Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey 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 built to free mankind from the limitations of a planar world. Safe and 

reliable sUAS with revolutionary payload capacity have the power to eliminate the waste of 

today' s flightless transportation solutions. We want mankind's dream of flight to be the 

solution to the future of transportation. 

We share Congress's goal of using commercial drones to reduce costs, increase 

commerce and create a domestic industry worth tons upon tons of American 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% of logistics costs 

concentrated into the last mile of delivery, 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 at the FAA, we request consideration for 

exemption under the Modernization and Reform Act of 2012, Section 333. We intend to use this 

authorization for the development and testing of our sUAS prototypes. 

The progress of experimentation and iteration has increased dramatically over the 

past 6 months. We have achieved the following milestones: 

• Testing a range of capabilities 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 

safety through driver assistance; 

• Developed an aerial vehicle that travels up to 100 miles per hour, and will 

carry 6-pound payloads, which cover the majority of Courier and Express 

Deliveries; and 

• Attracting a growing team of world-renowned roboticists, scientists, 

aeronautical engineers, remote sensing experts, and former NASA contractors. 

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Skylift has developed our sUAS vehicles up until now as hobbyists, but since 

incorporating in July we want to keep our focus, jobs and investment on continuing research 

in the United States and in compliance with the regulations and goals of the Federal and local 

authorities. In order to allow outdoor R&D testing, we are submitting this petition for 

exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 for the 

rights to test the following: 

• Flight tests at preapproved locations with payloads up to 6 lbs., under 55 lbs. 

maximum takeoff weight 

• Autonomous software testing with manual override ability for PIC, improving 

safety with 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 under the approved conditions by a certified pilot, or 

software simulating certified pilots, in accordance with our Safety Program and 14 CFR 

91.3. The UAS will be piloted inside the boundaries of an approved test site within the 

approved altitude and speed range. The UAS utilizes proprietary failsafe systems and 

emergency landing capabilities to minimize the risk to the 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 of origin 

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 for test 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 of impact or accident will be reported to the NTSB within 24 

hours. 

2. Before all flights, the safety of environmental 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 

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will be documented in the logbook. Condition of the UAS must be approved for safe 

flight before beginning any operation. 

3. Control of the UAS will be facilitated manually by a certified pilot, acting as the PIC, 

through the use of a two-way radio and in accordance with 14 CFR 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 

of software and sensors will be utilized to control the vehicle autonomously, 

maintaining manual control override, in compliance with 14 CFR 91.111, 91.113 and 

91.115. 

Regarding the Unmanned Aircraft PIC 

1. Operation of the UAS will be limited to certified pilots acting as the PIC, who are directly 

responsible for the 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 of testing with the proposed UAS. A Visual 

Observer (VO) will be present for both manual and autonomous flight tests and 

maintain visual line of sight (VLOS). The VO must be a representative of Skylift Global 

and be familiar with all relevant regulatory guidelines, including but not limited to FAA 

and FCC guidelines. The VO is responsible for the documentation and accuracy of 

manual flight logs. 

2. The PIC of the proposed UAS will have an active Third Class Medical Certification and be 

prepared to assist in the event of an impact or incident. The PIC is familiar with FAA 

Office of Security and Hazardous Materials Safety (ASH) standards and is prepared to 

report any events that may impact the integrity of the National Airspace System (NAS). 

Regarding the Operation of the Unmanned Aircraft 

1. The intended use of the proposed UAS is to develop autonomous flight controls under 

the guidelines of the 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 not travel over 150 mph in compliance with 14 CFR 91.117 and 

maintain a distance of 2,000 ft. from any clouds that could obscure visibility. UAS 

operation will respect a S-mile perimeter from any Airport Reference Point (ARP). Nonparticipating persons and property will need to be secured in a designated area at a safe 

distance from the operational area of the UAS before takeoff and during operation. 

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2. The proposed UAS will not operate outside of the designated operational area, below 

400 AGL and within 2 horizontal miles from the point of origin. The UAS will respect a Smile perimeter from any Airport Reference Point {ARP) and maintain a distance of 2,000 

ft. from any clouds that could obscure visibility. In compliance with 14 CFR 91.117, the 

UAS will not exceed speeds of 100 mph. The vehicle will not travel outside the VLOS of 

the VO. The UAS will maintain 5 horizontal miles and 1,000 vertical ft. of separation 

from other aircraft. The PIC will be responsible for correcting any deviation or inevitable 

deviation from these operating restrictions manually. 

3. The operational area of the vehicle will be a designated airfield, checked for safety 

clearance and permission to fly under the conditions laid out in the guidelines of the 

FAA. Testing will not involve flight over populated areas or restricted airspace. 

4. Aircraft will not be operated within 5 miles of any airports in accordance with the 

statutory mandate under Section 333 regarding proximity to airports. 

5. The UAS will operate within visual line-of-sight {VLOS), in accordance with the statutory 

mandate under Section 333{b){1). The operational area will be restricted to 400 AGL and 

a 2 mi horizontal radius from the point of origin, maintaining constant VLOS with the 

visual observer {VO). 

6. Preflight safety risk assessments will be used to determine that the UAS is in a condition 

safe for flight in accordance with 14 CFR 91.7. Preflight inspections will be conducted 

manually and autonomously in a safe area outside of the operational area of other 

aircraft. 

