February 8 2016 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

RE: Petition of Sky Shots State College, LLC for Exemption Pursuant to Section 333 of the 

FAA Reform Act 

Petitioner's Name and Address: 

Sky Shots State College, LLC 

Owners: Eric Allen 

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 Reform Act) 

and 14 CFR Part 11, Sky Shots State College, LLC, operator of Small Unmanned Aircraft 

Systems ("sUAS'1 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 sUAS, so long as such operations are conducted within and under the conditions 

outlined herein or as established by the FAA as required by Section 333.1 

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

unmanned sUAS under controlled conditions in airspace that is 1) Limited 2) Predetermined and 

3) Controlled. The proposed exemption, if granted, would allow Sky Shots of State College, LLC 

to conduct commercial operations of sUAS meeting or exceeding all of the operational and 

safety requirements set forth in Section 333. 

Sky Shots State College LLC is an aerial photography and cinematography company owned 

and operated by Eric Allen. 

Sky Shots State College LLC plans to 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 address of the applicant are: 

Name: Sky Shots State College LLC 

Owner: Eric Allen 

Address: 334 Boal Ave 

Boalsburg Pa 16827 

Phone: 570-220-2276 

Email: eric@boalsburgcarco.com 

Regulations from which the exemption is requested: 

14CFR 61.113(a) and (b) 

14 CFR 61.23(a) and (c) 

14 CFR 61.101 (e) (4) and (5) 

14 CFR 61.315 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.109 

14CFR91.119 

14 CFR 91.121 

14 CFR 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 impact on the environment, sUAS 

provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. 

Accordingly, the applicant respectfully requests that the FAA grant the 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 latest version 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. The sUAS has a built-in capability to limit 1) the 

height it flies above the ground and 2) the radius of the distance it flies from the operator. Both 

the 3DR Solo OJI Inspire 1 also has the fail-safe function of the autopilot system, when 

communication between the Main Controller and the transmitter is disconnected, the system will 

automatically triggerReturn to Home and will land safely. 

The 3D A 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, 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 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 parts will be used. 

FCC Information 
All transmitters used for controlling the sUAS complies with part 15 of the FCC rules. 

Operation is subject to the following two conditions: (1) this device may not cause harmful 

interference, and (2) this device must accept any interference received, including interference 

that may cause undesired operation. The lnspire1 radio transmitter used for controlling the 

sUAS is wireless technology which has been tested and found to be compliant with the 

applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency 

range. 

Antenna Separation Distance 

When operating the aircraft transmitter, the PIC will maintain a separation distance of at least 5 

em between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to 

meet RF exposure safety requirements as determined by FCC regulations. 

Pilot In Command and Observer Qualifications and Duties 

The PIC will maintain at least a Light Sport Pilot Certificate and a current State issued driver's 

license. 

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: 

*Safe in flight operations 

*Risk evaluation 

*Current weather conditions for safe flight 

The Observer must have the visual acuity to observe the sUAS and be able to communicate 

clearly with the PIC. 

The Observers duties are: 

flight. 

* Warning the PIC of any impending obstacles in the flight path of the sUAS. 

* Warning the PIC of any deviations in the planned flight path of the sUAS. 

* Warning the PIC should any unauthorized personnel appear in the area of the planned 

The Observer will have the authority to order the PIC to terminate the flight should he or she 

feel the flight cannot be conducted safely. 

General Operating Standards 

• Sky Shots State College 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. 

• Such operations will insure that the sUAS will "not create a hazard to users of the 

national airspace system or the public." 

• Before an operation of a sUAS within 5NM of an airport with a control tower, the 

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

position, altitude and the times the sUAS will be operated. The sUAS will not be 

operated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles 

visibility and a 1 000 foot ceiling. 

• Flights will be terminated at 30% battery power reserve. 
• The sUAS will be programmed so that it will not be operated at an altitude of no more 

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

operations are planned. 

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer. 

• The sUAS operated by the petitioner weighs 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 imagery for displaying the characteristics of large, complex subjects. The benefits of 

reduced cost and improved quality of production from the sUAS over manned aircraft will be 

valuable to many potential customers and the local economy. 

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

(b) 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 further than 1600 ft., or 0.263 NM from the 

PIC; 

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

communicate by voice or radio at all times during a flight 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 prior to 

operation; 

(f) Sky Shots State College LLC will not operate over densely populated areas; 

(g) Sky Shots State College LLC will not operate over any open-air assembly of people; 

(h) Sky Shots State College LLC will not operate over heavily trafficked roads; 

(i) Sky Shots State College LLC will not operate at night. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Sky Shots State College LLC requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the sUAS: 

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 Ill 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 

sUAS 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 91.119 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 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 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 1 00 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 conflict with other 

aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the sUAS on-board computer to the display screen held by the PIC, providing a 

constantly updated AGL readout. 

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 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 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 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 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 

Sky Shots of State College 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, advanced agriculture monitoring, film and still photography, real estate 

marketing, (see attachment 4), and water supply monitoring. Due to drought conditions in the 

area over the past few years, this would greatly supply safer, faster, and more efficient 

information to our local officials who need this information about the lake levels and our water 

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 safety for the 

pilots and crew. 

By granting Sky Shots of State College 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. Sky Shots of State College 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, the 3DR Solo and the DJI Inspire 1 which our company would 

use, under 

authorization by the US DOT-FAA, are small, light-weight device operated within the line of 

sight of the Pilot-in-Command (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. 

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 Model Aircraft in the USA. 

FAA studies, about Section 332, Public Law 112-95, 2014, have already provided necessary 

assurances of the airworthiness of the same or similar sUAS. 

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

State College 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. 

Signed, 

n 

resident 

Sky Shots State College, LLC 

Eric@boalsburgcarco.com