U.S. Department ofTransportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 

CFR 61.113 (a) & (b); 13 C.F.R. 61.133(a); 91.7 (a); 91.9 (b) (2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 

91.409 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Attachments: 

1) Phantom 2 Vision+ User Manual Vl.8 2015.01 

2) Phantom 2 Vision Plus (Quick Start Guide) 

3) Phantom Pilot Training Guide 

4) DJI Inspire 1 User Manual V1.4 2015.7 

5) DJI Inspire 1 Maintenance Manual Vl.O 2015.2 

6) DJI Inspire 1 Quick Start Guide 2014-DJI 

Dear Sir or Madam; 

In accordance with the instructions for filing a petition for exemption as 

provided, and pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

and 14 C.F.R. Part 11, Sky View Photography, Inc., the operator of Small Ultralight Unmanned 

Aircraft- DJI Phantom 2 Vision+ ("UA") and an DJI Inspire 1 ("UA"), respectfully 

seeks an exemption from the Federal Aviation Regulations ("FARs") and submits our reasons, 

rationale and necessary attachments to support our request, below, and enclosed. 

Sky View Photography, Inc. a corporation based in Port Saint Lucie, Fl. herewith 

respectfully petitions for exemption from the above referenced regulations, due to the Unmanned Aircraft(s,) (UA) and & Unmanned Aircraft Systems(s,) (UAS) we will utilize during the course 

ofbusiness. We will continue to comply with any and all other applicable regulations concerning 

the operation of said aircraft unless otherwise stated as exempt by the FAA. 
of small VAs at low altitude within the U.S. national airspace system, versus a manned aircraft. 

Operations will be performed only at the request of, and with the authorization and 

permission of the clients or their authorized agents, and will be done so in a manner consistent 

with facilitating commerce and raising awareness of the beneficial uses of small unmanned air 

systems, provided such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333. 

Sky View Photography, Inc. exemption request will permit the operation of 

comparatively inexpensive VAs in tightly controlled, predetermined and limited airspace. This 

airspace will include areas away from the general public, airports, heliports and vehicular 

traffic, being utilized for services as listed above, and within property boundaries for real estate 

listing videos and photos. 

Sky View Photography, Inc. VAs will be used in lieu of comparatively more at risk 

hazardous operations now conducted with fixed wing and rotary conventional, fueled aircraft, 

which should reassure the FAA that these operations will achieve at least an equivalent level, or 

greater level of safety. In the interest of economic efficiency and public safety, Sky View 

Photography, Inc. hereby respectfully applies for an exemption from the above listed F ARs to 

allow commercial operations of VAs, so long as such operations are conducted within and under 

the conditions outlined herein, or as may be established by the FAA, and/or as required by 

Section 333. The use of Sky View Photography, Inc. VAs for these purposes reduces the need to 

operate conventional aircraft, typically needed to perform these types of operations, provides an 

economic benefit to the business consumer as the VAs provide higher quality imagery at a 

fraction of the cost of aerial videography, and photography using conventional aircraft. These 

savings result in not only enhanced efficiency and productivity for the affected activities but 

added environmental and safety benefits to the public at large. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's responsibilities under Section 333(c) of the Reform Act to "establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to determine which types of VAs do not 
As we look to describe more fully below, Sky View Photography, Inc.'s requested 

exemption would while remaining compliant with all aspects of Section 333, authorize 

commercial operations of aerial videography and photography, using Sky View Photography, 

Inc. UAs, which will be operated under tightly controlled conditions at an altitude of no greater 

than four hundred (400) feet, in airspace that is limited in scope, and the UAs will have 

automated control features preventing and deviance from those established settings. 

