June 5, 2015

Re: Request for exemption from multiple regulatory provisions to allow the use of small

unmanned aerial systems on land controlled by clients of Jayson T. Firebaugh d/b/a Star 

City SkyCams to assist in the safe evaluation of real estate comparables, topography 

reports and private events as contracted by clients.

I Jayson T. Firebaugh, a sole-proprietorship d/b/a/ Star City SkyCams, respectfully

requests an exemption from several provisions of Title 14 of the Code of Federal 

Regulations (C.F.R.) to permit the use of small unmanned aerial systems (sUAS) to assist 

in the marketing and evaluation of real-estate properties as well as private events. This 

request is motivated by the demand for through topography results of marketable land 

and real estate to effectively and accurately indicate equal market values and 

comparables. While an exemption would not eliminate the current need for in-person 

visual inspection required by various federal regulatory departments, it would allow Star 

City SkyCams to broadly evaluate geographical markets, and market share comparables 

to assist with sUAS, resulting in a safer and more efficient infrastructure network. This 

would also allow Star City SkyCams the ability to provide a unique perspective on 

private events, that in the past were either unsafe to obtain or not possible. Accordingly, 

the grant of an exemption is consistent with Congress’ intent, reflected in Section 333 of 

the FAA Modernization and Reform Act of 2012 (Modernization Act),1 that safe systems 

be permitted in the national airspace prior to the issuance of final regulations governing 

general use of these systems.2 A summary of this request suitable for publication in the

Federal Register is provided as Appendix A.

Appendix B provides the manufacturers information regarding the design, aircraft

performance, and fail-safe features. We have provided manufacturer information related to

operating limitations, normal and emergency procedures, and maintenance and inspection

procedures. As we add aircraft designs, we will update this appendix appropriately.

1 P.L. 112-95, 126 Stat 11, February 14, 2012.

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type

of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, and

operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national

security.

Jayson T. Firebaugh, 

d/b/a Star City SkyCams

74 Chesney PL

Blue Ridge, VA 24064

(540) 819-3473

starcityskycams@gmail.com
Background Information

Star City SkyCams is a sole-proprietorship founded in Q2 of 2014 with the intent to assist 

real estate companies, brokers, appraisers, lenders and private parties the ability to obtain 

aerial visions, both motion and still, for evaluation purposes of their said requirements.

Aerial Operations Intentions

 Provide aerial views of residential property 

listed with the MLS or to be listed

 Provide aerial views of commercial properties 

listed with the MLS or to be listed

 To work directly with Real Estate Brokers, 

Lenders and Appraisers and all of the above 

listed affiliates to obtain aerial views for 

valuations, marketing and overviews of 

topography.

 To work with private parties and provide 

unique still and video of high quality for 

personal use.

As part of this Star City SkyCams is requesting FAA Exemption for sUAS operations for

safety, inspection and video capture usage.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA 

may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an 

exemption is in the public interest. The FAA has imposed a separate requirement in its 

procedural regulations, providing that the petitioner shall explain why granting the

exemption would not adversely affect safety or how the exemption would provide at least

an equivalent level of safety as compliance with the underlying regulation. In this case, 

approval of this exemption would advance the public interest by significantly enhancing 

the safety and efficiency of market comparables and private events by allowing the sUAS 

to accept the liability of the risks involved as the general public would attempt a duplicate 

result. As described more fully below, the requested exemption would permit the

operation of sUAS under tightly controlled conditions, thus ensuring that operations will

not have an adverse impact on safety. Granting an Exemption is in the Public Interest. 

The safety and accuracy that the uSAS can accept allows the general public to avoid 

potential accidents, both private industry and commercial. It provides a more accurate 

layout so fair market values (FMV’s) may be determined in the lending and marketing 

process. By allowing the uSAS to accept these tasks, it allows the general public safety 

to be greatly reduced and allows the property market and industry thrive on a fair and 

level ground.
Granting an Exemption will not Adversely Affect Safety

Star City SkyCams notes that there is no applicable standard for an equivalency

determination. Some have argued that the appropriate standard is that for model aircraft, 

noting that their operations, if conducted for recreational purposes, would fall completely

within the allowable operations for model aircraft. We believe it is difficult to argue that 

there is sufficient correlation between model operations controlled by the Academy of

Model Aeronautics and the ones considered by Star City SkyCams. At the same time, it is 

clear that equivalency cannot be established for traditional, manned civil aircraft because 

the design and use profiles between traditional aircraft and sUAS are simply too different. 

