### February 8 2016 

### Federal Aviation Administration U. S. DepartmentofTransportation Docket Management System 1200 

### NewJerseyAve., SE Washington, DC 20590 

### RE: Petition of Sky Shots State College, LLC for Exemption Pursuantto Section 333 

### ofthe FAA Reform Act Petitioner's Name and Address: Sky Shots State College, LLC Owners: EricAllen 334 

### BoaiAve Boalsburg PA 16827 570-220-2276 

### Eric@boalsburgcarco.com
To whom it may concern: Pursuant to Section 333 

### of the FAA Modernization and Reform Act of 2012 

### (the ReformAct) and 14

### CFR Part 11, 

### Sky Shots State College, LLC, operatorof Small UnmannedAircraft Systems ("sUAS'1 equipped to conduct aerial photography and videography, hereby appliesfor an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUAS, so long as such operations are conducted within and underthe conditions outlined herein or as established bythe FAAas required by Section 333.1 

### As described more fully below, the requested exemption would permitthe operation of small, unmanned sUAS undercontrolled conditions in airspace that is 1) 

### Limited 2) Predetermined and 3) Controlled. The proposed exemption, ifgranted, would allow Sky Shots ofState College, LLC to conduct commercial operations of sUAS meeting or exceeding all ofthe operational and safety requirements setforth in Section 333. 

### Sky Shots State College LLC is an aerial photography and cinematography company owned and operated by EricAllen. Sky Shots State College LLC plansto use the capabilities of sUAS to offer a multitude of services, including:

- Construction site inspection and monitoring

- Event PhotographyNideography -Agriculture and Livestock monitoring -Water level monitoring

- Real Estate Photography/presentation/appraisals

- Aerial nature photography

- Utility Inspections Petitioner meets all requirements to permit FAA approval of commercial UAS operations.The name and addressofthe applicantare: Name: Sky Shots State College LLC Owner: EricAllen Address: 334 Boal Ave Boalsburg Pa 16827 Phone: 570-220-2276 Email: eric@boalsburgcarco.com Regulations from which the exemption is requested: 14CFR61.113(a) and (b) 14CFR 61.23(a) and (c) 14CFR 61.101 (e) (4) and (5) 14 CFR 61.315 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14CFR 91.109 14CFR91.119 14CFR 91.121 14CFR 91.151(a) and (b) 14 CFR 91.203 (a) 

### &(b) 14 CFR 91.205 (b) 14 CFR 91.215 14 CFR (91.401

- 91.417)
In addition to providing cost savings and having little to no impacton the environment, sUAS provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests thatthe FAAgrantthe requested exemption without delay.
Petitioner is requesting an exemption to enable Sky Shots State College, LLC to operate a 3DR Solo and a DJIInspire 1, sUAS that is upgraded to latestversion firmware, equipped with a 3 axis camera gimbal, which uses a High-Def. video camera that can capture up to 4K (4096x2160p) video and 12M pixel photos. ThesUAS has a built-in capabilityto limit 1)the height itflies abovethe ground and 2) the radius ofthe distance itflies from the operator. Both the 3DR Solo OJI Inspire 1 also has the fail-safe function ofthe autopilot system, when communication between the Main Controller and thetransmitter isdisconnected, the system will automaticallytriggerReturn to Home andwill land safely.
The 3DA solo weighs 3.9 lbs and the DJI Inspire 1 6 lbs
The PIC will conduct a pre-flight safety check before all flights, in accordance with the factory instruction manual, aswell as redundant checks to includethe Internal Measurement Unit (IMU) to make surethatthe compass, gyro and acceleration values arewithin specs, positive GPS locks are secure, battery health in each individual LiPo cells are balanced, and radio signals are locked in. The sUAS will be maintained in accordance with the manufacturer's instruction manual and only manufacturer's authorized replacement partswill be used.
FCC InformationAll transmitters used for controlling the sUAS complies with part 15ofthe FCC rules. Operation is subjectto the following two conditions: (1) this device may notcause harmful interference, and (2) this device mustaccept any interference received, including interference that maycause undesired operation. The lnspire1 radio transmitter used for controlling the sUAS iswirelesstechnology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHzto 2.4835GHzfrequency range. Antenna Separation Distance
When operating the aircrafttransmitter, the PIC will maintain a separation distance of at least5 em between his body (excluding fingers, hands, wrists, ankles and feet) andthe antennato meet RF exposure safety requirements as determined by FCC regulations. Pilot In Command and Observer Qualifications and Duties
The PIC will maintain at leasta Light Sport Pilot Certificate and a current State issued driver's license. The PIC is responsible forthe safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation and inspection, in flight operation, postflight requirements, and all procedures including but not limited to: *Safe in flight operations *Risk evaluation *Currentweather conditions for safeflight
The Observer must have the visual acuityto observethe sUAS and be ableto communicate clearly with the PIC.
The Observers duties are:

flight. * Warning the PIC ofany impending obstacles in the flight path ofthe sUAS. * Warning the PIC of anydeviations in the planned flight path ofthe sUAS. * Warning the PIC should any unauthorized personnel appear in the area ofthe planned

The Observerwill have the authorityto orderthe PIC toterminate the flight should he orshe feel the flight cannot be conducted safely. General Operating Standards

