April	17 ,	2015

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Re:	Petition	of Joe	B.	Doran ( Skycam	Media )	for	an	Exemption	Request	Pursuant	to

Section	333	of the	FAA	Reform	Act	and	Part	11	of the	Federal	Aviation	Regulations from	14	C.P.R.	Part	21,	Subpart	H;	61.113(a) & (b);	91.119(c);	91.121;	91.151(a); 91.405(a);	91.407(a)(l);	91.409(a)(2);	91.417(a) & (b).

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Ac t	of2012	(the	"Reform Act")	and	14	C.P.R.	Part	11, Joe	B.	Doran ( Skycam	Media ), Skycam	Media does	hereby	apply for	an	exemption	from	the	Federal	Aviation	Regulations	("FAR's")	identified	below,	to	allow commercial	use	of	small	unmanned	aerial	systems	("sUA S")	for	the	purpose	of	aerial photography	and	filmmaking	under	certain	conditions	set	forth	in	the Skycam	Media confidential	Flight	Operations	Manual	and identical	conditions set	forth	in	the	FAA

- issued "Exemption	No.	11062",	and	related	exemptions	issued to	operators	for	closed	set	filming. Also,	pursuant	to	14	CPR	§ 11.87,	we	request	that	the	FAA not to delay	action	based	on	the following:

1. This	petition	for	exemption	does	not	set	precedent.	Previous	identical	exemption requests	have	been	approved.

2. Th e	requested	relief	is	identical	to	exemptions	granted	previously,	specifically, Exemption(s)	Nos.	11062	(Astraeus	Aerial),	11066	(Aerial	MOB),	11065	(Helivideo),

and	others.

3. A	delay	in	action	on	this	petition	would	adversely	affect	pending	requests	for	a erial filming	operations	and	result	in	lost	opportunity	and	wages	for	participating	crew, and	a	delay	in	the	public	benefit	of	granting	this	petition.	In	addition,	a	competitive advantage	for	unapproved	commercial	sUAS	operators	exists	and	continues	to	gro w every	day.



### 4. We	are	filing	this	exemption	petition	immediately	following	the	finalized	operations manual	with	respect	to	newly	acquired	sUAS.

Notwithstanding	the	request	not	to	publish	this	petition	request	in	the	Federal	Register, Skycam	Media has	sub mitted	supporting	materials	including	the	confidential	"Flight Operations	Manual"	which	are	confidential	documents	pursuant	to	14	CPR	§	11.35(b)	and are	not	available	to	the	public.

## Pursuant	to	14	CFR	§	11.87:

1. This	application	is	submitted	by : SkyCam Media
16635	Cord illera	Dr. Round	Rock,	TX	78681

2. 14	C.P.R.

- Regulations	for	which	exemption	is	requested: 1) 45.23(b) 2) 61.113(a)	and	(b) 3) 91.119(c) 4) 91.121 5) 91.151(a) 6) 91. 203(a ) and	(b ) 7) 91.405(a) 8) 91.407(a)(1) 9) 91.409(a)(2) 10) 91.417(a)	and	(b)

UASs	operated	by	Sky	Shots	weigh	less	than	55	pounds,	including	all	payload.	The	operate at	speeds	of	less	than	50	knots,	can	hover,	and	can	simultaneously	move	in	multiple directions.	Shy	Shots	will	only	operate	its	UASs	in	line	of	sight	and	will	operate only	within the	sterile	environment	described	in	the	FOPM.	Such	operations	will	insure	that	the	UAS will	not	create	a	hazard	to	users	of	the	NAS	or	public.

Given	the	small	size	of	our	UASs	and	the	restricted	area	that	they	will	be	operated,	Sky

shot’s	UAS operations	adhere	to	the	Reform	Act’s	safety	requirements.

Additionally,	due	to	the	size	of	the	UASs	and	the	limited	area	in	which	they	will	operate, approval	of	this	application	presents	no	national	safety	concerns.	Based	on	the	substantial

level	of	saf ety	surrounding	the	proposed	operations,	and	the	significant	public	benefit (enhanced	safety).	Reduction	in	environmental	impacts	in	the	outdoor	setting	these	UASs will	operate	leaving	no	trace	of	activity	behind,	the	grant	of	the	requested	exemption	is	in the	public	interest.	Accordingly,	Sky	Shots	respectfully	requests	that	the	FAA	grant	the requested	exemption.

