December 9, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Scott Amy	 	 	 	 	 	 	 	 	 	 	 	

dba- Skydance Aviation	 	 	 	 	 	 	 	 	 	

1120 Huffman Rd. Ste. 24546	 	 	 	 	 	 	 	

Anchorage, AK 99515

Dear Sir or Madam:

Attached please find Skydance Aviation’s request for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of its Small Unmanned 

Aircraft Systems ("sUASs") for primarily real estate photography, but also for 

inspecting, surveying and monitoring of secured and controlled environments with 

respect to construction sites, transmission towers, other similar industrial elevated 

structures of the like. This exemption request is exclusively for the use of the DJI 

Phantom 3 Advance with (reserved N- Number N-___SA) to be used by Skydance 

Aviation in conjunction with Northern Lens Photography, LLC.

In addition to my experience flying sUASs, I am a certified flight instructor in fixed wing 

and rotorcraft and hold a Airline Transport pilot certificate and have a current medical. I 

have over 7000 hours of flight time in many different aircraft. As a result, I understand 

the responsibilities undertaken when operating as pilot in command of any aerial 

vehicle and will ensure that any sUAS operated by Skydance Aviation will abide by all 

necessary safety and regulatory requirements.

Please be advised that this exemption request being submitted by Skydance Aviation 

is extremely similar in nature to the exemption submitted to the FAA by The Alaska 

Channel, Inc. For purposes of expediting the exemption process, Skydance Aviation is 

agreeable to abide by and accept similar Conditions and Limitations stipulated in the 

Exemption 333 for Alaska Channel and other recent approvals. Grant of Exemption 

Nos. 12235.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.P.R. Part 11, Skydance Aviation ("Skydance Aviation"), an imagery and 

inspection firm, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its Small Unmanned Aircraft 

Systems ("sUASs") for aerial imaging for cinematography and aerial inspection and 

monitoring of secured and controlled environments, such as construction sites or other 

elevated industrial structures so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

As detailed in this document, the requested exemption would permit the operation of 

sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3)
controlled as to access and 4) would provide for safer videography and inspections 

thus preventing the use of conventional aircraft over these sites and thereby eliminating

the need to place personnel in harm’s way when attempting to access sites or elevated 

structures without conventional access. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to"...establish requirements for the safe operation of such aircraft 

systems in the national airspace system." Section 333(c) of the Reform Act.

The name and address of the applicant is:

Skydance Paragliding	 	 	 	 	 	 	 	 	 	

16348 Noble Point Dr. 	 	 	 	 	 	 	 	 	

Anchorage, AK 99516	 	 	 	 	 	 	 	

907-301-6118

Thank you for your time and consideration, and please let me know if you have any 

questions.

Sincerely,

Scott A. Amy

President & Founder of Skydance Aviation

Regulations from which the exemption is requested: 

14 C.P.R. Part21 14 C.F.R.45.23(b) 14C.F.R. 61.113 (a) &(b) 14 C.P.R. 91.7 (a) 14 C.P.R. 

91.9 (b)(2) 14 C.P.R. 91.103 14 C.P.R. 91.109 14 C.P.R. 91.119 14 C.P.R. 91.121 14 

C.P.R. 91.151 (a) 14 C.P.R. 91.203 (a) & (b) 14 C.P.R. 91.405 (a) 14 C.P.R. 407 (a) (1) 14 

C.P.R. 409 (a)(2) 14 C.P.R. 417 (a) & (b)

I. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under §40 

101 of the Act, including sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §4470 

1(f) See also 49 USC §4471 1(a); 49 USC §44704; 14 CFR §91.203(a) (1).

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs 

may operate in the National Airspace System (NAS) without creating a hazard to the 

user, the public, or a threat to national security. In making this determination, the 

Secretary must consider:
	 •	 The sUAS's size, weight, speed, and operational capability;

	 •	 Whether the sUAS operates within the visual line of sight of the operator

	 •	 Whether the sUAS operates outside of highly populated areas and away from

close proximity to airports.

	 	 Reform Act §333(a). If the Secretary determines that a sUAS "may operate safely 

in the national airspace system (NAS), the Secretary shall establish requirements 

for the safe operation of such aircraft in the national airspace system." Id. 

