Hawkeye Skycam LLC 

Michael Stanard 

2927 Chris Lane 

Grapevine, Texas 76051 

altimig@yahoo.com

November 7, 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 from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 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). 

Dear Sir or Madam: 

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

Act) and 14 C.F.R. Part 11, Hawkeye Skycam LLC, operator of Small Unmanned Aircraft 

Systems (“sUASs”) specifically the DJI Phantom 2 Vision plus equipped to conduct aerial 

electronic data collection, (c) would be permitted to pursue commercial interests in 

providing services to consumers interested in aerial photography, videography, 

engineering, construction, and agricultural inspections, real estate marketing, marine and 

yacht services, and insurance adjusting services hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its DJI 

Phantom II Vision plus a sUAS, 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. 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) 

limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements 

to the already safe operations in the aerial filming and monitoring industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance 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. 

(c) "Aerial Data Collection” which includes any remote sensing and measuring by an 

instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), 

electronic measurement (precision surveying, RF analysis, etc.), chemical measurement 

(particulate measurement, etc.), or any other gathering of data by instruments aboard the UA 

 

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The name and address of the applicant is: 

Hawkeye Skycam LLC 

Michael Stanard

Airline Transport Pilot # 3045413 - B777; DC-9

USCG Merchant Mariner Credential # 2978487 Master-100ton

Texas Insurance Adjuster License # 1833588

Ph: 817-421-2919 

Email: altimig@yahoo.com 

Address: 2927 Chris Lane, Grapevine, Texas, 76051 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333(a) through (c) of the Reform Act. This law 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 rulemaking required under Section 332 of the 

Reform Act. In making this determination, the Secretary is required to determine which types of 

sUASs 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 sUAS’s size, weight, speed, and operational capability; 

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

• Operation of the sUAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, 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.” Id. §333(c) (emphasis added) (A)

_______________________________________________________________________ 

(A) Applicant interprets this provision to place the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions for 

the safe operation of the sUAS, if it should be determined that the conditions set forth herein 

do not fulfill the statutory requirements for approval. 

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The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Hawkeye Skycam LLC’s sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate only within the sterile area described in the Flight 

Safety Manual, attached as Exhibit B (hereinafter “the Manual”). Such operations will insure that 

the sUAS will “not create a hazard to users of the national airspace system or the public.” (B)

Given the small size of the sUASs involved and the restricted sterile environment within which 

they will operate, the applicant falls 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 UASs to commence immediately. Also due to the size of the sUASs and the 

restricted areas in which the relevant sUASs will operate, approval of the application presents 

no national security issue. Given the clear direction 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, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions associated 

with allowing sUASs for commercial operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already 

safe commercial operations conducted with conventional aircraft. 

__________________________________________________________________________ 

(B) Reform Act Section 333 (b). 

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These limitations and conditions to which Hawkeye Skycam LLC agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within visual line of sight of a pilot and/or observer in Day VMC. 

3. Maximum total flight time for each operational flight will be 25 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 

feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer.

6. sUAS pilot will be an FAA licensed airman with at least a private certificate and a valid 

driver’s license. The observer will also hold a valid driver’s license. 

7. sUAS Pilot will be Pilot in Command (PIC) and will not change during flight. 

8. The sUAS will only operate within a confined “Sterile Area” as defined in the Manual. 

Section C of the Manual requires the establishment of a “Security Perimeter” for the flight 

operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day. 

10. The operator will obtain the consent of all persons involved and ensure that only 

consenting and necessary persons will be allowed within 100 feet of the flight operation, all 

others will be kept at 500 feet.

11. Pilot and observer will have been trained in operation of sUAS generally and received upto-date information on the particular sUAS to be operated as required. 

12. Observer and pilot will at all times be able to communicate by voice. 

13. Written and/or oral permission from the relevant property holders will be obtained. 

14. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

15. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

16. The sUAS will have the capability and must abort a flight in case of unpredicted obstacles 

or emergencies.

17. The sUAS will not be operated within 5 miles of an airport reference point (ARP). See 

appendix A

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

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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 and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 particular sUAS. In all cases, 

an analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as 

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

airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the 

Manual’s requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the sUAS, 

due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 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 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. 

