Sept 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Skyless Productions, LLC for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, Skyless Productions, LLC (Skyless) hereby applies for an exemption from the Federal

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting closed-set aerial 

videography production for the film and entertainment industry.

This petition for exemption addresses pertinent FAA FAR’s and CFR’s as well as, but not limited to, 

these accompanying Skyless documents: 

1. Picture and Television Flight Operations Manual

2. Flight Operations Manual;

3. Operations Manuals

(Collectively referred to as “Operations Manuals")

4. User Guide and;

5. User Manual

(collectively referred to as "Manufacturer's Manual").

1

Skyless submits these as well as other Skyless supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary

information that the Skyless has not and will not share with others. Additionally, these documents contain 

operating conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. §552 et seq.

 _____________________

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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This Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Closed-set Filmmaking and Cinematography

B. Aerial Photography and Videography Services

III. Relevant Statutory Authority

IV. Skyless’ Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

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

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): 

Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

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

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

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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I. DESCRIPTION OF PETITIONER

Skyless Productions is an experienced, well-versed, Los Angeles-based production company achieving the 

highest quality in cinematic production for the film and television industry. Skyless specializes in aerial 

cinematography. Two of the production company’s team members are experienced drone pilots, having 

operated UAVs ranging from small lightweight drones to heavy lift drones capable of carrying up to 55 lbs. 

The Skyless team is experienced and knowledgeable in all forms of video, photography, and CGI. The 

company shoots for film, television broadcasts, internet productions, commercial shoots for advertising, 

and also conducts still photography, VFX/CGI, cinematography, and lighting services.

The contact information for Petitioner is as follows: 

 William King 

Skyless Productions, LLC

1855 Industrial Street

Los Angeles, CA 90021

Phone: 805-453-0485

Email: will@skylessproductions.net

II. DESCRIPTION OF PROPOSED OPERATION

Skyless seeks an exemption pursuant to Section 333 of the Reform Act to operate the TITAN X8 and 

DJI S1000 (known as T-UAS) for the proposed operations discussed below. All UAS operations will occur

under tightly controlled conditions on private property where Skyless has received permission to operate

from the landowner, controller or authorized representatives. The proposed UAS operations will be 

conducted in accordance with the conditions and limitations of this Petition for Exemption and Skyless’ 

Operations Manuals. As detailed in Skyless’ Operations Manuals, all UAS operations will be limited to 

daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, 

and will occur at least 5 miles away from an airport. Moreover, Skyless’ Operations Manuals incorporate

redundant safeguards to assure that the aircraft does not travel outside the controlled area of UAS 

operations, including GPS "geo-fencing" technologies.

A. Closed-set Filmmaking and Cinematography

Skyless seeks to use small UASs for the purpose of conducting scripted, closed-set filming for the 

motion picture, television, and web industry. Skyless has tailored its operations to meet the requirements 

established by the FAA in prior grants of exemptions authorizing commercial use of UAS in the motion 

picture and television filmmaking industry, including:
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 Astraeus Aerial (Exemption No. 11062)

 Aerial MOB, LLC (Exemption No. 11066)

 Pictorvision, Inc. (Exemption No. 11067)

 HeliVideo Productions, LLC (Exemption No. 11065)

 Snaproll Media, LLC (Exemption No. 11063)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying-Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

 Dronair Solutions (Exemption No. 11671)

All UAS filmmaking and television film production operations will be conducted on private property

in a controlled area, away from spectators and persons not involved in the film and TV production. All

UAS filming will be conducted during daylight hours, VFR conditions, at altitudes below 400' AGL. As 

set forth below, Skyless’ operations provide a superior level of safety and quality compared to performing

the same filming work using conventional fixed-wing aircraft or helicopters.

B. Aerial Photography and Videography

Skyless seeks to use small UASs for the purpose of conducting aerial photography and videography

services. Traditional methods of video, expose camera operators to higher risks of serious injuries, or

death. Camera operators need to climb and perform elevated work, which exposes them to the risk of 

dangerous falls, electrocution, burns (from lighting), or other special effects and work related injuries. The

use of small UASs mitigates these hazards and is ultimately a much safer method of performing these and 

most other types of productions.

Small UAS production is also safer than traditional manned aircraft performing the same function. 

Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks 

associated with vehicles weighing thousands of pounds and carrying passengers and large amounts of fuel. 

It is important to note that the use of small UAS in this area will not only be safer and more cost effective, 

but the quality of collected video footage is often far superior.
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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("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 unmanned aircraft systems to operate in 

the National Air Space ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

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

Additionally, the FAA Administrator has 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) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 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). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. SKYLESS’ PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT

The small UAS operations proposed by Skyless in this Petition for Exemption qualify for expedited

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are

satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UAS due to its size weight, speed,

and operational capability.

 The UAS has been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 The UAS weighs less than 55 pounds, including payload.

 The UAS will not be flown at a ground speed in excess of 50 knots.
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 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety

and predictability of the system. If connection to the remote control or ground control station is 

lost, failsafe systems will permit the UAS to return to a predetermined location and safely land

without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the T-UAS is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed 

6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference in 

weight between the T-UAS and a helicopter significantly reduces the potential harm to the participating and 

non- participating individuals or property in the event of an accident or incident. In addition, the risk to the

onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in Skyless’ Operations

Manuals

Skyless’ Operations Manuals and the Manufacturer's Manual for the selected UASs will contain all

the procedures and limitations necessary to safely and successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of Skyless’ proposed operations, 

below is a summary of operational limitations and conditions that Skyless will adhere to, and which will

ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight operation.

 ____________________________

2See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); 

Grant of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).
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3. All UASs operated under the Grant of Exemption will be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance

with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

6. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical 

Certificate. The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate.

7. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must

use human vision unaided by any device other than corrective lenses, as specified on the PIC's 

FAA-issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the

Skyless’ Operations Manuals. The Operations Manuals will be maintained and made available to the

Administrator upon request. If a discrepancy exists between the conditions and limitations in the

Grant of Exemption and Skyless’ Operations Manuals, the conditions and limitations in the Grant of 

Exemption shall take precedence and must be followed. Otherwise, Skyless shall follow the 

procedures outlined in their Operations Manuals.

10. Skyless may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. Skyless will also present an

updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of

Exemption. If an update or revision would affect the basis upon which the FAA grants the exemption, 

Skyless will seek an amendment to its Grant of Exemption. Skyless will contact the FAA’s UAS

Integration Office (AFS-80) if questions arise regarding updates or revisions to the operating

documents.
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11. Skyless’ Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the T-UAS will be limited to 40 

minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no 

less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter 

navigable controlled airspace without prior written authorization and approval from the FAA. In the

event the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 

100 feet above the highest point on the structure, and no more than 50 feet horizontally from the

structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. 

(persons other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and the PIC 

has made a safety assessment of the risk of operating closer to those objects and determined 

that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than three statute miles from the PIC.
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17. The UA may not operate within 5 nm of an airport reference point as denoted on a current

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the Skyless 

COA. The letter of agreement with the airport management will be made available to the 

Administrator upon request.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items,

or equipment, not already covered in the relevant sections of the operating documents. The PIC shall

not operate the UAS if the inspection reveals a condition that affects the safe operation of the UAS 

until the necessary maintenance has been performed and the UAS is found to be in a condition for

safe flight. The ground control station shall be included in the preflight inspection. All maintenance

and alternations must be properly documented in the UAS records as required by Skyless’ Operations 

Manuals.

19. Skyless will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in 

the UAS records, including total time in service, description of work accomplished, and the signature

of the authorized person returning the UAS to service.

 20. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or flight characteristics (e.g., replacement of a flight critical component) must undergo a functional

test flight in accordance with Skyless’ Operations Manuals. The PIC who conductsthe functional test

flight must make an entry in the UAS aircraft records of the flight. The requirements and proceduresfor

a functional test flight and UAS record entry shall be included in the Skyless’ Operations 

Manuals.

 21. The UAS will be operated and maintained according to the Manufacturer's Manuals and any

required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements 

on Skyless’ Operations Manuals.

23. Skyless will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude

level and potential transponder requirements.
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24. 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.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles 

or emergencies.

 28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as 

a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10

logged hours as UAS pilot operating the make and model of UAS to be utilized for operations under 

the exemption and thirty take-offs and thirty landing in the preceding 90 days.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

Special Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing

activities, hang gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAs will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control

of the UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.
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V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

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,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3

Skyless seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using

a UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety better 

than or equal to the rules from which exemption is sought.

