The Name andAddress oftheApplicant is:

March 25, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve. SE Washington, DC 20590 CWO 3 Lt Colonel Orlando Perez ret. Pilot in Command I COO Raymond Gorton I CEO Spotter I Photographer I Sales SkyVision Photography LLC 23 Sometimes Creek Road Sylva, NC 28779 828-508-8486 ;_;;

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RE: Exemption Request under Section 333 ofthe FAA Modernization and ReformAct of2012 and 14 C.F.R. Part 11 Dear Siror Madam: SkyVision Photography LLC (SVP) located at 23 Sometimes Creek Road Sylva, NC 28779 and Pursuantto Section 333 ofthe FAA Modernization and reformAct of2012 (FAA Reform Act) and 14 C.

### F.R. Part 11, respectfully requests exemptionsfrom several provisions ofthe FederalAviation regulations ("FAR"), specifically Section 333 which authorizes the FAAto determine:
1. Ifcertain unmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line ofsight do not create a hazard to users ofthe NationAir Space system or the public or pose a threatto National Security; and 2. Whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certificate under Section 44704 oftitle 49, United States Code, is required forthe operation of unmanned aircraft systems identified under paragraph (1). We are writing to requestthat SVP, LLC, the owner and operator ofthe small unmanned aircraft system, be exempted from the FederalAviation Regulations (FARs) listed below so· that SVP, may operate its small (under 201b) small unmanned aircraft system (sUAS) commercially in (G) airspace regulated by the FederalAviationAdministration (FAA) as long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAAas required under Section 333. SVP is actively involved in the technical developmentofsUAS systems for structural inspections ofbridges, construction sites, communication tower inspections, Search and Rescue, Fire and agriculture purposes. This service is to provide high definition aerial photographywith small unmanned aircraft (sUAS's). 1

.**~--------**The substance ofthis request is essentiallythe same as that granted to ASTRAEUS AERIAL Regulatory Docket No. FAA-2014-3052 in that SVP is engaged in aerial photogra·phy ofstructures using similar lightweight, remote controlled UAS's in remote areas to minimize the danger in climbing such structures and as lifesaving tool for Search and Rescue (SARs) and Fire fighters. SVP has fully equipped each of its sUAS's for aerial photography, primarilyfor use in inspections oftowers, and structures that would otherwise require climbing at great risk to the personnel involved, though given the stability and maneuverability, they may be used by Law Enforcement and SARs and by otherfirst responders for other photographic needs including HD video, Thermal Imaging and Infrared. SVP exemption request would permit its operation of lightweight, unmanned (remotely controlled in line ofsightwith 5 radar avoidance sensors) sUAS's in tightly controlled and limited airspace. Predetermined, specifically marked areas ofoperation, sectioned 

### offlocationswill allow SVP to operate within current safety parameters and new ones being implemented.As identified, similar lightweight, remote controlled UAS's are legally operated byAmateurs with no flight experience, safety plan or controls in place to prevent catastrophe. Granting SVP's request comports with the Secretary ofTransportation's (FAAAdministrator's) responsibilities to not only integrate UAS's into the NationalAirspace System (NAS), butto "establish requirements for safe operation ofsaid aircraft systems (UAS's) in the NAS under Section 333 ofthe Reform Act, SVPwill conduct its operations in full compliance with the protocols described herein or as otherwise established bythe FAA. The Extent of Relief SVP seeks and Reason it Seeks Such Relief: SVP submits this application in accordance with the ReformAct, 112 P.L. 95 

### §§ 331-334, seeking relieffrom any currently applicable FAR's operating to prevent SVP contemplated commercial inspections, research and otherflight operations within the NAS. The ReformAct in Section 332 provides for such integration ofcivil unmanned aircraft systems in our NAS as it is in the public's interestto do so. SVP lightweight sUAS's meetthe definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration ofSVP lightweight sUAS's are expressly contemplated bythe ReformAct. SPV.would like to operate its lightweight sUAS's priorto thetime period bywhich the Reform Act requires the FAAto promulgate rules governing such craft. The Reform act guides the Secretary in determining the types of UAS'sthat may operate safely in our NAS. · Theweight, size, speed and overall capabilities ofthe UAS; whetherthe UASwill be operated nearairports or populated areas; and, whetherthe UASwill be operated by line ofsight.
112 P.L. 95 