§333(c).

Skydance Aviation's sUAS is a multi-rotor vehicle, weighing 2.08 lbs. or less 

including payload. They operate under normal conditions at a speed of no more 

than 40 knots and have the capability to hover, and move in the vertical and 

horizontal plane simultaneously. The sUAS will operate only in the pilot's visual 

line of sight at all times and will operate only within sterile areas. Such 

operations will insure that the sUAS will "not create a hazard to users of the 

national airspace system or the public." Reform Act Section 333 (b).

	 	 Given the small size of the sUASs involved and the restricted and sterile 

environment within which they will operate, our application falls squarely within 

the zone of safety (an equivalent level of safety) in which Congress envisioned 

that the FAA might, by exemption, allow commercial operations of sUASs to 

take place. Also due to the small size of the UASs, the low altitudes, and 

restricted areas in which our sUASs will operate, approval of the application will

not present a national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, including enhanced safety, 

the grant of the requested exemptions is in the public interest. Accordingly, Skydance 

Aviation respectfully requests that the FAA grant the requested exemption without 

delay so that we may start taking advantage of the benefits this aircraft has to offer. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the NAS before completion of the rule making required under Section 332 of 

the Reform Act. By granting an exemption the FAA will fulfill Congress's intent of 
allowing sUAS to operate utilizing significant safety precautions in low risk 

environments.

The use of sUASs to photograph, inspect, collect data and monitor elevated hard to 

get areas on structures and towers can significantly reduce the risk to workers. 

Additionally, sUASs could replace the use of helicopters and small aircraft to 

photograph sites at often low level, which again, proposes a lot less risk to persons 

and property. The sUAS we propose to fly in this application weighs 2.08 lbs., and 

carries no combustible material on board, as opposed to the much larger 

conventionally powered small airplane or helicopter. Shifting to sUASs from helicopters 

presents a marked safety increase for us and the public. 

The use of sUASs to facilitate aerial videography for use in filmmaking and real estate 

visualizations has similar safety benefits as well as educational benefits. It will allow the 

general public to gain a much better understanding of the physical layout as seen from 

low altitudes. It is far safer to operate a sUAS in such settings than a manned 

helicopter or a fixed wing aircraft.

Lastly, sUASs reduce the environmental impact by dramatically decreasing the energy 

used for aerial imaging and data collection. Our sUASs use rechargeable lithium ion 

batteries, as opposed to fossil fuels burned in operation of small aircraft. They are 

much quieter compared to other forms of aircraft when used as a platform for 

photography and video imagery. 

III. EQUIVALENT LEVEL OF SAFETY 

Skydance Aviation proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent, or even higher, level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe protocols followed on industrial 

sites and imaging operations conducted with helicopters and other conventional 

aircraft.

Skydance Aviation will abide by the following operating limitations when conducting its 

sUAS under an FAA- issued exemption unless further authorization has been approved:

1. The sUAS will be less than 25 pounds.
2. Maximum airspeed of 100 mph (87 knots)

3. Visual line-of-sight (VLOS) of the unmanned flying aircraft will be maintained 

by the operator or visual observer at all times. The operator to be capable of 

seeing the aircraft with vision unaided by any device other than corrective 

lenses.

4. Daylight-only operations (official twilight to official twilight, local time).	 


5. Maximum total flight time for each operational flight will be 30 minutes. The

UAS calculates battery reserve in real time, and will return to its ground 

station with at least 5 min. reserve battery power should that occur prior to 

the 30 minute limit.

6. 	 	 Flights will be operated at maximum altitude of 400 feet above ground level.

7. First-person view camera cannot satisfy “see-and-avoid” requirement but 

can be used as long as requirement is satisfied in other ways.

8. Flight Crew for each operation will consist of the sUAS pilot who will keep

the sUAS within his visual line of sight at all times, and if deemed necessary 

by the pilot, a Visual Observer can be used to assist the pilot.

9. The sUAS pilot and the Visual Observer will be trained in flight, operations,

and safety procedures.

10. No person may act as an operator or VO for more than one unmanned 

aircraft operation at one time.