3. Aircraft	And	Equivalent	Level	Of	Safety 

### :

The	operating	limitations	proposed	by	Sky	Shots	provide	for	a	higher	level	of	safety	because operations further	enhance	safety	of	movie	and	television	filming	operations	using

conventional	aircraft.

As	set	forth	in	the	FOPM,	the	limitations	and	conditions	include:

• The	UASs	will	weigh	less	than	55	pounds

• Flights	will	be	operated	within	line	o f	sight	of	a pilot	and	observer

• Maximum	flight	time	for	each	flight	will	be	30	minutes	or	at	25%	of	battery	power

reserve whichever	comes	first.• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	as	indicated by

onboard GPS	system.

• Minimum	crew for	each	operation	will	consist	of	the	UAS	pilot,	the	observer	and a camera	operator.

• A	UAS	pilot	will	be	Pilot	in	Command	(PIC).

• A	UAS	pilot	will	be	an	FAA	licensed	airman	with	at	least	a	private	pilot’s	certificate

and	third	class	Medical

• The	UAS	wil l	only	operate	within	a	confined	“steril e	area”	as	defined	in	the	FOPM.

• The	FOPM	requires	the	establishment	of	a	“Security	Perimeter”	for	the	flight operations	area.

• A	briefing	will	be	conducted	for	Planned	UAS	operations	prior	to	each	day’s	flight.

All personnel

• Performing	duties	within	the	boundaries	of	the	safety	perimeter	are	required	to

attend.

• The	operator	will	file	a	FAA	Form	7711

- 1	or	its	equivalent,	as	modified	in	light	of the	requested	exemption,	with	the	appropriate	Fl ight	Standards	District Office.

• The	operator	will	obtain	consent	of	all	persons	involved	in	the	filming	and	ensure that	only	Consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation

.

• The	operator	will	submit	a	written	Plan	of	Activities	to	the	FSDO	three	days	b efore the	proposed shoot	as	required	in	the	FOPM.

• The	Pilot	and	observer	must	be	trained	in	UAS	operations	and	received	current information	on	the	particular	UAS	to	be	operated	as	required	by the	FOPM.

• The	Observer	and	Pilot	will	at	all	times	be	able	to	c ommunicate	by	voice.

• Written	and/or	oral	permission	from	the	relevant	property	holders	will be

obtained.

• All	required	permissions	and	permits	will	be	obtained	from	territorial, state, county,	or	city	Jurisdictions,	including	local	law	enforcement,	fire or other managing governmental	agencies.

• If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	and does	have the	capability	to	return	to	a	pre

- determined	location	within the	Secu rity	Perimeter and	land	safely.

• The	UAS	will	have	the	capa bility	to	abort	a	flight	in	case	of	unpredicted obstacles	or emergencies.

Section 45

. 23(b ): Marking	of	the	Aircraft

The	regulation	requires:

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

ne ar	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.

Even	though	the	UAS	will	have	no	ai rworthiness	certificate,	an	exemption	may	be needed	as	the	UAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	onwhich	the	word	“Experimental”	can	be	placed.	Given	the	size	of	the	sUAV,	two

- inch lettering	will	be	impossible.	The	word	“Experim ental”	will	be	placed	on	the	fuselage in	compliance	with	§45.29	(f).

The	equivalent	level	of	safety	will	be	provided	by	having	the	sUAV	marked	on	its fuselage	as	required	by	§45.29	(f)	where	the	pilot,	observer	and	others	working

with	the	sUAV	will	see	th e	identification	of	the	UAS	as	“Experimental.”	The	FAA	has issued	the	following	exemptions	to	this	regulation	to	Exemptions	Nos.	10700,	8738,

10167	and	10167A.

Section 61.113(a)	and	(b): Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.

Skycam Media is	seeking	relief	from	this	regulation,	as	the	requirement	for	a Commercial	Pilot	License	with	a	second	class	medical	would	be	an	unnecessary burden	on	the	operator	with	regard	to	obtaining	and	certifying	UA	pilots.

The	UAS	will	not	carry	a	pilot	or passengers,	and	the	proposed	operations	can achieve	the	equivalent	level	of	safety	by	requiring	the	pilot	to	possess	a	private pilot's	license	only,	with	a	valid	third	class	medical.	This	level	of knowledge	and	skill combined	with	the	proposed	operating	p rocedures	described	in	the	Flight Operations	Manual	(VLOS	only,	closed

- set	requirements,	etc.)	will	more	than adequately	allow	safe	operation	within	the	national	airspace	system,	and	with regard	to	persons	or	property	on	the	ground.	The	additional	knowledg e	and	skill requirements	for	a	Commercial	Pilot's	license	do	not	add	any	level	of safety	with respect	to	closed

- set	small	UAS	operations	in	the	same	manner	they	do	with	full scale,	passenger

- carrying	aircraft.

