February 21, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Petition of Sky Drone Pro for Exemption from Certain Federal Aviation

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of the 

FAA Modernization and Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act ("FMRA") and 14 C.F.R. 

part 11, Back2School Texas, LLC d/b/a as Sky Drone Pro ("SkyDrone") hereby petitions the 

Federal Aviation Administration ("FAA") for exemption from 14 C.F.R. §§	 45.23 (b), 

61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.417(a) and (b), 407(a)(1), 

409(a)(2), 417(a) and (b), 91.121, 91.151(a), 91.203(a) and (b) and 91.405(a), and any other 

rules the FAA deems necessary, to enable SkyDrone to operate unmanned aircraft systems 

("UAS") for aerial data collection. Specifically, SkyDrone seeks to operate UAS for aerial 

video and photography, real estate marketing and facilities inspection using the DJI Phantom 3, 

3DR Solo, Yuneec Q500+, and the DJI Inspire 1. Because this petition is similar in all material 

respects to previously-granted Section 333 petitions, SkyDrone requests expedited approval 

pursuant to the FAA's summary grant process.

I. PROPOSED OPERATIONS

The requested exemption would permit commercial operation of SkyDrone [unmanned 

aerial systems, a multi rotor aircraft, weighing less than 55 lbs. including cargo. The 

applications for this sUAS device would consist of still photographs and/or video taken by 

an onboard camera and associated data processing functions and used for aerial 

videography and photography for weddings and special events, real estate, filmmaking and 

aerial inspections on construction sites of difficult to reach equipment or structures. Use of 

the sUAS for these purposes reduces the need to operate conventional aircraft or other 

equipment for the same purpose and provides very high quality imagery at a fraction of the 

cost of surveys and inspections using conventional means.

Likewise, inspections of structures can be safely performed without endangering the 

inspector or inhibiting local industrial or public operations with ladders, lifts or other 

equipment. These savings result in enhanced safety efficiency and productivity for the 

affected activities, as well as environmental benefits and potential savings in both cost and

hazards to the public.
II. THE UAS

SkyDrone requests an exemption to operate the DJI Phantom 3, 3DR Solo, Yuneec Q500, and 

the DJI Inspire 1, all of which are well below 55 pounds including payload. Through the 

Section 333 exemption process, the FAA has authorized use of all UAS for which exemption is 

requested herein.1

III. REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has granted, 

SkyDrone requests that the FAA issue a summary grant of exemption pursuant to the agency's 

expedited summary grant process. Specifically, the public interest and safety benefits

SkyDrone’s operations will achieve are materially similar to those recognized in Grants of

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clay co,

Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see Docket No. FAA2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642).

SkyDrone will adhere to a series of operating parameters that will offer the same level of safety 

as the conditions the FAA currently requires in its summary grants2.

IV. APPLICANT INFORMATION

The name and contact information of the applicant is:

Paul Alex Islas

Back2School Texas, LLC d/b/a/ Sky Drone Pro

302 Lorenaly Drive, Suite E

Brownsville, TX 78520

(956)299-0571 • (956)525-0766 • (210) 993-3555

paul.islas@back2schooltx.com

Regulations from which exemption is requested:

14 C.F.R. §	45.23 (b);

14 C.F.R. §§	61.113(a) and (b);

14 C.F.R. §	91.7(a);

14 C.F.R. §	91.9(b)(2);

14 C.F.R. §	91.103;

14 C.F.R. §	91.109;

14 C.F.R. §	91.119;

14 C.F.R. §§	91.417(a) and (b);

14 C.F.R. §	91.407(a)(1);

																																																							 1		 See Exemption No. 11274A to United Services Automobile Association, Regulatory Docket No. FAA-2014-0796 (authorizing use of 

the 3DR Solo, DJI Phantom 3, and DJl lnspire); Exemption No. 11875 to Green Bee Limited, Regulatory Docket No. F AA-20 15-0698 

(authorizing use of the DJI Phantom 2); Exemption No. 12023 to William J. Henderson, Regulatory Docket No. FAA-2015-1518 

(authorizing use of the Yuneec Q500 Typhoon).

2 See, e.g., Exemption No. 12160 to Star Engineering Services LLC, Regulatory Docket No. FAA-20 15-1690 (Jul. 27, 20 15).
14 C.F.R. §	91.409(a)(2);

14 C.F.R. §§	91.417(a) and (b);

14 C.F.R. §	91.121;

14 C.F.R. §	91.151(a);

14 C.F.R. §§	91.203(a) and (b);

14 C.F.R. §	91.405(a).

V. OPERATING PARAMETERS

SkyDrone will adhere to the following operating parameters when operating UAS pursuant to a 

grant of the requested exemption:

1. Operations will be conducted using the DJI Phantom 3, 3DR Solo, Yuneec Q500+, and 

the DJI Inspire 1.

