Docket Operations, M-30 U.S. Department ofTransportation (DOT) 1200 NewJersey Avenue SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 October 1, 2015 

# Skylift Global Petition for Exemption

Dear Administrator: Skylift was builtto free mankind from the limitations ofa planarworld. Safe and reliable sUAS with revolutionary payload capacity have the powerto eliminate the waste of today'sflightless transportation solutions. We want mankind's dream offlightto be the solution to thefuture oftransportation. We share Congress's goal of using commercial drones to reduce costs, increase commerce and create a domestic industryworth tons upontons ofAmerican jobs. Utilizing our heavy-lifting sUAS designs, dependence on non-renewable fuel consumption, delivery time and logistics costs can be significantly reduced. With 10-28% oflogistics costs concentrated intothe last mile ofdelivery, this is a solution that small and large businesses have been anticipating. Potential for international export is equally exciting. In accordance with new expediting initiatives atthe FAA, we request consideration for exemption under the Modernization and Reform Act of2012, Section 333. We intend to use this authorization forthe development and testing ofour sUAS prototypes. The progress ofexperimentation and iteration has increased dramatically overthe past 6 months. We have achieved thefollowing milestones:

• Testing a range ofcapabilities for our aerial vehicle prototypes, including agility, flight duration, redundancy, autonomous transport and sense-andavoid algorithms;

• Autonomous software for autopilot using GPS and other sensors, increasing safetythrough driver assistance;

• Developed an aerial vehicle thattravels up to 100 miles per hour, and will carry 6-pound payloads, which coverthe majorityofCourier and Express Deliveries; and

• Attracting a growingteam ofworld-renowned roboticists, scientists, aeronautical engineers, remote sensing experts, and former NASA contractors.
1Skylift has developed our sUAS vehicles up until now as hobbyists, but since incorporating in July we wantto keep ourfocus, jobs and investment on continuing research in the United States and in compliance withthe regulations and goals ofthe Federal and local authorities. In orderto allow outdoor R&D testing, we are submittingthis petition for exemption pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 forthe rights totestthe following:

• Flight tests at preapproved locations with payloads upto 6 lbs., under55 lbs. maximum takeoffweight

• Autonomous softwaretesting with manual override abilityfor PIC, improving safetywith pilot aids

• Communications integration for reporting and navigation with NextGen and NTSB, as well as proprietary software and data links. Regarding the Unmanned Aircraft System
1. The proposed UAS will be piloted underthe approved conditions by a certified pilot, or software simulating certified pilots, in accordance with ourSafety Program and 14 CFR 91.3. The UAS will be piloted inside the boundaries ofan approved test site within the approved altitude and speed range. The UAS utilizes proprietaryfailsafe systems and emergency landingcapabilities to minimize the risk tothe NAS or persons and property on the ground. These systems include our patent pending low-latency avionics, autorotation rotor systems, redundant mechanical drivetrain systems and active independent yaw control to maintain directional stability. Additionally, the proposed UAS will utilize sensor and software safety systems for object detection and avoidance, as well as measuring and enforcing altitude restrictions, distance from point oforigin and other key metrics. GPS-based navigation system will be used to chart and maintain intended travel paths. Manual control override will be maintained at all times. Flight data will be recorded manually and digitally in a logbook fortest and R&D analysis. Testing operations will be conducted with respect to operational conditions and aircraft history. Incidents will be resolved in accordance with your Maintenance and Inspection Programs. Any incidence ofimpact oraccident will be reported tothe NTSB within 24 hours. 2. Before all flights, the safety ofenvironmental conditions and test site must be reviewed and documented. Pre-flight inspections will be conducted both manually and autonomously and recorded in the UAS logbook. Maintenance, repairs and inspections


