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## Suncoast Skyview

Richard Odato, (ATP 1909799),owner SuncoastSkyview, Inc

.. 7108CoachllghtStreet Sarasota, Florida 34243

December5, 2015

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

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b):14 CFR Part 21:14 CFR 61.113 (a) 

### &.(Qt._ 91.7 (a):91.9 (b) (2):91.103(b): 91.109:91.119:91.121: 91.151(a):91.203(a) & (bl:91.405 (a): 91.407(a) (1): 91.409 (a) (2):91.417 (a) &(b).

Dear Sir or Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the ReformAct) and 14 C.F.R. Part 11, SUNCOASTSKYVIEW, INC. developer and operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography forthe real estate, motion picture and television industry forscripted closed setfilming, hereby applies for an exemptionfrom the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofitssUASs, so long
as such operations are conducted within and under the conditions outlined herein oras may be established bythe FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation ofsmall, 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 safetyenhancements to the already safe operations in the film and television industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's(the FAA Administrator's) responsibilities to "

... establishrequirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act.

The name and address ofthe applicant is: SuncoastSkyview, Inc

.. Attn: Richard Odato,Owner Address: 7108 CoachlightStreet Sarasota, FL 34243 Ph:941-730-4461 Emaii: rick@odato.com

1The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-lssue a Certificate ofWaiverfor Real Estate, Motion Picture and Television Filming.

Regulations from which the exemption is requested: 14 CFR Part 21 14 CFR. 45.23(b) 14CFR61.113 (a)&(b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 

### CFR. 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) ofthe Reform Act. This law directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe ReformAct. In making this determination, the Secretary is required to determine which types of UASs do notcreate a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthe followingPAGE 3

•The UAS's size, weight, speed, and operational capability;
•Operation ofthe UAS in close proximity to airports and populated areas; and
•Operation ofthe UASwithin visual line ofsight ofthe operator.

Reform Act§ 333 (a). Lastly, ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." ld. §333(c) (emphasis added)2. The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, asthe term is defined under §40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have acurrent airworthiness certificate.

2Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but fortheAdministrator to craft conditions for the safe operation ofthe UAS, ifit should be determined thatthe conditions setforth herein do not fulfill the statutory requirements for approval.

The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthistitle ifthe Administrator finds the exemption in the public interest. 49 U SC §44701 (f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1)

SUNCOASTSKYVIEW'S sUASs are rotorcraft, weighting 55 orfewer lbs. including payload. They operate, under normal conditions ataspeed ofno 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 ofsight and will operate onlywithin the sterile area described in the Confidential Motion Picture and Television Operations Manual, attached as Exhibit 1(hereinafter "the Manual")3

.Such operations will insure thatthe sUAS will "not create a hazardto users of the national airspace system orthe public."

Given the small size ofthe sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within thatzone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofUASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe applicationpresents no national security issue. Given the clear direction in Section 333 ofthe 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 UASs for movie and television operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes thatthe exemption requested herein apply to civil aircraftthat have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level ofsafety to operations under the current regulatory structure because the proposed operations represent asafety enhancement to the already safe movie and television filming operations conducted with conventional aircraft.

3The Motion Picture Association ofAmerica has reviewed this manual and has found itto be acceptable forsUAS filming operations forthe television and movie industry. Applicant submits this manual as aConfidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary information thatthe applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom ofInformation Act 5 USC 552 et.seq.

4 Reform Act Section 333 (b).

These limitations and conditions to which SUNCOASTSKYVIEW, INC. 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 line ofsight ofa pilot and/or observer.3. Maximum total flight time foreach operational flight will be 30 minutes. Flights will be terminated at25% battery power reserve should that occur prior tothe 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crewforeach operation will consist ofthe sUAS Pilot, and the Visual Observer. 6. sUAS pilotwill be an FAA licensed airman with at least aprivate pilot's certificate and third class medical. The observer will hold at least athird class medical. 7. sUAS Pilotwill be Pilot in Command (PIC). Ifa pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can also be designated as PIC. 8. The UAS will only operate within a confined "Sterile Area" as defined in the Manual. Section H, Iand 

### J ofthe Manual requires the establishment ofa "Security Perimeter" forthe flight operations area. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's production activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be present forthis briefing. 10. The operator will file a FAA Form 7711-1, orits equivalent, as modified in light ofthe requested exemption, with the appropriate Flight Standards District Office. 11. The operator will obtain the consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, andthis radius may be reduced to 30 feet based upon an equivalent level ofsafety determination,
as required by Section K ofthe Manual. Withthe advanced permission ofthe relevant FSDO, operations atcloser range can be approved. 12. The operator will submit awritten Plan ofActivities to the FSDO three days before the proposed shoot as required in Section Kofthe Manual. 13. Pilot and observer will have been trained in operation ofUAS generally and received up-to-date information on the particular UAS to be operated as required Sections M and N ofThe Manual. 14. Observer and pilot will at all times be able to communicate by voice and/or text. 15. Written and/or oral permission from the relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county orcity jurisdictions, including local law enforcement, fire, orother appropriate governmental agencies. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the Security Perimeter and land. The sUAS will have the capability to abort aflight in case of unpredicted obstacles orother unanticipated hazard. 18.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under

Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS 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 orflammable liquid fuels, and operates exclusively within asecured 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 underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is now done with conventional filming. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide agreater degree ofsafety tothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threat to national security posed by the UAS, dueto its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry asubstantial external load.

