The Name and Address of the Applicant is: 

March 25, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. 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 

Sky Vision Photography LLC 

23 Sometimes Creek Road 

Sylva, NC 28779 

828-508-8486 

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.... 

__, 

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

and 14 C.F.R. Part 11 

Dear Sir or Madam: 

Sky Vision Photography LLC (SVP) located at 23 Sometimes Creek Road Sylva, NC 28779 

and Pursuant to Section 333 of the FAA Modernization and reform Act of 2012 (FAA Reform 

Act) and 14 C. F. R. Part 11, respectfully requests exemptions from several provisions of the 

Federal Aviation regulations ("FAR"), specifically Section 333 which authorizes the FAA to 

determine: 

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

visual line of sight do not create a hazard to users of the Nation Air Space system or 

the public or pose a threat to National Security; and 

2. Whether a certificate of waiver, certificate of authorization, or air worthiness certificate 

under Section 44704 of title 49, United States Code, is required for the operation of 

unmanned aircraft systems identified under paragraph (1). 

We are writing to request that SVP, LLC, the owner and operator of the small unmanned 

aircraft system, be exempted from the Federal Aviation 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 Federal Aviation Administration (FAA) as long 

as such operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required under Section 333. 

SVP is actively involved in the technical development of sUAS systems for structural 

inspections of bridges, construction sites, communication tower inspections, Search and 

Rescue, Fire and agriculture purposes. This service is to provide high definition aerial 

photography with small unmanned aircraft (sUAS's). 

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The substance of this request is essentially the same as that granted to ASTRAEUS 

AERIAL Regulatory Docket No. FAA-2014-3052 in that SVP is engaged in aerial 

photogra·phy of structures 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, primarily for use in 

inspections of towers, 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 other first 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 of sight with 5 radar avoidance sensors) sUAS's in tightly controlled and 

limited air space. 

Predetermined, specifically marked areas of operation, sectioned off locations will allow SVP 

to operate within current safety parameters and new ones being implemented. As identified, 

similar lightweight, remote controlled UAS's are legally operated by Amateurs with no flight 

experience, safety plan or controls in place to prevent catastrophe. 

Granting SVP's request comports with the Secretary of Transportation's (FAA Administrator's) 

responsibilities to not only integrate UAS's into the National Airspace System (NAS), but to 

"establish requirements for safe operation of said aircraft systems (UAS's) in the NAS under 

Section 333 of the Reform Act, SVP will conduct its operations in full compliance with the 

protocols described herein or as otherwise established by the FAA. 

The Extent of Relief SVP seeks and Reason it Seeks Such Relief: 

SVP submits this application in accordance with the Reform Act, 112 P. L. 95 §§ 331-334, 

seeking relief from any currently applicable FAR's operating to prevent SVP contemplated 

commercial inspections, research and other flight operations within the NAS. The Reform Act 

in Section 332 provides for such integration of civil unmanned aircraft systems in our NAS as 

it is in the public's interest to do so. SVP lightweight sUAS's meet the definition of "small 

unmanned aircraft" as defined in Section 331 and therefore the integration of SVP lightweight 

sUAS's are expressly contemplated by the Reform Act. 

SPV .would like to operate its lightweight sUAS's prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such craft. The Reform act guides the 

Secretary in determining the types of UAS's that may operate safely in our NAS. · 

The weight, size, speed and overall capabilities of the UAS; whether the UAS will be operated 

near airports or populated areas; and, whether the UAS will be operated by line of sight. 

112 P.L. 95 § 333 (a). Each of these mitigates in favor of an 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 less than 25 pounds, 

including camera and all equipment. Each of SVP's small unmanned aircraft is designed 

primarily to hover in place and operate at less than 40 knot maximum speed. 

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They are capable of vertical and horizontal operations, but operate only within line of sight of 

the operator (PIC, pilot in command). 

Such that, at minimum, two SVP personnel govern the safe flight of an 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, SVP fleet are programmed, in some instances, to slowly follow a predetermined set 

of waypoints to return to a safety point if communications are lost. 

Each sUAS have a backup parachute rescue system ensuring if that all systems fail and all 

power systems go offline, parachute will open automatically thus preventing damage of a 

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 of small unmanned system will not "create. a hazard to users of the 

National Airspace Systems or the public". 112 P.L. § 333 (b). 

Given the small size and weight of SVP 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 threat to 

the general public or National Security. The FAA has the authority to issue the exemption to 

SVP pursuant to the Federal Aviation 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 of the Reform Act. 

Second, SVP conducts research into safe UAS operations every time 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 more flight time 

directly relates to its research and its ability to further enhance current safety measures. 

Third, the public has an interest in reducing the danger associated with current aerial 

inspection methods, namely, resorting to physically climbing high or compromised structures 

to inspect. 

