June 23, 2015

Exemption No. 11877

Regulatory Docket No. FAA–2015–0596

Mr. Daniel L. Kofford

President

Mr. Charles D. Daubs

CEO

Sky Vision Services, LLC

4425 Front Street

Suite 759

Shasta Lake City, CA 96019-9904

Dear Messrs. Kofford and Daubs:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated February 28, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Sky Vision Services, LLC (hereinafter petitioner or operator) for an exemption. 

The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct recording videography/cinematography and/or still photographs.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot FY690S.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Sky Vision Services, LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Sky Vision Services, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Tarot FY690S 

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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 FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. 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.

15. 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. 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.

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

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

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 must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Page 1

Application for Exemption From FAA Regulations In Order

to Operate a Small Unmanned Aircraft System (sUAS)

Pursuant to Section 333 of the FAA Modernization and

Reform act of 2012 and Sections of 14 CFR

February 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, application is hereby made for Sky Vision Services, LLC (SVS) for

an exemption from the listed Federal Aviation Regulations (FARs) to operate a

commercial sUAS for the purpose of recording videography/cinematography and/or still

photographs to enhance the visual appeal and sale-ability of real estate listings in the

Northern California area.

As described more fully below, the requested exemption would permit the operation of a

small, unmanned and relatively inexpensive sUAS in the National Air Space (NAS)

thereby complying with Congress’s mandate and helping to fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements

for the safe operation of such aircraft systems in the national airspace system.” 

Submitted by:

Sky Vision Services, LLC

4425 Front Street

Suite 759

Shasta Lake City, CA 96019-9904

Daniel L. Kofford Charles D. Daubs

President CEO

skyvisionservices@gmail.com skyvisionservices@gmail.com

530-356-1961 530-524-0102

Daniel L Kofford Charles D Daubs
Page 2

Table of Contents

Company History ........................................................................................ 3

Owner Biography ........................................................................................ 3

Radio Controlled Aircraft Flying Skill ........................................................... 3-4 

Aircraft Description ...................................................................................... 4-5 

 

Flight Log and Documentation .................................................................... 5-6

Risk Management ....................................................................................... 6-7

List of CFR Regulations .............................................................................. 7

Exemption Requests ................................................................................... 7-14

Summary Statement ....................................................................................14

Public Benefits Statement ........................................................................... 15

Appendix
Page 3

Company History:

Sky Vision Services, LLC was founded in February 2014 by co-owners Daniel L.

Kofford, President and Charles D. Daubs, CEO. At present there are no other owners or

employees. The sUAS would be flown primarily by Mr. Daubs acting as Pilot in

Command (PIC) with Mr. Kofford acting as a ground based visual observer (VO).

Owner Biography:

Mr. Kofford is a licensed Airline Transport Pilot as well as a Certified Flight Instructor,

Instrument Flight Instructor, Multi Engine Instructor, and has over 30 years of flight

experience operating under FAR §91, FAR §135 and FAR §121. Mr. Kofford served as

the Chief Pilot and Check Airman for a FAR §135 scheduled and on-demand charter

company and is currently a Captain for a regional airline carrier. In addition Mr. Kofford

holds a Masters degree in Business Administration.

Mr. Daubs is a licensed, single engine, private pilot. He has been building and flying

radio control models for over 30 years, including fixed wing and rotary wing aircraft.

He is a member in good standing with the Academy of Model Aeronautics (AMA) and

has been since 1982. Mr. Daubs attended college for several years at the University of

California, Fresno and holds an AA degree.

Both Mr. Kofford and Mr. Daubs are retired law enforcement professionals with over 50

years of combined full time, law enforcement experience.

Radio Controlled Aircraft Flying Skills:

During the 30 plus years of flying radio controlled aircraft, Mr. Daubs has flown high

wing entry level airplanes, shoulder wing intermediate skill level airplanes, low wing

advanced skill level airplanes and high performance, semi-scale war bird airplanes. All

aircraft have had a minimum of "full control functions" to include throttle, rudder,

elevator and aileron control. The advanced models have had additional control of flaps

and retractable landing gear. In all, Mr. Daubs has flown well over 20 different styles

and models of fixed wing aircraft.

