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### Wanda W. Hicks Sky View Imaging 3164 Rolling Hills Lane Apopka, FL 32712 email: wjhicksart@gmail.com 

# I Phone: 407-284-1652, 321-403-5493 December 29, 2015 U.S. Department ofTransportation Docket Operations M-30 1200 NewJersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 Re : Petition of Sky View Imaging for an Exemption Pursuant to

**Secti~n** 333 ofthe FAA Modernization and Reform Act of2012 to Operate an Unmanned Aircraft System Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Sky View Imaging hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation ofthe Typhoon 4K, manufactured by Yuneec ("the TYPHOON " ).

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### I. 

### REGULATIONS FOR WH ICH EXEMPTION IS REQUESTED 

### Sky View Imaging requests exemption from the following regulations : 

### • 14 C.F.R Part 21, Subpart H; • 14 C.F.RPart 27; • 14C.F.R § 

### 45.23(b); • 14 C.F.R. § 

### 45.27(a); • 14 C.F.R § 

### 61 . 113; • 14 C.F.R § 

### 91 .7(a); • 14 C.F.R § 

### 91 .9(b)(2) ; • 14 C.F.R § 

### 91 .9(c); • 14 C.F.R § 

### 91.103; • 14 C.F.R 

### § 91 . 119; • 14 C.F.R § 

### 91 . 121; • 14 C.F.R § 

### 91 . 151(a} 

### & (b) • 14 C.F.R § 

### 91 .203 (a} 

### & (b); • 14 C.F.R § 

### 91 .405(a); • 14 C.F.R § 

### 91 .407(a)(l); • 14 C.F.R § 

### 91 .409(a)(2}; • 14 C.F .R § 

### 91 .417 (a} 

### & (b). This petition incorporates the material contained in the Yuneec Typhoon User Manual. , (the "Manual"}.

2of16II. STATUTORY AUTHORITY FOR REQUESTED E XEMPTIONS This petition for exemption is submitted in accordance with Section 

### 333 of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 

### 333 ofthe Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it does not create a hazard to users of the national airspace system (NAS) or the public or pose a threat to national security based on the following considerations: • The size, weight, speed and operational capabi l ity; • Operation in proximityto airports and populated areas; and • Operation within visual line of sight ofthe operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authorityto grant exemptions from the agency's safety regulations and minimum sta ndards when the Administrator decides a requested exemption is in the public interest. See 

### 49 U.S.C. 

### §§ 

### 106{f), 44701-44716, et seq . A party requesting an exemption must explain the reasons why the exemption: 

### {1) would benefit the public as a whole, and 

### {2) wou ld not adversely affect safety or how itwould provide a level of safety at least equal to the existing ru les. 

### 14 C.F.R. 

### § 

### 11.81 . Ill . DESCRIPTION OF SKY VIEW IMAGING AND ITS SERVICES Sky View Imaging is a company founded by Wanda W. Hicks, who has been a certified pilot since 

### 1977. Sky View Imaging will use the UAS's for community awareness to benefit/stim u late attraction to the Florida real estate market and to enhance real estate lis ting videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both will promote local economic growth through increased employment and increased tax base. Using a UAS will keep public safety in mind this will allow heavier manned aircraft, containing com bustible fuel that poses a potential public hazard out ofthese communities.



