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Snowy Ow l Productions 

17 December 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave S.E. 

Washington, D.C. 

Re: Exemption Petition for Snowy Owl Productions, LLC 

Regulatory Docket No. F AA-2015-0947 

A. Petition Summary 

4200 James Ray Drive 

Suite 161 

Grand Forks, ND 58202 

Tel: 701-738-4825 

matt@skyskopes.com 

Snowy Owl Productions, dba. SkySkopes ("SkySkopes") hereby respectfully requests expedited approval 

and necessary exemptions from the Federal Aviation Administration's ("FAA") airworthiness 

certification and related requirements (i.e., 14 C.P.R. part 21 and 137, and 14 C.P.R.§§ 61.113(a), 

91.7(a), 91.103, 91.109, 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)-(b), 

and 91 .1501) for the purpose of operating its remotely-piloted helicopter, the RMAX, to provide 

commercial agricultural-related services in the United States. The RMAX is 9 feet long and 3 feet 6 

inches tall, weighs 141 lbs. dry weight, has a load capacity of approximately 61 lbs., and is operated by a 

trained pilot and spotter maintaining visual line-of-sight. The RMAX has been safely and extensively 

used to provide agricultural related services in Japan, Australia, and other countries for over 20 years, as 

well as in testing in the United States. The RMAX has logged over 2 million flight hours and proven to be 

a safe, efficient, and effective unmanned aircraft system ("UAS") for these purposes, as most recently 

determined by Australia's Civil Aviation Safety Authority ("CASA"). SkySkopes seeks the exemptions to 

bring the commercial benefits of the RMAX to the United States. 

SkySkopes seeks the exemptions pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012, Pub. L. No. 112-95, 126 Stat. 11 (to be codified at 49 U.S.C. § 40101 (2012)) ("Section 333") and 

the FAA's general exemption authority under 49 U.S.C. § 44701(£) ("Section 44701(t)"). The requested 

exemptions satisfy the applicable statutory criteria and policies, will serve the public interest, would not 

adversely affect safety, and would provide a level of safety at least equal to the existing airworthiness and 

related regulations. 

B. Background 

1. SkySkopes 

Applicant SkySkopes is a United States corporation based in Grand Forks, ND. SkySkopes is exploring 

new and innovative agricultural uses for the RMAX in the United States. 
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2.RMAX 

The RMAX is a remotely-piloted helicopter controlled by trained, on-site pilots using a radio transmitter. 

See Exhibit 1. The RMAX is powered by a 2-cylinder, 246-cc engine that sounds much like a small 

motorcycle when operating. It uses regular unleaded fuel with 2-stroke engine oil and has a maximum 

output of 21 horsepower. The RMAX is 9 feet long and 3 feet 6 inches tall. It weighs 141 lbs. dry weight. 

For agricultural spraying, the RMAX has approximately a 61lbs.load capacity for both liquid (4.25 

gallons) and granular (7 gallons) applications. See Exhibit 2. The RMAX is generally flown at speeds of 

12 mph or less at heights below 20 feet. 

The RMAX has been safely and extensively used for agricultural purposes for over 20 years in Japan. 

Most recently, the RMAX was approved for use in Australia by its national aviation safety authority, 

CASA. The FAA and CASA have a bilateral agreement for the promotion of aviation safety. The Rmax is 

also approved for use in South Korea. To date, the RMAX has logged over 2 million flight hours. 

Approximately 2,600 RMAX are currently in use, treating more than 2.4 million acres of farmland each 

year in Japan alone (equivalent to treating the entire states of Delaware and Rhode Island combined). 

In the United States, the RMAX has been used for research and development purposes by the University 

of California- Davis ("UC Davis"). The UC Davis project has involved the spraying of vineyards in 

Napa Valley, California, pursuant to an FAA Certificate of Authorization ("CO A''). Since the project was 

started in the summer of2012, the RMAX has safely and successfully flown approximately 30 hours. 

