tion, pesticide monitoring, etc.) which will lead to increased farming efficiency benefiting both farmers and consumers .

- Insurance claim documentation for insurance companies such as hail damage, crop damage, bridge collapses, flooding, etc., which will benefit the insurance companies and consumers of insurance products

- C on struction progress for residential, commercial, and industrial construction companies.

- W etland and water drainage mitigation for public works departments, which will enhance the ability of civil engineers to plan for water drainage mitigation .

- Utility inspection services for utility companies - many more potential applications exist The increased efficiency and lower cost of operating a UAV for aerial applications will benefit the economy as a whole by allowing scarce resources, such as aircraft fuel, to be used in other areas of the economy. This will ensure that the United States remains competitive on the global market for aerial applications and ensure that more jobs stay located within the United States. Reason #2. Reduced Levels of Environmental and Noise Pollution Using the Cheerson CX- 20 and 3DR Solo UAVs, to conduct aerial operations instead of manned aircraft will greatly benefit the public by reducing the levels of air and noise pollution. Small UAVs are much more energy efficient than trad itional manned aircraft. By using battery power and electric motors, the Cheerson CX- 20 and 3DR Solo UAV produces no environmental pollution that the traditional four to six cylinder internal combustion aircraft engines that are typically utilized for aeri al video and photography. The Cheerson CX- 20 and 3DR Solo UAV also eliminates a significant amount of noise pollution. The small propeller blades and electric motors produce only a fraction of the noise level that traditional fixed -wing aircraft or helicopters produce.

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Reason #3 Increased Public Safety The public will b enefit f rom the safety and efficiency of t he Cheerson CX- 20 and 3DR Solo UAV. The light weight of the Cheerson CX- 20 and 3DR Solo , pose a negligible threat to people and property on the g round in the event of a crash. The damage a small UAV can do is minor compared to the damage that a manned aircraft with leaded fuel onboard would cause to both the occupants of the aircraft and those on the ground , not to mention the environment. Reason #4. Reduced Congestion of the National Airspace System Granting this request also benefits the public as a whole by reducing the number of manned aircraft, thereby decreasing the overall congestion of the NAS. This in turn, relieve s the air traffic control system of unnecessary aircraft traffic. This will allow the air traffic control system to focus their resources more on the needs of other types of manned flights. **How ProSky Studio LLC**  **plans to operate the UAV if this petition is granted** . If th is petition is granted flights o f C heerson CX- 20 and 3DR Solo UAV will be c onducted according Specific Operating Limitations 1. The UAV may not be operated less than 500 feet below or less than 2,000 feethorizontally from a cloud or when visibility is less t han 3 statute miles from the PIC. 2. The UAV must be operated at a n altitude of no more than 200 feet AGL 3. The UAV 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 . 4. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 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 SO can perform th e functions prescribed in the operating documents. 5. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground obstacles/obstructions and is not permitted to operate the camera or other instruments. 6. The operating documents and the grant of exemption must be accessible during UAV operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. 7. Prior to each flight the PIC must inspect the UAV to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAV, the aircraft is prohibited from

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operating until the necessary maintenance has be en performed and the UAV is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8. Any UAV that has undergone maintenance or alterations that affect the UAV operation or flight characteristics, e.g. replacement of a critical flight component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircr aft records. 9. The pre -flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 10. The operator must carry out its maintena nce, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAV to service. 11. Each UAV operated under this exemption must comply with all manufacturer Safety Bulletins. 12. UAV operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to prop osed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 13. The UAV may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA- published aeronautical chart, or within the lateral limits of class B, C or D airspace as denoted on a current FAA- published aeronautical chart. 14. If the UAV loses communications or loses its GPS signal, it must return to a pre - determined location within the planned operating area and land or be recove red in accordance with the operating documents. 15. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 16. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 17. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N - Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as pract icable. 18. The UAV must remain clear and yield the right of way to all manned aviation operations and activities at all times. 19. The UAV may not be operated by the PIC from any moving device or vehicle.

