### SkyPix LLC 

### Petition 

### for Exemption - 

### Section 333 

### Title 14

### CFR 111.81 (FAA)



### August 

### 26,2015
US Department ofTransportation Docket Management System 1200 New Jersey Ave, SE 

### Washington 

### D.C. 20590 Electronically submitted 

### via regulations.gov from: SkyPix 

### 3 Chipman Heights, 

### Middlebury 

### VT 05753 klemwav@omail.com 802-989-6081 www.skvoixvt.com SkyPix is requesting a petition for 

### exemption (Section 333) to

### flysmall UAS for the purpose 

### of infrastructure inspection 

### work such as solar

### farms,wind 

### turbines and construction projects as

### wellas real estate and other aerial photography/videography. SkyPix isfocusing on supporting energy and infrastructure since 

### this isa 

### critical part 

### of our nation's economic 

### success. Using UAS,

### wecan help contractors 

### and managers inspect aging infrastructure at reduced risk

### while providing a new level of information not previously 

### accessible. Flying UAS also produces 

### considerably less noise and air pollution 

### than alternative means of inspection 

### currently

### available. We are seeking exemption 

### from several 

### CFRs noted below 

### that remain burdensome 

### to SkyPix doing business and 

### growing. We

### will provide supporting documentation 

### that SkyPix can provide 

### a level of safety greater than or equal to

### the rules from 

### whichwe are seeking 

### exemption.This request is in

### the public interest, our interest and

### the interest of our local 

### communities here in rural Vermont and 

### New 

### England. We have completed due 

### diligence and have noticed profound positive impacts related to safety, economics and information quality.

Aircraft: SkyPix is

### currently in

### the process 

### of 

### registering (1) DJI Phantom 3

### Advanced UAS
The specific sections of

### Title 14 of

### the Code 

### of Federal Regulations 

### fromwhich SkyPix requests exemption: 

### 14CFR:Part21 SubpartH; 61.113(a)&(b); 

### 91.121;91.151;91.405(a); 91.407(a)(1); s1 .4oe(aXl ) and (2); 

### 9t.417(a)&(b).
For each 

### CFR I have 

### created a response addressing: 1) Rule is burdensome 

### to SkyPix

## 2) SkyPix 

### can provide a level of safety greater than or equal to

### the rule from 

### whichwe

are seeking exemption. 3)

### This request is in

### the public interest (SkyPix, public and community)



### RE: 

### Exemptlon Request 

### Sectlon 333 

### of FAA 

### Retorm 

### Act of FARs 

### and 14 CFR 

### Part 11.
14CFR

### 21 H -

### Aimorthrness Certificates sets

### forth requirements 

### for procurement 

### of necessary airworthiness 

### certificates in relation 

### to FAR $91.203(a)(1). The size, 

### weight and operational area 

### of my UAS permits exemption 

### from Part 21 because 

### my UAS meets, and 

### exceeds, an

### equivalent level of 

### safety pursuant 

### to Section 333 of

### the Reform

### Act. The FAA is authorized 

### to exempt aircraft from 

### the airworthiness certificate requirement under both the

### Act (49 U.S.C. S

### 44701 (f)) and Section 333 of

### the Reform 

### Act. Both pieces 

### of legislation permit 

### the FAA to 

### exempt UASfrom 

### the airworthiness 

### certificate requirement inconsideration of the weight, size, speed, maneuverability and proximity 

### to areas such as airports and 

### dense populations. 

### SkyPix UAS meets or exceeds each of

### the

### elements. Subpart Hestablishes the procedural requirements for 

### the issuance of airworthiness 

### certificatesas required by FAR 

### 91.203(a)(1). Given 

### the size and limited operating area associated with 

### the aircraft to be utilized by SkyPix, an exemption 

### from 

### Part2l Subpart H meets 

### the requirements of an 

### equivalent level of safety 

### under Part 11and Section 333 of

### the Reform

### Act. The 

### FederalAviation Act (49 USC S 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. ln all cases, an analysis ofthese criteria demonstrates that 