4

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.

5 If, however, 

the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements 

of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Skyless’ use of the T-UAS is safe when taking into account their size, weight, speed, and operational 

capability. As set forth in the description of proposed operations in Section IV (A), the T-UAS weighs less 

than 55 pounds, including payload and will not be flown at a ground speed in excess of 50 knots. UAS is

also equipped with safety features that will allow Petitioner to operate the UAS safely after experience

certain in-flight contingencies or failures.

6 7

________________________

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the

exemption would not adversely affect safety, or how the exemption would provide a level of safety at that

provided by the rule from which you seek exemption.

{Continue on next page}
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UNMANNED AIRCRAFT SYSTEM

Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area

of operation. Skyless will also provide the FAA with advance notice of all operations via NOTAMs as

required by the applicable COA. In all cases, operation of the T-UAS under the proposed conditions will

be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

 {Continued from Previous Page}

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [TITAN X8] has the capability to operate safely after experiencing certain in-flight contingencies or

failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to

respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, predictable,

automated flight maneuver, and manual flight control functionality as a backup. These safety features

provide an equivalent level of safety compared to a manned aircraft performing a similar operation."

7See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

The S1000’s operator can create no fly zones or maximum flight ranges and altitudes so the system cannot

enter areas. Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in Skyless’ Operations 

Manuals.

8See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.
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.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that Company’s small UASs would otherwise require

certification under Part 27, Petitioner 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, supra.

{continued from previous page}

The petitioner states further that the UAS has built-in intelligent fault handling which allowsthe T-UAS to 

detect a system fault while in the air and automatically fly back to its takeoff location and land. Faults that

can be detected include: loss of communication; exceeding pre-set wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate.

At any point if the operator is not explicitly commanding the system to move, the system automatically 

holds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors

including sonar, barometric pressure, temperature, wind speed and othersto ensure stability so long as wind

thresholds are not exceeded. Also a flight termination link – to prevent a 'fly away' or other potentially

dangerous situation – is available to the operator."
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Skylessseeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance

with Part 45 of this chapter.

● 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 two inches nor more than six inches high, the words "limited," "restricted," "light-sport,

"Experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

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.

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 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by Skyless will bear N-number markings that are as large as practicable in accordance

with 14 C.F.R. Part 45, Subpart C.

11

 _____________________

10

FAA Docket No. FAA-2014-0352.

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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C. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

Skyless seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 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 "shall 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 UAS to be operated under this grant of exemption 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 Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by Skyless’ Operations Manuals, the PIC will conduct a pre-flight inspection of the UAS 

and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance

will be performed and verified to address any conditions potentially affecting safe operation of the UAS and

no flights will occur unless, and until, all flight critical components of the UAS have been found to be 

airworthy and in a condition safe for operation. A functional test flight will be conducted following the 

replacement of any flight-critical components. As required by Skyless’ Operations Manuals, the PIC who 

conducts the functional test flight will make an entry in the UAS aircraft records of the flight.

Skyless’ Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, Skyless’ Operations Manuals also 

includes procedures to document and maintain a record of the UAS maintenance, preventative maintenance,

alterations, status of replacement /overhaul component parts, and the total time in service of the UASs used 

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in Skyless’ 

Operations Manuals ensure that an equivalent or higher level of safety will be achieved.
U.S. Department of Transportation

Sept 28, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Skyless seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 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 private pilot is carrying passengers or cargo for

hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo. 

In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique characteristics of

UAS operation outside of controlled airspace did not warrant the addition cost and restrictions attendant with 

requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment 

of the additional requirements for a private pilot to become qualified as a commercial pilot would not lead to 

any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions Skyless has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial. Skyless will operate on private property away from persons and property not

involved in the operation. Skyless will also obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 

NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Skyless will further ensure safe operation by requiring that any

PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators 

but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will have

experience not only in UAS operations generally but have logged flight time in the specific make and model 

used for the operations before they are permitted to participate in commercial flights on behalf of Skyless. 

