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September 30,2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Petition ofSky Systems Imaging for an Exemption Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 Director: Flight Standards Service: Pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 ("ReformAct") and 14 C.F.R. Part 11, Sky Systems Imaging ("Sky Systems") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified belowto allow commercial operation and manufacture ofsmall specialized unmanned aerial platforms (i.e., "small unmanned aircraft" or "UAS") for aerial photography and videography for inspection ofinfrastructure and power lines as well as training howto fly drones. This petition for exemption is made based on information outlined inthis Petition for Exemption, as well as the accompanying Sky Systems documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. Flight Manual 1 (Collectively referred to as "Manufacturer'sManual") Sky Systems submits these supporting materials as confidential documents pursuantto 14 C.F.R. 

### § 11.35(b), as the materials contain confidential commercial and/orproprietary information that Sky Systems has not and will not share with other requesting parties. Additionally, these documents contain operating conditions and procedures that are not generally available to the public and are protected from release under the Freedom oflnformationAct, 5 U.S.C. 

### § 552 et. seq. For your convenience, this Petition is organized as follows:

1

. The term "Manufacturer's Manual" also includes all relevant manufacturerpublications, including, but notlimited to: operations and flight manuals, user guides, component maintenance manuals, pilottraining manuals, service information letters and, safety/service bulletins.

# "u.s Department ofTransportation September 30, 2015 Page2 

### I. Description ofPetitioner II. Description ofProposed Operations
A. Aerial Photography and Videography for Power Line Inspection and Training 

### III. Relevant StatutoryAuthority IV. Sky Systems' Proposed UAS Operations Meet the Requirements of Section 333 ofthe ReformAct
A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions SetForth inthe Operations Manuals 

### V. Regulations FromWhich Exemption is Requested
A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

### § 91.203(a)(1) B. 14 C.F.R. Part 27Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. 

### § 61.3, 14 C.F.R. 

### § 61.113: Private PilotPrivileges and Limitations F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness G. 14 C.F.R. 

### § 91.9(b)(2): CivilAircraft Flight Manual intheAircraft and 14 C.F.R. 

### § 91.203(a) and 

### (b): Carrying CivilAircraft Certification and Registration H. 14 C.F.R. 

### § 91.103: PreflightAction I. 14 C.F.R. 

### § 91.109(a): Flight Instruction J. 14 C.F.R. 

### § 91.119(c): Minimum SafeAltitudes K. 14 C.F.R. 

### § 91.121: Altimeter Settings L. 14 C.F.R. 

### § 91.151(a): Fuel Requirements for Flight inVFR Conditions 

### Vl. Drug andAlcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. Conclusion I. DESCRIPTION OFPETITIONER Sky Systems, based inJohnston, RI provides aerial inspection and surveillance services for power lines and otherrelated infrastructure. Commercial operation and manufacture ofsmall specialized unmanned aerial platforms 

### (i.e., "small unmanned aircraft" or "UAS") for aerial photography and videography will be the basis for training and educationto perspective drone owners and users. The Company's Principal and ChiefPilotDennis Spicuzzahas beenflyingU.S Department ofTransportation September 30, 2015 Page3 UA V Quadcopters and otherradio powered aircraft as a hobby for overtwenty years without incident, spending thousands ofhours flying. Uponthe grant ofthe 333 Exemptionthe Company's business will specialize in aerial photography and videography surveillance and inspection ofpower lines and otherrelated infrastructure. Sky Systems' staffare well trained and experienced inproviding support as visual observers ("VO") for the pilot in command ("PIC") in addition to any other needed on site assistance. All ofthe equipment owned by Sky Systems is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Sky Systems' goal is to advise the perspective client that Sky Systems is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and cost effective product. Sky Systems seeks anexemption to allowfor aerial photography, videography, inspection and surveillance ofpower lines and otherrelated infrastructure as well as to allowthe training of drone use to their client base. The contact information for Petitioner is as follows: Dennis Spicuzza Sky Systems Imaging 117 Hopkins Ave. Johnston, RI 02919 Phone: (401) 569-2523 Email: dspicuzza1 @cox.net 

### II. DESCRIPTION OF PROPOSED OPERATION Sky Systems seeks an exemption pursuantto Section 333 ofthe ReformActto operate the: DJI Inspire (referred to SS-UAS)**(~der** 55lbs) for the proposed operations discussed hereinbelow. All UAS operations will occur undertightly controlled conditions onprivate property where Sky Systems has received verifiable permission to operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance with the conditions and limitations ofthis Petition for Exemption and Sky Systems' Operations Manuals. As detailed in Sky Systems' Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") ofthe operator, inuncontrolled airspace, and will occur at least 5 mm away from an airport reference point. Moreover, Sky Systems' Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. 