Given the small size of the UAs involved and the restricted environment within which they 

will operate, Sky View Photography, Inc. falls squarely within that zone of safety in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UAs to 

commence immediately. Sky View Photography, Inc. UAs are rotorcraft weighing less than five 

(5) pounds (2.26796 Kg) including energy source(s), camera, gimbal and assembly equipment 

and any payload. They operate, under normal conditions at a ground speed of no more than 

thirty (30) knots and have the capability to hover, and move in a vertical and horizontal plane, 

simultaneously. The UAs will operate only in a visual line of sight and within the geographical 

area described to us by owner and owners agent, notwithstanding any areas defined through 

regulations as "prohibited" "no-fly zones." Sky View Photography, Inc. UAs utilize four (4) 

counter-rotating propellers for balance, control and stability. 

Sky View Photography, Inc. UAs are equipped with GPS and auto return safety 

technology, and Sky View Photography, Inc. will ensure that that the UA's will not create a 

hazard to users of the national airspace system or the public. Due to the size of the UAs and the 

restricted areas in which the relevant UAs will operate, approval of the application presents 

no national security issue. Given the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with allowing UAs 

for aerial videography and photography operations, the grant of the requested exemptions is in 

the public interest. Additionally, there is economic efficiency created with the use of Sky View 

Photography, Inc. UAs as the typical cost to perform aerial videography and photography with 

helicopters and airplanes heavily multiplies the cost to business consumers and government 

agencies, including law enforcement, for the services which are to be provided by Sky View 

Photography, Inc. 

THE EXTENT AND BASIS OF THE RELIEF 

SOUGHT BY SKY VIEW PHOTOGRAPHY. INC. 

Sky View Photography, Inc. would like to operate its ultralight weight UAs prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such 
Sky View Photography, Inc. puts safety first and it is our paramount concern when 

considering any UA flight. Sky View Photography, Inc. UAs, utilized also in hobby flight, have 

a demonstrable safety record, and do not pose any threat to the general public or national 

security. 

Sky View Photography, Inc. small UAs are designed to hover in place via GPS and 

operate in Jess than a 24 knot (27 mph) wind. In order to increase safety plus stability, and limit 

hann and financial loss of property, Sky View Photography, Inc. will not fly its UAs in winds 

exceeding 17.3 7 knots (20 mph). Sky View Photography, Inc. U As have established safety 

systems that include a GPS mode that allows its UAs to hover in place when radio controls are 

released. Further, the UAs also utilize a Smart Mode during flight operations. This mode is the 

safest, most reliable and stable mode. When pilot communication is lost, Sky View 

Photography, Inc. UAs are designed to return, and slowly descend to the point of takeoff. Sky 

View Photography, Inc. does not operate its UAs near airports, hospitals, police heliports or 

news channel heliports. Sky View Photography, Inc. does not operate its UAs in areas where 

general public is within fifty (50) to one hundred (100) yards depending on location, 

conditions and weather. Sky View Photography, Inc. pilots and observers are constantly on 

alert for any manned aircraft and are prepared to immediately abort and land the UA at the 

nearest and safest ground point in the event a manned aircraft approaches or the Sky View 

Photography, Inc. pilot or observer suspects a manned aircraft may approach the operating area 

of a Sky View Photography, Inc. UA. 

Sky View Photography, Inc. UAs are further capable of vertical and horizontal 

operations, and are flown only within a visual line of sight of the pilot. Sky View Photography, 

Inc. UA flights generally last no longer than twenty (20) minutes with an altitude under four 

hundred feet ( 400') and utilize battery power rather than combustible fuels. Sky View 

Photography, Inc. does not operate its UAs below the manufacturer's recommended minimum 

charge levels for operation, preferring to remain well within a safe operating range to insure 

adequate communication between radio control and the UAs to eliminate potential for 

accidents, loss of control, or hazard. Fully charged reserve batteries are on hand to insure 

immediate replacement for a sufficiently safe level of operation. Sky View Photography, Inc. 

