## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

**FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF TITLE	14	OF	THE	CODE	OF	FEDERAL	REGULATIONS**  **SECTIONS 61.113(a)**  **, 61.23	(a)	&	(c),**  **91.7(a), 91.119	(c),**  **91.121,**

**91.151 (a)(1)	&**  **(b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	AND	91.417(a)	&	(b)**  **CONCERNING	COMMERCIAL OPERATION	OF	DJI**  **INSPIRE	1 UNMANNED	AIRCRAFT**  **SYSTEM**

**PURSUANT	TO	SECTION	333	OF THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012** 

**(PUBLIC	LAW	112 -**  **95)**

Contact Information: John D. Henley II UCay, Inc. DBA: Skyhawk Videos & Photography 12520 W estheimer Rd. , #A1 - 228 Houston, TX, 77077 - 5861 Tel: (832)894 - 9176 Email: skyhawkvideos@gmail.com June 10 , 2015Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 1

Tele: (281)849 -4060

; Email: skyhawkvideos@gmail.com **INTRODUCTION & OPERA** **TION OF BUSINESS** I, John D. Henley

II , am requesting in pursuant to Section 333 of FAA Modernization and Reform Act of 2012 an exemption from the requirements of 14 C.F.R §§ 61.113(a), 61.23	(a)	& (c),	91.7(a),	91.119	(c),	91.121,	91.151(a)(1)	& (b),	91.405(a),	91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) &	(b) . As a small bus iness owner of **UCay, Inc.**  with a **DBA: Skyhawk**  **Video &**  **P hotography**  , this ex emption will allow me to provide quality and cost efficient services to my

c lients by

providing aerial photography using an Unmanned Aircraft S ystem for commercial and residential purposes. The video and photography scope of my

business covers:  re al estate  construction  special events  film production  urban development  e ducation **Equipment** Sky hawk Video & Photography i s requesting an exemption to operate a DJI Inspire 1 as a sales tool for compensation & hire to be used within the National Airspace System. The DJI Inspire 1, Model T600 is a vertical takeoff and landing Unmanned Aircraft System with a Ground Control Station utilizing electronic tablet or smart phone systems. The DJI Inspire 1 is a brand new quadcopter ca

pable of capturing 4K video and transmitting an HD video signal (up to 2km) to multiple devices straight out of the box. Equipped with retractable landing gear, it can capture an unobstructed 360 degree view from its camera. The built- in camera has an inte grated gimbal to maximize stability

and weight efficiency

while minimizing space. When no GPS signal is available, Vision Positioning technology provides hovering precision. The DJI Inspire 1 has the following specifications:  maximum gross weight 2 935 gram s  dimensions

– 438x451x301 mm  maximum ascent speed

– 5 m/s  max descent speed

– 4 m/sSkyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 2

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; Email: skyhawkvideos@gmail.com  max speed

– 22 m/s (ATTI , no wind)  max flight altitude

– 4500 m  max flight time

– approx 18 minutes  velocity

range – below 8 m/s (2m above ground)  altitude range - 5 - 500 cm **Remote Controller** Specification for the radio control equipment:

 Operating frequency 5.725 - 5.825GHz & 2.400 - 2.483GHz  Transmitting Distance 2 km  EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G  Battery 6000 mAh LiPo 25 The DJ I Inspire 1 is also equipped with four main rotors , motor model DJI 3510 ; driven by Lithium Poly

mer high voltage battery ; remote controller and a 12.76 m/p video camera.

**OPERATION OF EQUIPMENT** Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary that it is to be allow that a Pilot in Command (PIC) holding a private pilot will be in command of this UAS, and who has demonstrated, by

meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJ I Inspire 1 in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **AIRCRAFT WORTHNESS** Sky hawk Video & Photography request exemption from Section 91.7(a), entitled Civil aircraft airworthiness , because in accordance with 14 C.F.R. Part 21, S ubpart H the DJIInspire 1 does not require to have airworthiness certification. (Section 91.7). In so saying Sky hawk Video & Photography do undertake that it will ensure that the UAS be maintained in an airworthySkyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 3

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; Email: skyhawkvideos@gmail.com condition, prior to every flight, by deter mining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and the DJI Inspire 1 In struction Manual), and that the aircraft are in a condition for safe flight. (Section 91.9).