### 3 of 16The contact information for the petitioner, Sky View Imaging, is as follows:

Wanda Hicks Sky View Imaging 3164 Rolling Hills Lane Apopka, FL 32712 (407)284- 1652/ (321)403-5493 wjhicksart @gmail .com 1111. DESCRIPTION OF PROPOSED OPERATIONS Sky View Imaging is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 ofthe Reform Act to perform photography of new and current real estate listings and surrounding community attributes that employ the TYHPOON series of quadcopters. The exemption will enhance safety by reducing riskto the operator, the general public and property owners from the substantial hazards associated with manned aircraft. IV DESCRIPTION OF UAS FOR PROPOSED OPERATIONS Sky View Imaging will operate the Yuneec Typhoon Q500 4K. The TYPHOON is a battery operated quadcopter with a maximum flight time of 25 minutes. The vehicle TYPHOON weighs approximately 2.5 pounds with a maximum takeoff weight of approximately 3.75 pounds. It has fixed landing gear, vibration dampers, small frame air incline and minimalized gimbal mount. The CG03 is an innovative combination of a 3-axis gimbal, camera and digital video downlink. Control the tilt angle direction from the STlO+ and view the world from above, as ifyou were flying, from horizon to 90 degrees down . Although the vehicle's ground speed has a maximum of 

### 22 mph, it will be operated between 

### 2 and 5 miles per hour, and it will operate at or below 400 feet AGL. The TYHPOON employs a GEO FENCE which includes three separate safety functions. First the No Fly Zones, which ensures utmost safety, the FAA compliant No Fly Zone feature prevents flight near commercial airports. Second, the Legal Flying Height, which prevents flight above 400 feet from the ground. Lastly, Smart Circle,in which the built-in GPS establishes a 26-foot (8-meter) diameter Safe Smart Circle around the pilot, and also creates a geo-fence that keeps the aircraft from traveling fartherthan 300 feet (91 meters) from the pilot's position. 4of16The TYHPOON also includes three Smart Features. First Follow Me, when Follow Me is enabled, the aircraft is leashed to the pilot, who is controlling the ST10+ location . With this feature, flying and capturing video following the pilot is easy, flexible and intuitive. Second is Watch Me, when Watch Me is enabled, the 4K camera stays pointed atthe pilot, holding the STlO+, in focus and in frame, no matter which way the drone is maneuvered. Last is the Dynamic Return Home, when switched to Home Mode, the Typhoon will fly back towards the location ofthe pilot holding the STlO+, and will automatically land within 13 to 26 feet (4 to 8 meters) ofthe pilot. V . Sky View Imaging Proposed Operations Demonstrate an Equivalent Level of Safety A. General Description of Proposed Flight Operations Sky View Imaging proposes to operate only on sites that are for real estate listings and with the permission ofthe owner and anyone within the surrounding areas if necessary and within the limitations and performance specifications listed in the Manual. These limitations provide for at least an equivalent, or higher, level of safety for operations underthe current regulatory structure because the proposed operations represent a safety enhancement to the protocols. The proposed operations do not create any hazard to users ofthe national airspace system or pose a threat to national security. The aircraft is a battery operated quadcopter with a maximum flight time of25 minutes.The vehicle weighs approximately 2.5-3.75 pounds. It has vibration dampers and small frame air incline. The vehicle's ground speed has a maximum of22 mph but it will be operated between 2 and 

### 5 miles per hour, and itwill operate at or below 400 feet AGL. Manned aircraft are at risk offuel spillage and fire in the event of an incident or accident. The TYPHOON carries no fuel, and therefore the risk offire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated by the petitioner reduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features ofthe TYPHOON . Sky View Imaging will operate in areas at least 5 miles from any airport and away from population centers . The FAA has determined that the risk of not having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology, is mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting daytime operations only, and requiring that the aircraft be operated within v!sualline ofsight and yield right of way to all other manned operations. Additionally, the operator will request 

### a NOT AM priorto operations to alert other users ofthe NAS. See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 13. The petitioner' s aircraft has the capability to operate safely 

### 5 of16after experiencing certain in- flight failures. The aircraft is also able to respond to a lostlink eventwith a pre-coordinated, predictable, automated flight maneuver. B. Specific Limitations on Proposed Flight Operations Given the small size involved, the restricted environment within which they will operate, the procedures listed below, and pilot certification requirements, Sky View lmagings proposed operations using the TYPHOON would unot create a hazard to users ofthe national airspace system or the public or pose a threat to national security." Reform Act Section 333(b)(1). 1. The aircraft is approximately 2.5-3.75 pounds. 