As such, we believe it makes more sense to focus on why the contemplated operations 

would not adversely affect safety, which is all that §11.81(e) requires.

Granting an exemption will not adversely affect safety. Star City SkyCams contemplates

conducting sUAS operations over client owned or controlled land, solely during daylight 

hours, at altitudes well below that which would pose a risk to other aircraft. In general,

sUAS operations are intended to be conducted in areas distant from both congested areas

and airports. The nature of requirements anticipated by Star City SkyCams requires that 

the sUAS be flown at relatively low altitudes and relatively low speeds. Star City

SkyCams expects that in most instances, the sUAS will be flown less than 200 feet from 

the ground level of the PIC along the path of the sUAS. Accordingly, the risk of 

interference with another aircraft is minimal. Star City SkyCams also plans to conduct 

sUAS operations at least 2 miles from any public airports (including heliports). In the 

event an operation needs to be conducted closer to an airport, Star City SkyCams will 

inform the airport operator and airport air traffic control tower of the contemplated 

operation and will comply with any directions issued by air traffic control at that airport.

Approval of exemptions allowing commercial operations of sUASs in aerial 

photography industry will enhance safety by reducing risk. Current operations 

recommend tall extension ladders on steep pitched roofs, or unsafe structures for 

inspection which could cause personal injury. This would also allow prevent private 

parties from inventing ways to get that “perfect” shot, and again let the sUAS take the 

risk. 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 and stable flying features as shown in Apendix B. The sUAS is carried 

to the site of the contracted party requirement. 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 UASs, weighing 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 333 Aircraft Exemption Status exempting 

the applicant from conventional aircraft requirements and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in 

a controlled environment and, as a result, are far safer than conventional operations 

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

people.
The safety of those on the ground is protected by the fact that no one will be allowed into 

the area without the permission of the company. Security will be established for the flight

area as part of the pre-flight control. Each individual within the secure area will be

briefed prior to flight and will consent to being in the area. All others will be excluded 

from the area.

Star City SkyCams initially intends to use a dedicated staff for sUAS operations. All 

operations will be within visual line-of-sight (i.e., no more than approximately 0.5 miles 

from the manipulator of the controls, or pilot in command (PIC)). Each PIC will conduct 

at least three take-offs and landings with the sUAS on which he or she is trained every

90 days. PIC’s will establish their qualifications thru a combination of aeronautical

knowledge, UAS airmanship skills, and verification through testing of flight ability before 

infrastructures operations have commenced. Depending on the type of operation, additional 

ground-based visual observers may be employed as well. These observers will be within 

constant visual line of sight and in constant contact with the PIC. The visual observers 

will assist the PIC in avoiding objects near the sUAS.

There are no standards for either Private or Commercial sUAS pilot certificates. The safe

operation and control of the UAS as described in this application does not depend on the

type of FAA license held by the PIC. Given the restricted and controlled airspace within

which operations will take place, the key factors needed by the PIC are knowledge of the

airspace within which the operation will take place and how that airspace fits into the

National Airspace System (NAS). That knowledge can be and is gained primarily

through ground school and not through flight training in fixed wing or rotor aircraft, nor 

is it dependent on the acquisition of a commercial or private pilot’s certificate. Those

certificates demonstrate knowledge of the factors and skills needed for the safe operation 

of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a

commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or 

ability to safely operate a small unmanned aerial vehicle, operating at 200 AGL or lower, 

within strictly controlled pre-approved airspace. Besides knowledge of airspace

regulations, dexterity in the control and operation of the sUAS acquired from actual

operation of the aircraft is the most important factor in establishing an equivalent level of 

safety.