Leveraging their current Section 333 exemption, Yamaha has been operating the RMAX over cherry and 

apple orchards in Eastern Washington in order to explore the efficacy of the RMAX in agricultural uses 

other than aerial application. One such use is the drying of cherry trees after precipitation. Every year this 

region suffers multiple manned helicopter crashes during cherry drying operations. The RMAX, being 

unmanned (along with its impeccable safety record), nearly eliminates the potential for injury or death 

during these low-altitude, high-risk flights. 

The RMAX has also been and is being used in other research programs in the United States under COAs, 

involving Virginia Tech, Georgia Tech, and others public entities. 

C. Relevant Statutory Authority 

1. Section 333 

Section 3 3 3 (a) states that the FAA "shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the [comprehensive] plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act." In Section 

332(b)(l), Congress expressly described Section 333 as a pathway for "expedited operational 

authorization." The FAA has committed to complying with this mandate; 

for example, FAA Administrator Michael P. Huerta informed Members of Congress in September 2012 

that: 

As mandated by Section 333 of the FAA Modernization and Reform Act, the FAA will seek additional 

opportunities to approve safe access under the provisions of this section. The agency is currently 

evaluating whether access to the operational area can be controlled to reduce risk to persons and property 

on the ground, as well as other users of the NAS [i.e., national airspace]. 
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Section 333(b) identifies several factors that the FAA should consider in determining whether a UAS 

should be approved for certain uses in the NAS. These include UAS that, "as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the [NAS] or the public or pose a threat to national security." 

Based upon these factors, and for purposes of this Petition, the FAA may determine that "airworthiness 

certification under section 44704 of title 49, United States Code" is not required for operation ofthe UAS 

for certain uses. In making that determination, the FAA "shall [also] establish requirements for the safe 

operation of' the UAS in the NAS. 

2. Section 44701(£) 

In addition, the FAA Administrator has general authority to grant exemptions from its safety regulations 

and minimum standards when the Administrator decides a requested exemption is in the public interest. 

See 49 U.S.C. § 44701(£) (authorizing the grant of exemptions from a requirement of regulations 

prescribed pursuant to section 44701(a}-(b) and sections 44702-44716). A party requesting an exemption 

must explain the reasons why the exemption (a) would benefit the public as a whole, and (b) would not 

adversely affect safety (or how it would provide a level of safety at least equal to the existing rules). 

For the reasons shown below, the RMAX qualifies for expedited approval and the requested exemptions 

under Sections 333 and 44701(f), subject to the proposed requirements for safe operation ofthe RMAX in 

the NAS. 

D. The RMAX Satisfies The Statutory Criteria For Approval Under Section 333. The RMAX is a 

type ofUAS that qualifies for expedited approval under Section 333 for the agricultural purposes 

proposed by SkySkopes. Each of the statutory criteria and other potentially relevant factors are satisfied: 

1. Section 333(b)(l) Criteria 

a. Size 

The RMAX is 9 feet long and 3 feet 6 inches tall. The main rotor is about 10 feet long. It extends 4 feet 

from each side of the RMAX, and Jess than 3 feet from the front. The tail rotor is about 1 foot 9 inches in 

diameter. 

b. Weight 

The RMAX weighs 141 lbs. dry weight. For agricultural spraying, the RMAX has approximately a 61 lbs. 

load capacity for both liquid ( 4.25 gallons) and granular (7 gallons) applications. 

c. Speed 

For agricultural purposes, the RMAX is generally flown at speeds of 12 mph or less. The RMAX has a 

maximum speed of approximately 45 mph. 

d. Operational Capability 

The RMAX is capable of providing a wide array of essential agricultural spraying services, including 

watering, fertilizers, pesticides, and herbicides. The RMAX can also be equipped with sensors and 

equipment to detect and monitor agricultural areas that require irrigation, fertilization, or other treatments. 