An	equivalent	or	greater	level	of	safety	is	achieved	by	requiring	UA	pilots	to	have	a minimum	number	of	hours	logged,	flight	sequences,	knowledge	and	experience testing,	etc.	as	described	in	the	Flight	Operations	Manual.

Section 91.119(c): Minimum	Safe	Al titudes.

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.	As	this	exemption	is	for	a	sUAS	that	is	a	helicopter	and	the	exemption	requests authority	to	operate	at	altitudes	up	to	400	Above	Ground	Level	(AGL,)	or	not	more	than	200 above	an	elevated	platform	from	which	filming is	planned,	an	exemption	may	be	needed	to allow	such	operations.	As	set	forth	herein,	except	for	the	limited	conditions	stated	in	the General	Operating	Manual,	the	UAS	will	never	operate	at	higher	than	400	AGL.	It	will however	be	operated	in	a	restricted area	with	security	perimeter,	where	buildings	and people	will	not	be	exposed	to	operations	without	their	pre

- obtained	notification	and	consent when	required.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and	speed	of	the	UAS	as

w ell	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	participants	in	the	filming	activity,	all	affected	individuals	will	b e	aware	of	the	planned flight	operations	as	set	forth	in	the	GOM.	Compared	to	flight	operations	with	aircraft	or rotorcraft	weighing	far	more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	of flammable	fuel,	any	risk	associated	with	these	operations is	far	less	than	those	presentlypresented	with	conventional	aircraft	operating	at	or	below	500	AGL	in	the	movie	industry.	In addition,	the	low

- altitude	operations	of	the	sUAS	will	ensure	separation	between	these

small

- UAS	operations	and	the	operations	of conventional	aircraft	that	must	comply	with

Section	91.119.

Section 91.121 :	Altimeter	Settings

Skycam	Media is	seeking	relief	from	this	regulation,	as	the	UA	will	not	have	a

barometric	altimeter.

Section	91.121	requires	each	person	operating	an	aircraf t	to	maintain	cruising altitude	by	reference	to	an	altimeter	that	is	set	“...	to	an	elevation	of	the	departure airport	or	an	appropriate	altimeter	setting	available	before	departure.”	As	a	UAS may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitude data,	an	exemption is	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to the	FOPM	and	Safety	Check	list,	confirming	the	altitude	of	the	launch	site	shown	on the	GPS	altitude	indicator	before	flight.

Section 91.151(a): Fuel	Requirements	for	Flight	in	VFR	Conditions

Skycam	Media is	seeking	relief from	the	fuel	requirements	of this	FAR	as	current battery	technology	allows	the	UA	to	fly	for	approximately	15

- 30	minutes	in	normal conditions.	As	91.151(a)	requires	a	30

- minut e	reserve	AFTER	reaching	the	point	of intended	landing,	there	is	no	practical	flight	possible	under	this	regulation.

A n	equivalent	or	greater	level	o	f	safety	exists	as	the	exact	battery	level	remaining	is transmitted	to	the	pilot	via	radio	telemetry,	and given	that	the	operating	area	for	the UA	is	in	close	proximity	to	the	pilot	(VLOS),	an	unsafe	condition	where	the	UA	is unable	to	return	for	landing	due	to	low	battery	condition	is	easily	avoidable. Additionally,	should	a	defective	battery	prematurely	dep lete,	the	UA	is	configured	to

auto land	above	the	point	at	which	the	flight	controller	detects	low	voltage.	And,	as part	of	the Skycam	Media Operations	Manual,	it	is	a	requirement	that	any	flight	be terminated	if	telemetry	is	lost.	Otherwise,	a	flight	limi t	of	30	minutes	or	25%	battery remaining	is	prescribed.

Section	91. 203 (a) and	(b ): Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	provides	in	pertinent	part:



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

## b) An	appropriate	and	current	airworthiness	certificate.	.	. 

## c) No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate required	b y	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	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an

on board	pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification	and registration	documents	or	to	display	them	on	the	sUAS.	Each	sUAS	operated	by	FlyHabana	will	be	registered	with	the	FAA	and	all	documentation	carried	by	the	PIC.