11. Must yield right-of-way to other manned aircraft or unmanned. The sUAS will 

only operate within a confined "Sterile Area.” 

12. No operations from a moving vehicle or aircraft, except from a watercraft on 

the water unless prior permission has been given and the operations can 

assure reasonable safety to persons and property. 

13. No careless or reckless operations.

14. No operations are allowed in Class A (18,000 feet & above) airspace

15. Operations in Class B, C, D and E airspace are allowed with the required 

ATC permission.

16. Operations in Class G airspace are allowed without ATC permission

17. A briefing will be conducted in regards to the planned sUAS operations prior

to each day's flight activities.
18. All onsite personnel will consent to the UAS flyover on site by waiver, and 

the pilot will obtain additional verbal or written consent of all persons that 

may be in a potential danger. 

19. 	 	 Written and/or oral permission from the relevant property holders will be 

obtained.

20. 	 	 All required permissions and permits will be obtained if necessary from 

territorial, state, county, or city jurisdictions, including local law enforcement, 

fire, or other appropriate governmental agencies.

21. 	 	 If the sUAS loses communications or loses its GPS signal it will have the 

capability to return to a pre-determined location within the “Sterile Area” and 

land.

22. 	 	 The sUAS will have the capability for the pilot to abort a flight at anytime in 

the event on an emergency.

23. The operator will always perform a complete preflight inspection before each 

new operation. 

24. A person may not operate a small unmanned aircraft if he or she knows or 

has reason to know of any physical or mental condition that would interfere 

with the safe operation of a small UAS.

25. The required operating documents will be accessible during UAS operations 

and made available to the Administrator upon request. 

Below Skydance Aviation states the description of the regulations that it request 

exemptions from and gives argument of how the operations will either meet or exceed 

an equivalent level of safety offered in the present regulations. 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from:

14 C.P.R. 45.23(b); 14 CFR Part21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) &(b); 91.405 (a); 91.407(a) (1); 

91.409 (a) (2); 91.417 (a) & (b).
IV. DESCRIPTION OF SPECIFIC REGULATIONS

(1) 14 CFR Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203(a)(l) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 

Skydance Aviation, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS.

Skydance Aviation's sUAS will be operated at low speeds, in a controlled environment. 

An analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

helicopter) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The sUAS to be operated hereunder is 2.08 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the pilot, and under the 

requirements, and in compliance with, local public safety requirements, to obtain aerial 

imagery. 

These safety enhancements, which already apply to civil aircraft operated in 

connection with similar sites, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.P.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and ability to carry an 

external load no greater than seven (7 ) lbs. 

(2) 14 C.F.R. 45.23(b): Marking of the Aircraft 

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

"limited," "restricted," "light-sport," "experimental," or "provisional," near each 

entrance to a cabin, cockpit, or pilot station.
Even though the UAS will have no airworthiness certificate, an exemption will be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

the word "Experimental" can be placed. Given the size of the sUAS, two- inch lettering 

will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAS will see the identification of the UAS as "Experimental." The FAA has issued the 

following exemptions to this regulation: Exemptions Nos. 10700, 873 8, 10167 and 

10167A. 14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in 

command 

(3) Sections 61.113 (a) & (b) limits private pilots to non-commercial operations.

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the pilot 

operating the aircraft to have completed a UAS flight training course and have 

accumulated at least twenty-five (25) hours of total time as a UAS pilot, with at least ten 

(10) hours logged as a UAS pilot with similar UAS type, before flying a UAS for 

Skydance Aviation in commercial operations. Unlike a conventional aircraft that carries 

the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo 

on board. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of the sUAS as requested with a pilot 

who has met the minimum requirements meets and exceeds the present level of safety 

achieved by 14 C.P.R. §61.113 (a) & (b). 

(4) 14 C.F.R. 91.7 (a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft, requirements for maintenance, and use of 

safety checklists prior to each flight, an equivalent level of safety will be provided. 

(5) 14 CFR 91.9 (b)(2): Civil aircraft flight manual, markings, and placard 

requirements 

The sUAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft. The equivalent level of safety

will be maintained by keeping a flight operations and procedures manual that exceeds 

currently accepted means and methods for safe flight at the ground control point where 
the pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602,32827, and 10700. 