### § 333 (a). Each ofthese mitigates in favor ofan exemption for SVP. SVP sUAS's use multi counter rotating propellers with 6 Gyroscopes for extreme balance, control and stability. Each sUAS's have 5 radar avoidance sensors, Emergency Parachute, GPS, 3 Cameras and strobe for up close inspections. They each weigh lessthan 25 pounds, including camera and all equipment. Each ofSVP's small unmanned aircraft is designed primarilyto hover in place and operate at less than 40 knot maximum speed. 2They are capable ofvertical and horizontal operations, but operate only within line ofsight of the operator (PIC, pilot in command). Such that, at minimum, two SVP personnel govern the safe flight ofan SVP aircraft at all times. Utilizing battery power and not combustible fuels, flights generally last between five and thirty minutes. SVP does not operate it sUAS's with less than twenty five percent battery capacity. Safety systems in place include GPS mode that allows SVP sUAS's to hover in place if communication with radio control pilot is lost and then slowly descend the sUAS at twenty five percent battery capacity. Further, SVPfleet are programmed, in some instances, to slowly follow a predetermined set ofwaypoints to return to a safety point ifcommunications are lost. Each sUAS have a backup parachute rescue system ensuring ifthat all systems fail and all power systems go offline, parachute will open automaticallythus preventing damage ofa possible crash landing. SVP sUAS will descend slowly back to Earth, not in a free fall. SVP does not operate its sUAS's near airports and generally does not operate them in populated areas. SVP operation of its fleet ofsmall unmanned system will not "create. a hazard to users ofthe NationalAirspace Systems orthe public". 112 P.L. 

### § 333 (b). Given the small size and weight ofSVP sUAS's combined with their operation in cordoned off and well-controlled areas, SVP's fleet falls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the NAS. Indeed, SVP sUAS's have a demonstrable safety record and do not pose any threatto the general public or National Security. The FAA has the authorityto issue the exemption to SVP pursuantto the FederalAviation Act, 85 

### P.L. 726 (1958), as amended (the "ACT"). Commercial and Public Benefits granting SVP exemption request furthers the public interest to integrate commercially flown UAS's into the NAS, hence the passing ofthe ReformAct. Second, SVP conducts research into safe UAS operations everytime it flies one of its sUAS's. Flight Data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols.Allowing SVP to log moreflight time directly relates to its research and its abilityto further enhance current safety measures. Third, the public has an interest in reducing the dangerassociated with current aerial inspection methods, namely, resorting to physically climbing high orcompromised structures to inspect. Granting SVP exemption request substantially furthers the public's interest in ways known and currently unknown. Permitting SVPto immediatelyfly within the United States furthers advancements in publicly usabletechnologies or advancements in equipment's available to Law Enforcement personnel and first responders with state ofthe artequipmentthat does not cost millions ofdollars. 3Reasons why SVP exemption will not adversely affect safety or howthe exemption will provide a level ofsafety at least equal to existing rule: SVP exemptionwill not adversely affect safety. Quitethe contrary, forthe various reasons stated, permitting SVPto log more flight time will allow SVPti innovate and implement new and as ofyet undiscovered safety protocols. SVP sUAS's weigh less than 40 pounds complete with cameras. SVP only operate its sUAS's below400 feet in G space; SVP sUAS's land when they reach 25% battery power; SVP remote control pilots operate SVP sUAS's byvisual line ofsight (VSOL) SVP remote control pilots have video backup should they somehow lose sight ofthe sUAS; SVP staffs eachflightwith a remote control pilot and camera man/spotter; SVP sUAV's have GPSflight modeswhereby they hover in place and then slowly land if communication with the remote is lost or battery power is below25%; SVP sUAS's are equipped with 5 radar avoidance sensors assuring sUAS will not hit any objects in its assigned duties; SVP are equipped with a Parachute recovery system ifall systems were to fail, descending it to the ground slowly preventing serious damage; SVP only operates in secured areas that are strictly controlled, are awayfrom airports and populated areas: SVP conducts extensive briefings priorto flight, during which safety carries primary importance; SVP always obtains all necessary permissions and permits priorto operation; SVP provides a level ofsafety at least equal to existing rules, and in nearly every instance, greaterthan existing rules. It is importantto notethat absentthe integration ofcommercial UAS's into our NAS, helicopters are the primary means ofaerial photography. While the safety record is remarkably astounding, it is far saferto operate a battery powered lightweight UAS. SVP's Pilot in Command (PIC) is Retired ChiefWarrant Officer Ill Lt. Col. Perezwho has logged 3985 hours ofstick time in Helicopters. Providing an even further assurance ofsafety in the air.



### 4First, the potential loss of life is diminished because UAS's carry no people on board and SVP only operates in specific areas awayfrom mass populations. Second, there is nofuel on board a UAS and thus the potential forfire orexplosions is greatly diminished. Third, the small size, Radar avoidance sensor's and extreme maneuverability ofSVP s UAS's allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture required images, SVP sUAS's need not be so close to the objects they arefocused on. Accordingly, SVP sUAS's will operate at or above current safety levels. 

