Skytilt Films, LLC, Michael Rollins

10638 101st Ave. Unit 1

Seminole, FL 33772

P: 727-422-7706 E: SkytiltFilms@Gmail.com

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September 4, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

West Building Ground Floor, Room w12-140

Washington DC 20590

RE: Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)

Petitioner:

Skytilt Films, LLC, Michael Rollins

10638 101st Ave. Unit 1

Seminole, FL 33772

P: 727-422-7706

E: SkytiltFilms@Gmail.com

Dear Sir or Madam,

I, Michael Rollins, on behalf of my company, Skytilt Films, LLC - and as its only owner and

pilot in command (PIC) - would like to respectfully petition for an exemption under Section 333

of the FMRA.

I intend to use Small Unmanned Aircraft Systems (sUASs) for aerial videography and

photography - i.e. real estate, landscape architecture, construction, advertising, and closed-set

film and television productions; aerial inspections, monitoring, and surveying; assisting crews

with aerial news gathering and aerial search and rescue; and sUASs training. 

Specific sections from which exemption is requested:

14 C.F.R. Part 21, Subpart H, 45.23(b), 61.23(a)(c), 61.101(e)(4)(5), 61.113(a)(b), 61.315(a),

91.7(a), 91.9(b)(2), 91.103(b)(2), 91.105, 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.203(a)(b),

91.215, 31.405(a), 91.407 (a)(1), 91.409 (a)(1)(2), and 91.417 (a)(b).

Extent of relief requested:

To allow commercial operation of sUASs, 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. Exemption would permit the operation of sUASs under controlled conditions and in a

limited, predetermined, and controlled airspace. Upon approval of this proposed exemption

request, Skytilt Films, LLC would conduct commercial operations with sUASs - while meeting

or exceeding all operational and safety requirements as described by the FAA .
Skytilt Films, LLC, Michael Rollins

10638 101st Ave. Unit 1

Seminole, FL 33772

P: 727-422-7706 E: SkytiltFilms@Gmail.com

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Public benefit:

The request for this exemption is in the public's best interest as there are countless industries in

which the unique views and services of a sUAS would be beneficial. Using a sUAS to capture

never-before-seen aerial video and photos creates an environmentally friendly, low cost solution

for both the operator and the consumer. Compared to manned aerial vehicles, sUASs can be

operated with significantly lower financial costs, while also lowering the safety risks for both the

operator and any person or property on the ground during flight.

Reasons why the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at least equal to the existing rule:

Proposed operations, using sUASs, provide increased safety enhancements - especially when

compared to manned helicopters and aircraft - for the following reasons:

1. All sUASs listed below weigh less than 15 pounds, including camera, lens, gimbal, etc.

2. The sUASs will operate at speeds of less than 50 MPH.

3. Flights will be operated at an altitude of no higher than 400 feet above ground level (AGL).

4. Flights will be operated within a visual line of sight (VLOS) of the PIC and under the watchful

eye of a visual observer (VO).

5. The PIC currently keeps, and will continue to keep, inspection, maintenance, and flight logs.

6. The PIC will conduct a pre-flight inspection prior to each flight.

7. The sUASs will not be operated during night.

8. Maximum total flight time for each operational flight will be less than (30) minutes, while the

sUAS will continuously monitor battery voltage and will automatically return to the ground

station with at least 20% battery power reserved if not already done by the PIC.

9. Written and/or oral permission from private property owners will be obtained prior to

operating the sUAS.

10. All permits, permissions, etc. will be obtained from local government offices, as required.

11. The sUASs have the capability to return (by GPS) and land at a pre-determined location

should a sUAS lose radio signal during any operation.

12. The sUASs can be switched into a Fail Safe mode (to return to the pre-determined location

mentioned above) at any time, by the PIC, should an unpredicted obstacle or emergency arise.

13. Operations will not be conducted directly over civilians.

14. Operations will not be conducted within a five (5) nautical mile radius of an airport without a

letter of agreement with that airport's management or the proper COA, issued by the FAA. 

Summary for Federal Register:

I, Michael Rollins, on behalf of my company, Skytilt Films, would like to respectfully petition

for an exemption under Section 333 of the FMRA in order to conduct commercial operations of

sUASs - for the purpose of aerial videography and photography - while within the conditions

outlined by the FAA.
Skytilt Films, LLC, Michael Rollins

10638 101st Ave. Unit 1

Seminole, FL 33772

P: 727-422-7706 E: SkytiltFilms@Gmail.com

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Additional information:

I have over 400 hours of flight time on sUASs and over 20 years of experience in the radio

control industry. I am the first company to be insured by AIG - for sUASs - for both liability

insurance (covering personal and property damage) and hull damage insurance, together.

Equipment and Specifications:

*All sUASs listed, below, are flown with DJI Flight Controllers (Wookong-M and Naza-m), and

have GPS, Attitude, Manual, Home Lock, and Course Lock flight modes. They are all calibrated

to return-to-home in the case of radio frequency loss or if the battery reaches a low-voltage

cutoff point. They are all flown with the same Spektrum DX9 radio; which includes a return-tohome switch. And they all have telemetry readings (battery voltage, motor temperature, altitude

AGL, airspeed, satellites connected, and radio signal strength) that are sent back to the DX9

radio in the form of a voice and screen readout. The DX9 also records ALL flight data to an SD

card, to be read out on a computer at any time post-flight. The F550 and S800 both have

electronic speed controls with LED marker lights that will relay information on the current status

of each motor while in-flight, as well.

DJI Phantom 2 - 4 Props - 3 lbs with battery, camera, and gimbal - top speed of 25 mph.

DJI F550 - 6 Props - 5 lbs with battery, camera, and gimbal - top speed of 45 mph.

DJI S800 - 6 Props - 20 lbs with battery, camera, and gimbal - top speed of 30 mph.

Lumenier QAV 500 - 4 Props - 4.5 lbs with battery, camera, and gimbal - top speed of 45 mph.

Skytilt Films, LLC will operate only within the limitations set by the FAA and also under the DJI

Phantom 2 User’s Manual, the DJI F550 User’s Manual, DJI S800 User’s Manual, and the

Lumenier QAV 500 User’s Manual.