January 9, 2015
U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;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).

To whom itmay concern,
In pursuantwith Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, OpenSky Drones LLC (OpenSky), an operator ofa small Unmanned Aircraft System (sUAS) for cellular tower and signal analysis in the telecommunication industry, seeks an exemption from the Federal Aviation Regulations (FARs) to allow commercial operations ofits sUAS. OpenSky's requested exemption would permitthe operation ofa sUAS under controlled conditions in cellulartower airspace thatis: (i) limited, (ii) predetermined, (iii) subjectto controlled access through our customers, and (iv) provides greater safety in connection with aircraft operations inthe telecommunication industry. OpenSky believes that an exemption in the telecommunication industry would enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to establish safe operations ofsUAS.
The head ofthe Occupational Safety and Health Administration has published statistics to showthat communications tower climbers had the highest fatality rate per 100,000 workers comparedto other professions in the US. Wireless Estimatorhas recorded over 100 fatalities from cell tower climbing accidents over the last 10 years. Even with OSHA procedures in place, inherent dangers ofelevation ofequipment and in many cases, its immediate locale to power lines cannotbe avoided. OpenSky's mission is to provide safertower inspection services to the telecommunication industrybyreducing the frequency need to climb the towers. With OpenSky's sUAS, we will be able to provide services thatwould limitthis need bybeing able to conduct mostinspections from the ground. Through mounted equipment on the sUAS, we will be able to observe, analyze and acquire valuable data withoutthe risk ofusing a climber. The elimination ofunnecessary climbs to inspectwould resultin less dangerto the crew and increase in making for a saferworking environment. Therefore, the purpose ofthis petition is to improve safety atthe cellular locations by eliminating the need for tower climbing for visual, measurement and signal. OpenSky is an engineering companyin both Civil/Structural as well as RF disciplines specializing in remote sensing services to major wireless providers across the continental United States. OpenSky's sUAS flights will be flown to achieve an aerial view, video recording, signal analysis, laser measurement ofwireless provider antennas and lines that are secured to cell phone towers. OpenSky's sUAS flights will also be used to view and record open antenna locations on towers for potential future modifications and additions.

Data captured from the flights will assist in determining not onlythe physical condition ofthe tower's equipmentbutwould also be able to provide a real-time functionality and transmission ability ofthe tower. Information gather can provide indication ofmalfunction, damage fromlightning strikes, strobe lights condition, coax cable condition, etc. Typical servicing requires technicians to make multiple climbs to up the tower even before tackling any repairwork
The sUAS will also be used to measure signal strength and mapping ofthe tower's equipmentto determine properfunctionality and/or interference created by faulty equipment. For every flight that OpenSky performs, inspection taskperformed will be done with the crew and bystanders safety
concerns in mind. Cell phone towers are highly restricted areas with low potential for consumers or bystanders to be in the area. Cell phonetowers are also highly restricted from any and all airtraffic and have minimal to zero likelihood ofnearby aircraft.
Information Supportingthis Petition as Specified in 14 C.F.R. §11.81

(a) Your name and mailing address and, ifyou wish, other contact information such as a fax number, telephone number, or e-mail address; OpenSky Drones, LLC. Dan 

### QPham, P.E. 12453 NW 44th St Coral Springs, FL 33095 (954) 918-3888 Email: dan@OpenSkydrones.com (b) The specific section or sections of 14 C.F.R. from which OpenSky seeks an exemption

· 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates

· 45.23- Display ofmarks; general

61.113- Private pilot privileges and limitations: Pilot in command 91.103- PreflightActions 91.105- Flight crewmembers at stations 91.109- Flight instruction; Simulated instrumentflight and certainflight tests 91.119 -Minimum safe altitudes: General 91.121- Altimeter settings

· 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

· 91.203 -Civil aircraft: certification required

· 91.405- Maintenance required

· 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration 91.409- Inspections

· 91.417- Maintenance records

We believe an exemption from the above regulations will allow OpenSky to conductthe needed work
as described above. (c) The extent ofreliefOpenSky seeks, and the reason OpenSky seeks the relief OpenSky seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent to operate small UASs around cellular towers and compound facilities.
14 C.F.R. 21

