Page 1



### Jeremy Edward Whitley N4604 County Rd. E Peshtigo, WI. 54157
Pilot Certificate Number: 3704602 Potential Business Name: Skyway Drone Services LLC Potential Business Location: Peshtigo Wisconsin
Tel. 715

- 587

- 2580 Jwhitley43@hotmail.com
Make of Aircraft: Yuneec Model of Aircraft: Typhoon Q500 4k
Serial Number of Aircraft: YU1537 1369B04C01 FAA Registration Number: FA3MKKTTLL



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



### Re: Request for Exemption per PL 112

- 95 §333 from §§14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CF R 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a ) ( 1), 14 CFR 91.409(a ) ( 2), 14 CFR 91.417(a) and (b)



### Dear Sir or Madam: My name is Jeremy Whitley and I am currently seeking to open a business under the name Skyway Drone
Services LLC. This will be a ground floor business that will rely solely on Aerial Drone operations. Currently I am seeking the Section 333 exemption to begin this business. It is currently not operational and is contingent on approval of this exemption. I Jeremy Whitley will be th e owner of this business. And So Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ( hence forth referred to as “the Reform Act”) and 14 CFR Part 11. I Jeremy Whitley as the sole operator of the Unmanned Aircraf t Systems (UASs), here by apply for an exemption from the listed Federal Aviation Regulations (“FARs”) to

a llow commercial operation of the UASs listed , 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.

Comme rcial operation of a UAS , as described herein, which is equipped with camera(s) and sensors, would operate in the following manner:

• Aerial photography and videography for public and private use including real estate, architecture, land surveying, engineering, and other related professional activities.

• Aerial photography and videography for public and private use including television, public events, cinematography, and newsgathering

.

• Aerial inspection of residential and commercial structures under contract with the owners or local government authority.Page 2

• Aerial inspection of residential and commercial utility infrastructure including but not limited to electrical power lines, win d turbines, and cell towers under contract with the owners or local government authority.

• Aerial photography and videography for providing real time data to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

• Aerial data collection using small payloads to include any remote sensing and measuring by an instrument(s) aboard an unmanned aerial system (UAS).

• Aerial training to persons individually or belonging to both private and public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS

. This is to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety

en hancements to the already safe operations in the 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 “....establi sh requirements for the safe operation of such aircraft systems in the national airspace system.”



## The specific section or sections of 14 CFR from which I seek an exemption
Jeremy Whitley and the potential business “Skyway Drone Services LLC” requests ex emption from the following applicable regulations, pursuant to the Administrator’s authority to grant exemptions contained in 49 U.S.C. § 106(f), 40113, and 44701:

14 CFR 21 Part H 14 CFR 61.113(a) and (b), 14 C.F.R. § 61.133 (b), 14 C.F.R. §91.7(a), 14 C.F.R. § 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a) (1), 14 CFR 91.409(a) (2), 14 CFR 91.417(a) and (b)Page 3



## Jeremy Whitley’s personnel background
Jeremy Whitley is a US Navy veteran who performed 6 years of Active duty as an Electronics Technician where he participated in two deployments. His first deployment was in 2007 to Djibouti Africa where he was utilized down range in Kenya, Tanzania, Ethiop ia, and Eritrea where he provided radio communications for humanitarian efforts performed by the Joint services. He was awarded the Joint Service Achievement Medal for his expertise and professionalism. Jeremy’s second deployment was aboard the USS Hoppe r DDG70 to the fifth fleet of operations where he provided communications support for protection of the Al Bazrah Oil Terminal (ABOT) off the coast of Iraq. For this tour, he was awarded with the Iraqi Campaign Medal. He was honorably discharged from the US Navy in June of 2011. Currently Jeremy is an Electronics Technician for a company named KS Kolbenschmidt located in Marinette, WI where he programs, maintains, and repairs industrial robotics and programmable logic controllers. In 2013, Jeremy accomp lished his life

- long dream of getting his pilots’ license.



## Skyway Drone Services LLC

A s stated above this business is not currently in operation. I Jeremy Whitley plan to open this business in the event that this exemption is approved. I plan to open it as a Limited Liability Company in the state of Wisconsin with the possibility of expanding into the state of Michigan as well. The purpose of not currently having this business opened is due to the fact that there is no other reason for this business oth er than utilizing UAS. If this exemption is not approved then I plan to continue flight as hobby/recreational use. This will be a business that is run on the side during off time from my everyday job. The services that we will provide to our customers ar e as follows:

• Aerial photography and videography for public and private use including real estate, architecture, land surveying, engineering, and other related professional activities.

