700 North Glenville Drive, Suite 700, Richardson, Texas 75081

www.iwire365.com

March 12, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

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, iWire365 dba SkyRecon365 (“SkyRecon365”), the operator of small Unmanned 

Aircraft Systems (“sUAS” ), seeks an exemption from the Federal Aviation Regulations (“FARs”) 

listed below and discussed in Appendix A. Attached as Appendix B is a summary of this request.

The requested exemption would permit commercial operation of SkyRecon365 sUAS's, which weigh 

between 5 and 15 lbs. and performs precision aerial inspections or surveys that consist of still 

photographs and videography taken by onboard cameras. The sUAS's takes a series of high quality, 

still digital images and video that are used to produce precision references to structural integrity of 

the subject under study. Applications for these sUAS devices and associated functions include

industrial plant mapping, real estate and property surveys, land surveys, construction prospecting, 

cinematic aerial photography and film, sports aerial photography and video, family functions and 

weddings, search and rescue, county surveying and state mapping, municipal police aerial drone 

video streaming, tall structure inspections including but not limited to wireless towers, storage silos, 

electrical transmission towers, unoccupied and unmanned structures. Use of the sUAS for aerial 

inspections and surveys reduce the need to utilize conventional manned aircraft, manned lifting 

devices or manned climbing for the same purpose and provides very high quality imagery at a 

fraction of the cost. These savings result in enhanced safety, efficiency and productivity for the 

affected activities, as well as environmental benefits.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft 

and under conditions as may be modified by the FAA as required by Section 333

As described more fully below, the requested exemption would authorize commercial operations of 

aerial inspections or surveys using the sUAS's, which weigh less than 15 lbs. and are small in size. 

(see the attached O&M manuals for the DJI Phantom 2, DJI Phantom 3, DJI Inspire and DJI S900). 

The sUAS's will be operated under controlled conditions at low altitude in airspace that is limited in 

scope, as described more fully herein; it will have automated control features, as described below 

and in the O&M manuals. The sUAS also will be operated by an individual who has passed an FAA 

approved Private Pilots ground training exam, medical certification and a required manufacturer’s 

training program for the sUAS. Finally, the airspace in which the sUAS will operate will be Class G 

airspace or airspace approved by the FAA in advance.

SkyRecon365 respectfully submits that because these small, unmanned aerial vehicles will be used 

in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional 

aircraft or other manned means of inspections, the FAA can have confidence that the operations will 

achieve at least an equivalent level or greater level of safety. Approval of these exemptions would 

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe 

operation of such aircraft systems in the national airspace system.”
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The name and address of the applicant are: 

iWire365, LLC. dba SkyRecon365

Attention: William Michael Hadala, Jr.

Phone: (972) 994-6650

Email: williammichael@iwire365.com

Address: 700 North Glenville Drive, Suite 700

Richardson, Texas 75081

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) & (b).

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest.
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THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

SkyRecon365 submits that grant of this exemption application for use of the proposed UAS's in 

precision aerial inspections will advance the Congressional mandate in Section 333 of the Reform 

Act to accelerate the introduction of UASs into the national airspace system (“NAS”) if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether certain 

UASs may operate safely in the NAS before completion of the rulemaking required under Section 

332 of the Reform Act. In making this determination, the Secretary is required to determine which 

types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following:

•	The UAS’s size, weight, speed, and operational capability;

• Operation of the sUAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c) (emphasis added).1.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the 

Administrator finds the exemption is in the public interest.

1. Applicant submits that this provision places a duty on the Administrator to not only process applications for exemptions 

under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow 
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approval, to supply conditions for the safe operation of the UAS. SkyRecon365 welcomes the opportunity to consult with FAA 

staff in order to address any issues or concerns that this proposal may raise that they believe may require modification.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to UASs for aerial 

inspections and survey photography. Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption without delay.

Airworthiness of the sUAS

A critical element of the exemption application involves evidence of the airworthiness of the sUAS. 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated areas of 

the particular sUAS. SkyRecon365 small UAS's will operate at low speed in a controlled 

environment, at least five miles from an airport and more than three miles from any city or densely 

populated area. An analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

Mandatory Operating Conditions (see O&M and Safety Lists)

Grant of the exemption to SkyRecon365 will be subject to the following mandatory conditions, which 

are based upon operating conditions set forth for operation of sUAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR 

charts.

• Operations to be conducted over private or controlled-access property.

• Permission from land owner/controller required before commencing any flight.

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles 

(NM).

o Cylinder walls may be expanded by observer with ability to control aircraft.

• Operations to occur during daylight hours.

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds.

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.
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Operator Requirements

SkyRecon365 respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the DJI Phantom Vision 2, DJI Phantom 

Vision 3, Inspire and DJI S900, are characterized by a high degree of control and various built-in 

technical capabilities that limit the potential for operation outside of the operating conditions set forth 

above. Please see details in the attached O&M manuals.

Additional automated safety functions and safety enhancing features of the sUAS's include the 

following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate return to 

aircraft take-off location ("home")

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure 

begins.

