# Thomas M Kane 179 East Positano Avenue St. Augustine, FL 32092

_ __ ______________ 4l2-491-1353 May 4, 2015 U.S . Department ofTransportation , Docket Operations West Building Ground Floor, Room Wl2-140 1200 New Jersey Ave, SE Wasbington, DC 20590 

# Petition for Exemption Under 14 CFR § 

# 11.81 To Allow Commercial Use ofUnmanned Aircraft Systems Regulation Date: March 23, 2015

- which automatically grant a " blanket" COA for flights at or below 200 feet. To whom it may concern, 

### I, Thomas 

### M. Kane of SKY 

### 1 IMAGING, 

### am submitting this application for exemption to the 

### FAA so that I may be permitted to operate a small unmanned aircraft(s) , for the purpose ofa commercial business . As an 

### FAA licensed Private Pilot and an experienced radio controlled (R.C .) Pilot

- the scope ofSKY 

### 1 IMAGING will include (but not limited to) videography, photography, inspections , promotions , corporate events and insurance applications. SKY 

### 1 IMAGING will not pose a threat to national airspace or national security. lt will conduct and maintain a safe flight protocol for all UA V flights . Also, strict safety guidelines 

### will be in place for all 

### UAV flights . 1- Petitioner

- Contact Information: SKY 1 

### IMAGING Thomas M . Kane, Principal 179 East Positano Avenue St. Augustine, FL 32092 Business Phone: 844-359-7591 Cell Phone: 412-491-1353 Email : thn(;..,Rf{ilom3 '1 cnm Website : ww\\- . skyt 1maging.com Rating: Private Pilot Date of Issue: September 30, 1995 Current Medical: Class 3 Medical : Date ofExamination - 3/25/20152- Sections from which Exemptions are Sought: This application is herby made for exemption from the following : A FAA Modernization and Reform Act of2012 , PL 112-95 February 14, 2012, Section 333 B. 14 CFR Part 21 , Subpart H C . 14 CF:R Part 61.113 (a) and (b) D . 14 CFT Part 91 , 91.7 (a) . 91.9 (b) E. 91.103 (b) (2) F. 91.105 G. 91.109 H. 91.119 I. 91.121 

### J. 91.15l (a) K. 91.405 

### L. 91.407 M. 91.409 (a)(2) N. 91.417(a)(b) 

### 3 - Relief Sought and Reasons for Seeking Relief: A Tom Kane and SKY 1 IMAGING is seeking relief and wishes to operate an Unmanned Aircraft System for commercial purposes . The scope of SKY 1 IMAGING wiJJ include (but not limited to) videography, photography, inspections , promotions, corporate events and insurance applications . B. This reliefis sought because commercial use ofUnmanned Aircraft Systems is currently prohibited by law unless an exemption is granted. C . Given the specifications required by the FAA ' s Reform Act, Tom Kane and SKY 1 IMAGING have met or exceeded the minimum conditions set forth that would reflect in a favor of exemption

- including : ALL aircraft will weigh less than 55 pounds including payload and energy systems . All aircraft used will have a minimum of4 counter-rotating propellers for balance, control and stability. Aircraft will have GPS technology

- with safe-mode

- return home capabilities. D . Aircraft currently used : 

### Dll Phantom Vision 2 Plus

- Version 3 : with camera and gimbals. Additional aircraft to be added by future amendment to this exemption. 4- Public Benefit: There are many benefits 

### in granting this exemption to operate a UAS commercial business

- including the following: 

### A Employing people

- hiring staffmembers, putting them on the tax role is a benefit for local , state and federal tax implications . From a receptionist, to video editors, to a sale's staffto other highly trained UAV pilots. B . Until recently, only fixed winged aircraft (airplane) or rotor-based aircraft (helicopter) had the means to conduct video and photographic images . By using UAS

- the benefits are large : reduces accident liability and potential dangers and also has a significant reduction in a carbon footprint and emissions . C . Other small businesses benefit , such as smaller real estate companies and homeowners . Until now, these companies were unable to use aircraft to obtain aerial images oftheir property. D. Business such as newspapers , websites, car dealerships , restaurants , retail applications , etc

