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 SkyshotsT ucson 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 o f 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 SkyshotsT ucson .com, requests exemption from the following Federal Aviation Regulation s (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 vi deo 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 ye ars. Our interest, based on customer feedback, is to add UAV videographi c 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 var iety of governmental, commercial, public, and residential uses, targeting construction sites, commercial and residential real estate appraisals andmarketing, 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 instruct ed 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 opera te 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 l evel 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, includ ing 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 compensatio n 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, veh icles 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 notcarry 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, 1 1080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
**Relief from 14CFR 91.7**  **(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 cond ition 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 14CFR91.1 19**  **:** Section 91.119 establishes safe altitudes for operation of civil aircr aft. 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 loca tion 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 pla nned 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 presen tly 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 small

UAS operations and the operations of conventional aircra ft 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 14CFR 91.121**  **:** 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 wi ll be maintained since the DJI Phantom 3 UAS areequipped 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 14CFR 91.151(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 visu al 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 practica lity 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 2 0 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" batte ry 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, thro ugh11067, 11080 and 11110.

**R elief 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 Modernizat ion 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 requ irements 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 it s operation, SkyshotsTucson operation of DJI Phantom 3 UAS meets the conditions ofFMRA 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.

**Reas ons Why Granting SkyshotsTucson** **’s Request Would Be i**  **n 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
a mount 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 . T he substantial risk to life and property in the air and on the ground will be substantially reduced or c ompletely 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 le ss 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 aeria l 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 c onsumer 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 t he Exemption Would Not Adversely Affec** **t 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 characteristi cs 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 s pecifications 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 P hantom 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.
i ii. 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, a fter 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 o perations of DJI Phanto m 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 desc ribed 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 certifica te. 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 fli ght. 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/obstruct ions 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 fol low 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. T he 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 t he 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 U AS 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 b e 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 insp ection 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, maintena nce, 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 statu s 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 e xemption 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 con sistent 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 b e 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 a eronautical 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 availab le 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 s ignal, 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 accord ance 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. p art 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 governme nt 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 Administra tor 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 pe rsons 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 followin g 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.
**Conclusio n**  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 ad vancing 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 Petiti on 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 i n 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

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-4651 Michael@SkyshotsTucson.com