November 24, 2015

United States Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and C.F.R. Part 11, Skylens Imaging, owner and operator of Small Unmanned

Aircraft Systems (UASs), is requesting to be exempted from the Federal Aviation

Regulations (FARs) listed below so Skylens Imaging may operate UASs commercially in

airspace regulated by the Federal Aviation Administration; as 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.

The Name and address of the applicant is:

Skylens Imaging

Attn: Jordan Richey -jordanrichey@gmail.com 318.623.9884

1961 Lone Star Rd

Mansfield, TX 76063

As described below, the requested exemption would permit the operation of lightweight

(less than 55 lbs total take off gross weight) UASs under controlled conditions for

commercial use by professional certificated pilots thereby enhancing safety and fulfill the

Secretary of Transportation's (the FAA Administrator's) responsibilities to “.... establish

requirements for the safe operation of such aircraft systems in the national airspace

system." Section 333(c) of the Reform Act.

Skylens Imaging respectfully requests the grant of an exemption to the following specific

sections of the Title 14 Code of federal Regulations allowing it to operate lightweight

UAS's for commercial use:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2),

91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.405(a),

91.407(a)(1), 91.409(a)(2), 91.417(a) &(b)

Skylens Imaging submits this application in accordance with the Reform Act, 112 P.L. 95

331-334, seeking relief from any currently applicable FAR's operating to prevent Skylens

Imaging future commercial use of small UASs to operate in the national airspace system

as described below. The Reform Act Section 332 provides for such integration of civil

unmanned aircraft systems into our national airspace system as it is in the public's interest
to do so. Skylens Imaging Service’s lightweight UASs meet the definition of "small

unmanned aircraft" as defined in section 331 and therefore the integration of Tubreaux

Aviation Service’s lightweight UASs are expressly contemplated by the Reform Act.

Skylens Imaging would like to operate its lightweight UASs prior to the time period by

which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain

unmanned aircraft systems may operate safely in the national airspace system (NAS)

before completion of the rule making required under Section 332 of the Reform Act. In

making this determination, the Secretary is required to determine which types of UASs

do not create a hazard to users of the NAS or the public or pose a threat to national

security in light of the following:

• The UAS's size, weight, speed and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator Reform Act 333 (a)

If the secretary determines that such vehicles "may operate safely in the National

Airspace System, the Secretary shall establish requirements for the safe operation of such

aircraft in the National Airspace System."

Skylens Imaging UAS’s are rotorcraft weighing less than 55 pounds including payload.

They operate at a speed of less than 50 knots and have the capability to hover and move

in the vertical and horizontal plane simultaneously. The UAS will operate only within the

line of sight of the pilot within a protected flight area as described below. Such operations

will ensure that the UASs will not create a hazard to the users of the national airspace

system or the public.

The small nature of the UASs utilized by Skylens Imaging combined with the safety

protocols outlined below will allow for a greater than equivalent level of safety in which

Congress envisioned that the FAA must, by exemption allow commercial operations of

UASs to commence immediately. Also due to the size of the UASs and the areas and

altitudes they will operate, approval of the exemption presents no national security issue

and absolutely minimal safety concerns which have been mitigated through a rigorous

risk management process. Given the clear direction given in Section 333 of the Reform

Act, the authority contained in the Federal Aviation Act, as amended; the strong

equivalent level of safety surrounding the proposed operations, the significant public

benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional

aircraft as well as the economic impact of greatly reducing the cost of aerial photography

thereby benefiting the greater public's interest. Accordingly, the applicant requests that

the FAA grant the requested exemption without delay.

The following limitations are considered to be binding for the operation of UASs for

commercial purposes by Skylens Imaging:
1. Flights will be operated in the line-of-sight by a ground-based pilot

2. Flights will operate clear of clouds

3. The UASs will weigh less than 55lbs at take off and during flight

4. Flights will be terminated with 25% of battery life remaining

5. Flights will be operated at an altitude at or below 400' AGL

6. Pilots, camera operators and observers will be trained as to the applicable portion of

the UAS's manual as well as the SOPs.

7. Minimum UAS crew will be one certificated Commercial pilot or higher rating with a

current Second Class FAA medical. A camera operator and or observer may be added as

required to further reduce the possibility of task saturation by the pilot depending on the

mission requirements.

8. Pilot, observer and camera operator will maintain real time communication capability

throughout flight operations.

9. The UAS Pilot will conduct a full site survey to determine the Area of Responsibility

(AOR). This AOR is the actual area for UAS operations for a particular day. Each survey

will include the assessment of potential hazards to include but not limited to airspace

classification, NOTAMS, temporary flight restrictions, closest airport proximity, natural

and manmade obstacles, and unnecessary persons which may pose a risk to operations or

safety. If deemed necessary, the crew will employ additional personnel as safety

observers.

10. Skylens Imaging will employ safety observers as well as sign notifications in areas

close to public activity.

11. A thorough briefing will be conducted, prior to the first flight of the day in an AOR,

utilizing the briefing guide in the SOPs. All persons who will be in the AOR while UAS

flights are conducted will be present for this briefing.

12. Skylens Imaging will obtain consent (verbal or written) for any persons who need to

be within 100 feet of UAS flight operations.

13. Written and or verbal permission from the relevant property owners will be obtained

prior to flight.

14. All required permissions and permits would be obtained from territorial, state, county,

parish or city jurisdictions, including local law enforcement, fire or other governmental

agencies.

15. If the UAS loses communications or loses its GPS signal, the UAS will have the

capability to return to a pre-determined location within the AOR and land autonomously.

16. The UAS will have the ability to abort a flight in case of unpredicted obstacles or

emergencies.

