## Richard E. Kozlowski, Esq. 2286 Hankinson Road Granville, OH 43023 (614) 354

- 6062 rich@sinokoz.com

June 8 , 2015
U.S. Department of T

ransportation, Docket Operations We st Building Ground Floor, Room W12

- 140 1200 New Jersey

Av enue, SE Wa shington, DC 20590

**Re: SkyOhio,**  **LLC /**  **Request for**  **e xemption**  **under**

**S ection**  **333 fr** **om :**  **14 CFR**  **Pa rt**  **21, Subpart**  **H ;**  **14 CFR**  **43.7 ;**  **14 CFR**  **43.1 1**  **; 14**  **CFR 45.1**  **1 ;**  **14 CFR**  **45.27 ;**  **14 CFR**  **45.29 ;**  **14 CFR**  **61.23 (a)**  **; 14**  **CFR 61.1**  **13 (a)**  **and (b)**  **; 14**  **CFR 91.7(a)**  **; 14**  **CFR 91.9(b)(2)**  **; 14**  **CFR 91.9(c)**  **; 14**  **CFR 91.103(b)(2)**  **; 14**  **CFR 91.105**  **; 14**  **CFR 91.109**  **; 14**  **CFR 91.1**  **13(b) ;**  **14 CFR**  **91.1 19(b)**  **and (c)**  **; 14**  **CFR 91.121**  **; 14**  **CFR 91.151**  **(a) ;**  **14 CFR**  **61.203 (a)**  **and (b)**  **; 14**  **CFR 61.215**  **; 14**  **CFR 61.403**  **; 14**  **CFR 91.405 (a) and (d) ;**  **14 CFR 91.407 (a)(1) ;**  **14 CFR 91.409 ;**  **14 CFR 91.417 (a) and (b)** Dear Sir or Madam:
In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 1 1, Ihereby a pply , as attorney

f or SkyOhio, LLC (“**SkyOhio** ”) and on behalf of SkyOhio, for an exemption from the listed Federal Av iation Regulations ( “**FA R**  ” s ) to allow commercial use of SkyOhio’ s Small Unmanned Aircraft Systems ( “**SUAS**” s), so long as such operations are conduc ted within and under the conditions outlined herein or as may b e established by

the FAA from time to time as required by Section 333. SkyOhio is reque sting this exemption because:
1. Existing regulations will severel y hinder and burden SkyOhio ’s operations; 2. SkyOhio can pro vide and execute a level of competence and safety that is, at the very l east, equal to (or , in many

cases , greater than) th ose provided by existing guidelines; and 3. The request is in the public interest and local benefit.Approval of this exemption for SkyOhio will allow commercial operations of its SUASs for the

purpose of videography

and photography. The requested exemption should be granted because operation of small S UASs, weighing approximately 7 pounds , inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level o f safety , as Congress inten ded, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than convention al operations conducted with helicopters and fixed

- wing aircraft weighing thousands of pounds and carrying highl y flammable fuel, and operating in close proximity to the ground, power lines, transmission towers, pipelines, and people. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, oper ational capability

, proximity

to airports, proximity

to populated areas, and operation within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow speeds and close to the ground in order to more safel y and efficientl y conducts its operations without undue risk to the operators and persons and property on the ground. The requested exemption will permit SkyOhio to operate its S UASs under closely m onitored conditions in airspace that is confined/limited (<1,000 feet in any direction and <400 feet altitude) , predetermined and agreed upon, and controlled to access and would prov ide safety enhancements to the already safe operations of those aircraft of similar size, weight, speed, and operating capability that have been granted entry into the NAS via the rules in Academy of Model Aeronautics ( “ **AMA** ” ) National Aircraft Safety Code. Approval of this exemption would thereby greatl y enhance safety and fulfill the Secretary

o f Transportation’ s (the “**Secretary** ”’ s ) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system” per Section 333 (c) of the Reform Act. SkyOhio is requesting exemption from the following regulations: **14 CFR Part 21, Subpart H 14 CFR 43.7**  **14 CFR 43.1 1**  **14 CFR 45.1 1**  **14 CFR 45.27 14 CFR 45.29**  **14 CFR 61.23 (a) 14 CFR 61.1**  **13 (a) and (b) 14 CFR 91.7(a)**  **14 CFR 91.9(b)(2) 14 CFR 91.9(c)**  **14 CFR 91.103(b)(2) 14 CFR 91.105**  **14 CFR 91.109 14 CFR 91.1**  **13(b) 14 CFR 91.1**  **19(b) and (c) 14 CFR 91.121**  **14 CFR 91.151 (a) 14 CFR 61.203 (a) and (b)**  **14 CFR 61.215 14 CFR 61.403**  **14 CFR 91.405 (a) and (d)**  **14 CFR 91.407 (a)(1) 14 CFR 91.409**  **14 CFR 91.417 (a) and (b)**

The FAA’ s authority to issue ex emptions from operating rules, and the Secretary ’s a uthority granted b y S ection 333 of P .L . 1 12

- 95, Special Rules for Certain Unmanned Aircraft S ys tems, providean opportunity to authorize certain SUAS operations in the National Airspace System ( “ **NAS**” ) prior to implementation of the SUAS rule. This incremental step will allow SkyOhio to safely and legall y enter into the NAS. Section 333 of the Reform Act grants the Secretary a uthority to determine (1) if an unmanned aircraft system, as a result of its size, weight, speed, operational capability , proximity

to airports and populated areas, and operation within visual line of sight ( “ **VLOS**” ) does not create a hazard to users of the NAS or the public or pose a threat to national security , and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC 44704 is requir ed for the o peration of civil (non

- governmental) S UASs. Therefore, if the Secretary determines that such vehicles “may operate safel y in the national airspace system, the Secretary s hall establish requirements for the safe operation of such aircraft in the national airspace s ys tem”. This exemption application is expressly submitted to fulfill Congress’g oal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider whether certain unmanned aircraft systems may operate safel y in the NAS before completion of the rule

- making r equired under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which ty

pes of S UASs do not create a hazard to users of the NAS, to the public, or pose a threat to national security

