UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE WASHINGTON, DC 20590
**IN THE M AT**  **TER OF THE PETITION FOR EXEMPTION OF:**



## Prairie Sky **Cam**

**FOR A N EXEMPTION SEEKING RELIEF FROM**  **THE REQUIREMENTS OF THE FAA**  **REFORM A CT AND**  **PA RT 11 OF THE FEDER** **AL A**  **VIA TION REGULA** 

**TI ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA**  **L REGUL AT**  **IONS SECTIONS C.F**  **.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);**

**91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). CONCERNING**  **COMMERCIA L**  **OPERA TION**  **OF UNM**  **AN NED**  **AIR CRA**  **FT SYSTEMS PURSUA**  **NT TO SECTION**  **333 OF**  **THE F AA M**  **ODERNIZ AT**  **ION AN**  **D REFORM A CT OF**  **2012 (PUBLIC L AW** **112 -**  **95) Submitted on**  **March 5, 2016 Prairie Sky** **Cam 2698 E. 400 North Rd**  **Pana, IL 62557**Prairie SkyCam 217 - 562 - 7222 2

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act, Anthony Ambrose of Prairie SkyCam , operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.  Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.  Aerial inspection/photog raphy of residential/commercial structures under contract with the owners or local government authority.  Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and c ell towers.  Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.  The ability t o offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System ( NAS) as well as for the protection of the persons and property . As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures or working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.Prairie SkyCam 217 - 562 - 7222 3

**Petitioner Name and A** **ddress :**  Prairie SkyCam Attn: Anthony Ambrose ( Owner & Pilot ) 2698 E. 400 North Rd Pana, IL 62557 Ph one : 217 - 562 - 7222 Email: info@prairieskycam.com **Background :**  The Petitioner, Prairie SkyCam is under Anthony Ambrose ’s direction. Anthony is a highly accomplished, capable, experienced , and trusted professional. Prairie SkyCam is a Midwest - region aerial photo graphy and video company with more than 10 years of professional UAS experience serving a wide variety of clients with p hotography (aerial & ground) , videography (aerial & ground) , 360 ° x180 ° panoramas and virtual tours (aerial & ground) in the following areas: recurring construction progress, site planning, industrial, commercial, residential, engineering, manufacturing, agriculture, and more . Prairie SkyCam provides photography and video services for clients across the Midwest and has always been fully insured from inception . **Expertise & Experience :**  For more than 25 years, Anthony has been a professional computer software engineer involved in the building and piloting of various types of remote controlled aircraft and ultralight aircraft. Also, as a result of more than 10 years in the Aerial Photography and Video business, Anthony, has an in - depth understanding of the capabilities a nd safety concerns involved in using this technology as an asset to the community. Anthony has also held an FAA Private Pilot Airplane Single Engine Land Certificate since 1997 (FAA Certificate Number 3826214) which adds an additional level of understandin g of the safety concerns involved
. **Safety Record**  **:** As a result of its adherence to detailed safety procedures before , during , and after all operations, Prairie SkyCam has a zero incidence safety record during its 10+ years of operation.Prairie SkyCam 217 - 562 - 7222 4

**Description of Ty**  **pe, Make and Model of sUA V/UA** **S Requested:** The petitioner is seeking an exemption to commercially operate a **DJI Inspire 1** , Model T600, with a total weight of 2935g or 6.47lbs. The dimensions are 438mm x 451mm x 3 01mm or 17.24inch x 17.75inch x 11.85inch. Under still air the maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Mod el DJI 3510, powered by a 6 - cell 4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controller with an operating frequency of 2.400GHz –2.483GHz. The live video feed will have an operating frequency of 5.728GHz – 5.850GHz. The applicant will operate the UAS in line of sight within a predetermined area owned and/operated by the property representative. Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Manuals related to the DJI Inspire 1 aircraft can be found in appendices A t o D. **The FAA**

**has already**

**granted several**  **exemptions for the use of the DJI Inspire 1.** A few examples include :  Exemption 12030 to American Family Mutual Insurance Company (Docket No. FAA–2015 – 1380)  Exemption 11789 to Legend Creative Group (Docket No. FAA–2015 – 1004 )  Exemption 12002 to Advanced Aviation Solutions LLC (Docket No. FAA–2015 – 1226)  Exemption 12046 to AerOptix, LLC (Docket No FAA–2015– 1534);  Exemption 12302 to Brad G. Beshaw (Docket No. FAA–2015 – 1527)  Exemption 11760 to Brian L. Short (Docket No. FAA–2015 – 0992)  Exemption 11814 to Alert5 International, LLC (Docket No. FAA–2015 – 1142)  Exemption 12496 to 360 Delaware Orbit Tours (Docket No. FAA–2015 – 0705)  Exemption 11788 to Bird’s Eye Aerial Photography, Inc. (Docket No. FAA–2015 – 1003)  Exemption 11 289A to Bird’s Eye Solutions, LLC (Docket No. FAA- 2014 - 0944)Prairie SkyCam 217 - 562 - 7222 5

