FAA Exem ption Rulem aking

Section 333 Of The FAA Reform Act and Part 11 Prepared by Alex Kim ball Septem ber 20, 2015 3981 Perch Circle Wi llits , CA 95490 707

-456

- 9303 abkim ball84@gm ail.comAttention:

United States Secretary of Transportation Mr. Anthony R. Foxx 1200 New

Jersey Ave, SE Wa shington DC 20590 Re: Exem ption Request Section 333 of the FAA Reform Act an d 14 CFR Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b) ; 14 CFR Part 21 ; 14 CFR 61.113 (a) & (b) ; 91.7 (a) ; 91.9 (b) (2) ; 91.103 (b) ; 91.109 ; 91.119 ; 91.121 ; 91.151 (a) ; 91.203 (a) & (b) ; 91.409 (a) (2) ; 91.417 (a) & (b) Dear Mr. Secretary, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Sky Edge Photography ., a California com pany and operator of Small Unm anned Aircraft Systems ( “ sUASs ” ) equippe d to conduct aerial photography and videography purposes, hereby applies for an exem ption from the listed Federal Aviation Regu lations ( “ FARs ” ) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as m ay be established by the FAA as required by Section 333. As described m ore fully below, the reques ted exem ption would perm it the operation of sm all, unm anned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) lim ited, 2) predeterm ined, and 3) controlled as to access. Approval of this exem ption would thereby fulfill the Secretary of Transportation ’ s responsibilities to

“ ...establish require me nts for the safe operation of such aircraft systems in the national airspace system

. ” Section 333 (c) of the Reform Act. Sky Edge Photography requests to use the DJI Phantom 3 Profe ssional for aerial im aging. The FAA has previously issued Grants of Exem ption in circumstances sim ilar in nearly all m aterial respects to those presented in this petition. In previous Grants of Exem ption [Nos . 11062 to Astraeus Aerial (see Docket No. FAA

− 2 014

− 0352), 11109 to Clayco, Inc. (see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA

− 2014

− 0642)], the FAA found that the enhanced safety achieved using an unm anned aircraft with the specifications described by the petitioners, carrying no passengers or crew

— rather than a manned aircraft of far greater proportions, carrying crew and flammable fuel

—gave the FAA good cause to find that the UAS operations were in the public intere st. Sky Edge Photography feels that the reasons stated by the FAA for granting Exemption Nos. 11062 , 11109, 11112, and 11213 would also reasonably apply to the situation presented by this petition. Additio nally, we feel that considering the enhanced safety features provided by the DJI Phantom 3 Professional (the “ No Fly Zone ” feature in particular), as well as the cost effectiveness of sm all UAS aerial photography, a grant of exem ption would be in the public interest.

The nam e and address of the a pplicant is: Sky Edge Photography Attn: Alex Kim ball Phone: 707

- 456

- 9303 Email: abkim ball84@gmail.com Address: 3981 Perch Circle, W illits, CA 95490Regulations from which the exem ption is requested:

14 CFR Part 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)
This exem ption application is expressly subm itted to fulfill Congress ’ goal in passing Section 333 (a) through (c) of the Reform Act. This directs the Secretar y of Transportation to consider whether certain unm anned aircraft system s may operate safely in the national airspace system (NAS) before com pletion of the rulem aking required under Section 332 of the Reform Act. In making this determ ination, the Secretary is required to determ ine w hic h types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national secur ity in light of the following:

• The sUAS ’ s size, weight, speed, and operational capability

• Operation of the UAS in close proxim ity to airports and populated areas ; and

• Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers

. Reform Act § 333 (a). Lastly, if the Secretary determ ines that such vehicles “ ma y operate safely in the national airspace system , the Secretary shall establish requirem ents for the safe operation of such aircraft in the national airspace system

. ” Reform Act § 333 (c). The Federal Aviation Act expressly grants the FAA the authority to issue exem ptions. This statutory authority by its terms includes exem pting civil aircraft, as the term is defined under § 40101 of the Act ; that includes sUASs, from the require me nt that all civil aircraft must have a current airworthiness certificate. The Adm inistrator m ay grant an exemption from a requirem ent of a regulation prescribed unde r subsection (a) or (b) of this section or any sections 4470244716 of this title if the Adm inistrator finds the exem ption in the public interest. 49 U.S.C. § 44704 ; 14 CFR § 91.203 (a) (1). Sky Edge Photography’s sUASs are small rotorcraft aircraft, weighing less than 60 oz including sensor payload. W e operate our rotorcraft under norm al condit ion s at a speed of no more than 17 knots, usually 05 knots. The rotorcraft have the capability to hover and move in the vertical and horizontal plane sim ultaneously. W e will m anually operate only i n Visual Line of Sight and will operate only within the ope rating param eters as described in the Operating Manual.Adherence to the Operating Manual will insure that the sUASs will “ not create a