- Subpart H Certification procedures for products and parts, Airworthiness Certificates OpenSky seeks exemption from 14 C.F.R. 21, Subpart Hwhich states the certification procedures for products and parts as well as airworthiness certificates. Due to the limited airspace that OpenSky will be using at cellular locations across the country, we are seeking exemptionto the airworthiness certification process. OpenSky has developed our own training procedures and regulations to promote and provide safe flying experiences for our PIC(s) which canbe viewed in section (e) ofthis

# ·.

petition. The sUAS to be operated hereunderis less than 55 lbs. fully loaded, carries neither a pilot
nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations underthis exemption will be tightly controlled and monitored byboth the operator, pursuantto the Manual's requirements, and under the requirements and in compliance with local public safetyrequirements, to provide securityfor the area ofoperation.

14 C.F.R. § 45.23 (b). Marking oftheAircraft OpenSky seeks exemption from 14 C.F.R. 45.23, which discusses the display ofmarks. Specifically, section 45.23 states, "(a) each operator ofan aircraft must display onthat aircraft marks consisting of the Roman capital letter "N" (denoting United States registration) followed by the registration number ofthe aircraft. Each suffix letter used inthe marks displayed must also be a Roman capital letter (b) when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entranceto the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable". OpenSky will need exemption from this regulation due to the small size ofthe aircraft and thatthere is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" can be placed on the fuselage in compliance with §45.29 (f) where the pilot, observer and others workingwith the sUAV will seethe identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

14 C.F.R. § 61.113 (a) & (b): Private PilotPrivileges and Limitations: Pilotin Command. OpenSky seeks exemption from 14 C.F.R. 61.113, which discusses private pilotprivileges and limitations for the Pilot in command (PIC). OpenSky is seeking exemption from this regulation, because OpenSky believes thatthere is inconclusive evidence thata person with a private pilot certificate can successfully maneuver a sUAS without first hand flight experience withthe particular sUAS. In fact, having a private pilot license does not automatically ensure competence atflying an sUAS in 3rct personview as required to properly operate an sUAS withinthe required line ofsight. However, we believe thatthe PIC and our FOVO (Field Operation Visual Observer) mustbe able to understand and correctly interactwiththe general aviation community. Therefore, we believe our own flight training with the sUAS will be
more than satisfactory. Our PIC and FOVO will be both certified in Ground School training to be able to properlyinteractwith General Aviation protocols. Theywill also actively pursue a private pilot's license as well have the necessary medical qualifications.
14 C.F.R. 91.103 -PreflightActions OpenSky seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning a flight, become familiar with all available information concerning thatflight. This information mustinclude: (a) For a flight under IFR or a flight notin the vicinity ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised byATC; actions, including reviewing weather, flight batteryrequirements, landing and takeoffdistances, and aircraftperformance data before starting a flight. OpenSky's will be operating our sUAS in VFR. Our operations manual already includes preflight procedures directly pertainingto our sUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review ofanypossible flight path ofgeneral aviation, our mission flight path and weather conditions amongst other parameters required to completethe mission.

### 14 C.F.R. 91.105- Flight crewmembers atstations OpenSky seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 91.105 states "(a) During takeoffand landing, and while en route, each required flight crewmember shall (1) Be atthe crewmember station unless the absence is necessaryto perform duties in connection withthe operation ofthe aircraft or in connection with physiological needs; and (2) Keep the safetybeltfastened while atthe crewmember station. (b) Each required flight crewmember ofa U.S.-registered civil aircraft shall, during takeoffand landing, keep his orher shoulderharness fastened while athis or her assigned duty station. This paragraph does not apply if (1) The seat atthe crewmember's station is not equipped with a shoulder harness; or (2) The crewmemberwould be unable to perform required duties withthe shoulder harness fastened. OpenSky will need exemption from this regulation due to the fact thatthe sUAS will nothave a flight
crew or crew stations otherthan the PIC and a Spotter. The PIC will also nothave to be restrained into a seatvia shoulderharness or safety belt atthe time ofthe flight.