### 2will be documented in the logbook. Condition ofthe UAS must be approved for safe flight before beginning any operation. 3. Control ofthe UAS will be facilitated manually by a certified pilot, acting as the PIC, through the use ofa two-way radio and in accordance with 14CFR 91.13. The two-way radio will be operated on the 2.4 Ghz and 72 MHz Radio Frequency (RF) bands in accordance with Federal Communications Commission (FCC) standards. A combination ofsoftware and sensors will be utilized to control the vehicle autonomously, maintaining manual control override, in compliance with 14CFR 91.111, 91.113 and 91.115. Regarding the Unmanned Aircraft PIC 1. Operation ofthe UAS will be limited to certified pilots acting as the PIC, who are directly responsible forthe aircraft and operational compliance. The PIC is familiar with all relevant regulatory guidelines, including but not limited to FAA and FCC guidelines. The PIC has also logged 25 hours with rotor-powered aerial vehicles and 10 hours in a multirotor aerial vehicle, including 5 hours oftesting with the proposed UAS. A Visual Observer (VO) will be present for both manual and autonomous flight tests and maintain visual line ofsight (VLOS). The VO must be a representative ofSkylift Global and be familiar with all relevant regulatory guidelines, including but not limited to FAA and FCC guidelines. The VO is responsible forthe documentation and accuracy of manual flight logs.
2. The PIC ofthe proposed UAS will have an active Third Class Medical Certification and be prepared to assist in the event ofan impact or incident. The PIC is familiar with FAA Office ofSecurity and Hazardous Materials Safety (ASH) standards and is prepared to report any events that may impactthe integrity ofthe National Airspace System (NAS). Regarding the Operation ofthe Unmanned Aircraft
1. The intended use ofthe proposed UAS is to develop autonomous flight controls under the guidelines ofthe FAA and other relevant regulatory bodies. We will conduct flights inside an operational border up to 400 AGL within 2 horizontal miles from the point of origin. The vehicle will nottravel over 150 mph in compliance with 14 CFR 91.117 and maintain a distance of2,000ft. from any clouds that could obscure visibility. UAS operation will respect a S-mile perimeterfrom any Airport Reference Point (ARP). Nonparticipating persons and propertywill need to be secured in a designated area at a safe distance from the operational area ofthe UAS before takeoffand during operation.


### 32. The proposed UAS will notoperate outside ofthe designated operational area, below 400 AGL and within 2 horizontal miles from the point oforigin. The UAS will respect a Smile perimeterfrom any Airport Reference Point {ARP) and maintain a distance of2,000 ft. from any clouds that could obscure visibility. In compliance with 14CFR 91.117, the UAS will not exceed speeds of 100 mph. The vehicle will nottravel outside the VLOS of the VO. The UAS will maintain 5 horizontal miles and 1,000vertical ft. ofseparation from other aircraft. The PIC will be responsible for correcting any deviation or inevitable deviation from these operating restrictions manually. 3. The operational area ofthe vehicle will be a designated airfield, checked for safety clearance and permission to fly underthe conditions laid out in the guidelines ofthe FAA. Testing will not involve flight over populated areas or restricted airspace. 4. Aircraft will not be operated within 5 miles ofany airports in accordance with the statutory mandate underSection 333 regarding proximityto airports.
5. The UAS will operate within visual line-of-sight {VLOS), in accordance with the statutory mandate underSection 333{b){1). The operational area will be restricted to 400 AGL and a 2 mi horizontal radius from the point oforigin, maintaining constant VLOS with the visual observer {VO). 6. Preflight safety risk assessments will be used to determinethatthe UAS is in a condition safe forflight in accordance with 14CFR 91.7. Preflight inspections will be conducted manually and autonomously in a safe area outside ofthe operational area ofother aircraft.
7. Software and communications testing is a primary objective forthe proposed UAS. We request the abilityto test integration with FAA NextGen and NTSB systems like ADS-B and the CPDLC ADS-C systems, as well as proprietary and third party data communications links tothe aircraft. We would like to coordinate as much as possible with the FSDO in this regard.

Exemption for Skyliftto allow R&D testing in the United States is in the public interest because it advances the need forsafer, more reliable sUAS with safety measures like mechanical redundancy and autorotation and NextGen integration. It is a necessary step towards realizingthe consumer benefits ofheavy-lifting sUAS transport and continuing innovation in this valuable domestic industry. We can achieve this with approval for outdoor testing.One day, dronetransportation will be as common as seeing deliverytrucks on the road today, resulting in enormous logistical efficiencies across the nation. We respectfully
4submit this petition for exemption so that we may worktowards the launch ofcommercial operations as soon as we are able to meetthe necessary requirements through the proper channels.

Information Supportingthis Petition as Specified in 14C.F.R. §11.81 

### (a} Mailing addressandothercontactinformation such asafaxnumber, telephone number, ore-mailaddress

Skylift Global, Inc. Compliance Department Re: Skylift Exemption Petition 722 Via Cafetal San Marcos, CA 92069 Fax:844-475-9543 Email: jesse@skyliftglobal.com


### (b) The specificsection orsections of 14C.F.R.from whichSky/iftseeksanexemption

• 14 C.F.R. 