Granting SVP exemption request substantially furthers the public's interest in ways known 

and currently unknown. Permitting SVP to immediately fly within the United States furthers 

advancements in publicly usable technologies or advancements in equipment's available to 

Law Enforcement personnel and first responders with state of the art equipment that does not 

cost millions of dollars. 

3 
Reasons why SVP exemption will not adversely affect safety or how the exemption will 

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

SVP exemption will not adversely affect safety. Quite the contrary, for the various reasons 

stated, permitting SVP to log more flight time will allow SVP ti innovate and implement new 

and as of yet undiscovered safety protocols. 

SVP sUAS's weigh less than 40 pounds complete with cameras. 

SVP only operate its sUAS's below 400 feet in G space; 

SVP sUAS's land when they reach 25% battery power; 

SVP remote control pilots operate SVP sUAS's by visual line of sight (VSOL) 

SVP remote control pilots have video backup should they somehow lose sight of the sUAS; 

SVP staffs each flight with a remote control pilot and camera man/spotter; 

SVP sUAV's have GPS flight modes whereby they hover in place and then slowly land if 

communication with the remote is lost or battery power is below 25%; 

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 if all systems were to fail, descending it 

to the ground slowly preventing serious damage; 

SVP only operates in secured areas that are strictly controlled, are away from airports and 

populated areas: 

SVP conducts extensive briefings prior to flight, during which safety carries primary 

importance; 

SVP always obtains all necessary permissions and permits prior to operation; 

SVP provides a level of safety at least equal to existing rules, and in nearly every instance, 

greater than existing rules. It is important to note that absent the integration of commercial 

UAS's into our NAS, helicopters are the primary means of aerial photography. While the 

safety record is remarkably astounding, it is far safer to operate a battery powered lightweight 

UAS. 

SVP's Pilot in Command (PIC) is Retired Chief Warrant Officer Ill Lt. Col. Perez who has 

logged 3985 hours of stick time in Helicopters. Providing an even further assurance of safety 

in the air. 

4 
First, the potential loss of life is diminished because UAS's carry no people on board and SVP 

only operates in specific areas away from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. 

Third, the small size, Radar avoidance sensor's and extreme maneuverability of SVP 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 are focused 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, entitled Airworthiness Certificates set forth 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 exemption from Part 

21 because SVP sUAS's meet an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from airworthiness certificate 

requirements under both the Act (49 U.S.C. § 44701 (f) and 

A. Section 333 of the Reform Act. 

Both pieces of legislation permit the FAA to exempt UAS's from airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to 

areas such as airports and dense populations. SVP sUAS's meet or exceed each of the 

elements. 

14 C.F.R. § 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this regulation 

is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots 

or passengers, and given the size of the UAV's, this regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a manual at the flight operations center. 

The FAA has previously issued exemptions to 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 gyroscopes to provide spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining such certifications and registrations at the SVP 

flight operations. 

5 
B. 14 C.F.R. § 45.23: Marking of the Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. SVP UAS's are, by definition, unmanned. They therefore do not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft. The FAA tias previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 

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

PIC Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. SVP can achieve an equivalent level of safety 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 pilot vetting and training 

programs (based upon completion of an FAA approved Ground School and a selfadministered UAS flight training program and internal procedure's) will. All Further, the risks 

attendant to the operation of SVP 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 Safe Altitudes 

14 C. F. R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

Helicopters to be operated at lower altitudes in certain conditions. SVP UAS's will never 

operate at an altitude greater than 400 AGL. SVP will, however, operate its UAS's in 

sectioned off areas with security perimeters, providing a level of safety at least equivalent to 

those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed 

Of SVP UAS's, an equivalent level of safety will 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 other things, aircraft owners and operators to 

"have [the] aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph C of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter." 

These Regulations only apply to aircraft with an airworthiness certificate. They will 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 of any damaged hardware. Therefore, an equivalent level of safety 

will be achieved. SVP has researched and developed its own designs. 

6 

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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 

of small unmanned vehicles and lightweight unmanned aircraft vehicles and to conduct its 

own research and to develop economic platforms for aerial survey, law enforcement, first 

responders, search and rescue. Granting SVP request for 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 of safe flight. 

There are no people on board SVP UAS's and therefore the likelihood of death or serious 

bodily injury is significantly limited. SVP operation of its UAS's, weighing less than 40 pounds 

and traveling at speeds lower than 40 knots in cordoned-off areas will provide at least an 

equivalent level of safety as that achieved under current FARs. 

SVP respectfully requests that the FAA grant its exemption request without delay. The FAA 

has the authority to issue the exemption sought by SVP pursuant to the Federal Aviation Act, 

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