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant

issues are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what

is being used today to accomplish the same mission, and (3) what precautions will be

taken to ensure the safety of those in the area of operation. We propose that the PIC has 

a minimum of 75 hours of logged sUAS flight time including video and still 

photographic capture; the aircraft be operated within a secure environment; and that no 

one be allowed to enter the secure environment unless they are part of the operation, 

have been fully briefed of the risks prior to operation of the sUAS, and have consented 

to the risks associated with being in the operating area. Should there be a mishap, the 

sUAS being flown pose significantly miniscule threat, as they carry no flammable fuel 

and have a GPS to Home map, which allows the sUAS to return to home should contact 

be lost. They are small in size, and with a low battery will hover to a landing avoiding 

the falling out the sky option. They do not carry a crew or passengers and pose and 

infinitesimal risk to others.
Minimum requirements for the PIC include:

1) 75 hours of logged uSAS Flight Time including still and video capture

2) Have undergone a qualification process as specified in the Flight Operations

& Procedures Manual consisting of a knowledge & skill test of the aircraft to be

used.

3) Maintain an understanding of all associated pre-flight, in-flight and post flight 

checklists.

Star City SkyCams intends to use commercially available sUAS Components for sUAS.

These sUAS systems will be tested for quality & safety before being deployed to the 

field. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

and operates exclusively within a secured area. We have a routine maintenance schedule 

to verify that the sUAS will remain in safe and operational condition. 

Please see Appendix B, for Specific Types of sUAS.

Notes Regarding: 14 C.F.R. Part 21, Subpart H

In accordance with the statutory criteria provided in Section 333 of PL 112---95 in reference to

49 USC 44704, and in consideration of the size, weight, speed, and limited operating area

associated with the aircraft and its operation, we request that this aircraft exemption meets

the conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and

any associated noise certification and testing requirements of part 36, is not necessary.

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft

Given the size of the sUAV, two-inch lettering will be impossible. UA will be identified 

by serial number, registered in accordance with 14 CFR part 47, and have identification (N-

--Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large

as practicable.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

Star City SkyCams request is based on the fact that no airworthiness certificate will be 

issued for the UAS. Star City SkyCams UAS will not require an airworthiness certificate 

in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness 

certificate will not be issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard

Certifications required, the original intent of these regulations was to display an aircraft’s 

airworthiness, certification, and registration documents so they would be easily available

to inspectors and passengers. Based on the FAA Memorandum subject “Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft’s 

control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2)

and 91.203(a) and (b) is not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests
Small UASs, 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. Aircraft being considered for use by Star City SkyCams allow the

UAS Instructor to place the aircraft into ‘loiter’ mode (fixed altitude stationary hold). In

the event of the student losing control, the UAS Instructor can quickly and via alternate

equipment (equipment not in the hands of the student) place the aircraft into a mode that

then allows the instructor to bring the aircraft back into control and back to the predetermined and/or safe landing location.

Star City SkyCams does not describe training scenarios in which a dual set of controls 

would be utilized or required, i.e. dual flight instruction, provided by a flight instructor 

or other company-designated individual, that would require that individual to have fully

functioning dual controls. Rather, Star City SkyCams evaluates the qualification of its 

PICs based on their experience with the UAS to be operated and verifies through testing, 

in lieu of formalized training. As such, Star City SkyCams does not seek relief from 14 

CFR § 91.109.

Notes Regarding § 14 CFR 91.119(b)

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, 

because Star City SkyCams operations will only be conducted within the secured area

described herein.

Star City SkyCams Safety Operations & Procedures Overview:

TechnologyConsiderations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from

highly-reputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the sUAS

loses communications, the sUAS will have capability to return to a pre-determined

location within the Security Perimeter and land.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we

can monitor the scene from the vehicle's perspective for collision avoidance, and to

maintain spatial orientation.

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle

health at all times: speed, altitude, number of GPS satellites (whenavailable),

heading and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2)

link failures occur (highly improbable), vehicle returns automatically to the point of

launch.

