# Petition for Exemption

in Accordance with

14 CFR Part 11 and Section 333 of Public Law 112

- 95



# From

14 CFR Part 21, Subpart H; 61.113(a) and (b) 91.7(a); 91.103(b); 91.119(c); 91.121; 91.151(a ) ( 1); 91.405(a) 91.407(a ) ( 1); 91.409(a ) ( 1) and (2) 91.417 (a) And (b)



# Submitted To

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



# by

SkyCentric LLC 7406 Chapel Hill Road, Suite C Raleigh, North Carolina 27607

July 15 , 2015Sk yCentric LLC

- Petition for Exemption i 1 

# Table of Contents

A. INTRODUCTION

................................ ................................ ................................ ... 1

A.1 Petitioner

................................ ................................ ................................ ................................ ..................... 1

A.2 Intended Operations

................................ ................................ ................................ ................................ .. 1

A.3 Sk yCentric’s Unmanned Aircraft Systems (UAS)

................................ ................................ ................... 2

A.4 Relief Sought

................................ ................................ ................................ ................................ ............... 2



### B. STATUTORY AUTHORITY FOR EXEMPTIONS

................................ ........... 2

B.1 Hazard to Users of the NAS or to the Public

................................ ................................ ........................... 4

B.2 Threat to National Security

................................ ................................ ................................ ....................... 4

B.3 Airworthiness Certification

................................ ................................ ................................ ....................... 4



### C. PUBLIC INTEREST

................................ ................................ ........................... 5

D. REGULATIONS FROM WHICH RELIEF IS SOUGHT

...................... 11

D.1 14 CFR Part 21, Subpart H: Airworthiness Certificates

................................ ........................... 11

D.2 14 CFR 61.113(a) and (b): Private P ilot P rivileges and L imitations: Pilot in C ommand

............. 12

D.3 14 CFR 91.7(a): Civil Aircraft A irworthiness

................................ ................................ .................... 12

D.4 14 CFR 91.103(b): Preflight Action

................................ ................................ ................................ ...... 13

D.5 14 CFR 91.119(c): Minimum Safe Altitudes

................................ ................................ ....................... 13

D.6 14 CFR 91.121: Altimeter Settings

................................ ................................ ................................ ....... 15

D.7 14 CFR 91.151(a) (1): Fuel Requirements for F light in VFR C onditions

................................ ...... 15

D.8 14 CFR 91.405(a); 407(a)(1); 409(a)(1) and (2); 417(a) and (b): Maintenance Requirements

... 16



### E. REGULATIONS FROM WHICH RELIEF IS NOT SOUGHT

...................... 18

E.1 14 CFR 45.23(b): Marking of the Aircraft

................................ ................................ ........................... 18

E.2 14 CFR 91.9 (b)(2): Civil A ircraft F light M anual, M arking, and P lacard R equirements

............. 18

E.3 14 CFR 91.109: Flight Instruction

................................ ................................ ................................ ........ 19

E.4 14 CFR 91.203(a) and (b): Carrying C ivil Aircraft C ertification and R egistration

..................... 19



### F. PRIVACY

................................ ................................ ................................ ............... 20

G. SUMMARY FOR PUBLICATION IN THE FEDERAL REGISTER

............ 20

H. CONCLUSION

................................ ................................ ................................ ...... 20

ATTACHMENT A: SkyCentric LLC’s Handbook for Civil Operations of Unmanned Aircraft Systems (UAS)

................................ ................................ ............... 22Sk yCentric LLC

- Petition for Exemption 1 1



## A. INTRODUCTION

Pursuant to 14 Code of Federal Regulations (14 CFR) part 11 and Section 333 of the Federal
Aviation Administration (FAA) Modernization and Reform Act of 2012 (Public Law 112

- 95),
SkyCentric LLC (“ SkyCentric ”) hereby applies for an exemption f rom the Federal Aviation Regulations (“FARs”) listed in T able 2 , to allow c ivil operation of its Unmanned Aircraft System s (UAS) Phantom 2, Phantom 3, Spreading Wings S900, and Spreading Wings S1000

, manufactured by DJI Innovations, so long as such operations are conducted within and under the
conditions outlined herein or as may be established by the FAA as required by Section 333 of

Public Law 112

- 95 or as later modified by SkyCentric under the app roval of the FAA subsequent

to future amendments.

Using as guide prior petitions for exemption and their corresponding FAA rulings, SkyCentric is
proposi ng actions that will allow the civil o perations of its UAS to achieve an equivalent level of
safety or that will meet the intent of (1) the airworthiness provisions of 14 CFR part 21; (2) airman
certification provisions of 14 CFR part 61; and operating limitations of 14 CFR part 91

.

In the following sections, SkyCentric discusses the actions that it propo ses to take to ensure that
its UAS operations do not create a hazard to the users of the N ational Air Space (N AS ) or the
public, or pose a threat to national security. SkyCentric also discusses how its UAS civil operations
will be of benefit to the public

.



### A.1 Petitioner

The name and address of the petitioner is:

SkyCentric LLC 7406 Chapel Hill Road, Suite C Raleigh, North Carolina 27607

Point of Contact: Karla Kassebaum

Vice President of Operations

Office: (919) 410

- 600 2 karla@skycentric.com www.skycentric.com



### A.2 Intended Operations

This exemption will allow SkyCentric LLC to use its UAS to safely, efficiently, and economically
acquire aerial imaging and data for real estate, architecture, aerial and land surveying, engineering,
construction and development, insurance, and marketing purposes.Sk yCentric LLC

- Petition for Exemption 2 2



### A.3 SkyCentric ’s U nmanned Aircraft Systems (U AS )

SkyCentric LLC is seeking exemption to opera te the UAS listed in Table 1, all of which are
manufactured by DJI Innovations

. The UAS identified in Table 1 weigh less than 55 lbs, h a ve a maximum flight speed well below 87 knots (100 mph or 44.8 m eters pe r second), and are powered
by Lithium Ion batteries. Technical specifications for the UAS listed in Table 1 may be found in
Appendix A, “Specifications for SkyCentric LLC’s Unmanned Aircraft Systems (UAS) Used for
Civil Operations” of the attached “ SkyCentric’s Handbook for Civil Operations of Unm anned Aircraft Systems.”

