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Snowy Owl Productions 

16 November 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave S.E. 

Washington, D.C. 

4200 James Ray Drive 

Suite 161 

Grand Forks, ND 58202 

Tel: 701-738-4825 

matt@skyskopes.com 

Re: Amendment to Snowy Owl Productions, LLC Exemption No. 11752 Regulatory Docket No. 

FAA-2015-0947 

Dear Sir or Madam: 

Pursuant to Section 333 of FAA Modemization Act of2012 and 14 CFR Part 11, Snowy Owl 

Productions, LLC (Snowy Owl) developer and operator of Small Unmanned Aircraft Systems ("sUAS"), 

equipped to conduct aerial infrastructure inspections, hereby requests a modification to Exemption No. 

11752, Regulatory Docket No. F AA-20 15-0947, Condition and Limitation 26, to allow commercial 

operations of a vertical takeoff and landing (VTOL) sUAS within 500 feet of any person, vessel, vehicle, 

or structure in a manner consistent with 14CFR 91.119( d). SNOWY OWL will not operate over persons 

non-participating in the operation of the sUAS unless they are under a covered structure. SNOWY OWL 

will comply with all other conditions and limitations of Exemption No. 11752 or as additionally 

established by the FAA. 

Exemption No. 11752 granted SNOWY OWL an exemption for 14CFR Section 91.119c to allow 

operations Jess than 500 foot AGL. Exemption No. 11752 Condition 26, prohibits the operation of sUAS 

within 500 feet of all non-participating persons, vessels, vehicles, and structures unless owner/controller 

permission is granted for each vessel, vehicle and structure and all non-participants remain under 

protection from a potential accident. 

This limitation is more onerous than what is required of manned aircraft. Per 14CFR 91.119( d) 

helicopters may be operated at less than the minimums prescribed in 14CFR 91.119 (b) or (c) ifthe 

operation is conducted without hazard to persons or property on the surface. In addition, each person 

operating the helicopter complies with any routes or altitudes prescribed by helicopters by the 

Administrator. All SNOWY OWL VTOL sUAS were registered as rotorcraft (helicopters). 

This modification request is organized by Section. Section I describes the petitioner. Sections 2-5 

respond to the FAA Public Guidance for Petitions for Exemptions filed under Section 333. Risk and 

Mitigation Justification for this proposal was added to Section 4. 

Sincerely, 

JIJI-~ Matt Dunlevy 

President and CEO 
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Snowy Owl Productions 

Section 1: Introduction and Interest ofPetitioner 

SNOWY OWL, Veteran owned and operated, is the leading developer of sUAV service operations, 

training, safety and management programs. The mission of SNOWY OWL is to support, develop and 

validate unmanned system operations. Our goal is to provide unmatched quality and safety. 

SNOWY OWL has five approved FAA Exemptions (11752, 11487, 11527, 11571 and 11577) authorizing 

the commercial use of sUAS in the National Air Space. 

Section 2: Unmanned Aerial Systems 

Regarding the Unmanned Aircraft System 

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk 

to the NAS or to persons and property on the ground Specifically, petitioners should describe the design 

and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft performance 

and performance limitations, operating procedures, and aircraft loading information in as much detail as 

possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document. 

NOTE: The FAA will consider all information and data submitted by the petitioner that describes the 

UAS developmental and operational history. This could include statistical data or other documentation 

for the specific design and performance characteristics of the UAS, including the operational history and 

operational failure modes, obtained through previous Research & Development (R&D) and/or flight test 

activities, e.g. operations conducted under a COA, with a civil airworthiness certificate, or under other 

authorized operating conditions. 

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, 

maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in 

the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document. 

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may be separate documents 

or combined in a single document 

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and 

associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with 

Federal Communications Commission (FCC) or other appropriate government oversight agency 

requirements. 

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC 

requirements upon request. 

General Information Pertaining to All Proposed sUAS 

All sUAS will conform to SNOWY OWL Exemption No. 11752 or as additionally established by the 

FAA. This request is limited to SNOWY OWL VTOL sUAS that are registered as rotorcraft (helicopters) 

in the associated Aircraft Registration Application (AC Form 8050-1 Series). 

Section 3: Unmanned Aircraft Pilot in Command (PIC) 

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qual(fications required of any PIC(s) who will be direct(Y responsible 

for the operation of the VAS, including information such as: the level of airman certificate held; any 
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Snowy Owl Production• 

applicable training related to the operation; and any minimum hours of flight experience required by the 

PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual 

obsen,ers, petitioners should describe their roles and qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible 

for the operation of the UAS. 

Flight Crew Qualifications and Standards will conform to SNOWY OWL Exemption No. I I 752 or as 

additionally established by the FAA. 

Section 4: Operations of sUAS 

Regarding the Operation of the Unmanned Aircraft 

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the 

proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at 

least equivalent to that provided by the rule from which exemption is sought. Petitioners should address 

any plans to implement clearly defined operational borders and procedures to ensure public safety, which 

includes persons and property both in the air and on the ground This can be described in the petition, in 

an Operations Manual, or similar document. 

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of flight, NAS 

safety considerations, and the safety of the non-participating persons and property during the operational 

period and within the operational area. 

