1 | Page UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATI ON FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

INTHE MATTER OF THE PETITION FOR EXEMPTI ON OF:

SKYS THE LIM IT PHOTOGRAPHY, LL C
FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTI ONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCIAL OPERATION OF DJ I INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERN IZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on November 25 , 2015

SKYS THE LIM IT PHOTOGRAPHY, LL C

Stephen Momot 3301 NW 64 th St Fort Lauderdale, Florida 33309 (954)

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- 67332 | Page TABLE OF CONTENTS Page GLOSSARY OF ABBREVIAT IONS

................................ ................................ ................................ ................................ 3
SUMMARY

................................ ................................ ................................ ................................ ............ 4
IN TRODUCTION AND INTERESTS OF PETITIONER

................................ ................................ .... 4
BACKGROUND

................................ ................................ ................................ ................................ .... 4
BASI S FOR PETITION

................................ ................................ ................................ .......................... 4
NAME AND ADDRESS OF PETITIONER

................................ ................................ .............. 6
THE SPECIFI C SECTIONS OF 14 C.F.R. FROM WHI CH SKYS THE LIM IT PHOTOGRAPHY SEEKS EXEMPTI ON

................................ .................. 6
THE EXTENT OF RELIEF SKYS THE LIMIT PHOTO SEEKS AND THE REASON SKYS THE LIMIT PHOTO SEEKS THE RELIEF

................................ ......... 9
THE REASONS WHY GRANTING SKYS THE LIM IT PHOTO REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ................................ .............. 11
THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ ............................. 13
CONCLUSION

................................ ................................ ................................ ................................ ....... 20
APPENDIX

................................ ................................ ................................ ................................ ............. 213 | Page

GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing DJI UAV manufacturer ESC Electronic speed control FPV First Person View LI

- PO Lithium Poly mer battery RCV Radio Controlled vehicle4 | Page **SUMMARY**
SKYS THE LIMIT PHOTOGRAPHY, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit SKYS THE LIMI T PHOTOGRAPHY, LLC to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography f or Marketing, film sets, real estate photography , commercials, special events, wedding cinematography , and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** My n ame is STEPHEN MOMOT , and I am a drone builder and operator (pilot) with expertise and knowledg e in all aspects of building programing and operating multiple ty pes of UAS'S along with camera set up and operation. SKYS THE LIM IT PHOTO GRAPHY , LLC also provides clients with the highest quality

dig ital content for use in their commercial, personal, and non - profit multimedia projects. SKYS THE LIMI T PHOTO GRAPHY has 15 ye ars of RCV experience and 3 ye ars of radio controlled helicopter experience. SKYS THE LIMI T PHOTO GRAPHY is recognized as an expert in this field and has repaired multiple drone

. The objective of SKYS THE LIM IT PHOTOGRAPHY aerial video and photography operations is to provide high quality imaging for a variety

of commercial, public, and residential uses, for clients in a safe manner recognizing and remaining at a proper distance from obstacles and the public at all times. SKYS THE LIM IT PHOTO GRAPHY will also provide knowledge of UAS and promote safe UAS operations.
**BACKGROUND** Unmanned Aircraft Sy stems: DJIInspire 1 UASs SKYS THE LIM IT PHOTOGRAPHY seeks an exemption to operate DJ I sy stems for compensation or hire within the NAS. The DJ I Inspire 1 is a vertical take off and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone sy stems. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 4 2 knots. The DJ I Inspire 1 UAS is equipped with four main rotors; driven by L ithium Poly

mer battery

p owered by e lectric motors. The DJIInspire 1 UAS that will be operated by Stephen Momot will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 4 5, Id entification and Registration Markings.

**BASIS FOR PETITION** Petitioner, SKYS THE LIM IT PHOTOGRAPHY , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commerciall y operate the DJ I Inspire 1 UAS in the National Airspace S ystem (NAS), and for an5 | Page

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91 .7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Sky ’s The Limit Photo’s operat ion of DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Skys The Limit Photo requests relief from Sections 91.405(a), 91. 407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate.
SKYS THE LIM IT PHOTO submits that the requested relief is proper since an equivalent level of safety will be ensured. SKYS THE LIMIT PHOTO will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the method s, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJIInspire 1 Instruction Manual). Furthermore, SKYS THE LIMIT PHOTO will document and maintain all maintenance records for the DJ I Inspire 1 UASs.
Reli ef from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y SKYS THE LIMIT PHOTOGRAPHY to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with this exemption , including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
SKYS THE LIM IT PHOTOGRAPHY seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJ I Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, SKYS THE LIM IT PHOTOGRAPHY submits that he will ensure that the DJ I Inspire 1UAS are in an airworthy condition, prior to every

flight, by determinin g that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJIInspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.
SKYS THE LIM IT PHOTOGRAPHY also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, DJ I Inspire 1 UAS will not have a ty pical barometric altimeter onboard. However, altitude information of the DJ I In spire 1UAS will be provided to the PI C via Glo bal Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with SKYS THE LIM IT PHOTOGRAPHY operation of the DJ I Inspire 1 UAS within vis ual line of sight, at or below 4 00 feet AGL , will ensure a level of safety equivalent to Section 91.121. Additionally , SKYS THE LIM IT PHOTOGRAPHY seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. SKYS THE LIM IT PHOTOGRAPHY submits that safety will not be affected by

operation of the DJ I Inspire 1 UA S during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.6 | Page