Mr. Daubs also assembled and flew a rotary wing aircraft for two years. This was a

typical helicopter model; equipped with a single main rotor and tail rotor and full flight

controls.

Mr Daubs has acted as a training pilot for students wishing to learn to fly radio

controlled aircraft. In that capacity, Mr Daubs has assisted in the training of over 20

student pilots over the past 30 years.

Mr. Daubs composed a training manual for a local radio control model club to be used

for flight training. It followed very closely the training that a private pilot would receive

during his training. The manual outlined basic aircraft operation, principles of flight,

traffic pattern procedures, safety and emergency procedures, take off and landing
Page 4

procedures and obstacle avoidance. It also included a pre-flight checklist and pilot log.

In all, during the past 30 plus years it is estimated that Mr. Daubs has well over 750

hours of PIC flying time in radio controlled aircraft. This can only be estimated as there

has never been a requirement to log flight hours in radio controlled model aircraft flown

as a hobby.

Aircraft Description:

The aircraft that SVS would be operating is a Tarot FY690S hexacopter with an overall

diameter of approximately twenty nine (29) inches and weighing fifty three (53) ounces

(gross flying weight is under twenty pounds). It is constructed primarily of two (2)

carbon-fiber, centrally located, main boards and six (6) carbon-fiber booms radiating 

out from the central main frame. It will be powered by rechargeable batteries carried

on board.

An electric motor is mounted at the outboard end of each boom driving alternating

clockwise and counter-clockwise pitched propellers, for a total of six (6) units. This

allows full control of yaw, pitch and roll by regulating the speed of each motor/propeller

unit. The motors are controlled by individual solid state electronic speed controls, all

maintained and controlled via a main controller and an Inertial Measurement Unit (IMU).

Main flight control will be provided by a state of the art, Spektrum DX-9 DSMX-9 radio

control transmitter linked to an onboard receiver operating in the 2.4GHz band (this

frequency is approved by the FCC for radio controlled aircraft). Also on board will be a

WooKong-M Multi Rotor Autopilot System linked with a barometric pressure altimeter

and G.P.S./Compass unit providing in-flight telemetry.

The WooKong M autopilot system translates inputs from the Radio control transmitter

through the receiver and controls the motors on the craft. With additional input from the

altimeter, G.P.S. and IMU the WooKong is capable of being operated in three different

modes: 1) Full control by PIC, 2) Altimeter hold and 3) Full autopilot.

In mode 1 the PIC has full control of the craft. In mode 2 the WooKong maintains

altitude and allows the craft to be flown in a very stable fashion. Altitude can still be

adjusted by the PIC but the flight characteristics in this mode are very smooth. In the

final mode 3, the WooKong takes over full control of the craft. This mode is used in

case of signal interruption or minor fault in the system. When mode 3 is engaged the

craft will cease all forward, lateral and vertical flight, stabilize it’s self and return to the

point of origin of the flight and land autonomously. Mode 3 can also be selected by the

PIC via the radio transmitter.

Additional safety features include redundant battery voltage warning devices. As part of

the WooKong system a large LED panel is installed and oriented so that it is visible

while the craft is in flight. This LED panel flashes different series and colors of lights to

indicate different status of the electronics. Chief among them are confirmation that

G.P.S. satellites have been located and fixed for navigation and a continuos readout of
Page 5

the voltage level of the main flight battery. (Refer to the diagram in the Appendix) A

secondary voltage monitoring and warning device is also used. This unit plugs directly

into the main flight battery and supplies a digital readout of the pack voltage. When the

pack voltage drops to within 25% of capacity an audible alarm sounds to warn the PIC

of the low battery voltage.

There are also features available on the Spektrum Transmitter than can be used to help

prevent a flight lasting past the safe voltage limit of the primary flight battery. A

countdown timer can be set to a pre-determined amount fo time. When that time is

reached, both an audible alarm and verbal warning will be sounded advising of such. 

An under belly, centrally located, auxiliary mounting platform will be utilized for a two

axis, gimbal stabilized, camera mount. Currently a GoPro camera is planned for use.

The canopy of the aircraft will be clearly marked with our company name, address and

contact information (following requirements already in place by the AMA).

