Page **1** of **5**

September 13 , 2015 Michael Van Beck SkyHi Vision LLC 371 Circle Drive New M unich, MN 56356 Cell 320

- 290

- 8564 Em ail: mvanbeck @ hot mail.com U.S. Departm ent of Transportation Docket Managem ent System 1200 New

Jersey Ave SE Wa shington, DC 2059
RE: Exem ption 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 Exem ption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter of the petition of DOUGLAS TRUDEAU 2. FAA Exem ption No. 11136, Regulatory Docket No. FAA

–2014

–0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 3. FAA Exem ption No. 11080 Regulatory Doc ket 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 Subm itting a Petition for Exem ption under section 333 of the FAA Modernization and Reform Act of 2012, SkyHi Vision LLC , referred to hereafter as the petitioner, request exem ption 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)Page **2** of **5**

In order to operate sm all unm anned aircraft system s (UAS) commercially in airspace regulated by the Federal Aviation Adm inistration (FAA) for the purposes of aerial photography, cinem atography, videography, mapping, crop surveying, inspections and other fligh t operations that could be performed safely and m ore cost effectively with the use of sm all UAS at low altitude within the U.S. national airspace system as com pared to a manned aircraft. Operations will be perform ed only at the request of and with the auth orization and perm ission of clients or their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses of small unm anned air system s. So long as such operations are conducted within and under the conditions outlined herei n or as m ay 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 exem ption from the above m entioned 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 exem ption would be required to com ply with any conditions as set forth an d in a sim ilar fashion to the previously granted exem ptions. 91.119(c) As discussed in Exem ption 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 person s, or objects that would not be possible without additional relief. The petitioner requests m odification, waiver or exem ption and clarification concerning the term s “congested areas” and “densely populated”. The petitioner requests waiver for this conditio n to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 91.121 As discussed in Exem ption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altim eter and instead utilizes electronic GPS with a barom etric sensor for altitude inform ation. 91.151(a) As discussed in Exem ption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for m anned aircraft to operate at less than the prescribed m inim um s, including Exem ption Nos. 2689, 5745, and 10650. In addition, sim ilar UAS

- specific relief has been granted in Exem ption Nos. 8811, 10808, and 10673 for daytim e, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approxim ately 25 m inutes of powered flight. Inform ation provided in the operating docum ents discusses procedures regarding rem aining battery power m anagem ent. Those docum ents contain a condition in which the PIC will initiate a landing procedure when battery rem aining reaches a specified level. Given the lim itations on propose d operations and the location of those proposed operations, the FAA found that a reduced m inim um power reserve for flight in daytim e VFR conditions was reasonable.Page **3** of **5**

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exem ption 11 138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating docum ents. The FAA found that adherence to the petitioner’s operating docum ents and the conditions and lim i tations specified, describing the requirem ents 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 simil ar airfram es. The DJI In spire 1 and the DJI Phantom 3 Professional. These airfram es are a "pro

- sum er" grade sm all rotorcraft in the quadcopter configuration powered by electric m otors each. Individual Specifications for the different airframes are located in the table below. The se airframes utilize an internal inertial m easuring unit (IMU) with integrated barom etric sensor augmented with global positioning system (GPS) to m aintain its geospatial orientation and position. It is controlled prim arily through an FCC certified radio control (RC) unit. Real tim e video and telem etry information is transm itted 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 cam era 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 fl ight 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 fl ig hts will usually last less than 10 minutes.
UAS Airframe Specifications DJI Phantom 3 DJI Inspire 1 We ight (Pounds) 2.82 6.47 Dimensions (inches) 23.23 (Diagonal) 17.25x17.75x11.85 Ma x 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.Page **4** of **5**

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 geograp hic 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 t he 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 photographi c 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 c lients 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 i ncluding 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 b e 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 petitione r 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 marketsPage **5** of **5**

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 th is 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