Table 1. SkyCentric’s UAS Covered in this Petition



### UAS NAME TYPE

PHANTOM 2 Quadcopter

PHANTOM 3 Quadcopter

SPREADING WINGS S900 Hexacopter

SPREADING WINGS S1000 Octocopter



### A.4 Relief Sought

Table 2 lists the regulations from which SkyCentric LLC is seeking relief. Each of these is

discussed in detail in Section D, “Regulations f rom W hich Relief is Sought,” along with
SkyCentric LLC’s proposed actions to provide an equivalent level of safety or to me et the
intent of the regulation.

Table 3 lists regulations from which other petitioners have sought relief, but from which SkyCentric is not seeking relief either because (1) they are not applicable to SkyCentric’s planned
operations, or (2) because the FAA has determined that relief is not necessary. To ensure that the
FAA does not consider this an oversight on the part of SkyCentric, Section E of this petition
discusses each of the regulations in Table 3, the reason why SkyCentric is not seeking relief, and
actions that SkyCentric proposes to take to ensure that the intent of the regulation is met, or that
its UAS operations provide an equivalent level of safety.



## B. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This

statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the

Act, including UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate. The Administrator may grant an exemption from a requirement of a
regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716Sk yCentric LLC

- Petition for Exemption 3 3

of this title if the Administrator finds the exemption to be in the public interest. 49 USC
44701(f)

. See also 49 USC §4471 l (a); 49 USC 44704; 14 CFR 91.203(a) (l).

Table 2 : Regulations from Which SkyCentric LLC is Seeking Relief



### 14 CFR PART REGULATION DESCRIPTION

PART 21 AIRWORTHINESS CERTIFICATION

21, SUBPART H CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS, AIRWORTHINESS

CERTIFICATES

PART 61 CERTIFICATION: PILOTS, LIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

61.113(a) and (b) PRIVATE PILOT PRIVILEGES AND LIMITATIONS; PILOT IN COMMAND

PART 91 GENERAL OPERATING AND FLIGHT RULES

91.7(a) CIVIL AIRCRAFT AIRWORTHINESS 91.103(b) PRE

- FLIGHT ACTION 91.119(c) MINIMUM SAFE ALTITUDES

91.121 ALTIMETER SETTINGS 91.151(a)(1) FUEL REQUIREMENTS FOR FLIGHTS IN VFR CONDITIONS 91.405(a) MAINTENANCE REQUIRED 91.407(a)(1) OPERATION AFTER MAINTENANCE 91.409(a)(1) and (2) INSPECTIONS 91.417(a) and (b) MAINTENANCE RECORDS REQUIRED

Table 3 : Regulations from Which SkyCentric is NOT Seeking Relief



### 14 CFR PART SUMMARY OF REGULATION

PART 91 GENERAL OPERATING AND FLIGHT RULES

91.203(a) and (b) CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION

91.9(b)(2) CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT

91.9(c) / 45.23(b) MARKING OF THE AIRCRAFT

91.109(a) FLIGHT INSTRUCTION

In order to determine whether certain UAS may operate safely in the NAS pursuant to section 333

of Public Law 112

- 95, the Secretary must find that the operation of the UAS would not: (1) create

a hazard to users of the NAS or to the public; or (2) pose a threat to national security. The Secretary

must also determine whether small UAS operations pose a safety risk sufficient to require

airworthiness certification.

Section 333(c) of Public Law 112

- 95 further states that if t he Secretary determines that a UAS
"may operate safely in the national airspace system, the Secretary shall establish requirements for
the safe operation of such aircraft in the national airspace system."Sk yCentric LLC

- Petition for Exemption 4 4



### B.1 Hazard to Users of the NAS or to the Public

Section 333 of Public Law 112

- 95 requires the Secretary to determine whether the operation of the

UAS would create a hazard to users of the NAS or the public. The two primary s afety concerns

associated with U AS operations are: (1) the ability to “see and avoid” other aircraft with no pilot
on board; and (2) the operator losing positive control of the airc raft. SkyCentric will mitigate these

concerns by adhering to the provisions listed in Table 4.

The light weight of SkyCentric’s UAS coupled with the provisions listed in Table 4 and in the attached “SkyCentric’s Handbook for Civil Operations of Unmanned Aircraft Systems (UAS),”
significantly reduce the risk posed by SkyCentric ’s proposed UAS operations when compared with
other categories of aircraft that weigh more, and fly highe r and f aster. Therefore, SkyCentric ’s
UAS operations would not create a hazard to users of the NAS or to the public.



### B.2 Threat to National Security

Section 333 of Public Law 112

- 95 also requires the Secretary to determine whether the operation

of the UAS would pose a threat to national security. The FAA has mitigated these threats by
limiting UAS operations to daylight and only within visual line of sight of the P ilot

- I n

- C ommand
(PIC) and /or the V isual O bserver (VO) . The UA S must also be registered with the FAA and display

its FAA

- issued registration marking prominently on the aircraft.

In addition, the FAA requires that the PIC of the UAS hold either an airline transport, commercial,
private, recreational, or sport pilot certificate. The process f or obtaining this certificate includes a

TSA

- review under 49 USC 46111, intended to screen out airman

- certificate applicants posing a
security risk. These provisions, coupled with those contained in Table 4 and in the attached “SkyCentric’s Handbook for Ci vil Operations of Unmanned Aircraft Systems (UAS),” which
SkyCentric will follow for all c ivil operations of its UAS , will ensure that SkyCentric’s operations

will not pose a threat to national security.