In many applications, the RMAX has proven to be more economical and effective than other spraying 

methods, helping farmers increase productivity, lower costs, and reduce the amount of chemicals used. 
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Autonomous-featured RMAX are used in Japan to monitor radiation levels at the Fukushima nuclear 

reactor, drop measuring and sensing equipment into active volcanoes, conduct topographical surveying, 

and other purposes. This petition does not cover RMAX models with autonomous features. 

e. Proximity to Airports/Populated Areas 

For agricultural purposes, the RMAX is only flown over uninhabited areas (e.g., fields, groves, and 

orchards) and away from airports (i.e., three nautical miles or more) or populated areas. In most 

applications, the RMAX is flown at low altitudes of 20 feet or less. For field sensing and surveying, the 

RMAX is generally flown at altitudes of 200 feet or less, with a maximum altitude of less than 400 feet. 

In both cases, these altitudes are well below the airspace where manned vehicles operate (typically, 500 

feet or higher) and lower than where many kites, hobby aircraft, and hobby helicopters fly. In addition, 

the RMAX is typically flown within a range of only 150 meters (i.e., 492 feet) from the operator. 

f. Visual Line-of-Sight 

For agricultural purposes, the RMAX is only flown during daylight hours, in good weather, and always 

within the pilot's line-of-sight. See Exhibit 4. In addition, under Yamaha protocol, the pilot is always 

accompanied by a trained "spotter," who is positioned at the opposite side ofthe agricultural area and is 

in constant radio communication with the pilot. The spotter ensures that the RMAX is always within lineof-sight, and helps identify and alert the pilot to any potential obstacles on the ground or in the air. By 

operating the RMAX only within line-of-sight, and at low altitudes and speeds, a pilot and/or spotter can 

see and avoid any other aircraft or other potential obstacles. This eliminates the need for other "sense and 

avoid" capabilities during such restricted operation, as well as the need for any method of air traffic 

control communications. 

Aircraft Systems Operations in the US. National Airspace System (Mar. 13, 2008) [hereinafter Interim 

UAS Guidance], (noting that "Visual Line-of-Sight" is "[a] method of control and collision avoidance that 

refers to the pilot or observer directly viewing the unmanned aircraft with human eyesight"). 

2. Other Relevant Factors 

a. Pilot/Spotter Training and Certification 

Yam aha has established comprehensive pilot and spotter training and certification requirements prior to 

use of the RMAX. The training and certification requirements that 

Yamaha most recently developed, in cooperation with CASA in Australia, include: 

• A comprehensive UA V training course which includes theory and practical components; 

• A pilot theory exam; 

• Supervised flight training including agricultural spraying; 

• Completion ofYamaha's training program requirements including examination; and 

• Continued periodic training even after certification. 

Completion and satisfaction ofYamaha training and certification requirements would be a condition for 

pilots and spotters operating the RMAX for agricultural purposes in the United States. See Exhibit 5 

(submitted on a confidential basis). In addition, for chemical applications, the pilot operating the RMAX 

would be certified under the FAA's rules governing Agricultural Aircraft Operations, 14 C.P.R. part 137 

("AAO Application"). 
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The AAO Application requirements are designed for manned aircraft. Based on RMAX usage experience, 

Yamaha may seek an exemption from certain of these agricultural pilot certification requirements in the 

future (similar to certain allowances made by CASA for RMAX spraying operations in Australia). 

Exemptions from other AAO Application requirements relevant to the aircraft itself are requested below. 

b. RMAX Production, Certification, and Maintenance Requirements In addition to pilot certification and 

training requirements, Yamaha has developed extensive production, certification, operation, and 

maintenance requirements for the RMAX, including ones recently adopted by CASA. These same kind of 

CASA-approved requirements would likewise be a condition for RMAX use in the United States. 