(6) 14 C.F.R. 91.109: Flight Instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls.

By design, sUASs and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a 

pilot nor passengers will be carried in the aircraft, and by the size and speed of the 

aircraft.

Skydance will use simulation devices to gain and maintain the required proficiency and 

currency that will meet or exceed the above regulation with out the use of dual controls. 

(7) 14 C.F. R. 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a 

helicopter, with vertical take off and vertical landing, which will operate at altitudes 

below 400' AGL, so an exemption may be needed to allow such operations. The sUAS 

will never operate at altitude higher than 400 AGL and will be in a relatively small 

controlled area where buildings and people will not be exposed to operations without 

their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the locations where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to 

the property owner and any onsite personnel, all affected individuals will be aware of 

the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the sUAS proposed herein, and carrying flammable fuel, any 

risk associated with our operations is far less than those presently presented with 

helicopters and other conventional aircraft operating at or below 500 AGL in the 

construction of filmmaking industry. In addition, the low-altitude operations of the sUAS 

will ensure separation between these small- UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

(8) 14 C.F.R. 91.121: Altimeter Settings 
This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the pre-flight 

requirements and checklists confirming the elevation of the launch site before flight. 

(9) 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight under VFR 

conditions to fly to the first intended point of landing and fly for 30 minutes after that

Our UAS is limited to operations in sterile and controlled environments, and has a 

limited range and flight time which requires an exemption from 14 CFR 91.151(a). 

The UAS we will be using will always be able to return to the home point if the power 

level reaches a point that may not allow it to return and land with out a reserve of 5 

minute of reserve flight time. 

At this time the battery powering the sUAS provides no greater than 30 minutes of 

powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS 

flights would be limited to approximately 0 minutes in length. Given the limitations on 

the UAS' s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or 

enough battery reserve to ensure that the sUAS lands at the ground station with at least 

enough battery power (as determined by the onboard monitoring system and the pilot), 

to assure a 5 min. reserve. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673,and 10808. 

(10) 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration The 

regulation provides in part: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate . . . .
(b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 25 lbs. and is operated without an onboard 

pilot. Therefore there is no ability or place to carry certification and registration 

documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground flight control point where the pilot flying the sUAS will have immediate access 

to them, to the extent they are applicable to the sUAS. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

(11) 14 CFR 91.405 (a); 407 (a)(l); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter ...," and others shall inspect or 

maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Skydance Aviation’s sUAS. 

Maintenance will be accomplished by the operator pursuant to standard procedures 

and manufacturer guidance. An equivalent level of safety will be achieved because 

these small UASs are very limited in size and will carry a small payload and operate 

only in restricted areas for limited periods of time. If mechanical issues arise the UAS 

can land immediately and will be operating from no higher than 400 feet AGL and 

within visual line of sight of the pilot. The pilot will ensure that the UAS is in working 

order prior to initiating flight and has the required maintenance. Moreover, the pilot is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 

C.F.R 45.23(b); 14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 

91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle 

(55 lbs or less) in aerial imagery operations.
In summary, the operation of small UASs, weighing less than 55lbs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety supporting 

the grant of the exemptions requested herein, including exempting the applicant from 

the requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a sterile environments and, 

as a result, are far safer than conventional operations.

It is our hope that approval of exemptions allowing commercial operations of sUASs for 

aerial imagery includes but is not limited to: aerial photography, surveying, monitoring, 

inspecting for the real estate, construction, industrial, and filmmaking industries. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-- size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight --provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant's sUAS.

Accordingly I respectfully request that the FAA grant my exemption

request and as a certified flight instructor #2778187CFII, I am willing to cooperate 

support the FAA in sharing information to benefit the safety of manned and unmanned 

flight and to the general public at large.

Respectfully Submitted,

Sincerely,

Scott Amy - 

Petitioner submits the Appendix and Manuals

DJI Phantom 3 

http://download.dji-innovations.com/downloads/phantom_3/en/

Phantom_3_Advanced_User_Manual_v1.0_en.pdf