### B.3 Airworthiness Certification

Section 333(b) (2) of Public Law 112

- 95 requires the Secretary to determine whether UAS
operations pose a safety risk sufficient to require airworthiness certification. In previous exemptions, as well as in the preamble of the FAA’s Notice of Proposed Rule Making (NPRM)

[Docket No.: FAA

- 2015

- 0150; Notice No. 15

- 01] published on February 15, 2015, the Secretary

has determined that airworthiness certification and any associated noise certification and testing
requirements of part 36 are not necessary for UAS due to their small size, light weight, low

- speed,

and their limited allowable operating area.Sk yCentric LLC

- Petition for Exemption 5 5

To ensure that the aircraft is in condition for safe flight, SkyCentric will follow the provisions contained in Table 4, “SkyCentric LLC’s Provisions to Mitigate Safety and Security Risks and
Comply with FAA Requir e ments ,” paying particular attention to Provision 3, “UAS Maintenance
Provisions” and 5, “Pre

- Flight Inspections, Assessment, and Checks Provisions .” These provisions

are also contained in “ SkyCentric’s Handbook fo r Civil Operations of Unmanned Aircraft Systems
(UAS), ” a copy of which is attached to this petition as Attachment A.

Because the provisions listed in Table 4 and in the attached Handbook will ensure that the UAS
is in a condition for safe operation and that the risk posed by SkyCentric’s UAS is significantly

lower than the public risk posed by other groups of aircraft, pursuant to section 333(b) (2) of

Public Law 112

- 95, airworthiness certification would be unnecessary for SkyCentric’s UAS.



## C. PUBLIC INTEREST

This application for exemption is expressly submitted to fulfill Congress' goal in passing Section
333(a) through (c) of Public Law 112

- 95

. This law directs the Secretary to consider whether

certain U A S m ay operate safely in the NAS before completion of the rulemaking required

under Section 333 of the Law . By granting this exemption, the FAA will fulfill Congress's intent
of allowing UAS to operate with significant safety precautions in low risk environments.

The use of UAS to safely, efficiently, and economically acquire aerial imaging and data for real
estate, architecture, aerial and land surveying, engineering, construction and development,
insurance, and marketing purposes can significantly reduce the risk to workers arisin g from

falls while inspecting, surveying, or monitoring site progress , or attempting to take quali t y images of hard to reach places

. UAS can take video and photos, and collect data o f high and

hard

- to

- get

- to areas that otherwise would require worker inspection. Falls are the leading source

of workplace fatality and injury on construction site s 1 and using UAS for aerial imaging could
significantly reduce the risk for workers performing inspections, ultimately sav ing

workers’ lives.

Additionally, UAS could replace the use of helicopters and small aircraft to inspect and monitor

sites and take aerial images and data. SkyCentric’s UAS weigh less than 55 lbs and carry
no explosi ve materials or flammable liquid fuels on board, as opposed to much larger,
conventionally powered small aircraft. The use of UAS over helicopters presents a substantial
increase in safety for workers and the public. Lastly, the rechargeable Lithium Polymer batteries used to power SkyCentric’s UAS ha ve a reduced environmental impact over fossil fuel burned to

operate much heavier small aircrafts.

1 “ Commonly Used Statistics", Occupational Safety and Health Administration. Available at: https://www.osha.gov/

oshstats/ commonstats.htmlSkyCentric LLC

- Petition for Exemption 6

Table 4 : SkyCentric ’s Pro visions to Mitigate Safety and Security Risks and to Comply with FAA Requirements



### SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

1. General Provisions

 SkyCentric will conduct its UAS civil operations in accordance with the “blanket” Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA) issued concurrently with its grant for exemption. Skycentric will apply for a new or an amended COA if it intends to
conduct operations that cannot be conducted under the terms of its “blanket” COA.

 SkyCentric will remain clear of all Temporary Flight Restrictions.

 SkyCentric will not operate its UAS in Prohibited Areas, Special Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone, as depicted on charts available at http://www.faa.gov/air_traffic/flight_info/aeronav/ . Additionally, SkyCentric will beware of and avoid

other areas identified in Noti ces to Airmen (NOTAMS) which restricts operations in proximity to Power Plants, Electric Substations, Dams, Wind Farms, Oil Refineries, Industrial Complexes, National Parks, The Disney Resorts, Stadiums, Emergency Services, the Washington DC Metro Flight

R estricted Zone, Military or other Federal Facilities.

 The maximum weight of SkyCentric’s UAS, including payload, will be less than 55 lbs. This is consistent with the 55

- lb weight limit in the

definition for small unmanned aircraft contained in Public Law 112

- 95, sec. 331(6).

 The airspeed of SkyCentric’s UAS will not exceed the maximum operating airspeed recommended by the aircraft manufacturer, whi ch are well below the FAA’s maximum allowable limit of 87 knots (100 mph).

 SkyCentric’s UAS will not be opera ted unless they are in condition for safe operation, as determined by SkyCentric’s preflight checks and
regular maintenance procedures.

 SkyCentric will discontinue the flight of its UAS if conditions (i.e. unpredicted obstacles or emergencies) develop such that continuing the flight would pose a hazard to other aircraft, people, or property.

 The UAS will have enough power to operate for their intended operational time and an additional five minutes.

2. UAS Registration and Markings Provisions

 SkyCentric will register its aircrafts with the FAA in accordance with 14 CFR part 47.

 The aircraft identification number (N

- number) will be displayed on each aircraft in as large a manner as practicable. The location of the
display will be as prescribed in 14 CFR part 45 subpart C, for the type of aircraft.

3. UAS Maintenance Provisions

 SkyCentric will maintain its UAS in a condition for safe operation by performing the manufacturer’s recommended maintenance at

manufacturer

- recommended intervals.

 SkyCentric will follow the UAS manufacturer maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

components.

 SkyCentric will comply with all applicable UAS manufacturer safety bulletins.

 SkyCentric will conduct a functional test flight ea ch time the UAS undergoes maintenance or alterations that affect the UAS operation or flight characteristics. The functional test flight will be conducted by the Pilot

- In

- Command with a Visual Observer, at least 500 ft away from otherSkyCentric LLC

- Petition for Exemption 7



### SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

people, in a manner t hat will not pose an undue hazard to persons or property.