### A. Aerial Photography and Videography for Power Line Inspection and Training Sky Systems seeks to use small SS-UAS for the purpose ofconducting aerial photography, videography ofpower lines and otherrelated infrastructure as well as provide training intheU.S Department ofTransportation September 30,2015 Page4 drone operation. Sky Systems has purposefully tailored its operations to meetthe requirements established bythe FAA inprior grants ofexemption authorizing commercial use ofUAS inthe real estate industry, including:

• Trudeau, Realtor® (ExemptionNo. 11138) • Alon Sicherman (Exemption No. 11728) • Sokoler Medly (ExemptionNo. 11341) • StarnesAviation, LLC (ExemptionNo.12377) • Mark Reid (Exemption No.12767) • AirGon, LLC (ExemptionNo.12604) • Thomas JohannWalter (ExemptionNo.l2719) All UAS photography and videography operations will occur onprivate property in a controlled area away from spectators andpersons not involved in the recording process. In addition, the filming will be conducted between dawn and dusk to ensure maximum safety for the public and those involved inthe manipulation and operation ofthe UAS; VFR conditions, at altitudes below 400' above ground level ("AGL"). As set forth below, Sky Systems' operations provide an equivalent level ofsafety which is superior to performing the same work using conventional fixed-wing aircraft orhelicopters. Small UAS video production is also safer than traditional manned aircraft performing the same function. Videographer-inspectors also frequently need to climb rooftops, trees, or otherwise perform elevated work, which exposes them to the risk ofdangerous falls, electrocution or other work related injuries. In addition, depending onthe nature ofthe video needed and inspection, proximityto equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofSS-UASs mitigates these hazards and is ultimately a much safer and cost efficient method ofperforming these and most othertypes ofinspections. Moreover, conventional operations using rotorcraft and fixed-wing aircraft inlowlevel operations presentrisks associated with vehicles weighing tens ofthousands ofpounds (includingpayload) and carrying large amounts offuel which inherently presents significant fire hazards as well as exposure to other chemical contaminates. It is important to note the use of small UAS inthis area will not only be safer and more cost effective to the perspective user or purchaser ofthe service, but the quality and expanse ofacquired information will be far more robust giventhe low cost associated with its acquisition and otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greater precision and duration at a very lowcost. Small UAS will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible orhighly dangerous using conventional aircraft or other inspection methods. 

### III. RELEVANT STATUTORYAUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) oftheU.S Department ofTransportation September 30,2015 PageS FAAModernization and ReformAct of2012 ("ReformAct"). Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 ofthe ReformAct, the FAAAdministrator is to permit unmanned aircraft systems to operate inthe NationalAirspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within the visual line ofsight ofthe operator. Additionally, the FAAAdministratorhas general authority to grant exemptions from the agency's safety regulations and minimum standards whentheAdministrator decides a requested exemption is inthe public interest. See 49 U.S.C. § 106(f) (defining the authority ofthe Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and 

### §§ 44702-44716, et seq.). A party requesting an exemption must explainthe reasons whythe exemption: (1) would benefitthe public as a whole, and (2) would not adversely affect safety (or howit would provide a level ofsafety at least equal to the existing rules). See 14 C.P.R. § 11.81 (petitions for exemption). IV. SKY SYSTEMS'PROPOSED SS-UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The small SS-UAS operations proposed by Sky Systems as noted above inthis Petition for Exemption qualify for expedited approval pursuantto Section 333 ofthe ReformAct as each of the statutory criteria and relevant factors are satisfied. A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The SS-UAS utilized by Sky Systems has been approved for use inprior Section 333 Grants ofExemption from the FAA. 2

• The SS-UAS weighs less than 55 pounds, including payload

• The SS-UAS will not be flown at a ground speed inexcess of50 knots.

• Altitude information will be generated by equipment onboardthe UAS as specified using GPS triangulation, digitally encodedbarometric altimeter, radio altimeter, or any combination thereof. This information will be transmitted to the pilot viatelemetric data feed.