Given these safety features, SkyRecon365 proposes that operators of the sUAS should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required to:

• Have successfully completed, at a minimum, FAA private pilot ground school instruction and 

passed the FAA Private Pilot written examination or FAA-recognized equivalents;

• Have completed the manufacturer’s training or a minimum of 40 hours training program for 

operation of the sUAS's.

SkyRecon365 notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs when the 

mandatory operating conditions specified above were present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 

2013). The FAA has the statutory authority to grant exemptions to the requirements for and 

privileges associated with the grant of airmen’s certificates. 49 USC

§44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a sUAS's conducting precision aerial inspections or surveys.

Approval of the exemption allowing commercial operations of the sUAS for precision inspection and 

survey work will enhance safety by reducing risk. Conventional aerial inspection and survey 

operations, using jet or piston-powered aircraft present risks associated with vehicles that weigh in 

the neighborhood of 5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in 

some cases, cargo. Such aircraft must fly to and from the survey location. Other conventional 

manned climbing or manned lifts risk safety hazards associated with falls, electrical hazards, fuel 

related hazards, and inhalation hazards associated with the structures being inspected. In contrast, 

a sUAS weighing less than 15 lbs. and powered by batteries eliminates a portion of that risk given 

the reduced mass and lack of combustible fuel carried on board a manned aircraft and the lack of 

risks associated with manned lifts or manned climbing apparatus. The sUAS will carry no 

passengers or crew and, therefore, will not expose any individuals to the risks associated with 

manned aircraft flights, manned lifts or climbing hazards.
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Additionally, no national security issue is raised by the grant of the requested exemptions. Given the 

size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or 

other dangerous materials, the sUAS poses no threat to national security.

The operation of the sUAS, weighing less than 15 lbs., for precision inspections or surveys in 

accordance with the strict conditions outlined above, will provide an equivalent level of safety 

supporting the grant of the exemptions requested herein, including exempting SkyRecon365 from 

the requirements of Part 21.

The sUAS’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, 

speed, operating capabilities, lack of proximity to airports and populated areas, operation within 

visual line of sight, and national security—and its showing of an equivalent level of safety as it may 

relate to the requirement for FAA training, provide more than adequate justification for the grant of 

the requested exemptions allowing commercial operation of the sUAS in the commercial precision 

aerial inspection and survey business.

Very truly yours,

William Michael Hadala, Jr. 

President & CEO 

iWire365, LLC. dba SkyRecon365

Enclosures:

Appendix A: Exemption Request and Equivalent Level of Safety Showings Under Applicable 

Rules Subject to Exemption

Appendix B: Operation and Maintenance Manuals: DJI Phantom Vision 2 O&M Manual, DJI 

Phantom Vision 3 O&M Manual, DJI Phantom Inspire O&M Manual, DJI S900 O&M Manual

Appendix C: Safety Checklists
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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

SkyRecon365 requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAS's:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, 

the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The sUAS's has no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” 

can be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the forward fuselage in compliance with

§ 45.29(f). The equivalent level of safety will be achieved by having the sUAS marked on its forward 

fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV will 

see the identification of the sUAS as “Experimental.” The FAA has issued the following exemptions 

to this regulation to SkyRecon365, Exemption No. 10700, and to others, including Exemption Nos. 

8738, 10167 and 10167A.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated with the aircraft to be utilized by SkyRecon365, an exemption from Part 

21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular UAS. Our small sUAS's will be operated at low speed in a 

controlled environment, at least five miles from an airport and more than three miles from any city or 

densely populated area. An analysis of these criteria demonstrates that the sUAS's operated without 

an airworthiness certificate, in the restricted environment and under the conditions proposed will be 

at least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 15 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within 

a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by the operator, pursuant to the Manual's requirements, and under the requirements and 

in compliance with local public safety requirements, to provide security for the area of operation as is 

currently done on active construction sites. The FAA will have advance notice of all operations.

These safety enhancements, which already apply to civil aircraft operated in connection with 

construction sites, power plant sites and the like provide a greater degree of safety to the public and 
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property owners than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and ability to carry an external load 

no greater than two lbs.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the sUAS in this case is remotely controlled with 

no passengers or property of others on board. Section 61.133(a) requires an individual with a 

commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. 

SkyRecon365 respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. SkyRecon365 sUAS has a high degree of control and various 

built-in technical capabilities that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application.

The sUAS has a navigation and control system comprised of a Ground Control Station (GCS) and 

auto-pilot system. All flights utilize precision GPS guidance. In the case of unplanned events, the 

operator inputs evasive maneuvers from the control unit, and the control unit executes that 

maneuver. Operator interventions include diversion to the right; initiation of holding at present 

position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and 

land; and emergency power cut off and land (Flight Termination System).

Given these safety features, SkyRecon365 proposes that operators of the sUAS should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required to:

• Have successfully completed, at a minimum, FAA private pilot ground instruction and 

passed the FAA Private Pilot written examination or FAA-recognized equivalents;

• Have completed manufacturer's training program or a minimum 40 hours training program 

for operation of the UAS.