### the SUAS operated 

### without an airworthiness 

### certificate in

### the restricted 

### environment, and under the conditions proposed, 

### will be at least as safe or safer than aconventional aircraft operating 

### with an airworthiness certificate without 

### the restrictions and conditions proposed.
61.113 (a)(b) - 

### Private 

### Pilot Privileges

### and Limits These regulations 

### limit private pilots 

### to non-commercial 

### operations. Because 

### the SUAS 

### will not carrya pilot or passengers due to

### the SUAS's size, weight, speed and operational capabilities; and since operations 

### will occur in

### tightly controlled 

### and limited airspace, 

### the proposed operations 

### can achieve 

### the equivalent 

### levelof safety of current operations that 

### currently require a

### commercial pilot license 

### while still benefitting 

### the public good.
91.121 regarding 

### altimetersettlngs is inapplicable insofar as 

### our UAS utilizes electronic 

### global positioning systems 

### with a barometric 

### sensor. This regulation requires 

### each person operating an aircraft 

### to maintain cruising altitude by reference 

### to an altimeter 

### that isset "...tothe elevation ofthe 

### departure airport or an appropriate altimeter setting available before 

### departure." As

### the SUAS may not have 

### a barometric altimeter, but instead a GPS altitude readout, an

### exemption may be 

### needed. An

### equivalent level of safety 

### will be achieved bythe 

### operator by confirming the altitude 

### of

the launch site shown on

### the GPS altitude indicator before flight. 91.151(a) 

### prescribes that no 

### person may begin 

### aflight in an 

### airplane under visual 

### flight rules (VFR) 

### conditions unless (considering wind

### and forecastweather 

### conditions)there is enough 

### fuelto flyto

### the first

### point of intended landing and, assuming normal 

### cruising speed

--- (1) During the day,tofly

### afterthat for at least 30 minutes. (2)

### At night,tofly

### after that for

### at least45 minutes.
This regulation prohibits 

### an individual 

### from beginning a

### flight inan 

### airplane under VFR 

### conditions unless (considering 

### wind and

### forecastweather conditions) 

### there isenough fuel tofly to the

### first point 

### of intended Ianding, and 

### assuming normal cruising speed, 

### fly thereafter 

### for 30 minutes during the day and 

### 45 minutes 

### during night 

### operations. The battery powering 

### the SUAS provides only 

### 25 minutes of powered 

### flight, making it impossible 

### to meet

### the requirements of a30 or 45 minute reserve. Given 

### the limitations ofthe SUAS's 

### flight area and

### the location 

### of its operations 

### within a predetermined area, a longer time frame for

### flight in daylight VFR 

### conditions is 

### reasonable. An 

### equivalent level of safety can be achieved by limiting flights to 25 minutes 

### or 25/o of battery power (whichever occurs 

### first). This restriction 

### would be more 

### than adequate 

### to return 

### the SUAS 

### to its planned landing zone 

### from anywhere in its limited operating area.
Mai 

### ntenance I

### nspections

91 .405(a) requires, 

### in pertinent part,

### that an aircraft operator or owner shall have 

### that aircraft inspected 

### as prescribed in 

### Subpart E of

### the same part and 

### shall, between required inspections, except as provided in paragraph (c) ofthe same 

### section, have 

### discrepancies repaired as prescribed in Part43 ofthe chapter. 

### 91.407(a)(7/ prohibits, in pertinent part, any person 

### from operating an aircraft 

### that has undergone maintenance, preventative maintenance, rebuilding or 

### alteration unless it has been approved 

### for return to seruice by

### a person authorized under 543.7 ofthe same chapter. 