2See e.g., Grant ofExemptionto Trudeau, Realtor® (ExemptionNo. 11138); Grant ofExemption to Alon Sicherman (Exemption No. 11728); Grant ofExemption to SokolerMedly (ExemptionNo. 11341).U.S Department ofTransportation September 30,2015 Page6

• The SS-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnectionto the remote control or ground control station is lost, failsafe systems will permit the UASs to return to a predetermined location and safely land without injury ordamage.

• The radio frequencies used for operations and control ofthe SS-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the SS-UAS is 2.4 GHz frequency bands. Ifthe same operations were conducted using a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference in weight betweenthe SSUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surroundingproperty inthe event ofanunintended accident or incident. In addition, the risk to the onboard pilot and camera operator is eliminated. B. Approval is Warranted Based on the Operational Restrictions Set Forth in Sky Systems' Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected SS-UAS will contain all the procedures and limitations necessary to safely and successfully performthe operations specified inthis Petition for Exemption. To assist the FAA inmaking a safety assessment ofSky Systems' proposed operations, belowis a summary ofoperational limitations and conditions that Sky Systems will adhere to, and whichwill ensure an equivalent orhigher level ofsafety to operations conducted under current regulatory guidelines:
1. The SS-UAS weighs less than 55 pounds, with payload. 2. All operations shall be conducted over private or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UASs operated under the Grant ofExemption will be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C. Markings will be as large as practicable. 4. Minimum crew for each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe SS-UAS, and one ormore Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a private, recreational, or sportpilot certificate. The PIC must also hold a current Class III medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meetthe flight reviewrequirements specified in 14 C.F.R 61.56 in an aircraft inwhich the PIC is rated onhis orherpilot certificate.U.S Department ofTransportation September 30, 2015 Page7 6. The SS-UAS shall be operated within VLOS ofthe PIC and Observer at all times. The PIC must use human visionunaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will not be permitted during flight operations. 9. The additional requirements identified inthe Grant ofExemption shall be added to the Sky Systems' Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator uponrequest. Ifa discrepancy exists betweenthe conditions and limitations inthe Grant ofExemption and Sky Systems' Operations Manuals, the conditions and limitations in the Grant ofExemption shall take precedence and must be followed. Otherwise, Sky Systems shall follow the procedures outlined intheir Operations Manuals. 10. Sky Systems may update orrevise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be providedto the Administrator upon request. Sky Systems will also present an updated and revised Operations Manuals ifit petitions for extension or amendmentto its Grant ofExemption. Ifan update or revision would affect the basis upon which the FAA grants the exemption, Sky Systems will seek an amendment to its Grant ofExemption. Sky Systems will contact the FAA's UAS Integration Office (AFS-80) ifquestions arise regarding updates or revisions to the operating documents. 11. Sky Systems Operations Manuals and its Grant ofExemption will be available to the PIC atthe ground control station anytime the SS-UAS is operating. 12. The PIC is prohibited from beginning a SS-UAS flight unless (considering wind and forecast weather conditions) there is enough powerto fly to the first intended point of landing, and assuming normal cruising speed, to fly after that for at least 1 0 minutes. 13. Maximumtotal flight time for each operational flight using the SS-UAS will be limited to 40 minutes or the amount oftime the UAS canbe flown and still maintain a reserve batterypower ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than400 feetAGL and will never enter navigable controlled airspace without timely prior written authorization and approval from the FAA. Inthe eventthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the structure. 15. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons. (persons otherthan the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:U.S Department ofTransportation September 30, 2015 Page8