4. Pilot

- In

- Command (PIC) and Visual Observer (VO) Provisions

 SkyCentric’s UAS will be operated by a Pilot

- In

- Command (PIC) holding either an airline transport, commercial, private, recreational, or s port pilot certificate. The PIC will be designated before the flight and will not be allowed to transfer his or her designation for the duration of the flight.

 The PIC will 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 will meet the flight review requirements specified in 14 CFR part 61.56 in an aircraft in which the PIC is rated on his or her pilot

ce rtificate.

 SkyCentric will not permit any PIC to operate its UAS unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated. This includes evasive and emergency maneuvers and maintaining appropriate dist ances from
persons, vessels, vehicles, and structures.

 SkyCentric will use a Visual Observer (VO) for all its UAS civil operations. The PIC will ensure that the VO can perform the duties required of the VO, and that s/he is able to see the aircraft as spe cified in 14 CFR part 107.31 and 37. The VO will not be allowed to operate the UAS.

 Training, proficiency, and experience

- building flights for the purposes of training SkyCentric’s PICs and VOs and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated will only be conducted during dedicated training

sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considered
nonparticipa nts, and the PIC will operate the aircraft with appropriate distance from nonparticipants in accordance with 14 CFR part 91.119.

 The PIC and VO will only participate in the operation of one UAS at a time.

 The PIC will not operate the UAS from a moving airc raft or a land

- borne vehicle.

 When operating the UAS, the PIC will refrain from careless or reckless behavior that could endanger the life or property of o ther. This includes not dropping objects from the aircraft as to create a hazard to persons or proper ty.

 The PIC and VO will comply with the FAA alcohol and drug use prohibitions.

 SkyCentric will not allow an individual with a physical or mental condition that could interfere with the safe operation of t he UAS to function

as PIC or VO. In the event that t he PIC or the VO have reason to believe that the physical or mental condition of self or other might interfere with the safe operation of the UAS, s/he will immediately notify the SkyCentric Project Manager for appropriate action.

 The PIC and VO will scan the airspace where the UAS is operating for potential collision hazards and will maintain awareness of the position

of the UAS through direct visual observation.

 The PIC and VO will maintain effective verbal communication with each other at all times. Elec tronic messaging or texting will not be permitted during flight operations.

 The PIC and VO will maintain Visual Line of Sight (VLOS) of the UAS through the duration of the flight, with human vision tha t is 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.

 The PIC or VO’s vision of the UAS will be sufficient to allow them to know the aircraft’s location; determine the aircraft’s attitude, altitude,SkyCentric LLC

- Petition for Exemption 8



### SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

and direction; obse rve the aircraft for other traffic or hazards; and determine that the aircraft does not endanger the life or property of

another.

5. Pre

- flight Inspections, Assessments, and Checks Provisions

 The PIC will inspect the UAS to ensure that it is in a condition for safe operation. This will include performing the manufacturer

recommended preflight inspection and/or performing an on

- the

- ground test of the UAS to determine whether safety

- critical systems and
components are working properly. The pre

- flight inspectio n will 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 will be prohibit ed from operating
until the necessary maintenan ce has been performed and the UAS is found to be in condition for safe flight.

 The PIC will ensure that all links between the control station and the aircraft are working properly. In the event that a con trol link is not functioning properly, flight will n ot commence until the problem is resolved.

 Prior to each flight event, the PIC will become familiar with the confined area of operation of the UAS by assessing the oper ating environment and risks to persons and property in the immediate vicinity both on t he surface and in the air. As part of this pre

- flight assessment, the PIC will consider conditions that could pose a hazard to the operation of the UAS, as well as conditions in w hich the operation of the UAS could pose a hazard to other aircraft, persons or property on the ground. Special consideration will be given to:

 L ocal weather conditions;

 L ocal airspace and any flight restrictions;

 T he location of persons and property on the ground;

 O verhead wires and power transmission cables;

 Any other ground or air hazards.

 SkyCentric will be responsible for coordination and deconfliction between Military Training Routes (MTRs). When identifying a n operational area, SkyCentric will evaluate whether an MTR will be affected. In the event the UAS operational are a overlaps (5 miles either side of centerline) an MTR, SkyCentric will contact the scheduling agency 24 hours in advance to coordinate and deconflict. If prior coordination and deconfliction does not take place 24 hours in advance, SkyCentric will remain c lear of all MTRs.

 The PIC will compare the GPS altitude read

- out with the launch site altitude to ensure proper readings.

 In the event of loss of control of the aircraft for any reason, the PIC will ensure that the UAS will pose no undue hazard to other aircraft,
people or property.

 If the operation takes place in an area where other air traffic could pose a hazard, the PIC will advise local air traffic control (ATC) as to the

location of his or her area of operation and add extra visual observers to the operation so that they can notify the PIC if other aircraft are
approaching the area of operation.

6. Provisions to Confine the Area of Operations (to mitigate risks associated with loss

- of

- positive

- control)

 All SkyCentric’s operations will 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 event.

 SkyCentric’s UAS operations will take place in Class G airspace. Operations in Class A airspace will not be allowed. SkyCentr ic will seekSkyCentric LLC

- Petition for Exemption 9



### SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

permis sion from the ATC having jurisdiction and/or from the using or controlling agency of Class B, C, D, or E airspace, or prohibi ted or restricted areas, in the event that it wishes to operate in such spaces/areas.

 SkyCentric’s UAS will not operate within 5 n autical 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 Sk yCentric obtains a letter of agreement with that airport’s management or SkyCentric’s COA permits it. If the former, SkyCentric will, upon request, make available to the Administrator or any law enforcement official, the letter of agr eement with the
airpor t management.

 The UAS will operate at an altitude not to exceed 200 ft above ground level (AGL). This is consistent with the altitude limit ations on the “blanket” COA that the FAA grants automatically to UAS operator with a Section 333 exemption.