. **I. SkyOhio**  **Overview** SkyOhio’ s business contact information is as follows: SkyOhio, LLC 6895 Epic Drive New Albany

, OH 43054 SkyOhio uses S UAS s (qu ad

- copters) weighing less than 7 pounds fully l oaded (camera and battery). Quad

- copters are small, agile S UASs with the ability to hover and move in the vertical and horizontal planes simultaneously

. SkyOhio will operate only in VL OS , and only in tightly c ontrolled and limited airspace. The S UA Ss are capable of operating at speeds of up to 49 MPH, but are routinely operated at much lower speeds, usually at a standstill for imaging. They are most frequentl y operated below 200 feet above ground level ( “ **AGL** ” ), and never over 400 feet AGL. SkyOhio's exemption request would permit a commercial operation of its SUAS s for aerial photography and videography in tightl y controlled and limited airspace. Aerial photography and videography

s ervices will be of

fered to homeowners, realtors, commercial property owners/managers, homebuilders, and/or ranchers and farmers for use in, but not limited to, real estate and business marketing and safer inspections of real property . All operations will be conducted on private property and with the written and/or oral permi ssion of the property owner(s), and always with privacy in mind. Operations will always be conducted in areas that are clear of all people, except the pilot in command ( “ **PIC** ” ) and the PI C’ s helper(s).Such operations will ensure that the SUAS will “not create a hazard to users of the national airspace

system or the public”.
**II. SkyOhio’**  **s Air** **craft** SkyOhio operates and uses the Phantom 3 P rofessional by DJ I (see Exhibit 1 ) and the Inspire 1 b y DJI (see Exhibit 2 ). The specifications for the Phantom 3 Professional are as follows : Remote Controller Operating Frequency : 2.400 GHz

- 2.483 GHz Live V iew W orking Frequency : 2.400 GHz I SM We ight (Battery

& Propellers Included): 1280 g Max. Ascent Speed: 5 m/s Max. Descent Speed: 3 m/s Max. Speed: 16 m/s (A

TTImode, no wind) Max. Distance: 2000m (outdoors and unobstructed) Max. Flight Time: Approximately 23 minutes GPS Mode: GPS/GL ONASS Operating Temperature Range: 0°C to 40°C Battery : 600 0 mAh LiPo 2S Transmitter Power (EIRP) FCC: 20 dbm; CE:16 dbm Fail

- S afe Automatic Return

- to
- Home The specifications for the Inspire 1 are as follows : Remote Controller Operating Frequency : 2.400 GHz

- 2.483 GHz Live V iew W orking Frequency : 2.400 GHz I SM We ight: 2935 g Max. Ascent Speed: 5 m/s Max. Descent Speed: 4 m/s Max. Speed: 22 m/s (A

TTImode, no wind) Max. Distance: 2000m (outdoors and unobstructed) Max. Flight Time: Approximately 18 minutes GPS Mode: GPS/GL ONASS Operating Temperature Range:

- 10°C to 40°C Battery : 6000 mAh LiPo 2S Transmitter Power (EIRP) FCC: 20 dbm; CE:16 dbm Fail

- S afe Automatic Return

- to
- Home The DJ I Phanto m 3 Professional and Inspire 1 have multiple factory

- installed safety features. These features serve to minimize any risk posed by

loss of control, loss of transmission signal or loss of orientation. These features include, but are not limited to: GPS controlled positioning allows the SUAS to "know" its location, attitude and altitude.

 RT H (return to home) when triggered, will bring the SUAS back and land it autonomously in the event the PIC is unable to do so.
 FA ILS AFE will return the SUAS an d land it autonomously should the control transmission get cut of f for any reason.
 Auto

- Takeof

f and Landing These highl y advanced capabilities will ensure that the SUASs can be safely operated and “not create a hazard to users of the national airspace s ys tem or the public.”
**III. Pr** **e -**  **flight Action Plan**  The PI C will follow comprehensive pre - flight and flight checklist s to ensure that the SUAS is in a condition for and will maintain safe fli ght. This plan will be improved as needed in order to ensure all known safety precautions and/or safety precautions suggested by the manufacturer are being accounted for

. BASE CAMP CHECKLIST

- Before Traveling to Location 1. Confirm controller firmware is up to date 2. Confirm SUAS firmware is up to date 3. Inspect SUAS for obvious defects 4. Confirm batteries are fully charged 1. SUAS Batteries 2. Controller batteries 3. iPad 5. Confirm previously

shot footage has been backed up and SD card is formatted PRE

- FLIGHT CHECKLIST

- On Location 1. Mark of

f an area with traf

fic cones that has a 20 ft. radius, approximately 3 0 ft. from the PI C , that will be used as the “home position” for the SUAS to return 2. Remove SUAS , place in safe launch and recover position 3. Setup controllers

- Confirm iPad Monito r brightness is set to high & hoods are installed 4. Angle controller antennas upward 5. Turn on controllers 6. Turn on SUAS 7. Exit travel mode 8. Install camera 9. Calibrate compass 10. Install propellers 11. Adjust minimum return height 12. Confirm a clear frequency is chosen 13. Power down SUAS and controllers 14. Hold safety meetingSAFETY MEETING TALKING POINTS

1. All bystanders must stand at least 10ft behind the PI C and at least 20ft from the home position during flight. 2. Everyone should keep their eyes on the SUAS AT ALL TIMES whil e it is in flight so that if something goes wrong, they are aware and ready

to react in an instant. 3. All bystanders must keep conversation during flight to a minimum

– Only the PI C and the PI C’s helpers should be talking during flight so that the PI C can have complete focus and can hear the helpers

. FLIGHT CHECKLIST 1. Power on controllers and SUAS 2. Confirm flight area is clear of people 3. Warn bystanders of imminent takeoff 4. Hover close for 20 seconds. Look/listen for defects 5. Confirm expected stick operation 6. Moni tor battery

power 7. Keep line

- of

- sight with SUAS if possible 8. Monitor signal strength

**IV .**  **Pr eventative Maintenance** 
A comprehensive preventative maintenance plan will be fo llowed in order to ensure the SUAS’ s firmware is up - to
- date, the batteries are in good health, and the aircraft itself is always ready for safe fli ght. (SkyOhio follows suggested maintenance in attached DJ I User Manuals