a. Barriers or structures are presentthat sufficientlyprotect nonparticipating persons from the UAand/or debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave suchprotection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has grantedpermission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does notpresent anundue hazard, and; c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 16. The SS-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 17. The SS-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required bythe Sky Systems COA. The letter ofagreement withthe airport management will be made available to the Administrator upon request. 18. Priorto each flight the PIC shall inspect the SS-UASs to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, orequipment, not already covered inthe relevant sections ofthe operating documents as well as equipment updates. The PIC shall not operate any SS-UAS ifthe inspectionreveals a condition that affects the safe operation ofthe SS-UAS until the necessary maintenance has beenperformed and the SS-UAS is found to be in a condition for safe flight. The ground control station shall be included inthe preflight inspection. All maintenance and alternations mustbe properly documented in the UAS's records as required by Sky Systems' Operations Manuals. 19. Sky Systems will timely carry out its maintenance, inspections, and record keeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted inthe SS-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized person returning the SS-UAS to service. 20. Any SS-UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional test flight in accordance with Sky Systems' Operations Manuals. The PIC who conducts the functional test flight must make an entry inthe UAS aircraft records ofthe flight. The requirements andprocedures for a functional test flight and SS-UAS record entry shall be included inthe Sky Systems' Operations Manuals.U.S Department ofTransportation September 30, 2015 Page9 21. The SS-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and product updates. 22. Priorto the operation, a Mission Packet will be created in accordance with the requirements on Sky Systems' Operations Manuals.
23. Sky Systems will obtain anAir Traffic Organization ("ATO") issued Certificate of Waiver orAuthorization, otherwise known as a COA, prior to conducting any operations underthis Grant ofExemption. A NOT AM will be issued as required by the COA. All operations will be conducted in accordance with airspace requirements inthe ATO issued COAincluding class ofairspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe SS-UAS loses communication with the PIC, it will have the capability to safely returnto a pre-determined location within the operational area and land safely. 26. Contingency plans will be inplace to safely terminate flight ifthere is a loss of communicationbetween the PIC and the Observer. 27. The SS-UAS will have the capability to safely abort flight inthe case ofunpredicted obstacles oremergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued withinthe United States. 29. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CPR § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar SS-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistent with 14 CPR§ 61.51(b), a minimum ofhours pursuant to 54 CPR§ 61.51(b) as UAS pilot operating the make and model ofSS-UAS to be utilized for operations under the exemption and three take-offs and three landing in the preceding 90 days. 31. Operations shall occur during daytime VPRMeteorological Conditions; flights under special visual flight rules ("SVPR") shall not be conducted. 32. The SS-UAS shall remain clear and yield the right ofway to all othermanned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).U.S Department ofTransportation September 30, 2015 Page 10 33.**SS~UAS** Operations under Instrument Flight Rules, at night, orbeyondVLOS are prohibited. 34. The**SS~UAS** will notbe operated from an elevated platform ormoving device/vehicle. 35. Before conducting operations, the radio frequency spectrum used for operation and control ofthe SS-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED The FederalAviationAct expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defmed under § 40101 oftheAct, including UAS, from its safety regulations and minimum standards when the Administrator decides a requested exemption is inthe public interest.3 Sky Systems seeks an exemptionfrom several interrelated provisions ofTitle 14 ofthe Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes ofconductingthe requested operations using SS-UAS platforms noted above. Listed below are: 

### (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level ofsafety better than or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.P.R. Part 21, Subpart H-Airworthiness Certificates and 14 C.P.R. §91.203(a)(1) The FAAhas stated that no exemption is needed from this section ifa finding is made under the ReformActthatthe UAS selected provides an equivalent level ofsafety when compared to aircraft normallyused for the same application. These criteria are met and in point offact exceeded, and therefore no exemptionis needed. 5 If, however, the FAAdetermines that there are some characteristics ofthe chosen UAS that fail to meet the requirements ofthe ReformAct, an exemption is requested. EquivalentLevelof Safety

349 U.S.C. § 44701(f) (authorizing the grant ofexemptions from requirements ofregulations prescribedpursuant to Sections 44701(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, orhow the exemption wouldprovide a level ofsafety at least equaltothat provided bythe rule from whichyou seek exemption.

5See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).U.S Department ofTransportation September 30,2015 Page 11 Sky Systems' use ofthe SS-UAS is safe whentaking into account its size, weight, speed, and operational capability. As set forth inthe description ofproposed operations in Section IV (A), the SS-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of50 knots. The SS-UAS is also equipped with safety features which will allow Petitionerto operate the SS-UAS safely after experiencing certain in-flight contingencies or failures as noted below. 6 7Additionally, the SS-UAS carries neitherpilots norpassengers, carries no explosive materials or flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Sky Systems' Operations Manuals. Operations conducted under this exemption will be closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. Sky Systems will also provide the FAAwith advance notice of all operations viaNOTAMs as required bythe applicable COA. In all cases, operation ofthe SSUAS under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate. Lastly, the SS-UAS do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the SS-UAS. 8 In addition, no sense-and-avoid technology is necessary for the SS-UAS because they will be operated at all times inVFR conditions and withinVLOS ofthe PIC and Operator.9

6See e.g., Grant ofExemptionNo. 11184 to Low Country RC, Corp. (FAA-2014-0803 atpg. 3): "The [Dll SIOOO] hasthe capabilityto operate safely after experiencing certain in-flight contingencies or failures anduses an autopilot system to maintain UAS stability and control. The UAS is also able to respondto a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation."

