July 6, 2015 U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590 Submitted Electronicallyvia the Federal Docket Management System (FDMS) Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: On Behalf ofSkycraft Media, LLC, and Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, IJoseph Harrington, President ofSkycraft Media, LLC, am seeking an exemption from Part 21 Subpart H; and Sections 91.203 (a) (1), 45.23 (b), 91.7 (a), 91.9, 61.113, 61.133, 91.109, 91.119, 91.121, 91.151, and (91.401- 91.417) Subpart E, ofTitle 14, Code of Federal Regulations (14 CFR). This proposed exemption would allowforthe operation ofour unmanned aircraft (UAS) are: • DJI Phantom 3 • DJIInspire 1 • DJI S900 

### THE UNMANNED AIRCRAFT SYSTEMS {UAS): • The UAS's are lightweight (under 551b. gross weight), battery operated Multi Rotor copters that take offand land vertically and have the abilityto hover maintaining asingle position. 

### EACH UAS INCLUDES:

• An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from aground-based transmitter/controller; • An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video • An on-board telemetry system that delivers flight data from the on-board flight computerto the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site • A 5.8GHz on-board radio transmitterthattransmits live video from the on-board camera plus all the flight data from the telemetry system described above 

### THE GROUND STATION PART OF THE SYSTEM:

• A Pilot in Command (PIC) who is charged with operational control of missions from beginning to end, and who controls the UAS while in the air • A 2.4GHz radio transmitter/controlleroperated by the PIC to control the UAS while in flight • Ground Station (computer, tablet for smart phone based app) which receives and displays video and system telemetry real timefrom the UAS • A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UAS while in flight. Skycraft Media, LLC.- SECTION 333 EXEMPTION REQUEST Page 

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### 3PILOT IN COMMAND (PIC) AND VISUASL OBSERVER: The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training. Isubmitthat the combination ofthe UAS's lightweight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions listed above, the FAA can have full confidence thatthe operation will have an equivalent or greater level ofsafety than manned aircraft performingthe same mission. INTENDED USE: The requested exemption would allow us to use the UAS for aerial image acquisition to support various mapping and surveying applications as well as video documentation and training for the public good. Typical applications would include, but are not limited to: 

# • Videography /Film-making 

# • Aerial Photography 

# • Aerial Mapping 

# • Architectural Surveys 

# • Archeological Surveys 

# • Disaster Monitoring 

# • Education/Training The inherent ability ofthe UAS is to capture imagery from a low altitude including oblique photos and video from several angles is far more effective than ground based imagery for displaying the characteristics of buildings, sites and properties or areas where consistent monitoring is needed. The reduced cost and higher quality data from the UAS will be beneficial to the public in applications such as preservation of historic buildings or archeological sites where access is limited and project sites potentially sensitive to disruption. Skycraft Media, LLC, is a reseller of UAS's and as part of our operations we would like to be able to incorporate education and training programs for our customers. PUBLIC SAFETY: UAS's, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft running on combustible fuel; they operate at lower altitudes (under 400') with no people on board thereby reducing current risk levels and enhancing public safety. With a small payload and maximum flight time ofapproximately 22 minutes, UAS's offer little or no risk to national security. Skycraft Media, LLC, intends to offer training and education programs, thereby reducing risk and improving operator safety as part oftheir purchase. In addition the DJI UAS's have their own built in flight restrictions in special areas such as airports, which limit flight in these areas. More information can be found in the UAS's User Manual or on DJI's website at https:/ /www.dji.com/fly-safe.

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### 3SUMMARY GRANT REQUEST: This request follows many others using similar systems and process that have been granted previously. I am requesting the FAA issue asummary grant ofexemption, as this request would not set a precedent.

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213 and 11624 also applyto this request • A grant ofexemption would be in the public interest. THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith a proposed equivalent level ofsafety for each regulation:

- 14 CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a} (1) Addendum Page 1

- 14 CFR 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2

- 14CFR 91.9 Addendum Page 2

- 14CFR 61.113, 61.133 Addendum Page 2 -14 CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14CFR 91.151 Addendum Page 3

- 14CFR Subpart E(91.401- 91.417) Addendum Page 4 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am prepared to modify or amend any part ofthis request to satisfythe need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification. I am the primary point of contact forthis request and lookforward to workingwith your office.

Jose Harrington President Skycraft Media, LLC Phone: 813-326-5920 Email: info@Skycraftmedia.com Addendum Containing Exemption Requests and Equivalent Level ofSafety Appendix A- Flight Operations/Procedures Appendix B-User's Manuals

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### 3ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY I, Joseph Harrington, President of Skycraft Media LLC, request an exemption from the following regulations as well as any additional regulations that may technically apply to the operations ofthe DJI Phantom 3, DJIInspire 1, and DJI S900 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. 91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR 91.203( a) (1). 

