Global SkyVizion LLC 2500 Tiltonshire Lane Apex, North Carolina 27539

U.S. Department ofTransportation Docket Management System 1200 NewJersey Avenue, SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11ofthe Federal Aviation Regulations from 14CFR 61.113 (a) 

### & (b) 14CFR 91.9 (b) (2) 14C.F.R. 91.103 14C.F.R. 91.119 14 C.F.R. 91.12114 CFR 91.151 (a) 14CFR 91.405 (a) 14CFR 407 (a) (1) 14CFR 409 (a) (2) 14 CFR 417 (a) 

### & (b) To Whom It May Concern: This application is being submitted on ourown behalf. Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Global SkyVizion LLC, operatorofSmall Unmanned Aircraft Systems r'sUASs") 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 sUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required bySection 333.1. As described more fully below, the requested exemption would permitthe operation ofsmall unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operation in videography presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to"

...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe application is: Global SkyVision LLC Contact: Ken Shorsher, Ret. Captain 2500 Tiltonshire Lane Apex, North Carolina 27539 919-656-9698 niteflyr727@aol.comRegulations from which the exemption is requested: 14CFR 61.113 (a) 

### & (b) 14 CFR 91.9 (b) (2) 14C.F.R. 91.103 14C .F.R. 91.119 14 C.F.R. 92.12114 CFR 91.151 (a) 14CFR 91.405 (a) 14 CFR 407 (a) (1) 14CFR 409 (a) (2) 14 CFR 417 (a) (b) This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333 (a) through (c) ofthe Reform Act. This law directsthe Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe reform Act. In making this determination, the Secretary is required to determine which types of UASs do notcreate a hazard to users ofthe NAS orthe public or pose a threatto national security in light ofthe following: The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in close proximityto airports and populated areas; and Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act 333 {a). Lastly, ifthe Secretary determinesthat such vehicle "mayoperate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." ID 333(c) emphasis added) 2. The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by itsterms includes exempting civil aircraft, as theterm is defined under40101 ofthe Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. Applicant interpretsthis provision to place the dutyon the Administratorto notonly process applications for exemptions undersection 

### 333, butfor the Administratorto craft conditions forthe safe operation ofthe UAS, if it should be determined thatthe conditions set forth herein do notfulfill the statutory requirements for approval. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section orany sections 44702-44716 ofthistitle ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. 44701(f) See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203 (a) (1). Global SkyVizion LLC: UASs are rotorcraft, weighing 5 orfewer lbs. including payload. They operate, under normal conditions at a speed ofno more than 30 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. They will operate only in line ofsite. Such operations will insure thatthe sUAS will"not create a hazard to users ofthe national airspace system or the public." Given the small size ofoursUASs, the applicant falls squarely within that zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA 

### must, by exemption, allow commercial operations of UASs to commence immediately. Also dueto the size ofthe UASs and the restricted areas in whichthe relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the FederalAviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for photography, thegrant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grant the requested exemption without delay. 

### AIRCRAFT AND EQUIVALENT LEVEL OF 

### SAFETY
The applicant proposes thatthe exemption requested herein applyto civil aircraftthat have the characteristtcs and that operate with the limitations listed herein. These limitations provide for atfeast an equivalent or even higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancement to thealready safe movie and television filming operations conducted with conventional aircraft.
These limitations and conditions to which Aerial Approach, ltd. agrees to be bound when conducting commercial operations underan FAA issued exemption include:
1. The sUAS will weigh less than 5 lbs. 2. flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum total flighttimefor each operational flightwill be 25 minutes. Flights will be terminated at25% battery power reserve should that occur priorto the 25 minute limit. 4. Flights will be operated at an altitude of no morethan 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist ofthe sUAS Pilot, and the Visual Observer. 6. sUAS Pilotwill be Pilot in Command (PIC) 7. The UAS will onlyoperate within a confined area. 8. A briefing will be conducted in regard tothe planned sUAS operations priorto each project. Itwill be mandatorythat all personnel who will be performing duties be presentforthis briefing. 9. The operatorwill obtain the consent ofall persons involved in the photography and filming and ensure that only consenting persons be allowed within 50 feet ofthe flight operation. 10. Pilot and observer wi11 have been trained in operation of UAS generally and received up-to·date information on the particular UAS to be. 11. Observer and pilotwill at all times be able to communicate byvoice and/or text. 12. Written and/or oral permission from the relevant property holders will be obtained. 13. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have capabilityto return to a predetermined location within the Security Pertmeter and land. 14. The sUAS will have the capability to abort afHght in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 

### (f)) and Section 333 ofthe Reform Act both authorize the FAA toexempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operatingwith an airworthinesscertificate withoutthe restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 5 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquidfuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored by the operator. These safety enhancements provide a greater degree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. 