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an 

altitude greater than 400 feet above ground level, or, when visibility is less than 3 

statute miles, less than 500 feet below or 2,000 feet horizontally from a cloud. All 

operations will be conducted during the day under visual meteorological conditions.

3. All operations will be conducted in accordance with a Certificate of Waiver or

Authorization ("COA'').

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and 

the UAS will remain within the visual line of sight of the PIC or the VO at all times. 

The PIC will maintain VLOS capability and the ability to communicate verbally with 

the VO at all times.

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot

certificate, as well as an FAA airman medical certificate or a valid U.S. driver's license.

The PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an

aircraft in which the PIC is rated on his or her pilot certificate.

6. SkyDrone will ensure prior to operation that the PIC has demonstrated the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

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

flight hours and currency will be logged in a manner consistent with 14 C.F.R. § 

61.51(b).

7. SkyDrone’s operating documents will be accessible during UAS operations and made 

available to the Administrator upon request.
8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the UAS will not be operated until the necessary maintenance 

has been performed and the U AS is found to be in a condition for safe flight.

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

or flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting further operations under this exemption.

10. SkyDrone will follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements, as well as safety bulletins, for the aircraft and 

aircraft components.

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and 

will yield to all manned aviation activities.

12. SkyDrone will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION

The FAA has authority to grant the exemption requested herein under the FMRA and the

Federal Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into 

the national airspace, and directs the Secretary of Transportation to determine which UAS, "as 

a result of their size, weight, speed, operational capability, proximity to airports and populated

areas, and operation within visual line of sight do not create a hazard to users of the national

airspace system or the public or pose a threat to national security."3 Section 333 further directs

the Secretary to "establish requirements for the safe operation of such aircraft systems in the

national airspace system."4 The Federal Aviation Act authorizes the Administrator of the FAA

to grant exemptions from regulations prescribed under certain provisions of the Act where such

exemptions are in the public interest.5 Part 11 of the Federal Aviation Regulations governs the

FAA's exemption process and requirements. 6 The FAA has granted more than 1,100 

exemptions to date pursuant to its Section 333 and exemption authority, enabling commercial 

UAS operations in a wide variety of industries.

																																																							 3 Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 U.S.C. § 40101).

4 Id.

5 49 U.S.C. § 44701 (f) ("The Administrator may grant an exemption fi·om a requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds the exemption is in the public interest.").

6 See 49 C.F.R. Part 11.
VII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Should the FAA determine that publication in the Federal Register is required, SkyDrone offers 

the following summary pursuant to section 11.81 of the FAA's rules:7

Petitioner: Sky Drone Pro

Sections of 14 C. FR. Affected: 14 C.F.R. §	45.23 (b); 14 C.F.R. §§	61.113(a) and (b); 14 C.F.R. 

§	91.7(a); 14 C.F.R. §	91.9(b)(2); 14 C.F.R. §	91.103; 14 C.F.R. §	91.109; 14 C.F.R. §	91.119; 

14 C.F.R. §§	91.417(a) and (b); 14 C.F.R. §	91.407(a)(1); 14 C.F.R. §	91.409(a)(2); 14 C.F.R. 

§§	91.417(a) and (b); 14 C.F.R. §	91.121; 14 C.F.R. §	91.151(a); 14 C.F.R. §§	91.203(a) and 

(b); 14 C.F.R. §	91.405(a).

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §	45.23 

(b); 14 C.F.R. §§	61.113(a) and (b); 14 C.F.R. §	91.7(a); 14 C.F.R. §	91.9(b)(2); 14 C.F.R. §	

91.103; 14 C.F.R. §	91.109; 14 C.F.R. §	91.119; 14 C.F.R. §§	91.417(a) and (b); 14 C.F.R. §	

91.407(a)(1); 14 C.F.R. §	91.409(a)(2); 14 C.F.R. §§	91.417(a) and (b); 14 C.F.R. §	91.121; 14 

C.F.R. §	91.151(a); 14 C.F.R. §§	91.203(a) and (b); 14 C.F.R. §	91.405(a) to operate unmanned 

aerial systems for newsgathering, content production, and facilities inspection.

VIII. CONCLUSION

As demonstrated above, the UAS operations SkyDrone has proposed in this petition for

exemption will garner significant public benefits while presenting minimal safety risks.

SkyDrone's petition satisfies the criteria of Section 333 of the FMRA and is substantially 

similar to previous petitions the FAA has granted, meriting a summary grant of exemption. 

SkyDrone respectfully requests that the FAA grant this petition to enhance SkyDrone's ability 

to produce marketing and visual art material.

Sincerely,

Paul Alex Islas

Sky Drone Pro

																																																							 7 Id. § 11.81(f).