7. Software and communications testing is a primary objective for the proposed UAS. We 

request the ability to 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 to the aircraft. We would like to coordinate as much as possible 

with the FSDO in this regard. 

Exemption for Skylift to allow R&D testing in the United States is in the public interest 

because it advances the need for safer, more reliable sUAS with safety measures like 

mechanical redundancy and autorotation and NextGen integration. It is a necessary step 

towards realizing the consumer benefits of heavy-lifting sUAS transport and continuing 

innovation in this valuable domestic industry. We can achieve this with approval for outdoor 

testing. 

One day, drone transportation will be as common as seeing delivery trucks on the 

road today, resulting in enormous logistical efficiencies across the nation. We respectfully 

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submit this petition for exemption so that we may work towards the launch of commercial 

operations as soon as we are able to meet the necessary requirements through the proper 

channels. 

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

(a} Mailing address and other contact information such as a fax number, telephone 

number, or e-mail address 

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 specific section or sections of 14 C.F.R. from which Sky/ift seeks an exemption 

• 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, and placard requirements 

• 14 C.F.R. § 91.203(a) and (b)- Civil Aircraft: Certifications Required 

• Public Law 112-95- FAA Modernization and Reform Act of 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 extent that 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 of the specific relief sought by this 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 relief from any 

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associated or implementing requirements of several related provisions that may otherwise 

be applicable, such as 14 C.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 moot or deemed incorporated herein. Nevertheless, we seek an 

exemption from any such specific provisions to the extent FAA finds it necessary to grant this 

request. 

(c) The extent of relief Sky/1ft seeks, and the reason Skylift seeks the relief 

We seek an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 

and 91 to the extent necessary to engage in private, non-commercial R&D operations of sUAS 

on designated property that would otherwise be expressly permitted if conducted 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 of safeguards that will apply to these R&D 

operations. Operations under these safeguards will provide for a level of safety exceeding the 

level of safety required of similar sUAS operations that 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 of the National Airspace System or the public or 

pose a threat to national security'' (§ 333, 126 Stat. 76) and are thus consistent with the 

congressional mandate in Section 333 of the FAA Modernization and Reform Act of 2012, 

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, it would be impractical for Skylift 

to pursue either one of these avenues as our sole or even primary method of R&D testing at 

this time, and doing so would unnecessarily tax scarce FAA resources. For example, it would 

be an unreasonable burden on both the FAA and Skylift if we were required to apply for a 

special airworthiness certificate for every sUAS design or testing configuration while we are 

in R&D and conducting rapid prototyping. 

(d) The reasons why granting Skylift's request would be in the public interest; that is, 

how it would benefit the public as a whole 

As described above, Skylift aims to significantly reduce the cost, fuel consumption, 

reliability and safety issues of current transportation solutions. Please see the introduction 

for details on how granting this request would benefit the public. 

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(e) The reasons why granting the exemption would not adversely affect safety, or how 

the exemption would provide a level of safety at least equal to that provided by the 

rule from which Skylift seeks the exemption 

Our R&D operations will provide for a level of safety that far exceeds the level of safety 

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 of hobbyists and manufacturers of model aircraft is the appropriate 

comparison. 

The following operating procedures will apply during the R&D testing conducted 

under this exemption request: 

• The sUAS without its payload will (i) have a maximum weight of less 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 

extent that FAA determines that the Skylift sUAS operating under this 

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 under this 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 separately for the necessary certificates of waiver 

from the requirements of 14 C.F.R. §§ 91.113 and 91.119 and the associated 

airspace authorization. Specific details of the 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 of the 

operating area, taking into account all factors, including wind, gross weight 

and glide distances, that may affect the capability of the sUAS to remain 

within the airspace boundary; moreover, the integrity of the operating area 

will be reinforced by software geo-fencing, including the ceiling height of no 

more than 400 feet AGL. Geo-fencing is a feature in a software program that 

uses GPS or radio frequency triangulation to define geographical boundaries. 

A geo-fence is a virtual barrier- effectively an electronic box in which the 

sUAS will be confined. 

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• Our sUAS R&D testing under this exemption will be conducted (i) under the 

supervision of a 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 

equivalent or (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 for the 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 of flight which could distract any 

operator or observer from the performance of his/her duties or interfere in 

any way with the proper conduct of his/her duties. 

• Operators will maintain the sUAS system in a condition for safe operation, and 

conduct a pre-flight inspection prior to 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 of the 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 

if any condition occurs that may otherwise cause the operation to be unsafe, 

the operator will immediately conclude the operation. 

• Each sUAS will safely stop operating and return automatically to a specific 

location on Amazon's private property if the 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 power to the 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 to the operations 

area; security measures will be put in place to deter unauthorized access. 

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• The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as 

applicable, will be available to the PIC referred to above at any time Skylift's 

sUAS are operating. 

We will continue to operate our test flights with additional safeguards that go far beyond 

those that the FAA requires. The combination of manual override and tightly defined 

operating area with geofencing on preapproved testing grounds will allow for an 

uncompromised safe testing environment. 

UJ A summary FAA can publish in the FEDERAL REGISTER, stating: (1} The rule from 

which you seek the exemption; and (2} A brief description of the nature of the 

exemption you seek 

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 relief from 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) Any additional information, views or arguments available to support your request 

Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United 

States, the reason why you need to do so. 

The research and development operations described in this exemption request will be 

conducted wholly within 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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