7See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The SS-UAS can be operated entirely by a touch-screen, map-based interface. This means the operator only needs to commandthe system where to go, and the system does all the flying for the operator. The SS-UAS can be operated in both semi and fully autonomous flight modes, withthe operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones ormaximum flight ranges and altitudes so the system cannot enter areas deemed unsafe orunnecessaryto fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the SS-UAS to detect a system fault while in the air and automatically fly back to its takeofflocation and land. Faults that canbe detected include: loss ofcommunication; exceeding pre-set windthresholds; and lowbattery levels. All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any point ifthe operator is not explicitly commandingthe system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link

- to prevent a 'fly away' or other potentially dangerous situation

- is available to the operator."

8See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 atpg. 13).U.S Department ofTransportation September 30, 2015 Page 12 

### B. 14 C.F.R. Part27Airworthiness Standards: Normal Category Rotorcraft Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent that Sky Systems' small SS-UASs would otherwise require certification underPart 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): AircraftMarking and Identification Requirements Sky Systems seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. 

### § 91.9(c), CivilAircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. 

### § 45.23(b), Markings oftheAircraft, states: When marks include only the Roman capital letter "N" and the registration number is displayed onlimited, restricted orlight-sport category aircraft orexperimental orprovisionally certificated aircraft, the operator must also display onthat 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.

• 14 C.F.R. 

### § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by § 45.23.
In a previous Grant ofExemption, the FAAdetermined that exemption from these requirements was warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 

### EquivalentLevelof Safety All SS-UASs flown by Sky Systems will bearN-number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11

10. FAA DocketNo. FAA-2014-0352. llSee, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation September 30, 2015 Page 13 

### D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections Sky Systems seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. 

### § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 91.405(a) (stating that each owner or operator ofan aircraft"[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption from these regulations is needed because Part43 andthese sections only apply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption will not have. (Emphasis added) 

### EquivalentLevelof Safety An equivalent level ofsafety will be achieved or exceeded because maintenance and inspections will be timely performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Sky Systems' Operations Manuals, the PIC will conduct a pre-flight inspection ofthe SS-UASs and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe SSUASs and no flights will occur unless, and until, all flight critical components ofthe SS-UASs have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Sky Systems' Operations Manuals, the PIC who conducts the functional test flight will make an entry inthe SS-UAS aircraft records ofthe flight. Sky Systems' Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Sky Systems' Operations Manuals also include procedures to document and maintain a record ofthe SS-UAS's maintenance, preventative maintenance, alterations, status of replacement /overhaul component parts, and the total time in service ofthe SS-UAS used under this Grant ofExemption. As a whole, the maintenance and inspection procedures required in Sky Systems' Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved. 

### PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations Sky Systems seeks exemption from 14 CFR 

### § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. Inthis case, while the SS-UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. Inthe Grant ofExemption toAstraeusAerial, the FAAdetermined that the unique characteristics ofUASU.S Department ofTransportation September 30,2015 Page 14 operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when UAS operations are involved. 

### EquivalentLevelof Safety The restrictions Sky Systems has placed on its SS-UAS operations meet or exceed the restrictions similarly imposed onAstraeus Aerial. Sky Systems will operate onprivate property away from persons and property not involved inthe operation. Sky Systems will also obtain an ATO issued COAprior to conducting any operations under this Grant ofExemption. All operations will be conducted in accordance with airspace requirements intheATO issued COA including class ofairspace, altitude level and potential transponderrequirements. ANOTAM will also be issued as required by the applicable COA. In addition to these flight restrictions, Sky Systems will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also inthe unique aspects ofSS-UAS flight. As set forth inthe Operations Manuals, pilots will have experience not only in SS-UAS operations generally but have logged flight time inthe specific make and model used for the operations before they are permittedto participate in commercial flights onbehalfofSky Systems. The pilot qualification, training, and currency requirements inthe Operations Manuals ensure that Sky Systems pilots are competent andproficient inthe SS-UASs they are operating. Sky Systems' training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. OPERATING PARAMETERS OFTHE UAS 

### F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UASs, Sky Systems seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAAhas stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extentthatthe requirements ofPart 21 are waived or found inapplicable. 13 Accordingly, Petitioner requests thatthe requirements for§ 91.7(a) be treated in accordance with SectionV(A), supra. 