• Aerial photography and videography for public and private use includ ing television, public events, cinematography, and newsgathering.

• Aerial inspection of residential and commercial structures under contract with the owners or local government authority.

• Aerial inspection of residential and commercial utility infrast ructure including but not limited to electrical power lines, wind turbines, and cell towers under contract with the owners or local government authority.

• Aerial photography and videography for providing real time data to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

• Aerial data collection using small payloads to include any remote sensing and measuring by an instrument(s) aboard an unmanned aerial system (UAS).

• Aerial training to persons individually or belonging to both private and public organizations that
have interests in th e use and application of a UAS for the purpose of the safe operation of a UAS. This is to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.Page 4

And will be performed within a safe manner a ccording to the Safety Checklist. (see attached Safety checklist and regulations set forth in the approved 333 exemptions) 

## Description of aircraft and systems o perated by Jeremy Whitley and potentially Skyway Drone Services LLC
Jeremy Whitley and if appro ved Skyway Drone Services LLC will be flying the Yuneec Typhoon Q500 4k. This is an extremely stable platform and I have been flying this drone recreationally for over 35 flight hours. It comes equipped with full GPS systems so that it is known where the m ulti

- copter is located at all times. The ST10+ is the ground station transmitter/receiver and has the capability to do a full systems check on the ground station and the Q500. There are three different flight modes, watch me, follow me, Angle, Smart, and Return to Home. In the event that communication is lost between the ST10+ ground station and the Q500, Return to Home will automatically be triggered in the quad

- copter itself and it will immediately return to the take off point and will land within 10 fe et of where the Q500 took off from. This is an extremely safe and very effective Drone. The Q500 comes pre

- programmed with boundaries such as not flying over 400’ AGL as well as a safety fence for takeoffs and landings so that no personnel, even the
PIC is within a certain distance of the drone during takeoff and landing. My Q500 is currently registered with the FAA as well as with the Manufacturer, Yuneec. This is so that I can get updates from Yuneec as to different firmware updates to be sure that I am i n compliance at all times. Please see the attached User Manual, Safety and Warning Manual, Cheat sheet for the LED indications on board the Q500, and the Quick Start guide.

Figure 1: Yuneec Typhoon Q500 4k, ST10+ transmitter, and Steady grip for gr ound shots



## Jeremy Whitley/Skyway Drone Services LLC proposal for conducting flight operations
Jeremy Whitley/Skyway Drone Services LLC intends to conduct multi

- rotor operations for the purpose of aerial photography, videography, data collection, and prototype ancillary systems development.Page 5

The aircraft is equipped with failsafe features that return the aircraft to a predetermined poin t within the
controlled area and land in the ev ent of lost radio communication. The aircraft’s control system also features an altitude limiting and operational distance limiting capability which can be preprogrammed and customized for each flight operati on. The aircraft’s control system incorporates a low battery warning which will automatically land UAV in the event that battery voltage falls be low a pre

- determined
threshold.

The control of the UAV will be through a Radio Transmitter and Receiver th at is manufactured by Yuneec operating on the 2.4 GHz spectrum called the ST10+

. The ST10+ radio system is FCC approved.

The following protocols will be implemented for each flight:

1. The UAS take

- off weight, with payload, will be less than 55 pounds

2. The UAS will be operated at speeds less than 87 knots (100 miles per hour) or less than the maximum airspeed recommended by the manufacturer, whichever is lower.

3. The UAS will be operated at an altitude equal to or less than 400 feet above ground level (A GL).

4. The UAS Flights will be operated within visual line of sight (VLOS) of the pilot in command (PIC) at
all times. The PIC will be capable of maintaining VLOS using human vision unaided by any device other than corrective lenses, as specified on the P IC’s FAA

- issued airman medical certificate or
U.S. driver’s license.

5. All operations will utilize a visual observer (VO). The UAS will be operated within the VLOS of the PIC and/or VO at all times.