- See Exhibits 1 and 2 )
**V. PIC**  **Qualifications** The PI C does not hold an airman certificate or medical ce rtification. Since the SUAS is similar in size, weight, speed and operating capability a s those currentl y allowed to be fl own for hobby /recreation, holding the PI C to those same s et of standards will allow for an e quivalent level of safety

. The PI C began fl ying model airplanes in 1995 at the age of 13. H e has over 20 ye ars of experience piloting gas and electric powered model aircraft. He was an active member of the Tailspinners RC club in Rey

noldsburg, Ohio and is a current member of the Academy of Model Aeronautics

. Be cause the PI C is not actually in the aircraft, quick reflexes, manual dexterity and computer knowledge are more important to safel y piloting the SUAS than possession of an airman certificate.
It cannot be assumed that a commercial pilot, approved to operate a helicopter or fix ed wing aircraft, has the skill or ability

to safe ly operate an unmanned aerial vehicle, operating at 400 feet AGL or lo wer, within strictly

c ontrolled pre - approved airspace. Since there are no standards for either private orcommercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control

and operation of the SUAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety

. Wi th that in mind, SkyOhio proposes that its PIC be required to do the following prior to the first commercial operation: **(Note**
**- These**  **ar e**  **mostly the**  **same requir** **ements pr** **oposed by**  **John Sherman,**  **D BA**  **M ad**  **Hornet Aerial**  **Photography ,**  **and by**  **Singer's Cr eations in their**  **successful r equest**  **s for**  **exemption. )** 
**SkyOhio believes**  **t hat**  **these requir** **ements ar** **e an**  **excellent start**  **to ensur** **e the**  **PI C**  **is qualified**  **to operate safely**  **:** 1. Perform 40 fli ghts or log 4 0 hours of fli ght time with the DJIP hantom 3 Professional and DJ I Inspire 1. 2. Study and be familiar with all sections of the DJ I Phantom 3 Professional User Manual. 3. Study and be familiar with all sections of the DJ I Inspire 1 User Manual. 4. Study , be familiar with, and demonstrate (where possible) the “Always be Prepared for the Wo rst” scenarios.
**VI. Public Inter** **est and Equivalent Level of Safety**  Granting this exemption would benefit the public as a whole. SUASs of fer a strong equivalent level of safety , a reduction in environmental impac ts, and are free from the harmful emissions associated with the manned aircraft that are currentl y used for aerial photography and videography

. Due to the size of the SUAS and the tightly controlled and limited airspace in which the SUAS will operate, approval of this application presents negligible risk to the public. Furthermore, the public will be able to legally acquire aerial photography and videography that would normally o nl y be obtainabl e by

employing helicopters or fixed wing aircraft, which are far more dangerous to the public than an SUAS that is properl y flown.
**VII. Equivalent Level of Safety** 
In an ef fort to join the FAA in its mission to provide the sa fest, most efficient aerospace system in the world and to minimize the risk to the NAS o r to persons and property on the ground, SkyOhio agrees to be bound by

the following limitations and conditions when conducting commercial operations under an FAA issued exemption:
A. For the purposes of ensuring the SUASs will be operated within the standards that the FAA has allowed in the AMA

National Model Aircraft Safety Code:
1. SUASs will not be flown: a. In a careless or reckless mannerb. At a location where SUAS activiti es are prohibited

2. SUAS pilots will: a. Yi eld the right of way to all human

- carrying traf fic b. See and avoid all aircraft and utilize a spotter when appropriate c. Not fly

higher than 400 feet AGL or within three (3) miles of an airport without notifying the airpor

t operator d. Not interfere with operations and traf fic patterns at any

airport, heliport, or seaplane base except where there is a mixed use agreement e. Not exceed a takeof

f weight of 55 pounds (including payload) f. Ensure the aircraft is identified by a ffixing the owner ’s c ontact information to the outside of the SUAS g. Not operate SUASs while under the influence of alcohol or while using any drug that could adversely

affect the PI C’ s ability

to safel y control the model h. Not operate SUASs carryingp yrotechnic devic es that explode or burn, or any device which propels a projectile or drops an object that creates a hazard to persons or property
. 3. SUASs will not be flown unless: a. The aircraft, control system, and pilot skills have successfull y demonstrated all m aneuvers intended or anticipated prior to the specific event b. An inexperienced pilot is assisted by an experienced pilot 4. All pilots shall avoid flying directly o ver unprotected people, vessels, vehicles, or structures and shall avoid endangerment of life and property of others 5. A successful radio equipment ground

- range check in accordance with manufacturer ’s reco mmendations will be completed before the first flight of a new or repaired model aircraft 6. SUASs must use the radio

- control frequencies currentl y allowed by the Federal Communic ations Commission (FCC) 7. SUASs will not knowingly operate within three (3) miles of any p re - existing fl ying site without a frequency

- management agreement 8. Excluding takeof

f and landing, no SUASs may b e flown outdoors closer than 25 feet to any individual, except for the PI C and the PIC’ s helper(s) located at the takeof f site 9. Under no circumstances may a PI C or other person touch a SUAS in flight while it is still under power, except to divert it from striking an individual 10. The PI C of the S UAS shall: a. Maintain control during the entire flight, maintaining visual contact without enhanc ement other than b y corrective lenses prescribed to the PI C b. Fly u sing the assistance of a camera or First

- Person Vi ew (FPV) onl y in accordance with the procedure s outlined in AMA Document #550 c. Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560 11. The flying area must be clear of all utility w ires or poles and SUAS will not be flown closer than 50 feet to any above

- ground electric utility lines12. The fl ying area must be clear before the engine is started, except for the PIC and the spotter