### 2. The aircraft will be identified by serial number, registered with the FAA, and have identification (N-Number) markings as large as practicable. 3. Flights will be operated within visual line of sight ofthe pilot in command (P IC) . 

### 4. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by PIC. 

### 5. Maximum flight time for each operational flight will be 10 minutes. 

### 6. The aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) five minutes offlight time remaining. 7.The aircraft will be operated during daylight and in VFR conditions. 

### 8. Flights will not exceed 

### 400 feet AGL, so as to basic flight training. 

### 9. Flights will be operated at a lateral distance of at least 

### SO feet from any persons or property not associated with the operation who have not given prior permission. 10. Flights will be limited to a groundspeed of 5 mph. 

### 11. Minimum crew for each flight will consist of a PIC and an Ground Safety Officer. 12. The PIC will possess at least a private pilot certificate and an airmen medical certificate . Any designee from Sky View Imaging will have completed a Factory Certified Basic Operator Course for the TYPHOON. 

### 13. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact informationfor the PIC. 6of1614. The flight operations will yield the right ofway to other manned aircraft operations. 15. All persons who are not involved with photo session will be required to stay 25 feet from the edge ofthe filming perimeter. 16. The aircraft will only operate within the requested site. 17. All required permissions and permits will be obtained from territory, state, county or city jurisdictions prior to flight. 18. If the aircraft loses communications, itwill have the capability to return to a predetermined location within the operational area and land. 19. Ifthe aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location within the operational area and land. 20. The flight will be aborted in case of unpredicted obstacles or emergencies. 21. Each flight will be recorded in an Operations Log Book. 22. Maintenance on the aircraft will be recorded in a Maintenance Log Book. VI. SPECIFIC FAR EXEMPTIONS REQUESTED Sky View Imaging seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21 , 45, 61, and 91for purposes of conducting the requested operations using the TYPHOON. Listed below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Sky View Imaging has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e). A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

### § . 91.203(a)(1) The FAA has stated that no exemption is needed from this section ifa finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same application. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014- 0352 at 13-14, 22 . If, however, the FAA determines that there are some characteristics ofthe TYPHOON that fail to meetthe requirements ofthe Reform Act, an exemption is requested . Equivalent Level of Safety: The TYPHOON is safe when taking into account its size, weight, speed, and operational capability. The TYPHHON weighs 7 of16approximately 2.5-3.75 pounds and will be flown at speeds less than 5 miles per hour, in visual line of sight ofthe operator, and in remote and unpopulated airspace. The TYPHOON does notcarry pilots, passengers, explosive materials, orflammable liquid fuels. The TYPHOON will be operated within the parameters ofthe Manuals. The proposed operations will be at least as safe as, orsafer than, conventional rotorcraft operating with an airworthiness certificate withoutthe restrictions and conditions proposed here. The proposed operations will also be as safe, orsafer than, traditional power line monitoring and/orwind turbine inspection methods. B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft.To the extent the TYPHOON would otherwise requ i re certification under Part 27, Sky View Imaging seeks an exemption from Part 

### 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H. C. 14 C.F.R. 

### §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements 14 C.F.R. §45.23(b), Markings ofthe Aircraft states: When marks include onlythe Roman capital letter " N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each 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," 11 1ight-sport, (/experimental," or (/provisional," as applicable. 14 C.F.R. 

