### U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590

SKYCHASE DESIGNS LLC PETITION FOR EXEMPTION TO OPERATE UNMANNEDAIRCRAFT SYSTEMS PURSUANTTO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Proposed Use:

Aerial video and photographyforthe purpose ofcreating content for:

Heal estate photography Aerial cinematography and photographyfor personal and business Construction site inspection and monitoring Corporate and business promotional videos and stills Aerial video and photography of business and private events Property mapping and survey, boundary discovery services. Search and Rescue contract orVolunteer Work Conservation and wildlife photography Tour orvacation videography capturefor personal or business purposes.



### Proposed Aircraft: DJI Inspire 1, 3DR Solo

Petitioner's Name and Address:
Skychase Designs, LLC Matthew Michael Chase 229 Cedar Mill Lane Woodstock, Georgia 30189 Phone: 770.364.2240 Email: matthewmchase@gmail.com

On or aboutAugust 15, 2015 the FAA granted exemptionsto over 700 hundred UAS operators. It is in good faith thatthis exemption request will follow the
same outline ofthe exemptions granted forthe same general intents and purposes to commercially operate UASs.1. The specific section orsections of 14 CFR from which SkyChaseDesigns LLC seekan exemption;

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 Page 3 14 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401- 91.417)

2. The extent of reliefyou seekand the reason SkyChase Designs LLC seekthe relief;

Pursuant to Section 333(a) through (c) ("Section 333") ofthe FAA Modernization and Reform Act of2012 ("Reform Act 11)1 and the Federal Aviation Administrations' ("FAA") general exemption authority under49 U.S.C. §44701

### (f), SkyChase Designs LLC ("Petitioner") petitions for exemption from 14 Code of Federal Regulations ("CFR") sections: The proposed exemptions, if granted, would allow Petitionerto operate small unmanned aircraft systems

### C 1UAS 11 ) weighing 55 pounds or less forthe purpose ofcreating content for: real estate photography, aerial cinematography and photographyfor personal and business, construction site inspection and monitoring,corporate and business promotional videos and stills, aerial video and photography of business and private events,property mapping and survey, boundary discovery services, search and rescue contract orvolunteer work, conservation and wildlife photography, tour orvacation videography capture for personal or business purposes.
SkyChase Designs LLC will seekto operatefor commercial purposestwo UAS a DJI Inspire 1 and 3DR Solo

A pre-flight inspection will be performed bythe PIC in accordancewith the factory instruction manual and additionally SkyChase Designs LLC requiredprocedures, checklist and internal flight plan will be executed, as well as redundant checks to includethe Internal Measurement Unit (IMU) to make sure thatthe compass, gyro and acceleration values are within specs, positive GPS locks are secure, battery health and charge status, and communication from ground station to UAS are within acceptable parameters for safe flight.

A Safety Briefing will be administered by the PIC to all participants in and around the proposed flight. All consenting persons and flight crew within the flight plan vicinity will be made aware ofthe flight and associated safety standards and procedures as well as proper action in the case ofan UAS emergency, which may result in harm tothe UAS itself, property or persons.

Based on the diminutive size of Petitioner's UAS (DJIInspire 1 and 3DR Solo which are well under 55 pounds including payload of batteries and all cinematography attached equipment needed for flight. The qualifications and experience of Petitioner's UAS operators, the requested exemptions fall squarely within the zone ofsafety envisioned by Congress and set forth in Section 333. Additionally, the enhanced safety achieved by replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers orcrew and operated underthespecific guidelines and procedures proposed by Petitioner givesthe FAA good cause to find thatthe UAS operations enabled bythis petition are in the public interest.
SkyChase Designs LLC requests an exemption from the following regulations.

14 CFR Part21, Airworthiness Certificates

This part establishes the procedures forthe issuance of an airworthiness certificate. While the FAA continues to workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe DJI Inspire 1 and 3DR Solo under either or both ofthefollowing provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques,
or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliancefor issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such asmarket surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will onlyfly understrict operational requirements. Combined with the UAS 1S light weight, being constructed primarily of carbon fiber and plastic, we proposethat the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.

14 CFR45.23 Displayofmarks;generaland45.29Size ofmarks.

These regulations providethat each aircraft must display 11N 11 and the aircraft 1S registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word 11EXPERIMENTAL 11 in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS does not have an entrance in which the word 11EXPERIMENTAL 11 can be placed, and may not have
a registration number assigned to it bythe FAA. We proposeto achieve an equivalent level ofsafety by including the word 11EXPERIMENTAL11 in the placard
on the top ofthe aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in thevicinity ofthe aircraft while it is preparing for launch will be ableto see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will providethe aircraftls registration information at the ground station. Finally, we will display at the ground station a high contrast flag or bannerthat contains the words**~~unmanned** Aircraft Ground Station II in letters 3 inches high orgreater. Sincethe aircraft will operate within 0.263 NM ofthe ground station, the banner should be visible to anyonethat observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Privatepilotprivilegesandlimitations: Pilotin Commandand61.133 Commercialpilotprivilegesandlimitations.