 SkyCent ric will cooperate with the UAS manufacturer to upgrade UAS operating software to incorporate exclusions or no

- fly zones

. 7. “See

- and

- A void” and Visibility Provisions

 SkyCentric’s UAS operations will not be conducted during night, as defined in 14 CFR part 1 .1.

 All SkyCentric’s UAS operations will be conducted under visual meteorological conditions (VMC).

 In the event that SkyCentric wishes to conduct UAS operations under special visual flight rules (SVFR), it will seek authoriz ation in advance

and will not conduct such operations unless and until authorization is granted.

 Minimum flight visibility from the control station will be three statute miles (5 km).

 The UAS will not be operated less than 500 ft below or less than 2,000 ft horizontally from a cloud or when visibility is less than 3 statute

miles from the PIC.

8. Mid

- Air Collision Avoidance P rovisions

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

 The PIC will always initiate avoidance maneuvers to av oid collision with any other user of the NAS.

 The UAS will not operate so close to any other aircraft as to create a collision hazard.

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

. 9. Other Provisions to Mitigate the Risk Po sed by Loss

- of

- Positive

- Control

 Prior to flight, the PIC will verify that all links between the control station and the aircraft are working properly and tha t the battery is fully
charged.

 If the UAS loses communications or loses its GPS signal, th e aircraft will return to a pre

- determined location within the private or controlled

access property.

 The UAS will not be operated over people not directly involved in the operation.

 All Flight operations will be conducted at least 500 feet from all nonparticipating persons 2 , vessels, vehicles, and structures unless:

 Barriers or structures are present that sufficiently protect nonparticipating persons from the aircraft and/or debris in the event of an

2 For the purpose of this exemption, the PIC, VO, SkyCentric’s trainees and essential persons are not considered nonparticipati ng persons.SkyCentric LLC

- Petition for Exemption 10



### SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

accident. The PIC will ensure that nonparticipatin g persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the aircraft, the PIC will cease flight operations immediately in a manner that

will ensure the safety of nonparticipating persons; and

 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.

 Prior to the flight, the PIC will ensure that all persons directly involved in the operation receive a briefing that includes: (1) operating conditions; (2) emergency procedures; (3) contingency procedures; (4) rol es and responsibilities; and (5) potential hazards.

 The PIC will ensure that the UAS will not pose undue hazard to other aircraft, people, or property in the event of loss of control of the

aircraft.

10. Documentation and Demonstration of Compliance Provisions

 SkyCentric will make available to the PIC all documents required to ensure the safe operation and flight of the UAS, as well as any documents required under 14 CFR §§ 91.9 and 91.203. These documents will at the Ground Control Station of the UAS any time the aircraft is operating.

 Upon the request of the FAA or any law enforcement official, SkyCentric will make available any document, record, or report r equired to demonstrate compliance and/or for the operation and maintenance of the UAS. These i nclude SkyCentric’s FAA exemption and COA, aircraft certificate of registration, PIC’s certificate, letters of agreement with the airport management (if operating within 5 nauti cal miles from airport); letters of authorization from owners/controllers or re presentatives of property, vessels, vehicles and/or structures within 500 ft of flight path; UAS operating documents; and all amendments and/or revisions of aforementioned documents, as applicable.

 SkyCentric, its PIC and/or VO, will allow the FAA to make any test or inspection of the UAS, the PIC and/or the VO, to determine compliance
with applicable regulations.

11. Reporting Provisions

 SkyCentric will submit a monthly UAS Activities R eport to the FAA

.

 SkyCentric will file a distance (D) Notice to Airman between 24 and 72 hours of each flight event. This will serve as advance ATC facility notification of UAS operations in an area.

 SkyCentric will cancel NOTAMs when UAS operations are completed or will not be conducted.

 Within 24 hours of occurrence, SkyCentric will report to the FAA’s UAS Integration Office (AFS

- 80) any incident, accident, or flight operation
that transgresses the lateral or vertical boundaries of the operational area as defined by SkyC entric’s COA.

 SkyCentric will report any accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site www.ntsb.gov

.SkyCentric LLC

- Petition for Exemption 11



## D. REGULATIONS FROM WHICH RELIEF I S SOUGHT

The regulations from which SkyCentric is seeking relief are listed in Table 2 of this petition. This
Section discusses each of these regulations, the reasons why SkyCentric is seeking relief, and
SkyCentric ’s provisions to assure an equivalent level of safety

. To avoid repetition, a ny references

to specific sections of Attachment A, “SkyCentric’s Handbook for Civil Operations of Unmanned
Aircraft Systems (UAS),” are identified as “Handbook” references.



### D.1 14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, Airworthiness Certificates , establishes the procedural requirements for the issuance of
airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating

area associated with the aircraft s to be utilized by SkyCentric , an exemption from Part 21 Subpart
H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of Public

Law 112

- 95.

The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of Public Law 112

- 95 authorize
the FAA to exemp t aircraft from the requirement for an airworthiness certificate, upon consideration of the UAS’ size, weight, speed, operational capability, and proximity to airports
and populated areas. As discussed in Section B.3 of this petition, the FAA has deter mined in
previous exemptions that airworthiness certification should not be required for UAS due to their

low

- risk operational characteristics.

During preflight and post flight inspections, SkyCentric will seek to identify problems that could
impact the airworthiness and reliability of its aircrafts. In addition, as described in Section 5.5 of

the attached Handbook, the control link will be checked prior to each flight event to ensure proper flight control. These combined efforts will ensure that SkyCen tric ’s UAS are in a condition for
safe operation. The implementation of the above and all the other provisions listed in Table 4 and

in the attached Handbook will make SkyCentric ’s UAS operated without airworthiness certificate s

in the restricted operation al environment currently allowed by the FAA under Section 333
exemptions, as safe as, or safer than

, conventional aircraft operating with an airworthiness
certificate without the restrictions and conditions proposed.

