U.S. Department of Transportation, 

Docket Operations West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Skyward Film Inc – Section 333 Exemption Petition

The regulations from which the exemption is requested are as follows: - 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

Dear Sir or Madam:

My name is Ryan Casey, and I am writing pursuant to the FAA Modernization and Reform Act of 

2012, and the procedures contained within 14 C.F.R. 11, to request that Skyward Film Inc, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations (“FARs”) listed above. This is so we may operate a small ultra light weight 

unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”) located in Southern New England in accordance with FAA and UAS 

Regulations & Policies.

This exemption request is made based on information outlined in this petition, as well as the 

accompanying DJI Inspire 1. The DJI Inspire 1 UAS was selected because it has a proven 

capability for controlled flight as well as a gyro stabilized flight mode, GPS-aided navigation, a 

compass, blinking LED’s on the bottom, a failsafe mode for returning home, and prop guards. 

Skyward film will record flight data and other information gained through permitted flight 

operations to share with the FAA through any required FAA reports to assist with future protocol 

and safety regulation.

Ryan J. Casey

CEO, Skyward Film, Inc.

401.316.8346

casey@skywardfilm.com
Safety:

The DJI Inspire 1 also has “no fly zones” programmed into it, which will prevent flights in 

restricted zones. Although Skyward will take every precaution to avoid flying in airspace other 

than class G airspace, the preprogrammed “no fly zones” will add an additional level of safety to 

operations. For further information regarding the DJI’s “no fly zones,” please refer to Exhibit 1, 

Section 6.7 of the DJI User Manual, beginning on page 28 of that document, and Exhibit 7.

Other than this automated feature of the DJI Inspire 1, the PIC will always fly the UAS manually. 

The Pilot in Command (PIC) and a ground-based Visual Observer (VO) have tested the UAS in 

a variety of weather conditions, including on overcast days and in winds up to 15 knots. The PIC 

and VO will not fly the sUAS in heavy rainstorms, due to decreased visibility and the potential 

for water damage to the sUAS. The PIC and VO have also practiced emergency bailout 

procedures by having the sUAS return to home. In the event of an emergency, the PIC will 

release the joysticks. This will make the sUAS automatically hover in place and maintain its 

position and altitude, and the PIC and VO can determine if and when it is safe for the sUAS to 

return to the home location.

During flights, the PIC and the VO will be standing next to each other and communicating orally 

at all times at the ground station. The VO will observe the telemetry data on the IPad and will 

monitor the images from the camera to the IPad. The VO will direct the PIC if they wish to 

capture a different angle on the camera. The Inspire 1 gimbal will be filming or taking still 

images at intervals during the entirety of the flight and is not controlled independently from the 

ground station, other than by the movement of the sUAS.

Flights will be limited to 15 minutes, which is 75% of the total battery life of the DJI Inspire 1. 

The drone has a total battery life of approximately 17 minutes.

The requested exemption should be granted because proposed operation of the DJI Inspire 1, a 

small UAS weighing 6.47 lbs., inclusive of battery and payload, conducted in the strict 

conditions outlined below, will provide an equivalent level of safety, as Congress intended, while 

still allowing commercial operations. The lightweight aircraft covered by the exemption are far 

safer than conventional operations conducted with helicopters and fixed-wing aircraft operating 

in close proximity to the ground and people. The seven factors Congress directed the FAA to 

consider when approving Section 333 exemption petitions - size, weight, speed, operational 

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

sight – each support the request. In particular, the aircraft are small, and will operate at slow 

speeds, close to the ground, far from airports and in a low risk, low population environment.

No attempt will be made to identify any individuals filmed or photographed.

State the details of the Skyward Film Inspire1: The aircraft will be operated in the field with both 

a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions:

- All operations will occur in Class G airspace at no more than 400' AGL

- Operations will only be conducted with permission from the appropriate land owner

- All required permits will be obtained from state and local government prior to operation

- The aircraft will not be operated over populated areas as defined on FAA sectional maps
- The aircraft will not be operated at air shows or over an open-air assembly of people

- The aircraft will not be operated over heavily trafficked roads

- The aircraft will not be operated within 5 NM of a public airport or heliport

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight at no greater than 1/4 NM of the PIC at all time

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation a

minimum of 72 hours before any planned flight activity

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete a course of maintenance instruction as part of their initial training.

Flight Operation:

The week of an operation, the flight crew will file a flight plan with our local aviation inspector. 

The day before an operation, the flight crew will visit and inspect for safety the area in which 

operations will take place. The UAS will only fly over land which it has permission from the 

landowner or landowner’s agent to fly above. The notification will consist of, at minimum, the 

time, place, and type of UAS operation being conducted.

On the day of filming, the flight crew will wear florescent shirts or vests to increase visibility. 

Prior to departing for an operation, the flight crew will briefly turn on the sUAS to ensure that 

everything is connected and that the sUAS is in operational condition.

Upon arrival at a location for filming or photography, the flight crew will conduct an aerial and 

ground preflight inspection.

Note: If the radio control link is broken during flight, the autopilot system will recognize this 

broken control link and cause the sUAS to automatically return to the home area as recorded by 

the GPS instrumentation.

We seek to operate the Inspire 1 freely for both commercial and personal interests within 

the regulations and concerns of the FAA protocols. 

Sincerely,

Ryan J. Casey

CEO, Skyward Film, Inc.

401.316.8346

casey@skywardfilm.com