The regulation providesthat no person that holds a Private Pilot certificate may act as pilot in Command ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate with a Class Ill Medical issued by the FAA and since the aircraft cannot carry passengers or property, we feel wemeet the intent of61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.

14 CFR 91.7Prohibits the Operation ofan aircraft withoutan airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civilaircraftflightmanual, marking, andplacardrequirements.

This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assumethat the intent ofthis requirement is to ensure that flight manual information is availableto the aircrew while operating the aircraft. We request an exemption tothis requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available tothe crew during flight operations. To obtain an equivalent level ofsafety and meetthe intent of91.9, we proposethat a current, approved UAS Flight Manual must be availableto the crew at the ground station anytimethe aircraft is in, or preparing for, flight, and ready for presentation for any governing official upon request.

14 CFR 91.109 FlightInstruction; Simulatedinstrumentflightandcertain flight tests

The regulation states that IINo person may operate a civil aircraft that is being used forflight instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 is capable ofduel/linked controls, SkyChase Designs LLC will be operating with a single remote controller, a second remote can in
some instances be used by a non PIC too control the aerial camera only. This second remote does not affect or interfere with PIC primary responsibility ofsafe operation of UAS while maintaining line ofsite at all times via directview of UAS of PIC or real time position reporting by authorized and trained spotters in the
rare cases that directview of UAS is impeded.

14 CFR 91.119 Minimum safealtitudes:

General. The regulation statesthat over sparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person, vessel, vehicle, or structure. Sincethe typical mission ofthe UAS would be photography or survey of persons, vessels, vehicles orstructures it would be necessaryto operate closerthan 500 feet tothe items listed. Operations will only be flown over property or persons where permission has been obtained and careful preplanned flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without unduehazard to persons or property on the surface. Therefore we maintain that dueto the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimetersettings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimetersetting available within 100 NM ofthe aircraft. The UAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement abovethetakeoff point is transmitted via radio from the UAS onboard computerto the display screen held bythe PIC, providing a constantly updated AGL readout. Both UAS have manufacture imposed limiters that will not allow eitherthe OJI Inspire 1 or3DR Solo to operate above 400 feet AGL.

14 CFR 91.151 Fuelrequirements forflightin VFR conditions.

The regulation providesthat no person may begin aflight in an airplane under day-VFR conditions unlessthere is enough fuel to fly tothefirst point of intended landing and to fly afterthat for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing. The UAV is battery operated and the maximum duration of flight from a single battery charge is 18 minuteswith a 20% reserve. Sincethe aircraft will neverfly morethan 0.263 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption tothe word "fuel" and askfor an equivalent interpretation with theword "energy".

14 CFR 91.203(a) & (b) Civilaircraft: Certifications required.

The regulation providesthat an airworthiness certificate, with the registration number assigned tothe aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) providesthat the airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legibleto passengers or crew." At a maximum gross weight of6.47 pounds, the UAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meet the intent of 91.203, we proposethat documents deemed appropriate forthis aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In orderto identifythe aircraft, we proposethat the information found on airworthiness and registration certificates be permanentlyaffixed tothe aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfythe requirement of 14 CFR 45.23.

14 CFR SubpartE (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation providesthatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. It is our intention thatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approvethe aircraft for return to service." The PIC will
ensure that the aircraft is in an airworthy condition priorto every flight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing
a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repair facility. The PIC will documentwork performed in accordance with 91 .417. We feel that duetothe size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.

3. How SkyChase Designs LLC requestwould benefitthe public as a whole;

The request forthis exemption is in the Public Interest as it is safe to assume thatthere are many consumer applications forthe services that can be provided by UAS systems. It is clearthat the Congress ofthe United States, the business sector, and the consumerwant to integrate Unmanned Aircraft Systems into the National Airspace System and utilizetheir unique and cost effective capabilities. It is also in the Public Interestthat many ofthe low level flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant unmanned aircraftthat can operate at a fraction ofthe costto both the operator and consumer. These aircraft can be operated without risk of loss of life
or limb, without significant financial impactto the operatoror any person or property on the ground in the event ofthe loss ofan aircraft. Finallythe petitioner believes that granting this exemption would help to further by Administrators process of integration of UAS systems and possibility helpto create additional regulations and guidanceto be used as these systems become
more widely utilized.4. Reasons whythe exemption would not adversely affect safety, or how the exemption would provide a level of safetyat least equal to the existing rule;
Safety and Benefits ofthe exemption for UAS employed by SkyChase Designs LLC.
SkyChase Designs LLC will be using the UAS in avariety ofapplications that generally require expensive full-size manned aircraftto complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefits overthe use of full-sized manned aircraft for aerial photography. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafetyforthe pilots and
crew. By granting SkyChase Designs LLC's requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operations. In the event ofan emergency dueto the diminutive size ofthe UAS being used and lack of flammable fuel sources being employed, the safety of participants or non participating bystanders is greatly reduced.

