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, 2015
SkyCentric LLC - Petition for Exemption

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Table of Contents

A. INTRODUCTION................................................................................................... 1

A.1 Petitioner.....................................................................................................................................................1

A.2 Intended Operations ..................................................................................................................................1

A.3 SkyCentric’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 14CFR Part 21,Subpart H: Airworthiness Certificates...........................................................11

D.2 14 CFR 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command .............12

D.3 14 CFR 91.7(a): Civil Aircraft Airworthiness....................................................................................12

D.4 14 CFR 91.103(b): PreflightAction......................................................................................................13

D.5 14 CFR 91.119(c): Minimum SafeAltitudes.......................................................................................13

D.6 14 CFR 91.121: Altimeter Settings.......................................................................................................15

D.7 14 CFR 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions ......................................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 Aircraft Flight Manual, Marking, and Placard Requirements.............18

E.3 14 CFR 91.109: Flight Instruction ........................................................................................................19

E.4 14 CFR 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration .....................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)............................................................................... 22
SkyCentric LLC - Petition for Exemption

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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 from the Federal Aviation 

Regulations (“FARs”) listed in Table 2, to allow civil operation of its Unmanned Aircraft Systems

(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 approval of the FAA subsequent 

to future amendments.

Using as guide prior petitions for exemption and their corresponding FAA rulings, SkyCentric is 

proposing actions that will allow the civil operations 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 proposes to take to ensure that 

its UAS operations do not create a hazard to the users of the National Air Space (NAS) 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) 410-6002

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.
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A.3 SkyCentric’s Unmanned Aircraft Systems (UAS)

SkyCentric LLC is seeking exemption to operate 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, have a 

maximum flight speed well below 87 knots (100 mph or 44.8 meters per 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 Unmanned 

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 from Which Relief is Sought,” along with 

SkyCentric LLC’s proposed actions to provide an equivalent level of safety or to meet 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, asthe 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 44702-44716
SkyCentric LLC - Petition for Exemption

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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 the 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." 
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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 safety concerns 

associated with UAS 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 aircraft. 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 higher and faster. 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 Pilot-In-Command 

(PIC) and/or the Visual Observer (VO). The UAS 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 for 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 Civil Operations of Unmanned Aircraft Systems (UAS),” which 

SkyCentric will follow for all civil 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. 
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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 Requirements,” 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 for 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 may 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 arising from 

falls while inspecting, surveying, or monitoring site progress, or attempting to take quality 

images of hard to reach places. UAS can take video and photos, and collect data of 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 sites

1

and using UAS for aerial imaging could

significantly reduce the risk for workers performing inspections, ultimately saving

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 explosive 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 have 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.html
SkyCentric LLC - Petition for Exemption 6

Table 4: SkyCentric’s Provisions 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 Notices to Airmen (NOTAMS) which restricts operations in proximity to Power Plants, Electric Substations, Dams, Wind 

Farms, Oil Refineries, Industrial Complexes, National Parks, The DisneyResorts, Stadiums, Emergency Services, the Washington DC Metro Flight 

Restricted 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, which are 

well below the FAA’s maximum allowable limit of 87 knots (100 mph). 

 SkyCentric’s UAS will not be operated 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 each 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 other 
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SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

people, in a manner that 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 sport 

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

certificate.

 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 distances 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 specified 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 

nonparticipants, 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 aircraft 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 other. This 

includes not dropping objects from the aircraft as to create a hazard to persons or property.

 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 the UAS to function 

as PIC or VO. In the event that the 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. Electronic 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 that 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, 
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SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

and direction; observe 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 forsafe operation. This will include performing the manufacturerrecommended 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 inspection 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 prohibited from operating 

until the necessary maintenance 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 control link is not 

functioning properly, flight will not 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 operating 

environment and risks to persons and property in the immediate vicinity both on the 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 which the 

operation of the UAS could pose a hazard to other aircraft, persons or property on the ground. Special consideration will be given to:

 Local weather conditions;

 Local airspace and any flightrestrictions;

 The location of persons and property on the ground;

 Overhead 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 an operational 

area, SkyCentric will evaluate whether an MTR will be affected. In the event the UAS operational area 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 clear 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 trafficcould 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. SkyCentric will seek 
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SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

permission from the ATC having jurisdiction and/or from the using or controlling agency of Class B, C, D, or E airspace, or prohibited or 

restricted areas, in the event that it wishes to operate in such spaces/areas. 

 SkyCentric’s UAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility 

Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA published 

aeronautical chart, unless SkyCentric 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 agreement with the 

airport management. 

 The UAS will operate at an altitude not to exceed 200 ft above ground level (AGL). This is consistent with the altitude limitations on the 

“blanket” COA that the FAA grants automatically to UAS operator with a Section 333 exemption. 

 SkyCentric will cooperate with the UAS manufacturer to upgrade UAS operating software to incorporate exclusions or no-fly zones.

7. “See-and-Avoid” 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 authorization 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 Provisions

 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 avoid 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 Posed 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 that the battery is fully 

charged.