hazard to the national airspace system or the public. ” Given the sm all size and weight of the sUASs involved and the restricted sterile environm ent within which they will operate, Sky Edge Photography falls squarely within tha t zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exem ption, allow commercial o perations of UASs to comm ence immediately. Also due to the size of the sUASs and the areas in which the relevant sUAS will operate, approval of the application prese nts no national security issue. Given the clear direction in Section 333 of the Reform Act, the aut hority contained in the Federal Aviation Act, as am ended, granting the requested exem ptions is in the pu blic interest for the following reasons: (1) the strong equivalent level of safety surrounding the p roposed operations, and (2) the significant public benefits, including enhanced safety, reduction in environm ental im pact, including reduced em issions associated with allowing UASs for educationa l and marketing operations, (as opposed to full scale aircraft). Accordingly, Sky Edge Photography respectfully requests that the FAA grant the requested exem ption without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY Sky Edge Photography proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the lim itations listed herein. These lim itations provide for at least an equivalent or possibly higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancem ent to the already safe film ing operati ons conducted with conventional aircraft. These lim itations and condition to which Sky Edge Photography agrees to be bound when conducting commercial operations under an FAA issued exem ption include: 1. The sUASs will weigh less than 5 lbs. 2. Flights will be operated m anually within visual line of sight (VLOS) of the Pilot and aircrew (Spotter / Observer). 3. Maxim um total flight tim e for ea ch operational flight will be 20 mi nutes. Flights will be term inated at 25% battery power reserve s hou ld that occur prior to the 20 mi nute lim it. 4. Flights will be operated at an altitude of no more than 200 feet AGL, though m ost operations will be conducted within 50 feet of the ground 5. Minim um two (2) m an crew for each sUAS operation will consist of t he Pilot and Spotter /Observer. In m ost cases the third aircrew m em ber will serve as the Safety Officer. 6. The s UAS Pilot will be an FAA licensed airman with at least a private pilot ’ s certificate and third class m edical. The Spotter (Observer) will hold at least a third class medical. 7. The sUAS Pilot will serve as Pilot in Comm and (PIC). If a pilot certificate holder, other than the sUAS Pilot, possesses the necessary PIC qualifications and is als o present, that person m ay also be designated as PIC. 8. The sUAS will only operate within an area as defined in the Manual on pages 45

- 48. Additionally, the sUAS will only operate under 200ft AGL, and outside a 3 statute m ile radius of any airport. The sUAS w ill never enter any MOA or Restricted Airspace, nor s hall it violate any TFR as outlined by the FAA. 9. A preflight briefing w ill be conducted in regard to the plann ed sUAS operation prior to each day ’ s flying / recording activities. It will be m andatory that all personne l who will be performing duties as “flight crew” be present for this briefing.10. The Operator w ill obtain the consent of all persons involved in the filming and

ensure that only consenting persons will be allowed within 100 feet of the flight op eration, and this radius m ay be reduced to 30 feet based upon an equivalent level of safety determ ination. 11. Pilot, and Spotter (Observer) will have been trained in operation of sUASs generally and received up

-to

- date inform ation on the particular sUAS to be operated as required. 12. Spotter (Observer) and Pilot will at all tim es be able to communicate by voice or radio. 13. W ritten and/or oral perm ission from the relevant property holders will be obtained. 14. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a predeterm ined location and land. 15. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or em ergencies. **14 CFR Part 21, Subpart H: A irworthiness Certificates 14 CFR**  **§ 91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirem ents for the issuance of airworthiness certificates as required by FAR § 91.203 (a) (1). Given the size and lim ited operating area associated with the aircraft to be utilized by Sky Edge Photography, an exem ption from 14 CFR Part 21 Subpart H meets the requirem ents of an equivalent level of safety under 14 CFR 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 authoriz e the FAA to exem pt aircraft from the requirem ent capability, and proxim ity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria dem onstrates that the UAS operated without an airworthiness certificate, in the restricted environm ent and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certifica te without the restrictions and conditions proposed. The sUAS to b e operated hereunder weighs less than 5 lbs. fully loaded, carries neither a pilot nor passengers , carries no explosive m aterials or flamm able liquid fuels, and operates exclusively wit hin a lim ited ra dius area as set out in the pre