### G. 14 C.F.R. § 

### 91.9(b)(2): CivilAircraft Flight Manual in 

### theAircraft and 14 C.F.R. § 

### 91.203(a) and (b): Carrying CivilAircraft Certification and Registration

12

ExemptionNo. 11062 (FAA DocketNo. FAA-2014-0352).

13See Id. at 13-14, 22.U.S Department ofTransportation September 30,2015 Page 15 Title 14 C.F.R. § 91.9(b) (2) and§ 91.203(a) and (b) require the operator to carry airworthiness documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b) (2): (b) No personmay operate a**U.S.~registered** civil aircraft- (2) For which anAirplane or Rotorcraft Flight Manual is required by § 21.5 ofthis chapter, unless there is available inthe aircraft a current approvedAirplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas within it the following: (1)

### An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew. Giventhe small size and configuration ofthe**SS~UAS,** it would be impossible to keep airworthiness documents and other aircraft manuals onboard the**SS~UAS** because there is simply no room and the SS"UAS has no cabin or cockpit. As a wayto comply withthe code Sky Systems will maintain the documents with the PIC and make them available for inspection. EquivalentLevelof Safety
In an FAAOffice ofChiefCounsel's Opinion datedAugust 8, 2014, and prepared by DeanE.**Griffith,Attomey,AGC~220,** it was acknowledgedthat the intent of 14 C.P.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircraft has access to the UAS flight manual, registration certificate, and other required documents from the ground control station from whichhe or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilot has access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilot has access to the documents atthe ground control station from whichhe or she is piloting the UAS. H. 14 C.F.R. § 91.103: PreflightAction Sky Systems seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before eachflight, including information contained inthe**FAA~approved** Flight Manual onboard the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extent that an FAA"approved Flight Manual is required.

14 Memorandum from Mark Bury, FAAAssistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also DocketNo.**FAA~2014~0352** at 16-18.U.S Department ofTransportation September 30,2015 Page 16 EquivalentLevelof Safety An equivalent level ofsafety will be provided by following the Sky Systems' Operations Manuals andthe Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance withthe Sky Systems' Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, UAperformance data, and contingency landing areas-before initiation of flight. Sky Systems' Operations Manuals and the Manufacturer's Manual will be kept atthe ground control station and will be accessible to the PIC at all times while operating the UAS. I. 14 C.F.R. § 91.109(a): Flight Instruction Sky Systems seeks an exemption from 14 C.F.R. 

### § 91.109(a), which provides inpertinent part that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, bytheir design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates withthe aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. 

### § 91.109(a). EquivalentLevelof Safety Given the size and speed ofthe UASs that Sky Systems intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot orpassengers are aboard the UAS, and as required bythe Sky Systems' Operations Manuals, all persons will be a safe distance away inthe event that the UAS experiences any difficulties during flight instruction. Moreover, as required bythe Sky Systems' Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safetyprocedures provided for in Sky Systems' Operations Manuals ensure that the proposed UAS operations provide an equivalent orhigher level ofsafety thanthat provided bythe flight instruction regulations. J. 14 C.F.R. § 91.119(c): Minimum SafeAltitudes Sky Systems requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft maynot operate, including 500 feet above the surface and away from anyperson, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. §91.119(c). Section 91.119(d) allows for a helicopter to operate at less thanthose minimum altitudes when it can be operated "without hazard to persons orproperty onthe surface," provided that "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