14 C.F.R. 

### §45.23 (b). Marking ofthe Aircraft

The regulation requires: When marks include onlythe 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 lettersnot less than 2inches nor more than 6 inches high, thewords "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will be provided by having the sUAV marked on itsfuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAVwill see the identification ofthe UAS 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 UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license rather than acommercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with
no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as setforth in the Manual. The level ofsafety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate operating aconventional aircraft. The risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot asthe PIC exceeds the present level ofsafety achieved by

14C.F.R. §91.7(a): Civil aircraft airworthiness The regulation requires that no person may operate acivil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and
use ofsafety check lists priorto each flight, as setforth in Sections 

### J, Land Q, an equivalent level ofsafety will be provided.

14C.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) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no piloton board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control pointwhere 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, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. §91.103: Preflight action

This regulation requires each pilot in command totake certain actions before flightto insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafety will be provided as setforth in Sections 

### J and Kofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate acivil aircraft (except amanned 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 accomplishedthrough the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A The equivalent level ofsafety provided by the factthat neither a pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft.14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudesfor operation ofcivil 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 oraltitudes prescribed for helicopters bythe FAA As this exemption is for asUAS that is ahelicopter and the exemption requests authority to operate ataltitudes upto400 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 setforth herein, except forthe limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS
as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in thefilming activity, all affected individuals will be aware ofthe planned flight operations as setforth in Section Kofthe Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lackof flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating ator below 500 AGL in the movie industry. In addition, the low-altitude operations ofthe sUAS will ensure separation between thesesmaiiUAS operations and the operations ofconventional 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 ofthe departure airport oran appropriate altimeter setting available before departure." Asthe sUAS may not have abarometric altimeter, but instead aGPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the Manual and Safety Check list, confirming the altitude ofthe 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 ofintended landing, and, assuming normal cruisingspeed- (1) During the day, to fly afterthatfor at least 30 minutes; or(2) At night, to fly afterthat forat least 45 minutes."

The battery powering the sUAS provides approximately 40 minutes ofpowered flight. To meetthe 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longertime frame for flight in daylight ornight VFR conditions is reasonable.
Applicant believes that an exemption from 14 CFR §91.151(a) fallswithin the scope of priorexemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in atightly controlled area where only people and property owners orofficial representativeswho have signed waivers will be allowed, with less than 30 minutes ofreserve fuel, does not engender thetype ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility forwhich the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 30 minutes or25% ofbattery 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 G.F.R. §91.203(a) arid (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate acivil aircraft unless it has within itthe following:
(1) An appropriate and current airworthiness certificate.
(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section oraspecial flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance sothat it is legible to passengers or crew.The UAS 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 levelofsafety will be achieved by keeping these documentsatthe ground control point where the pilot flying the sUAS will have immediateaccess to them, to the extent they are applicableto the sUAS. The FAA has issued numerous exemptionsto this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14C.F.R. §91.405 (a); 407 (a) (1); 409 (a) 

### (2); 417(a) 

### &(b): Maintenance Inspections

These regulations require that an aircraft operatoror owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except
as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter.

.. ," and others shall inspect or maintainthe aircraft in compliancewith Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sectionswill not apply to the applicant. Maintenancewill be accomplished by the operator pursuantto the flight manual and operating handbookas referenced in the Manuai. (See Sections L and Q) An equivalent levelofsafety will be achieved becausethesesmall UASs
are very limited in size and will carry a small payload and operateonly in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land immediately andwill be operating from no higherthan400feetAGL.As provided in the Manual,the operatorwill
ensurethat the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenanceperformed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintainthe aircraft in an airworthy conditionto providethe equivalent levelofsafety.

Pursuantto 14 CFR. Part 11, the following summary is providedfor 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 (551bs or less) in real estate, motion picture and television operations.Approval ofexemptions allowing commercial operations ofsUASs in the film industry will enhance safety by reducing risk. Conventional film operations, using jetor piston power aircraft, operate atextremely lowaltitudes justfeet from the subject being filmed and in extremeproximity to people and structures; and present the risks associated with vehicles thatweigh in the neighborhood of4,0001bs., carrying large amounts ofjetA orother fuel (140 gallons forjet helicopters shown below). Such aircraft must flyto and from the film location. In contrast, asUAS weighing fewerthan 55 lbs. and powered by batteries eliminates virtually all ofthat riskgiven the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the film set and notflown. The sUAS will carry no passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation ofsmall UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate atslow speeds, close to the ground, and in asterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.
Privacy All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Filming will be ofpeople who have also consented to being filmed
orotherwise have agreed to be in the area where filming will take place.

Setforth below are pictures ofaerial filming conducted in both day and night environment, asflowntoday in highly populated and/or urban areas, Vllith turbine powered helicopters. The grant ofthis exemption request will provide improved safety in both day and night operations.

# mNight operations will also be conducted by sUASs such operationsare fully lighted
so thatvisibility is as though filmingwas conducted during daylight hours.

Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operationwithin visual line ofsight and national security- provide more than adequate justification forthe grant ofthe requested exemptions allowing commercial operation of applicant's UAS in the real estate, motion picture and television industry pursuant to the Manual appended hereto.

Shouldyou have anyquestions, please contactme. Thankyou in advanceforyourconsideration.

Sincerely,

# ~~;...-- Richard Odato, Owner SuncoastSkyview, Inc. AirlineTransport PilotCertificate: 1909799 7108CoachlightStreet Sarasota, FL34243 PHONE: (941)-730-4461 EMAIL: rick@odato.com