In accordance with 14 C.F.R. § 11.81, SKYS THE LIM IT PHOTOGRAPHY provid es the following information in support of its petition for exemption:

**A. Name And Address Of The Petitioner.** The name and address of the Petitioner and point of contact is: SKYS THE LIM IT PHOTOGRAPHY OWNER/OPERATOR: STEVE MOMOT 3301 NW 64 TH ST FORT LAUD ERDALE, FLORIDA 33309 (954 )

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- 6733 Email: SKYSTHELIMITPHOTO@OUTLOOK.COM **B. The Specific Sections Of 14 C.F.R. From Which SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption.** 
**1. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, s ubsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilo t may , for compensation or hire, act as PI C of an aircraft in connection with any business or employment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.
**2. SKYS THE LIMIT PHOTOGRAHPY**  **Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworth y condition.
**3. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may

be, by reference to an altimeter that is set, when operating

—7 | Page

(1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. **4. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirements Of Section**  **91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b ) No person may begin a flight in a rotorcraft under VFR con ditions unless (considering
w ind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing a nd, assuming normal cruising speed, to fly after that for at least 20 minutes.
**5. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirement Of**  **Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provi ded in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]
**6. SKYS**  **THE LIMIT**  **PHOTOGRAPHY Seeks**  **Exemption From**  **The Requirements**  **Of Section 91.407(a)(1**  **)**
Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may

o perate an y aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to se rvice by a p erson authorized under § 43.7 of this chapter [.]
**7. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections, subsection (a), states the following:8 | Page

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to ser

vice b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
**8. SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Exemption From The Requirements Of Sections 91.417(a)**  **And 91.417(b).** Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) R ecords of the maintenance, preventive maintenance, and alt eration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A d escription (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, prop eller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained.9 | Page (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If th e AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propelle rs, and appliance s. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar af ter the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
**C. The Extent Of Relief**  **SKYS THE LIMIT PHOTOGRAPHY Seeks And The**  **Reason SKYS**  **THE LIMIT PHOTOGRAPHY Seeks The Relief.** 
**1. Extent Of Relief**  **SKYS THE LIMIT PHOTGRAPHY Seeks And The Reason**  **SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot p rivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

hour and currenc y re quirements, to conduct the proposed UAS flight operat ions for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, act as PI C of an aircra ft in connection with any business or employ

ment if: (1) The flight is onl y incidental to that business or employment; and (2) The aircraft does not carry

passengers or property for compensation or hire. As set forth more full y below, SKYS THE LIMIT PHOT OGRAPHY submits that an equivalent level of safety

will be maintained because no PI C will be allowed to operate the DJ I Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operat e either the DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, SKYS THE LIMI T PHOTOGRAPHY submits that all flights of the DJ I Inspire 1 UAS , conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to SKYS THE10 | Page

LIM IT PHOTOGRAPHY business; and (2) will not carry passengers or property for compensation or hire.

**2. Extent Of Relief**  **SKYS THE LIMIT PHOTOGRAPHY Seeks And The Reason**  **SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Relief From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow SKYS THE LIMI T PHOTOGRAPHY to determine that the DJ I Inspire 1 UAS are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., SKYS THE LIMIT PHOTOGRAPHY Aerial Operations Manual, Monthly Maintenance Lo g, and DJIInspire 1 Instruction Manual). SKYS THE LIM IT PHOTOGRAPHY seeks the requested relief because the DJ I Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, SKYS THE LIM IT PHOTOGRAPHY will ensure that the DJ I Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.
**3. Extent Of Relief**  **SKYS THE LIMIT PHOTOGRAPH Y**  **Seeks And The Reason SKYS**  **THE LIMIT PHOTOGRAPHY Seeks Relief**  **From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), SKYS THE LIM IT PHOTOGRAPHY seeks the requested relief because the DJ I Inspire 1 UA S altimeter may

be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, befo re each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply

with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of safety will be maintained since the DJ I Inspire 1 UA S are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS.
**4. Extent Of Relief**  **SKYS THE LIMIT PHOTOGRAPHY Seeks And The Reason**  **SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJ I Inspire 1 UA S during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. SKYS THE LIM IT PHOTOGRAPHY seeks the requested relief because without11 | Page