B. In addition to the above rules outlined by the AMA

N ational Model Aircraft Safety C ode and in an eff ort to enhance the safety offered by the already

s afe operations mentioned above, SkyOhio also agrees to be bound b y the foll owing limitation and conditions:
1. Flights will be operated within VL OS of the PIC 2. Maximum total flight time for each operational fl ight will be 18 minutes. F lights will be terminated at 25% battery

power reserve should that occur prior to the 18 minute limit 3. The SUAS will only

operate in tightl y controlled and limited airspace 4. A briefing will be conducted in regard to the planned SUAS operations prior to each flight. It will be mandatory

to all personnel who will be performing duties within the boundaries of the safety perimet er be present for this briefing 5. The PI C and the PI C’ s helper(s) will have been trained in operation of the SUAS and received up - to
- date information on the particular SUAS to be operated 6. The pilot and the PI C’ s helper(s) will at all times be able to communicate by voice 7. If the SUAS loses communications or loses its GPS signal, the SUAS will have capability to return to a pre
- determined location within the security perimeter and safely

land 8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies 9. All flights will be conducted on private property and with the written and/or oral permission of the property owner(s) 10. Flights will always be conducted in areas that are clear of all people, except the PI C and the PI C’ s helper(s) 11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during severe weather conditions 12. Flights will not occur in weather conditions that prevent the PI C from operating within VLOS at all times or in weather conditions that dramatically a ff ect the SUAS ’s f

light (e.g. high winds) 13. If operation occurs in an area where people could inadvertentl y enter the area, an operational border will be establis hed with traf fic cones. I f it is not feasible to use traffic cones due to interference with the photography/videography , the PI C’ s helper(s) will be responsible for keeping a safe perimeter around the operation. The operation will cease immediately and be resched uled if it is impossible to establish a safe perimeter around the operation 14. The PI C will be responsible for logging all flights to ensure the comprehensive preventative maintenance plan can be followed, as describe by the “Preventative Maintenance” section b elow 15. The SUAS will not be routinely operated in the proximity o f any airports. In any cases where the SUAS must be operated within three (3) miles of an airport, the airport operator will be notified before the operation commences. The operatio n of SUASs, weighing less than 7 lbs., conducted in the strict conditions as outlines above, will provide an equivalent level of safetysupporting the grant of exemptions requested herein, including exempting the applicant from

the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly c ontrolled environment. A s a result, they o ff er a much safer way

to represent a safety enhancement to the already safe operations that have been granted by the FAA for the establishment of the AMA N ational Model Aircraft Safety Code.
**VIII. Privacy**  Since the areas being photographed or filmed will b e on private property , accessed only after given written and/or oral consent by the property owner (s), and clear of all people, except for the PI C and the PI C' s helper(s), approval of this application presents no risk to the public privacy

. In addition, SkyOhio will honor all req uests for "no

- fly

zone".
**IX. National Security** 
Due to the size of the SUAS and the tightly c ontrolled and limited airspace in which the SUAS will operate, approval of this application presents no ris k to national security

. **X. Requested Exemptions**  SkyOhio requests exemption from the following regulations since it is not possible to fully c omply with them, and attempting to follow them for the purposes of operating a SUAS would make it impo ssible for SkyOhio to conduct its commercial operations : **( 1**  **) 14 CFR Part 21, Subpart H:**  **Airworthiness Certificates** Subpart H establishes the procedural requirements for the issuance of airworthiness certificates as required by F AR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft , an exemption from Part 21 Subpart H meets the requirements o f an equivalent level of safety under Part 1 1 and Section 333 of the Reform Act. The Federal A viation Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certifi cate, upon consideration of the size, weight, speed, operational capability , and pro ximity to airports and populated areas of the particular SUAS. Inall cases, an analysis of these criteria demonstrates that the SUAS operated without an airworthiness certificate, in the restricted enviro nment and under the conditions proposed, will be at least as safe, or sa fer, than a conventional aircraft operating with an airworthiness certificate without the restriction s and conditions proposed. **( 2**  **) 14 C.F** 

**.R. 43.7: Persons Authorized to**  **Appr ove Return to Service**  This regulation provides, in part , that the holder of a mech anic certificate or a repair station certificate may a pprove an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service. Since the nature of the SUAS is that of a model aircraft, and SkyOhio’ s service technicianswill conduct maintenance as outlined in Article IV and required by the manufactur er of the SUAS, DJI , the capabilities of SkyOhio ’s s ervice technicians to maintain and repair the S UAS will meet the requirement for an equivalent level of safety pursuant to Section 333 for the ty pe of S UAS, its inten ded use, and the operating environment. **( 3**  **) 14 C.F** 

**.R. 43.1 1: Content, form, and disposition of r** **ecords** This regulation provides, in part, that maintenance record entries be maintained and for the listing of discrepancies and placards by inspectors. The SUASs, due to their small size, do not have room for placards to be placed in or on them and no inspection s for SUAS have been certified by F AA at the present time. S ince SkyOhio’ s flight crews will keep log books of all maintenance and repair at the ground station, an equivalent level of safety will be achieved because the documentation will be at the ground station with the PI C, where it will be useable in case of an emergency , rather than with the SUAS. **( 4**  **) 14 C.F** 

**.R. 45.1 1: Marking of pr** **oducts.** This regulation provides, in part, that the manufacturers of aircraft, engines, propellers, mark such ai rcraft, engines, or propellers with an approved fireproof identification plate. The SUAS, due to its small size, does not have room for fireproof placards to be placed in it. Any required placards could become hazardous, due to the additional weight and strain plac ed on the SUAS.
An equivalent level of safety will be achieved because SkyOhio’ s flight crew will keep information related to the SUAS, including the user manual, at the ground control station, and af fix its N

-Number, once obtained from the FAA Registrati on Of fice, on the “arms” of the SUAS as large as practicably possible. Inaddition, the relevant documentation will be at the ground station with the PI C, where it will be useable in case of an emergency , rather than with the SUAS. Also, the fuselage is marked with “DJ I, ” the manufacturer of the SUAS. **( 5**  **) 14 C.F** 

**.R. 45.27: Location of marks; nonfixed**
**- wing air** **craft.** The FAA has stated that a petitioner ’s aircraft must be identified by s erial number, registered in a ccordance with 14 CFR part 47, and have identification (N

-Number) markings in accordance with 14 CFR part 45, Subpart C, and that markings must be as large as practicable. S kyOhio is prepared to identify i ts SUASs by

serial number, register them in accordance with 14 C.F.R. part 57, and have N

Number markings on the SUASs. However, 14 C.F.R. 45.27 requires that each operator of a rotorcraft must display

o n that rotorcraft horizontally o n both surfaces of the cabin, fuselage, boom, or tail the marks required by