SkyCentric ’s UAS weigh less than 55 lbs., carr y no pilot

, passenger, explosive materials or
flammable liquid fuels, and operate exclusively within a secured area as set out in Table 4 of this
petition and in Section 5.1 of the attached Handbook. Like other civil aircraft, operations under

t his exemption will be tightly controlled and monitored by SkyCentric and its PIC, and will be in
compliance with local public safety requirements, to provide security for the area of operation as
is currently done on active construction and other sites. T hese safety enhancements, which already
apply to civil aircraft operated in connection with construction and other sites, provide a greaterSkyCentric LLC

- Petition for Exemption 12

degree of safety to the public and property owners than conventional operations conducted with

airworthiness certificates issued under 14 CFR Part 21, Subpart H.

The FAA has previously granted exemptions from this regulation, some examples of which may
be found in Exemption Nos. 11062, 11067, 11080, 11112, 11114, 11138 , and 11658

.



### D.2 14 CFR 61.113(a) and (b): Private P ilot P rivileges and L imitations:

Pilot in C ommand

Section 61.113(a) and (b) prescribe that

( a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is
carrying passengers or property for compensation or hire; nor may that person, for compensation or hire,
act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Unlike a conventional aircraft, which is operated by an onboard pilot, SkyCentric ’s UA S will
not carry a pilot, passenger ( s ) , o r any other life form on board. T he aircraft w ill be remotely

controlled and, as shown on the provisions contained in Table 4 and in Section 5.1 of the

attached Handbook

, the area of operation will be controlled and restricted, and all flights
will be planned and coordinated in advance. These provisions s ignificantly reduce the risk

of SkyCentric ’s UA S operations compared with t he level of risk posed by the commercial
operations governed by 14 CFR Part 61.

To date, the FAA has granted petitions for exemption similar to this one, and has
authorized UAS to be operated by a PIC with a private pilot certificate and either a third

class airman medical certification or a va lid driver’s license issued by a state, the District
of Columbia, Puerto Rico, a territory, a possession, or the Federal Government

. The PIC has
been required to demonstrate his/her ability to operate the UAS.

The FAA has issued the following exemptions to this regulation as shown in Exemption Nos.

11062, 11065, 11067, 11110, 11109, 11136

, 11138 and 11658

.



### D.3 14 CFR 91.7(a): Civil Aircraft A irworthiness

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworth y
condition. As there will be no airworthiness certificate issued for the aircraft, should this
exemption be granted, there will be no FAA regulatory standard for determining
airworthiness. The size and operational characteristics of SkyCentric’s aircraft s and the
provisions outlined in Table 4 of this petition related to preflight inspections, checks,SkyCentric LLC

- Petition for Exemption 13

assessments, and maintenance will ensure that SkyCentric’s UAS are in a condition for
flight. Therefore, an equivalent level of safety will be provided.

T he FAA has granted exemptions from this regulation in several instances, including Exemption

Nos. 11080, 11109, 11136, 11138, 11150, 11153, 11157, 11159, and 11658.



### D.4 14 CFR 91.103(b): Preflight Action

Section 91.103 prescribes that the aircraft’s pilot in command shall, before beginning a flight,
become familiar with all available information concerning that flight. This information must

include:

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landin g distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and
landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temper ature.

SkyCentric seeks relief from this regulation because the type of information and actions required
to ensure the safe operation of a UA S are different from those called for in 14 CFR 91.103 (b).

The Provisions contained in Table 4 and in Section 6 of the attached Handbook addressing
preflight inspections, assessments, and checks will ensure an equivalent level of safety as that
provided for conventional aircraft governed by 14 CFR 91.103(b).



### D.5 14 CFR 91.119(c): Minimum Safe Altitudes

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or pro perty on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open

- air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(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 struct ure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without
hazard to persons or property on the surfaceSkyCentric LLC

- Petition for Exemption 14 (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or paragraph (c)
of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Section 91.119(d) allows helicopters to be operated at less than the minimum prescribed altitudes,
provided the person operating the helicopter complies with any route or altitudes prescribed for
helicopters by the FAA. This petition of exemption is for quad , hexa, and octo copter s t hat fl y similarly to a helicopter, with vertical take

- off and vertical landing, which will operate at altitudes
of 200 feet above ground level (AGL) or less. Therefo re, an exemption will be needed to allow
such operations.

As stated in Table 4 and in Section 5.1 of the attached Handbook, SkyCentric intends to conduct
its UAS operations in secure, confined areas that are not congested. To this effect, the only portio n of this regulation from which SkyCentric seeks relief is 119(c), which sets the minimum flying

altitude to 500 feet AGL.

SkyCentric ’s UA S will not operate over any person that is not directly involved in the operation
of the UAS unless these persons a re protected by a structure. Further, prior to each flight event,
SkyCentric will ensure that:

(1) All persons directly involved in the UAS operation receive a briefing that includes operating
conditions, emergency procedures, contingency procedures, roles and responsibilities, and
potential hazards;

(2) All persons not essential to flight operations (nonparticipating persons) remain at least 500
ft. away from the area of operations unless they are protected by barriers or structures that

can sufficie ntly protect nonparticipating persons from debris in the event of an accident. The

PIC will ensure that nonparticipating persons remain under or within such protection. If a situation arises where nonparticipating persons leave such protection and are with in 500 feet

of the aircraft, flight operations will cease immediately or the PIC will move the aircraft to a

safe distance, whichever is safer

.

(3) In the event that operations need to be conducted closer than 500 ft. from vessels, vehicles

and/or structures, SkyCentric will first obtain permission from the owner/controller, and the

PIC will make a safety assessment of the risk of operating closer to those objects.

The size, weight, and speed of SkyCentric’s UAS , combined with the provisions listed above and

in Table 4 of this petition will ensure the safety of SkyCentric ’s UAS operations and will provide

an equivalent level of safety as that inte nded for conventional aircraft governed by 14 CFR
91.119, which are heavier and carry flammable fuel.SkyCentric LLC

- Petition for Exemption 15

T he FAA has gran ted relief from this regulation, as shown on Exemption Nos. 4063, 11062,

11063, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138

, and 11658

.