### Summary the FAA may publish in the Federal Register:
14 C.F.R. 21 and 14 C.F.R. 91 : Airworthiness Certificates, Manuals and the like. 14 C.F.R. 21, subpart H, entitledAirworthiness Certificates setforth requirements for procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of SVP sUAS's permits exemptionfrom Part 21 because SVP sUAS's meet an equivalent level ofsafety pursuantto Section 333 ofthe ReformAct. The FAA is authorized to exemptaircraftfrom airworthiness certificate requirements under both theAct (49 U.S.C. § 44701 (f) and
A. Section 333 ofthe ReformAct. Both pieces of legislation permitthe FAAto exempt UAS'sfrom airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. SVP sUAS's meet or exceed each ofthe elements. 14 C.F.R. § 91.7 (a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificatewill be applicable in the form contemplated by the FARs, this regulation is inapplicable.
14 C.F.R. § 91.9 (b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UAV's, this regulation is inapplicable. An equivalent level ofsafetywill be achieved by maintaining a manual attheflight operations center. The FAA has previously issued exemptionsto this regulation in Exemption Nos. 8607, 8737, 8738, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827.
14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as SVP sUAS's utilize electronic global positioning systems and internal gyroscopesto provide spatial coordination.
14 C.F.R. § 91.203 (a) and (b) provides forthe carrying ofcivil aircraft certifications and registrations. They are inapplicableforthe same reasons described above. The equivalent level ofsafetywill be achieved by maintaining such certifications and registrations atthe SVP flight operations. 

### 5B. 14 C.F.R. 

### § 45.23: Marking oftheAircraft Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. SVP UAS's are, by definition, unmanned. Theytherefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficultto place on such small aircraft. The FAA tias previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700. C. 14 C.F.R. 

### § 61.113: Private Pilot Privileges and limitations PIC Pursuantto 14 C.F.R. 

### §§61.113 (a) 

### &(b), private pilots are limited to non-commercial operations. SVP can achieve an equivalent level ofsafety as achieved by current Regulations because SVP UAS's do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though SVP pilotvetting and training programs (based upon completion ofan FAA approved Ground School and a selfadministered UASflight training program and internal procedure's) will. All Further, the risks attendantto the operation ofSVP UAS's is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

### § 61, et seq. D. 14 C.F.R. 

### § 91.119: Minimum SafeAltitudes
14 C.F.R. 

### § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows Helicopters to be operated at lower altitudes in certain conditions. SVP UAS's will never operate at an altitude greaterthan 400AGL. SVPwill, however, operate its UAS's in sectioned offareas with security perimeters, providing a level ofsafety at least equivalentto those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed OfSVP UAS's, an equivalent level ofsafetywill be achieved. E. 14 C.F.R. 

### § 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) &(b): Maintenance Inspections The above-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph C ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter." These Regulations only applyto aircraftwith an airworthiness certificate. Theywill not, therefore, apply to SVP should its requested exemption be granted. SVP conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment ofany damaged hardware. Therefore, an equivalent level ofsafety will be achieved. SVP has researched and developed its own designs.



### 6

-· --. -----------F. Summary SVP seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23 (b); 14 C.F.R. 

### §§ 61.113 (a) & (b); 14 C.F.R. 

### § 91.7 (a); 14 C.F.R. 

### § 91.9 (b)(2); 14 C.F.R. 

### § 91.103 (b); 14 C.F.R. 

### § 91.109; 14 C.F.R. 

### § 91.119;.14 C.F.R. 

### § 91.121; 14 C.F.R. 

### § 91.151 (a); 14 C.F.R. 

### §§ 91.203 (a) and (b); 14 C.F.R. 

### § 91.405 (a); 14 C.F.R. 

### § 91.407 (a)(1); 14 C.F.R. 

### § 91.409 (a)(2); and, 14 C.F.R. 

### §§ 91.417 (a) & (b) to commercially operate its fleet ofsmall unmanned vehicles and lightweight unmanned aircraftvehicles and to conduct its own research and to develop economic platforms for aerial survey, law enforcement, first responders, search and rescue. Granting SVP requestfor exemption will reduce current risk levels and thereby enhance safety. Further, SVP operates at lower altitudes and in controlled airspace. SVP has been analyzing flight data and other information in compiling novel safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and methods ofsafe flight. There are no people on board SVP UAS's and therefore the likelihood ofdeath or serious bodily injury is significantly limited. SVP operation of its UAS's, weighing lessthan 40 pounds and traveling at speeds lowerthan 40 knots in cordoned-offareas will provide at least an equivalent level ofsafety as that achieved under current FARs. SVP respectfully requests thatthe FAA grant its exemption request without delay. The FAA has the authorityto issue the exemption sought by SVP pursuantto the FederalAviationAct, 85 P.L. 726 (1958), as amended (the "Act").



### By

______________ __ Raymond Gorton 

# coo for: Sky Vision Photography 23 Sometimes Creek Road Sylva, NC 28779 828-508-8486 skyvision.photography