 Exemption 11993 to BUNGEE LLC (Docket No. FAA–2015 – 1511) **Commercial (Mission, Operation) Purpose:** This exemption request, once granted would allow the petitioner to operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge i nspections, flare stack inspection s , utility- power generation system inspections and patrol ling, aerial inspection s , photography and videography of residential and commercial real estate, weddings, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline in spection and patrolling, filmmaking, cinematography, and videography, precision agriculture with onboard sensors, wildlife and forestry monitoring, aerial surveying, construction site inspection and monitoring, a erial imaging for safety, monitoring and com paring work efforts and completion percentages, and security of controlled environment of various sites, 360°x180° aerial panoramas and virtual tours, aerial video and live video feed to assist with search and rescue operations under the authority and supp ort of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, aerial mapping, training to persons individually or belonging to both privat e and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events including high schools , colleges, professional sports, open air events and fairs, research, risk management and assessm ent, motion picture production, surface mining, closed set filming, disasters, and catastroph ic events. **Ai rcraft**  **a nd Equivalent Level**  **o f Safety**  **:** Regarding the level of safety surrounding the proposed operations and the public benefit, reductio n in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay. The operatio n limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of th e persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to wh en conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

 The UAS will weigh less than 55 lbs.  The UAS will have a maximum operating speed of no more than 50mph.Prairie SkyCam 217 - 562 - 7222 6

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).  Flights will be terminated at 25% battery power.  Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.  Minimum crew for each operation will consist of the UAS Pilot, t he Visual Observer (VO) and may include but not limited to a Camera Operator.  The UAS pilot will be a designated Pilot in Command (PIC) and hold a Private Pilot’s License along with a valid United States Driver’ s License .  A briefing will be performed regarding the plann ed UAS operations prior to each flight.  All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.  The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.  The operator will file FAA Form 7711 - 1, or its equivalent, as modified in light of the requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from planned operation .  The operator will obtain verbal/written conse nt of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as requi red under the FOM. Wi th the advanced permission of the FSDO, operations at closer range may be approved.  The PIC and VO will have been trained in operation of UAS and receive up - to date information for the particular UAS to be operated.  The PIC and VO will be able to communicate by voice or radio at all times.  Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.  If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre - determined location within a designated location and land autonomously.  The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.Prairie SkyCam 217 - 562 - 7222 7

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 for the issuance of airworthiness 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 of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight , speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and und er the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less t han 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be t ightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. Thes e safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly,application of these same criteria demonstrates that there is no credible threat to national security pos ed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. **Specific Uses Public Benefits:** The UAS , powered by batteries, is smaller, l ighter and more maneuverable than larger aircraft running on combustible fuel . I t operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bod ily injury. W ith a small payload and maximum flight time of only 20 minutes, th ere is little or no risk to national security. Low level oblique photos , 360 °x180° panoramas, and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex properties. The benefits of reduced cost and improved quality of presentation from the UAS will be valuable to many clients in a wide variety of applications.Prairie SkyCam 217 - 562 - 7222 8

Additionally, Prairie SkyCam request s that they be allowed to use the UAS to benefit first responders (f irefighters, police, sherriff, et al.) who m ay desire assistance while remaining subject to all limitations cited in this application as they do so. Prairie SkyCam respectfully submits that using UAS to perform the aforementioned operations offers a net safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Approval of this application also will benefit many clients in various areas of the United States economy
. **Maintenance:** Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety wi ll be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 f eet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance pe rformed. Moreover, the operator is the person most familiar with the aircraft and best suited t o maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As pr ovided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance needed. Satisfaction of criteria provided in Section 333 of the Reform Act provide more than adequate justification for the grant of the requested exemptions allowing the commercial operation of the applicant’s UAS. Respectfully submitted, Anthony Ambrose Prairie SkyCam 2698 E. 400 North Rd Pana, IL 62557