15Relieffrom § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons orproperty onthe ground inthe event ofa failure. Petitioner's proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to Slugwear, Inc., dbaLike on a tree Aerial (FAA-2014-0534 at 15).U.S Department ofTransportation September 30, 2015 Page 17 An exemption is required because the proposed SS-UAS operation will normally needto occur below400 feet AGL. In circumstances where the SS-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the SS-UAS will not be operated more than 100 feet above the highest point onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the SS-UAS. EquivalentLevelof Safety Compared to flight operations with rotorcraft weighing far more thanthe maximum weights proposed herein, and giventhe lack offlammable fuel with the above noted UASs, any risk associated withthese operations is far less thanthose whichpresently exist with conventional aircraft. An equivalent level ofsafety will be achieved giventhe size, weight, and speed ofthe SS-UASs, as well as the controlled location where the operations will occur. In orderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals, the SS-UASs will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless that personis in a position where he or she is shielded from the SS-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating person within 500 feet ofthe SS-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and, operations nearthe PIC or Observer will not present an undue hazard per§ 91.119(a). Adherence to these restrictions in Sky Systems' Operations Manuals will ensure operations canbe conducted without compromising public safety. 16
K. 14 C.F.R. § 91.121: Altimeter Settings Sky Systems seeks anexemption from 14 C.P.R.§ 91.121, whichrequires a person operating an aircraft to maintain cruising altitude or flight level byreference to an altimeter that is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent that the UASs do nothave a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety

16See e.g., Grant ofExemptionNo. 11138 toDouglas Trudeau (FAA-2014-0481 at 19): "lfbarriers or structures are presentthat can sufficiently protect nonparticipating persons from the UA or debris in the event ofan accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operatormust also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipatingpersons. In addition, the FAA fmds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does notpresent an undue hazard."U.S Department ofTransportation September 30, 2015 Page 18 The FAAhas stated that an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 canbe achieved incircumstances where: (1) the UASs will be operated below400 feet AGL or below17

, (2) withinVLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiation point is established for the PIC to confirm accuracy ofthe onboard GPS

.18
The SS-UASs that Sky Systems intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Sky Systems' Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass priorto each flight operation. Like prior FAA Section 333 Grants ofExemption, the SS-UASs Sky Systems intends to use, and the safety mitigationprocedures contained in the Operations Manuals, both ensure that an equivalent level ofsafety or greater level will be achieved, and a Grant ofExemption to the requirements of§ 191.121 is therefore appropriate. 

### L. 14 C.F.R. 

### § 91.15l(a): Fuel Requirements for Flight in 

### VFR Conditions Sky Systems requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFRconditions. Section 91.151 states: (a) No person maybegin a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery power means that no meaningful flight operations canbe conducted while still maintaining a 30-minute batteryreserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, 

### it is not Sky Systems' intentionto fly the SS-UASs at night. 

### EquivalentLevelof Safety
In the Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAAdetermined that an equivalent level ofsafety to the fuel requirements for flight inVFRconditions could be achieved byprohibiting the PIC from beginning a SS-UAS flight unless (considering wind and forecast weather conditions) there was enough powerto fly to the first intendedpoint oflanding and, assuming normal cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAAconsidered that the UAS batteries for the SS-UAS provide approximately 50 minutes ofpowered flight (withpayload) andprovided battery level and battery time remaining inminutes and seconds to the PIC. 19 The FAA also considered the fact the SS-UAS

17Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will notbe operated more than 100 feet above the highestpoint onthe structure.

18See Grant ofExemptionNo. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).

19. Grant ofExemptionNo. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).U.S Department ofTransportation September 30,2015 Page 19 operating manual states: "start every flight with a fully charged battery inthe aerial vehicle", and that inthe event that the SS-UAS should run low onpower, the PIC will be alerted and can safely land the- SS-UAS as soon as possible. Like the VDOS Grant ofExemption, Sky Systems' use ofthe SS-UAS, combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety canbe achieved and in fact exceeded. Similarly, inthe Grant ofExemptiontoAlanPurwin (ExemptionNo. 11161), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight inVFR conditions could be achieved byprohibiting the PIC from beginning a flight withthe UAunless (considering wind and forecast weather conditions), there was enough power to safely fly at normal cruising speed to the intended landing point and land the UAwith 25%battery power remaining. Sky Systems will adhere to this limitation for its SS-UAS flights. The SS-UAS includes a lowbattery warning system and the amount ofbattery reserve power remaining is continuously transmitted tothe PIC viatelemetric data feed, which downlinks from the SS-UAS to a ground-based-on-screen display.20 As required by Sky Systems' Operations Manuals, the PIC will promptly fly the SS-UAS backto the home launch location orpredetermined abort location where it may safely land, while still maintaining a minimum of25% reserve batterypower. Sky Systems submits thatthe procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined withthe requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and withinVLOS ofthe PIC and Observer(s), ensure thatthe proposed operation will provide an equivalent orhigher level ofsafetyto the public to that provided by the regulations from which exemption is sought. 