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as 

the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be 

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impossible. The word “Experimental” 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 the 

identification of the sUAS as “Experimental.” The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level 

of safety of current operations by requiring the PIC operating the aircraft to have a private 

pilot’s license rather than a commercial pilot’s license to operate this small sUAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with 

no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the Manual. The level of safety provided by 

the requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 

C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

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

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance 

and use of safety check lists prior to each flight, as set forth in Section C and D, an equivalent 

level of safety will be provided. 

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

Section 91.9 (b) (2) 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. 

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The sUAS, given its size and configuration has 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. 

The equivalent level of safety will be maintained 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 the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

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

14 C.F.R. § 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 as set forth 

in the Manual. 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 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides 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. 

sUASs and remotely piloted aircraft, by their 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 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. The equivalent level of safety is provided by the 

fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed 

of the aircraft. 

Safe simulation and practice flight will be carried out in controlled environments. All simulations 

will be carried out on a computer using the drone controls. Any practice flying will take place in 

a safe environment, with no risk to human life below. 

14 C.F.R. §91.119: Minimum safe altitudes 

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 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 the sUAS will never operate at higher than 400 AGL. It will however be operated in a 

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restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

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

well 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 be aware of the planned flight 

operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft 

weighting 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 presently presented with 

conventional aircraft operating at or below 500 AGL in similar operations. In addition, the lowaltitude 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. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety 

Checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) 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 battery powering the sUAS provides approximately 25 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 20 minutes in length. Given the limitations on the sUAS’s proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time frame 

for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small sUAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small sUAS. 

Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the 

exemption will be granted. 

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Applicant believes that an equivalent level of safety can be achieved by limiting flights to 25

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating 

area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

14 C.F.R. §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: 

(1) 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 weighs no more than 55 lbs and is operated without an onboard pilot. 

As such, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS. 

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, to the extent 

they are applicable to the sUAS. 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 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 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook as referenced in the 

Manual.(See Sections A and B) An equivalent level of safety will be achieved because these 

small sUASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land 

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immediately and will be operating from no higher than 400 feet AGL. As provided in the 

Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in 

an airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55lbs or less) in motion picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs for the uses Hawkeye

Skycam LLC has proposed will enhance safety by reducing risk. Similar conventional 

operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from 

the subject being filmed and in extreme proximity to people and structures; and present the 

risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large 

amounts of jet A or avgas. Such aircraft must fly to and from the location. In contrast, a sUAS 

weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given 

the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the 

location and not flown. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft flights. 

The operation of small sUASs, weighting less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and 

people. 

sUASs Details: See Appendix C 

Safety Features: 

● Emergency “Return-To-Home” 

○ At the beginning of each flight a home point is set. This home point is set in accordance with 

the manual to allow for a safe take-off and return. Should the pilot’s control lose signal with the 

sUAS or battery gets low, or manually request a return, the sUAS will return to the starting 

point.

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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 to 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 sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s sUAS in the 

commercial pursuits proposed by Hawkeye Skycam LLC pursuant to the Manual appended 

hereto. 

Sincerely 

Hawkeye Skycam LLC 

Michael Stanard

 

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 Appendix A: No-Fly Zones 

Hawkeye Skycam LLC’s Pilots will not be operating within 5 nautical miles of any airport. 

As a safety precaution, Hawkeye Skycam LLC’s pilots will not be operating within 5 nautical 

miles of any airport similar to the permission granted in Exemption No. 11153 - Regulatory 

Docket No. FAA20140519, page 25, "20. The UA may not operate within 5 nautical miles of an 

airport reference point (ARP) as denoted on a current FAA-published aeronautical chart unless 

a letter of agreement with that airports management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operators COA. The letter of 

agreement with the airport management must be made available to the Administrator upon 

request." 

As well as in Exemption No. 11195 - Regulatory Docket No. FAA20140884, page 12, "19. The 

UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airports 

management is obtained, and the operation is conducted in accordance with a Notice to 

Airmen (NOTAM), as required by the operators Certificate of Waiver or Authorization (COA). 