an exemption from Section 91.151(b), the flight ti me duration of the battery powered DJIInspire 1 UA S will severel y constrain the practicality of any aerial video or still photo flight operations that SKYS THE LIM IT PHOTOGRAPHY proposes to conduct pursuant to this Petition. Significantl y, as set forth be low, the technical specifications of the DJ I Inspire 1 UAS , the DJ I Inspire 1 operating documents, and SKYS THE LIM IT PHOTOGRAPHY proposed operating limitations, ensure that SKYS THE LIMIT PHOTOGRAPHY will safel y operate the battery powered DJIInspire 1 UA S during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly

for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y af ter that for at least 4.5 minutes.
**5. Extent Of Relief**  **SKYS THE LIMIT PHOTOGRAPHY Seeks And The Reason**  **SKYS THE LIMIT PHOTOGRAPHY**  **Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y appl y to aircraft with an airworthiness certificate, SKYS THE LIMIT PHOTOGRAPHY requests relief from these Sections because the DJ I Inspire 1 UAS do not require airworthiness certificate. As set forth more fully

below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, SKYS THE LIM IT PHOTOGRAPHY will use trained technicians to perform maintenance , alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., SKYS THE LIM IT PHOTOGRAPHY Aerial Operations Manual, Monthly Maintenance L og, and DJ I Inspire 1 Instruction M anual). Furthermore, SKYS THE LIMI T PHOTOGRAPHY will document and maintain all maintenance records for the DJ I Inspire 1 UAS.
**D. The Reasons Why Granting**  **SKYS THE LIMIT PHOTOGRAPHY Request Would Be In The**  **Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the present Petition will further the public interest b y allowing SKYS THE LIMIT PHOTOGRAPHY to safely , efficiently , and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally , use of the and DJ I Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused b y pilot error and provide significant benefits to the economy . Notabl y, the benefits of SKYS THE LIM IT PHOTOGRAPHY proposed operation of the DJ I Inspire 1 UAS will be realized without implicating any

privacy issues.
**1. The Public Will Benefit From Decreased Congestion Of The NAS.** 
The DJ I Inspire 1 UA S IS battery powered and serve as a safe, ef ficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airp orts caused b y arriving and departing aircraft will be reduced. The DJ I Inspire 1 UA S do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video12 | Page

and photograph y missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.**  Conducting aerial acquisitions with the DJIInspire 1 UASs, instead of manned aircraft, will greatly benefit the public b y drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By

using battery

power and electric motors, the DJIInspire 1 UAS produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty picall y utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UA S , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Inspire 1 UAs (weighing approximately 6 pounds 7.5 ounces respectivel y, at maximum gross weight with length 17.3 inche s respectivel y, width 17.7 inches respectivel y, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (wei ghing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).
**3. Performing Aerial Video and Photography Operations With The**  **DJI Inspire 1 UAS Will Benefit The Economy.** 

In addition to being safe and efficient, the DJ I Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UAS will allow United States based UAS companies to remain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and al ternative technology in order to remain competitive. Operating the battery powered DJ I Inspire 1 UAS is one such technology that not only

allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility without th e high operational cost of a traditional manned aircraft. By operating the DJ I Inspire 1 UAS, UAS companies can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute t o growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJIInspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows com panies to invest in research and development in order to remain competitive both in the United States and abroad.13 | Page

**4. There Are No Privacy Issues.**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, SKYS THE LIM IT PHOTOGRAPHY proposed operation of the DJ I Inspire 1 UASs will not implicate any privacy issue s. Specifically , the DJ I Inspire 1 UASs will be operated only in compliance w ith operating documents (i.e., SKY’S THE LIMIT PHOTOPGRAPHY Aerial Operations Manual, Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.
**E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The**  **Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  **SKYS THE LIMIT PHOTOGRA PHY**  **Seeks Exemption.**
**1. Reasons Why The**  **DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraf

t and its operation, SKYS THE LIM IT PHOTOGRAPHY ’ operation of the DJ I Inspire 1 UASs meet the conditions of FMRA Sectio n 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 stat es the following, in part: (a) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

--In making the determination unde r subsection (a ), the Secretary shall determine, at a minimum

— (1 ) which types of 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 national airspace system or the public o r pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identi fied under paragraph (1).14 | Page

(c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe o peration of such aircraft systems in the national airspace system. In seeking this exemption, SKYS THE LIM IT PHOTOGRAPHY submits that the DJ I Inspire 1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the charact eristics of the DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The**  **DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.** 
T he DJ I Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

**(i) T**  **echnical Specifications Of The DJI Inspire 1 UASs.** 
The t echnical specifications of the DJ I Inspire 1 UASs are set forth b y the DJIInspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.