The pilot qualification, training, and currency requirements in the Operations Manuals ensure that Skyless

pilots are competent and proficient in the UAS they are operating. Skyless’ training and qualification 

requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption, and will

provide a higher level of competency and proficiency for its pilots and will ensure at least an equivalent level

of safety.

 ____________________

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Sept 28, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

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

Although there will be no airworthiness certificate issued for the UASs, Skyless 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 for 14 C.F.R. § 91.7(a) to the extent that the requirements of 

Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the requirements for § 

91.7(a) be treated in accordance with Section V (A), supra.

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

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

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

...

(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 Manual, approved 

manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(b) No person may operate a U.S.-registered civil aircraft –

(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.

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness documents

and other aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or 

cockpit.

__________________

13

See id. at 13-14, 22 
U.S. Department of Transportation

Sept 28, 2015

Page 18

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) 

is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and 

other required documents from the ground control station from which he or she is operating the aircraft.

14 

As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has access 

to these key documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring 

that the pilot has access to the documents at the ground control station from which he or she is piloting the 

UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Skyless 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. While the PIC will be familiar with all information necessary to safely conduct the

flight, 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 Skyless’ Operations Manuals and the 

Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the Skyless’ Operations Manuals, including checklists covering

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather,

flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency

landing areas—before initiation of flight. Skyless’ Operations Manuals and the Manufacturer's Manual will

be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

_______________________

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-

0352 at 16-18.
U.S. Department of Transportation

Sept 28, 2015

Page 19

Skyless seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

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." UASs and remotely piloted aircraft, by their design, 

do not have functional dual controls. Instead, flight control is accomplished through the use of a device

that communicates with the aircraft via radio communications. Accordingly, an exemption will be required

for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Skyless intends to use, an equivalent level of safe training

can still be performed without dual controls because no pilot or passengers are aboard the UAS, and as 

required by the Skyless’ Operations Manuals, all persons will be a safe distance away in the event that the

UAS experiences any difficulties during flight instruction. Moreover, as required by the Skyless’ Operations

Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety

procedures provided for in Skyless’ Operations Manuals ensure that the proposed UAS operations provide an 

equivalent or higher level of safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Skyless’ requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those

minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided 

that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and within 

50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or

Observers(s) may need to be less than 500 feet away from the UAS.

__________________________

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b)

will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial 

(FAA-2014-0534 at 15)
U.S. Department of Transportation

Sept 28, 2015

Page 20

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 with the UASs, 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 UASs, as well the controlled location where

the operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted 

to 400 feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 

feet above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that 

person is in a position where he or she is shielded from the UAS and any possible debris resulting from 

UAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person

within 500 feet of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet 

away from vehicles or structures unless the property owner/controller has granted permission and the PIC 

has made a safety assessment of the risk of operating closer to those objects and, operations near the PIC or

Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in Skyless’ 

Operations Manuals will ensure operations can be conducted without compromising safety.

16

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

Skyless 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 or barometric pressure An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out.

 __________________________

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such

protection. The operator must also ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA,

flight operations must cease immediately. When considering how to immediately cease operations, the

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any

such vessels, vehicles orstructures grants permission for the operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue

hazard.”
U.S. Department of Transportation

Sept 28, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 can be

achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or below

17

, (2) within 

VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based 

on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the 

PIC to confirm accuracy of the onboard GPS.

18

The UASs that Skyless intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by CAL’ Operations Manuals, the PIC will be required to calibrate

the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the UASs Skyless to use, and the safety mitigation procedures contained in the Operations 

Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of Exemption to the 

requirements of § 191.121 is therefore appropriate.

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

Skyless 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.

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required.

 _________________________

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more

than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

Sept 28, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a T-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that 

the UAS batteries for the T-UAS provided provide approximately 20 minutes of powered flight (with 

payload) and provided battery level and battery time remaining in minutes and seconds to the PIC.19 The 

FAA also considered the fact that the T-UAS operating manual states: “start every flight with a fully 

charged battery in the aerial vehicle”, and that in the event that the UAS should run low on power, the PIC 

will be alerted and can land the T-UAS as soon as possible. Like the VDOS Grant of Exemption, Skyless’ 

use of the TITAN X8, combined with the requirements of Petitioner's Operations Manuals, ensure that an 

equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the T-UAS unless (considering wind and forecast weather 

conditions), there was enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 25% battery power remaining. Skyless will adhere to this limitation for T-UAS flights. 