A ground based station will be utilized primarily by the VO during all operations. An 8"

LCD video screen will be used to display live video feed and telemetry information being

broadcast by the sUAS. Included in the telemetry information will be the altitude,

direction of flight and speed of the sUAS in “real time”. This information will be super

imposed over the live video feed showing the on-board camera view.

In addition, all maintenance logs, flight logs and other required legal documents will be

kept with the ground station. This will ensure that they are available for inspection

should the need arise.

SVS will utilize various weather and radar applications on our iPad and smart phones

prior to and during operations to assist in confirming suitable weather conditions exist to

execute and maintain an operation. We will also be using a digital anemometer for

current wind speed and direction readings. 

Mr. Daubs assembled the airframe and installed all operating systems and controls on

the Tarot FY690S used by SVS. He has test flown the aircraft for airworthiness as well

as conducted more than 10 hours of practice flights to become fully familiar with the

aircraft's performance, maneuverability and flight characteristics. He has conducted

well over 3 take offs and landings within the past 30 days.

Flight Log and Documentation:

The Tarot FY690S is not a "buy and fly" sUAS as are many less expensive sUAS

currently being used. It was designed and manufactured with the intent of the end user

to build and equip it with electronics of their own choosing. As such there is no

manufacturer supplied owner's manual or operating manual. SVS has developed 

documents specific to the equipment installed on our sUAS.
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Documentation will be maintained detailing the construction and maintenance of the

aircraft to include modifications, damage and repairs. A flight log will be kept to record

the date, time, location, duration and other pertinent information related to each flight. 

A separate log will be maintained for tracking individual battery charging and

discharging information to assist in identifying when a battery has reached the end

of it's useful life.

Screen shots of the flight log and copies of the maintenance log are in the Appendix.

Risk Management:

Each flight will be performed during daylight hours following established Visual Flight

Rules (VFR) and conditions. There will be a minimum of two (2) persons present; one

designated as the pilot in command (PIC) and the other as the visual observer (VO).

The PIC and VO will be in constant verbal contact with each other during all flights. The

sUAS will be flown within the visual line of sight (VLOS) of the PIC and VO. All flights

will be flown at or below 400 feet above ground level (AGL) in keeping with existing

established practices. No flights will be conducted within the controlled airspace of an

active airport.

The subject property owner and surrounding neighbors will be advised that a sUAS

operation is going to take place. This will help to ensure that no one is startled by the

sight of the sUAS and will assist with crowd control. Additionally, as much as is possible,

all non essential ground personnel will be kept out of the flight area for the duration of

the flight.

Prior to each flight a thorough pre-flight inspection will be conducted in a manner

typical with full scale aircraft, checking to be sure that the airframe and all components

are in a proper and good state of repair, all subsystems are operating properly and that

the radio control system is communicating with the sUAS. In the event of an in-flight

loss of radio control signal between the sUAS and the transmitter, the on board central

computer system has a built in "return to home" feature. That feature will stop all vertical

and lateral flight, take over control of the sUAS and return it to the location the flight

originated, landing it completely autonomously.

An on-board management system confirms that the computer system is operating

properly and has established a good link to multiple G.P.S. satellites. A system of

flashing and steady LED lights visually confirms the status with the operator. This LED

is oriented so that it can be observed while the sUAS is in flight.

The sUAS will also be fitted with an on-board battery management system which will

display a digital readout of the voltage of the primary flight battery. In addition the

system will sound an audible warning to indicate a low voltage condition. In such event,

the flight will be terminated and the sUAS will be returned to the point of origin and

landed.
Page 7

********************

Sky Vision Services, LLC (SVS) is seeking exemption from the following regulations:

14 CFR Part 21; 14 CFR §45.23 (a) & (b); 14 CFR §47 Subpart A, B and C;

14 CFR §91.119; 14 CFR §91.121; 14 CFR §91.151 (a); 14 CFR §91.203 (a) & (b); 14

CFR §91.405 (a); 14 CFR §91.407 (a) (1); 14 CFR §91.409 (a) (1) & (2); 14 CFR

§91.417 (a) & (b) and a COA.

Following each annotated regulation is the explanation requesting each exemption. 

• 14 CFR Part 21 - Certification Procedures for Products and Parts

Part 21 prescribes, in pertinent part, the procedural requirements for issuing and

changing design approvals, production approvals, airworthiness certificates, and

airworthiness approvals. 