 If the UAS loses communications or loses its GPS signal, the aircraft will return to a pre-determined location within the private or controlledaccess 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 persons2, 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 nonparticipating persons.
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SkyCentric’s Provisions to Mitigate Safety and Security Risks and Comply with FAA Requirements

accident. The PIC will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the 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) roles 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 required to 

demonstrate compliance and/or for the operation and maintenance of the UAS. These include SkyCentric’s FAA exemption and COA, aircraft 

certificate of registration, PIC’s certificate, letters of agreement with the airport management (if operating within 5 nautical miles from 

airport); letters of authorization from owners/controllers or representatives 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 Report 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 SkyCentric’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 IS 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, any 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 aircrafts 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 exempt 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 determined 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 SkyCentric’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 certificates

in the restricted operational 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., carry 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 

this 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. These safety enhancements, which already 

apply to civil aircraft operated in connection with construction and other sites, provide a greater 
SkyCentric 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 Pilot Privileges and Limitations:

Pilot in Command

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 UAS will 

not carry a pilot, passenger(s), or any other life form on board. The aircraft will 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 significantly reduce the risk 

of SkyCentric’s UAS operations compared with the 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 thirdclass airman medical certification or a valid 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 Airworthiness

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy

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 aircrafts 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. 

The 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): PreflightAction

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 landing 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 temperature.

SkyCentric seeks relief from this regulation because the type of information and actions required 

to ensure the safe operation of a UAS 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 SafeAltitudes 

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 property on the surface.

(b) Over congested areas. Over any congested area of a city, town, orsettlement, 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, orstructure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without 

hazard to persons or property on the surface
SkyCentric 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 octocopters that fly

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. Therefore, 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 portion 

of this regulation from which SkyCentric seeks relief is 119(c), which sets the minimum flying 

altitude to 500 feet AGL. 

SkyCentric’s UAS will not operate over any person that is not directly involved in the operation 

of the UAS unless these persons are 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 sufficiently 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 within 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 intended for conventional aircraft governed by 14 CFR 

91.119, which are heavier and carry flammable fuel.
SkyCentric LLC - Petition for Exemption 15

The FAA has granted 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 not have a barometric 

altimeter but a Global Positioning System (GPS) altitude read-out whose altitude information 

is generated by GPS equipment installed onboard the aircraft. Prior to each flight, the 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 altitude 

information via a radio communications telemetry data link which downlinks from the UAS to the 

PIC’s display. These provisions, coupled with SkyCentric’s intent to operate its UAS within 

VLOS and below 200 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 Flight in VFR

Conditions

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 seeking relief from 151(a) (1). This relief 

is required because the batteries that power SkyCentric’s UAS provide less than 20 minutes of 

powered flight, thus making it unfeasible to meet this 30-minute fuel reserve requirement. 

Therefore, SkyCentric proposes to determine the percentage of battery power that will provide 5 
SkyCentric 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 power 

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 each owner or operator of an aircraft

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed 

in part 43 [Maintenance, Preventive Maintenance, Rebuilding, and Alteration] of this chapter.

Section 91.407(a)(1) prescribes that 

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

rebuilding, or alteration unless

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

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 

service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

Section 91.417(a) and (b) prescribe that

(a) Each registered owner or operator shall keep the following records forthe periods specified in paragraph 
SkyCentric 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 performed;

and

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

(iii) The signature and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

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

appliance.

(iii) The time since last overhaul of all items installed on the aircraftthat are required to be 

overhauled on a specified time basis.

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

required by the inspection program under which the aircraft and its appliances are

maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If 

the AD or safety directive involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) 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 forthe 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 approved 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 maintenance

will be accomplished i n a c c orda nc e w ith the manufacturer’s operating manual. The 

date and type of preventive and corrective maintenance will be documented on the UAS 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, 11159, 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 discussed 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 with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable.

E.2 14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual, Marking, and

Placard Requirements

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 UAS do not have the ability or 

place to carry a flight manual on the aircraft; therefore, an exemption is required. On 

previous exemptions, however, the 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 requiring dual controls; therefore, this regulation does not apply and 

SkyCentric is not seeking relief from it.

E.4 14 CFR 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

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 regulation. Prior to the above referenced 

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

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700).
SkyCentric LLC - Petition for Exemption 20

F. PRIVACY

SkyCentric’s UAS 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 

otherwise 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 accordance 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 CFR 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 

Unmanned Aircraft Systems (UAS) 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 purposes.

Conventional operations for the above referenced purposes utilizing rotorcraft 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 the operational site and fly at low altitudes. In contrast, the UAS under this petition weigh less 

than 55 lbs., are powered by rechargeable batteries, are transported (not flown) to the designated site, and carry no

passengers or crew. These features eliminate virtually all risks posed by manned aircraft flights for these purposes.

The operation of UAS weighing less than 55 lbs. provides an equivalent level of safety and thus supports the grant 

of the exemptions requested herein, including exempting the applicant from the requirements of part 21 and 

allowing civil operations. These light UAS operate a slow speed, close to the ground, and in sterile environments. 

As a result, they are safer than conventional operations conducted with fixed-wing aircraft or helicopters.

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

H. CONCLUSION

As detailed in this petition, the requested exemption will permit SkyCentric to conduct civil 

operation of UAS under controlled conditions in airspace that is limited, predetermined and

accessed-controlled, and will 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 

will thereby enhance safety and fulfill the Secretary of Transportation's (the FAA

Administrator's) responsibilities to"...establish requirements for the safe operation of such aircraft 
SkyCentric 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 

implementing for all its civil operations, make SkyCentric’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 civil 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 Aviation Act, as amended, the strong equivalent level of safetysurrounding 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 et. seq.