1 SkyFire Services LLC 2015

July 4, 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

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”), 

SkyFire Services, LLC (the “Applicant”), planned operator of a Small Unmanned Aircraft 

Systems (“sUAS”) seeks an exemption from Federal Aviation Regulations (“FARs”) listed 

below and discussed in Appendix A. Attached, as Appendix C, is a summary of this request.

The requested exemption would allow the Applicant to safely, efficiently, and economically use 

commercial sUAS in the National Airspace System (NAS), 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.

This exemption would permit commercial operation by the applicant, which uses all versions of 

aircraft to include:

Ritewing Spade Z3 47” Fixed Wing, Ritewing Drak 60” Fixed Wing, and H4-680 Quadcopter. 

The FAA has already granted Part 333 exemptions to other companies seeking to utilize these 

same Ritewing aircraft (Terraplane LLC - Exemption No. 11732 Regulatory Docket No. FAA–

2015–0007 ), and the H4-680 quadcopter is substantially similar to many other Part 333 

exemptions issued for operations of similar quadcopters (DJI Phantom 2, DJI Inspire, DJI S1000, 

3DRobotics Iris, etc. - exemptions: 11677, 11597, 11692 ).

As described more fully below, the requested exemption would authorize the Applicant to 

perform commercial operations with sUAS that will provide the following benefits:

1. Commercial use of sUAS to perform aerial data acquisition and research in support of 

government entities, agriculture industry, utility companies, local infrastructure, scientific 

studies, wildlife monitoring, mining, surveying, forestry, sSUAS flight training, and 

much more. All of which are critical to the well-being of the general public..

2. The use of sUAS will decrease congestion in the NAS along with reducing the noise and 

air pollution generated during traditional manned aircraft flight operations.
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3. When using sUAS to complement field personnel, they reduce safety concerns when 

gathering data from inaccessible or unstable/unsafe areas and in extreme weather or 

terrain.

4. Operation of sUAS will substantially reduce the risk to life and property in the air, and on 

the ground, which is commonly associated with traditional manned aircraft flight 

operations.

5. Similar to the current manned aircraft flight operations that have been conducted for 

many decades, sUAS used for similar tasks will not generate any new privacy issues.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the 

Reform Act to "establish requirements for the safe operation of such aircraft systems in 

the national airspace system."

The name and address of the applicant are:

SkyFire Services, LLC

Attn: M. Fontenot

Address: 2255 Quail Drive

Lakewood, Colorado, 80215

Ph: 303-731-6645

Email: mikef@skyfire-usa.com

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to 

the proposal set forth in this letter are appropriate, provide an equivalent level of safety, 

and are in the public interest.
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QUALIFICATION FOR APPROVAL UNDER SECTION 333 

OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other potentially 

relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive sUAS

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) 

controlled as to access, and; (4) would provide an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

The sUAS's planned to be operated are rotorcraft and fixed wing aircraft, each weighing

typically less than 15 lbs., and always less than 55 lbs., including payload. They would 

operate under normal conditions, at a speed of no more than 65 knots. The principal 

construction material of the sUAS aircraft would typically be foam and/or plastic. 

Operations will be performed by a qualified sUAS Pilot in Command (PIC), as outlined 

below, to insure that the sUAS will "not create a hazard to users of the national airspace 

system or the public." Given the small size of the sUAS involved and the pre-planned 

environment within which they will operate, the applicant believes that these operations 

fall squarely within that 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 size of the sUAS and the pre-defined, restricted 

area in which the sUAS will operate, approval of the application presents no national 

security issue. The operation of sUAS by knowledgeable professionals will serve to 

enhance safety, add to the public benefit, and reduce environmental impacts related to 

current methods of manned aircraft flight operations.

These limitations and conditions to which the operator, or its employees, acting as sUAS

PIC agrees to be bound when conducting commercial operations under an FAA issued 

exemption:

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The sUAS pilot will be considered Pilot in Command (PIC), whether flying or

supervising, and will be responsible for safe operation of the flight.

3. Flights will be operated within line of sight of the PIC and/or an observer, which will 

be at a distance of less than one (1) mile.

4. The sUAS will weigh typically less than 15 lbs., and always less than 55 lbs.

5. The sUAS will operate at a maximum speed of no greater than 65 knots.
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6. Flights will be operated in Class G airspace whenever possible. If operation in other

airspace is required, the relevant controlling agency will be notified at least 24 hours

prior to the operation and, if required, any necessary permission obtained.

7. Aircraft shall not be operated within 3 miles of an airport without prior approval of, 

and establishing a line of communication for the duration of the flight operation with, the

controlling authority of that airport.

8. Aircraft shall avoid areas where manned aircraft can be expected to be descending

through 400ft.