### Given the size and limited operating area associated with the UAS to be utilized by the Petitioner, an exemptionfrom Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 andSection 333 ofthe FMRA. The FederalAviationAct {49 U.S.C.44701 (f)) and Section 333 ofthe FMRA both authorize the FAA to exemptaircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas oftheparticular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment 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 certificate withoutthe restrictions andconditionsproposed. The UAS tobeoperatedhereunderis less than 55 lbs.fully loaded, is bydefinition unmannedandcarries neither a pilot norpassenger, carries no explosive materials orflammable liquidfuels, and operates exclusively within a limitedflight area. Unlike other civil aircraft operations under this exemption will be tightly controlled and monitored by the Operator and will also remain within the requirements of, and in compliance with local public safety requirements. These safety enhancements, which already apply to civil aircraft provide a greater degree ofsafety 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 ofthese same criteria demonstrates that there is no credible threat to national securityposed by the UAS due to its size, speed ofoperation, location ofoperation, lack of explosive materialsor flammable liquidfuels, andinability to carry asubstantialexternalload.

14C.F.R. 45.23 (b). Marking ofthe Aircraft The regulation requires; When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

### Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin; cockpit orpilot station on which the word "Experimental" can be placed. Given thesize ofthe UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on thefuselage in compliance with 45.29 (f). The equivalent level ofsafety will beprovided by Skycraft Media LLC.- EXEMPTION REQUEST AND LEVEL OF SAFETY Page 

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### having the UAS marked on itsfuselage as required by 45.29 (f) where the pilot_ observer and others working with the UAS willsee theidentification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 14C.F.R. 91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate acivil aircraft unless it is in airworthycondition. 

### As there will beno airworthiness certificate issuedfor the aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements containedhereinfor the use ofsafetycheck listspriorto eachflight, an equivalentlevel of safetywillbeprovided. 14CFR 91.9 Civil aircraftflight 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 ofthis 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 duringflight operations. 

### To obtain an equivalent level ofsafety and meet the intent of91.9, we propose that a current, approved UAS Flight Operations/Procedures (AppendixA) mustbe available to the crew at the ground station anytime the aircraftis in, orpreparingfor,flight. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

### 8607, 8737, 8738, 9299,9299A,9565,95658, 10167, 10167A, 10602,32827,and10700. 14CFR 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. 

### Ourproposedoperations require that the PICmusteither

1. Hold a Private orSport Pilot Certificate issued bythe FAA, andhave logged 10hours of flight experience in this type ofUAS, or 2. Meet the requirements of8900.227para 16{c}{2}{c) "Operations withoutapilotcertificate"in which the PIC is required to complete "FAA private pilot ground instruction" andpass "the FAA Private Pilot written examination." Since there are currentlyno means availablefor the pilotofa UAS to gain the experience in an equivalent categoryandclass in orderto applyfor aprivatepilot's license, wepropose to generate an equivalentlevel ofsafetybyrequiring our Skycraft Media LLC.- EXEMPTION REQUEST AND LEVEL OF SAFETY Page 

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### pilots to complete, at a minimum, FAA private pilot ground instruction and pass the FAA Private Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers orproperty, wefeel that we meet the intent of 61.113 Subparagraph (b) even though the intentofthis application is to conducta business. 14CFR 91.109 Flight Instruction; Simulated instrumentflight 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 VAS's ground-based control station consists ofa 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 setofcontrols simultaneously. With both studentand instructorhaving "hands-on" the controls duringflight, wefeel that this technique meets the intent 91.109 andprovides an equivalent level of safety. 14CFR 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 aircraft will be operating at a maximum of400 feet AGL, we cannot complywith this requirement. 

### In ordertoprovide an equivalentlevelof safetyThe VAS's willnotbe operatedovercongestedareas or overanyopen airassemblyof persons withpriorapproval. Anypropertyowneraffected will be briefed on the expected route of flight and the associated risks to persons andproperty on the ground. The aircraft will beoperatedata low altitude allowing, 

## ifapowerunitfails, an emergencylanding without undue hazard to persons orproperty on the surface. Therefore we maintain that due to the smallsize ofthe VAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which shouldbeconsideredin granting the exemption. 14CFR 91.121 Altimeter Settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. 

### The VAS will alwaysfly below400feetAGL and will notneed to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimetermeasurement above the takeoff pointis transmitted via radiofrom the VAS'S on-board computerto the display screen held bythe PIC, providing aconstantlyupdatedAGL readout. 14CFR 91.151 Fuel requirements forflight 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. 

### The intention ofthisparagraph is toprovide an energyreserve as a safetybufferfor delays to landing. Each VAS is battery operated and the maximum duration of flightfrom a single battery charge is Skycraft Media LLC.- EXEMPTION REQUESTAND LEVEL OF SAFETY Page 

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### approximately 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 3/4NMfrom the point ofintended landing, afull battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word ''fuel" and askfor an equivalentinterpretation with the word "energy". 14CFR 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 airworthycondition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. 