Additionally, all uses of the RMAX for agricultural purposes would be under the direction, supervision, 

and control ofYamaha. 

c. Safety Systems 

The RMAX has a host of onboard safety systems, including: 

• Self-Monitor Function (diagnostic before takeoff); 

• Altitude Control System ("Y ACS"); 

• GPS flight control system; 

• Loss link safety default (hover and land); 

• YACS and GPS Warning/Indicator Lights; 

• Speed Indicator Light; and 

• Rotor Brake (propellers tilt upon shut down to allow air resistance to quickly bring the propellers to full 

stop). RMAX units operated in the United States would include these onboard safety systems and 

features. 

d. Physical Security 

Yamaha will retain custody of the units and arrange for provision of the agricultural related services, 

which will only be performed by trained and certified pilots and spotters. This will enable Yamaha to 

maintain custody over each unit and to ensure safe and proper usage. The same system has proven 

effective in other countries, without any loss or misuse of RMAX units by third parties. 

e. Privacy 

Yamaha and SkySkopes policies prohibit use of the RMAX in any way that might invade personal 

privacy. SkySkopes will comply with any federal, state, and/or local privacy policies or rules that may 

apply in particular areas where the RMAX is used. From a practical perspective, privacy has not been 

(and should not be) an issue for this kind of usage, since it involves spraying, sensing, and surveying over 

farmland and other rural, uninhabited spaces. 

3. Well-Established Performance and Safety Record 

The RMAX has a well-established performance and safety record that further justifies expedited approval 

of the product for agricultural uses pursuant to Section 333. The RMAX has been extensively used for 

agricultural purposes for over 20 years in Japan. As noted above, more recently, the RMAX was approved 

for use in Australia by CASA. The RMAX is also approved for use in South Korea. To date, the RMAX 

has logged over 2 million flight hours, treating more than 2.4 million acres of farmland each year in Japan 

alone. During this more than two decade period, there have been no injuries due to problems with the 

aircraft in Japan, Australia, or South Korea. In the limited instances where a problem with the aircraft has 
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occurred, the unit has either been safely landed and shut down by the pilot or fallen to the ground without 

personal injury. There have been no collisions with other aircraft. 

4. Lack of Threat to the NAS, Public, or National Security 

Together, the relevant Section 333 criteria, proposed operating restrictions and requirements, Yamaha's 

established training, safety, and performance record, and the other factors discussed above mitigate any 

threat or risk of hazard that the desired RMAX uses would pose to the NAS, public, or national security. 

For all of these reasons, the RMAX qualifies for expedited approval and exemption from airworthiness 

certification, pursuant to Section 333, for the specified uses and under the proposed operating 

requirements and restrictions. 

E. The RMAX Also Qualifies For The Requested Exemption Under Section 44701(f). The RMAX 

and its proposed uses also satisfy the requirements and policies for exemption under Section 4470l(f) 

from the FAA's related safety regulations. See also 14 C.P.R. 

§ 11.81 (setting forth petition requirements). 

1. Public Interest Benefits 

As noted above, the RMAX can provide some agricultural services more efficiently, economically, and 

safely than other air- or ground-based methods. In the recent UC Davis project, for example, the RMAX 

was able to treat 11.1 acres of a Napa Valley vineyard in the same time (one hour) that a conventional 

tractor took to treat 1.2 acres. Other benefits identified in the project include: 

• Greater operator safety (on steep/slippery hills and terrain); 

• Reduced chemical usage; 

• Reduced operator and other human exposure to chemicals; 

• No crop damage or soil compaction; and 

• Greater fuel efficiency. 

These same public interest benefits will be realized for similar agricultural and other precision uses (e.g., 

mosquito/insect treatment) of the RMAX in the United States. Farmers, growers, and land managers, 

therefore, will immediately benefit from the availability of the spraying services. These benefits will 

ultimately redound to American consumers. Usage experience and data resulting from the RMAX's 

operations may also be valuable to the FAA in developing comprehensive rules for civil UAS integration. 

This represents an additional important public interest benefit that would be served by the requested 

exemption. 

2. No Adverse Safety Effects 

Granting the Petition will not adversely affect aviation safety or pose any undue risks to the public. As 

shown above, the RMAX has logged over 2 million safe flight hours. CASA and additional aviation 

authorities (e.g., the Japan Agricultural Aviation Authority) have approved the RMAX for use in other 

countries recognizing that it has been and can be safely operated for commercial agricultural and related 

purposes. Moreover, although the requested exemption would enable SkySkopes to use the RMAX 

commercially in the United States, each use would be subject to further review by the FAA under the 

COA process. SkySkopes expects that, in each instance, use of the RMAX would be conditioned upon the 

same stringent training, certification, operating, manufacturing, maintenance, and other requirements and 

restrictions set forth above (collectively, "RMAX operating requirements and restrictions")-e.g., for 
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precision agricultural spraying purposes; use of the RMAX solely by trained pilots and spotters; during 

daylight and good weather; at speeds generally 12 mph and altitudes below 20 feet; and away from 

airports (three nautical miles or more) and inhabited areas. 

