,/ 

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 of Transportation 

Docket Operations M-30 

1200 New Jersey 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 of the FAA 

Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (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 of the Typhoon 4K, 

manufactured by Yuneec ("the TYPHOON"). 

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I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED 

Sky View Imaging requests exemption from the following regulations: 

• 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); 

• 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"}. 

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II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS 

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 of the 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 capability; 

• Operation in proximity to airports and populated areas; and 

• Operation within visual line of sight of the operator. 

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency's safety regulations and minimum standards 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) would not adversely affect safety or 

how it would provide a level of safety at least equal to the existing rules. 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/stimulate 

attraction to the Florida real estate market and to enhance real estate listing 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 

combustible fuel that poses a potential public hazard out of these communities. 

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The 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 of the 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 risk to 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 if you 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 farther than 300 feet (91 meters) from the pilot's position. 

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The 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 at the 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 of the 

pilot holding the STlO+, and will automatically land within 13 to 26 feet (4 to 8 meters) of the 

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 of the 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 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the protocols. The proposed operations do not create any 

hazard to users of the national airspace system or pose a threat to national security. The 

aircraft is a battery operated quadcopter with a maximum flight time of 25 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 of 22 mph but it will be operated 

between 2 and 5 miles per hour, and it will operate at or below 400 feet AGL. Manned 

aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

TYPHOON carries no fuel, and therefore the risk of fire 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 of the 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 of sight and yield right of 

way to all other manned operations. Additionally, the operator will request a NOT AM 

prior to operations to alert other users of the NAS. See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 13. The petitioner' s aircraft has the capability to operate safely 

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after experiencing certain in- flight failures. The aircraft is also able to respond to a lostlink event with 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 of the 

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 of the pilot in command (PIC). 

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 of flight 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 information for the PIC. 

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14. The flight operations will yield the right of way 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 of the 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, it will have the capability to return to a predetermined location within the operational area and land. 

19. If the 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 91 for 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 if a 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 of the TYPHOON that fail to meet the requirements of the 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 

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approximately 2.5-3.75 pounds and will be flown at speeds less than 5 miles per hour, in 

visual line of sight of the operator, and in remote and unpopulated airspace. The 

TYPHOON does not carry pilots, passengers, explosive materials, or flammable liquid 

fuels. The TYPHOON will be operated within the parameters of the Manuals. The 

proposed operations will be at least as safe as, or safer than, conventional rotorcraft 

operating with an airworthiness certificate without the restrictions and conditions 

proposed here. The proposed operations will also be as safe, or safer than, traditional 

power line monitoring and/or wind 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 require 

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 of the Aircraft states: 

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," 111ight-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 of the cabin, 

fuselage, boom, or tail 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 of this 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 if the 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 

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Sky 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 if the 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 attendant with 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 by the 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 in TYPHOON 

operations described above. Furthermore, the security screening conducted by the 

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 of wind 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 extent that the requirements of Part 21 are waived or found 

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inapplicable. 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 of this 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) 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. 

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 at the 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 14 C.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 

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have 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 of flight. 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 extent that 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 of flight. 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 of Safety: Compared to flight operations with rotorcraft weighing far 

more than the maximum weights proposed herein, and given the lack of flammable 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 of the 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 

altimeter that is set to the elevation of the departure airport. The TYPHOON uses both 

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barometric 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 extent that the 

TYPHOON does not have a barometric altimeter setting. The altitude of the aircraft is 

monitored by the PIC on the ground control station and by the Ground Safety Officer. 

Equivalent level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the 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 under 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. 

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 

proposes that the maximum flight time for each operational flight will be 10 minutes. 

The aircraft will be safely landed with no less than the greater of (a) 20% battery life 

remaining or (b) five minutes of flight time remaining. 

Equivalent level of Safety: The FAA has stated that an equivalent level of safety is 

provided if the UAS flight is conducted under daytime VFR 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 of safety by 

safely landing with no less than the greater of (a) 20% battery life remaining or (b) five 

minutes of flight time remaining and otherwise complying with the flight restrictions 

above. 

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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., 14 C.F.R. § 91.405{a) (stating that each owner or operator of an aircraft 

"(s]hall have the aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections ... have discrepancies repaired as prescribed in part 43 of 

this chapter"). An exemption from these regulations is needed because Part 43 and 

these sections only apply to aircraft with an airworthiness certificate, which the 

TYPHOON will not have. 

Equivalent Level of Safety: An equivalent level of safety 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 includes preflight inspection procedures. See Exemption No. 11062, Docket No. 

FAA 2014- 0352, at p. 14-15. 

As provided in the Manuals, flights will not be conducted unless a flight operations 

checklist is performed that includes all of the 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 of such 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 valuable. 

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VIII. PRIVACY 

All flights will occur over the 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); 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). 

X. ATTACHMENTS 

Attachment 1: Typhoon 4K User Manual v2 

XI. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security considerations - provides more than adequate justification for the 

grant of the 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 Hicks 

Sky View Imaging 

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(407)284-1652/ (321)403-5493 

wjhicksart@gmail.com 

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