§ 45.23. SkyOhio’ s SUASs, due to their small size, do not have a cabin, fuselage, boom or tail to display

the marks required b y §45.23.
An equivalent level of safety will be achieved because once SkyOhio receives N

-Numbers for its SUASs, it will display

these marks on the “arms” of the aircraf t as large as practicabl y possible and because the SUASs will be registered with the F AA A ircraft Registration Branch. In the event of inc ident, the SUAS will be traceable to SkyOhio.**( 6**  **) 14 C.F**  **.R. 45.29: Size of marks** The FAA has previously d etermined th at relief from this Section is not necessary , so long as the SUAS in question is registered with the FAA and markings are as large as practicabl y possible. See Exemp tion No. 111 36

. S kyOhio requests the FAA make the same determination for this petition. A lternatively

, SkyOhio requests an exemption from 14 C.F.R. 45.29. This regulation provides, in part, that the registration marks for rotorcraft must be at least 12 inches high. The SUAS, due to its small size, does not have any s urface area large enough to display marks 12 inches high.
An equivalent level of safety w ill be achieved because SkyOhio will affix its registration numbers as large as practicabl y possible on its “arms” once it obtains N

-Numbers for its SUASs and the SUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the SUAS will be traceable to SkyOhio. **( 7**  **) 14 CFR 61.23 (a):**  **Medical certificates** This regulation requires pilots of manned aircraft to h old a medical certificate. Since: risks associated with the operation of the proposed S UAS s are significantly diminished from the level of risk associated with any

manned aircraft; the SUAS s are of a size, weight, spe ed, and operational capability which makes it much safer than any manned aircraft; operations will occur in tightly c ontrolled and lim ited airspace; and considering that all operations will be on private property that is clear of all people, o btaining and maintaining a medical certificate would not improve the safety o f the operation. Inthe very r are case of a mishap , the SUAS being flown will pose significantly l ess of a threat than any manned helicopter or fix ed wing aircraft because the SUASs are a fraction of the size, a fraction of the weight, will be fl own at a fraction of th e speed, carry no flammable fuel, and carry no crew or passengers. **( 8**  **) 14 CFR 61.1**  **13 (a) and (b) : Private pilot privileges and limitations: Pilot in command**  These regulations limit private pilots to non

- comm ercial operations. Because : the SUAS s will not carry a pilot or passengers; due to the SUASs’size, weight, speed, and operational capabilities; and since operations will occur in tightly c ontrolled and limited airspace, the proposed operations can achieve the equivalent level of safety of current operations that currentl y require a commercial pilot’ s license. Furthermore, since there are no standards for either private or commercial SUAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the S UAS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety

. It cannot be assumed that a commercial pilot, approved to operate a manned helicopter or fixed wing aircraft, has the skill or ability to safely operate an unmanned aeri al vehicle, operating at 400 feet AGL

or lower, within strictly

controlled pre

- approved airspace. **( 9**  **) 14 C.F** 

**.R. 91.7(a): Civil air craft airworthiness.**  This regulation requires that no person may operate a civil aircraft unless it is in airworthy c ondition. The FAA has previousl y stated that no ex emption is required for this Section

. S kyOhio requests thesame determination to be made for this Petition. Alternatively , SkyOhio requests an exemption from 14 C.F.R. 91.7(a). As there will be no airworthiness certificate issued for the aircraft should this e xemption be granted, no standard will exist for determining airworthiness.
An equivalent level of safety will be achieved because SkyOhio will keep the SUASs’m aintenance and safety

information at the ground station, where it will be readily accessible to the PI C and VO b efore , during, and after operations, and the PI C will be able to reference this material and make the d etermination of whether the SUAS is in an airworthy mech anical and electrical condition in accordance with 14 C.F.R. 91.7(b). **(10) 14 C.F** 

**.R. 91.9(b)(2): Civil air craft flight manual, marking, and placard r** **equir ements.**  The FAA previously

s tated that exemption to this Section was not necessary . See Exemption No. 111 36

. SkyOhio requests the same determination to be made for this Petition. Alternatively , SkyOhio requests an exemption from 14 C.F.R. 91.9(b)(2). This regulation provides: "(b) No person may operate a U.S.

- registered civil aircraft... (2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof." First, there does not currentl y exist a method of approving manuals for SUAS. Second, given the size and configuration of the SUAS, there is no space to carry such a flight manual on the aircraft. Inaddition, carrying the manual on the airc raft would be pointless, since there is no pilot or other person on board who could read or use it. On August 8, 2014, the FAA issued a memorandum entitled “Interpretation regarding whether certain required documents may b e kept at an unmanned aircraft’ s c ontrol station.” This document stated that in the case of SAUSs, “maintaining these documents at the pilot’ s control station would meet the intent of the rule as the pilot would be able to produce the do cuments for his or her own information or to an F AA inspector.”
An equivalent level of safety will be achieved because SkyOhio will keep its flight manual at the ground st ation, where both the PI C and the PI C’ s helpers can access it and, therefore, the intent of this rule

– the pilot having access to this material during flight

– is met. **(1 1)**  **14 C.F**

**.R. 91.9(c): Civil air craft flight manual, marking, and placard r** **equir ements.**  The FAA has previously

determined that relief from this Section is not necessary. S ee Exemption No. 111 36

. S kyOhio requests the FAA to make the same determination about its petition. Alternatively , SkyOhio requests an exemption from 14 C.F.R. 91.9(c). This regulation provides: "(c) No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance w ith part 45 of this chapter." As stated above, SkyOhio will obtain N

-Numbers from the F AA Registration Office and the SUASs, due to their small size, do not have room to contain fireproof placard or to display aircraft marks in a conventional size. However, once SkyOhio obtains its N

-Numbers, it will place the number on the “arms” of the aircraft as large as practicabl y possible.An equivalent level of safety w ill be achieved because SkyOhio will affix its registration numbers as large as practicabl y possible on its “arms” once it obtains N

-Numbers for its SUASs and the SUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the SUAS will be traceable to SkyOhio. **( 12**  **) 14 C.F** 

