### U.S. DepartmentofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 November29, 2015



## SKYLINE VISUALS Section 333 Petition to Operate Small UnmannedAerial Systems

Prepared by: TylerGregg Owner: Skyline Visuals 4215 Old Grove Road Oceanside CA, 92057 760-716-5721 tygregg@skylinevisuals.net L,·.,

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...Petition Summary: Pursuant to Section 333 ofthe FAA Modernization and Reform Actof 2012, Pub. 

### L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general exemption authority under 49 U.S.C. section 44701(f), Skyline Visuals ("Petitioner") hereby petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Airworthiness Standards: Normal Category Rotorcraft),14 C.F.R sections 61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a)-(b). The proposed exemption, ifgranted, would allow Petitionerto conduct commercial operations of small unmanned aircraft systems ("UASj meeting orexceeding all ofthe operational and safety requirements Congress has setforth in Section 333. Petitioner is an aerial service and technology company that plans to exploitthe capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Realestate Photography

- Telecommunications

- Agriculture

- Aerial filmmaking and photography

- Energy systems inspections and asset management

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations • Pipeline inspection and patrolling StatutoryAuthority Section 333, titled "Special Rules for Certain UnmannedAircraft Systems", provides a mechanism for seeking expedited FAAauthorization ofsafe civil UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthisAct orthe guidance required bysection 334 of thisAct." In Section 332(b)(1), Congress made it clearthat Section 333 provides a mechanism for "expedited operation authorization" if several factors are met. Petitioner meets all requirements to permit FAAapproval ofcommercial UAS operations.
The Petitioner Requests Relief From the Following: Section 61.113(a) and (b) prescribes that- (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire.Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning aflight, become familiar with all available information concerning that flight, to include- (a) For aflight under IFA or aflight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised byATC; (b) For anyflight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraftfor which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; (2) For civil aircraft otherthan those specified in paragraph (b)(1) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. Section 91.119 prescribes that, except when necessaryfor takeoff or landing, no person may operate an aircraft belowthe following altitudes: (a) Anywhere. An altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or propertyon the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet ofthe aircraft. (c) Over otherthan congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. Ifthe operation is conducted without hazard to persons or propertyon the surface- (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe FAA; and (2) Apowered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) ofthis section. Section 91.121 requires, in pertinent part, each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat isset "to the elevation ofthe departure airport or an appropriate altimetersetting available before departure." Section 91.151 (a) prescribes that no person may begin aflight 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 afterthatfor at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes. [emphasis added] Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart Eofthe same .part and shall, between required inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed in part 43 ofthe chapter. Section 91.407(a)(1) prohibits, In pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under§ 43.7 of the same chapter.Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance ofan airworthiness certificate in accordance with part 21 of this chapter. Section 91.417(a) and (b) prescribes, in pertinent part, that- (a) Each registered owneror operator shall keep the following records forthe periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 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 ofan aircraft. The records must include- (i) Adescription (or reference to data acceptable to theAdministrator) ofthe work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate numberofthe 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, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraftwhich are required to be overhauled on aspecified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required bythe inspection program underwhich the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, theAD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owneroroperator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall 

### be retained untitthe work is repeated or superseded by otherwork orfor 1year afterthe work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft atthe time the aircraft is sold. (3) A listof defects furnished to a registered owner oroperator under 

### § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
The Petitioner has supplied the Following Additional Information:
FPVModel FX680 Custom build statement from builder: See attached.UnmannedAircraft Systems requested to operate underthis request:
FPVModel FX680
The petitioner statesthat the unmanned aircraft (UA) to be operated underthis request are less than 55 lbs. fully loaded, fly at a speed of no more than 50 knots, carry neither a pifot nor passenger, carry no explosive materials orflammable liquid fuels, and operate exclusively within a secured area as set out in the POHs.
The FX680 is a four-rotor manufactured by FPVModel. The VTOL quadrotor-type design has four motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, the craft has integrated safetyfeatures built into the design ofthe UAS, as described in the POH, to ensure the safety of persons and property within and surrounding the limited operating area. The petitioner further describes that, in the eventthe UAS loses communications or its GPS signal, the UAwill have the capability to return to a pre-determined location within the Security Perimeter and land. It will also have the capability to abort a flight in the eventof unpredicted obstacles or emergencies.