As stated by the FAA in a prior request for exemption (ASTRAEUS AERIAL exemption

#11062 and TRUDEAU #11138) exemption is not necessary from this section as it

would not directly apply to the operation of a sUAS due to it’s limited size, weight,

operating conditions and design safety features.

• 14 CFR §45.23 (a) & (b) - Display of marks; general.

(a) Each operator of an aircraft must display on that aircraft marks consisting of

the Roman capital letter “N” (denoting United States registration) followed by the

registration number of the aircraft. Each suffix letter used in the marks displayed

must also be a Roman capital letter.

(b) When marks include only the 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 letters

not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Pertaining to 14 CFR §45.23 (a) an exemption is sought for the following reasoning. 

The sUAS that SVS plans to operate differs in no way from a regular radio controlled

(RC) aircraft in it’s manufacture, build/assembly or flight. There are no requirements for

RC aircraft to be registered and marked with any registration numbers. It also appears

that the requirements of the following, 14 CFR §47, subpart A, B and C are contrary to

the design and manufacture of our sUAS. 
Page 8

Pertaining to 14 CFR §45.23 (b) , as previously ruled in (ASTRAEUS AERIAL #11062)

an exemption from this section is not necessary.

• 14 CFR §47, Subpart A, B and C - Aircraft Registration 

Relief is sought under these sections as follows: Our sUAS is a kit, manufactured

outside of the United States, does not have any registration, serial numbers, model

number, or any identification numbers affixed to it by the manufacturer. There is

nothing in place in local, state or federal government for the owner of a sUAS to have

his craft examined and have any identifying serial numbers assigned or affixed to it. 

In order to register any aircraft, AC form 8050-1 must be filed. That form requires the

listing of the serial number of the aircraft to be registered in addition to other

requirements that cannot be meet. Without any such serial number the requirement to

have the sUAS registered appears to be unobtainable.

• 14 CFR §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.

SVS is requesting exemption from 14 CFR §91.119 (c). Our intention is to fly our sUAS

above and around real property taking aerial video to be used to enhance real estate

listings. The altitude such operations would be conducted would not exceed 400' AGL. 

The owner’s of the real property and structures we would be flying above and around

would have prior notice and have given prior authorization for our operations. All

persons present at the time of the operation would be notified of the impending

operation and cautioned to either leave the immediate area or to remain inside until the

operation is finished (excluding those persons actively involved in the operation). 

As indicated in our earlier statement, every effort would be made to keep unauthorized

persons out of the immediate area and at least 500' away. In the event that the 500'

zone was violated, the operation would cease immediately and the sUAS landed.

Given the limited size, weight, operating conditions as set forth herein and the design

safety features of our sUAS the equivalent level of safety will be achieved during all

operations. Compared to flight operations of fixed wing aircraft or rotary wing aircraft
Page 9

carrying a pilot and or crew, the potential danger is far less in the same circumstances

than with our sUAS.

• 14 CFR §91.121 - Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating—

(1) Below 18,000 feet MSL, to—

The sUAS that SVS will be operating is equipped with a barometric altimeter and a

G.P.S. antenna/compass. Information from these two sources is fed directly into the onboard flight controller for use during flight. This information is also relayed, via real time

video feed, to the ground station for both the PIC and VO to monitor during the flight

operation. Thus a constant confirmation of the sUAS altitude will be readily available at

all times.

Although this is not typical of the equipment required in fix wing aircraft an equivalent

level of safety will be achieved by the PIC and VO at all times. Therefore, SVS is

requesting exemption from14CFR §91.121.

• 14 CFR §91.151 (a) - 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; or

(2) At night, to fly after that for at least 45 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.

Regarding relief from 14 CFR §91.151 (a). Our sUAS carries no fuel. Instead it is

battery powered. As explained earlier within this document, our sUAS is equipped with

a dual system of alerting the PIC and VO of a low voltage condition in the main flight

battery. Namely, a digital readout and audible sounding alarm will alert the PIC and VO

when the on board battery voltage reaches 25% or less capacity. A second visual

warning device, the LED, will flash a warning indicating the same condition has been

reached.
Page 10

In the event either of the two visual warnings or audible warning is detected, the

operation will be terminated and the sUAS returned to land immediately. Given the

restrictive operating area that these operations would be carried out, the 25% battery

level affords more than sufficient time to safely return and land the sUAS.