9. Aircraft shall maintain a minimum horizontal separation of no less than one (1) mile

from all other manned or unmanned airborne aircraft unless that other aircraft is

maintaining level flight or climbing at an altitude above 8000ft AGL.

10. If at any time the operator see or hears another aircraft and it appears that aircraft

may come within one (1) mile of the operator’s system, or it is questionable whether

or not it will do so, the operator shall immediately descend the system to 100 ft. AGL

or less and direct the system on a heading toward it’s designated landing area, or

alternate landing area if necessary, until the system has landed or it is determined the

other aircraft has maintained a separation of one (1) mile.

11. Flights will be operated under visibility and cloud clearance requirements equivalent

to Visual Flight Rules (VFR).

12. The sUAS will at all times give way to any and all aircraft carrying persons.

13. Minimum crew for each operation will consist of the sUAS PIC. An observer will be

utilized if the Risk Assessment, as detailed in Section 5.5 of the General Operations

Manual, determines the need. The observer and PIC will at all times be able to

communicate by voice.

14. Prior to a sUAS flight, an area of operation will be established. This area of operation

will include a defined lateral and vertical area, where the sUAS will operate. Safety

procedures will be established for persons, property and applicable airspace within

the area of operation.

15. The sUAS shall operate from on-site takoff/landing locations directly next to the PIC

and/or Observer.

16. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the sUAS or appropriate timing.

17. The sUAS will be equipped with an autopilot system which will be equivalent to, or

better than, a Pixhawk, Mikrokopter, WooKong, Sensefly, or Gatewing system. For
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example, the sUAS will utilize GPS navigation, failsafe’s, lost link/return-to-home 

(RTH), and flight abort safety features, among other built-in safety features.

18. A Ground Station will be connected, by radio communication, to the sUAS during the

entire flight, which will give the PIC flight information such as GPS Position, Altitude,

Battery Remaining, and other telemetry information.

19. A briefing will be conducted in regard to the planned sUAS operations prior to

operation at each new location. All personnel who will be performing duties within the

boundaries of the area of operation will be present for this briefing.

20. All required permissions and permits will be obtained from appropriate state, county

or city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

21. Written, to include electronic, and/or oral permission from the relevant property

owners will be obtained prior to an operation.

22. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be

operated. This will include operation of the sUAS both in normal and emergency

modes of operation, and will include familiarization with the operation manual (or

similar) if published by the sUAS manufacturer. Training will also include types of

maneuvers to be performed and the safe operation in relation to persons, property

and applicable airspace. It is the applicant's belief that the size, weight, speed, operating 

environment, and operating capabilities provide an "equivalent level of safety" or better 

when operating a sUAS for the public interest as outlined in Section 333 of the Reform 

Act. It is requested that the FAA issue an exemption to permit safe, legal, commercial 

sUAS operation by the applicant as soon as possible.

Respectfully submitted,

SkyFire Services, LLC

Attn: M. Fontenot

Address: 2255 Quail Drive

Lakewood, Colorado, 80215

Ph: 303-731-6645

Email: mikef@skyfire-usa.com
6 SkyFire Services LLC 2015

Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

The applicant requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of sUAS’s:

14 CFR Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 

21, 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 of the aircraft (typically less than 15 lbs., and always less 

than 55 lbs.) and the limited operating area associated with its utilization, it is 

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart 

H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act 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 sUAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness 

certificate. The sUAS weighs typically less than 15 lbs., and always less than 55 lbs. fully 

loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will 

operate exclusively within an area pre-disclosed and in compliance with conditions set 

forth herein. Operations under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the conditions set forth above, and by local public safety 

requirements. The FAA will have advance notice of all operations through the filing of 

NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the 

lack of flammable fuel, and the fact that the aircraft is carried to the location and not 

flown there all establish the equivalent level of safety. The sUAS provides at least an 

equivalent, and most likely exceeds, level of safety to that of such operations being 

conducted with conventional aircraft that would be orders-of-magnitude larger and would 

be carrying passengers, cargo, and flammable fuel.

14 CFR. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(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.
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(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.

Regulation 91.9(c) provides:

No person may operate a U.S.-registered civil aircraft unless that aircraft is

identified in accordance with part 45 of this chapter.

The sUAS has no entrance to the cabin, cockpit, or pilot station on which the markings 

can be placed. Given the size of the sUAS, two-inch lettering will be impossible. Official 

marking systems for sUAS have not yet been established for operations inside the NAS. 

The applicant is prepared to mark the sUAS with the name of the organization and 

location or origin and fulfill any other request by the FAA to this topic in accordance to § 

45.29(f) where the pilot, observer, and others working with the sUAS will see the 

identification of the sUAS.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 

8738, 10167, 10167A and 10700.