For these reasons, granting the requested exemptions would not adversely affect safety. Furthermore, the 

RMAX operating requirements and restrictions would provide a level of safety at least equal to the 

regulations covered by the exemptions. 

F. Description of the Relief Sought 

Based on the foregoing, the RMAX satisfies the relevant statutory criteria and related factors for 

expedited approval pursuant to Section 333, including waiver of airworthiness certification under Section 

44704. In addition, the RMAX meets the requirements and policies for exemptions, pursuant to Section 

44701(±), from the FAA's related airworthiness certification and related regulations (i.e., 14 C.P.R. part 

21 and 137, and 14 C.P.R.§§ 61.113(a), 91.7(a), 91.103, 91.109, 91.119, 91.121 , 91.151(b), 91.405(a), 

91.407(a)(l), 91.409(a)(2), 91.417(a)-(b), and 91.1501).5 SkySkopes has attempted to identify the 

applicable FAA regulations for purposes of this Petition. To the extent that the FAA determines any other 

safety regulations might apply to the desired uses of the RMAX (and would not otherwise be addressed as 

part of a future COA), SkySkopes further requests that its Petition be deemed to cover and seek 

exemption from any such other safety regulations for the reasons established above. 

1. 14 C .F .R. Part 21 : Airworthiness Certification 

Part 21 establishes procedural requirements for certifications under Section 44704, including 

airworthiness certificates. Both Sections 333 and 44701(b) authorize the FAA to exempt aircraft from 

airworthiness certification under this Part. As shown above, the RMAX meets the criteria for exemption 

from Part 21 based upon consideration of its size, weight, speed, operational capability, and proximity to 

airports and populated areas. See Section 333. Furthermore, the proposed use of the RMAX without an 

airworthiness certificate in the restricted operating environment and conditions identified above would be 

at least as safe, or safer than, conventional aircraft operating with an airworthiness certificate, and would 

provide multiple benefits to the public. Therefore, SkySkopes requests an exemption from Part 21 's 

requirements for airworthiness certification. 

2. 14 C.P.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft Part 27 sets forth the 

procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the 

RMAX would otherwise require certification under Part 27, as a rotorcraft, SkySkopes requests an 

exemption from Part 27's airworthiness standards for the same reasons identified in subpart F.l, above. 

3. 14 C.P.R. § 45 .23(b): Marking Requirements 

Section 45.23(b) requires that on limited, restricted, or light-sport category aircraft, markings indicating 

the aircraft category must be displayed "near each entrance to the cabin, cockpit, or pilot station." 

Exemption from§ 45.23(b) is warranted because the RMAX has no entrance to the cabin, cockpit, or pilot 

station on which the required marking can be displayed. SkySkopes proposes instead to display markings 

to the fullest extent possible in compliance with the location requirements of§ 45.27(a) and the size 

requirements of§ 45.29(±). Thus, SkySkopes requests an exemption to§ 45 .23(b)'s marking 

requirements. 

4. 14 C.P.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command 
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Section 61.113(a) limits private pilots to being in command of non-commercial flights. SkySkopes 

therefore requests an exemption to§ 61.113(a)'s commercial limitation. 

5. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Section 91.7(a) requires that a civil aircraft be in an airworthy condition to be operated. 

The RMAX has over two million flight hours and a stellar safety record, demonstrating that the UAS is 

airworthy. Furthermore, Yamaha's CASA-approved flight manual and operating instructions include a 

comprehensive preflight safety protocol for operation of each unit. Nonetheless, to the extent that the 

requirements of§ 91.7(a) would otherwise apply to the RMAX, SkySkopes requests an exemption from 

these requirements for the same reasons stated in subparts F .1 and 2, above. 