**.R. 91.103(b)(2): Pr eflight action.**  SkyOhio re quests an exemption from 14 C.F.R. 91.103(b)(2) to the extent that it is applicable. This regulation provides: "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— ... (b) For any flight, runway l engths at airports of intended use, and the following 16 takeof f and landing distance info rmation:

... (2) For civil aircraft other than those specified in paragraph (b)(1) of this Section , other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway s lope, aircraft gross weight, and wind and temperature." SkyOhio’ s flight crew in fact will, before beginning a flight, become f amiliar with all available information co ncerning that flight, as outlined in Article III, above, and elsewhere in this Petition. As the flights of the SUAS will not be at airports, the information required of Part 91.103(b)(2) does not apply

. An equivalent level of safety w ill be achieved because SkyOhio shall perform preflight operations as outlined previously

in this Petition, flights will not be at airports, and the PI C and VO will become familiar with the conditions prior to the flight, also as outlin ed previously in this Petition. **( 13**  **) C.F**  **.R. 91.105: Flight crewmembers at stations.** SkyOhio requests an exemption from 14 C.F.R. 91.105 since this regulation is not applicable due to the SUAS carrying no flight crewmembers.
An equivalent level of safety will be achieved because SkyOhio will not operate the aircraft unless someone is at the radio controls at all times and because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft but on the ground. **( 14**  **) 14 CFR 91.109**  **: Flight instruction** This regulation provides that no person may operate a c ivil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. SUASs and remotel y piloted aircraft, and by their design do not have fully f unctional dual controls. Flight control is acc omplished through the use of a control box that communicates with the aircraft via rad io communications. The FAA has approved exemptions for fli ght training without fully f unctional dual controls for a number of aircraft and for fli ght instruction in experimental aircraft. Alternatively , SkyOhio requests an exemption from 14 C.F.R. 91.109. The equivalent level of safety will be achieved because neither a pilot nor passengers will be car ried in the aircraft and by the s ize and speed of the aircraft. **( 15**  **) 14 C.F** 

**.R. 91.1 13(b): Right** 
**- of** 

**- way rules: Except water**  **operations.**This regulation provides: “(b): General. When weather conditions permit, regardless of whether an

operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by e ach person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way , the pilot shall give way to that aircraft and may n ot pass over, under, or ahead of it unless well clear." SkyOhio requests an exemption from 14 C.F.R. 11 3(b) to the extent that it applies to overhead aircraft operating at or above 500 feet AGL a s the SUAS will be operating no higher than 400 feet AGL. Despite this, should another aircraft enter the area in which SkyOhio is operation, because the flight will be within his or her line of sight, the PI C will be able to give right of way to th at aircraft.
An equivalent level of safety will be achieved because SkyOhio will operate its SUAS to see and avoid and give way

to other aircraft that might enter nearb y airspace at or below 400 feet AGL, and will give right

- of

- way to manned aircraft. Also, because the SUAS has significantly greater mobility than a much larger, manned aircraft, the PI C will be able to react and respond to avoid any collision much more quickl y than the other pilot. **( 16**  **) 14 C.F** 

**.R. 91.1 19(b) and (c): Minimum safe altitude**  **s: General.** This regulation provides: "Except when necessary f or takeoff or landing, no person may operate an aircraft below the following altitudes... (b) Over congested areas. Over any c ongested area of a city , town, or settlement, or over any open air assembly o f persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. Inthose cases, the aircraft may n ot be operated closer than 500 feet to any person, vessel, vehicle, or structure.”
An equivalent level of safety will be achieved because SkyOhio will operate the SUAS no higher than 400 feet AGL

and SkyOhio’ s SUAS operations will provide at least an equivalent level of safety to manned aircraft that are maintaining a distance of at least "500 feet to any person, vessel, vehicle, or structure.” The 400 feet AGL m aximum will provide an equivalent level of safety to 14 C.F.R. 91.1 19(c) because, since 1981 with AC 91

- 57, this height has been an operating standard for model aircraft. Additionally

, the flight crew will make a safety assessment prior to each operation regarding the risks of operating in a certain area, and onl y operate when the risk does not present an undue hazard to themselves or to others. **(17 )**  **14 CFR 91.121: Altimeter**  **settings** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available b efore departure.” As the SUAS does not have a barometric altimeter, but inste ad a GPS alti tude read

- out, an exemption is appropriate . An equivalent level of s afety will be achieved by the PIC by c onfirming the altitude of the launch site shown on the GPS altitude indicator before flight. Additionally , SkyOhio will not be flying into or out of an airport. SkyOhio will no t operate the SUASabove 400 feet AGL in a sustained cruising flight mode such as a manned aircraft will ty pically f ly

. The PI C will at all times be controlling the maximum height of the SUAS through the telemetry f e atures of the SUAS. Additionally , the SUAS will be operated within the line of sight of the PI C. The FAA has previousl y granted this exemption in the MP AA Exemptions. **( 18**  **) 14 CFR 91.151 (a)**  **: Fuel Requir ements for**  **F light in**  **VFR Conditions** This regulation prohibits an individual from beginning “a fli ght in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to fly after that for at least 30 minutes; or (2) At night, to fly a fter that for at least 45 minutes.” The battery p owering the SUAS provides approximately < 25 minutes of powered fl ight. That would make it impossible to meet the 30

- minute reserve requirement. However, the SUAS will be operated in a manner with at least the equivalent level of safety a s a manned aircraft complying with Part 91.151. Operation of a SUAS with less than 30 minutes of reserve fuel does not engender the ty pe of risks that Section 91.151(a) was intended to alleviate. During the entire flight, the PI C will always have a visual line of sight of the SUAS, and be able to monitor the battery life via the telemetry

display on the controller. Additio nally , there will be a timer set to ensure that the flight time doe s not exceed 80% of the battery l ife of the SUAS. Thus, the SUAS will always have enough power to land safel y, g iven the minimum level of reserve capacity of the batteries. Granting an exemption from 14 CFR §91.151(a) is entirel y co nsistent with similar ex emptions already granted to other operations, including the MP AA Exemptions. An equivalent level of safety will be achieved because SkyOhio will limit flights to 80% of battery power. The proposed exemption meets an equivalent level of safety to 14 C.F.R. 91.151 because, given the limitations on SkyOhio’ s proposed operations and the location of those operations, a reduced minimum power reserve for flight in daylight VFR conditions is reasonable. **( 19**  **) 14 C.F** 