SkyRecon365 notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs where the 

mandatory operating conditions specified above are present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 

2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot 

requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the sUAS without a private pilot’s certificate or a commercial pilot’s certificate, under the 

conditions set forth herein.

The risks associated with the operation of the sUAS (given its size, speed, operational capabilities, 

and lack of combustible fuel) are so diminished from the level of risk associated with private pilot 

operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed wing 

or rotorcraft), that allowing operations of the UAS as set forth above meets or exceeds the present 

level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring 

a commercial pilot to operate the aircraft under

§ 61.133(a).
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14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation of the sUAS without an 

airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size of the 

aircraft and the requirements that have presumably already been met for the sUAS (for instance, the 

sUAS’s Operations and Maintanence Manual and Safety Manual and Checklist), an equivalent level 

of safety will be achieved by insuring compliance with the SkyRecon365 manuals prior to each flight.

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

The regulation provides:

No person may operate a U.S.-registered civil aircraft

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5

(2) of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration of the sUAS, it has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity 

to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User Guide, 

Exhibit 4) at the ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety 

of flight. An exemption is needed from this requirement as the pilot will take separate preflight 

actions, including checking for weather conditions, checking flight battery requirements, checking 

takeoff and landing distances, and all other actions in the Preflight Checklist in the Manual and 

safety Checklists. These actions will provide an equivalent level of safety.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The sUAS is a remotely piloted aircraft and by design, does not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft 

via radio communications. If instruction is accomplished through a training program, as set forth in 

Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be 

achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 and 

through the use of experienced and qualified pilots familiar with the sUAS.
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14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the sUAS will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. 

Because aerial survey work must be accomplished at relatively low altitudes and at altitudes less 

than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which 

the sUAS's are built. Also, no flight will be taken without the permission of the landowner or those 

who control the land. Because of the advance notice to the landowner, all affected individuals will be 

aware of the inspection or survey flights. Compared to aerial inspection and survey operations 

conducted with aircraft or rotorcraft weighing far more than 15 lbs. and carrying flammable fuel, any 

risk associated with these operations will be far less than those currently allowed with conventional 

aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the UAS will 

maintain separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R § 91.121 Altimeter Settings

SkyRecon365 requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for 

altimeter use below 18,000 feet mean sea level (“MSL”) in maintaining the cruising altitude or flight 

level of the aircraft. SkyRecon365’s operation of the sUAS will not exceed 400 feet AGL and will be 

operated in a fashion that is not a sustained cruising flight such as a manned aircraft will typically fly. 

The ground station has live feedback and GPS information about the sUAS, including but not limited 

to the height of the sUAS, its forward velocity, and compass heading. The operator will be able to 

observe and control the maximum height of the sUAS. Additionally, the sUAS will be operated within 

the line of sight. Therefore, the equivalent level of safety provided by Section 91.121 will be met.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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 sUAS batteries provide approximately 25 to 30 minutes of powered flight. Without an exemption 

from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. 

Given the limitations on its proposed operations and the location of those proposed operations, a 

longer time frame for flight in daylight VFR conditions is reasonable.

SkyRecon365 believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a 

prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel does not 

engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at 

which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its 

safety. Additionally, limiting sUAS flights to 20 minutes would greatly reduce their utility. In the 

unlikely event that the sUAS should run out of fuel, it would simply land.
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Given its weight and construction material, the risks are less than contemplated by the current 

regulation.

SkyRecon365 believes that an equivalent level of safety can be achieved by maintaining 10 minutes 

of battery life, which, allowing 15 to 20 minutes of flight time, would be more than adequate to return 

the sUAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) No person may operate a civil aircraft unless it has an appropriate and current airworthiness 

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew.

The sUAS's fully loaded weighs no more than 15 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the sUAS. In addition, there is no pilot 

on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the sUAS will have immediate access to them. The FAA has 

issued numerous exemptions to this regulation. A representative sample of other exceptions 

includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . 

.” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires 

an annual inspection for the issuance of an air worthiness certificate.

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work 

that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records 

of approval of the aircraft for return to service.

Maintenance of the sUAS's will be accomplished by the owner/operator pursuant to the manuals, 

such as Exhibit 3, provided by SkyRecon365. An equivalent level of safety will be achieved because 

the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined 

areas and is not a complex mechanical devise. As provided in the attached Maintenance Manual 

and the Safety Checklist, the operator of sUAS will ensure that the sUAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance that is performed. 

Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the 

aircraft in an airworthy condition and to ensure an equivalent level of safety.
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APPENDIX B 

SUMMARY OF TRIMBLE SECTION 333 EXEMPTION REQUEST

SkyRecon365 hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the DJI Phantom Vision 2, DJI Phantom Vision 3, DJI Inspire, DJI S900

sUAS's in precision aerial inspection and survey work. An exemption is requested from the following 

regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) & (b).
700 North Glenville Drive, Suite 700, Richardson, Texas 75081

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APPENDIX B

Operation and Maintenance Manuals
700 North Glenville Drive, Suite 700, Richardson, Texas 75081

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APPENDIX C

Safety Checklists