November 12, 2015

Petition for Exemption 14 CFR § 11.81

Addressed too: 

Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, S.E. 

West Building Ground Floor, Room W12-140 Washington, DC 20590

Petitioner:

SkySnap LLC

7215 W. Ustick Rd

Boise, ID, 83704

Phone: 208-918-2047

Email: Ivy@skysnap.us or Kiel@skysnap.us

Dear Sir or Madam, 

SkySnap LLC respectfully requests an exemption from several provisions of Title 14 of 

the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems 

(UAS) and in regards to commercial use in many fields. Including, but not limited to: 

engineering, inspections, photogrammetry, photography, videography, agriculture , motion 

picture, television, etc.

SkySnap LLC is seeking exemption because of a want to create a successful commercial 

business with the use of UAS while working co-operatively with the FAA to keep air space safe 

for the public. SkySnap LLC plans to benefit the public as a whole by offering services and 

opportunity for business owners, real estate agents, farmers, adventurers, and any others who 

seek aerial documentation. SkySnap LLC plans to offer these individuals the opportunity to take 

advantage of the technology that now exists in the form of UAS, and allow them to do so using 

an experienced UAS Pilot who understands how to safely operate such technology. SkySnap 
LLC also believes in the overall reduction of risk to individuals who would otherwise have to 

physically leave terra firma (i.e. high roofing inspections, search and rescue in a standard air 

craft, etc.) by allowing unmanned aircraft to gather the data while their human controller stays 

safely on the ground and out of harm’s way. 

SkySnap LLC understand these UAS are the technology of the future and wants to work 

within the FAA codes and regulations to keep this budding technology thriving in a safe manner 

in regards to the public. SkySnap LLC is a highly educated company focused on safety, hiring 

only the best pilots with pervious UAS training, and adhering strictly to the regulations. SkySnap 

LLC has bi-monthly meetings to review and stay up to date on any new and old UAS regulations 

ensuring we will only improve safety standards and ensure we in no way adversely affect 

the public safety. 

Description of UAS to be deployed under requested Exemption: 

1) DJI Phantom 3 Advanced- Using 2.400 GHz-2.483 GHz Operating Frequency

2) DJI Phantom 3 Professional- Using 2.400 GHz-2.483 GHz Operating Frequency

3) Future models to be added by amendments to this exemption

Please note: All models of aircraft used by SkySnap LLC will be under 55 pounds in total 

weight, with cameras and energy sources. 

Safety Regulations used by SkySnap LLC: 

 All flights will be performed with in the conditions and limitations laid out by the FAA

 Standard operating procedures prior to launch will include the manufacturer 

recommended preflight checklist (See below) as well as a SkySnap LLC preflight 

checklist of the vehicle and a visual inspection of landing area

 Flight operations will be conducted by a two-person team consisting of the PIC and the 

Visual Observer. All operations will be conducted with a clear line of sight between the 

UAS and the team. Team will stay stationary on the ground and in verbal communication.

 SkySnap LLC will only operate the UAS over private or public property with the 

permission of the property owner or the governing body and will maintain a safe distance 

from any structures, people or vehicles.

 Aircraft will comply with maintenance and inspection requirements of the manufacturer. 

All repair and maintenance work will be conducted or approved by qualified personnel, 

and will require a test flight after such work. Records of all maintenance and repair work 

will be kept in a maintenance log for each aircraft.
 All flight operations will be conducted in accordance with valid Certificates of 

Authorization.

 All UAS will have automated recall systems for any disruption of signal between the 

operator and UAS

 UAS will not exceed 87 knots (100 miles per hour) and will not operate at above an 

altitude of 400 feet above ground level. 

 UAS will always be with in line of site of the visual observer and PIC. This is human 

vision unaided by any devices

 Kiel Lampe is SkySnap LLC’s head PIC. He is a highly educated well trained UAS 

operator who brings detail oriented safety practices to any and all UAS flights. He sets 

the standard for SkySnap LLC’s safe flying practices. Any PIC for SkySnap LLC will 

hold a minimum of a Recreational/Sport Pilot license with all of the associated flight 

hours and knowledge. All PIC will undergo SkySnap LLC’s training program requiring a 

minimum of 10 hours of supervised flight with the UAS to the safety standards set by 

Kiel Lampe, SkySnap LLC ‘s head PIC. If the potential PIC does not show a satisfactory

level of safety and proficiency with the UAS they will be required to complete additional 

hours until such time they can act as they pass the requirements set forth by Kiel Lampe. 