### 14 C.F.R. 91.109- Flight instruction; Simulated instrumentflight and certain flight tests OpenSky seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No person may operate a civil aircraft (except a manned free balloon) thatis being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane thatis equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls, when (1) The instructorhas determined that the flight canbe conducted safely; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place offixed, dual controls may be used for flight instruction to conducta flight review required by §61.56 ofthis chapter, orto obtain recent flight experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals atboth pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command duringthe entire flight; (3) The instructoris current and qualified to serve as pilot in command ofthe airplane, meets the requirements of§61.195(b), and has logged atleast 25 hours ofpilot-in-command flight time in the make and model ofairplane; and ( 4) The pilot in command and the instructorhave determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other control seatis occupied by a safetypilotwho possesses atleast a private pilot certificate with category and class ratings appropriate to the aircraftbeing flown. (2) The safety pilot has adequate vision forward and to each side ofthe aircraft, or a competentobserver in the aircraft adequately supplements the vision ofthe safety pilot; and (3) Except in the case oflighterthan-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight maybe conducted in a single-engine airplane, equipped with a single, functioning, throw over control wheel, in place offixed, dual controls ofthe elevator and ailerons, when (i) The safety pilothas determined thatthe flight can be conducted safely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft thatis being used for a flight testfor an airline transport pilot certificate or a class ortype rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated atthe controls, otherthan the pilotbeing checked, is fully qualified to act as pilotin command ofthe aircraft". Again, Except when necessary for takeofforlanding, no person may operate an aircraftbelow the following altitudes: (a) Anywhere. An altitude allowing, ifa power unit fails, an emergency landingwithout undue hazardto persons or property onthe surface. (b) Over congested areas. Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet ofthe aircraft. (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may notbe operated closerthan 500 feet to anyperson, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conducted withouthazard to persons orproperty onthe surface- (1) Ahelicopter may be operated atless than the minimums prescribedin paragraph (b) or (c) ofthis section, provided each person operatingthe helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) Apowered parachute or weight-shift-control aircraft may be operated atless than the minimums prescribed in paragraph (c) ofthis section (a) Each person operating an aircraft shall maintain the cruising altitude
orflight level ofthat aircraft, as the case may be, by reference to an altimeterthatis set, when operating-(1) Below 18,000 feet MSL, to-(i) The currentreported altimeter setting ofa station alongthe route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area ofoperation as shown in the following table: OpenSky believes thatthere is inconclusive evidence that a personwith a private pilot certificate or license can successfully maneuver ortrain someoneto use an sUAS withoutfirst hand flight experience withthe particular sUAS. Flying in 3rct person orientation requires built-up experience in thatform offlying for manyyears. Therefore, we believe our own flight training, pilot protocols and first hand experiences with the sUAS as laid outin our Flight Operations Manual meets and exceeds the requirements necessaryto safely operate our sUAS for the tasks we purpose. Also, the sUAS will be operated by a remote control, which will only require a single person operator and dual controls will notbe necessary.

14 C.F.R. 91.119- Minimum safe altitudes: General OpenSky seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Since Cell towers are much less than 500ftand ourflight ceiling will be below400ft, this would not pertainto our sUAS operations

14 C.F.R. 91.121- Altimeter settings OpenSky seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest usable flight level. CF R 91121 states



## ... ' Current altimeter setting Lowest usable flight level 29.92 (orhigher) 180

29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210 (c) To convertminimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall takethe flight level equivalent ofthe minimum altitude in feet and add the appropriate b ft: 'fi db I d' h d I . " num ero eet speo e e ow, accor mgtot e currentreporte a t1meter settmg: Current altimeter setting Adjustment factor 29.92 (orhigher) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000OpenSky's sUAS uses both GPS altitude and barometric sensors and relays thatinformation to our ground station. However, this data is used help the sUAS to automatically maintain position hold at the required elevation and therefore this code is notpertinentthe functionality ofthis sUAS.