### § 45.23 (b). Marking ofthe Aircraft The regulation requires:
When marks include onlythe Roman capital letter "N" and the registration number is djsplayed on limited, restricted or light-sport category aircraft or experjmental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor morethan 6 inches high, the words "limited, 11 11restricted, 11 "lightsport," "experimental," or "provisional," as applicable.
Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS although there is no entrance to a cabin, cockpit or pilot station on which the word "Experimental'' can be placed. Given the size ofthe sUAV, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).
The equivalent level ofsafety will be provided by havingthe sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe UAS as "Experimental."
No person mayoperate a U.S.-registered civil aircraft

... (2) For which an Airplane or Roton:raft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Plight Manual, approved manual material, markings, and placards, or any combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such aflight manual on the aircraft, not only because there is no piloton board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level ofsafety

### will be maintained by keeping the flight manual atthe ground control pointwhere the pilotflying the sUAS will have immediate access to it. The FAA has issued the followingexemptions tothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command totake certain actions before flight to insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafety will be provided as set forth in Sections 

### J and Kofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 14C.F.R. §91.109: Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a mannedfree balloon) that is being used forflight instruction unless that aircraft has fullyfunctioning dual controls. sUASs and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraftvia radio communications. The FAA has approved exemptions forflighttraining withoutfullyfunctional dual controls for a number of aircraft and forflight instruction in experimental aircraft. See Exemption Nos.5778K 

### & 9862A. The equivalent level ofsafety provided bythe factthat neithera pilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119**estab~ishes** safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authorityto operate at altitudes up to400 AGL, or not marethan 200 above an elevated platform from which filming 

### is planned, an exemption may be needed to allow such operations. As set forth herein, except forthe limited conditions stated in the Manual, the UAS will neveroperate at higherthan 400 AGL Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.
The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is**operat~d.** No flight will be taken withoutthe permission ofthe property owneror local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these small- UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119. 14C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...tothe elevation ofthe departure airport or an appropriate altimetersetting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuanttothe Manual and Safety Check list, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel tofly to thefirst point of intended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthat for at least 30 minutes; or (2} At night, to fly afterthatfor at least 45 minutes."
The battery powering the sUAS provides approximately30 minutes of powered flight. To meetthe reserve requirement in 14CFR §91.151, sUAS flights would be limited to approximately 10-12 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longertime frame forflight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14CFR §91.1Sl(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with**FA~** 91.151 (a)). Operatingthe small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utilityforwhich the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights to 30 minutes or 25% ofbattery powerwhichever happens first. This restriction would be morethan adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a} Except as provided in§91.715, no person may operate a civil aircraft unless it has within itthe 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 atthe cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS.
An equivalent level ofsafety.will be achieved by keeping these documents atthe ground control point where the pilotflying thesUAS will have immediate access tothem, tothe extentthey are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section,have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply onlyto aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant tothe flight manual. An equivalent level ofsafety will be achieved because these small UAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higherthan 400 feetAGL. As provided in the Manual, the operatorwill ensure thatthe UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. The operation ofsmall UASs, weighing less than 5 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close tothe ground, and in a sterile environment and as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximityto the ground and people. Privacy: All flights will occur over private orcontrolled access property with the property owner's prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012, i.e. size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line ofsight and national security provide morethan adequatejustification forthe grant ofthe requested exemptions allowing commercial operation ofthe applicants UAS. In summary, based on thirty-fouryears ofcommercial airline experience and with over 19,000 hours of flight time, Global SkyVizion LLC is well qualified to meetthe high standards ofthe FAA with reference to regulations and standards. Thank you for yourconsideration forthis exemption.

Ken Shorsher Retired Airline Captain 919-656-9698 niteflyr727@aol.com