operates very conservatively and does not believe in taking risks that could create hazard to the 

public, property, or manned aircraft. As well as being well versed in the operating manuals and 

pilot training guides, Sky View Photography, Inc. PICs have logged hundreds of hours in 

numerous practice flights in order to simulate flights for future commercial use, to gain 

familiarization with the characteristics of this specific UA's performance during different 

times, temperature and climate conditions. 
cost prohibitive. Typically, only large businesses, large high end real estate companies and high 

net worth landowners are able to absorb such an enormous expense. This deprives non-luxury 

landowners and small revenue business and real estate companies from enjoying the benefit of this 

valuable marketing and promotional tool. Manned aircraft pose a clear threat to the general public 

through potential catastrophic crashes that may occur. There are many documented events where 

a manned aircraft has crashed into populated areas with the size and combustibility of these 

manned aircraft causing large property damage, human injuries and loss of life. The UA's Sky 

View Photography, Inc. propose to utilize pose no such threat since size and lack of combustible 

fuel alleviates any of these potential threat to the public. 

With the passage of the Reform Act, Congress has already proclaimed that it is in the 

public's interest to integrate commercially flown UAs into the national airspace system. The grant 

of this exemption request by Sky View Photography, Inc. furthers the public interest through 

academic and visual awareness of the geographical benefits of certain areas and by making this 

cost effective alternative available to small real estate companies, the average landowner, and the general public. Sky View Photography, Inc.'s ultralight UAs are battery powered and create no emissions that may harm the environment. In the unlikely event of a Sky View Photography, Inc. 

UA emergency landing, the consequence are far less than a full size helicopter or fixed wing 

aircraft, which are heavy, contain a crew, combustible fuel, and the crashing would cause 

catastrophic devastation to the public. 

The public's interest is furthered as Sky View Photography, Inc. minimizes ecological and 

crash threat by permitting aerial videography and photography captured through battery operated 

ultralight UA's. Permitting Sky View Photography, Inc. to immediately fly within national air 

space furthers not only the public safety but economic growth. Granting Sky View Photography, 

Inc. exemption request, substantially furthers the economic impact for any community and for 

companies looking to relocate or build in a certain community as well as individuals looking 

to relocate to a community for career advancement through academic and geographical 

awareness provided by Sky View Photography, Inc. In the end, the granting of this exemption to 

Sky View Photography, Inc. will serve as a benefit and stimulus to any economic community. 

SAFETY 

Sky View Photography, Inc. exemption will not adversely affect safety, as it will in fact improve 

upon and enhance safety for the public at large. Sky View Photography, Inc. submits the 

following representations of enhancements to current aerial videography and photography: 

• Sky View Photography, Inc. UAs weigh less than 5 pounds (2.26796 Kg) complete with 

the camera, gimbal assembly and entire payload. 
• Sky View Photography, Inc. pilots operate the U As through Visual Line of Sight only. 

• Sky View Photography, Inc. UAs have a GPS flight safety feature whereby if 

communication with the PIC is lost, the UA hovers, returns to the point of takeoff, and 

then slowly lands. 

• Sky View Photography, Inc. actively analyzes flight data and other sources of 

information to constantly update and enhance its safety protocols. 

• Sky View Photography, Inc. only operates in reasonably safe environments which are 

strictly controlled and away from power lines, elevated lights, airports, heliports and 

other actively populated areas. 

Sky View Photography, Inc. conducts extensive pre-flight inspections and protocol 

consistent with the owner's manuals (enclosed) to ensure safety remains the primary 

concern. 

• Sky View Photography, Inc. will always obtains all necessary permissions from the FAA 

and landowners prior to the operation of its UAs and; 

• Sky View Photography, Inc. is prepared to abort flights in the event of safety 

breaches or any potential danger. 

Manned fixed wing airplanes and helicopters are the primary means of aerial 

videography and photography for community awareness and real estate uses. While the safety 

record of such airplanes and helicopters is outstanding, there have been incidents involving loss 

oflife as well as extensive property damage due to crashes of these manned aircraft and it is 

far safer and less expensive to operate battery powered Sky View Photography, Inc. ultralight 

UAs to accomplish the same task. The potential for loss of life is greatly diminished with a UA as 

Sky View Photography, Inc. UAs carry no people or fuel on board, and the UAs are also very 

small and versatile which allows hazard avoidance quickly and safely. 

