U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., 

SE Washington, DC 20590

SKYCHASE DESIGNS LLC PETITION FOR EXEMPTION TO

OPERATE UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 

333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Proposed Use:

Aerial video and photography for the purpose of creating content for:

Real estate photography

Aerial cinematography and photography for personal and business

Construction site inspection and monitoring

Corporate and business promotional videos and stills

Aerial video and photography of business and private events

Property mapping and survey, boundary discovery services.

Search and Rescue contract or Volunteer Work

Conservation and wildlife photography

Tour or vacation videography capture for personal or business purposes.

Proposed Aircraft: DJI Inspire 1, 3DR Solo

Petitioner’s Name and Address:

Skychase Designs, LLC

Matthew Michael Chase

229 Cedar Mill Lane

Woodstock, Georgia 30189

Phone: 770.364.2240

Email: matthewmchase@gmail.com

On or about August 15, 2015 the FAA granted exemptions to over 700 hundred 

UAS operators. It is in good faith that this exemption request will follow the 

same outline of the exemptions granted for the same general intents and 

purposes to commercially operate UASs.
1. The specific section or sections of 14 CFR from which 

SkyChaseDesigns LLC seek an exemption;

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

14 C.F.R. 91.119

14 C.F.R. 91.121Page 3

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)

2. The extent of relief you seek and the reason SkyChase Designs LLC 

seek the relief;

Pursuant to Section 333(a) through (c) (“Section 333”) of the FAA Modernization 

and Reform Act of 2012 ("Reform Act")1 and the Federal Aviation 

Administrations’ (“FAA”) general exemption authority under 49 U.S.C. §44701(f), 

SkyChase Designs LLC (“Petitioner”) petitions for exemption from 14 Code of 

Federal Regulations (“CFR”) sections: The proposed exemptions, if granted, 

would allow Petitioner to operate small unmanned aircraft systems ("UAS") 

weighing 55 pounds or less for the purpose of creating content for: real estate 

photography, aerial cinematography and photography for personal and 

business, construction site inspection and monitoring,corporate and business 

promotional videos and stills, aerial video and photography of business and 

private events,property mapping and survey, boundary discovery services, 

search and rescue contract or volunteer work, conservation and wildlife 

photography, tour or vacation videography capture for personal or business 

purposes.

SkyChase Designs LLC will seek to operate for commercial purposes two UAS a 

DJI Inspire 1 and 3DR Solo

A pre-flight inspection will be performed by the PIC in accordance with the 

factory instruction manual and additionally SkyChase Designs LLC required 
procedures, checklist and internal flight plan will be executed, as well as 

redundant checks to include the Internal Measurement Unit (IMU) to make sure 

that the compass, gyro and acceleration values are within specs, positive GPS 

locks are secure, battery health and charge status, and communication from 

ground station to UAS are within acceptable parameters for safe flight.

A Safety Briefing will be administered by the PIC to all participants in and around 

the proposed flight. All consenting persons and flight crew within the flight plan 

vicinity will be made aware of the flight and associated safety standards and 

procedures as well as proper action in the case of an UAS emergency, which 

may result in harm to the UAS itself, property or persons.

Based on the diminutive size of Petitioner’s UAS (DJI Inspire 1 and 3DR Solo 

which are well under 55 pounds including payload of batteries and all 

cinematography attached equipment needed for flight. The qualifications and 

experience of Petitioner’s UAS operators, the requested exemptions fall squarely 

within the zone of safety envisioned by Congress and set forth in Section 333. 

Additionally, the enhanced safety achieved by replacing significantly larger 

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

passengers or crew and operated under the specific guidelines and procedures 

proposed by Petitioner gives the FAA good cause to find that the UAS 

operations enabled by this petition are in the public interest.

SkyChase Designs LLC requests an exemption from the following regulations.

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 Inspire 1 and 3DR Solo under 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 UAS's light 

weight, being constructed primarily of carbon fiber and plastic, we propose that 

the UAS 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, 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 UAS 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. Finally, we will display at 

the ground station a high contrast flag or banner that contains the words 

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the 

aircraft will operate within 0.263 NM of the ground station, the banner should be 

visible to anyone that observes the aircraft and chooses to investigate its point 

of origin.

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 with a Class III Medical 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.

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 UAS Flight Manual must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight, and ready for presentation for 

any governing official upon request.

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. 

Although the DJI Inspire 1 is capable of duel/linked controls, SkyChase Designs 

LLC will be operating with a single remote controller, a second remote can in 

some instances be used by a non PIC too control the aerial camera only. This 

second remote does not affect or interfere with PIC primary responsibility of safe 

operation of UAS while maintaining line of site at all times via direct view of UAS 

of PIC or real time position reporting by authorized and trained spotters in the 

rare cases that direct view of UAS is impeded.

14 CFR 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 UAS 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 preplanned flight path 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.

14 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 UAS will 

always fly below 400 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An Above Ground Level altimeter 

measurement above the takeoff point is transmitted via radio from the UAS onboard computer to the display screen held by the PIC, providing a constantly 

updated AGL readout. Both UAS have manufacture imposed limiters that will not 

allow either the DJI Inspire 1 or 3DR Solo to operate above 400 feet AGL.

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 UAV 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 0.263 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 6.47 pounds, the UAS 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 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. 

Maintenance performed by the PIC is limited to repairing 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.

3. How SkyChase Designs LLC request would benefit the public as a 

whole;

The request for this exemption is in the Public Interest as it is safe to assume 

that there are many consumer applications for the services that can be provided 

by UAS systems. It is clear that the Congress of the United States, the business 

sector, and the consumer want to integrate Unmanned Aircraft Systems into the 

National Airspace System and utilize their unique and cost effective capabilities. 

It is also in the Public Interest that many of the low level flight operations now 

conducted by manned aircraft could be accomplished with these light, fire 

resistant unmanned aircraft that can operate at a fraction of the cost to both the 

operator and consumer. These aircraft can be operated without risk of loss of life 

or limb, without significant financial impact to the operator or any person or 

property on the ground in the event of the loss of an aircraft. Finally the 

petitioner believes that granting this exemption would help to further by 

Administrators process of integration of UAS systems and possibility help to 

create additional regulations and guidance to be used as these systems become 

more widely utilized.
4. Reasons why the exemption would not adversely affect safety, or how 

the exemption would provide a level of safety at least equal to the existing 

rule;

Safety and Benefits of the exemption for UAS employed by SkyChase Designs 

LLC.

SkyChase Designs 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 more efficient and safer benefits over the use of 

full-sized manned aircraft for aerial photography. 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 SkyChase Designs LLC’s 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. In the event of an 

emergency due to the diminutive size of the UAS being used and lack of 

flammable fuel sources being employed, the safety of participants or non 

participating bystanders is greatly reduced. 

Local community businesses will have access to aerial marketing content to 

promote and expand their business otherwise not available or achievable due to 

the cost of gaining similar marketing content and services via manned aircraft, 

this content acquisition previously was reserved for larger corporations that 

could afford to acquire this content at a much higher cost via manned aircraft. 

The result of SkyChase Designs LLC exemption being granted is that local 

business will be able to expand and improve via more efficient delivery of their 

associated services and or products; this will impact the local economy they 

operate due to increased tax revenue and the creation of jobs for local 

population. The community as a whole will benefit. 

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

responders who request the capabilities of SkyChase Designs LLC UAS’s in 

their operations, including: fire fighters, police, sheriff, water front lifeguard 

operations ,etc., all while operation under and within exemption limitations 

previously requested from FAA.

5. Additional information, views, or arguments available to support 

your request
Pilot in Command and Observer Qualifications and Duties

The PIC will maintain at least a Private Pilot Certificate and a current State 

issued driver’s license, plus at least 2 hours flying time and 3 takeoffs and 

landings within 30 days in the type of UAS utilized in operations.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific 

duties include all preflight preparation and inspection, in flight operation, post 

flight requirements, and all procedures including but not limited to:

1. Safe in flight operations

2. Risk evaluation

3. Current weather conditions for safe flight

4.The Observer must have the visual acuity to observe the UAS and be able to 

communicate clearly with the PIC. 

5 Monitor appropriate Unicom Frequency of Airports in the region of UAS flight 

plan operation.

The Observers duties are:

1. Warning the PIC of any impending obstacles in the flight path of the UAS.

2. Warning the PIC of any deviations in the planned flight path of the UAS.

3. Warning the PIC should any unauthorized personnel appear in the area of the 

planned

flight.

The Observer will have the authority to order the PIC to terminate the flight 

should he feel the flight cannot be conducted safely.

General Operating Standards

1. SkyChase Designs LLC will only operate its UAS in line of sight of a pilot 

and/or observer and will operate at sites that are a 'sufficient distance' from 

populated areas. Such operations will insure that the UAS will "not create a 

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

2. Before an operation of a UAS within 5NM of an airport with a control tower, 

the control tower will be called to gain permission to operate the UAS. The PIC 

will give the position, altitude and the times the UAV will be operated. The UAS 

will not be operated at an altitude of over 400 feet AGL. Weather minimums will 

be 3 miles visibility and a 1000 foot ceiling.
3. Before an operation of a UAS within 5NM of a non-tower controlled, airport 

operators will be notified and the PIC will give the right of way to avoid flying in 

the proximity of non UAS manned aircraft. At no time will the UAS be operated 

within the final approach course and the takeoff course of any runway. The UAV 

will not be operated at an altitude of over 400 feet AGL. Weather minimums will 

be 3 miles visibility and a 1000 foot ceiling.

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

5. Flights will be terminated at 25% battery power reserve should that occur 

prior to the 20 minute limit.

6. The UAV 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.

7. Minimum crew for each operation will consist of the UAS Pilot, and Visual 

Observer.

8. The UAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbals).

9. The UAS will operate at speeds of no more than 45 knots, can hover, and can 

simultaneously move vertically and horizontally.

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

able to communicate by voice or direct real time electronic transmission (cell 

phone, unicom, radio), at all times during a flight operation

11. Operations will be restricted to flights over private property with the 

permission of the property owner;

12. All required permits will be obtained from state and local government prior to 

operation

13. SkyChase Designs LLC will not be operated over densely populated areas.

14. SkyChase Designs LLC will not be operating over any open-air assembly of 

people.
The UAS, powered by batteries, is smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel. The UAS operates at lower altitudes 

with no people on board and will thereby reduce current risk levels, 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 offers little or no risk 

to national security.

6. Federal Register Summary 

Skychase Designss LLC “Petitioner” seeks an exemption from the following 

rules in Title 14 of the Code of Federal Regulations: 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. 91.109,14 C.F.R. 91.119,14 C.F.R. 91.121Page 3,14 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)

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 with conventional fixed-wing aircraft, rotorcraft, or other 

methods.

7. Conclusion 

SkyChase Designs LLC 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.

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

Should you have any questions, or if you need any additional information to 

support the requested exemptions, please do not hesitate to contact us.

Sincerely,

SkyChase Designs, LLC

Matthew Michael Chase
229 Cedar Mill Lane

Woodstock, Georgia 30189

Phone: 770-364-2240

Email: Matthewmchase@gmail.com