Local community businesses will have access to aerial marketing contentto promote and expand their business otherwise not available or achievable dueto the cost ofgaining similar marketing content and services via manned aircraft, this content acquisition previously was reserved for larger corporationsthat could afford to acquirethis content at a much higher costvia manned aircraft. The result of SkyChase Designs LLC exemption being granted is that local business will be able to expand and improve via more efficient delivery oftheir associated services and or products; this will impactthe local economythey operate due to increased tax revenue and the creation ofjobs for local population. The community as a whole will benefit.
Additionally, we request that we be allowed to use our UAS to benefitfirst responders who request the capabilities of SkyChase Designs LLC UAS's in their operations, including: fire fighters, police, sheriff, waterfront lifeguard operations ,etc., all while operation underand within exemption limitations previously requested from FAA.



### 5. Additional information, views, orarguments available to support your requestPilot in Command and Observer Qualifications and Duties

The PIC will maintain at least a Private Pilot Certificate and a current State issued driver's license, plus at least 2 hoursflying time and 3 takeoffs and landings within 30 days in thetype of UAS utilized in operations.

The PIC is responsible forthe safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation and inspection, in flight operation, post flight requirements, and all procedures including but not limited to:

1. Safe in flight operations 2. Risk evaluation 3. Current weather conditions for safe flight 4.The Observer must havethe visual acuityto observethe UAS and be ableto communicate clearly with the PIC. 5 Monitorappropriate Unicorn Frequency ofAirports in the region of UAS flight plan operation.

The·Observers duties are:

1. Warning the PIC ofany impending obstacles in the flight path ofthe UAS. 2. Warning the PIC ofany deviations in the planned flight path ofthe UAS. 3. Warning the PIC should any unauthorized personnel appear in the area ofthe planned flight.

The Observerwill havethe authorityto orderthe PIC toterminatethe flight should he feel the flight cannot be conducted safely.

General Operating Standards

1. SkyChase Designs LLC will only operate its UAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the UAS will"not create a hazard to users ofthe national airspace system orthe public."

2. Before an operation ofa UAS within 5NM ofan airport with a control tower, the control towerwill be called to gain permission to operate the UAS. The PIC will give the position, altitude and thetimes the UAV will be operated. The UAS will not be operated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.3. Before an operation ofa UAS within 5NM ofa non-tower controlled, airport operators will be notified and the PIC will givethe right ofwayto avoid flying in the proximity of non UAS manned aircraft. At notimewill the UAS be operated within the final approach course and thetakeoff course of any runway. The UAV will not be operated at an altitude ofover 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

4. Maximum flight time for each operational flight will be 20 minutes.

5. Flights will beterminated at25% battery power reserve should that occur priorto the 20 minute limit.

6. The UAV will be programmed so that it will not be operated at an altitude of
no morethan 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.

7. Minimum crewfor each operation will consist ofthe UAS Pilot, and Visual Observer.

8. The UAS operated by the petitionerweighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbals).

9. The UAS will operate at speeds of no morethan 45 knots, can hover, and can simultaneously move vertically and horizontally.

10. All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice or direct real time electronictransmission (cell phone, unicom, radio), at all times during aflight operation

11. Operations will be restricted toflights over private property with the permission ofthe property owner;

12. All required permits will be obtained from state and local government priorto operation

13. SkyChase Designs LLC will not be operated over densely populated areas.

14. SkyChase Designs LLC will not be operating over any open-air assembly of people.'.

The UAS, powered by batteries, is smaller, lighter and more maneuverablethan larger aircraft running on combustiblefuel. The UAS operates at loweraltitudes with no people on board and will thereby reduce current risk levels, enhance safety and diminish the likelihood of death orserious bodily injury. With a small payload and maximum flight time of only 20 minutes, this offers little or no risk to national security.



### 6. Federal Register Summary

Skychase Designss LLC "Petitioner" seeks an exemption from thefollowing rules in Title 14ofthe Code of Federal Regulations: 14 C.F.R. Part 21,14 C.F.R. 45.23 (b),14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a),14 C.F.R. 91.9 (b)(2),14 C.F.R. 91.109,14 C.F.R. 91.119,14 C.F.R. 91.121 Page 3,14 C.F.R. 91.151 (a),14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b),14 C.F.R. 91.215,14 C.F.R. (91.401

- 91.417)

The exemption will enhance safety by reducing risktothe general public and property ownersfrom the substantial hazards associated with performing equivalent film workwith conventional fixed-wing aircraft, rotorcraft, or other methods.

7. Conclusion
SkyChase Designs LLC Petition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 including weight, speed, operating capabilities, proximityto airports and populated areas, operation within VLOS and national security. The proposed UAS operations will benefit the public as a whole by improving safety and reducing risk byalleviating human exposure to danger. In consideration ofthe foregoing, this Petition for Exemption provides the FAA with morethan adequatejustification for granting the requested exemptions.

We thankyou foryour prompt consideration ofour requested exemptions. Should you have any questions, or ifyou need any additional information to supportthe requested exemptions, please do not hesitateto contact us.



### SkyChase Designs, LLC Matthew Michael Chase

### 229 Cedar Mill Lane Woodstock, Georgia 30189 Phone:??0-364-2240 Email: Matthewmchase@gmail.com