Sky View Photography, Inc. proposes that the exemptions requested herein will provide 

for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure because the proposed operations represent a safety enhancement to the 

operations conducted with conventional aircraft. The FAA has noted in past exemptions that 

"Conventional aerial video operations, using jet or piston-powered aircraft present risks 

associated with aircraft that weigh in the neighborhood of 5,000 to 7,000 pounds or more, carry 

large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must fly to and 

from the survey location." See, FAA Exemption 11110. 

These limitations and conditions being reiterated, are to which Sky View Photography, 

Inc. agrees to be bound when conducting all operations under an FAA issued exemption include: 

The UAs will weigh less than five (5) pounds (2.26796 Kg). 
A briefing will be conducted with regard to the planned UA operations prior to flight 

operations. It will be mandatory that all personnel who will be performing duties with 

regard to the flight operations be present for this briefing. 

The PIC and any VO will have been trained in the operation of UAs and will have 

received up-to-date information on the particular UA to be operated. 

The PIC and VO will at all times be able to communicate via voice communication. 

Written and/or oral permission from the relevant property holder(s,) or their authorized 

representative(s,) will have been obtained. 

All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

If the UA loses communications or loses its GPS signal, the UA will return to the 

initial launch site and automatically land. 

The UA will have the capability to abort a flight in case ofunpredicted obstacles or 

emergenctes. 

Accordingly, Sky View Photography, Inc. respectfully requests that the FAA grant the requested 

exemption without delay. 

14 C.F.R. PART 21. SUBPART H: AIRWORTHINESS 

CERTIFICATES 14 C.F.R. §91.203 fAlftl 

Given the size and limited operating area associated with the U A's to be utilized by 

Sky View Photography, Inc., 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. Considering 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 ofthe size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates 

that the UA operated without an airworthiness certificate, in the restricted environment and 

under 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 are less than five (5) pounds (2.26796 Kg) fully 

loaded, carry neither a pilot nor passengers, carry no explosive materials or flammable liquid 

fuels, and operate exclusively within a secured, pre-determined area, and restricted flight level as 

set by the PIC during preflight inspection. Unlike other civil aircraft, operations under this 
load. 

J4 C.F.R. § 45.23 (8). MARKING OF THE AIRCRAFT 

Even though the UAs will have no airworthiness certificate, an exemption may be needed 

as the UAs will have no entrance to the cabin, cockpit or pilot station on which the words "limited," 

"restricted, 11 ''light-sport," "experimental," or "provisional,'' may be placed. Sky View 

Photography, Inc. hereby requests that exemption. Given the size of the UAs, two-inch lettering 

will be impossible, the word "experimental," or any other term as designated by the FAA, can 

and will be placed on the UAs pursuant to FAA instruction, so as to remain in compliance with 

§45.29 (f). 

The equivalent level of safety will be provided by having the UAs marked on its fuselage 

as required by §45.29 (f) where the pilot, observer and others working with the UAs will see the 

identification of the UAs as "Experimental," or as any other term that the FAA finds acceptable for 

stated exemption. The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700,8738, 10167 and 10167A. 

14 C.F.R. § 61.113<Al & <Bl; 61.133<Al: PRIVATE PILOT PRIVILEGES 

AND LIMITATIONS; PILOT IN COMMAND; COMMERCIAL 

PILOT PRIYILEGES AND LIMITATIONS: PILOT IN COMMAND 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the UA's in this case are 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot's license to be the pilot in command of an aircraft 

for compensation or hire. Sky View Photography, Inc. respectfully proposes that operator 

requirements should take into account the characteristics of the particular UAs Sky View 

Photography, Inc. intends to utilize. These UAs have various built-in technological capabilities 

that strictly limit the potential for operation outside of the operating conditions set forth in this 

exemption application, including a fly back to launch point to terminate the flight. Further, 

detection of lost GPS or of insufficient satellites initiates an immediate return to launch location 

by the UAs; low power on the aircraft triggers escalating alarms at 30% and 15% levels and 

the aircraft weighs less than five (5) pounds (2.26796 Kg), fully loaded. 