**.R. 91.203(a) and (b): Civil air craft: Cert**  **ifications r equir** **ed.** The F AA has previously

determined that exemption from 14 C.F.R. 91.203(a) and (b) is not necessary

. See Exemption No. 111 36

. Alternativel y, S kyOhio requests an exemption from 14 C.F.R. 91.203(a) and (b). This regulation provides in part: “(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate... (2) An ef

fective U.S. registration certificate issued to its own er... (b) No person may operate a civil aircraft unless the airworthiness certificate required by p aragraph (a) of this section or a special fl ight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is le gible to pass engers or crew.” First, there are currently n o procedures in eff

ect for providing airworthiness certificates for SUAS s . However, as a condition to the approval of exemption, SkyOhio will di splay N

-Numbers, once received, on the SUASs. Additionally , the fli ght crew will keep the S UAS manuals at the ground station. Second, SkyOhio will use the DJ I Phantom 3 and Inspire 1, which have an equivalent level of safety a s a manned aircraft with an airworthiness certificate. These SUAS s provide a number of safety features, including the automatic return to home failsafe. Because of the use of GPS with the SUAS, the operator will set the initial location of flight takeof f ("home position") and if the radio control link is broken, the autopilot system will recognize thi s broken control link andcause the SUAS to automatically return to the home position as recorded by the GPS instrumentation. Additionally

, because the SUAS team will mark off an area with traf fic cones that has a 20 ft. radius, approximately

3 0 ft. from the operators, that will be used as the “home position” for the SUAS to return , no one will be standing in the way o f the path. These enhancements and procedures provide a greater degree of safety to the public and property o wners than conventional operati ons conducted with airworthiness certificates issued under Subpart H. Application of these same criteria demo nstrates that there is no credible threat to national security posed by the SUAS , due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial payload. In the restricted environment and under the conditions proposed, operation of the SUAS will be at least as safe as a conventional aircraft (fixed wing or rotorc raft) operating with an airworthiness certificate. An equivalent level of safety will be achieved because SkyOhio’ s SUASs weigh less than 7 lbs. each, inclusive of batteries and technical payload, carry neither a pilot nor passen gers, and carry no explosiv e materials or flammable liquid fuels. Each SUAS will be tightly controlled and monitored by the operator and the observer, and in compliance with local public safety requirements, in order to provide security for the area of operation. **( 20**  **) 14 C.F** 

**.R. 91 .215:**  **AT C T** **ransponder and**  **Altitude Reporting Equipment and Use.** This regulation requires that installed Air Traf fic Control (A

TC) transponder equipment must meet specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder

. There are presently n o known commercially available AT C transponders that meet the payload requirements of a SUAS and are available at reasonable cost. Howe ver, because the SUASs used by SkyOhio will not be flying into or near airports, and will fly no higher than 400 feet AGL, there is very l ow risk of collision with any m anned aircraft. In addition, because there will be no need to have contemporaneous communication with AT C Control, due to the short distances, short flight times, and restricted altitude the SUASs will operate within, SkyOhio request s an exemption from this regulation

. Additionally , the SUAS is too small to contain AT C transponder equipment in any

f orm that is known to be available commercially . An equivalent level of safety will be achieved because SkyOhio will not fl y its SUAS into or near airports, and all operations will be below 400 feet AGL, so there is very l ow risk of collision with any m anned aircraft. SkyOhio also will give right of way

to any manned aircraft that do appear

. **( 21**  **) 14 C.F** 

**.R. 91.403: General.** This regulation requires that the owner or operator of an aircraft is primarily responsible for maintai ning that aircraft in an airworthy c ondition. SkyOhio will adhere to this requirement. However, this Section also limits maintenance to that “prescribed in this subpart and other applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 requested above, SkyOhio requ ests an exemption from this Section. This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 based on the small size, light weight, relativel y slow speed, controlled area, and use of barriers to protect nonparticipating individuals, as appropriate. An equivalent level of safety will be achieved because SkyOhio will maintain its SUASs in an airworthy condition and adhere to all manufacturer requirements for inspecting andmaintaining them. S kyOhio’ s service technician s will conduct maintenance as required by the manufacturer of the SUASs, DJI

. The maintenance records will be available to the flight crew before, during, and after operations. **( 22**  **) 14 C.F** 

**.R. 91.405 (a) and (d): Maintenance Requir ed.**  The FAA has previou sly determined that relief from 14 C.F.R. 91.405 is warranted. This regulation requires that aircraft be inspected as prescribed by S ection E, 14 C.F.R. §§91.401

- 91.421. As shown below, SkyOhio is appl ying for an exemption for these S ections, due to the f act that its operators will inspect the SUAS prior to each flight and keep maintenance records of all parts that are replaced. B ecause the Sections discussed below are concerned with manned aircraft, and as such have inspection requirements designed for th e safety of passengers, they

are inapplicable to SkyOhio. SkyOhio is also applying for an ex emption to subpart (d) of this S ection, which requires a placard to be installed and references §43.1 1. As noted previously , SkyOhio requests an exemption to the pl acard requirement, because, due to the small size of the SUAS, there is no room to place the placard. Despite the reques ted exemption fro m subparts (a) and (d) of this S ection, SkyOhio will follow subp arts (b) and (c) of this Section

. An equivalent level of safety will be achi eved because SkyOhio will keep logbooks detailing all inspection, maintenance, and repairs to the SUAS. SkyOhio will also follow DJ I’ s guid elines for inspection and maintenance. As the FAA has determined in Exemption Nos. 111 36 and 11 138, following the manufacturer ’s guidelines will achieve an equivalent level of safety to 14 C.F.R. 91.405(a) and (d), because of the small size of the SUAS in question and the limited nature of operations. **( 23**  **) 14**  **C.F**

