Dec 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Amendment to Exemption No. 12857 Issued Under Section 333 of the FAA

Reform Act and Part 11, in Regulatory Docket No. FAA-2015-2090 of the Federal Aviation 

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”

or “Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, New Sky

Perspectives, LLC seeks an amendment to Exemption No. 12857 to operate additional small 

Unmanned Aircraft Systems: the DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly 

Alta, Intuitive Aerial Aerigon, Stedidrone Mavrik/ Vader, Xfold Rig (X8 and X12) and Tayzu 

Titan X8.

On May 21, 2015, the FAA issued Exemption No. 12857 to New Sky Perspectives, LLC to allow

it to operate the DJI S1000 and 3DRobotics Iris + sUAS for conduct aerial filming and 

photography in the motion picture, television, advertising and real estate industries. This 

requested amendment to that exemption will allow New Sky Perspectives, LLC to operate the 

DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, Intuitive Aerial Aerigon, 

Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu Titan X8 for the same reasons and 

under the same conditions. There has been no other change in conditions and reasons relative to 

public interest and safety that were the basis for granting the original exemption.

NAME AND ADDRESS OF PETITION 

New Sky Perspectives, LLC 

Attn: Jonathan Shaul 

590 Farrington Hwy # 524-405

Kapolei, HI 96707 

808.721.4842 

jonahshaul@gmail.com

Additional sUAS Platforms DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo Freefly 

Alta, Intuitive Aerial Aerigon, Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and 

Tayzu Titan X8

Operations pursuant to the exemption will be subject to strict operating requirements and 

conditions to ensure at least an equivalent level of safety to currently authorized operations using 

manned aircraft and under the same conditions as permitted by the FAA in Exemption No. 

12857.

The DJI Phantom 3 Series weighs approximately 2.8 lb. and the DJI Inspire 1 Series weighs 6.4 

lb., including payload. 3DR Solo weight 3.9lbs. Freefly Alta Maximum Gross Takeoff Weight: 

29.9 lb / 13.6 kg, Intuitive Aerial Aerigon 11kg/24lbs (with batteries) pre-preg molded carbon 
fiber structure, Stedidrone Mavrik x4 is above average in weight, weighing in at 2,200 grams or 

4.9 pounds, Vader Weight MAX AUW: 31.3lbs (X4); 44.1lbs (X8) and Tayzu Titan x8 max 

weight of 42 lb. All models are powered electrically via small, lithium polymer batteries that 

drive electric propellers. The DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, 

Intuitive Aerial Aerigon, Stedidrone Mavrik and Vader, Xfold Rig (X8 and X12) and Tayzu 

Titan X8 have extensive automated control features, redundant systems, and integrated fail-safes, 

and they will be operated under controlled conditions and at low altitudes in airspace that is 

limited in scope.

Exemptions Requested

New Sky Perspectives, LLC respectfully requests exemptions from the following regulations 

previously granted by the FAA in Exemption No. 12857:

14 C.F.R. Part 21:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 61.133(a)

14 C.F.R 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R 91.103(b)(1)

14C.F.R 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151

14 C.F.R.91.203(a) and (b)

14 C.F.R.91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a)-(b).

Airworthiness of the DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, 

Intuitive Aerial Aerigon, Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu 

Titan X8

The DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, Intuitive Aerial 

Aerigon, Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu Titan X8 are airworthy

and compliant with a significant level of safety. In fact, the many previous 333 Grants of 

Exemptions by the FAA for operations of these platforms, underscore that operations of DJI 

Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo Freefly Alta, Intuitive Aerial Aerigon, 

Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu Titan X8 by New Sky

Perspectives, LLC will not adversely affect safety when compared to similar operations 

conducted by aircraft that have been issued an airworthiness certificate under 14 C.F.R. Part 21, 

Subpart H. [E.g., FAA Exemption Nos. 12646 (granting exemption for 324 sUAS), All nine

sUAS are powered electrically by small, lithium polymer batteries that drive electric propellers,

platforms were designed with extensive automated control features, redundant systems, and 
integrated fail-safes which enhance safe takeoff, flight, and landing in many conditions. Further

details of these features are provided in the links below.

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.p

df

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf

https://3drobotics.com/solo-gopro-drone-specs/

http://freeflysystems.com/alta/specs

http://www.intuitiveaerial.com/specs/

http://192.168.1.1:8181/http://www.steadidrone.com/brochures/MavrikBrochure.pdf

http://www.spacecitydrones.com/steadidrone-vader/

http://tayzu.com/tayzu-technology.html

To maintain airworthiness, New Sky Perspectives, LLC will follow the inspection and 

maintenance programs designed specifically for the DJI Phantom 3 Series, DJI Inspire 1 Series,

3DR Solo Freefly Alta, Intuitive Aerial Aerigon, Stedidrone Mavrick/Vader, Xfold Rig (X8 and 

X12) and Tayzu Titan X8 by their manufacturers. Those programs are enhanced by inflight 

monitoring systems for current position, wind speed and direction, battery charge, flight time, 

and altitude, including both above the takeoff location and above sea level. If onboard sensors 

detect a critical situation at any time (low battery, close proximity to the ground, weak data link 

signal, etc.) the aircraft will automatically initiate a preprogrammed safety procedure. 

In the event of any malfunction, the DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo,

Freefly Alta, Intuitive Aerial Aerigon, Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and 

Tayzu Titan X8 will return home or land and undergo all maintenance required by the 

manufacturers and undergo flight testing before recommencing commercial operations. Good 

cause exists to grant New Sky Perspectives, LLC an amendment to Exemption No. 12857.

Doing so, is in the public interest based on the clear direction in Section 333, the Federal 

Aviation Act, the high and equivalent level of safety of the proposed operations, and in 

consideration of the size, weight, speed and limited operating area associated with the DJI 

Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, Intuitive Aerial Aerigon, 

Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu Titan X8. 

Accordingly, New Sky Perspectives, LLC respectfully requests that the FAA grant an expedited

amendment to add the DJI Phantom 3 Series, DJI Inspire 1 Series, 3DR Solo, Freefly Alta, 

Intuitive Aerial Aerigon, Stedidrone Mavrik/Vader, Xfold Rig (X8 and X12) and Tayzu Titan 

X8 to its sUAS operations.

Respectfully submitted,
Jonathan Shaul