Thomas M Kane 

179 East Positano Avenue St. Augustine, FL 32092 _ ________________ 4l2-491-1353 

May 4, 2015 

U.S. Department of Transportation, 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 of Unmanned 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 of a commercial 

business. 

As an FAA licensed Private Pilot and an experienced radio controlled (R.C.) Pilot - the scope of SKY 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 UA V flights. 

1-Petitioner- Contact Information: 

SKY 1 IMAGING 

Thomas M. Kane, Principal 

179 East Positano A venue 

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 of Examination - 3/25/2015 
2- 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 relief is sought because commercial use of Unmanned 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 of 4 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 staff members, 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 

staff to other highly trained UA V 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 of their 

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 used 
5- 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 of sight'' (VLOS) flying 

• An observer will be used in certain applications 

• The unmanned aircraft will weigh less than 50 pounds 

• Will conduct preflight inspections of aircraft 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- of the word "Experimental" will be dependant 

ofthe size of the aircraft being used - and in most cases be smaller than 2 inches in 

height. 

C. All aircraft will comply with maintenance and inspection requirements of the 

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% of the attached battery or 25 minutes of flying 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 UA V currently being utilized is the Phantom 2 Vision Plus- Version 3: This UA V 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 UA V allows for 

planned flights that enable the UA V to fly automatically via the onboard GPS system. 

Additionally, this UA V 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 of unmanned 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