**(ii) The**  **DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.** 
The DJ I Inspire 1 UASs may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Inspire 1 UASs is provided at pages 25

- 35 of the pages 12

- 16 and 45

- 50 of the DJIInspire 1 User Manuals, attached hereto as Appendix A

. **(iii) The**  **DJI Inspire 1 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or**  **Navigation.**
When the Control L ink is lost, the DJIInspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and wi ll descend to the takeoff position and shutdown. A complete description of the Failsaf e Functions of the DJ I Inspire 1 UAS are set forth at pages 27 through 29 and for the DJIInspire 1 at pages 13 through 15 of the DJ I In spire 1 User Manuals, attached he reto as Appendix A

.

**(iv) The**  **DJI Inspire 1 GCS And It’s Operation.** A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at pages 40 through 47 of the DJ I Inspire 1 User Manual. DJ I Inspire 1 User Manuals are att ached hereto as Appendix A

.15 | Page **b Flight Operations Of**  **DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.** 
SKYS THE LIM IT PHOTOGRAPHY will only utilize certificated pil ots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJ I Inspire 1 UASs. Additionally , a safety observer will assist all pilots during flight time.

**c Flights Of**  **DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, SKYS THE LIM IT PHOTOGRAPHY proposes to commerciall y operate DJ I Inspire 1 UASs for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations:
1. Operations authorized b y this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJIInspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography

. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in fee t AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certif icate. 6. The use of first person view (FPV) b y the PI C or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PI C alway s maintains VLOS capability . Th e SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstruction s and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow th e procedures as outlined in its operating documents. The operator may update or16 | Page

revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the ope rator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to en sure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a c ondition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must ac count for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, repl acement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overh aul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The operator may

not permit any

PI C to operate unless the PI C meets th e operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, train ing operations may onl y be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with app ropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 18. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at17 | Page

ni ght is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 19. The UA may

not operate within 5 nautical miles of an airport reference point 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 b y the operator’s COA. The letter of agreement with the air port management must be made available to the Administrator upon request. 20. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. 21. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22. The PI C must abort the flight in the event of unpredicted obstacles o r emergencies in accordance with the operating documents. 23. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operat or to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 25. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 26. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Admi nistrator or any law enforcement official upon request. 28. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times. 29. The UAS may

not be operated b y the PIC from any moving device or vehicle. 30. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficient ly protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. I f a situation arises where18 | Page nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 31. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for e ach flight to be conducted. 32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
**2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)**  **Would Not Adversely Affect Sa fety.**  SKYS THE LIM IT PHOTOGRAPHY submits that the equivalent level of safety established b y Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the DJ I Inspire 1 UASs unless that PI C has demonstrated, by meeting mi nimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehic les and structures. Considering SKYS THE LIM IT PHOTOGRAPHY ’ proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the DJIInspire 1 UAS, SKYS THE LIMIT PHOTOGRAPHY submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for SKYS THE LIM IT PHOTOGRAPHY ’ specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e. g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). SKYS THE LIM IT PHOTOGRAPHY will not allow any PIC to operate the DJ I Inspire 1 UAS unless that PI C has d emonstrated, b y meeting minimum flight

- hour requirements or the DJ I Inspire 1 UAS training and currency requirements, that the PI C is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

m aneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the19 | Page

exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during SKYS THE LIM IT PHOTOGRAPHY ’ proposed operat ions. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pil ot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarific ation, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft tim e. In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency

in the skills necessary

to safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Trainin g, proficiency, and experience

building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, SKYS THE LIM IT PHOTOGRAPHY will ensure safe operations by not allowing any PIC to operate the DJIInspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consi stent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.20 | Page **CONCLUSION** SKYS THE LIM IT PHOTOGRAPHY seeks an exemption pursuant to 14 C.F.R. § 11. 61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Inspire 1 UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography ov er certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing SKYS THE LIM IT PHOTOGRAPHY to safel y, efficientl y , and economically operate the DJ I Inspire 1 UASs commerciall y within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, SKYS THE LIM I T PHOTOGRAPHY respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), an d permit SKYS THE LIMIT PHOTOGRAPHY to operate the DJ I Inspire 1 UASs commerciall y for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: June 12, 2015

Submitted by ,

____________________ ____________ SKYS THE LIM IT PHOTOGRAPHY Stephen Momot 3301 NW 64 th Street Fort Lauderdale, FL 33309 Cell: 954.369.6733 Email: s.momot@hotmail.com21 | Page **APPENDIX A**
DJII NSPIRE 1 TECHNICALSPECIFICATIONS
SKYS THE LIM IT PHOTOGRAPHY only utilizes safe and reliable UASs. DJIis an industry leader in small UAS production. DJIUASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Param eters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked m onitor (smart phone/tablet devices) All specifications can be found in the attached user manual or at http://www.dji.com/product/inspire

1/spec