### § 21.191(a)- 

### Experimental Certificates

• 14 C.F.R. § 45.23(b)- Display 

### of marks; general

• 14 C.F.R. § 91.9(b)- 

### Civil aircraft flight manual, marking, andplacardrequirements

• 14 C.F.R. § 91.203(a) and (b)- 

### CivilAircraft: Certifications Required

• Public Law 112-95-

### FAA Modernization andReformActof 2012

• 14 C.F.R. § 61- Certification: Pilots, Flight Instructors, and Ground Instructors

We believe an exemption from the regulations noted above will be sufficient to conduct the R&D described in this exemption request. To the extentthat FAA may deem it necessary, however, we also request an exemption from any regulations ancillary to the foregoing that may be needed to facilitate the desired operations.

Given the nature ofthe specific relief sought bythis exemption request under 14 C.F.R. 

### §§ 21.191(a), 45.23(b), 91.9(b) and 91.203(a) and (b), and the particular contours of our desired testing operations and proposed safeguards, a request for relieffrom any 

### 5associated or implementing requirements ofseveral related provisions that may otherwise be applicable, such as 14C.F.R. 

### §§ 91.7(a) (civil aircraft airworthiness); 91.103(b) (pre-flight action); 91.109 (flight instruction); 91.119 (minimum safe altitudes); 91.121 (altimeter settings); 91.151(a) (fuel requirements in VFR conditions); 91.405(a) (maintenance required); 91.407(a)(1) (operation after maintenance, preventive maintenance, rebuilding, or alteration); 91.409(a)(2) (inspections); and 91.417(a) and (b) (maintenance records), should either be unnecessary as mootor deemed incorporated herein. Nevertheless, we seek an exemption from any such specific provisionstothe extent FAA finds it necessary to grantthis request. 

### (c) The extentof relief Sky/1ftseeks, andthereasonSkyliftseeks the relief
We seek an exemption from several interrelated provisions of 14C.F.R. Parts 21, 45 and 91 tothe extent necessary to engage in private, non-commercial R&D operations ofsUAS on designated propertythat would otherwise be expressly permitted ifconducted by a hobbyist or a manufacturer producing such sUAS. (Pub. 

### L. No. 112-95, 

### § 336, 126 Stat. 77-78) We have detailed, below, a significant set ofsafeguards that will applytothese R&D operations. Operations underthese safeguards will provide for a level ofsafety exceeding the level ofsafety required ofsimilar sUAS operationsthat FAA authorizes currently and without requiring compliance with the regulations from which we seek an exemption. Moreover, our operations will not "create a hazard to users ofthe National Airspace System orthe public or pose athreatto national security'' (§ 333, 126 Stat. 76) and are thus consistent with the congressional mandate in Section 333 ofthe FAA Modernization and Reform Act of2012, which gives FAA a mechanism to allow certain sUAS to operate safely in the National Airspace System. We also intend to use FAA-selected test sites and seek a special airworthiness certificate (experimental category) for our sUAS. However, itwould be impractical for Skylift to pursue eitherone ofthese avenues as our sole or even primary method of R&D testing at thistime, and doing so would unnecessarilytax scarce FAA resources. For example, itwould be an unreasonable burden on both the FAA and Skylift ifwe were required to applyfor a special airworthiness certificate for every sUAS design ortesting configuration while we are in R&D and conducting rapid prototyping. 

### (d) The reasons whygrantingSkylift's requestwouldbein thepublicinterest; thatis, howitwouldbenefitthepublicasa whole
As described above, Skylift aims to significantly reduce the cost, fuel consumption, reliability and safety issues ofcurrent transportation solutions. Please see the introduction for details on howgrantingthis request would benefitthe public.



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### (e) The reasons whygranting theexemption wouldnotadverselyaffectsafety, orhow theexemption wouldprovidea levelof safetyatleastequalto thatprovidedbythe rulefrom which Skyliftseeks the exemption
Our R&D operations will provide for a level ofsafety that far exceeds the level ofsafety required by FAA for hobbyists and manufacturers of model aircraft. Because Skylift's desired testing operations could not possibly be conducted using conventional aircraft, the level of safety required ofhobbyists and manufacturers of model aircraft is the appropriate comparison. The following operating procedures will apply duringthe R&D testing conducted underthis exemption request:

• The sUAS without its payload will (i) have a maximum weight ofless than 55 pounds; (ii) be rotor- powered via a battery source; and 

### (iii) be U.S.-registered and display marks in accordance with 14 C.F.R. Part 45, Subpart C. To the extentthat FAA determines thatthe Skylift sUAS operating underthis exemption must bear an "experimental" marking, we seek an exemption from 14 C.F.R. § 45.23(b) to accommodate the required markings pursuant to 14 C.F.R. § 45.29(f).

• Our sUAS R&D testing underthis exemption will be conducted (i) at less than 400 feet AGL; and (ii) within predefined airspace.