### D.6 14 CFR 91.121: Altimeter Settings

Section 91.121 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."

SkyCentric requests relief from this regulation because its UAS do n ot have a barometric
altimeter but a Global Positioning System (GPS) altitude read

- out whose altitude information
is generated by GPS equipment insta lled onboard the aircraft. Prior to each flight, t he GPS

read

- out will be verified by the PIC by comparing it to the launch site altitude, thus setting the zero
altitude initiation point. To actively monitor the flight path, the PIC will have access to al titude
information via a radio communications telemetry data link which downlinks from the UA S to the PIC’s display . These provisions, coupled with SkyCentric ’s intent to operate its UA S within

VLOS and below 2 00 feet AGL, will ensure the safety of SkyCentric ’s UAS civil operations, and
will provide an equivalent level of safety as that intended by the provisions of 14 CFR 91.121 for

conventional aircraft.

The FAA has granted relief from this regulation, as shown in Exemption Nos. 11136, 11138,

11150, 11153 , 11159, and 11658.



### D.7 14 CFR 91.151(a ) ( 1): Fuel Requirements for F light in VFR

C onditions

Section 91.151(a) prescribes that no person may begin a flight in an airplane under visual flight
rules (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.

As indicated in Table 4 and in Section 5.3 of the attached Handbook SkyCentric will conduct its
UAS operations in daylight; for this reason, the fuel requirement for night operations covered
under 151(a) (2) is not applicable, and SkyCentric is only seek ing relief from 151(a) (1). This relief
is required because the batter ies that power SkyCentric’s UAS provide less than 20 minut es of
powered flight, thus making it unfeasible to meet this 30

- minute fuel reserve requirement.

Therefore, SkyCentric propose s to determine the percentage of battery power that will provide 5SkyCentric LLC

- Petition for Exemption 16

minutes of flight time, and will ensure that the aircraft returns to the ground control station when
the battery reaches this level of power. This measure will provide an equivalent level of safety
as intended by 14 CFR 91.151(a)

.

SkyCentric ’s provision to return the aircraft to the ground control station when the battery has 5
minutes of flight time can be easily carried out because when in flight, the remaining battery p ower

of the UAS is shown live on the PIC’s display, letting the PIC know the remaining flight time.

Built

- in algorithms calculate the distance of the aircraft and the estimated time to return to the
ground control station, which allows the operator to know when it’s time to fly back. These
features, combined with the above flight

- duration provision, the confined nature of the operating
area, and the size, weight, speed, and construction material of SkyCentric’s UAS will ensure the
safety of SkyCentric ’s UAS civil operations.

To date, the FAA has granted relief from this regulation to UAS for daytime, VFR conditions.
Examples of these exemptions include Exemption Nos. 2689F, 5745, 8811, 10159, 10650, 10673,

10808, 11112, 11136 11138, and 11658.



### D.8 14 CFR 91.405(a); 407(a )( 1); 409(a )( 1) and (2); 417(a) and (b): Maintenance Requirements

Section 91.405(a) prescribes that e ach 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 [Maintenance, Preventive Mainte nance, Rebuilding, and Alteration] of this chapte r.

Section 91.407(a )( 1) prescribes that

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

r ebuilding, or alteration unless

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter;

Section 91.409(a ) ( 1) and (2) prescribe that:

(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

s ervice 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.

Section 91.417(a) and (b) prescribe that

(a) Each registered owner or operator shall keep the following records for the periods specified in paragraphSkyCentric LLC

- Petition for Exemption 17 (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

(i) A description (or reference to data acceptable to the Administrator) of the work perform ed;

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 that 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 cu rrent 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 wh en the next action is
required. (vi) Copies of the forms prescribed by § 43.9(d) 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. (3) A list of defects furnished to a registered owner or operator under § 43.11 shall be retained until the defects are repaired and the aircraft is appr oved for return to service.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to SkyCentric ’s UAS. However, SkyCentric will ensure that

its UAS are in proper working condition prior to initiating flight operations (see

Provisions in Table 4 and in the attached Handbook ). Regular preventive m aintenance

will be accomplished i n a c c orda nc e w ith the manufacturer’s operating manual. The
date and type of preven tive and corrective maintenance will be documented on the UA S log,
which will be made available to FAA personnel upon request.

The above provisions, combined with the UAS size and weight and the confined area where
they will be operated for short periods of time, will achieve an equivalent or level of safety
as that intended by these regulations for conventional aircraft.
The FAA has granted similar exemptions from these regulations, as shown in Exemption

Nos. 11080, 11109, 11136, 11138, 11150, 11153, 11157

, 1115 9, and 11658.SkyCentric LLC

- Petition for Exemption 18



## E. REGULATIONS FROM WHICH RELIEF IS NOT SOUGHT

As mentioned earlier, previous petitioners have sought relief from other regulations which the
FAA has determined are not necessary or applicable. To ensure that the FAA does not consider
this an oversight on the part of SkyCentric , those regulations are d iscussed next, along with the
reason why SkyCentric is not seeking relief from them , and the actions that SkyCentric proposes to take to ensure that the intent of the regulation is met, or that its UAS operations provide an
equivalent level of safety.



### E.1 14 CFR 45.23(b): Marking of the Aircraft

This regulation prescribes that:

(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

. As stated by the FAA on previous rulings (see Exemption No. 11109), this regulation applies only
to aircraft with an experimental certificate under 14 CFR Part 21.191, which is not SkyCentric’s

case . For this reason, SkyCentric is not seeking relief from this regulation. SkyCentric ’s UAS will
be identified by serial number, will be registered with the FAA in accordance with 14 CFR part

47, and will have identification (N

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



### E.2 14 CFR 91.9 (b )( 2): Civil A ircraft F light M anual, M arking, and

P lacard R equirements

Section 91.9(b) (2) prescribes, in pertinent part, that no person may operate a US

- registered civil

aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight
Manual, approved manual material, markings, and placards, or any combination thereof.