91.409(a)(1) 

### and (2) prescribes 

### that no person may operate any 

### aircraft unless, within 

### the preceding 12

### calendar months, it has had 

### an inspection for 

### the issuance of an airworthiness certificate in accordance 

### with 

### Part21 of

### this chapter. 

### 91.417(a)(b) The above 

### cited regulations require, among other 

### things, aircraft owners and operators 

### to "have [the] 

### 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 Part43 of

### this chapter...." These regulations only apply 

### to aircraft 

### with an airworthiness 

### certificate. They 

### will not, 

### therefore, apply 

### to SkyPix 

### UAS. However, as a

### safety precaution, SkyPix operators willinspect 

### all UAS before and after each 

### flight in accordance with 

### the DJI Phantom 

### 3 user



### manual. All maintenance required 

### will be performed by SkyPix authorized operators in accordance 

### with DJI Phantom 3

### operator's 

### manuals. ln addition, 

### proper preflight and post

### flight inspections 

### will be performed 

### on a regular basis anytime 

### the UAS is 

### used. lf mechanical issues arise, 

### the UAS 

### can be

### safely landed immediately and

### will be operated at or below 

### 400'AGL. Given that 

### the operator is

### the person most familiar with 

### the aircraft and best suited 

### to maintain 

### the aircraft in an airworthy 

### condition provides the 

### equivalent level of safety. 

### UAS 

### Equipment SkyPix 

### will utilize 

### a DJI Phantom 3

### Advanced 

### UAS. SkyPix PIC will operate 

### the UAS in a safe manner 

### fully aware of

### the NAS, minimizing risk in

### the air and onthe ground. With

### full VLOS 

### and redundant systems 

### on board, as well as GPS/GLONASS, 

### the UAS 

### will be carefully 

### flownto inspect infrastructure and 

### energy installations, 

### conduct real estate photography and videography, GIS and construction 

### sites. SkyPix shall officially register 

### the UASwith 

### the FAA before any

### flights commence. 

### The DJI Phantom 

### 3 is less

### than 50 pounds and 

### flies under 

### 30 MPH at an altitude below 

### 400'AGL. Flights

### will be

### terminated and

### the UAS returned 

### to starting point if battery power 

### falls below

### 25%. The UAS isequipped 

### with a return home feature 

### that isalso automatically activated inthe event of a malfunction. 

### Procedures PreflighVpost 

### flight checklists 

### will be

### followed IAW

### the UAS user manual and SkyPix 

### operating 

### procedures. Maintenance repairs and battery usage 

### will be 

### logged IAWthe UAS user manual and SkyPix 

### operating procedures. 

### Radlo Frequencies
2.400GH2-2.483GH2 radio

### frequencieswill be used to communicate and provide video 

### feeds fromthe UAS

### to aground 

### station. Allfrequencies and usage will comply with 

### existing FCC regulations. 

### Pilot in Command (PlC)

### andVisual Observer (VO) SkyPix 

### founder and CEO,

### Thomas KIemmer, 

### will be

### the PIC of 

### all UAS operated by 

### SkyPix. Thomas Klemmer is currently employed 

### fulltime as a Captain 

### for NetJets, lnc. Captain Klemmer holds anATP (certificate #13306176) with five 

### type ratings, and is currently assigned as acaptain on

### the Gulfstream 

### G-lV 

### SP. Captain Klemmer has logged 

### over 11,000 hours, holds 

### a First 

### Class Medical certificate 

### and FCC Radio Telephone 

### Operators 

### Permit. He attends aircratt recurrent every 

### six months at 

### FlightSafety lnternational 

### (FSl) in Savannah, GA.All Visual 

### Observers (VO)

### for SkyPix 

### will understand 

### the basic UAS operational

characteristics, 