14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203

(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of

necessary airworthiness certificates in relation to FAR 91.203(a)(1) The size, weight and

defined area of operations for Skylens Imaging. UAS flights permits exemption from Part

21 because Skylens Imaging meets an equivalent level of safety pursuant to Section 333

of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness
certificate requirement under both the ACT (49 U.S. C. 44701(f)) and Section 333 of the

Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the

airworthiness certificate requirement in consideration of weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations. Skylens

Imaging meets or exceeds each of these elements.

14 C.F.R. 91.203 (a &b) provides for carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons stated above. The equivalent

level of safety will be achieved by maintaining such certifications and registrations at

Skylens Imaging flight operations center.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by the

FARs, this regulation is inapplicable.

14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UASs, this regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining an operators manual at the

flight operations center. The FAA has previously issued exemptions to this regulation in

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

10700 and 32827.

14 C.F.R. 91.103(b) Preflight actions

14 C.F.R. 91.103 Each pilot in command shall, before beginning a flight, become

familiar with all available information concerning that flight. This information must

include: (b) For any flight, runway lengths at airports of intended use, and the following

takeoff and landing distance information. This subparagraph is not applicable due to our

off airfield operations.

14 C.F.R. 91.109 Flight instructions; Simulated instrument flight and certain flight

tests.

14 C.F.R. 91.109 and all the subparagraphs address the operation of a civil manned

aircraft in conjunction with training and flight tests. The UAS to be employed by Skylens

Imaging are not designated in this category.

14 C.F.R. 91.121 Altimeter Settings

14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Skylens Imaging
UASs utilize GPS systems and internal gyroscopes to provide spatial stability and a

reference datum.

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions

14 C.F.R. 91.151 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.

The battery powering the UAS provides approximately 18 minutes of powered flight,

which is less than the reserve requirement alone by FARs for day. Given the limitations

on the UAS's flight envelope, proposed AOR size, battery life and its ability to land

immediately it is reasonable to allow an exception.

An equivalent level of safety can be achieved by limiting flights to 25% of battery power.

This restriction would be more than adequate to return the UAS to its planned landing

zone in the AOR.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673 and 10808.

14 C.F.R. 45.23 Marking of the Aircraft

Applicable Codes of Federal regulations require aircraft to be marked according to

certain specifications. Skylens Imaging UASs are unmanned; do not have a cabin, cockpit

or pilot station on which to mark certain words or phrases. Further, two-inch lettering is

impractical to place on such small aircraft. Skylens Imaging will, however, place the

word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. 45.29 (f) so that the

pilot, camera operator, observer and any other persons operating in the AOR can see the

markings on the UAS. The FAA has previously issued exemptions to this regulation

through Exemptions Nos. 8738, 10167, 10167 A, and 10700.

14 C.F.R. 91.119 Minimum Safe Altitudes

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

helicopters to be operated at lower altitudes in certain conditions. Skylens Imaging will

only operate its UASs at or below 400 AGL. Skylens Imaging will operate its UASs in a

defined AOR that has been carefully reviewed for hazards and minimizes the presence of

any persons not essential for operations. Flights will only be conducted over private

property with consent of the property owner. The equivalent level of safety will be

achieved given the size, weight and speed of the UAS as well as the location where it is

operated. Compared to flight operations with traditional aircraft or rotorcraft weighing far
more than 55lbs, operating below 500 AGL with flammable fuel UAS operations present

a far smaller risk.

14 C.F.R. 91.405 (a), 407 (a)(1), 409(a)(2), 417(a&b) Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have the aircraft

inspected as prescribed in subpart E of this part and shall between required inspections,

except as prescribed in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter, and others shall inspect or maintain the aircraft in

compliance with Part 43.

These regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to Skylens Imaging UASs, should its requested exemption be granted. As

an equivalent level of safety, Skylens Imaging requires its pilots to conduct a preflight,

thorough flight and post flight inspection of the UAS to ensure it's flight worthiness prior

to launch. Each UAS is flown in compliance with the applicable manufacturer’s manual

to include all software update cycles as well as flight checklists. In the event of a

malfunction the UAS can land immediately.

Privacy

All flights will occur over private or controlled access property with the property owner's

prior consent and knowledge.

Summary

Skylens Imaging is seeking exemption from the following rules:

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 91.9 (b)(2), 91.103(b), 91.109,

91.119, 91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.407(a)(1), 91.409(a)(2),

91.417(a)&(b).

Approval of the above exemptions allowing commercial operations of small UASs in the

service of aerial photography will greatly enhance safety by reducing the overall risk

associated with traditional aircraft. Traditional aerial photography requires large aircraft

weighing thousands of pounds and carrying hundreds of pound of fuel presenting a

significant risk to life and property. With Skylens Imaging’s use of small UASs weighing

less than 55 lbs, powered by batteries and operating at or below 400 AGL they virtually

eliminate all of the risk associated with traditional aerial photography. The UASs will

carry no people, thereby eliminating the exposure to the risks associated with flying while

accomplishing the same task in a much safer manner.

Granting Skylens Imaging the above exemptions will allow for the expansion of UAS

systems into the future, in a professional, safety conscious culture steep in the tradition of
Aviation. The safety culture established by the founding members of Skylens Imaging is

based on our eight (8) years of aviation experience.

Skylens Imaging respectfully requests that the FAA grant its exception without delay.

The FAA has the authority to issue the exemption sought by Skylens Imaging pursuant to

the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Sincerely,

Jordan Richey

Skylens Imaging

Mansfield, TX

jordanrichey@gmail.com

318.623.9884