Given that similar exemptions have been granted under similar conditions (exemptions

ASTRAEUS #11062 and TRUDEAU #11138) an exemption to these regulations is

sought.

• 14 CFR §91.203 (a) & (b) - Civil aircraft: Certifications required.

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S.

airworthiness certificate used to comply with this subparagraph (except a

special flight permit, a copy of the applicable operations specifications

issued under §21.197© of this chapter, appropriate sections of the air

carrier manual required by parts 121 and 135 of this chapter containing

that portion of the operations specifications issued under §21.197©, or an

authorization under §91.611) must have on it the registration number

assigned to the aircraft under part 47 of this chapter. However, the

airworthiness certificate need not have on it an assigned special

identification number before 10 days after that number is first affixed to the

aircraft. A revised airworthiness certificate having on it an assigned special

identification number, that has been affixed to an aircraft, may only be

obtained upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for

operation within the United States, the second copy of the Aircraft

registration Application as provided for in §47.31©, or a registration

certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The sUAS operated by SVS weighs less than 20 pounds and is operated without an onboard pilot and as such there is no provision for carrying the required documents as

outlined under this regulation.

An equivalent level of safety will be achieved by keeping these or similar documents at
Page 11

the ground station during any operations. They will be readily available for inspection by

any so authorized official requesting to inspect them.

In keeping with other exemptions (ASTRAEUS #11062 and TRUDEAU #11138) SVS is

requesting exemption from 14 CFR §91.203 (a) & (b).

• 14 CFR §91.405 (a) - 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;

• 14 CFR §91.407 (a) (1) - Operation after maintenance, preventive maintenance,

rebuilding, or alteration.

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

preventive maintenance, rebuilding, or alteration unless—

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

under §43.7 of this chapter;

• 14 CFR §91.409 (a) (1) & (2) - 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.

• 14 CFR §91.417 (a) & (b) - Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration

and records of the 100-hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an aircraft.

The records must include—
Page 12

(I) A description (or reference to data acceptable to the

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving

the aircraft for return to service.

(2) Records containing the following information:

(I) The total time in service of the airframe, each engine, each

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time

since the last inspection required by the inspection program under

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD)

and safety directives including, for each, the method of compliance,

the AD or safety directive number and revision date. If the AD or

safety directive involves recurring action, the time and date when

the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for

each major alteration to the airframe and currently installed

engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be

retained until the work is repeated or superseded by other work or for 1

year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be

retained and transferred with the aircraft at the time the aircraft is sold.
Page 13

(3) A list of defects furnished to a registered owner or operator under

§43.11 of this chapter shall be retained until the defects are repaired and

the aircraft is approved for return to service.

Regarding 14 CFR §91.405 (a); 14 CFR §91.407 (a) (1); 14 CFR §91.409 (a) (1) (2) and

14 CFR §91.417 (a) & (b); an exemption is sought from these sections. The

manufacturer of our sUAS does not offer any documentation regarding regular

maintenance schedules and suggested maintenance. As such it is the responsibility of

SVS to create and use a similar maintenance log. 

As described earlier, SVS will utilize a maintenance and repair log that will fully

document any maintenance, upgrades or repairs performed on their sUAS. Additionally

a flight log will be used to fully document every flight conducted by the sUAS outlining at

a minimum the date, time, location, duration and any other pertinent information of said

flight. It will be the responsibility of the PIC to ensure the sUAS is flight worthy prior to

any operation by conducting a pre-flight check as outlined in the Pre Flight Check List

developed by SVS.

By following these restrictions an equivalent level of safety will be achieved in ensuring

that the sUAS is maintained in an airworthy condition and is checked to be fully

operational prior to any flight.

• Certificate of Waiver or Authorization (COA) - The COA will require the operator

to request a Notice to Airman (NOTAM), which is the mechanism for alerting other

users of the NAS to the UAS activities being conducted.