**SPEED, WEIGHT, SIZE AND LIMITED OPER ATING AREA**  With relevance to the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, the DJI Inspire 1 meets the conditions of FAAMRC Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, we hereb y request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. **Exemption of Section 91.121** Sky hawk Video & Photograp y hereb y request exemption from the requirement of Section 91.121, entitled Altimeter Settings for the DJI Inspire 1 do not have a typical barometric altimeter on board the equipment. **Exemption of Section 91.151** Sky hawk Video & Photograp y hereb y request exemption from the requirement of Section 91.121, entitled Fuel Requirements for Flight in VFR Conditions for the DJIInspire 1 do not have a typical barometric altimeter on board the equipment. **In accordance**  **w ith**  **14 C.F.R.**  **Section 11.81**  **, I**  **hereby provide**  **the following**  **information in**  **support of this petition for exemption: Name and address of the Petition:**  John D. Henley

II UCay, Inc. DBA: Sky

hawk Video & Photography 12520 Westheimer Rd. A- 1 #228 Houston, TX 77077 - 5861 Tel: (281)849 - 4060Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 4

Tele: (281)849 -4060

; Email: skyhawkvideos@gmail.com

**UNMANNED AIRCRAFT PIC** In addition to holding a private pilot licence certification and FAR61.31F endorsement since 1997 I,John D. Henley II have extensive experience in flying a UAS on a recreational basis since 2013 and during this time I have exercise safety protocols and controls of the aircraft in order to prevent hazard or catastrophe to the general public while being in compliance with the regulations of the FAA and the National Airspace System. As record keeping for sharing with the FAA the DJ I Inspire 1 maintain an internal recording system . This next generation flight controller system provides a more reliable flight experience. A new flight recorder stores the flight data from each flight , and Vision Positioning enhances hovering precision when no GPS is available. **PROPOSED OPERATION OF EQUIPMENT** It is the intention of Sky hawk Videos & Photography to utilize this UAS for the purpose of recreational use and for the following commercial & residential use for compensation and hire as it is approved under the regulation of these exemption requirements of the FAA. This business will be conducted mainly in the State of Texas . These areas of flight are as follows: (a) Video filming by

air and photographing for public and private purposes, including: television, cinematography, advertising or promotions. Filming and Photography will only be conducted with permission and under contract with registered owners or with any l ocal government authority and only when safe to do so. (b) Video filming by

air and photographing to support professional operations in engineering, land surveyingand development, architecture, real estate and other related professional activities. Filming and Photography will only b e conducted with permission and under contract with registered owners or with any local government authority and only when safe to do so.Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 5

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; Email: skyhawkvideos@gmail.com (c) In spection by

air of infrastructure such as bridges, highways, photovoltaic power stations, and pipelines. These inspections will only b e done under contract and permission with any

registered owners or with any l ocal government authority and only when safe to do so. (d) Inspection by

air of land and residential, commercial and industrial structures, only under contract and permission with any registered owners or with any l ocal government authority and only when safe to do so. (e) Support provided to search and rescue operations and reconnaissance in cases of need, emergency

or natural disasters only when government authorities have requested it b y contract or donation and only when safe to do so. **(f)** In formation and technical support for educational purpose. **PUBLIC BENEFIT**  The DJ I In spire 1 are battery p owered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce the amount of manned aircraf t in the NAS, reduce noise and air pollution, as well as increase the safety

of life and property

in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **Operational Restriction** DJIInspire 1 Operational Manual and the Safety Guidelines (See attached DJI Inspire 1 Operational Manual and Safety Guidelines) contain all of the safety and operational proceduresSkyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 6

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; Email: skyhawkvideos@gmail.com and limitations deem necessary to responsibly perform the operations speci fied in this Petition for Exemption. **Relevant Statutory Authority** This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely acce lerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air Space ("NAS") where it is s afe to do so based on the following considerations:  The UAS’s size, weight, speed and operational capability;  Operation of the UAS in close proximity to airports and populated areas; and  Operation of the UAS within the visual line of sight of the operator. Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority o f the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702 - 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). These proposed UAS operations meet the Requirements of Section 333 of the Reform Act The proposed operations in this Petition for Ex emption qualify f or expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied . Approval is also warranted b ased on the UAS Size, Weight, Speed, and Operational Capability . Additionally, approval is warranted based on the 0perational restrictions as it is s et forth in the operations manual.Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 7