All PIC will hold at least class or obtain a U.S. driver’s license in conjunction with their 

pilot’s license. 

 All visual observers will act as support for the PIC. They will undergo SkySnap LLC’s 

training program. Including instruction from trained SkySnap LLC pilots, training in the 

regulations set forth by the FAA to assist the PIC in maintaining safe flying practices, and 

the mechanical workings of the UAS to ensure all UAS will be safe in the air. When the 

aircraft is in the air it will be the visual observer’s roll to ‘keep eyes on the sky’ watching 

the UAS and for any hazards the UAS could encounter and maintain verbal 

communication with the PIC. 

 Any operations requiring notification of the Flight Standards District Offices (FSDOs) 

prior to operations – such as motion picture and television filming, or pipeline and 

powerline patrol- will be made aware of flight operations. Depending on location of the 

flight the correlating office will be made aware of SkySnap LLC’s operations. 

Manufacturer Recommended Preflight Checklist: 

1) Remote controller, Intelligent Flight Battery, and mobile device are fully charged

2) Propellers are mounted correctly and firmly.

3) Micro-SD card has been inserted, if necessary.

4) Gimbal is functioning normally.

5) Motors can start and are functioning normally

6) The DJI Pilot app is successfully connected to aircraft. 
SkySnap LLC Preflight Checklist: 

1) When flying over private property: verify with land owner to ensure permission. 

2) Ensure all software and firmware are up to date

3) Ensure all documentation is available and current. Including but not limited to current 

FAA regulations, this exemption, flight logs, operating documentation, any revisions of 

operating documents, etc.

4) Cross reference FAA regulations to confirm compliance

5) Determine location of nearest airport and verify flight team is a minimum of 5 miles 

away

6) Obtain permission from individuals on the ground in the intended flight path of the UAS

7) Full visual inspection of UAS to ensure no damage has occurred that could hinder flight

8) At the beginning of each flight sequence PIC will take off from ground, and hover at 5 

feet for a full 20 seconds to ensure aircraft is safe to fly. PIC will also verify compass and 

GPS is working accurately

a. Note: The UAS flown by SkySnap have an automatic hover safety feature. The 

hover feature tests the compass and GPS systems. If the UAS hovers without 

‘drift’ up, down, or side to side will confirm all systems are working properly and 

is safe to fly. Any ‘drift’ or other problems present themselves flight will be 

immediately terminated until the issues can be resolved. 

Request for the exemption of the following sections:

1) 14 C.F.R. Part 21, Airworthiness Certificates: 

a. In accordance with the statutory criteria provided in Section 333 of PL 112-95 in 

reference to 49 USC 44704, and in consideration of the size, weight, speed, and 

limited operating area associated with the aircraft and its operation, we request 

that this aircraft exemption meets the conditions of Section 333. Therefore, if 

granted Section 333 relief of 14 CFR part 21, and any associated noise 

certification and testing requirements of part 36, is not necessary.

2) 14 C.F.R. § 45.23 (b). Marking of the Aircraft: 

a. Due to the size of the UAS, two-inch lettering will be impossible. SkySnap LLC 

will mark all UAS with the ‘N’ on the fuselage but will be unable to mark UAS in 

the above mentioned format. All UAS will be registered in accordance with 14 

CFR part 47. 

3) 14 C.F.R. § 61.113 Private Pilot Privileges and Limitations: 

a. SkySnap LLC’s UAS will not be carrying any passengers or property for 

compensation and feel that a private pilot can successfully carry out the 

responsibility of PIC. In the Grant of Exemption in FAA Docket No. FAA2014-

0352, the FAA determined that the unique characteristics of UAS operation 

outside of controlled airspace did not warrant the additional cost and restrictions 

attendant with requiring the PIC to have a commercial pilot certificate and a class 

II medical certificate. 