An exemption is being sought from obtaining a COA based on the following information

and belief. The sUAS that SVS would be operating is no larger than the vast majority of

radio controlled (RC) aircraft currently being flown as a hobby by thousands of people

across the United States. RC aircraft are similar to sUAS in that they are unmanned

and are operated remotely via radio transmitted signals. 

Under agreement between the FAA pursuant to Advisory Circular 91-57, Model Aircraft

Operating Standards, and the AMA safety guidelines for operating RC aircraft, it is

agreed that RC aircraft would not be flown above 400' AGL, would weigh less than 55

pounds and would not be flown in any controlled airspace or interfere with the flight path

of any full scale aircraft. SVS has proposed the same restrictions apply to it’s sUAS.

Full scale aircraft operating in the NAS are prohibited from flying below 500' AGL except

under certain conditions such as takeoff and landing or after obtaining an exemption (14

CFR §91.119 (b)). This alone creates a 100' safety zone in altitude between legally

operating full scale aircraft and legally operating RC aircraft or sUAS.
Page 14

There is no requirement for any RC aircraft or pilot of such aircraft to obtain a COA nor

to file a NOTAM prior to any flight. Requiring such would overwhelm the ATC system

with such notices, thus rendering them less effective by shear numbers.

Operating a sUAS as SVS is proposing would not differ in any substantial manner from

operating any other RC aircraft, other than it’s use for commercial purposes. The fact

that the operator is being compensated for flying the sUAS has no impact on the

physical presence of the sUAS in the NAS or how it is safely operated. A more practical

solution would be to place a requirement on the operator of a sUAS to check for

NOTAMs involving full scale aircraft operating in the area prior to any sUAS operations.

This is something that SVS would be more than willing to do and abide by.

********************

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the

Federal Registry if needed.

Sky Vision Services, LLC (SVS) is seeking exemption from the following regulations:

14 CFR Part 21; 14 CFR §45.23 (a) & (b); 14 CFR §47 Subpart A, B and C;

14 CFR §91.119; 14 CFR §91.121; 14 CFR §91.151 (a); 14 CFR §91.203 (a) & (b); 14

CFR §91.405 (a); 14 CFR §91.407 (a) (1); 14 CFR §91.409 (a) (1) & (2); 14 CFR

§91.417 (a) & (b) and a COA.

Granting these exemptions would permit SVS to operate a sUAS weighing less than 20

pounds for the primary purpose of recording aerial videography/cinematography and/or

still pictures for the purpose of enhancing real estate listings of property and/or homes

for sale.

The operation of said sUAS conducted within the strict conditions set forth would

provide an equivalent level of safety supporting the grant of exemptions sought. 

Additionally by granting an exemption from Part 21 would allow the operations outlined

to be conducted for commercial purposes.

Due to the limited size, weight, operating conditions and design safety features of the

sUAS result in a safer operation than those of fulls scale aircraft being operated for the

same purpose.
Page 15

Public Benefits:

Shasta County has been a hub for growth and recreation in California for many past

decades. The diverse natural resources of the area have been a large factor in

attracting people to the north state. In the mid to late 1980's, the city of Redding (the

largest city in Shasta County) had a population of approximately 50,000 people and

covered approximately fifty square miles. Today, Redding's population has grown to

nearly 100,000 people and encompasses over sixty five square miles.

With both Lake Shasta and Wiskeytown Lake offering water sports activities and

abundant fishing and the surrounding forested mountains offering camping, hunting

and outdoor recreation, the north state is growing rapidly. With this growth comes the

need for more development in both the business sector and residential housing. With

the recent upturn in the economy the Redding area is beginning to enjoy more growth

again. 

Traditionally more expensive fixed wing and rotary wing aircraft have been the only

option for aerial surveying and photography. This method is inherently dangerous for

not only the pilots and crews of the aircraft but the general public in the unfortunate

event of a failure resulting in a crash by the aircraft in use. The biggest danger is in the

fuel used by these aircraft. The fuel is highly combustible and often results in setting off

uncontrolled fires at the scene of a crash.

The use of a battery powered sUAS puts no crew in danger (it is unmanned) and poses

no immediate fire danger in the case of a crash (it is battery powered). Due to the

relatively small size of the sUAS the possibility of collateral damage to structures or the

public in the event of a crash is also greatly reduced, if not eliminated. The cost to

operate and maintain a sUAS is only pennies on the dollar compared to full size aircraft. 

