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September 13, 2015

Michael Van Beck

SkyHi Vision LLC

371 Circle Drive

New Munich, MN 56356

Cell 320-290-8564

Email: mvanbeck@hotmail.com

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave SE 

Washington, DC 2059 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 

1. DJI Phantom 3 Professional User Manual v1.2

2. DJI Inspire User Manual v1.2

3. DJI Inspire Maintenance Manual v1.0

4. DJI Inspire Safety Guidelines v1.0

References: 

1. FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the 

matter of the petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the 

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the 

matter of the petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, SkyHi Vision 

LLC, referred to hereafter as the petitioner, request exemption from the following 

sections of Title 14, Code of Federal Regulations: 

61.113(a)

61.113(b)

91.119(c)

91.121

91.151(a)

91.405(a)

91.407(a)(1)

91.409 (a)(1)

91.409(a)(2)

91.417(a) & (b)
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In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, mapping, crop surveying, inspections 

and other flight operations that could be performed safely and more cost effectively 

with the use of small UAS at low altitude within the U.S. national airspace system as 

compared to a manned aircraft. Operations will be performed only at the request of 

and with the authorization and permission of clients or their authorized agents in 

order to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. 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. The conditions identified and proposed by the petitioner are drawn from 

references 1-3. 

The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of 

pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under 

this exemption would be required to comply with any conditions as set forth and in a 

similar fashion to the previously granted exemptions. 

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated 

closer than 500 feet to essential persons, or objects that would not be possible 

without additional relief. The petitioner requests modification, waiver or exemption 

and clarification concerning the terms “congested areas” and “densely populated”. 

The petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic GPS with a 

barometric sensor for altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS 

LLC) prior relief has been granted for manned aircraft to operate at less than the 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 

10673 for daytime, VFR conditions. The UAS provides battery power remaining in 

percent to the PIC. The UA batteries provide approximately 25 minutes of powered 

flight. Information provided in the operating documents discusses procedures 

regarding remaining battery power management. Those documents contain a 

condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specified level. Given the limitations on proposed operations and the 

location of those proposed operations, the FAA found that a reduced minimum

power reserve for flight in daytime VFR conditions was reasonable. 
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91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and 

ensure that the UAS is in a condition for safe flight in accordance with the operating 

documents. The FAA found that adherence to the petitioner’s operating documents 

and the conditions and limitations specified, describing the requirements for 

maintenance, inspection, and record keeping, were sufficient to ensure that safety 

would not be adversely affected.

The UAS

The petitioner plans on utilizing separate, but similar airframes. The DJI Inspire 1 

and the DJI Phantom 3 Professional. These airframes are a "pro-sumer" grade small 

rotorcraft in the quadcopter configuration powered by electric motors each. Individual 

Specifications for the different airframes are located in the table below. 

These airframes utilize an internal inertial measuring unit (IMU) with integrated 

barometric sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC certified 

radio control (RC) unit. Real time video and telemetry information is transmitted back 

to a ground control station allowing the operator and/or PIC to monitor battery level, 

GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control 

camera angle. 

Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude 

is limited and pre-programmed to not exceed 400ft AGL. Battery life limits flight times to 

approximately 20-25 minutes for each airframe. The onboard flight controller will warn the 

pilot via telemetry and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined low state. It is anticipated that flights will usually last less than 10 minutes. 

UAS Airframe Specifications DJI Phantom 3 DJI Inspire 1

Weight (Pounds) 2.82 6.47

Dimensions (inches) 23.23 (Diagonal) 17.25x17.75x11.85

Max Speed (Knots) 30 43

Temp Range (°C) 0° to 40° -10° to 40°

More information is available in product manuals which are Attachments 1 through 4. 

Risk Mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist has been developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure-prone components. 
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The petitioner requests that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that; “The UA may not operate in Class B, C, or D 

airspace without written approval from the FAA. The UA may not operate within 5 

nautical miles of the geographic center of a non-towered airport as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the airport management 

must be made available to the Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner 

is requesting a mechanism to facilitate such activities without requesting a new and 

separate exemption(s) should the need arise. Operations within Class B airspace are not 

requested due to the lack of Mode C transponder. 

Public Interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography.

Aerial photography is a valuable marketing tool that can lead to increased commerce 

and enhance personal photography. Crop surveying applications could lead to 

decreased use of pesticides and fertilizer and conservation of water as well as increased 

crop yields and decreased costs. Aerial surveying and inspections can increase work 

site efficiency, improve volumetric estimations and reduce risks. The petitioner will 

provide clients with photographic data for these purposes on a ‘for hire’ basis acting as 

an independent contractor. A visual observer will be utilized. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details 

concerning any deviations from normal operations will be available to FAA for use in 

collecting data regarding the use of UAS as part of this application. This data may be 

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as 

required. 

Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight 

operations”. The reason for such a general and broad based request is that the 

petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future 

without the long turnaround time associated with additional exemptions. The petitioner's 

business model is based on the idea of offering ad hoc small UAS services to individuals 

or companies who wish to employ these services as a safe, effective, and legal option to 

enhance their business or hobby. The petitioner’s own market research shows pent up 

demand for these services currently exists in the real estate market and other markets 
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are just beginning to emerge. The petitioner has identified Universities and other 

Agencies that could benefit from the operation requested in this application.

A quick internet search will show that many are currently operating similar UAS in 

exactly this fashion without, it is assumed, FAA authorization. The petitioner has 

refrained from engaging in commercial use of the UAS. The primary purpose of seeking 

this exemption is to obtain the capability to offer those services while remaining in 

compliance. 

Adding to the level of safety and experience in these operations, the petitioner has 10 

years of experience in the radio control model aircraft hobby.

Thank you in advance for your time and consideration. 

Kind Regards, 

Michael Van Beck

SkyHi Vision LLC