4) 14 C.F.R. § 91.1 09(a) Flight instruction; Simulated instrument flight and certain 

flight tests
a. SkySnap LLC’s UAS do not offer the capability of a second set of controls and 

asks for exemption from this section. SkySnap LLC’s UAS do however offer 

safety features such as the capability to automatically hover, we offer this as our 

additional level of safety for our pilots and students. 

5) 14 C.F.R. § 91.119: Minimum Safe Altitudes in Uncongested Areas: 

a. The FAA has already determined that relief from Section 91.119(c) is warranted 

for UAS operations in uncongested areas with similar flight restrictions in 

reference to Grant of Exemption No. 11062, p. 2021. SkySnap LLC also seeks 

exemption from this section for similar operations. 

6) 14 C.F.R. § 91.121: Altimeter Settings:

a. SkySnap LLC seeks exemption form this section as our UAS do not use 

altimeters. Instead they use a combination of barometric pressure, as well as GPS 

location to determine altitude and location. Before any take off the UAS will be 

set to 0 to ensure accuracy. 

7) 14 C.F.R. §§§ 91.151 Fuel requirements for flight in VFR conditions.: 

a. The UAS will have a total flight time of between 15-25 minutes. The operator is 

notified of the power levels at all times, to allow for safe return of the UAS. 

SkySnap LLC asks for exemption due to the short duration of total flight. 

8) 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections: 

a. SkySnap LLC seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). 

These regulations specify maintenance and inspection standards in reference to 14 

C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a). An exemption from these 

regulations is needed because Part 43 and these sections only apply to aircraft 

with an airworthiness certificate, which the UAS proposed here will not have. 

SkySnap LLC proposes to have all UAS maintenance and inspections preformed 

in accordance with the manuals. This includes maintenance, overhaul, 

replacement, and preflight inspection requirements.

9) 14 C.F.R. §91.7 Civil aircraft airworthiness

a. As the UAS is not required to receive an airworthy condition by the FAA 

SkySnap LLC seeks exemption from this section. SkySnap LLC will have 

supplemental in-house and manufacturer inspections verifying the UAS’s 

mechanical and electrical systems for safe flight. 

10) 14 C.F.R. § 91.203(a)(1) Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration: 

a. Certifications required, the original intent of these regulations was to display an 

aircraft’s airworthiness, certification, and registration documents so they would be 

easily available to inspectors and passengers. Based on the FAA Memorandum 

subject “Interpretation regarding whether certain required documents may be kept 

at an unmanned aircraft’s control station,” dated August 8, 2014, the requested 

relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary
Summary for the Federal Register: 

SkySnap LLC seeks an exemption from the following rules for the commercial operation of a 

small unmanned aerial system in endeavors such as, but not limited to: engineering, inspections, 

photogrammetry, photography, videography, agriculture, motion picture, television, etc., .: 14 

C.F.R Part 21, Subpart H; 14 C.F.R § 61.113; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 

C.F.R § 91.121; 14 C.F.R § 91.151; 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(1); 14 C.F.R § 

91.409(a)(2); 14 C.F.R § 91.417 (a) & (b); 14 C.F.R § 91.7; 14 C.F.R § 91.203 (a)&(b). The 

exemption will enhance safety by reducing risk to the operator, the general public and property 

owners from the substantial hazards associated with performing equivalent work using 

traditional aircraft and rotorcraft. SkySnap LLC requests that the FAA grant this petition using 

the "summary grant" process such that publication in the Federal Register is not required. This 

petition would not set a precedent, and any delay in acting on this petition would be detrimental 

to the petitioner.

Use of Petition outside of the United States:

Given the opportunity SkySnap LLC would like to use this exemption outside of the United 

States. If an opportunity presented itself for SkySnap LLC to work commercially outside of the 

United States doing any kind of aerial data collection, photography, or videography we would 

like to take full advantage of it. 

Thank you for your consideration,

Ivy Lampe

Owner

SkySnap LLC