-flight briefing / VLOS operations. Unlike other civil aircraft, operations under this exem ption will be tightly controlled and m o nitored by both the Operator, pursuant to safety requirem ents, and under the requirem en ts and in com pliance with local public safety requirem ents, to provide security for the area of operation as is now done w ith conventional aircraft. These safety enhancem ents, which already appl y to civil aircraft operated in connection with video production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these sam e criteri a demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive m aterials or flammable liquid fuels, and i nability to carry a substantial external load.**14 CFR §** **45.23 (b):**

Wi th regard to m arking of the aircraft, this regulation requires: Wh en marks include only the Rom an capital letter “ N ” and the registration num ber is displayed on lim ited, restricted or light

- sport category aircraft o r experimental or provisionally certificated aircraft, the operator must also display on that aircraft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor m ore than 6 inches high, the words “ lim ited, ” “ restricted ” , “ light

- sport, ”

“ experim ental, ” or “ provisional, ” as applicable. Even though the sUASs w ill have no airworthiness certificate, an exem ption m ay be needed as the sUASs w ill have no entrance to the cabin, cockpit or pilot station on which the word

“ Experim ental ” can be placed. Given the size of the sUAVs, two inch letteri ng will be im possible. The word “ Ex perim ental ” wi ll be placed on the fuselage in com pliance with 14 CFR § 45.29 (f). The equivalent level of safety will be provided by having the sUAV m arked on its fuselage as required by 14 CFR § 45.29 (f) w here the Pilot, Spotter (Observer) a nd others working with the sUAV will see the identification of the UAS as “ Experim ental. ” The FAA has issued the following exem ption s to this regulation to Exem ptions Nos. 10700, 8738, 10167 and 10167A. **14 CFR §**  **61.113 (a) & (b): Private Pilot P rivileges a**  **nd Limitations Pilot in Command**  **(PIC)** Sections 61.113 (a) & (b) lim it private pilots to noncommercial operations. Because the sUASs w ill not carry a pilot or passengers, the proposed operations can achieve th e equivalent level of safety of current operati ons by requiring the PIC operating the aircraft to have a private pilot ’ s license rather than a commercial pilot ’ s license to operate this sUAS. Unlike a convent ional aircraft that carries the pilot and passengers, the sUAS is rem otely controlled with no l iv ing thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as se t forth in the Operating Manual. The level of safety provided by t he requirem ents included in the Operating Manual m eets t hat provided by a single individual holding a commercial pilot ’ s certificate operating a conventional aircraft. The risks associated with commercial operations contem plated by Part 61 when drafted, that allowing operations of the sUAS as reques ted with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR § 61.113 (a) & (b). **14 CFR §**  **91.7 (a): Civil A ircraft A**  **irworthiness** The regulation requires that no person m ay operate a civil aircraft unles s it is in airworthy con dition. As there w ill be no airworthiness certificate issued for the aircraft, sh ould this exem ption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirem ents contained in the Opera ting Manual for maintenance and use of safety checks prior to each flight, as set forth in the Operating Manual, an equivalent level of safety w ill be provided. However, as required by 14 CFR 91.7(b) a preflight assessm ent will be conducted.**14 CFR §**  **91.9 (b) (2): Civil A**  **ircraft Flight Manual in the A ircraft** 

Section 91.9 (b) (2) provides: No person m ay operate a U.S.registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved m anual m aterial, m arkings, and placards, or any com bination thereof. The sUAS, given its size and configuration, 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 m aintained by keeping the Operating Manual at the ground control point w here the pilot flying the sUAS w ill have immediate a ccess to it. The FAA has issued the following exem ptions to this regulation: Exem ption Nos. 8607, 8737, 8738 , 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700 **14 CFR §**  **91.103 : Preflight A** **ction** This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for th e aircraft an exem ption will be needed. An equivalent level of safety will be provided as set forth i n the Operating Manual. The PIC will take all actions including reviewing weather, flight battery re quirem ents, landing and takeoff distances and aircraft performance data before initiation of flight. **14 CFR §**  **91.109: Flight Instruction**  Section 91.109 provides that no person m ay operate a civil aircraft (except a m anned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. SUASs and remotely piloted aircraft, by their design do not have fully functional d ual controls. Flight control is accom plished through the use of a control box that communica tes with the aircraft via radio comm unications. The FAA has approved exem ptions for flight trainin g without fully functional dual controls for a num ber of aircraft and for flight instruction in experi me ntal aircraft. See Exem ptions Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact that aircraft will be piloted by a certified private pilot who has previously trained in rem ote flight areas before attem pting flight within filming distance of structures. **14 CFR §**  **91.119: Minimum Safe A ltitudes**  Section 91.119 establishes safe altitudes for operation of civil airc raft. Section 91.119 (d) allows helicopters to be operated at less than the m inim um s prescribed, provided the person operating the helicopter com plies w ith any route or altitudes prescribed for helicopters by the FAA. As this exem ption is for a sUAS, Sky Edge Photography requests authority to op e rate at altitudes up to 200 ft. AGL ; an exem ption m ay be needed to allow such operations. As set fo rth herein, the sUAS will never operate at higher than 200 ft. AGL. It will however be operated in a controlled area where buildings and people will not be exposed to operations without their pre