8. Altitude information will be provided to the sUAS pilot via a digitallyencoded

telemetric data feed, which downlinks from the aircraft to a ground-based on-screen

display. This altitude information will be generated by equipment installed on board

the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or

radio altimeter, or any combination thereof. Prior to each flight, a zeroaltitude

initiation point will be established and confirmed for accuracy by the pilot.
Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS

to the pilot, thus eliminating the concern of signal severance (flying behind

objects/walls).

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 200 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR

part 45 or as otherwise authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators

(pilot, gimbal op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle

control/communication.

3. A briefing will be conducted in regard to the planned sUAS operations priorto

each day’s activities. It will be mandatory that all personnel who will be performing

duties within the boundaries of the safety perimeter be present for this briefing.

4. The operator will obtain the consent of all persons involved in the sUAS operations

and ensure that only consenting persons will be allowed within 100 feet of the flight

operations.

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

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

7. Pilot and observer will have been trained in operation of UAS generally and

received up-to-date information on the particular UAS to be operated.

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), 

including energy source(s) and equipment. Operations authorized by this petition 

of exemption are limited to the following aircraft described in Appendix B. 

Proposed operations of any other aircraft will require a new petition or a petition 

amendment to this request.

2. The UA may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 200 feet above ground

level (AGL), as indicated by the procedures specified in the operator’s manual. 

All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s State issued identification 

license.

5. All operations must utilize a visual observer (VO). The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times.
6. The operator’s manual included as Appendix C and this petition of exemption 

must be maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in this exemption and 

the procedures outlined in the operator’s manual, the conditions and limitations 

herein take precedence and must be followed. Otherwise, the operator must

follow the procedures as outlined in its operator’s manual.

The operator may update or revise its operator’s manual. It is the operator’s 

responsibility to track such revisions and present updated and revised documents 

to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment. If the operator 

determines that any update or revision would affect the basis for which the FAA 

grants this petition for exemption, then the operator must petition for amendment

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be

contacted if questions arise regarding updates or revisions to the operator’s 

manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition

for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the aircraft is prohibited from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station, if utilized, must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

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

must undergo a functional test flight in accordance with the operator’s manual. 

The PIC who conducts the functional test flight must make an entry in the UAS 

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

flight and aircraft record entry must be added to the operator’s manual.

9. The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the

operator’s manual. At a minimum, requirements for the following must be

included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;
10. The Pilot In Command (PIC) Must have logged the required information as 

set previous in the minimum requirements for a PIC

11. During training, proficiency, and experience-building flights, all persons not

essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119.

12. Prior to operations conducted for the purpose of infrastructure inspection, the

PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAS pilot operating the make and model of 

UAS to be utilized for operations under the exemption and three take-offs and 

three landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and landing currency flights can be conducted under this 

petition of exemption to accomplish the required flight time and 90 day currency.

During training, proficiency, experience-building, and take-off and landing 

currency flights all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this petition of exemption, the PIC 

and VO must have successfully completed a qualification process, as outlined in 

the operator’s manual. As this is a requirement stipulated by the operator, the test

must be developed and implemented by a qualified person designated at the sole

discretion of the operator. A record of completion of this qualification process 

must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of infrastructure inspection, a flight

demonstration, administered by an operator-approved and -qualified pilot mustbe

successfully completed and documented. This documentation must be availablefor

review upon request by the Administrator. Because the knowledge and airmanship

test qualifications have been developed by the operator, and there are no established

practical test standards that support a jurisdictional FAA FSDO evaluation and

approval of company designated examiners, the petitioner will conduct these tests in

accordance with the operator’s manual.

