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, Sky Snap 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 limi ted to: engineering, inspections, photogrammetry, photography, videography, agriculture , motion picture, television, etc. Sky Snap LLC is seeking exemption because of a want to create a successful commercial business with the use of UAS while working co

- operativel y with the FAA to keep air space safe for the public. Sky Snap LLC plans to benefit the public as a whole b y offering services and opportunity

for business owners, real estate agents, farmers, adventurers, and any others who seek aerial documentation. Sky Snap LLC plans t o offer these individuals the opportunity to take advantage of the technology tha t now exists in the form of UAS , and allow them to do so using an experienced UAS Pilot who understands how to safel y operate such technology. Sky SnapLLC also believes in the overall reduction of risk to individuals who would otherwise have to

phy sicall y leave terra firma (i.e. high ro ofing inspections , search and rescue in a standard air craft , etc. ) b y allowing unmanned aircraft to gather the data while their human controller stays safel y on the ground and out of harm’s way. Sky Snap LLC understand these UAS are the technology of the future and want s to work with in the FAA codes and regulations to keep this budding technology thriving in a safe manner in regards to the public. Sky Snap LLC is a highl y educated compan y focused on safety, hiring only the best pilots with pervious UAS tra ining , and adhering strictl y to the regulations. Sky Snap LLC has bi

- monthl y 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) DJIPhantom 3 Advanced

- Using 2.400 GHz

- 2.483 GHz Operating Frequency 2) DJIPhantom 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 b y Sky Snap 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 procedure s prior to launch will include the manufacturer recommended preflight checklist (See below) as well as a Sky Snap LLC preflight checklist of the vehicle and a visual inspection of landing area

 Flight operations will be conducted b y a two

- person team consisting of the PI C 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 communic ation.

 Sky Snap 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 an y structures, people or vehicles.

 Aircraft will comply

with maintenanc e and inspection requirements of the manufacturer. All repair and maintenance work will be conducted or approved b y qualified personnel, and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenanc e log for each aircraft. All flight operations will be conducted in accordance with vali d Certificates of

Authorization.

 All UAS will have automated recall s ys tems 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 alway s be with in line of site of the visual observer and PIC. This is human vision unaided by

an y devices

 Kiel Lampe is Sky Snap LLC’s head PIC. He is a highl y educated well trained UAS operator who brings detail oriented safety practices to any and all UAS flights. He sets the standard for Sky Snap LLC’s safe fl yi ng practices. Any PI C for SkyS nap LLC will hold a minimum of a Recreational/Sport Pi lot license with all of the associated flight hours and knowledge. All PI C will undergo Sky Snap LL C’s training program requiring a minimum of 10 hours of supervised flight with the UAS to the safety standards set by Kiel Lampe , Sky Sn ap LLC ‘s head PI C

. If the potential PI C does not show a satisfactory level of safety

and proficiency

with the UAS they

will be required to complete additional hours until suc h time they can act as they

pass the requirements set forth by Kiel Lampe. All PI C will hold at least class or obtain a U.S. driver’s license in conjunction with their pi lot’ s license.

 All visual observers will act as support for the PI C. They will undergo SkySnap LLC’s training program. Including instruction from trained Sky Snap LLC p ilots , training in the regulations set forth b y the FAA to assist the PI C in maintaining safe fl yi ng 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 observ er ’ s roll to ‘keep eyes on the sky ’ watching the UAS and for an y hazards the UAS could encounter and maintain verbal communication with the PI C.

 Any operations requiring no tification 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 Sky Snap LLC’s operations.



### Manufacturer Recommended **Preflight Check list:**  1) Remote controller, Intelligent Flight Battery , and mobile device are full y charged 2) Propellers are mounted correctl y 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 DJ I Pilot app is successfully connected to aircraft.

### Sk

**ySnap 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 doc umentation 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 b y Sky Snap have an automatic hover safety feature . The hover feature tests the compass and GPS sy stems. If the UAS hovers without ‘drift’ up, down, or side to side will confirm all systems are working properly and is safe to fl y. An y ‘drift’ or other problems present themsel ves 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 PL112

- 9 5 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 S ection 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. Sky Snap 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. Sky Snap L LC’ 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 PI C. In the Grant of Exemption in FAA Docket No. FAA 2014

- 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 PI C 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. Sky Snap LLC’s UAS do not offer the capability of a second set of controls and asks for exemption from this section. Sky Snap 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. 20 21. Sky Snap LLC also seeks exemption from this section for similar operations. **6) 14 C.F.R. § 91.121: Altimeter Settings:**  a. Sky Snap LLC seeks e xemp tion form this section as our UAS do not use altimeter s. 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

. Sky Snap 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. Sky Snap 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. S ee, e.g., 14 C.F.R. § 91.405(a). An exemption from these regulations is needed because Part 43 and these secti ons only appl y to aircraft with an airworthiness certificate, which the UAS proposed here will not have. Sky Snap LLC proposes to have all UAS maintenance and inspections preformed in accordance with the m anuals. This includes maintenance, overhaul, replace ment, 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 Sky Snap LLC seeks exemption from this section. Sky Snap LLC will have supplemental in

- house and manufacturer inspections verifyingthe UAS ’s mechanical and electrical sy stems 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 Registrati**  **on :**  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 Regis **ter:**

Sky Snap 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 , photograph y, videograph y, 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 b y reducing risk to the operator, the general public and property owners from the substantial hazards associated with performing equivalent work using traditional aircr aft and rotorcraft. Sky Snap 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 wou ld be detrimental to the petitioner

.



### Use of Petition outside of the United States: Given the opportunity

Sky Snap LLC would like to use this exemption outside of the United States. I f an opportunity presented itself for Sky Snap LL C to work commercially outside of the United States doing an y kind of aerial data collection, photograph y, or videograph y we would like to take full advantage of it.

T hank you for your consideration, Iv y Lampe Owner Sky Snap LLC