14 CFR § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot 

in Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the sUAS in this case is 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot’s license to be pilot in command of an 

aircraft for compensation or hire. The applicant respectfully proposes that operator 

requirements should take into account the characteristics of the particular sUAS. Most 

sUAS autopilot’s have a high degree of pre-programmed control and various built-in 

technical capabilities that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application. Hands-on experience with the sUAS are 

a far more effective guarantee of flight safety than a commercial pilot certificate would 

be, until the FAA Pilot Certificate requirements catch up to the sUAS technology.

The sUAS autopilots have an all-digital software platform with advanced features 

previously restricted to full size unmanned aircraft. Automated features and advanced flysafe controls enable safe, reliable operation, as well as advanced networking capabilities 

and system extensibility.

● The system can autonomously fly a programmed flight path or fly in manual mode

● Flight time and battery minutes are displayed at all times. The system will return

home and land automatically if user-configurable limits are reached.
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Flight safety is a priority, no matter the operating environment or project. sUAS offer

superior safety over manned aircraft by removing the need for people to be onboard in

potentially dangerous situations. With multiple built-in safety features, sUAS platforms 

lead manned operations with respect to safety.

● The sUAS automatically detects potential issues - with configurable automated

response behavior such as a return-to-home-and-land routine

● The sUAS self-calibrate all of their sensors and perform required failsafe pre-flight 

tests prior to takeoff to check for errors

● The sUAS have the ability to set up visual no-fly zones or create a virtual fence so the 

sUAS can’t fly horizontally or vertically beyond the pre-planned flight area

● The sUAS have battery minutes and flight time displayed at all times. The system will

return home and land automatically if user-configurable limits are reached

● The sUAS auto detect a lost GPS, warns the pilot and initiates an immediate landing.

● Low battery on the sUAS triggers a Non- Fatal Warning alarm to return home, land

and replace the battery

● If sUAS detect a lost-link to the Ground Station the vehicle will perform its pre-defined

Non-Fatal Condition Response.

Given these safety features, the applicant proposes that operators of sUAS with these

features should not be required to hold a commercial or private pilot certification. 

Instead, operators should be required to:

● have successfully completed, at a minimum, FAA Sport Pilot ground instruction and

passed the FAA Sport Pilot written examination or FAA-recognized equivalents

including ICAO issued commercial, private license and ground school; operators will

therefore receive instruction in aeronautical navigation, meteorology, and aviation

regulations prior to conducting commercial sUAS operations.

● have completed a training program for operation of the sUAS, if available.

● have completed 10 hours (35 flights) of training on the sUAS and/or simulator before

commencing commercial operations.

The applicant notes that the FAA has found that safety factors permitted operation of 

SUASs by operators with these qualifications in the case of operations pursuant to public 

COAs where the mandatory operating conditions specified above are present. See 

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(sUAS) Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory 

authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial 

operations.

The applicant notes that the FAA has required at least an FAA Sport Pilot’s certificate on 

prior Section 333 exemptions due to the statutory requirement to hold an airman 

certificate as prescribed in 49 U.S.C.§44711. The applicant feels that a passing a Sport 

Pilot knowledge examination provides the sUAS PIC with the required aeronautical 

knowledge to safely operate the sUAS under the conditions listed above. The FAA and 
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the applicant both agree that hours in a manned aircraft add no benefit to the safe 

operation of a sUAS.

The applicant notes that the FAA has mentioned that a pilot certificate subjects the pilot 

to a security screening by the Department of Homeland Security. To satisfy this 

requirement, while not obtaining a pilot certificate, the applicant will require all sUAS

pilots to undergo an equivalent or better security screening by the Department of 

Homeland Security at the pilot’s expense, equivalent to having a TSA background check 

and Known Traveler Number issues. In fact if the sUAS PIC already has a TSA Known 

Traveler Number the applicant submits that the FAA security screen requirement has 

been met.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the sUAS without a private pilot’s certificate or a commercial 

pilot’s certificate, under the conditions set forth herein. The risks associated with the 

operation of the sUAS (given its size, speed, operational capabilities, and lack of 

combustible fuel) are so diminished from the level of risk associated with private pilot 

operations or commercial operations contemplated by Part 61 with conventional aircraft 

(fixed wing or rotorcraft), that allowing operations of the sUAS as set forth above meets 

or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and 

does not rise to the level of requiring a commercial pilot to operate the aircraft under § 

61.133(a).

14 CFR § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of 

sUAS without an airworthiness certificate, no standard will exist for airworthiness of the 

sUAS. 