15. The UA may not be operated directly over any person, except authorizedand

consenting personnel, below an altitude that is hazardous to persons or property on

the surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has

safety mitigations for authorized and consenting personnel. At all times,those

persons must be essential to the operations.
Regarding distance from nonparticipating persons, the operator must ensurethat no 

persons are allowed within 500 feet of the area except those consenting tobe

involved and necessary for the flight path operations. Thisprovision may be reduced

to no less than 200 feet if it would not adversely affect safety and the Administrator 

has approved it. For example, an equivalent level of safety maybe determined by an 

aviation safety inspector’s evaluation of flight path area to note terrain features,

obstructions, buildings, safety barriers, etc. Such barriers may protect 

nonparticipating persons (observers, the public, news media, etc.) from debris in the 

event of an accident.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre-determined location within the security perimeter and land or be recovered in

accordance with the operator’s manual.

18. The UAS must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operator’s manual.

19. Each UAS operation must be completed with 25% battery power remaining.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this petition

of exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation.

21. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have identification

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

22. The operator must develop procedures to document and maintain a record of the

UAS maintenance, preventative maintenance, alterations, status of

replacement/overhaul component parts, and the total time in service of theUAS.

These procedures must be added to the operator’s manual.

23. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

24. The operator must develop UAS technician qualification criteria. These criteria

must be added to the operator’s manual.

25. The preflight inspection section in the operator’s manual must be amended to

include the following requirement: 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 operator’s manual.

26. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.
27. At least three days before scheduled uSAS flight as contracted by any party, the

operator of the UAS affected by this exemption must record a plan of activities. The

plan of activities must include at least the following:

 Dates and times for all flights;

 Name and phone number of the operator for the UAS operations conducted

under this petition of exemption;

 Name and phone number of the person responsible for the on-scene

operation of the UAS;

 Make, model, and serial or N-number of UAS to be used;

 Name UAS PICs involved in the flight event;

 A statement that the operator has obtained permission from property

owners and/or local officials to conduct the infrastructure inspectionevent; the list

of those who gave

 Signature of exemption-holder or representative; and

 permission must be made available to the inspector upon request;

 A description of the flight activity, including maps or diagrams of any area,

city, town, county, and/or state over which flight path willbe conducted and the 

altitudes essential to accomplish the operation.

28. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law

enforcement official upon request.

29. The UA must remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultralight vehicles,

parachute activities, parasailing activities, hang gliders, etc.).

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

All operations must be conducted under visual meteorological conditions(VMC).

Flights under special visual flight rules (SVFR) are not authorized.

31. The UAS may not be operated by the PIC from any moving device or vehicle.

32. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

33. The UA may not operate in Class B, C, or D airspace without writtenapproval

from the FAA. The UA may not operate within 5 nautical miles of thegeographic

center of a non-towered airport as denoted on a current FAA-published aeronautical

chart unless a letter of agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by theoperator’s

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

the Administrator upon request.
34. Any incident, accident, or flight operation that transgresses the lateral orvertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe

reported to the National Transportation Safety Board (NTSB) perinstructions

contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not

be conducted until the incident, accident, or transgression is reviewed by AFS-80 and

authorization to resume operations is provided.

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, SKYCAPTURE 

provides the following information:

Contact Information:

Jayson T. Firebaugh d/b/a 

Star City SkyCams, LLC

74 Chesney PL

Blue Ridge, VA 24064

(540) 819-3473

starcityskycams@gmail.com

Regulatory Provisions from which Jayson T. Firebaugh d/b/a Star City 

SkyCams seeks an Exemption

Star City SkyCams believes it may need an exemption from the following 

provisions to conduct the contemplated operations. In some instances, relief is needed 

because relief from another provision renders compliance with the regulation at hand

infeasible.

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)(1)&(2)

14 C.F.R. §91.417(a)&(b)

Star City SkyCams believes an exemption is only needed from the above-listed

regulatory provisions. To the extent that the FAA believes that additional relief is 

required for Star City SkyCams to conduct the operations described here, we request an 

exemption from any such regulatory provisions as well.3

3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as

applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met andwill

require an exemption, Star City SkyCams believes a separate exemption should not be required for

§91.417(a).
The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft fromthe

requirement for an airworthiness certificate based on a consideration of the size,weight,

speed, operational capability of the particular UAS, as well as its proximity to airports and

populated areas. An analysis of these criteria demonstrates that the sUAS operated without an

airworthiness certificate in the areas and under the conditions contemplated by Star City 

SkyCams will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the conditions proposed in this

request.