6. The PIC and VO will be able to communicate verbally at all times during operation. The PIC will be designated before the flight and duties will not be transferred for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

7. The PIC will possess at least a pr ivate pilot certificate. The PIC will also have a current third

- class
medical certificate or U.S. driver’s license.

8. A PIC will only be permitted to operate if he/she demonstrates the ability to safely operate the
UAS in a manner consistent with how the UAS will be operated as described in this petition, including evasive and emergency maneuvers and maintaining appropriate distances from person and property. PIC qualification flight hours will be logged. Flights for the purposes of training PICs
and VOs and determining the PICs ability to safely operate the UAS will be conducted in dedicated training sessions in clear and safe locations in such a way so as not to pose a hazard to any persons
or property.

9. All operations will be conducted over private or controlled access property with permission from the property owner/controller or authorized representative.

10. The PIC will not commence a flight unless there is enough power for the UAS to conduct the intended operation and to operate after that for at le ast 5 minutes or with the reserve power recommended by the manufacturer if greater. Actual data for flight endurance will be compiled for each aircraft battery configuration prior to the aircraft being deployed for service. Resulting
data will be used to limit flights more accurately than the voltage alert can provide.Page 6

11. Prior to each flight the PIC will conduct a pre

- flight inspection and determine if the UAS is in a condition for safe flight. The pre

- flight inspection will account for all potential disc repancies, e.g. inoperable components, items or equipment. If the inspection reveals any conditions that affects the safe operation of the UAS, the aircraft will not be operated until the necessary maintenance has been performed. The Safety Checklists ar e attached for reference.

12. If the UAS undergoes any maintenance or alterations that affect the UAS operation or flight characteristics, a functional flight test will be performed prior to conducting further operations in such a way so as not to pose a haz ard to any persons or property. This flight test will be logged as an after maintenance functional flight test.

13. The operator will maintain, overhaul, replace, and inspect the UAS according to the
manufacturer’s recommendations.

14. If the UAS loses commun ication with its PIC it will return to a predetermined location within the privat e or controlled access property.

15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

16. The UAS will remain clear of and give way to all manned aviation operations and activities at all
times.

17. All operations will be conducted in accordance with an Air Traffic Organization (ATO) issued certificate of Waiver or Authorization (COA).

18. All UAS approved for operation under this petition will be ident ified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings as large as practicable.

19. The PIC will not operate the UAS from any moving device or vehicle.

20. The UAS will not be operated within 5 miles o f an airport unless a letter of agreement with that airports management is obtained or otherwise permitted by a COA exemption holder. The letter or agreement with the airport management will be available to the Administrator or any law
enforcement officia l upon request.

21. Documents used by the operator in accordance with safe operation and flight of the UAS will be available at the ground control station and will be made available to the Administrator or any law enforcement official upon request.

22. The op erator will obtain the consent of all persons involved in the operation and ensure that only consenting persons will be allowed within 50 feet of the flight operation. This radius may be reduced further based upon an equivalent level of safety determinati on with the advanced permission of the relevant FSDO.



## The extent of relief sought by Jeremy Whitley/ Skyway Drone
Services LLC and the reason relief is sought
The following section will describe the extent of relief Jeremy Whitley/ Skyway Drone Services LLC seeks in each section of 14 CFR requested, as well as reasons why the exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to the existing rule:Page 7



### C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 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, weigh t, speed, operational capability, and proximity to airports and populated areas of the particular
UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate under the conditions proposed will b e 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 UAS 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 and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthine ss certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, 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. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. The FAA has found in previous grants of exemption that a PIC with a private pilot certific ate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with limitations and conditions specified in this petition. (This request is similar in all material aspects to request for same in grant of exemption for Troy Built Models number 11493 Regulatory Docket No. FAA

– 2015

– 0315 & Aerius Flight LLC number 11240 Regulatory Docket No.
FAA2014

- 0894)



### 14 C.F.R. § 61.133 (b): Commercial pilot privileges and limitations.

Th e FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with limitations and con ditions specified in this petition.



### 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 for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provi ded.



### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.Page 8

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 th is 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. The UAS, 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 t he ground control point where the pilot flying the UAS will
have immediate access to it.