**.R. 91.407:**  **Operation after**  **m ainten**  **ance, pr** **eventive maintenance,**  **rebuilding, or**  **a l**  **teration.** The FAA has previousl y determined that relief from 14 C.F.R. 91.407 is warranted. This S ection pr events any aircraft from operation that “has undergone maintenance, preventative maintenance, r ebuilding, or alteration unless (1) [i]t has been approved for return to service by a p erson authorized under § 43.7 of this chapter; and (2) [t]he maintenance record entry r equired by

§ 43.9 or §43.1 1, as applicable, of this chapter has been made.” However, SkyOhio has requested an exemption from §§ 43.7 and 43.1 1 as described previously

. The capability

o f the operators to maintain and repair the SUAS meets the requirements for an equivalent level of safety pursuant to Section 333 for both the ty pe of SUAS, its intended use, and the rural operating environment. Additionally , due to the small size of the SUAS, there is no room to place inspection placards. Therefore, because SkyOhio has r equested an exemption from §§ 43.7 and 43.1 1, SkyOhio respectfull y requests an e xemption from 91.407. An equivalent level of safety will be achieved because SkyOhio will regularl y inspect and maintain its SUASs in accordance with the S UAS manuals. SkyOhio will keep detailed inspection and maintenance records that will be available to the flight crew before, during, and after operations. **(24 )**  **14 C.F**

**.R. 91.409: Inspections.** The FAA has previousl y determined that relief from 14 C.F.R. 91.409 is warranted. This S ection lays out specific requirements for inspections of aircraft. SkyOhio requests an exemption from these re-quirements because they are intended to maintain the safety of manned aircraft significantly l arger and capable of significantly l onger flights than is SUAS. An equivalent level of safety will be achieved because, as discussed above, SkyOhio has an inspection procedure that provides an equiv alent level of safety

to 14 C.F.R. 91.409. **( 25**  **) 14 C.F** 

**.R. 91.417: Maintenance r ecords.**  The F AA has previously

determined that relief from 14 C.F.R. 91.417 is warranted. SkyOhio reques ts an exemption from this Section, as it is onl y applicable for aircraft with an airworthiness certificate. Because SkyOhio will not have an airworthiness certificate, this Section is inapplicable. An equiv alent level of safety

w ill be achieved because SkyO hio will keep detailed maintenance records that will be accessible to the PI C and the VO before, during, and after operations.
**In accordance**  **with 14**  **CFR Part**  **11 ,**  **the foll**  **owing summary**  **is pr** **ovided for**  **publication in**  **the Federal Register: The applicant**  **seeks an exemption fr om** **t he following rules:**  **Section 333 from 14 CFR**  **Pa rt**  **21, Subpart H ;**  **14 CFR 43.7 ;**  **14 CFR**  **43.1 1**  **; 14**  **CFR 45.1**  **1 ;**  **14 CF R**  **45.27 ;**  **14 CFR**  **45.29 ;**  **14 CFR 61.23 (a) ;**  **14 CFR 61.1 13 (a) and (b)**  **; 14 CFR 91.7(a)**  **; 14 CFR 91.9(b)(2)**  **; 14 CFR**  **91.9(c) ;**  **14 CFR**  **91.103(b)(2) ;**  **14 CFR**  **91.105 ;**  **14 CFR**  **91.109 ;**  **14 CFR**  **91.1 13(b)**  **; 14**  **CFR 91.1**  **19(b) and**  **(c) ;**  **14 CFR**  **91.121 ;**  **14 CFR**  **91.151 (a)**  **; 14**  **CFR 61.203**  **(a) and**  **(b) ;**  **14 CFR**  **61.215 ;**  **14 CFR**  **61.403 ;**  **14 CFR**  **91.405 (a)**  **and (d)**  **; 14**  **CFR 91.407**  **(a)(1) ;**  **14 CFR**  **91.409 ;**  **14 CF**  **R 91.417**  **(a) and**  **(b) to**  **homeowners, realtors,**  **commer cial**  **pr operty**  **owners/managers, home**  **builders, and/or** 

**r anchers**  **and farmers**  **for u**  **se in,**  **but not**  **limited to,**  **real estate**  **and business**  **ma rketing and safer** 

**inspections of r eal pr** **operty .**  The operation of SUASs conducted in the strict conditions outlined above, will provide an equivalent and/or greater level of safety supportin g the grant of the exemptions requested herein, including e xempting the applicant f

rom the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment, and a s a result, are far safer than existing operations conducted with helicopters operating in close proximity to the ground, people, or other buildings in the vicinity

. Given the small size of the SUASs involved, the slow speed at which they must be operated in order to capture photos and videos, and the restric ted environment within which they w ill operate, SkyOhio’ s SUASs demonstrate that they can be operated within an equivalent level of safety in which Congress envisioned that the FAA must, by e xemption, allow commercial operations of SUASs to commence immediately

. Also, due to the size of the SUASs and the restricted areas in which the relevant SUASs w ill operate, approval of this application presents no threat to national security . Given the clear direction in Section 333 of the Reform Act, the authority c ontained in the Federal Av iation Act, the strong equivalent level of safety s urro unding the proposed operations, the significant public benefit

– including enhanced safety , reduction in enviro nmental impacts, no emissions, ability to legally

obtain aerial photography and videography ser vices

– the grant of the requested exemptions is in the public interest. Accordingly , SkyOhio respectfully

requests that the FAA grant the requested exemption without delay

. Satisfaction of the criteria pro vided in Section 333 of the Reform Act

– size, weight, speed, operating capability , proximity

to airpo rts andpopulated areas, operation within the visual line of sight, public safety , and national security

– provide more than adequate justification to grant SkyOhio the requested exemption, allowing for commercial operations as described herewith. Sincerely ,

Richard E. Kozlowski, Esq. Attorney for SkyOhio, LLC**Attachments :** 

**Exhibit 1** 

**– DJI Phantom 3 Pr** **ofessional quick start guid e and User**  **Manual** Phantom 3 Professional Quick Start Guide Phantom 3 Professional User Manual

**Exhibit 2**

**– DJI Inspir** **e 1 quick start guide and User Manual** 
Inspire 1 Quick Start Guide Inspire 1 User Manual