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption

will be tightly controlled and monitored by the operator and observer. Operations will be

conducted in compliance with the FAA and with local public safety requirements to provide

security for the area of operation as is now done with conventional equipment, infrastructure,

bridge and out building evaluation. These safety enhancements provide an expanded degree

of safety to the inspectors over conventional operations. Lastly, application of thesesame

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 and

inability to carry a substantial externalload.

Given the size and limited operating area associated with the aircraft to be utilized by the

Applicant, this 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 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.
14 C.F.R. §61.113(a) and (b)

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an aircraft

that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of 

an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or 

hire.

*****

Star City SkyCams anticipates initially using a cadre of specially trained staff to 

conduct the sUAS operations. Although Jayson T. Firebaugh holds a Commercial Pilot 

Certificate, other individuals will not hold commercial pilot licenses. The sUAS will not 

carry property for compensation or hire since they will be used solely to assist in 

evaluation of market comparables for real estate purposes and private party contracts; 

however, the employees’ operation of the sUAS will not be incidental to their 

employment with Star City SkyCams, and they will be compensated for such work. 

Without an exemption, the pilot would be required to hold a commercial pilot certificate

under §61.133. However, the risk associated with the contemplated operations is less than 

the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the

permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within 

a geographical envelope under the sole control of Star City SkyCams clients. 

Accordingly, the risk would be limited to Star City SkyCams personnel, who will be 

appropriately outfitted in safety gear, and Star City SkyCams client’s property on the 

ground. Requiring a commercial pilot certificate would provide no appreciable safety 

benefit and would needlessly impose additional cost on Star City SkyCams. Because the 

contemplated operations would not comply with §61.113(b)(1) and none of the other 

exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b).
14 C.F.R. 91.119(c)

§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes:

***

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

*****

Star City SkyCams submits that the only relief it requires from §91.119 is from 

the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for 

fixed wing operations because asset evaluation conducted at 500 feet or higher is

insufficiently distinct to be meaningful. Since operations at this altitude also pose a 

heightened risk of collision with another aircraft, safety can only be assured through the 

grant of an exemption. The anticipated rotorcraft operations should be adequately

addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph 

(a) because an emergency landing of the aircraft due to a power failure will not create an

undue hazard to persons or property on the surface. As noted in the explanation of why

an exemption will not adversely affect safety, Star City SkyCams clients has exclusive 

use of the land over which the sUAS will be operated, and public access is restricted. It 

also has exclusive use of significant portions of land adjacent to the infrastructure and

structures that will be the objects of evaluation and analysis. Star City SkyCams Clients 

tightly control access to land and have the ability to assure that no individuals 

unassociated with the planned operations are on the affected land. As such, the risk of 

injury is minimal. Star City SkyCams does not contemplate conducting operations over 

congested areas, so relief is not requested from paragraph (b).

14 C.F.R. 91.121

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 Check list, confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric

data feed, which downlinks from the aircraft to a ground-based on-screen display.This

altitude information will be generated by equipment installed on board the aircraft, using

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, orany

combination thereof. Prior to each flight, a zero altitude initiation point will be established

and confirmed for accuracy by the pilot.
14 C.F.R. 91.151

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin 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.

(b) No person may begin a flight in a rotorcraft 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, to 

fly after that for at least 20 minutes.

*****

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could 

run out of fuel in the event it has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. Star City SkyCams does not intend to 

use the sUAS for point-to-point flights and will not operate the sUAS beyond visual line 

of sight. Nor will the sUAS require an airport in order to land. Rather, Star City

SkyCams will operate the sUAS using pre-planned flight paths (taking into account 

weather conditions) designed to allow the sUAS to fly to the point of intended landing. 

As such, there is no need for a time- based excess fuel requirement. Rather it should be 

sufficient to require only as much additional excess flight capacity as necessary to safely 

land the sUAS. We believe that a 25% battery reserve is more than sufficient to meet this

objective.
14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

§91.405 Maintenance required.