### It is ourintention that the PICperform maintenanceand inspection ofthe aircraftand "be authorized to approve the aircraftfor return to service." Asprovided in the Pre-Flight Checklist in Appendix

### A the PIC will ensure that the aircraft is in an airworthy condition prior to everyflight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing smallcracks, replacing apropeller, checking electrical connections and updating software and firmwarefor the on-board computer. All othermaintenance will beperformed by the manufacturer or their designated repairfacility. The PIC will document workperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety. 8900.227 Paragraph 16(c)(4) PIC Medical. And Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot or observer. 

### The UAS's maximum gross weight are each less than Bibs., are constructed primarily of, plastic and carbonfiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is inflight_ the UAS will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as commercial pilot carryingpassengers in a large aircraftis an unnecessaryburden. Wepropose thattheminimummedicalrequirementsfor thePICand VO be vision correctedto 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

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### 4APPENDIX A- FLIGHT OPERATIONS/PROCEDURES The UAS's will be operated underthe following flight restrictions.

OPERATIONAl FLIGHT RESTRICTIONS The UAS will be operated in the field with both a PIC and aVO in accordance with and with the following Restrictions:

• All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 25 knots and no furtherthan 3/4 NM from the PIC; • All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice at all times during aflight operation; • The PIC must have accumulated and logged, in a manner consistent with 14 CFR § • 61.51 (b), 10 hours of total time as a UAS rotorcraft pilot and at least 5 hours logged as a UAS pilotwith a similar UAS type; • The UAS will not be operated over densely populated areas; without priorapproval. • The UAS will not be operated over any open-air assembly ofpeople; without priorapproval. • The UAS will not be operated within 5 NM ofan airport or heliport; without prior approval. • Operations will be restricted to day only and weather conditions equivalentto VFR; • The PIC will briefthe VO and property owneraboutthe operation and risk before operation • No flight will be made without a Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UAS is in acondition safe forflight

PRE-FLIGHT CHECKLIST Prior to operation preflight checklists provided by the manufacturer of the UAS's will be followed. Below is such an example. 1. Remote Controller, smart battery, Range Extender and smartphone are fully charged. 2. Propellers are mounted correctly. 3. Damping absorbers are in good condition, not broken orworn. 4. Camera lens cap has been removed. 5. Micro-SO card has been inserted ifnecessary. 6. Gimbal is functioning as normal. 7. Motors can start and are functioning as normal. 8. Smart phone App can connect to the camera.

Skycraft Media LLC- APPENDIX A- FLIGHT OPERATIONS AND PROCEDURESTAKE OFF/lANDING PROCEDURES Manufacturer recommended Takeoff and Landing procedures will be followed. Place the UAS on ground with the battery level indicatorfacing you. 

### 1. Power on the remote controller. 2. Power on the range extender. 3. Switch the camera to the "WIFI ON" position. 4. Power on the aircraft by turning on the intelligent battery 5. Connect the mobile device to the UAS, run the Smart phone App to enterthe camera preview page. 6. Wait until the LED flight indicator starts to slowly blink green/yellow. This means the aircraft is initializing and entering the "Ready to Fly"/"Ready to Fly (non-GPS)." state. Then proceed to execute the

# esc command to start motors. 7. Push thethrottle stick up slowlyto liftthe aircraft offthe ground. 8. When landing, be sure to be hovering over a level surface. Pull down on the throttle stick gentlyto descend and land. 9. After landing the aircraft on the ground, keep the throttle stick at its lowest position for about 3to 5 seconds, which will automatically stop the motors. FAILSAFE FUNCTION The UAS will enter Failsafe mode when the connection from the remote controller is lost. The flight control system will automatically control the aircraft to return to home and land to reduce injuries or damage. The following situations would make the aircraft fail to receive a signal from the remote controller and enter Failsafe mode: 

### 1. The remote controller is powered off. 2. The aircraft has flown out ofthe effective communication range ofthe remote controller. 3. There is an obstacle obstructing the signal between the remote controller and aircraft, essentially reducing the distance the signal can travel. 4. There is interference causing a signal problem with the remote controller.

Skycraft Media LLC- APPENDIX A- FLIGHT OPERATIONS AND PROCEDURESAPPENDIX B-USER'S MANUASLS DJI Phantom 3, DJIInspire 1, DJI S900

Users Manuals foreach ofthese systems can be downloaded here. Skycraft Media, LLC, keeps a copywith each UAS. http://www.dji.com/product/phantom-3/ download http:/ /www.dji.com/product/inspire-1/download http:/ /www.dji.com/product/spreading-wings-s900/download Upon request these will be provided

Skycraft Media LLC APPENDIX B-User's Manuals