Sky View Photography, Inc. believes that these safety factors permit operation ofUAs by 

operators under the conditions and restrictions outlined herein, and a not less than equivalent 
size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the 

level of risk associated with private pilot operations or commercial operations contemplated by 

Part 61 with conventional aircraft (fixed wing or rotorcraft,) that allowing operations of the 

UAs, as set forth above, meets or exceeds the present level of safety provided under 14 C.F.R. § 

61.1 13(a) & (b) and does not rise to the level of requiring a commercial or pilot license to operate 

the aircraft under §61.133(a). 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries the pilot and passengers, the UAs are remotely controlled with 

no living body on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance. Because the UAs will not carry a pilot, passengers, fuel or 

cargo, the proposed operations can achieve the equivalent level of safety by a ground PIC 

operating the UA. 

The risks associated with the operation of the UAs are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations ofthe UAs as requested far exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) &(b). 

14 C.F.R. §91 .7CAl; CIVIL AIRCRAFf AIRWORTHINESS 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Sky View Photography, Inc. will utilize the pre-flight checklist requirements as set forth in the 

submitted owner manuals, ensuring that not only the flight environment is conducive to UAs, but 

that the preflight checklist has been reviewed by the PIC and any UA, and is satisfactory for 

flight. Further, with hundreds of flight hours by each of our PIC, the experience of the PIC along 

with the performance of a flight environment check, as well as the performance of a preflight 

checklist, will ensure the airworthiness of each U A flight conducted by Sky View Photography, 

Inc. 

14 C.F.R. § 91.9 CBl C2l; CIYIL AIRCBAFf FLIGHT 

MANUAL IN THE AIRCRAFf 

The UAs, given their size and configuration, have no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because there is no 

room or capacity to carry such an item on the aircraft. Sky View Photography, Inc. respectfully 

requests an exemption. 
14 C.F.R. § 91.103: PREFLIGHT ACTION 

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided or 

needed for the aircraft, an exemption is hereby requested. It is for this reason that Sky View 

Photography, Inc. respectfully requests an exemption. 

As previously noted, the equivalent level of safety will be maintained by keeping Sky 

View Photography, Inc. user manuals, quick start guides, maintenance manuals and pilot 

training guides at the ground control point where the PIC flying the UAs will have immediate 

access to it. The user manuals and pilot training guides cover specific protocol to 

follow prior to flight and Sky View Photography, Inc. will ensure ofPIC's strictly adhere to 

these preflight checks. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of any 

flight. 

J4 C.F.R. §91.109; FLIGHT INSTRUCTION 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. Sky View Photography, Inc. respectfully requests an exemption. 

UAs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications as indicated within our submitted user manuals. In the 

event of a break in that signal or transmission, the UA automatically returns and lands, at the 

point of its initial takeoff. Given the safety features that are built within the system and the fact 

that a seasoned PIC would be accompanying the PIC in-training, Sky View feels there is not loss 

in safety and requests an exemption. Further, prior to any flight hours being logged, the PIC will 

be in-serviced and will be required to be thoroughly familiar with the pilot training guide, user 

manuals, evasive maneuvers, and preflight check lists. 

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. Please see 

FAA Exemption Nos. 5778K & 9862A. At a minimum, the equivalent level of safety is provided 

as neither a pilot nor passengers will be carried in the aircraft, the size and speed of the aircraft 

are but a fraction of what manned aircraft would be, there are no combustibles on-board and the 

automatic return feature of the UAs in the event of a lost signal enhance the safety of each flight. 
Sky View Photography, Inc. respectfully requests an exemption. This exemption is for UAs that 

are by nature a helicopter and thru this exemption requests authority to operate at altitudes up to 

four hundred (400) feet AGL, since an exemption may be needed to allow such operations. Sky 

View Photography, Inc. UAs will never operate at higher than the four hundred (400) feet AGL threshold. It will however be operated in a restricted area with a pre-determined security 

perimeter, where buildings and people will not be exposed to operations without their preobtained consent. 