Due to their small size and configuration, SkyCentric’s UA S do not have the ability or
place to carry a flight manual on the aircraft; therefore, an exemption is required. On
previous exemptions, however, t he FAA has stated that based on the FAA’s memorandum titled
"Interpretation regarding whether certain required documents may be kept at an UA's control
station" dated August 8, 2014, relief is not necessary. SkyCentric will achieve an equivalent
level of safety by keeping the flight manual at the ground control point where the PIC
flying the UAS will have immediate access to it.SkyCentric LLC

- Petition for Exemption 19



### E.3 14 CFR 91.109: Flight Instruction

Section 91.109 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. By design, UAS and remotely piloted aircraft 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 previously approved exemptions for

aircraft without fully functional dual controls. See Exemption Nos.5778K and 9862A.

In Exemption No. 11109, the FAA ruled that this regulation does not apply if the operator
does not intend to conduct training that requires dual controls. SkyCentric does not intend to
conduct training requir ing dual controls ; therefore, this regulation do es not apply and
SkyCentric is not seeking relief from it.



### E.4 14 CFR 91.203(a) and (b): Carrying C ivil Aircraft C ertification and

R egistration

The regulation provides in part:

(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. . .

.

(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 size and configuration of SkyCentric’s UAS prevent them from carrying certification

and /or registration documents onboard, or to display them on the aircraft. An equivalent

level of safety will be achieved by keeping these documents at the ground flight control
point where the PIC will have immediate access to these documents. See Section 7 of the

attached Handbook.

The FAA has already addressed this matter on the memorandum titled "Interpretation regarding
whether certain required documents may be kept at an UA's control station" dated August 8, 2014.

For this reason, SkyCentric is not seeking relief from this regula tion. Prior to the above referenced

memorandum, the FAA had issued numerous exemptions to this regulation (see Exemption

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700).SkyCentric LLC

- Petition for Exemption 20



## F. PRIVACY

SkyCentric ’s UA S flights in support of its civil operations will occur over private or controlled
access property with the consent and knowledge of the property owner or the authority having
jurisdiction. Images taken will be of individuals who have consented to being filmed or

ot herwise have agreed to be in the area where aerial imagery will take place.



## G. SUMMARY FOR PUBLICATION IN THE FEDERAL

REGISTER

Pursuant to 14 CFR 11, SkyCentric provides the following summary for publication in
the Federal Register, should the FAA determine that such publication is needed.

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

In a ccordance with 14 CFR Part 11 and Section 333 of Public Law 112

- 95 (the 2012 Reform Act) SkyCentric LLC seeks relief from the following rules:

14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.7(a); 14 CFR 91.103(b); 14 CFR 91.119(c);

14 C FR 91.121; 14 CFR 91.151(a) (1); 14 CFR 91.405(a); 14 CFR 91.407(a) (1); 14 CFR 91.409 (a) (1) and (2); 14 CFR 91.417 (a) and (b);

Approval of this petition will allow petitioner to safely, efficiently, and economically conduct civil operations of

U nmann ed A ircraft Systems (UA S ) weighing less than 55 lbs, to safely, efficiently, and economically acquire aerial imaging and data for real estate, architecture, aerial and land surveying, engineering, construction and development, insurance, and marketing purp oses.

Conventional operations for th e above referenced purposes utilizing r otorcraft or fixed

- wing aircraft present the risks associated with vehicles that weigh several thousand pounds and carry large amounts of fuel. Such aircraft must fly to and from t he operational site and fly at low altitudes. In contrast, t he UA S under this petition weigh less

than 55 lbs., are powered by rechargeable batteries, are transported (not flown) to the designated site, and carr y no passengers or crew. These features eliminate virtually all risks posed by manned aircraft flights for th ese purpose s

.

The operation of UA S weighing less than 55 lbs. provides an equivalent level of safety and thus supports the grant of the exemptions re quested herein, including exempting the applicant from the requirements of part 21 and allowing c ivil operations. These light UAS operate a slow spee d, close to the ground, and in sterile environment s

. As a result, they are safer than conventional operatio ns conducted with fixed

- wing aircraft or helicopters.

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



## H. CONCLUSION

As detailed in this petition , the requested exemption will permit SkyCentric to conduct c ivil
operation of UAS under controlled conditions in airspace that is limited, predetermined and

accessed

- controlled, and w ill provide safety enhancements over the traditional methods used to
acquire aerial imaging and data for real estate, architecture, aerial and land surveying, engineering,
construction and development, insurance, and marketing purposes. Approval of this exemption

w ill t hereby enhance safety and fulfill the Secretary of Transportation's (the FAA
Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraftSkyCentric LLC

- Petition for Exemption 21

systems in the national airspace system."

The small size and light weight of SkyCentric’s UAS identified in Table 1 of this petition, their
operating capabilities, the restricted and sterile environment within which SkyCentric will operate

them

, and the provisions in Table 4 and in the attached “SkyCentric’s Handbook for Civil
Operations of Unmanned Aircraft Systems (UAS),” which SkyCentric is committed to
implement ing for all its civil operations, make S kyCentric ’s proposed UAS operations fall within

the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow c ivil operations of UAS to commence immediately. In addition, as
discussed in Section B.2 of this petition, approval of this petition presents no threat to national
security.

Given the clear direction in Section 333 of Public Law 112

- 95, the authority contained in the

Federal A viation Act, as amended, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, FAA’s granting of the
requested exemptions is in the public interest. Accordingly, SkyCentric respectfully requests that
the FAA grant the requested exemptions without delay.SkyCentric LLC

- Petition for Exemption 22



## ATTACHMENT A: SkyCentric LLC’s Handbook for Civil Operations of Unmanned Aircraft Systems (UAS)

Subject to non

- disclosure under the Freedom of Information Act, 5 USC § 552 e t

. s e q

.