• Sky Shots State College LLC will only operate its sUAS in line ofsightofa pilot and/or observer and will operate atsitesthat are a sufficient distance from populated areas. • Such operations will insurethatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public." • Before an operation ofa sUAS within 5NM ofan airportwith a control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude and thetimes the sUAS will be operated. The sUAS will not be operated at an altitude ofover400feetAGL. Weather minimums will be 3 miles visibility and a 1000foot ceiling. • Flights will beterminated at30% battery power reserve.•The sUAS will be programmed so that itwill not be operated at an altitude of no more than 400 feetAGL, and not more than 400 feet above an elevated platform from which operations are planned. • Minimum crew for each operation will consist ofthe sUAS Pilot, and Visual Observer. •The sUAS operated bythe petitionerweighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). •The sUAS will operate at speeds of no more than 25 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 sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. The sUAS 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. Low level oblique photos and video from several angles are far more effective than ground based imageryfor displaying the characteristics of large, complex subjects. The benefits of reduced cost and improved quality of production from the sUAS over manned aircraftwill be valuable to many potential customers and the local economy. (a) No flight will be made with aGross weight exceeding 55 pounds; (b) All operations must occur in FAAClass G airspace at no more than 400ft.AGL, at an airspeed of no more than 25 knots and no furtherthan 1600 ft., or 0.263 NM from the PIC; (c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate byvoice or radio at all times during aflight operation; (d) Operations will be restricted to flights over private property only with the expressed permission' of the property owner; (e) All required permits will be obtained from state and local government priorto operation; (f) Sky Shots State College LLC will not operate over densely populated areas; (g) Sky Shots State College LLC will not operate over anyopen-air assemblyof people; (h) Sky Shots State College LLC will notoperate over heavilytrafficked roads; (i) Sky Shots State College LLC will notoperate at night. EXEMPTION REQUESTS AND EQUIVALENT LEVELOF SAFETY Sky Shots State College LLC requests an exemption from the following regulations as well as any additional regulations that maytechnically applytothe operation ofthe sUAS:
14 CFR 61.113 Private pilot privilegesand limitations: Pilotin Command and 61.133 Commercial pilotprivilegesand limitations The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraftfor compensation or hire. Subparagraph (b) allows aprivate pilotto act as pilot in command ofan 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 notcarry passengers or property for compensation or hire. Our proposed operations require thatthe PIC must hold at least a Private Pilot Certificate with aClass Ill Medical issued bythe FAAand since the aircraft cannot carry passengers or property, we feel we meet the intent of 61 .113

### Subparagraph (b) even though the intentofthis application isto conduct abusiness.
14CFR 91.7 ProhibitstheOperation ofan aircraftwithoutan airworthiness certificate 

### As no such certificate will be applicable in the form contemplated bythe FARs, this Regulation is inapplicable.
14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements 

### This regulation provides that no person mayoperate an aircraft unless acurrent, approved flight manual is in the aircraft. We assume that the intentofthis 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 notonlytoo small to carry documentation; the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meetthe intent of 91.9, we propose that acurrent, approved sUAS Flight Manual must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight, and ready for presentation for any governing official upon request.
14 CFR 91.119 Minimum safe altitudes 

### 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 ofthe sUAS would be photography or surveyof persons, vessels, vehicles or structures itwould be necessaryto operate closerthan 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 ofthe 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 altimetersetting available within 1 00 NM of the aircraft. The sUAS will alwaysfly below400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computerto the display screen held bythe PIC, 

### providing a constantly updated AGL readout.
14 CFR 91.151 Fuel requirementsforflight In VFR conditions 

### The regulation provides that no person may begin aflight in an airplane underday-VFR conditions unless there is enough fuel to flyto the first point of intended landing and to fly after thatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as asafety bufferfor delays to landing. The aircraft will neverfly more than 0.263 NM from the point of intended landing, afull battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" andaskfor 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 numberassigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew."At a maximum gross weight of 6.47 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 ofsafety and meetthe intent of 91.203, we propose that documents deemed appropriate forthis aircraft bythe FAA will be with the crew at the ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the following information plus the word "EXPERIMENTAL" to satisfythe requirement of 14 CFR 45.23.
14 CFR Subpart E (91.401· 91.417)· Maintenance, Preventive Maintenance, Alterations The regulation providesthatthe 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 ofthe aircraft and "be authorized to approve the aircraftfor return to service." The PIC will ensure that the aircraft is in an airworthycondition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturerortheir designated repairfacility. 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 ofthe UAS Sky Shots of State College LLC will be using the UAS in avariety of applications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefits overthe use of full-sized manned aircraftfor aerial photography, advanced agriculture monitoring, film and still photography, real estate marketing, (see attachment 4), and water supply monitoring. Due to drought conditions in the area overthe pastfewyears, this would greatly supply safer, faster, and more efficient information to our local officials who need this information about the lake levels and ourwater supply. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safetyforthe pilots and crew. Bygranting Sky Shots of State College LLC's requested exemptions, the FAAwill help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Sky Shots of State College LLC is committed to promotingthe UAS research efforts of policymakers including the FAA, NASA, DOD and DARPAby sharing datafrom its commercial UAS operations and serving as a resource forfuture UAS research operations. Thus, the FAA has good cause to grantthis Petition.
Conclusion
As pointed out in this application,the 3DR Solo and the DJI Inspire 1 which our company would use, under authorization bythe US DOT-FAA, are small, light-weightdevice operated within the line of sight ofthe Pilot-in-Command (PIC), less than 400feet 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 ofthis distance. Both sUAS have been proven capable for controlled flight. It is a UAS offered for general sale on the market around the world and have often been used as ModelAircraft in the USA

. FAA studies, about Section 332, Public Law 112-95,2014, have already provided necessary assurances of the airworthiness ofthe same orsimilar sUAS. For the foregoing reasons, the exemptions requested herein should be granted and Sky Shots State College LLC should be permitted to conductsmall UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA. Signed,



### n

resident Sky Shots State College, LLC Eric@boalsburgcarco.com