### § 45.27(a) states: Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, ortail the marks required by§ 45.23. 14 C.F.R. § 91.9(c) states: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 ofthis chapter. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft (/have identification (N -Number) markings in accordance with 14 CFR part 45, Subpart C ifthe markings are 

### (/as large as practicable." 

### See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14. Equivalent Level of Safety: Sky View Imaging will mark all TYPHOONs with their N- Number in a prominent spot on the fuselage with markings that are as large as practicable. D. 14 C.F.R. § 61.113 : Private Pilot Privileges and limitations 

### 8 oflGSky View Imaging seeks exemption from 14 CFR 

### § 61.113, which restricts private pilots from flying aircraft for compensation or hire and would also require a second class medical certificate . The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe pilot is carrying passengers or cargo for hire. While the TYPHHON will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and restrictions attendantwith requiring the PIC to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The PIC will possess at least a private pilot certificate, an airmen medical certificate, and will have completed a Factory-Certified Basic Operator Course for the TYPHOON. The FAA stated in its grant of an exception to Astraeus Aerial the "the FAA considers the overriding safety factor for the limited operations proposed bythe petitioner to be the airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing." See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 

### 18. The proposed operations can achieve an equivalent level of safety by requiring the knowledge and experience inTYPHOON operations described above. Furthermore, the security screening conducted bythe Transportation Security Administration of certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a threat to national security. The restrictions Sky View Imaging has placed on its TYPHOON operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. Sky View Imaging will operate in restricted areas away from persons and property not involved in the operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate inspections ofwind turbines on specified sites.



### E. 14 C.F.R. § 91 .7(a) : Civil Aircraft Airworthiness Sky View Imaging seeks an exemption from 14 

### C.F.R. § 91 .7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the extentthat the requirements of Part 21 are waived orfound 9 of16inapplicable. Accordingly, Sky View Imaging requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19. F

. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. 

### §§ 91 .203(a) and (b): Carrying Civil Aircraft Certification and Registration Pursuant to 14 C.F.R. § 91.9(b)(2): (b)No person may operate a U.S.-registered civil aircraft- ... ( 2)For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manuat approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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) ofthis 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. Sky View Imaging does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept atthe control station with the PIC during flight.The Chief Counsel's Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19-20, and Grant of Exemption No. 8607. G. 14 C.F.R. § 91.103: Preflight Action Sky View Imaging seeks an exemption from 14C.F.R. 

### § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft.The aircraft will not 

### 10 

### of 16have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. Under these circumstances, the FAA has stated that no exemption is required . See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extentthat an FAA-approved Flight Manual is required. Equivalent Level of Safety: An equivalent level of safety will be provided by following the Manuals. The PIC will take all required preflight actions- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas - before initiation offlight. The Manuals will be kept at the ground station with the operator at all times. H. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas Sky View Imaging requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91 . 119(c). Section 91.119{c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The Manuals provide for operations away from congested populations areas on the sites. The FAA has already determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by Sky View Imaging. See Grant of Exemption No. 11062, p. 20-21. Equivalent Level ofSafety: Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed ofthe TYPHOON, as well as the locations where it is operated -the sites. In order to avoid any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. As set forth in the Manuals and herein, the TYPHOON will be operated away from persons or structures not involved in the operation. All persons who are not involved with Sky View Imaging operations will be required to be at least 25 feet from the filming perimeter. 

### I. 14 C.F.R. § 91.121: Altimeter Settings This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeterthat is set to the elevation ofthe departure airport. The TYPHOON uses both 11 of16barometric pressure sensors and GPS to determine altitude but does not have the ability to set in a current altimeter setting. An exemption is required to the extentthat the TYPHOON does not have a barometric altimeter setting. The altitude ofthe aircraft is monitored bythe PIC on the ground control s tation and by the Ground Safety Officer. Equivalent level of Safety: The FAA has stated that an equivalent level of safety can be achieved ifthe aircraft will be operated at or below 400 feet AGL and within visual lineof-sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20-21. 

### As the attached Manuals indicate, the TYPHOON will be operated at or below 400 feet AGl and complies with the limitations in the Grant of Exemption No. 11062. 

