Jarrett C Speith

President/CEO Sky-Forge Robotics

950 Lincoln Street Suite 201

Bellingham, WA 98229

360.202.9148

U.S. Department of Transportation

Document Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Dear Sir or Madam:

Sky-Forge Robotics LLC (SFR) located at the corner of 10th St. and Mill Ave., South Bay Suites 

Bellingham, WA 98229, and Pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2012 ("FAA Reform Act") and 14 C.F.R. Part 11, hereby respectfully requests exemptions from 

several provisions of the Federal Aviation Regulations ("FAR"), to allow commercial operations 

of its Small Unmanned Aircraft System (UAS) for aerial imaging for safety, monitoring, training, 

and remote sensing of secured controlled environment sites, so long as such operations are 

conducted within the conditions outlined herein or as established by the FAA as required by 

Section 333.

Specifically Section 333 which authorizes the FAA to determine:

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

visual line of sight do not create a hazard to users of the national airspace system or the 

public or pose a threat to national security; and

2. Whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1).

As detailed in the document we and the attached Flight Manual and Operating Instructions, we 

are writing to request that SFR, LLC, an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations ("FARs") listed below so that SFR, may operate 
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its small unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal 

Aviation Administration ("FAA"); 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.

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. 91.7 (a)

14 C.F.R. 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 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. 407 (a)(1)

14 C.F.R. 409 (a)(2)

14 C.F.R. 417 (a) & (b)

SFR has been and is actively involved in the education, awareness, training, research, and 

technical development of UAS/ UAV service applications to provide high definition aerial 

imagery and remote sensing capabilities with small, unmanned aircraft and lightweight UAS's.

The substance of this request is essentially the same as that granted to ASTRAEUS AERIAL 

Regulatory Docket No. FAA-2014-0352 and VIKING UNMANNED AERIEL SYSTEMS, INC 

Regulatory Docket No. FAA–2014–0850 in that SFR is engaged in training, aerial photograph and 

imaging, and 3d mapping of agriculture and structures using similar lightweight, remote 

controlled UAS's in remote areas to minimize the need to climb such structures and other high 

risk activities.

SFR has fully equipped each of its small unmanned aircraft for aerial imaging, primarily for use in 

the inspection of towers and structures that would otherwise require climbing at great risk to 

the personnel involved, though given the stability and maneuverability, they may be used by law 

enforcement personnel, search and rescue and by other first responders for other aerial 

photography including video and remote sensing.

SFR exemption request would permit its operation of lightweight, unmanned (remotely 

controlled in line of sight) UAS's in tightly controlled and limited airspace. Predetermined, 

specifically marked areas of operation, sectioned off locations will allow SFR to operate within 
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current safety parameters as well as new ones being implemented. As identified, similar 

lightweight, remote controlled UAS's are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. SFR will dictate precise and repeatable 

preflight planning, decision making, and operator risk mitigation procedures to mitigate risk to 

personnel and property. 

Granting SFR's request comports with the Secretary of Transportation's (FAA Administrator's)

responsibilities to not only integrate UAS's into the national airspace system, but to" ... establish 

requirements for the safe operation of such aircraft systems [UAS's] in the national airspace 

system" under Section 333 of the Reform Act. Further, SFR will conduct its operations in 

compliance with the protocols described herein or as otherwise established by the FAA.

The Extent of Relief SFR Seeks and the Reason It Seeks Such Relief:

SFR 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 SFR contemplated commercial 

inspections, research and other flight operations within the national airspace system. The 

Reform Act in 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. SFR lightweight UAS's meet 

the definition of "small unmanned aircraft" as defined in Section 331 and therefore the 

integration of SFR lightweight UAS's are expressly contemplated by the Reform Act. SFR would 

like to operate its lightweight UAS's prior to the time period by which the Reform Act requires 

the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in 

determining the types of UAS's that may operate safely in our national airspace system. 

Considerations include:

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated 

near airports or populated areas; and, Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for SFR.

SFR UAS's uses primarily multi counter-rotating propellers for extreme balance, control and 

stability. They each typically weigh less than 55 pounds, including camera or other equipment. 

Each of SFR's small unmanned aircraft is designed to primarily hover in place and operate at less 

than a 50 knot maximum speed. They are capable of vertical and horizontal operations but 

operate only within the line of sight of the remote control pilot. In addition to the remote 

control pilot, SFR uses a camera operator, such that, at minimum, two SFR personnel govern the 

safe flight of an SFR aircraft at all times.