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimum 

flight visibility and distance from clouds for their intended operation(s). Petitioners should describe 

potential hazards and safety mitigations associated with these proposed conditions. These issues can be 

addressed in the petition, an Operations Manual, or similar document. 

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated 

potential hazards, in accordance with the statutory mandate under Section 333 regarding proximity to 

populated areas. These issues can be addressed in the petition, an Operations Manual, or similar 

document. 

9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance 

with the statutory mandate under Section 333 regarding proximity to airports. 

10. The VAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory 

mandate under Section 333(b)(J). Petitioners should describe how they intend to comply with his 

mandate. 

11. Petitioners should describe any procedures they would implement for conducting a preflight safety 

risk assessment to determine that the VAS is in a condition for safe flight (14 CFR § 91. 7(b)) and that the 

planned operation can be completed safely. These procedures can be addressed in the petition, an 

Aircraft Flight Manual, Operations Manual, or similar document. 

12. If petitioners intend to conduct operations which have existing requirements to notify Flight 

Standards District Offices (FSDOj) prior to operations - such as motion picture and television filming. 

or pipeline and powerline patrol - petitioners should describe their intended coordination in this regard 

for their proposed operalionM. 
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Snowy Owl Produrtion• 

13. The FAA intends to require entities who obtain an exemption under this process to also obtain a 

Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting 

operation(s) in the NAS. 

SNOWY OWL requests a modification to Exemption No. 11752, Regulatory Docket No. F AA-20 15-

094 7, Condition and Limitation 26, to allow commercial operations of a vertical takeoff and landing 

(VTOL) sUAS within 500 feet of any person, vessel, vehicle, or structure in a manner consistent with 

14CFR 91.119(d). 

Exemption No. 11752 granted SNOWY OWL an exemption for 14CFR Section 91.119c to allow 

operations less than 500 foot AGL. Exemption No. 11752 Condition 26, prohibits the operation of sUAS 

within 500 feet of all non-participating persons, vessels, vehicles, and structures unless owner/controller 

permission is granted for each vessel, vehicle and structure and all non-participants remain under 

protection from a potential accident. 

This limitation is more onerous than what is required of manned aircraft. Per 14CFR 91.119( d) 

helicopters may be operated at less than the minimums prescribed in l4CFR 91.119 (b) or (c) if the 

operation is conducted without hazard to persons or property on the surface. In addition, each person 

operating the helicopter complies with any routes or altitudes prescribed by helicopters by the 

Administrator. 

SNOWY OWL requests a modification to Exemption No. 11752, Regulatory Docket No. F AA-20 15-

094 7, Condition and Limitation 26, to allow commercial operations of a vertical takeoff and landing 

(VTOL) sUAS within 500 feet of any person, vessel, vehicle, or structure in a manner consistent with 

14CFR 91.119(d). SNOWY OWL will not operate over persons non-participating in the operation ofthe 

sUAS unless they are under a covered structure. 

Risk Mitigation and Justification 

The proposed change to Exemption No. 11752 Condition 26 is consistent with the Operation and 

Certification of Small Unmanned Aircraft Systems (sUAS) Notice for Proposed Rulemaking (NPRM). 

SNOWY OWL has a documented safe and effective operating experience conducting infrastructure 

inspection testing with sUAS operating within the guidelines of existing FAA approved Certificates of 

Authorization proximate to non-participants, participants, vehicles and a structures. 

It is SNOWY OWL's policy that sUAS shall never be deliberately operated over any personnel. This is 

included as part of the flight safety brief. Prior to flight operations, SNOWY OWL shall conduct an 

assessment of the planned flight area to ensure that the planned flight operations can be conducted in a 

manner without hazard to persons or property on the surface. Covered shelters to protect participants are 

briefed prior to flight operations. During sUAS takeoff and landing only the SNOWY OWL flight crew 

are allowed to be proximate to the sUAS. 

SNOWY OWL FOM dictates that the sUAS Fail Safe protocols default to "Land Now" vice "Retum to 

Home" automation to minimize the likelihood of unintentionally striking a structure or flying over 

personnel. 

SNOWY OWL Infrastructure Inspection flight profiles are planned to minimize horizontal flight 

operations away from the flight crew. This improves flight crew situational awareness, and lessons the 

likelihood of inadvertently flying over personnel. 
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Snowy Owl Produclion• 

The low mass and lack of liquid fuel on SNOWY OWL sUAS ensure that the consequence of the hazard 

associated with the operation of sUAS is significantly less than that associated with manned helicopters. 

All SNOWY OWL VTOL sUAS were registered as rotorcraft (helicopters) as directed by the FAA in the 

associated Aircraft Registration Applications (AC Fonn 8050-1 Series). 

SNOWY OWL sUAS operations shall confonn to Exemption No. 11752 except as noted above or as 

additionally established by the FAA. 

Images illustrate SNOWY OWL UAVs during recent testing missions and demonstrates the close 

proximity that is maintained from structures being inspected, routinely inside of20 feet. To ensure safety 

of personnel on the ground, SNOWY OWL UAVs will remain within a safe distance from structures 

being inspected and NEVER overfly personnel. 

Section 5: Requested Exemptions from Regulations 

No additional exemptions from regulations are requested beyond what was approved in SNOWY OWL 

Exemption No. 11752 at this time. 

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