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 or local officials and Sky View Photography, Inc. will be in 

compliance with all state, county and local ordinance, rules and regulations. Because of the 

advance notice to the property owner(s), or their authorized representative(s), all affected 

individuals will be aware of the planned flight operations. When one compares the flight 

operations proposed herein with aircraft or rotorcraft weighing far in excess of the less than five 

(5) pounds (2.26796 Kg) and the lack of flammable fuel that the UAs have, any risk associated 

with these proposed operations is far less than those presently presented with conventional 

aircraft operating at or below five hundred (500) feet AGL. Through the use of the UAs, we can 

severely diminish the amount of flights occurring via helicopter or small airplanes providing 

similar services, thereby reducing the potential of severe loss of life or property in the event of a 

crash of such helicopter of small plane. 

14 C.F.R. §91.121 ALTIMETER SETTINGS 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the UA may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption may be needed. Sky View Photography, Inc. 

respectfully requests that exemption. 

An equivalent level of safety will be achieved by the operator during our preflight 

check as indicated within the user manual for each UA intended to be utilized, and enclosed 

herein. Each UA that Sky View Photography, Inc. utilizes has capabilities that will be utilized to 

preset height, distance and radius limits, as well as no-fly zones, for each flight. Further, through 

the utilization ofGPS contained within each UA that Sky View Photography, Inc. the PIC 

receives a constant read-out showing height, distance, angle oflaunch and all other relevant data 

to provide for a safe, expedient, and efficient flight. 
Sky View Photography, Inc. respectfully requests an exemption as it believes that an 

equivalent level of safety can be achieved by limiting flights to twenty (20) minutes or thirty 

percent (30%) of battery power whichever happens first. Further, those conditions can and will 

be preset on the UA to initiate a landing when the battery powered is reduced to that level. This 

restriction would be more than adequate to return the UAs to their planned landing zone from 

anywhere in its severely limited and pre-set operating area. 

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

5745, 10673, and I 0808. 

14 C.F.R. §91.203 <Al AND <Bl; CARRYING CIYIL 

AIRCRAFT CERTIFICATION AND REGISTRATION 

The regulation provides in pertinent part: Except as provided in§ 91.715, no person may 

operate a civil aircraft unless it has within it the following: An appropriate and current 

airworthiness certificate. 

No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

Sky View Photography, Inc. UAs fully loaded weight is no greater than five (5) pounds (2.26796 

Kg) and is operated without an onboard pilot. As such, and due to size, there is no ability or 

place to carry certification and registration documents or to display them on the UA. Sky View 

Photography respectfully requests and exemption. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UA will have immediate access to them to the extent they 

are applicable to the UA. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797 A, 9816A, and I 0700. 

14 C.F.R. §91.405 <Al; 407 CAl ttl; 409 <Al (2l; 41 7(Al & CBl; 

MAINTENANCE INSPECTIONS 

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Sky View Photography, Inc. and based on that, we 
operating from no higher than four hundred (400) feet AGL. Sky View Photography, Inc. 

operators will ensure that the UAs are in working order prior to initiating flight, perform required 

maintenance pursuant to the attached manuals, and keep a log of any maintenance performed. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. 

Thank you for your time on this matter and I look forward to your response. 

Respectfully Submitted; 

Jonathan Quigley 

President 

Sky View Photography, Inc. 

168 SW Peacock Blvd. 

Bldg. 35-201 

Port Saint Lucie, Fl. 

34986 

quigley.jonathan@yahoo.com 

973-907-6563 

Attachments