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20. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless the following conditions are present : a. Barriers or structures are present that sufficiently p rotect nonparticipating persons from the UAV 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 UAV, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons pe r § 91.119(a). 21. All operations shall be conducted over private or controlled - access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtaine d for each flight to be conducted. Flight safety will be maintained because the PIC operating the Cheerson CX - 20 and 3DR Solo is already a private pilot and has demonstrated that the PIC is able to safely operate the Cheerson CX - 20 and 3DR Solo UAV in a m anner consistent with safe operation, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. ProSky Studio LLC will not allow any PIC t o operate the Cheerson CX- 20 or 3DR Solo unless that PIC has demonstrated, that he or she that the PIC is able to safely operate the Cheerson CX- 20 and 3DR Solo UAV in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from peo ple, vessels, vehicles and structures. **Technical Specifications of t he Cheerson CX** **- 20 and 3DR Solo UAV.**  ProSky Studio LLC desires to opera te a C heerson CX- 20 and 3DR Solo. These Unmanned Aerial Vehicle s are each a four bladed “quad” copter allowing for vertical takeoff and landing. The unit s are powered by a Lithium Polymer battery which supplies power to four of the engines. Each UAV is controlled wirelessly through a Ground Control Station allowing it to be operated using a remote and an electron ic tabl et or smart phone system . The Cheerson CX- 20 has a max speed of 22 MPH and a maximum gross weight of 1.92 pounds with dimensions of 7.87 in. tall, 11 in. motor-to - motor . The 3DR Solo has a max speed of 55 MPH and a maximum gross weight of approximately 3.3 pounds, with dimensions of 10 in. tall, 18 in. motor-to - motor . The Cheerson CX- 20 and 3DR Solo both comply with all FCC radio frequency regulations. ProSky Studio LLC can provide a FCC compliance letter upon request. 

### Both t he Cheerson CX- 20 and 3DR Solo UAV Autonomous Flig ht a nd Navigation Modes enable the UAV to remain within a d efined o perational a rea. The Cheerson CX- 20 and 3DR Solo UAV may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigation al modes of the Cheerson CX- 20 and 3DR Solo UAV are provided in the Cheerson CX- 20 and 3DR Solo User Manual (see attachment s ) .

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The Cheerson CX- 20 and 3 DR Solo UAV are designed for automatic return to home point or hover i n the event of communication control link is lost. When the c ontrol l ink is lost, the Cheerson CX - 20 and 3DR Solo UAV will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the Cheerson CX- 20 or 3DR Solo UAV does not reacquire control link data from the GCS, the UAV will assume that the Control Link is lost and the UAV will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the Cheerson CX - 20 and 3DR So lo UAV are set forth in the Cheerson CX- 20 and 3DR Solo User Manual (see attachment) . A complete description of the operation and specifications of the Cheerson CX - 20 and 3DR Solo GCS and flight control software is also provided in the User Manual s and in the Mission Planner Guide. Considering the size, weight, speed and operation capability, ProSky Studio LLC believes the Chee rson CX- 20 and 3DR Solo UAV do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securi ty. For further technical information concerning the Cheerson CX - 20 and 3DR Solo, see the attached operators manual . **CONCLUSION** ProSky Studio LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Cheerson CX - 20 and 3DR Solo UAV commercially, without an airworthiness certificate, for the li mited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also adva ncing the interests of the public, by allowing ProSky Studio LLC to safely, efficiently, and economically operate the Cheerson CX - 20 and 3DR Solo commercially within the NAS. In accordance with the Federal Aviation Regulations and the FAA Modernization an d Reform Act of 2012, Section 333, ProSky Studio LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 91.103(b), 91.105, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), AND 91.417(a) & (b) to operate the Cheerson CX- 20 and 3DR Solo UAV commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: August 14th, 2015 Respectfully submitted, Michael Arnold , Owner