August	11,	2015

U.S.	Department	of	Transportation	Docket	Management	System	

1200	New	Jersey	Ave.,	SE	Washington,	DC	20590

Re:	Exemption	Request	Under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations

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,	Chad	Short	DBA:Sky	Eye	Drone	Services,	seeks	

an	exemption	from	Federal	Aviation	Regulations	(“FARs”)	detailed	below	for	(1)	DJI	

Phantom3	quadcopter	manufactured	by	DJI	Innovations.

The	requested	exemption	would	support	an	application	for	a	commercial	Certificate	

of	Authorization	to	use	the	system	to	support	aerial	photography	and	videography.	

The DJI	Phantom3	(3lb)	consist	of	a	battery	operated	aircraft,	a	tablet-based	ground	

control	station	and/	a	RC	Controller,	and	associated	communications	equipment.	

The	aircraft	carries an	onboard	geo-referenced	gimbaled	camera	that	allows	it	to	

obtain	photography	and	videography.

The	Unmanned	Aircraft	System	will	be	operated	in	the	field	with	a	PIC	in	accordance	

with	FAA	Policy	N	8900.227	Section	14	"Operational	Requirements	for	UAS".

Chad	Short	DBA:	Sky	Eye	Drone	Services respectfully	requests	the	grant	of	

exemption	allowing	to	operate	lightweight,	remote controlled	UAS lawfully	and	

safely.

Sky	Eye	Drone	Services also	respectfully	requests	Exemption	Request	Section	333	

from	(but	not	limited	to)	the	Specific	Sections	of	Title	14	of	the	Code	of	Federal	

Regulations	and	part	ll	of	the	Federal	Aviation.	Regulations	listed	below.

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)

The	extent	of	relief		Sky	Eye Drone	Services seeks	and	the	reason	why:

Sky	Eye	Drone	Services is	seeking	relief	from	any	applicable	FARs	operating	to	

prevent	Sky	Eye	Drone	Services from	conducting	aerial	shots	of	real	estate	and	

other	possible	legal	flight	operations.	The	weight	of	the	UAS	meets	the	definition	of	

''small	unmanned	aircraft”	found	in	section	331	"The Reform	Act”.	Sky	Eye	Drone	

Services seeks	to	operate	legally	as	a	small	business	that	cater	mostly	to	real	estate	

agents.	Realtors	are	not	allowed	to	use	UAS's	or	hire	unless	they	or	the	person	they	

hire,	is	allowed	by	the	FAA	to	fly	a	UAS.	Visual	Aerial	Pros	would	satisfy	the	need	for	

safe	and	affordable	aerial	shots.

At	less	than	7	pounds,	Sky	Eye	Drone	Services uses	UAS	that	is	considerably	less	

than	55	pounds	including	the	camera	that	is	attached.	The	UAS	will	be	used	at	
speeds	under	35	mph	because	of	the	nature	of	the	business	and	the	limited	physical	

capabilities	of	the	UAS.	It	is	designed	to	hover	and	take	pictures.	The	UAS	will	be	in	

accordance	with	flying	well	below	400ft.

The	UAS	in	which	Sky	Eye	Drone	Services would	be	using	only	utilizes	battery	

power	for	its	operations.	There	are	no	combustible	fuels	used	in	the	UAS	that	Sky	

Eye	Drone	Services uses.	The	maximum	flight	time	for	our	particular	UAS	is	20	

minutes	battery	life.	It	will	fly	no	more	than	15	minutes	maximum	at	one	time	at	one	

location.	The	amount	of	time	the	UAS	will	be	in	the	air,	less	than	400ft,	is	very	

minimal.

A	Safety	system	in	place	for	Sky	Eye	Drone	Services UAS	includes	a	GPS	mode	that	

allows	the	UAS	to	return	home	if	communication	is	lost.	Further,	the	GPS	onboard	

allows	the	UAS	to	return	back	to	its	launched	position	if	the	battery	life	of	the	UAS	is	

low.

THE	GROUND	STATION	PART	OF	THE	SYSTEM:

A	Pilot	in	Command	(PIC)	in	operational	control	of	a	flight	operation	from	beginning	

to	end	and	who	controls	the	UAS	while	in	the	air.	Additionally,	the	line	of	site	of	the	

UAS	will	not	leave	the	sight	of	the	PIC.

A	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control	the	U.AS	while	

in	flight;

A	radio	receiver	receiving	live	video,and	flight	data	from	the	on-board	camera	and	

computer.	It	projects	it	all	in	one	screen	to	the	Pilot	in	Command

The	UAS,	weighing	less	than	7lbs	fully	loaded,	is	powered	by	batteries	and	operates	

with	no	people	on	board	which	lowers	the	likelihood	of	death	or	serious	bodily	

injury.	With	a	small	payload	consisting	of	harmless	electronics	such	as	a	camera	and	

GPS,	the	UASs	only	purpose	is	to	be	used	as	a	tool	to	take	pictures	and	videos.