An	equivalent	l evel	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,	to	the	extent	they	are	applicable	to	the	sUAS.	The	FAA	has	issued	numerous exemptions	to	this	regulat ion.	A	representative	sample	of	other	exceptions	includes Exemption	Nos.	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

Section 91.405(a),	91.407(a)(1),	91.409(a)(2);	91.417(a)	and	(b): Maintenance	Inspections

Skycam	Media is	seeking	relied	from the	above	stated	FAR's	as	the	UA	will	not	have an	airworthiness	certificate.	Therefore	there	is	no	requirement	to	perform	an inspection	in	order	to	maintain	airworthiness	as	stated	in	Appendix	D	to	Part	43	for 1OOhr.	and	annual	inspections.

An	equivalent or	greater	level	of	safety	exists	as	the Skycam	Media Flight	Operations Manual	does	prescribe	regular	maintenance	and	inspections,	compliance	with manufacturer's	service	bulletins,	test	flights	after	maintenance,	technician	training, and	so	forth,	in	the spirit	of	the	scope	and	detail	of	Appendix	D	to	Part	43.	In addition,	while	mechanical	failures	are	not	out	of the	question,	a	crash	resulting from	a	catastrophic	failure	has	a	very	small	amount	of risk	of injury	when	compared to	a	failure	in	a	passenger	c arrying	full	size	aircraft,	for	which	this	regulation	was

intended.

4. Public	Interest:

Skycam	Media believes	that	allowing	commercial	use	of	small

- unmanned	aircraft will	enhance	the	safety	of	filming	operations	by	reducing	the	risk	associated	with

low	al titude	full	size	aircraft	operations.	A	manned,	turbine	powered	helicopter operating	in	close	proximity	to	production	personnel	and	actors	on	the	ground	has	a far	greater	risk	o	f	i nj ury	than	a	small,	lightweight	U	A	carrying	no	combustible	fuel, especiall y	when	the	UA	is	operating	within	the	parameters	of	the Skycam	Media Flight	Operations	Manual.		Additionally,	the	safe	integration	of	sUAS	within	the national	airspace	is	a	growing concerns amongst	pilots,	the	FAA,	and	general	public. This	exemption	would provide	a	safe	stepping

- stone	to	a	more	robust	set	of	future

sUAS	rules.

5. Level	of	Safety:

As	outlined	in	each	of the	FAR's	above	for	which	relief	is	sought	(underlined).

6. Summary:		Flying	Cross	Aerial	Production	seeks	exemption	from	the	following	rules for	the	commercial	operation	of	a	small	unmanned	aerial	system	in	order	to	conduct filming	and	photography	operations	below	an	altitude	of	400'	AGL	and	within	a limited	opera ting	area:	14	C.P.R.	Part	21,	Subpart	H;	61.113(a) & (b);	91.119(c); 91.121;	91.151(a);	91.405(a);	91.407(a)(l);	91.409(a)(2);	91.417(a) & (b).		This exemption	will	enhance	the	level	of	safety	currently	able	to	be	obtained	using	full sized	manned	helicopte rs	for	the	same	type	of	work.

7. Privacy :All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	who	have	also consented	to	being	filmed	or	otherwise	have	agreed	t o	be	in	the	area	where	filming 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	sig ht	and	national	security

– provide	more	than adequate	justification	for	the	grant	of	the	requested	exemptions	allowing commercial	operation	of	applicant’s	UAS	in	the	motion	picture	and	television industry	pursuant	to	the	Manual	appended	here to.

8. Additiona l	Information:

T he	applicant, Joe	Doran ,	is	a	safety	conscious	member	of AMA	(Academy	of	Model

Aeronautics

. He	has	been	flying	single	rotor	RC	aircrafts	for	over	10	yeas,	and	he	has professional	competed	in	acrobatics	RC	helicopter	for	over	eight	years.	Joe	Doran	is also	very	active	in	the	AMA	community,	including	being	the	President	of	a sanctioned	club,	and	h e	has	putting	together	really	large	RC	helicopter	events,	with safety	as	the	number	one	factor.	The	RC	helicopters	that	are	flown	usually	have	a rotor	span	of	over	six	feet	in	diameter.	Joe	Doran	has	been	doing	areal	photography and	cinematography	for	over four	years	now	with	small,	unmanned	aircraft	and lightweight	UASs	capturing	high	definition	featured	films.

If	you	have	any	questions	or	need	any	additional	information,	please	contact	the	undersigned	at

512

- 368

- 4102 or	at joe@skycammedia.com

Thank	you

,

Joe	B.	Doran Founder	/	Owner SkyCam	Media