Given the size of the sUAS and the previous COAs issued for similar sUAS, an 

equivalent level of safety will be achieved by ensuring compliance with the given sUAS

manuals and use of safety checklists prior to each flight.

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of

this chapter, unless there is available in the aircraft a current approved airplane

or Rotorcraft Flight Manual, approved manual material, markings, and

placards, or any combination thereof.

Given the size of sUAS, they have 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.
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The equivalent level of safety will be achieved 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 to others the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. 

An equivalent level of safety will be provided by following a comprehensive preflight 

checklist. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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.

The sUAS are remotely piloted aircraft and by design, do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The flight plan is either 

manually controlled through point-and-click navigation or preprogrammed as way points 

into the auto pilot before or during flight and only in unusual circumstances will the pilot 

input control functions to alter the pre-programmed flight. 

Given the size and speed of the sUAS, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the sUAS, and 

all persons will be a safe distance away should the sUAS experience any difficulties 

during flight instruction. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K & 9862A.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to 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.

Because aerial survey, mapping and inspection work must be accomplished at relatively low

altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is

needed. The equivalent level of safety will be achieved given the size, weight, speed, and 

material with which sUAS are built. 
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Also, no flight will be taken without the permission of the land owner or those who control the 

land. Because of the advance notice to the landowner, all affected individuals will be aware of 

the flights. 

Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more 

than 55 lbs. and carrying flammable fuel, any risk associated with these operations will be far 

less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. 

Indeed, the low-altitude operations of the sUAS will maintain separation between these sUAS

operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR § 91.121: Altimeter Settings

Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level

by reference to an altimeter that is set to the elevation of the departure airport or barometric

pressure. 

Some sUAS have a barometric pressure sensor, while others only use GPS for elevation or 

altitude. When a barometric pressure sensor is on the sUAS, it is typically “zeroed” at the point 

of take-off; this is right next to the PIC and not at a departure airport. The altitude reading will be 

relative to that point (on the ground) and not a known elevation. The equivalent level of safety 

will be achieved by the PIC confirming the elevation or altitude of the launch site. The altitude of 

the sUAS will also be displayed via telemetry on the Ground Station and will be constantly 

monitored by the PIC during the entire flight operation.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The different sUAS batteries provide a variety of powered flight times. An exemption from § 14

CFR 91.151 is therefore required. The applicant believes that an exemption from 14 CFR § 

91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing 

Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the 

sUAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 

91.151(a) was meant to prevent given the size and speed at which the sUAS operates. The fact 

that it carries no pilot, passenger, or cargo also enhances its safety. 

In the unlikely event that the sUAS should run out of fuel, it would simply land. Given its weight 

and construction material, the risks are less than contemplated by the current regulation. The 

applicant believes that an equivalent level of safety can be achieved by maintaining 20% of

reserve fuel (or battery), which would be more than adequate to return the sUAS to its planned

landing zone from anywhere in its operating area. The FAA has granted similar exemptions to 

others, including Exemptions 2689F, 5745, 10673 and 10808.
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14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current 

airworthiness certificate.

(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 sUAS fully loaded weigh typically less than 15 lbs., and always less than 55 lbs. As such,

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

on the sUAS. In addition, there is no pilot on board the aircraft.

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

control point where the pilot flying the sUAS will have immediate access to them. 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 CFR § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires 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 ...” 

Section 91.407 similarly makes reference to requirements in Part 43. 

Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness

certificate. Section 91.417(a) requires the owner or operator to keep records showing certain

maintenance work that has been accomplished by certificated mechanics, under Part 43, or

licensed pilots and records of approval of the aircraft for return to service.

The sUAS are nearly maintenance free, they perform automatic pre-flight checks and the failure

of any check will prevent take-off. Checks which cannot be done by the system will be

performed by a qualified person prior to each flight and at predefined intervals as part of a

maintenance schedule.

Pre-flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no

external payload, will operate only in restricted predetermined areas and is not a complex

mechanical devise. The operator of aSUAS will ensure that it is in working order prior to

initiating flight, perform required maintenance, and keep a log of any maintenance that is
13 SkyFire Services LLC 2015

performed. Moreover, the operator is the person most familiar with the aircraft and is best

suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of

safety. If mechanical issues arise, the sUAS can land immediately due to the pre-determined area 

of operation. Moreover, the sUAS's small size, carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time, create less risk than 

the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the 

same operation.

APPENDIX C

SUMMARY OF SECTION 333 EXEMPTION REQUEST

SkyFire Services, LLC hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of sUAS for aerial data acquisition and research in 

support of government entities, agriculture industry, utility companies, local infrastructure, 

scientific studies, wildlife monitoring, mining, surveying, forestry, flight training, and much 

more. All of which are critical to the well-being of the general public. An exemption is requested 

from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).