### 14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions OpenSky seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in VFR conditions. Specifically, 91.151 states "(a) No person may begin a flight in an airplane underVFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed- (1) During the day, to fly after that for atleast 30 minutes; or (2) At night, to fly afterthatfor atleast 45 minutes. (b) No personmay begin a flight in a rotorcraft under VFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after thatfor at least 20 minutes". OpenSky's sUAS has a typical mission time ofless than 15 minutes with maximum flight time of25 minutes. Since this amountless thanthe 30 minute reserve minimum, this reserve minimum would not even make sense in allowing the sUAS a chance to fly. According to OpenSky's aircraft flight manual, the PIC is instructedto maintain flight until battery power reaches 25%, or 1stlevel warning. At this level, landing procedures will be intiated. Once the sUAS reads 20%, 2nd level warning, the flight control system automatically take over and initiates safe landing sequence atthe logged in takeoffpoint. OpenSky policy outlined in our operatingflight manual achieves a satisfactory safety standards.



### 14 C.F.R. 91.203- Civil aircraft: certification required OpenSky seeks exemption from 14 C.F.R. 91.203, which discusses states:
(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply withthis subparagraph (except a special flight permit,
a copy ofthe applicable operations specifications issued under §21.197(c) ofthis chapter, appropriate sections ofthe air carriermanual requiredbyparts 121 and 135 ofthis chapter containing thatportion ofthe operations specifications issued under §21.197(c), or an authorization under §91.611) musthave on it the registration number assigned to the aircraftunder part4 7 ofthis chapter. However, the airworthiness certificate need not have on it an assigned special identification numberbefore 10 days afterthat number is first affixed to the aircraft. Arevised airworthiness certificate having on it an assigned special identification number, thathas been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft registration Application as providedfor in §47.31(c), or a registration certification issued under the laws ofa foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required byparagraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so thatitis legible to passengers or crew. (c) No person may operate an aircraftwith a fuel tankinstalled withinthe passenger compartment or a baggage compartmentunless the installation was accomplished pursuantto part 43 ofthis chapter, and a copy ofFAA Form 337 authorizingthatinstallation is onboardthe aircraft. (d) No person may operate a civil airplane (domestic orforeign) into or outofan airport in the United States unless itcomplies with the fuel venting and exhaust emissions requirements ofpart 34 ofthis chapter". certifications. Specifically, 91.203 states" OpenSky believes that an appropriate and current airworthiness certificate would notbe necessary to fly a sUAS given the size ofthe aircraft and the necessary level ofskill needed to operate theaircraft. Before puttinginto service, each ofour sUAS goes through our own airworthiness proceedures ofmiminum test flight and reliability checks. Also, our sUAS are recalibrated each atthe site location before each flight to ensure that all systems functions as designed. OpenSky seeks exemptionfrom this regulation because we believe this rule was not meantfor a sUAS and operators.

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 OpenSky seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and maintenance records. In OpenSky's aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. OpenSky believes these regulations
are meantfor manned operated aircrafts and not unmanned systems, therefore making them unnecessary.
Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it necessaryto grantthis request. (d) The reasons why granting OpenSky's requestwouldbe in the public interest; thatis, howitwould benefitthe public as a whole. OpenSky is classified as an engineering companybythe U.S. Department ofTransportation and provides services to the wireless industry. Wireless services have become a majorbackbone for nationwide 911 emergencyresponse and OpenSky's use ofa sUAS can assist in verifying thatthe components that make up thatbackbone are fully functional and in proper repair. OpenSky's sUAS usage inthe wireless industry, we will be able to gathervaluable information to help increase safety and productivity. In addition, the sUAS flights will minimize the need for technicians to climb towers, putting fewer lives in danger. Ultimately, tower climbers will still be neededto install tower equipment, but a sUAS will decrease the amount oftimes a climber will be needed. (e) The reasons why grantingthe exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety atleast equal to that provided bythe rule from which OpenSky seeks exemption Our Engineering departmentwill provide a level ofsafetythat exceeds the level ofsafety required by the FAA for its use on sUAS. The following are OpenSky's safety procedures, features, regulations, and operating specifications for our sUAS:

• Our Squadron Leader/ChiefPilot in Charge is an engineer who has 10 years ofRC Model building and flight experience with over 1000 flight hours in Fixed-wing, Helicopter and Multi-Rotor 3rd person flight. He has been involved with flight design, experimentation and system optimization for model industry since 2008 though SAPAC, Inc. models.
• Our staffincludes an FAA-rated commercial flight instructor (ret) who coordinates our FOVO team in integration with general aviation.
• The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will be required to wearhard hats, safetyvests, and safety glasses to protectthe head and eyes from potential mishaps during given operational flights includingtraining ortesting ofsUAS.
• The flight area ofthe sUAS will be observed for besttake offand landing locations. Desired conditions include: flat and level surfaces clear ofdebris, at least 15ftfrom power lines and structures, and a minimum distance of 12ftfrom the PIC and observers.
• The sUAS will also be in the Visual Line ofSight (VLOS) to boththe PIC and FOVO during all flights.
• Flights musttake place during good weather conditions with no rain, low laying clouds, or heavywinds. All flights will take place during daylight hours with no evening or late night flights.• The PIC(s) ofthe sUAS will at least have 12 training hours or 24 flights accrued before being designated working flights around cellular communication towers.
• All batteries mustbe charged completelybefore each flight and each flight must end when the batteryhas a 25% power level remaining.
• Avisual safetyinspection will occur before each flight, testing propellertightness, security mount ofcamera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and FOVO.
• The sUAS will be flown under a height of500ftAGL.
• No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase offlight so as to ensure thatthe sUAS is in a condition for safe flight operation and in a configuration appropriate for the purpose ofthe intended flight.
• Ifthere is more thanjustan operator at a site during a flight, the PIC operator and observer
or FOVO will maintain two-way communication with each other during all operations; if unable to maintain two-way communications, or ifany condition occurs that may otherwise
cause the operationto be unsafe, the operatorwill immediately conclude the operation.
• Ifthe communication linkis lostthe sUAS will go into fail-safe mode and safely descend to its designated home-point location. Ifthe communication link is reconnected during fail-safe mode, control ofthe sUAS canbe regained before landing occurs atthe home-point location.
• There is no fuel or payload to the sUAS, therefore there will be no potential explosives orrisk ofexplosion ifa crash occurs with the sUAS.
• The sUAS will feature a built in compass that will be recalibrated at every site to maintain accurate directional readings. The compass will also help in keepingthe sUAS stable during flights.
• The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum of6 satellites will activate the Ready to Fly status.
• The weight ofthe sUAS is less than 10 lbs. with a maximum ascent speed of6 

### mjs and a descent speed of2 

### mjs. The aircrafts maximum flight speed is 15 

### mjs.
• The aircrafts vertical and horizontal aspect concerninghovering accuracy is 0.8m and 2.5m respectfully.
• The typical aircraftwheelbase will be less than 600mm in length.
• The aircraftruns offa Li-Po battery.

(f) A summary FAA can publish inthe FEDERAL REGISTER stating: (1) The rule from which you seek the exemption; and (2) Abriefdescription ofthe nature ofthe exemption you seek
Petitioner: OpenSky Drones, LLC.
Sections of14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 Description ofReliefSought: Petitioner seeks relieffrom the requirements of 14 C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct cellular tower and compound surveys for wireless providers ontheirproperties and subjectto operating procedures that meet or exceed those that FAA requires.

(g) Any additional information, views or arguments available to supportyour request
Please see the introduction to this exemption request. (h) Ifyou wantto exercise the privileges ofyour exemption outside ofthe United States, the reason whyyou need to do soThe Operations described in this exemption requestwill be conducted wholly withinthe United States.
Attached hereto, and submitted as a 

### confidential document, is our Field Operations Manual. We respectfully submitthat good cause exists so thatthis confidential manual does not need to be published in the Federal Register

Please do nothesitate to contactme via email at dan@OpenSkydrones.com ifyou have any questions
or concerns.

Dan 

### QPham, P.E. Vice President OpenSky Drones, LLC