Date: July 24, 2015

U.S . Department ofTransportation

Docket Management System

1200NewJerseyAve.,

SE Washington , DC 20590

Thomas L. Stiles Jr.

Private Pilot Cert #3435712

SkyShots Photography, LLC

9567 Winnepeg Ct.

Mechanicsville, VA 23116

804-550-1712

www.skyshots.com

RE: Petition of SkyShots Photography LLC for Exemption Pursuant to section 333. of the FAA

Reform Act

Attn: To whom it may concern

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

14 C.F.R . Part 11, SkyShots Photography LLC, operator of Small Unmanned Aircraft Systems (sUASs) equipped 

to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow commercial operation

of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.1

In recent history we have been bidding on jobs that have been bid by drone operators in our area and we find it 

difficult to compete with them. Therefore, we would like to add drone aircraft to our feet. All of our drone operators 

will be rated pilots.

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive sUAS under controlled conditions in airspace that is

The proposed exemption, if granted, would allow SkyShots Photography, LLC to conduct commercial 

operations of small, unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and 

safety requirements Congress has set forth in Section 333.
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SkyShots Photography, LLC is a media/technology company that plans to use the capabilities of Unmanned

Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Agricultural support

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS

operations in the NAS. Section 333(a) states that the FAA “shall determine if certain

unmanned aircraft systems may operate safely in the national airspace system before

completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of

this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1),

Congress made it clear that Section 333 provides a mechanism for “expedited operation

authorization” if several factors are met. Petitioner meets all requirements to permit FAA

approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

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

14 C.F.R. 91.109
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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. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System

sUAVs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment

and personnel cost, reduced noise and as such, a much smaller environmental impact which

promotes public safety.

We are petitioning for exemption to enable, SkyShots Photography, LLC to operate a DJI

Phantom 3 and the DJI Inspire 1, both are equipped with a three-axis gimbals and using HighDef cameras. These sUAV have a built-in capability to limit the height they fly above the ground, to

limit the radius of the distance they fly from the operator and to exclude it from Class B, C and D

airspace including a no-fly zone feature.

The above specifications meet with the Model Aircraft Operating Standards as set

below:

• SkyShots Photography, LLC will only operate its sUAS in line of sight of a pilot and/or

Observer and will operate at sites that are a 'sufficient distance' from populated areas within the

sterile area described in the FOPM. Such operations will insure that the sUAS will "not create a

hazard to users of the national airspace system or the public."

• When flying sUAV within 5 miles of an airport, airport operators will be notified and the

operator will give the right of way to avoid flying in the proximity of full-scale aircraft.

 Maximum flight time for each operational flight will be 20 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 20

minute limit.
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 The sUAV will be programmed so that it will not be operated at an altitude of no more

than 400 feet AGL, and not more than 200 feet above an elevated platform from which

filming is planned.

 The sUAS operated by the petitioner weighs less than 55 pounds, including the payload

(i.e. camera, lens, and gimbal).

 The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

 Given the small size of the sUAS and the restricted sterile environment within which

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, it operates at lower altitudes with no people on board and will

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of

death or serious bodily injury. With a small payload and maximum flight time of only 20

minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground based

imagery for displaying the characteristics of large, complex properties with several buildings and

large trees. The applicants in the past have chartered 2-seat full-sized helicopters for this

purpose, which has proven more costly than many potential clients have been able to afford.

The benefits of reduced cost and improved quality of presentation from the UA will be valuable

to and benefit many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al.,

while remaining subject to all limitations cited in this application as we do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;
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(b)

(c)

(d)

(e)

All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an

airspeed of no more than 25 knots and no further than 1/8th NM from the PIC;

All operations must utilize a visual observer (VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation;

Operations will be restricted to flights over private property with the permission of the property

owner;

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

(f) SkyShots Photography, LLC will not be operate over densely populated areas;

(g) SkyShots Photography, LLC will not be operating over any open-air assembly of people;

(h) SkyShots Photography, LLC will not be operating over heavily tracked roads;

(i) SkyShots Photography, LLC will not be operating within 5 NM of an airport or heliport without prior

permission.

We respectfully request exemption under Section 333 to enable, SkyShots Photography, LLC to operate

efficient, limited, low-risk commercial sUAV operations for the activities stated respecting at all times the

space and privacy of citizens and property whilst keeping our skies safe. 

Sincerely,

Thomas L Stiles, Jr
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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

SkyShots Photography, LLC requests an exemption from the following regulations as well as any additional

regulations that may technically apply to the operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an

experimental certificate be issued for the DJI Phantom 3 and DJI Inspire 1under either or both of

the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to

show compliance with the airworthiness regulations including flights to show compliance for

issuance of type and supplemental type certificates, flights to substantiate major design changes,

and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys,

sales demonstrations, and customer crew training, we would expect that an experimental certificate

would permit our commercial purpose as well. The aircraft will not carry persons or property, will

not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light

weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at

least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If

an experimental airworthiness certificate is not appropriate for this application, then we request an

exemption of 14 CFR Part 21, Subpart H,
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and the requirement for an airworthiness certificate in general, citing the equivalent level of safety

outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.These regulations provide

that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches

high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches

high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance

in which the word "EXPERIMENTAL" can be placed, and may not have a registration number

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the

word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC

(Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing

for launch will be able to see the designation. Additionally, we feel that the permanent placard

discussed in the previous paragraph will provide the aircraft's registration information at the ground

station.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as

pilot in command of an aircraft in connection with any business or employment if: (1) The flight is

only incidental to that business or employment; and (2) The aircraft does not carry passengers or

property for compensation or hire. Our proposed operations require that the PIC must hold at least

a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or

property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable.
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14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This

regulation provides that no person may operate an aircraft unless a current, approved flight manual

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual

information is available to the aircrew while operating the aircraft. We request an exemption to this

requirement since the aircraft is not only too small to carry documentation, the documentation would

not be available to the crew during flight operations. To obtain an equivalent level of safety and

meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available

to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The

regulation states that "No person may operate a civil aircraft that is being used for flight instruction

unless that aircraft has fully functioning dual controls." The sUAS System ground- based control

station consists of a small hand-held radio transmitter and while it does not offer a second set of

"controls", both the student and instructor can, and will, operate the single set of controls

simultaneously. With both student and instructor having "hands-on" the controls during flight, we

feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated

areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or

structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels,

vehicles or structures it would be necessary to operate closer than 500 feet to the items listed.

Operations will only be flown over property or persons where permission has been obtained and

careful pre-planned has been performed. The aircraft will be operated at a low altitude allowing, if a

power unit fails, an emergency landing without undue hazard to persons or property on the surface.

Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and

structures is minimal compared to manned aircraft, which should be considered in granting the

exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising

altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will

always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent
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conflict with other aircraft

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least

30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer

for delays to landing. The sUAV is battery operated and the maximum duration of flight from a single

battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than 1/8 NM

from the point of intended landing, a full battery charge at launch will ensure that we meet the

reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask

for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b)

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is

legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the sUAS is too small to

carry documentation, does not have an entrance, and is not capable of carrying passengers or crew.

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents

deemed appropriate for this aircraft by the FAA will be co- located with the crew at the ground

control station and available for inspection upon request. In order to identify the aircraft, we

propose that the information found on airworthiness and registration certificates be permanently

affixed to the aircraft via placard containing the following information plus the word

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409

require that the aircraft be "approved for return to service by a person authorized under 43.7" after

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of

the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that

the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed

inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing
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small cracks, replacing a propeller, checking electrical connections and updating software and

firmware for the on-board computer. All other maintenance will be performed by the manufacturer

or their designated repair facility. The PIC will document work performed in accordance with

91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure

an equivalent level of safety.

Safety and Benefits of the UAS

SkyShots Photography, LLC will be using the UAS in a variety of applications that generally require

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer

myriad benefits over the use of full-sized manned aircraft for electric power line inspection, oil/gas

pipeline inspection, advanced agriculture, film and still photography, just to name a few. Replacing

significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no

passengers or crew creates a much greater margin of safety for the pilots and crew.

By granting SkyShots Photography, LLC requested exemptions, the FAA will help drive development of safe and

successful commercial UAS operations and will advance the public knowledge base for such operations.

SkyShots Photography, LLC is committed to promoting the UAS research efforts of policymakers including the

FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for

future UAS research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion

As pointed out in this application, all the SUAs which our company would use, under authorization by

the US DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-inCommand (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport,

seaplane base, spaceport, or other location with aviation activities, unless the air traffic control

authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general sale

on the market around the world and have often been used as Model Aircraft in the USA. We are

certain that the studies conducted until now by the FAA, about Section 332, Public Law 112-95,

2014, have already provided you with the assurances on the airworthiness of SUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and SkyShots 

Photography, LLC should be permitted to conduct small UAS operations in accordance

with its manuals and all other operating parameters deemed necessary and appropriate by the FAA.
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The submission of this application and its contents is the best demonstration that indeed it is possible

to pursue the authorization process so that some SUAs may be used for legitimate commercial

activities and underreasonably safe conditions.