• The operations will be conducted in a confined area over preapproved property located a sufficient distance away from (i) any airport, heliport, seaplane base, spaceport or other location with aviation activities; (ii) any densely populated areas; and 

### (iii} any military or U.S. government installations or airfields. We will apply separatelyforthe necessary certificates ofwaiver from the requirements of 14 C.F.R. §§ 91.113 and 91.119 and the associated airspace authorization. Specific details ofthe operating area, including latitude and longitude, and aeronautical charts and/or photographs, will be provided upon request.

• All operations will remain within the lateral and vertical boundaries ofthe operating area, taking into account all factors, including wind, gross weight and glide distances, that may affect the capability ofthe sUAS to remain within the airspace boundary; moreover, the integrityofthe operating area will be reinforced by software geo-fencing, includingthe ceiling height of no more than 400 feet AGL. Geo-fencing is a feature in a software program that uses GPS or radio frequencytriangulation to define geographical boundaries. A geo-fence is avirtual barrier- effectively an electronic box in which the sUAS will be confined.

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### • Our sUAS R&D testing underthis exemption will be conducted (i) under the supervision ofa designated pilot in command (PIC) who has final responsibility for the operation in accordance with 14 C.F.R. § 

### 91.3 or autonomous software where a PIC will maintain final responsibility with manual override capability and either (A) holds a current FAA private pilot certificate issued under 14 C.F.R. Part 61, Subpart E, a higher FAA pilot certification, or a FAA-recognized equivalentor (B) has completed FAA private pilot ground instruction and passed the FAA private pilot written examination or FAA-recognized equivalent; and (ii) using only operators that have completed training on the normal, abnormal, and emergency procedures in specific details and demonstrated proficiency with the sUAS being operated. A private pilot certificate should be sufficient forthe PIC to conduct these research and development sUAS flights. (14 C.F.R. § 

### 61.113(b))

• No operator or observer will engage 

### in, nor may an operator or observer permit, any activity during a critical phase offlight which could distract any operator or observer from the performance of his/her duties or interfere in any way with the proper conduct ofhis/her duties.

• Operators will maintain the sUAS system in a condition for safe operation, and conduct a pre-flight inspection priorto each flight so as to ensure that the sUAS, control station, data link equipment, payload, and support equipment are in a condition for safe operation and in a configuration appropriate for the purpose ofthe intended flight.

• The operators and observers will maintain two-way communications with each other during all operations; if unable to maintain two-way communications, or ifany condition occurs that may otherwise cause the operation to be unsafe, the operatorwill immediately conclude the operation.

• Each sUAS will safely stop operating and return automaticallyto a specific location on Amazon's private property ifthe communications link is lost.

• For each sUAS, the observer will have the ability to press a physical button, that will be within his/her reach at all times, that reduces powertothe vehicle so as to force a controlled landing; both the hardware and communication for this safety system will be physically separate from the sUAS flight control systems.

• Testing operations will be conducted on designated property, and only Skylift employees, contract personnel, and invitees will be invited tothe operations area; security measures will be put in place to deter unauthorized access.


### 8• The aircraft documentation required by 14C.F.R. §§ 91.9 and 91.203(b), as applicable, will be available tothe PIC referred to above at any time Skylift's sUAS are operating. We will continue to operate ourtest flights with additional safeguards that go far beyond those thatthe FAA requires. The combination of manual override and tightly defined operating area with geofencing on preapproved testing grounds will allowfor an uncompromised safe testing environment. 

## UJ A summaryFAA can publish in the FEDERAL REGISTER, stating: (1} The rulefrom which you seekthe exemption; and(2} A briefdescription ofthe nature ofthe exemption youseek


### Petitioner: Skylift Global, Inc. 

### Sections of 14 C.F.R. Affected:§§ 21.191(a); 45.23(b); 91.9(b); and 91.203(a) and (b) 

### Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F.R. §§ 21.191(a); 45.23(b); 91.9(b}; and 91.203(a} and (b) to conduct private, non-commercial small unmanned aircraft systems (sUAS) operations on designated property subject to operating procedures that meet or exceed those that FAA requires for similar operations. (g) Anyadditionalinformation, views orarguments available to supportyourrequest Please see the introduction tothis exemption request. (h) If you want to exercise theprivileges of yourexemption outside ofthe United States, the reason whyyou need to do so. The research and development operations described in this exemption request will be conducted whollywithin the United States.

Please do not hesitate to contact me via email at**~se.Ql_oore@sl~y!Jft__gl_ob_~_com** if you have any questions or concerns.
Respectfully submitted,
Jesse Moore Treasurer Skylift Global, Inc.



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