### safety protocols and have site specific knowledge 

### to conduct successful missions 

### with an emphasis on 

### safety. VOs 

### will be responsible 

### for assisting 

### the PIC by providing 

### visual guidance regarding 

### any hazards 

### to safety, 

### obstacles, people or 

### property. Constant radio communication will be maintained between 

### the PIC and VO. 

### Operation 

### of UAS

### I Prlvacy 

### / Public Safety SkyPix isseeking to work 

### with customers inthe construction, energy and real estate market primarily in

### the state of Vermont to

### staft. Our 

### goal is

### to provide aerial inspection of solar farms, wind 

### farms, construction 

### sites, mining operations, GIS, agriculture and real estate photography and 

### videography. Our 

### state's infrastructure requires 

### constant maintenance and inspection, especially as new

### forms of energy are developed and 

### implemented. SkyPix feels 

### that incorporating 

### the use 

### of UASwill greatly 

### complement existing 

### technologies and 

### equipment being used today,

### while simultaneously adding a higher level of safety and a much smaller carbon 

### footprint as compared 

### to other inspection systems 

### currently in 

### use. ln addition, our customers 

### will benefit from considerable cost 

### savings using 

### a UAS in place of

### other more expensive inspection systems. SkyPix will conduct its operations inVMC during 

### daylight hours outside of 

### Class B airspace and a minimum of 5 miles

### from Class C/D airports unless 

### approved inthe 

### COA. ln addition, 

### flight altitudes 

### will be at or below 

### 400'AGL, and all operations 

### will be conducted 

### via line of sight 

### (LOS). ln addition, any 

### required NOTAMS

### will be completed 

### 48 hours prior toflight.
All potential hazards 

### to beavoided 

### will be clearly outlined and identified 

### during preflight safety 

### briefings. See and 

### avoid rules 

### using LOS and VOs

### will be employed 

### to minimize 

### any impact to

### the 

### NAS. Further, permissions 

### will be

### obtained prior to operating 

### over private andlor public spaces.
COA 

### will be 

### secured before any

### flights inaccordance with 

### the latest FAA

### guidance. All aspects of a

### flight including, but not limited 

### to, NOTAMS, TFRs, 

### weather and airspace 

### will be considered 

### as part of

### the preflight 

### safety briefing. 

### ln 

### Closing:



## - SkyPix 

### will conduct all operations 

### with an emphasis on safety 

### first and

### foremost 

### "Allflights will be preceded by a

### thorough preflight safety briefing



## . All operations will avoid populated 

### /congested areas 

## * Proper notifications will be made inadvance 

### to local

### / legal authorities 

## " SkyPix 

### willfile any 

### necessary NOTAMS as required by

### the FAA 

### * Checklists 

### will be

### developed and used by all SkyPix pilots SkyPix anticipates 

### that most of

### the areas being filmed 

### / inspected 

### will be

### on private 

### property. Written consent 

### will be

### obtained by

### the property owner 

### or his/herrepresentative prior

### to conducting aerial 

### operations. ln addition, the

### flight area 

### shall be

kept clear of 

### all people except 

### SkyPix personnel. As such, approval of

### this petition presents no riskto

### the public privacy.


### Reference 

### tosimilar petltions:
Planet lnhouse, lnc. 

### -- Exemption 

### #12593, Docket

### #FAA-2015-2412 August 

### 25,2015 lmage Effects -- Exemption 

### #12583, Docket 

### #FAA-2015-2018 August 

### 25,2015 AirShark LLC -- Exemption #11651 , Docket

### #FAA-2015-0664 May 21 

### ,2015 

### Suppofiing Documents:
* Phantom 3

### Advanced User Manual * Phantom 

### 3 Safety Guidelines " Phantom Training Guide "AMA Safety Code

SkyPix 

### would like to thank you for your consideration 

### while processing our petition 

### for 

### exemption. Wewill 

### gladly modify or amend our petition 

### as necessary 

### to illustrate our commitment 

### to achieving an 

### equivalent level of

### safety. Please feel free to contact our office if

### further information or 

### clarification is required.



### Thomas Klemmer Founder and CEO, 

### SkyPix LLC 

### 3 Chipman Heights 

### Middlebury 

### VT 05753 802-989-6081 klemway@gmail.com Respectfully,