Tele: (281)849 -4060

; Email: skyhawkvideos@gmail.com **To Be Publish in the Federal Register SUMMARY OF EXEMPTION OF 14 C.F.R**  **1 .**  **Skyhawk Video & Photography seeks exemption from the requirements of** § **61.113 (a).**  **Private pilot privileges and limitations: Pilot in command.** Pursuant to 14 C.F.R. 61.113 I , John Henley II do hold a valid Private Pilot license and that I will be the Pilot in command for the operation of the DJIInspire 1. A s Pilot in Command I hereb y agree to safely operate the DJ I Inspire 1 in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **2 .**  **Skyhawk Video**  **& Photography**  **seeks exemption**  **from the**  **requirements of**  § **61.23 (a)**  **& (c). Medical certificates: Requirement and duration**  **.** The medical requirements based on Medical Certificate requirements outlined in the FARs (14 CFR 61.23). Given the size and weight of 6.47 pounds, the DJI Inspire 1 , its structure, the limited flight area, and the safety f eatures integrated in the autopilot (among others the Flight Termination System), we believes that an Equivalent Level of Safety can be reached if the PIC has a valid driver’s license. **3 .**  **Skyhawk Video**  **& Photography**  **seeks exemption**  **from the**  **requirements of**  **§ 91.7**  **(a) Civil aircraft**  **airworthiness.** Pursuant to 14 C.F.R. §91.7 (a) I, John Henley II hereb y agree to ensure that the DJI Inspire 1 used by Sky hawk Video Photography will be maintain in an airworthy condition prior to any and all flight of the equipment. **4 .**  **Skyhawk Video & Photography seeks exemption from the requirements of**  **§ 91.**  **9 (b)(2)**  **Civil aircraft flight manual, marking, and placard requirements.** Pursuant to 14 C.F.R. §91.9 the DJ I Inspire 1 as a UAS will be operated and maintained in accordance with the instruction operational manual of the equipment. The equipment will be marked with the identification of ownership as being Skyhawk Video and Photography.Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 8

Tele: (281)849 -4060

; Email: skyhawkvideos@gmail.com **5 .**  **Skyhawk Video**  **& Photography**  **seeks exemption**  **from the**  **requirements of**  **§ 91.119**  **(c) Minimum safe altitudes: Ge**  **neral.** Pursuant to maintaining safe altitudes I, John Henley II, hereb y attest that in adhering to the FAA regulations the DJ I Inspire 1 being operated by S ky hawk Videos and Photography, will not be operated at an excess legal height of 400 feet. **6 .**  **Skyhawk Video**  **& Photography**  **seeks exemption**  **from the**  **requirements of**  § **91.121 Altimeter settings.**  Pursuant to the Altimeter settings of the DJI Inspire 1, the equivalent level of safety as established in this section wil l be adhered to by this exemption. In monitoring the altitude information this will be generated by the GPS equipment installed onboard the aircraft. Exemption is being requested based on the requirements and specification of the DJI Inspire 1. **7 .**  **Sky h**  **awk Video & Photography seeks exemp**  **tion from the**  **requirements of**  **§ 91.151 (a)**  **(1) & (b) Fuel requirements for flight in VFR conditions.**  Further to the power operation of the DJIInspire 1 , fuel is not required for flying the UAS , instead a 6000 mAh LiPo 25 battery i s used for the operation of the UAS. Therefore, I John Henley II will hereb y ensure that prior to the commencement of each flight there will be sufficient battery

p ower for the intended flight time with a minimum of 3 minutes remaining. Additionally, each battery have an estimated flight time of approximately 1 8 minutes flight time which allow each of my flights to be for approximately 15 minutes. **8 .**  **Skyhawk Video**  **& Photography**  **seeks exemption**  **from the**  **requirements of**  **§ 91.405**  **(a) Maintenance**  **re quired;**  **§ 91.407**  **(a)(1) Operation**  **after maintenance,**  **preventive mainten**  **ance, rebuilding,**  **or alteration;**  **§ 91.409**  **(a)(1) and**  **(2) Inspections**  **and §**  **91.417 (a) and (b)**  **Maintenance records.** Further to previous exemptions granted by the FAA concerning these sections it was established that safety

i s not adversely

affected when the technical characteristics and operating limitations of the UA S are considered. A s these Regulations apply only to aircrafts with an airworthiness certificate and not to UAS

– DJI Inspire 1, an exemption is being requested for these section s . However, I John Henley II hereb y undertake that prior to each flight of the UAS a maintenance inspection will be done to the UAS .Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 9

Tele: (281)849 -4060

; Email: skyhawkvideos@gmail.com As set forth herein, UCay, Inc DBA Sky hawk Video & Photography 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 DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited 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 advancing the interests of the public, by allowing UCay, Inc DBA Sky hawk Video & Photography to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, UCay, Inc DBA Sky hawk Video & Photography respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Sky hawk Video & Photography to operate the DJI Inspire 1 UAS commercially f or the purpose of conducting aerial video and photography over certain areas of the United States . **June 10 , 2015** Skyhawk Video &Photography, 12520 Westheimer Rd., A1 - 228, Houston, TX 77077 Page 10

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; Email: skyhawkvideos@gmail.com 

# APPENDIX **– A**  **DJI Inspire 1 Manufacturer’s User Manual**

**http://download.dji****** **innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf**