### 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 requiredprocedures, 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 asmarket 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 wemeet 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 o ffi cial 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 a ff ect 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 overproperty 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 unduehazard 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 takeo ffpoint 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 bu ff er 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 permanentlya ffi xed 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 e ff ective 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 a ff ect 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 o ff er more e ffi cient 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 a ff ord 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 e ffi cient 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, sheri ff , 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 requestPilot 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 takeo ff s and landings within 30 days in the type of UAS utilized in operations.

The PIC is responsible for the safe and e ffi cient 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 'su ffi cient 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 takeo ff course of any runway. The UAV will not be operated at an altitude of over 4 00 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 o ff ers little or no risk to national security.



### 6. Federal Register S ummary

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. C onclusion

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,

SkyC hase Designs, LLC
Matthew Michael Chase

### 229 Cedar Mill Lane Woodstock, Georgia 30189

Phone: 770-364-2240 Email: Matthewmchase@gmail.com