Michael H. Ossipov, Owner

Flashcalc Digital Solutions, LLC dba SkyshotsTucson

7058 W Pebble Valley Dr

Tucson, AZ 85757

520-271-4651

15 Feb 2016

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

Re: Flashcalc Digital Solutions, LLC dba SkyshotsTucson request an exemption from the requirements of 

Title 14 of the Code of Federal Regulations Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) concerning commercial operation of a 

DJI Phantom 3 unmanned aircraft system, pursuant to section 333 of the FAA Modernization and 

Reform Act of 2012 (public law 112-95)

Dear FAA;

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14

C.F.R. Part 11, the Petitioner, Michael H. Ossipov, owner of Flashcalc Digital Solutions, LLC dba 

SkyshotsTucson.com, requests exemption from the following Federal Aviation Regulations (FAR) in order 

to legally operate a small Unmanned Aircraft System (UAS) in the National Airspace System (NAS). This 

exemption will permit SkyshotsTucson to operate a UAS, specifically the DJI Phantom 3, for the 

commercial purpose of conducting aerial video and photography of construction sites, residential and 

commercial real estate, civil landscapes and events over certain areas of the United States. 

The regulations the Petitioner requests exemptions from are the following:

14CFR 61.113 (a) & (b)

14CFR 91.7(a)

14CFR 91.119 (c)

14CFR 91.121

14CFR 91.151(a)

14CFR 91.405 (a)

14CFR 91.407(a) (1)

14CFR 91.409 (a) (2)

14CFR 91.417 (a) & (b)

Introduction

SkyshotsTucson has been providing aerial photography services in Southern Arizona for the past 8 years. 

Our interest, based on customer feedback, is to add UAV videographic capabilities by using the UAS DJI 

Phantom 3. Our aim is to use the DJI Phantom 3 for aerial operations in order to provide a more 

affordable, high-quality production system for a variety of governmental, commercial, public, and 

residential uses, targeting construction sites, commercial and residential real estate appraisals and 
marketing, coverage of civic landmarks, and coverage of special events. The Petitioner states that all 

UAS flights will occur over private or controlled access property and will do so with the property owner's 

consent and knowledge. The UAV will not fly near individuals that are nonparticipants in the project 

being recorded, and all participants will be instructed to maintain visual contact with the UAV. 

The Petitioner, Michael H. Ossipov, will act as Pilot in Command of the DJI Phantom 3, and will be 

directly responsible for the operation of the UAS. The Petitioner holds a current Private Pilot certificate 

and has a current Class 3 Medical Certificate. He has received instruction in the safe operation of the DJI 

Phantom 3 and has experience flying the UAV. 

SkyshotsTucson seeks an exemption to operate DJI Phantom 3 system for compensation or hire within 

the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has 

a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of 23.2”, a 

maximum speed of approximately 16.4’fps and a maximum flying height of 400'. The DJI Phantom 3 is 

equipped with four main rotors that are driven by Lithium Polymer battery powered electric motors. A 

Form 8050-1 Aircraft Registration Application has been submitted, requesting the reserved registration 

N804WM for the UAV. Accordingly, the DJI Phantom 3 that will be operated by SkyshotsTucson will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

Basis for the Petition

Relief from 14CFR61.113(a) and (b):

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by SkyshotsTucson to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, 

and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC 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. 

As set forth more fully below, SkyshotsTucson submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate 

either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in 

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures.

Further, SkyshotsTucson submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to SkyshotsTucson’s business; and (2) will not 
carry passengers or property for compensation or hire. The FAA has previously granted relief from 

Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Relief from 14CFR91.7(a):

SkyshotsTucson seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, SkyshotsTucson submits that they will ensure that the DJI Phantom 3 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft 

are in a condition for safe flight. A preflight inspection, as described in the Phantom 3 User Manual, will 

be performed before each flight to ensure safety of the flight.

Relief from 14CFR91.119:

Section 91.119 establishes safe altitudes for operation of civil 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 by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner, 

facility owner, and/or local officials. Because of the advance notice to the property owner and 

participants, all affected individuals will be aware of the planned flight operations as set forth in the 

Manuals. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 

55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography 

industry. In addition, the low-altitude operations of the UAS will ensure separation between these smallUAS operations and the operations of conventional aircraft that must comply with Section 91.119. The 

FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 

and 11110.

Relief from 14CFR91.121:

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), SkyshotsTucson

seeks the requested relief because the DJI Phantom 3 UA’s altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully 

set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 UAS are 
equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

Relief from 14CFR91.151(b):

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered DJI Phantom 3 UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 

minutes. SkyshotsTucson seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that SkyshotsTucson proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI Phantom 

3 operating documents, and SkyshotsTucson’s proposed operating limitations, ensure that 

SkyshotsTucson will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly 

for a total duration of 23 minutes. 

SkyshotsTucson believes that an equivalent level of safety can be achieved by limiting flights to 20 

minutes or 25% of remaining battery power, whichever happens first. This restriction would be more 

than adequate to return the UAS to its planned landing zone from anywhere in its limited operating 

area. 

The DJI Phantom 3 UAS provides a low battery warning to indicate when it should be returned to the 

launch point. In addition, a "low" and "critical" battery level warnings will implement a "return to Home" 

(or "Go land") action in these situations. The Petitioner will not initiate a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and all flights will be conducted during daylight hours and at times not to be a nuisance to

others.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

10808 and Exemptions 11062, through11067, 11080 and 11110. 

Relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

The Petitioner, SkyshotsTucson, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

§ 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI 

Phantom 3, UAS in the National Airspace System (NAS), and for an exemption from the requirements of 

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

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

aircraft and its operation, SkyshotsTucson operation of DJI Phantom 3 UAS meets the conditions of 
FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. 

Accordingly, SkyshotsTucson requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft 

with an airworthiness certificate. 

SkyshotsTucson submits that the requested relief is proper since an equivalent level of safety will be 

ensured. SkyshotsTucson will use experienced personnel or technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction 

Manual). Furthermore, SkyshotsTucson will document and maintain all maintenance records for the DJI 

Phantom 3 UAS.

Reasons Why Granting SkyshotsTucson’s Request Would Be in The Public Interest

Granting the present Petition will further the public interest by allowing SkyshotsTucson to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real estate, 

events and civic landscape over certain areas of the United States. Moreover, use of the DJI Phantom 3 

UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Use of the DJI Phantom 3 UAV will reduce the need for manned aircraft to perform aerial 

acquisitions. Consequently, an exemption allowing the use of a DJI Phantom 3 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of 

life and property in the air and on the ground. The substantial risk to life and property in the air and on 

the ground will be substantially reduced or completely eliminated. The absence of flight crew members 

onboard the aircraft, the light weight (approximately 2.8 pounds) of the DJI Phantom 3 UAS, the small 

size (23 inches) and the absence of fuel on board contribute to an enhanced safety profile and less 

physical potential for collateral damage to life and property on the ground compared to manned 

aircraft.

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. Thus, operation of the DJI Phantom 3 UAS

will allow United States based companies, such as SkyShotsTucson, to remain competitive and 

contribute to growth of the U.S. economy. The battery powered DJI Phantom 3 UAS also represents an 

alternative fuel technology that allows companies greater operational flexibility compared to manned 

aircraft and also provides such flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the DJI Phantom 3 UAS, companies such as SkyshotsTucson, can remain competitive and 

profitable, ultimately contributing to growth of the U.S. economy. Improved financial performance of 

U.S. companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and 

abroad.

Reasons Why Granting the Exemption Would Not Adversely Affect Safety
In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, SkyshotsTucson’s operation of the DJI Phantom 3 UAS meet the conditions of 

FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H.

In seeking this exemption, SkyshotsTucson submits that the DJI Phantom 3 UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the DJI Phantom 3 UAS; 

(b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications of the DJI Phantom 3 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security considering its size, weight, speed, and operational capability. 

i. Technical specifications of the DJI Phantom 3 UAS. 

The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 

User Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 3 UAS global positioning modes enable the UAS to remain within a 

defined operational area. 

The DJI Phantom 3 UAS may be operated in both manual and global positioning flight 

modes. A complete description of the flight and navigational modes of the DJI Phantom 

3 UAS is provided at pages 11 of the DJI Phantom 3 User Manual attached hereto as 

Appendix A. 

iii. The DJI Phantom 3 UAS is designed for automatic return to home point or hover in the 

event of loss of the control link or navigation. 

When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 

3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire 

control link data from the GCS, the UAS will assume that the Control Link is lost and the 

will return to the home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set forth 

at pages 12 through 14 of the DJI Phantom 3 User Manual, attached hereto as Appendix 

A. 

iv. The DJI Phantom 3 GCS and its operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS 

and flight control software is provided at pages 23 through 29 of the DJI Phantom 3 User 

Manual. DJI Phantom 3 User Manual is attached hereto as Appendix A. 

b. Flight operations of DJI Phantom 3 uas is limited to the line of sight of a certificated pilot in 

command with a safety observer. 
The owner of SkyshotsTucson, Michael H. Ossipov, will be the only person to act as a pilot in 

command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all 

times during flight time. 

c. Flights of the DJI Phantom 3 UAS will be conducted pursuant to specific operating limitations. 

In seeking this exemption, SkyshotsTucson proposes to commercially operate DJI Phantom 3 UAS

for the special purpose of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI 

Phantom 3 small Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UAV must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made 

and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed 

in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or 

other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations contained in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office 
(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited 

from operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. 

The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the 

UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized. 

20. The UAV may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as required 

by the operator’s COA. The letter of agreement with the airport management must be made 

available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC. 
22. If the UA loses communications or loses its GPS signal, it must return to a pre-determined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

29. The UAV must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such 

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an undue 

hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 
32. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

This request for exemptions is similar in part or in whole to relief previously granted, including 

Exemption Nos. 11062 through 11067, 11080, 11110, 11109, 11112, 11213, and 12701.

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

SkyshotsTucson seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 

91.417 (a) & (b) to operate commercially a small Unmanned Aircraft Vehicle (55 lbs. or less) for the 

purpose of conducting aerial video and photography over certain areas of the United States.

SkyshotsTucson requests that the FAA consider whether good cause exists for not publishing a summary 

of the petition in the Federal Register because the requested exemption would not set a precedent, and 

any delay in acting on this petition would be detrimental to the petitioner.

Conclusion

SkyshotsTucson seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 

UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing SkyshotsTucson to safely, efficiently, 

and economically operate the DJI Phantom 3 UAS commercially within the NAS. 

Consequently, SkyshotsTucson respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.119, 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit SkyshotsTucson 

to operate the DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.
List of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333

FAA Modernization and Reform Act of 

2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

Dated: 28 February 2016

Michael H. Ossipov, Owner

Flashcalc Digital Solutions, LLC dba SkyshotsTucson

7058 W Pebble Valley Dr

Tucson, AZ 85757

520-271-4651

Michael@SkyshotsTucson.com