- obtained consent.The equivalent level of safety will be achieved given the size, weigh t, speed of the sUAS as

well as location where it is operated. No flight will be taken without the perm i ssion of the property own er and without advance notice to participants. Because of the advance n otice to the property owner and participants in the photographic activity, all affected individuals will be aware of the planned flight operations as set forth in the Operating Manual. Com pared to fli ght operations with aircraft or rotorcraft weighing far m ore than the m aximum 5 lbs. proposed he rein and because of the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with convent ional aircraft operating at or below 500 ft. AG L. In addition, the low

- altitude operations of the sUAS will ensure separation between these sm all UAS o perations and the operations of conventional aircraft that must com ply with Section 91.119. **14 CFR §**  **91.1 21: Altimeter Settings**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altim eter that is set “ ...to the elevation of the departure airport or a n appropriate altim eter setting available before departure. ” As the sUAS will not have a barom etr ic altim eter, but instead a GPS altitude read out, an exem ption m ay be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Operating Manual and Safety Checklist, confirm ing the altitude of the launch site shown on the GPS altitude indicator before flight. **14 CFR §**  **91.151 (a): Fuel Requirements for Flight in VFR Conditions** Section 91.151 (a) prohibits an individual from beginning “ a flight in a n 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, assum ing norm al cruising speed

– (1) During the day, to fly af

ter that for at least 30 minutes ; or (2) At night, to fly afte r that for at least 45 minutes. ” The battery powering the sUAS provides approxim ately 2 0 minutes of powered flight . To meet the 30 minute reserve requirem ent in 14 CFR § 91.151, sUAS flights would be im possibl e. Given the lim itations on the sUAS ’ s proposed flight area and the location of its proposed operatio ns within a predeterm ined area, a longer tim e frame for flight in daylight or night VFR conditions is reasonable. Sky Edge Photography believes that an exem ption from 14 CFR § 91.151 (a) falls within the scope of prior exem ptions. See Exem ption 10673 (allowing Lockheed Martin Corporation to operate without com pliance with FAR 91.151 (a)). Operating the sUAS in a tightly controlled area where only pe ople and property owners or official representatives who have signed wai vers will be allowed, with less than 30 m inutes of reserve fuel, does not engender the type of ri sks that Section 91.151 (a) was intended to alleviate given the size and speed of the sUAS. Additional ly, lim iting sUAS flights would greatly reduce the utility for which the exem ption will be granted. Sky Edge Photography believes that an equivalent level of safety can be achieved by lim iting flights to 20 m inutes or 25% of battery power whichever happens first. This restrict ion would be m ore than adequate return the sUAS to its planned landing zone from anywhere in its lim ited operating area. Sim ilar exem ptions have been granted to other operations, including Exem ptions 2689F, 5745, 10673, and 10808.**14 CFR §**  **91.203 (a) and (b): C arry**  **ing Civil A ircraft Certification and Registration** 

The regulat ion provides in pertinent part: (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 airworthines s certificate... (b) No person m ay operate a civil aircraft unless the airworthiness certificate required by paragraph (b) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is l egible to passengers or crew