Utilizing battery power and no combustible fuels, flights generally last between five and twenty 

minutes. SFR does not operate its UAS's with less than twenty five percent battery capacity. 

Safety systems in place include a GPS mode that allows SFR UAS's to hover in place if 
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communication with the radio control pilot is lost and then slowly descend the UAS at twenty 

five percent battery capacity. Further, SFR fleet is programmed, in some instances, to slowly 

follow a predetermined set of waypoints to return to a safety point if communications are lost

or battery drops below twenty five percent.

SFR does not operate its UAS's near airports and generally does not operate them near 

populated areas when conducting training, inspections, or imaging activities.

SFR operation of its fleet of small unmanned aircraft will not "create a hazard to users of the 

national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). Given the small size and weight 

of SFR UAS's, combined with their operation in cordoned off and well-controlled areas, SFR fleet 

falls within Congress's contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. Indeed, SFR UAS's 

have a demonstrable safety record and do not pose any threat to the general public or national 

security. The FAA has the authority to issue the exemption to SFR pursuant to the Federal 

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

Commercial and Public Benefits Granting SFR exemption request furthers the public interest. 

First, Congress has already pronounced that it is in the public's interest to integrate 

commercially flown UAS's into the national airspace system, hence the passing of the Reform 

Act. Second, SFR conducts research into safe UAS operations every time it flies one of its UAS's. 

Flight data, visual inspections, recorded observations and flight analyses are compiled to further 

enhance current safety protocols. Allowing SFR to log more flight time directly relates to its 

research and its ability to further enhance current safety measures. Third, the public has an 

interest in reducing the danger associated with current aerial inspection methods, namely, 

resorting to physically climbing high or compromised structures to inspect.

Granting SFR exemption request substantially furthers the public's interest in ways known and 

currently unknown. Permitting SFR to immediately fly within the United States furthers 

advancements in publicly usable technologies or advancements in equipment available to law 

enforcement personnel and first responders with state of the art equipment that does not cost 

millions of dollars.

Reasons Why SFR Exemption Will Not Adversely Affect Safety Or How The Exemption Will 

Provide a Level of Safety At Least Equal To Existing Rule:

SFR exemption will not adversely affect safety. Quite the contrary, for the various reasons 

stated, permitting SFR to log more flight time will allow SFR to innovate and implement new and 

as of yet undiscovered safety protocols.

SFR UAS's weigh less than 55 pounds complete with cameras and sensors
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SFR only operates its UAS's below 400 feet;

SFR UAS's only operate for 5-45 minutes per flight;

SFR lands its UAS's when they reach 25% battery power;

SFR remote control pilots operate SFR UAS's by Visual Line of Sight (VSOL)

SFR remote control pilots have video backup should they somehow lose sight of the UAS; SFR

staffs each flight with a remote control pilot and camera operator;

SFR UAS's have GPS flight modes whereby they hover and then slowly land if communication 

with the remote control pilot is lost or battery power is below25%;

SFR actively analyses electronic flight data and other sources of information to constantly 

update and enhance safety protocols;

SFR only operates in secured areas that are strictly controlled, are away from airports and 

populated areas;

SFR conducts extensive briefings prior to flight, during which safety carries primary importance;

SFR always obtains all necessary permissions and permits prior to operation;

SFR provides a level of safety at least equal to existing rules, and in nearly every instance, 

greater than existing rules. It is important to note that absent the integration of commercial 

UAS's into our national airspace system, helicopters are the primary means of aerial 

photography. While the safety record of such helicopters is remarkably astounding, it is far safer 

to operate a battery powered lightweight UAS.

First, the potential loss of life is diminished because UAS's carry no people on board and SFR

only operates in specific areas away from mass populations. Second, there is no fuel on board a

UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and 

extreme maneuverability of SFR UAS's allow our remote control pilots to avoid hazards. Fourth 

the SFR UAS will allow the replacement of helicopters or other small aircraft to conduct similar 

work in a safer more affordable and environmentally friendly manner. Finally, given their small 

size and weight, even when close enough to structures or property to capture required images, 

SFR UAS's present a marked increase in safety over traditional larger aircraft. Accordingly, SFR

UAS's have operated and will continue to operate at and above current safety levels.

Equivalent level of safety

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR ₴ 91.203 (a) (1)
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14 C.F.R. 45.23 (b) Display of marks; general.

