US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA
Reform Act and Part 11 ofthe Federal Aviation 

### February4, 2016
Eric Hyde Sky HydeAerial Images 800 Highway409 Slaughter, LA 70777 chyde@turner-industries.com

U.S Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590 ·
Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)
The exemption is in the public interest. Pursuantto the authority contained in 49 U.S.C. 106(f), 40113, and 44701.
Dear Siror Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS) 

### Eric Hyde hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated UAS, provided such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.
Thankyou in advance foryour consideration.

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### Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following areas:
1. Aerial Photography 

### IVideography 

### 2. Building Surveying 

### 3. Public and Private Events 

### 4. RoofTop Inspections 

### 5. Site Inspections 

### 6. Sidewalk 

### I Parking Lot Inspections

As described fully below, the requested exemption would permit the operation of designated UAS as setforth in this document undercontrolled conditions in the NASthat would be a) limited b) 

### controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness of UAS operations and enhance safety to aid in fulfilling the SecretaryofTransportation's (the FAAAdministrator's) responsibilities to "

....establish requirements for the safe operation of such aircraft systems in the national airspace system."
The name and address ofthe applicant is
Eric Hyde Sky HydeAerial Images 800 Highway409 Slaughter, LA 70777 ehyde@turner-industries.com
From which the exemption is requested: 

### 14 CFR Part

### 21 subpart 

### H

14 CFR 

### 45.23 (b) 

### 14 CFR 

### 61.113 (a) & 

### (b) 14 CFR 

### 91.7 (a) 

### 14 CFR 

### 91.9 (b) 

### (2) 14 CFR 

### 91.103 14 CFR 

### 91.109 14 CFR 

### 91.119 (c) 

### 14 CFR 

### 91.121 14 CFR 

### 91.151 (a) 

### 14 CFR 

### 91.203 (a) 

### 14 CFR 

### 91.405 (a) 

### 14 CFR 

### 91.407 (a) 

### 14 CFR 

### 91.409 (a) 

### 14 CFR 

### 91.417 (a)

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### As 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), 11213to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804), There is 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 bythis exemption is in the public interest.
Eric Hydewill operate one or more ofthe following model UAS.
OJI Phanton 3, Standard, Professional and Advanced. OJI Inspire 

### 1, OJI Inspire 

### 1 Pro and DJI Inspire 1 V20. Safety requirements. The approval of this application presents no national security issues. Regarding the level ofsafetysurrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the applicant graciously requests that the FAA grant the requested exemption. 0


### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere towhen conducting commercial operations underthe FAA issued exemption as setforth in the Flight Operations Manual (FOM) include: 0



### 1. The UAS will weigh significantly less than 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more than 50 mph.
3. Flightswill be operated within line ofsight ofthe Pilot in Command (PIC) and/orVisual Observer (VO).

4. Maximum flighttime foreach operational flightwill be depending on the UAS model in operation, butwill notexceed 30 minutes. Flightswill beterminated at25o/o battery power reserve or 30 minutes offlight time whichever occurs first.

5. Flights will be operated at an altitude ofno more than 400 feetAbove Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned. Page 3 of96. Minimum crewfor each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged
a minimum of20 hours on the designated UAS.

8. A safety briefing will be performed priorto each day'sflights consisting ofall the days' Production activities.

9. All flight activities will be logged.

10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

12. Flights will not be closerthan a 5 mile radius ofthe geographic center/Airport.

13. The operatorwill do a pre check ofaircraft priorto each flight. And log each flight.

14. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as U.S. Department ofTransportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to date information forthe particular UASto be operated.

16. The PIC and VO will be able to communicate by voice and/or radio atall times.

17. The PIC will abide by all rules.

18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously.

19. The UAS will have the capability to abort a flight in case of emergencies with an automated "Return Home and Land" function.

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, oremergencies such as low battery. Page 4 of921. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA mustbe 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 NTSBWeb site: www.ntsb.gov.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemptionfrom Part21 SubpartH meetsthe requirements ofan equivalent level ofsafety under Part 11 and Section 333ofthe ReformAct. The FederalAviationAct (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exemptaircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated
areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate in the restricted env.ironment 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. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operatorand underthe requirements and in compliancewith local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials orflammable liquid fuels, and inabilityto carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: 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 mustalso display on that aircraft neareach entranceto the cabin, cockpit, orpilotstation, in letters not lessthan 2 inches normorethan 6 inches high, the words "limited/' "restrictedf "light sport/' "experimental/' or "provisionalf as applicable. 14 C.F.R. § 45.23 (b). Marking ofthe AircraftThe regulation requires: When marks include onlythe 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 entranceto the cabin, cockpit, or pilotstation, in letters not lessthan 2 inches normorethan 6 inches high, the words "limited/' "restricted/' "light sport/"'experimentall' or "provisional/' as Page 5 of9applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed asthe UAS will have no entrance to the cabin, cockpit orpilotstation on which the word "Experimental" can be placed. Given the size of the UAS, two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 