. The sUAS fully loaded weighs no m ore than 5 lbs. and is operated wit hout an onboard Pilot. As such, there is no ability or place to carry certification and registration docum ents or to display them on the sUAS. An equivalent level of safety w ill be achieved by keeping these docume nts at the ground control point where the Pilot flying the sUAS will have imm ediate access to them, to the extent they are applicable to the sUAS, and should they be issued. The FAA has iss ued num erous exem ptions to this regulation. A representative sam ple of other exceptions includes E xem ption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. **14 CFR §**  **91.405 (a) ;**  **407 (a) (2) ;**  **417 (a) & (b): Maintenance Inspections** These regulati ons require that an aircraft operator or owner “ shall have that aircraft inspected as prescribed in subpart E of this part and shall between required ins pections, except as provided in paragraph C of this section, have discrepancies repaired as prescribed in Part 43 of this chapter..., ” and others shall inspect or m aintain the aircraft in com pliance with Part 43. Given that these section and Part 43 apply only to aircraft with an a irworthiness certificate, these sections will not apply to the Sky Edge Photography. Maintenance will be accom plished by the operator ; pursuant to the Operating m anual. An equivalent level of safety will be a chieved because these sUASs are very lim ited in size and will carry a sm all payload and operate only in restricted areas for lim ited periods of time. If mechanical issues arise the sUAS can land immedia tely and will be operating from no higher than 200 ft. AGL. As provided in the Operating Manual, the PIC (operator) will ensure that the sUAS is in working order prior to initiat ing flight, and perform required m aintenance. Moreover, the operator is the person most familiar w ith the aircraft and best suited to m aintain the aircraft in an airworthy condition to provide the equivalent level of safety. **Publication Summary** Pursuant to 14 CFR 11.81(f), the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed: Applicant seeks an exem ption from the following rules: 14 CFR § 21, subpart H ; 14 CFR § 45.23 (b) ; 1 4 CFR § 61.113 (a) & (b) ; 91.7 (a) ; 91.9 (b) (2) ; 91.103 (b) ; 91.109 ; 91.119 ; 91.121 ; 91.151 (a) ; 91.203 (a) & (b) ; 91.405 (a) ; 91.407 (a) (1) ; 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially Sm all Unmanned Aircraft Systems (5lbs or less) in ph otography and videography operations.**Privacy**

All flights will occur over private or controlled access property with the property owner’ s prior consent and knowledge, or over rem ote public land. Im age capture of people wil l rarely take place, but in the e vent they are, they will have consented prior to being filmed or oth erwise have agreed to be in the area where data collection will take place. **Airborne Image Capture**
Wi th regard to airborne filming, Sky Edge Photography adheres to all FAA regulations. Further Sky Edge Photography airborne team s operate under the principles of: S afety First, Quality Assurance, Accountability, Reporting, and Training. W hen approved by the FAA, it is Sky Edge Photography’s ma ndate to treat all sUAS operations the exact sam e level of professionalism a nd seriousness as that of conventional aircraft. Approval of exem ptions allowing commercial operations of sUASs in our industry will enhance safety by reducing risk. Conventional operations, using turbine or piston powered aircraft, present the risks associated with vehicles th at weigh in the neighborhood of 2,000lbs.+, carrying large am ounts of Jet A or 100LL. Such aircraft m ust fly to and from location. In contrast, a sUAS weighing fewer than 5 lbs, and powered by batteries, el im inates virtually all of the risk , given the substantial reduced mass and lack of combustible fuel carried on board. The sUAS is typica lly transported to the location via auto, or cargo van, in a m edium sized case and is never flow n to t he site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with m anned aircraft. The operation of sUASs, weighing less than 5lbs, conducted in the st rict conditions outlined above, will provide an equivalent level of safety supporting the grant of t he exem ptions requested herein, including exem pting the applicant from the requirem ents of 14 CFR Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a ster ile environm ent. As a result, they are far safer than conventional o perations conducted with piston helicopters, or fixed wing aircraft operating in relatively close proxim ity to the ground and people. The prim ary m arket of interest for Sky Edge Photograp hy utilizing sUASs is aerial videography and photography. It is anticipated that the airborne im age capture process will be acco mp lished exclusively in daytim e VFR environments. To capture the highest quality of resolution t he m aj ority of airborne data collections w ill take place during the 10:00 am
– 4 :00pm window

.**Summary of A** **pplication** Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

– size, weight, speed, operating capabilities, proxim ity to airports and populated areas and operation within visual line of sight and national security

– provide m ore than adequate justification for the grant of the requested exem ptions allowing commercial operation of applican t ’ s s UASs for aerial videography and photography. Operating Manual appended hereto. Sky Edge Photography is eagerly standing by to support the FAA and sUAS community in its quest to establish prope r regulations and protocols for the safe introduction of un manned aircraft into the national airspace. Sincerely,
Alex Kim ball Sky Edge Photography 3981 Perch Circle Wi llits, CA 95490 707

-456

- 9303 abkim ball84@gm ail.com