6. 14 C.F.R. § 91.121: Altimeter Settings 

Section 91.121 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 or barometric pressure. The 

RMAX does not have a barometric altimeter, but rather its location is determined using a GPS, and its 

height is constantly monitored by the pilot in command and spotter, thus ensuring operation at safe 

altitudes. For these reasons, SkySkopes requests an exemption to § 91.121 's altimeter requirements. 

7. 14 C.F .R. § 91 .151 (b): Fuel Requirements for Flight in VFR Conditions 

Section 9l.151(b) prohibits a person from "begin[ning] a flight in a rotorcraft under VFR [(i.e., Visual 

Flight Rules)] 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, to fly after that for at 

least 20 minutes." Although the RMAX has sufficient fuel capacity to provide for one hour of flight time, 

flight times for agricultural-related purposes are typically only 30 minutes due to the RMAX's load 

capacity for spraying and other applications. The RMAX is typically refueled while it refills its payload, 

and thus is likely to comply with the 20 minute requirement most of the time. Regardless of the potential 

for compliance, such a requirement is not necessary for the RMAX because it only operates 20 feet above 

an empty field, so the risk or danger associated with failing to reach a safe landing place is not present. 

Therefore, SkySkopes requests an exemption to§ 91.151(b)'s fuel requirements. 

8. 14 CF.R. §§ 91.405(a); 91.407(a)(l); 91.409(a)(2); 91.417(a) & (b): Maintenance Inspections 

These regulations specify maintenance and inspection standards in reference to 14 C.P.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 

that 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 to these regulations is 

needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which 

the RMAX will not have. See id. § 43.1(a). Furthermore, equivalent levels of safe maintenance and 

inspection can be achieved using the same kind of CASA-approved maintenance requirements and 

Yamaha's own certified technicians. See Exhibit 6 (submitted on a confidential basis). Therefore, 

SkySkopes requests an exemption to the maintenance and inspection requirements contained in§§ 

91.405, 91.407(a)(l), 91.409(a)(2), 91.417(a), and 91.417(b). 

9. 14 C.P.R. Part 137: Agricultural Aircraft Operations 
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Part 137 provides requirements for the certification and operation of agricultural aircraft. Some of these 

requirements include that the aircraft must be certificated and airworthy, see 14 C.F.R. § 137.19(d), and 

"equipped with a suitable and properly installed shoulder harness for use by each pilot," id. § 13 7.31 (b). 

These requirements, and many others contained in Part 137, were designed for manned aircraft and do not 

apply to the unmanned RMAX. Additionally, the RMAX will not have an airworthiness certification to 

satisfy the Part 137 requirements. Thus, SkySkopes requests an exemption from the Part 137 

airworthiness certification and operations requirements for agricultural aircraft, for the same reasons 

stated in subparts F .1 and 2, above. 

G. Conclusion 

SkySkopes, with roots in aerospace, both manned and unmanned, will uphold the highest standards for 

safe and legal operation of the RMAX during all operations. For all the reasons shown above, the RMAX 

satisfies the relevant statutory criteria and related factors for expedited approval pursuant to Section 333, 

including waiver of airworthiness certification under Section 44704, and meets the requirements and 

policies for exemptions, pursuant to Section 44 701 (f), from the FAA's related airworthiness certification 

and other specified regulations. Accordingly, SkySkopes requests that the foregoing relief be granted for 

the purpose of operating the RMAX to provide commercial agricultural-related services in the United 

States. This aircraft has been approved for commercial agricultural spraying in exemption 11448, and we 

respectfully request to fly under the same conditions of 11448. In addition, SkySkopes has been 

approved to fly other aircraft for aerial data collection under exemption number 11752. If we can provide 

any additional information to assist your understanding or review of this document, please do not hesitate 

to contact us at 701-73 8-4825 or via email at matt@skyskopes.com. Thank you. 

Very respectfully, 

Matt 

~~ Dunlevy 

President and CEO