### (f). US Department of Transportation February 20, 2015 The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 

### (f) wherethe pilot, observerand othersworking with the UASwill see the identification of the UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers norproperty. The risks attendanttothe It is believed thatthe operation and limitationsset forth in the FOM will equateto the safe operation ofthe UAS.

14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issuedforthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safetywill be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft. Section 91.9 (b) {2) provides: No person mayoperate a U.S. registered civil aircraft

... (2) Forwhich anAirplane or Rotorcraft Flight Manual is not required by§21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, notonly because there is no pilot on board, but because there is
no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping theflight manual atthe ground control pointwherethe pilot flying the UAS will have immediate accessto it.

14 C.F.R. §91.103: Preflight Action. This regulation requires each pilot in command to take certain actions beforeflightto insurethe safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC willtake all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS

**~nd** remotely piloted aircraft, bytheirdesign do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions forflighttraining withoutfully functional dual controls for a number of aircraft and forflight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. Page 6 of914 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes foroperation ofcivil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route oraltitudes prescribed for helicopters bythe FAA. Asthis exemption is for
a UASthat is a helicopterand the exemption requests authorityto operate ataltitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allowsuch operations. As setforth herein, the UAS will never operate at higherthan 400AGLwith the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feetAGL,the UASwill notbe operated morethan 200feetabovethe highestpointon the structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained consent. Theequivalent level ofsafetywill beachieved given thesize, weight, and speed ofthe UAS aswell as the location where it is operated. Noflightwill be taken withoutthe permission ofthe property owner or local officials. Because ofthe advance notice tothe property owner and participants in the filming activity, all affected individuals will be
aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraftweighting far morethan the maximum SSibs. Proposed herein and the lack of flammable fuel, any risk associated with these operations is far lessthan those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UASwill ensureseparation betweenthese UASoperations and the operations ofconventional aircraftthat must complywith Section 91.119.

14 C.F.R. §91.121 AltimeterSettings. 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 UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved bythe operator, pursuanttothe safety check listand liveflight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14C.F.R. §91.151(a): Fuel Requirementsfor Flight in VFRConditions Section 91.151 (a) prohibits an individualfrom beginning "aflight in an airplane underVFRconditions unless (considering wind and forecastweather conditions) there is enough fuel toflyto the first pointofintended landing, and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least45 minutes." The applicant believesthat an exemption from 14 CFR §91.151(a) falls within the scope ofpriorexemptions. Operatingthe UAS in atightlycontrolled areawhere onlypeople and propertyowners orofficial representativeswho have signed waiverswill be allowed does notengenderthetype ofrisks that Section 91.151 (a) was intended to alleviate given the size and speed ofthesmall UAS. Theapplicantbelievesthatan equivalent level ofsafety
can be achieved by limiting flights to 30 minutes or 25% of battery power- whichever happens first. This restriction would be more than adequate to return the UAS to its Page 7 of9

### planned landing zone from anywhere in its limited operating area.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate (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 atthe cabin orcockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed 551b limitand is operated withoutan onboard pilot. As such, there is no abilityorplaceto carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilotflying the UAS will have immediate access to them, to the extentthey are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance Inspections. These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspectormaintainthe aircraft in compliancewith Part43. Given thatthese sections and Part43 apply onlyto aircraftwith
an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level ofsafetywill be achieved becausethe UAS isvery limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feetAGL. The operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostfamiliarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, and a link on last page, the operator will ensure that the UAS is in working order priorto initiating flight and perform required maintenance needed.
Additional Information.
The applicant Eric 

### Hyde believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of 2012, providing sufficient justification for the granting of commercial operations of the applicant's UAS. I also feel it's in the public's interest on granting the exemption, as we can educate them atthe same time. And all the positive sides ofthe newtechnology and the level ofsafety.
Page 8 of9The applicant , Eric Hyde , requests your respective approval of this Section 33 3 exemption petition request. Thank you for your attention in this matter . Please notify Eric Hyde of your actions , and or approvals . Thank you , for your interest in this request. **~** Eric Hyde Pag e 9 of 9