Due to the size and nature of the UAS, it would be impossible to comply with the marking 

requirements. The equivalent level of safety will be provided to mark the UAS as “Experimental” 

that is clearly visible to the operator, pilot, or observer. The FAA has issued the following 

exemptions to this regulation: Exemption No’s 10700, 8738, 10167, and 10167A.

14 CFR 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 UAS will 

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

safety of current operations by requiring the pilot operating the aircraft to have completed a

UAS flight training course specific to SFR operations before flying a UAS. In substitute the FAA 

approved Private Pilot Ground School or equivalent may be completed as a further equivalent

level of safety to this rule. A minimum of 40 hours instructional ground and 10 hours of 

supervised flight time will be required of any operator prior to commercial application or use. 

Unlike a conventional aircraft that carries a pilot and passenger the UAS is a remotely controlled 

with no living occupant or cargo. They are of operation is controlled and restricted, and all 

flights are planned and coordinated in advance. the risks associated with the operations of the

UAS are so diminished from the level of risk associated with the commercial operations 

contemplated by part 61, that allowing operations of the UAS as requietrsdte with a pilot who 

has met the minimum requirements exceeds the present level achieved by 14 CFR 61.113 (a) & 

(b).

14 CFR 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 are no airworthiness certificates issued for the UAS aircraft, should this 

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

Given the size, of the UAS and requirements contained in the operation manual for use, safety, 

and maintenance, as well as the use of safety checklists prior to each flight, as set forth, an 

equivalent level of safety will be provided.

14 CFR 91.9 (b) (2): Civil aircraft Flight manual, marking and placards.

Given the UAS size and configuration, there is no ability to place or carry a flight manual on the 

aircraft.

The equivalent level of safety will be maintend by keeping the flight manual that the ground

control point where the pilot flying the UAS will have immediate access to it. The FAA has issued 

the following exemptions to this regulation: Exemption No’s 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
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14 CFR 91.103 Preflight Actions

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

of flight. An exemption is needed form this requirement as the pilot will take a separate list of 

preflight actions, including checking for wheatear conditions flight batter, take of ad and landing 

clearances, and other actions specified in the SFR preflight checklist. These actions will profcie 

an equivalent level of safety.

14 CFR 91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully function dual controls. 

By design the UAS and remotely piloted aircraft of this configuration 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 previolsyul approved exemptions for 

aircraft without fully funcitonlinal dual controls. See exemption No’s 5778K and 9862A. The 

equivalent level of safety provided by the fact that neither a pilot more passenger will be carried 

in the aircraft, the ability to control the UAS via radio signal from the control, and by the size and 

speed of the aircraft.

14 CFR 91.121 Altimeter Settings

An equivalent level of safety will be achieved by the operator by using a GPS altitude readout 

and proper safety checklist and preflight planning confirming the altitude of launch site prior to 

flight

14 CFR 91.151 (a) VFR Fuel requirements for flight in VFR

An equivalent level of safety will be achieved by limity flights to 30 minutes or enough battery 

reserve to ensure the UAS lands at the ground control point with at least 20% battery power 

remaining (as determined by on board monitoring system and the pilot). Furthermore the UAS 

can be programed to safety descend and land automatically in the event of loss of 

communications or battery level is exceeded. Similar exemptions have been granted to other 

operations, including exemptions 2689F, 5745, 10673, and 10808.

14 CFR 91.203(a) and (b): Carrying civil aircraft certification and registration

The UAS fully loaded weighs no more than 10lbs and is operated without an onboard pilot. 

Therefore the is no ability to place or carry the certification and registration documents or 

display them on the UAS. 
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An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot of the UAS will have immediate access to them, the extent they are 

applicatnle to the UAS. The FAA has issued numerous exemptions to this regulation such as 

Exemption No’s 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR 91.405 (a): 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

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

these sections will not apply to the SFR UAS. Mainteneatn will be accomplished hty eh operator

pursuant to the flight manual and operating handbook. An equivalent level of safety will be 

achievedbecasue these small UAS are limited in sizes, complexity, and will carry only a small 

payuleo to operate for specific limited time. If mechanical issues arise the UAS can land safely

immediately and will be operating no higher than 400 feet AGL. Preflight inspection will ensure 

the UAS is in working order and requiremed maintenance will be performer. A flight and 

maintenance log will be kept with the operator and maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

Respectfully,

Jarrett C Speith

President/CEO Sky-Forge Robotics