The letter of agreement with the airport management must be made available to the 

Administrator upon request." 

Hawkeye Skycam LLC requests the same flexibility as exemptions 11153 and 11195 for 

acquiring agreement with the airports' management should operations fall within 5 nautical 

miles of an airport.

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Appendix B: Safety Manual 

A. Maintenance 

a. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the sUAS,

the aircraft is prohibited from operating until the necessary maintenance has been

performed and the sUAS 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.

b. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation

or flight characteristics, e.g. replacement of a flight critical component, must undergo

a functional test flight in accordance with the operating documents. The PIC who

conducts the functional test flight must make an entry in the sUAS aircraft records of

the flight. The requirements and procedures for a functional test flight and aircraft

record entry must be added to the operating documents.

c. The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or 

equipment, not covered in the relevant preflight inspection sections of the operating documents.

d. The operator must follow the manufacturer’s sUAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

e. The operator must carry out their maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

and alterations must be noted in the aircraft logbook, including total flight hours and

description of work accomplished, before returning the sUAS to service. The petitioner will return the 

sUAS to the manufacturer for maintenance purposes as stipulated by the manufacturer’s maintenance.

B. Record Keeping 

a. A record will be kept for all flights, flight times, and maintenance records. 

C. Safety Parameter 

a. Before operation occurs, a 100 yard perimeter from the planned flight path will be identified 

in order to set a “sterile” environment for the operation. 

b. Hawkeye Skycam LLC must obtain written or oral permission from all landowners in sterile 

environment. 

D. Identify potential obstacles 

a. Before each flight, an inventory will be taken for all potential obstacles that must be avoided 

while in flight. Including: 

1. Powerlines 

2. Cell Phone Towers 

3. Trees 

4. Flocks of birds that may take flight 

5. Heavily traveled roadways 

6. Utility wires 

7. Elevated structures

8. At least 5 nautical miles from the nearest airport or helipad. 

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E.. Pre-Flight Checklist 

Pre-Flight Checklist Environmental 

Check for people, animals, property in the flight vicinity 

Notify any bystanders or nearby property owner of intentions 

When flying FPV, discuss flight plan with observers 

If Flying in controlled airspace, notify airspace authority of intentions 

Hardware/Equipment – VISUALLY CHECK THE AIRFRAME 

Check for cracks (especially in high stress areas like joints) 

Check for loose or damaged screws/fasteners/bands/straps/ties 

Check for loose or damaged wiring 

Check for loose or damaged connections (solder, plugs, etc.) 

Inspect prop mounts & screws & apply slight counter pressure on arms to check for 

loosened construction 

For FPV, inspect/clean FPV smartphone battery charged and/or camera lens and 

ensure that camera is secured 

Check Battery/batteries are fully charged, properly seated and secured 

Check props free of damage, installed, and tight. 

SD card installed

Gimbal guard and camera lens cap off

Ensure Wi-fi extender battery is fully charged 

Wi-fi extender on and antennae tilt is 45 degrees

Ensure transmitter battery is fully charged and on 

Phantom on and wi-fi app is connected

Pre-Flight Run Up – Power Up 

S1and S2 switches up and check satellites (6 min, 8 for good hover)

Calibrate the Compass away from metal and power lines

Position quad-copter in a level, safe location for takeoff 

Confirm good FPV, satellites, video receiver, goggles, etc. 

Wait for home lock and Turn on Camera 

Check all transmitter controls move freely in all directions 

Check all transmitter trims in neutral position 

Check all transmitter switches in correct position 

Transmitter throttle to zero 

Radio transmitter is on 

Ensure visual observer is ready

Ensure LED indicators & audible tones are all correct 

Stand Clear – audibly, loudly announce the word “CLEAR” 

Scan for nearby people, animals, low flying aircraft or obstacles 

Arm Flight Controls 

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F. After Landing Checklist

 

 Throttle - off

 Camera - off

 Phantom - off

 Wi-fi extender - off 

 Transmitter off

 Gimbal guard and camera lens cap - install

 sUAS will be inspected for any damage that occurred in flight

 Appendix C

 sUAS : DJI Phantom II Vision +

 19" x 19" x 8"

 23" diagonally

 5.6 pounds

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