Each owner or operator of an aircraft –

(a) 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;

*****

§91.407 Operation after maintenance, preventive maintenance, 

rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, 

rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under

§43.7 of this chapter;

*****

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate

an aircraft unless, within the preceding 12 calendar months, it has had 

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by §43.7 of this 

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

*****

§91.417 (a) & (b)

*****

Star City SkyCams believes that an exemption from these three maintenance 

requirements is appropriate because the FAA has not developed maintenance standards 

that would allow an operator to meet the part 91 maintenance requirements. In particular, 

there are no individuals authorized by the FAA to approve a sUAS for return to service

under

§91.407(a) or to conduct the initial airworthiness and annual return to service inspections 

required by §91.409(a). Star City SkyCams will maintain the aircraft as instructed in the

owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft 

until it has reasonably determined that any needed repairs have been made. However, 

because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is

appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address 

provided above should you have any questions or concerns.
Appendix A

Summary for Federal Register Publication

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

Federal Register should the FAA determine that publication is needed.

Petitioner: Jayson T. Firebaugh d/b/a Star City SkyCams, LLC

Sections of 14 C.F.R. Affected:

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

14 C.F.R. §91.417(a)&(b)

Description of Relief Sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 

C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and

91.417(a)&(b) to conduct sUAS operations over Star City SkyCams Client’s owned or

controlled land, solely during daylight hours, to assist in the safe evaluation and analysis

of infrastructure and operations. In general, sUAS operations are intended to be

conducted in areas remote from both congested areas and airports. The nature of

operations anticipated by Star City SkyCams requires that the sUAS be flown at 

relatively low altitudes Star City SkyCams expects that in most instances, the sUAS will 

be flown less than 75 feet from the highest structure along the path of the sUAS and in no 

instances will be flown higher than 200 feet above the ground. Accordingly, the risk of 

interference with other aircraft is minimal.
Appendix B

Specific type(s), make, andmodel

#1 ---DJI Phantom 2 Vision+

See attached manuals
Aircraft

Supported	Battery

DJI 5200mAh LiPo Battery

Weight	(Battery	&	Propellers	included)

1242g

Hover	Accuracy	(Ready	to	Fly)

Vertical: 0.8m; Horizontal: 2.5m

Max	Yaw	Angular	Velocity

200°/s

Max	Tiltable	Angle

35°

Max	Ascent	/	Descent	Speed

Ascent: 6m/s; Descent: 2m/s

Max	Flight	Speed

15m/s (Not Recommended)

Diagonal	motor-motor	distance

350mm

Gimbal Working	Current

Static : 750mA; Dynamic : 900mA

Control	Accuracy

±0.03°

Controllable	Range

Pitch : -90°-0°

Maximum	Angular	Speed

Pitch : 90°/s

Camera Operating	Environment	Temperature

0°C-40°C

Sensor	size

1/2.3"

Effective	Pixels

14 Megapixels

Resolution

4384×3288

HD	Recording

1080p30 & 720p

Recording	FOV
110° / 85°

Remote	

Control

Operating	Frequency

5.728 GHz-5.85 GHz

Communication	Distance	(open	area)

CE Compliance: 400m; FCC Compliance: 800m

Receiver	Sensitivity	(1%PER)

-93dBm

Transmitter	Power

CE Compliance: 25mW; FCC Compliance: 100mW

Working	Voltage

120 mA@3.7V

Built-in	LiPo	Battery	Working	Current/Capacity

3.7V, 2000mAh

Range	

Extender Operating	Frequency

2412-2462MHz

Communication	Distance	(open	area)

500-700m

Transmitter	Power

20dBm

Power	Consumption

2W

DJI	VISION	

App

System	Requirement	Of	Mobile	Device

iOS version 6.1 or above/ Android system version 4.0 or above

Mobile	Device	Support

 iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, 

iPod touch 5 (available but not recommended: iPad 3, iPad 4, iPad mini)

 Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of 

similar configuration