### VI. DRUGAND ALCOHOL PROGRAM Sky Systems will have policies inplace to ensure that no personmay participate in SS-UAS flight operations ifthey are under the influence ofalcohol or any drug. 

### VII. PUBLIC INTEREST The public interest will be served by granting Sky Systems' Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal inpassing Section 333(a) through (c) ofthe Reform Act-the FAAAdministrator's assessment ofwhether certain UAS may operate safely inthe NAS before completion ofthe statutorily required rulemaking. The proposed SS-UAS operations inthis Petition for Exemption significantly improves the safety andreduces risk ofharm, physical injury and property damage to the public at large, the property owners from whom permission was granted for use by Petitioner and abutting

20. The SS-UAS ground control station displays, the UASs position, navigationroute, tail number, altitude, heading, north seeking arrow, range to targets, calculatedtargetposition, date/time, and sensorheading and orientationrelative to the UAS.U.S Department ofTransportation September 30,2015 Page20 properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who maybe inthe local vicinity. Traditional methods ofproviding surveillance and mapping services locationpersonnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for whichthe individual is neither trained nor equippedto perform, which exposes them to unnecessary risk ofserious physical injury from dangerous falls orotherphysical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and otherhazards associated with identifying specific locations for potential recording sites to be used inthe end product. The use ofsmall UAS can eliminate these hazards and ultimately create a much safer method ofperforming these types ofinspections creating a safer environment for thepublic as well as Sky Systems employees. The use ofsmall UASs also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew orexplosive fuel. Furthermore, inthe unlikely event of an accident, Sky Systems' small batterypowered SS-UAS presents significantly less danger to persons onthe ground when comparedto operations by conventional manned aircraft.21 As Petitioner's SS-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing inthe same functions proposed herein. Air quality will naturally be improved withthe reduction offuel powered vehicles. Lastly, as recognized by the FAAinprior Section 333 Grants ofExemptionto filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offeredbymanned aircraft.22 The quality ofthe finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry andprovide additionaljobs as the cost of providing the needed product is greatly reduced while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, given the lower cost, owner/operators and others inthe relevant industry will be more inclined to utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY All SS-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted over private or controlled-access property with permissionfrom the land owner/controller or authorized representative. Permission

21See Grant ofExemptionNo. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Mannedhelicopters conducting aerial filming canweigh 6,000 pounds ormore and are operatedby an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will weigh less than 55 pounds with no onboardpilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harmto participating and nonparticipating individuals orproperty inthe event ofan incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation."

22See e.g., Grant ofExemptionNo. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation September 30, 2015 Page 21 from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY Pursuantto 14 C.F.R. Part 11, the following summary is provided for publication inthe FEDERALREGISTER, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules inTitle 14 ofthe Code ofFederal Regulations: Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemption will enhance safety byreducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video production with conventional fixed-wing aircraft, rotorcraft, or other methods. 

### X. CONCLUSION Sky Systems' Petition for Exemption satisfies the criteria articulated in Section 333 ofthe ReformAct of2012 which includes weight; speed; operating capabilities; proximityto airports and populated areas; operation within VLOS and national security. The proposed SS-UAS operations will benefit the public as a whole by improving safety and reducing riskby alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. Inconsideration ofthe foregoing, this Petition for Exemption provides the FAA with more than adequatejustification for granting the requested exemptions allowing Sky Systems to use small SS-UAS inthe recorded production ofits product. We thank you for your prompt consideration ofour requested exemptions. Respectfully Submitted,

--. --··-··-:;::;:> '-A----

# ::~"-<S~**~-** 1 Dennis Spicuzza ·· Sky Systems Imaging 117 Hopkins Ave. Johnston, RI 02919 Phone: (401) 569-2523 Email: dspicuzza1@cox.net (The following attached items containproprietary and commercial information exempt from disclosure underthe Freedom ofInformationAct, 5 U.S.C. 

### § 522 et seq., and should be held in a separate file pursuantto 14 C.F.R. 

### § 11.35(b)).U.S Department ofTransportation September 30, 2015 Page22 Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing Location Protocols 7. TransmitterProtocols 8. Preflight Checklist 9. Post Flight Checklist 10. Equipment Checklist 11. UAS Manufacturer's Manuals a. User Manuals b. UAS Maintenance Manuals