The T-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a groundbased-on-screen display.20 As required by Skyless’ Operations Manuals, the PIC will promptly fly the UAS 

back to the home launch location or pre-determined abort location where the UAS may safely land, while 

still maintaining a minimum of 25% reserve battery power. Skyless submits that the procedures requiring 

flights to be safely terminated once the batteries fall below 25% capacity, combined with the requirement 

that flights only be conducted within a secure, isolated area, using a UAS weighting less than 25 pounds, 

and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent 

or higher level of safety to that provided by the regulations from which exemption is sought. 

 ________________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The T-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS. 
U.S. Department of Transportation

Sept 28, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

Skyless will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST

The public interest will be served by granting Skyless’ Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

Skyless seeks to use small UASs for the purpose of conducting aerial photography and 

videography services. Traditional methods of video, expose camera operators to higher risks of serious 

injuries, or death. Camera operators need to climb and perform elevated work, which exposes them to 

the risk of dangerous falls, electrocution, burns (from lighting), or other special effects and work related 

injuries. The use of small UASs mitigates these hazards and is ultimately a much safer method of 

performing these and most other types of productions.

Small UAS production is also safer than traditional manned aircraft performing the same 

function. Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present 

risks associated with vehicles weighing thousands of pounds and carrying passengers and large amounts 

of fuel. It is important to note that the use of small UAS in this area will not only be safer and more cost 

effective, but the quality of collected video footage is often far superior. The use of small UAS also 

enhances safety and reduces risk because, unlike manned aircraft weighing thousands of pounds, carrying 

crew in addition to flammable fuel, the UASs carry no passengers or crew. Further, in the unlikely event 

of an accident, Skyless’ small battery powered UASs presents significantly less danger to persons on the 

ground when compared to operations by conventional manned aircraft.

21 As the Petitioner's UAS are 

battery powered, the public will also benefit from a reduction in harmful emissions associated with 

conventional aircraft performing in the same functions proposed herein. Lastly, as recognized by the 

FAA in prior Section 333 Grants of Exemption to filmmakers, UASs provide an additional tool for the 

aerial filming industry, adding a greater degree of flexibility, which supplements the current capabilities

offered by manned aircraft.

22

 ______________________________________

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12):

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by 

an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will

weigh less than 55 pounds with no onboard pilot or crew. 

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Sept 28, 2015

Page 24

VIII. PRIVACY 

All Skyless’ UAS operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

IX. FEDERAL REGISTER SUMMARY 

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:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) 

& (b).

The exemption will enhance safety by reducing risk to the general public and property owners from the 

substantial hazards associated with performing equivalent film work and aerial inspection and 

environmental monitoring of industrial sites, transmission and storage facilities, construction facilities 

and precision aerial surveys with conventional fixed-wing aircraft, rotorcraft, or other methods. The 

pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the 

potential for harm to participating and nonparticipating individuals or property in the event of an 

incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated 

with the use of a UA for the aerial filming operation.

X. CONCLUSION

Skyless’ Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation 

within VLOS and national security. The proposed UAS operations will benefit the public as a whole by 

improving safety and reducing risk by alleviating human exposure to danger. In consideration of the 

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing Skyless’ use of small UASs for: scripted, closed-set filming for the 

motion picture, television, and web industry.
U.S. Department of Transportation

Sept 28, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

William King 

William King 

Skyless Productions, LLC

1855 Industrial Street

Los Angeles, CA 90021

Phone: 805-453-0485

Email: will@skylessproductions.net

(The following attached items contain and commercial information exempt from disclosure under the 

Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 

C.F.R. § 11.35(b)). (Digital signature use has been approved by William King)

Attachments: 

1 MPTOM Motion Picture and Television Operations Manual

2. General Operations Manual

3. PIC Operating Manual

4. Company Protocols

5. Location Protocols

6. Flight Communications Protocols

7. Departing Location Protocols

8. Transmitter Protocols

9. Preflight Checklist

10. Post Flight Checklist

11. Equipment Checklist

12. Company Safety Manual

13. UAS Manufacturer’s Manuals

a. User Manuals

b. Maintenance Manuals