The granting of this exemption would afford local realty companies a more affordable

and safer alternative to acquire aerial videography/cinematography or still photography

to help enhance real estate listings and advertising in order to assist sales. This would

benefit the community as a whole by helping to increase home sales, increase

spending in the local economy and generate increased tax revenue at the local, state

and federal level. The exemption would also aid the general public in acquiring a better

knowledge of the geographical layout of the surrounding area and the accessibility of

the area's recreational diversity thus ameliorating the service industry it supports.

Another ancillary benefit would be an increase in the general public's knowledge and

understanding of integrating the use of sUAS into every day life in keeping with the

intent of the Reform Act.
Page 16

Appendix

• Tarot FY690S Airframe

• Basic airframe under construction

• Dimensions and 2 Axis Gimbal Mount with Camera

• The WooKong M Multi Rotor Control System 

• Schematic of WooKong Components

• LED Status Chart

• LED Flight Status Chart

• Single Flight Log 

• Total Flights Log 

• Total Flight Time on sUAS Log

• Battery Use Log

• Pilots License Scans

• Maintenance Log

• Pre Flight Check List
Page 17

Tarot FY690S multi-rotor sUAS airframe
Page 18

Basic airframe under construction with motors installed on the booms
Page 19

Typical dimensions, overall gross weight,

as flown by SVS

Tarot 2 Axis, Gimbal Stabilized

Camera Mount

Shown with GoPro Camera

installed - mounts under the

airframe
Page 20

The WooKong M Multi Rotor Control System main components
Page 21

Schematic of installation of WooKong Components
Page 22

LED Status Chart
Page 23

LED Flight Status Chart
Page 24

Representative Copy of “Single Flight” Log Entry
Page 25

Representative Copy of “Total Flights” Log Entry
Page 26

Representative Copy of “Total Flight Time” on sUAS Flight Log Entry
Page 27

Representative Copy of “Battery Log” Log Entry
Page 28

Scans of Pilots Licenses/AMA Membership

Daniel Kofford

Charlie Daubs
Page 29

Maintenance Log

This log is to used to document all builds, upgrades, repairs and maintenance performed

on the sUAS used by SVS, the Tarot FY690S.

DATE BUILD, UPGRADE, REPAIR, MAINTENANCE DONE

Feb. 2014 Purchase of major components begins, Tarot FY690S

March 2014 Continued purchase of components

April 2014 Build of Tarot FY690S begins

May 2014 Main air frame completed

May 2014 Installation of electronics begins

June 2014 Build Complete

06/13/14 First Test Flight was successful!

06/14/14 Changed Flight Batteries to higher capacity

06/21/14 Second Test Flight successful!

09/20/14 Installed On-Board Camera Mount, 2 Axis Gimbal w/GoPro Camera

09/23/14 Installed Video Equipment On-Board

09/27-28/14 Maintenance Done – All screws checked, all equipment checked for solid

mounting, all electrical connections checked, CG checked and confirmed,

propellers checked for damage and balanced, motor bearings oiled

11/29-30/14 Maintenance Done – All screws checked, all equipment checked for solid

mounting, all electrical connections checked, CG checked and confirmed,

propellers checked for damage and balanced, motor bearings oiled

11/30/14 New propellers installed

01/13/15 Retractable landing gear installed, CG checked

01/29/15 Maintenance Done – All screws checked, all equipment checked for solid mounting,

all electrical connections checked, CG checked and confirmed, propellers checked for

damage and balanced, motor bearings oiled

02/27/15 Second receiver installed for control of camera and retractable landing gear
Page 30

sUAS Flight Check List

n Primary Flight Batteries Charged

n Radio Control Transmitter/Receiver Batteries Charged

n Base Station Video Receiver Batteries Charged

n Components of sUAS Installed Properly, Secured

n Components of sUAS Are Wired Properly

n Activate Transmitter/Receiver – Confirm Radio Connection

n Activate sUAS – Confirm:

1. G.P.S. Satellite Connection

2. No Errors in LED Display

3. Primary Flight Battery Voltage

4. Video Link Established

5. Camera Gimbal Control Established

6. Motors Operate Properly

n Area Clear for Take Off