- all benefit because they didn 't have the means for aerial imaging in the past E . No combustible fuel is used5- Safety 

### will not be adversely affected: As an FAA licensed pilot, safety is always a top priority for Tom Kane and SKY 1 IMAGES . Weather conditions, heavily populated areas, the location of airports, and the surroundings of a client's location- will all be taken into consideration. A. The following safety protocols will be implemented for each flight: • Will conduct all flights during daylight hours . • Most flights will be at the tree line or below • All flights will be below 200 feet altitude • All flights will be less than 40 knots • All flights will be in "visual line ofsight'' (VLOS) flying • An observer will be used in certain applications • The unmanned aircraft will weigh less than 50 pounds • Will conduct preflight inspections ofaircraft prior to each flight B . All aircraft will be registered and market in accordance with Section 44711, Part 47 and Part 45, Subpart C. The size ofmarJcjngs

- ofthe word "Experimental" will be dependant ofthe size ofthe aircraft being used

- and in most cases be smaller than 2 inches in height. C. All aircraft will comply with maintenance and inspection requirements ofthe manufacturer. All maintenance and repairs will be conducted or approved by qualified personnel. A test flight will be conducted after any maintenance is preformed. Records of maintenance will be kept in a log for each aircraft. D . All UAV flight operations will be conducted in accordance with manufacturers operational guidelines . E . Will not intrude into Class B, C or D airspace. F. Will not exceed 75% ofthe attached battery or 25 minutes offlying time, whichever occurs first. G. Should any incidents occur, all incidents will be reported and/or logged within 24 hours of occurrence. H. Tom Kane will maintain liability insurance of$1 ,000,000 by a qualified insurer. l. The UAV currently being utilized is the Phantom 2 Vision Plus

- Version 3 : This UAV is an extremely SAFE aircraft

- as it's a " first person view" aircraft with a high performance camera and remote control that features in-flight content sharing. The UAV allows for planned flights that enable the UAV to fly automatically via the onboard GPS system. Additionally, this UAV has a safety, built-in " Return to Home "

- Failsafe feature . NOTE: The Phantom 2 Vision Plus " User Manual " is attached to this petition. 6- Publish in the Federal Register: In Summary

- Thomas M. Kane, owner of SKY I IMAGNING, is seeJcjng a Petition for Exemption under 14 CFR 

### § 11 .81

- To allow commercial use ofunmanned aircraft systems . I am seeking and exemption to the following rules : FAA Modernization and Reform Act of 2012 , PL 112-95 February 14, 2012, Section 333 , 14 CFR Part 21 , Subpart H, 14 CFR Part 61.113 (a) and (b), 14 CIT Part 91,91.7 (a). 91.9 (b), 91.103 (b) (2), 91.105 , 91.109, 91.119 , 91.121 , 91.151 (a) , 91.405 , 91.407 , 91.409 (a) (2), 91.417 (a) (b) .The Petition for Exemption is being submitted to operate an Unmanned Aircraft System for commercial purposes . The scope of SKY 1 IMAGING will include (but not limited to) videography, photography, inspections , promotions , corporate events and insurance applications . As an FAA licensed Private Pilot, the highest safety standards will be implemented and in place at all times . 7- Additional information to support this request: Should UAS and/or UA V laws be amended by the FAA and Congress , Tom Kane and SKY 1 IMAGING would be interested in partnering with the FAA once official guidelines and regulations are modified, changed or adopted

- to become a UAV certified flight training center, a written test center, or any other safety center that might night aide and support in the safe operation of Unmanned Aerial Systems and Unmanned Aerial Vehicles . 8- Exemption outside tbe United States: NO exemption is being requested to operate outside the United States . Should you require additional information, please do not hesitate to contact me either by phone or email. Thank you very much for your consideration! Sincerely,

Tnomas M . Kane, Principal SKY 1 IMAGING Date:

Attachments: 1 - FAA Petition for Exemption 2- FAA - Pilot ' s License 3- FAA - Third Class Medical Certificate 4- Phantom 2 Vision Plus

- Version 3 : User Manual