### 14 CFR 91.103: Pre Flight 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. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight bat tery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. (This request is similar in all material aspects to request for same in grant of exemption for Troy Built Models number 11493 Regulatory Docket No. FAA

– 2015

– 0315)



### 14 CFR 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. UAS 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 f or flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety 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. (This request is similar in all material aspects to request for same in grant of exemption for Aerius Flight LLC number 11240 Regulatory Docket No. FAA

- 2014

- 0894)



### 14 CFR 91.119: Minimum safe altitudes

As set forth herein, the UAS will never operate at higher than 400 ’ AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above th e highest point on the structure. It will be operated where buildings and people will not be exposed to operations without their pre

- obtained

consent. No flight will be taken without the permission of the property owner or local officials. Because
of th e advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. p roposed 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 400 ft. AGL. In addition, the low

- altitude operations of the UAS will ensu re separation between these UAS operations and the operations of conventional aircraft that must complyPage 9

with Section 91.119. (This request is similar in all material aspects to request for same in grant of exemption for Aerius Flight LLC number 11240 Regu latory Docket No. FAA

- 2014

- 0894)



### 14 CFR 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 app ropriate altimeter setting available before departure.” As the UAS 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 safet y check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. (This request is similar in all material aspects to request for same in grant of exemption for Aerius Flight LLC nu mber 11240 Regulatory Docket No. FAA

- 2014

- 0894 & High Adventure Air Inc. number 11461 Regulatory Docket No. FAA

- 2015

- 0270)



### 14 CFR 91.151(a): Fuel requirements 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, t o fly after that for at least 45 minutes.” The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to near 0 minutes in length. Given the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR
conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a 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 int ended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to nearly 0 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be ac hieved by limiting flights to 30 minutes or 20% of battery power

— whichever happens
first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. (This request is similar in all material aspects to request for same in grant of exemption for Aerius Flight LLC number 11240 Regulatory Docket No. FAA

- 2014

- 0894)



### 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require th at an aircraft operator or owner “will have that aircraft inspected as prescribed in subpart E of this part and will 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 will inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant.
Maintenance wil l be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise thePage 10

UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS 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. An equivalent level of safety will be achie ved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. The operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed. (This request is similar in all material aspects to request for same in grant of exemption for Troy Built Models number 11493 Regulatory Docket No. FAA

– 2015

– 0315 & Aerius Flight LLC number 11240 Regulatory Docket No.

FAA2014

- 0894)



## The reasons why g ranting Jeremy Whitley/Skyway Drone Services
LLC request would be in the public interest
By granting this exempti on request Jeremy Whitley/Skyway Drone Services LLC will provide the service of aerial photography, video and data collection to the general public and comme rcial enterprise that would benefit greatly from these services. These services would normally be cost prohibitive utilizing traditional methods. These services when performed in accordance with the safety measures outlined herein pose less harm to the gen eral public than traditional manned aircraft.

By granting this exemption Jeremy Whitley/Skyway Drone Services LLC will be able to perform critical development of UAS systems and ancillary systems that will allow safer conduct of certain jobs such as power line inspection, roof inspection and bridge inspection in a much safer and economically advantageous manner.

By granting this exemption Jeremy Whitley/Skyway Drone Services LLC will be allowed to demonstrate UAS aircraft capability, systems capability and potential applications to the general public. This will enable Jeremy Whitley/Skyway Drone Services LLC to introduce UAV and UAS to the general public in a safe an d professional manner.

The commercial, demonstrations and development operations described in this exemption request will be conducted wholly within the United States.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (si ze, 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 to grant Jeremy Whitley/Skyway Drone

Services LLC requested exemp tion allowing for Jeremy Whitley/Skyway Drone Services LLC UAS commercial operations for the purpose of photography, videography and promotional demonstration pursuant to the FOM and POHs.



### Attachments:Page 11

- Typhoon Q500 4k User Manual V2 0701

- Typhoon Q500 4 k Warning Sheet V1.0 0701

- Typhoon Q500 Cheat Sheet for LED Indications V1.0

- 0701

- Jeremy Whitley/Skyway Drone Services LLC Safety Checklist

Sincerely

,


# Jeremy Edward Whitley

Potential owner Skyway Drone Services LLC upon acceptance of exemption Email: jwhitley43@hotmail.com Phone: 715

- 587

- 2580 Address: N4604 County rd. E

Peshtigo, WI 54157