Low	level	aerial	photos	and	video	from	several	angles	are	far	more	effective	than	

ground	based	photos.	Low	level	aerial	video	and	pictures	show	the	layout	of	

properties	with	the	advantage	of	seeing	more	in	one	photo	or	short	video.

Current	applicants	have	used	helicopters	and	small	planes	for	this	purpose	but	the	

cost	of	fuel,	time,	and	emissions	of	such	aircraft	is	not	efficient	enough	for	most	

customers	to	afford.

The	benefits	of	reduced	cost	and	improved	efficiency	of	the	UAS	allows	future	

customers	to	afford	this	service	with	a	faster	turnaround	time	at	a	lesser	cost.

Additionally,	I	respectfully	request	that	Sky	Eye	Drone	Services be	allowed	to	use	

the	UAS	to	benefit	possible	first	responders	our	local	area	for	actions	that	could	

benefit	the	public.	Such	as,	fires	and	search	and	rescue.

Sky	Eye	Drone	Services will	not	operate	a	UAS	near	airports	and	generally	does	not	

fly	over	crowds.	Situational	awareness	is	most	important.	The	areas	where	Sky	Eye	

Drone	Services aerial	photography	is	predetermined	which	allows	for	a	controlled	

environment	to	operate	safely.

With	allowing	Sky	Eye	Drone	Services to	conduct	business	with	a	light	weight	UAS,	it	

could	very	well	help	the	economy	and	benefit	people	in	first	response	situations.	

Further,	Sky	Eye	Drone	Services UAS	is	considerably	lighter	than	the	alternative	
which	is	a	helicopter	or	small	plane.	Currently,	Sky	Eye	Drone	Services has	1	UAS	

which	only	operates	off	20	minutes	of	battery	power.	Therefore,	the	UAS	used	by	

Visual	Aerial	Pros	would	only	have	a	flight	time	of	5	- 15	minutes	at	one	time.	The	

likelihood	of	injury	or	even	death	with	such	a	small	unmanned	aircraft,	compared	to	

an	aircraft	flown	by	a	person	loaded	with	combustible	fuel,	is	considerably	low

SUMMARY:

Sky	Eye	Drone	Services is	more	than	willing	to	follow	the	safety	guidelines	of	the	

FAA	Policy	N	8900.227	Section	14	"Operational	Requirements	for	UAS'1	with	the	

appropriate	exemptions	for	flying	a	small	UAS.

A-No	flight	will	be	made	with	a	UA	Gross	weight	exceeding	55lbs

B- All	operations	must	occur	in	FAA	Class	G	airspace	at	no more	than	400	ft.	AGL,	at	

an	airspeed	of	not	more	than	25	knots	and	no	further	than	3/4	NM	from	the	Pilot	In	

Charge

C- Operations	will	be	restricted	to	flights	over	private	property	with	the	permission	

of	the	property	owner

D- All	required	permits	will	be obtained	from	state	and	local	government	prior	to	

operation

E- The	UAS	will	not	be	operated	over	densely	populated	areasF- The	UAS	will	not	

be	operated	at	air	showsG- The	UAS	will	not	be	operated	over	any	open-air	

assembly	of	people	H-The	UAS	will	not	be	operated	over	heavily	trafficked	roads

I-The	UAS	will	not	be	operated	within	5	NM	of	an	airport	or	heliport

J- Operations	will	be	restricted	to	day	only	and	weather	conditions	equivalent	to	

VFR

K- The	PIC	will	notify	property	owner	about	the	operation	and	risk	before	the	first	

flight	at	each	new	location;

L- No	flight	may	be	made	without	a	Pre-Flight	Inspection	by	the	PIC	before	each	

operation	to	ascertain	that	the	UAS	is	in	a	condition	safe	for	flight	(see	Appendix	A).

My	operations	above	are	the	bare	minimum	safety	guidelines	Sky	Eye	Drone	

Services will	follow.	Sky	Eye	Drone	Services is	also	more	than	willing	to	follow	any	

additional	safety	requirements	if	not	listed	above.

Sky	Eye	Drone	Services believes	flying	its	UAS	as	a	small	business	within	the	safety	

parameters	of	the	FAA,	can	help	people	and	promote	the	economy.

The	name	and	contact	information	of	the	applicant	is:	Sky	Eye	Drone	Services Attn;	

Chad	ShortPhone:	410-215-4628

Email:	Chadshort328@GMAIL.COM

Sky	Eye	Drone	Services respectfully	requests	that	the	FAA	grant	its	exemption	

request	without	delay.	I	very	much	look	forward	working	together	with	you	guys.	

Thank	you	for	your	time.

Respectfully,

Chad	Short	BDA:Sky	Eye	Drone	Services

410-215-4628