### J. 14 C.F.R. 

### § 91.151(a) : Fuel Requirements for Flight in VFR Conditions Sky View Imaging requests an exemption from 14 C.F.R. 

### § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91 .151 states: (a) No person may begin a flight in an airplane underVFR 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 afterthat for at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes. The technological limitations on TYPHOON battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery powered with a maximum flight time of 25 minutes. Sky View Imaging proposesthat the maximum flight time for each operational flight will be 10 minutes. The aircraft will be safely landed with no less than the greaterof (a) 20% battery life remaining or (b) five minutes offlight time remaining. Equivalent level ofSafety: The FAA has stated that an equivalent level ofsafety is provided ifthe UAS flight is conducted under daytimeVFR flight conditions using VlOS, and terminated with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21 -22. The Manuals providing an equivalent level ofsafety by safely landing with no less than the greater of (a) 20% battery life remaining or (b) five minutes offlight time remaining and otherwise complying with the flight restrictions above. 12 of 16

### K. 14 C.F.R. 

### §§ 91.40S(a), 91.407{a)(l), 91.409{a)(2); 91.417(a) and {b): Maintenance Inspections Sky View Imaging seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. 

### § 91.40S(a), 91.407(a)(l), 91.409{a)(2}; 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14C.F.R. 

### § 91.405{a) (stating that each owner or operator of an aircraft "(s]hall have the aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections ... have discrepancies repaired as prescribed in part43 of this chapter"). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraftwith an airworthiness certificate, which the TYPHOON will not have. Equivalent Level of Safety: An eq uivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance with the Manuals. This includes maintenance, overhaul, replacement, and inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also incl udes preflight inspection procedures. See Exemption No. 11062, Docket No. FAA 2014- 0352, at p. 14-1 5. As provided in the M anuals, flights will not be conducted unless a flight operations checklist is performed that includes all ofthe aircraft's components. The Manuals also set requirements for maintenance log books and record keeping as well as routine and post-flight maintenance. The Manuals set requirements for both annual maintenance and preventative maintenance. VII . PUBLIC INTEREST Granting Sky View Imaging's petition for exemption furthers the public interest. Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense ofsuch aerial videography is cost prohibitive. Only large companies can afford to absorb such costs, thus depriving lower budgeted realtors for a marketing tool that is so val uable.

13 of 16VIII. PRIVACY All flights will occur overthe identified site. All flights will be conducted in accordance with any federat state or local laws regarding privacy. IX. SUMMARY FOR FEDERAL REGISTER Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Sky View Imaging seeks an exemption from the following rules for the commercial operation of a small unmanned aerial system to inspect wind turbine blades and towers for the renewable energy industry: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R 

### § 45.23{b); 14 C.F.R. 

### § 45.27(a); 14 C.F.R 

### § 61.113; 14 C.F.R 

### § 91 .7(a); 14 C.F.R 

### § 91.9(b)(2); 14 C.F.R 

### § 91.9(c); 14C.F.R 

### § 91.103; 14 C.F.R 

### § 91.119; 14 C.F.R 

### § 91.121; 14 C.F.R 

### § 91.151(a) 

### & (b) 14 C.F.R 

### § 91.203 (a) 

### & (b); 14 C.F.R 

### § 91.405(a); 14 C.F.R 

### § 91.407(a)(l); 14 C.F.R 

### § 91.409(a)(2) ; 14 C.F.R 

### § 91 .417 (a) 

### & (b).

X. ATTACHMENTS Attachment 1: Typhoon 4K User Manual v2

XI. CONCLUSION Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act - size, weight, speed, operating capabilities, proximityto airports and populated areas, operation within visual line of sight, and national security considerations - provides more than adequate justification for the grant ofthe requested exemptions to permit Sky View Imaging to operate the TYPHOON. Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger; and {2) decreasing the risks of unmanned aircraft Interfering with manned aircraft. Respectfully submitted, Wanda Hick s Sky View Imaging 14 of 16

### (407)284-1652/ (321)403-5493 wjhicksart@gmail.com



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