Petitioner's UAS will be identified by serial number, registered in accordance with 14C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as large as practicable. Pre-flight Inspection, Maintenance Before each flight the PIC will perform a series of pre-flight and takeoff checks as defined bythe POH supplied. After each 60 minutes of airtime, the craft will undergo a thorough inspection of all aircraft components, including, but not limited to: a. Actuators I Servos b. Motors, wiring and connectors c. Propellers, smooth, no chips d. Electronic speed controller, wiring and connectors e. Batteries, wiring and connectors f. Remote command and control g. Ground control station
UAS Operating Parameters The petitioner states thatall flights will be operated within visual line of sight (VLOS) of pilot, in daytime VFR flight conditions and all operationswill be conducted with the assistance of a second spotter/observer. The UAS flights will be limited to a maximum altitude of400 feetAGL. Altitude is accurately measured by GPS. The petitionerfurther states that an operator will ensure that only consenting production personnel will be allowed within 100 feet ofthe UA operation, and UAS will be kept at least 1 00'from any inhabited structure. Flight Standards District Offices (FSDOs) will be notified as required priorto operations to describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver orAuthorization ("COA") priorto conducting anyoperations under this grant of exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOT AM not more than 72 hours in advance, but not less than 48 hours priorto the operation.Petitioner's UAS will remain clear and yield the right ofway to all manned operations and activities at all times (including, but not limitedto, ultralight vehicles, parachute activities, parasailing activities, and hangliders). Petitioner will notconduct UAS operations within 5 nautical miles ofthe geographic center of a non-towered airport unless a letter of agreement with that airport's management is obtained and the operation is conducted in accordance with a Notice to Airmen ("NOT AM").

Pilotin Command (PIC) The pilot in command will be Skyline Visuals Owner, Tyler Gregg. Mr. Gregg received his Private Pilot Certificate in 1994, number 560657553, and has logged over 1 00 hours in single engine aircraft. He is a holder of a valid driver's license, CA License numberA7379002, Expiring 04/26/2018. In addition to PIC experience in manned aircraft, Mr. Gregg has approximately 8 years of experience with RIC fixed wing and rotor wing aircraft. Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply with the other applicable procedures and requirements stated in§ 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and takeoff distances before initiation of a flight. The PIC will also accountfor all relevant site-specific conditions in their preflight procedures. Risks presented by sun glare will be mitigated bythe PIC's and VO's ability to see other airtraffic and initiate a return-to-home sequence if needed.
Radio Frequencies Radio frequencies used will be those allotted bythe FCC for datatransmission and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage and emissions regulations. Safety and Benefits ofthe UAS The petitioner will be using the UAS in a variety of applications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad of benefits over the use offuJI-sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still photography, justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafetyfor the pilots and crew. By granting Petitioner's requested exemptions, the FAAwill help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Petitioner is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.
Conclusion Forthe foregoing reasons, the exemptions requested herein should be granted and Petitioner should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA.November29,2015
FAAAircraftRegistration Branch, AFS-750 P.O. Box 25504 OklahomaCity, OK73125-0504

DearSirorMadam 

### SkylineVisuals

Owner: Tyler Gregg 4215 OldGrove Road Oceanside, CA92057

This statementis presentedto outline the specifications ofthe sUA that

### willbeinuse bythe
ownerTyler Greggof Skyline Visuals for theuse ofarielphotographyandvideography. The mainframe oftheUAis manufacturedbySkylarkwiththemodel designation "M4-680". The main controllerandautopilot systemis theDJINaza-MV2.

Full Legal Name of UA Builder Tyler Gregg .sUA Model Designation M4-680 sUA Serial Number None Class Rotorcraft sUA MaxTakeoffWeight 61bs 9oz Category Land Engine Manufacturer Sunny Skies Engine Model Designation MC4012 KV400 Engine Serial-Numbers None Numberof Engines 4 Engine Power Output 6.31bs Thrust per Motor Engine Type Electric

Tothe bestof the undersigned'sknowledge the informationprovided above is correct, the describedUAis notcurrentlyregistered inanothercountry, and the undersignedis the aircraft's rightful ownerNovember 29, 2015
FAA Aircraft Registration Branch,AFS-750 

### P.O. Box 25504 Oklahoma City, OK 73125-0504

DearSirorMadam 

### SkylineVisuals
Owner: Tyler Gregg 4215 Old Grove Road Oceanside, CA92057

This statementis presented to outline the specifications ofthe sUA thatwill be in use by the
ownerTyler Greggof Skyline Visuals for the use of arielphotography andvideography. The mainframe ofthe UA is manufacturedby Skylarkwith the model designation ''M 4-680". The main controller andautopilot system is the DJI Naza-MV2.

Full Legal Name of UA Builder Tyler Gregg sUA Model Designation M4-680 sUASerial Number None Class Rotorcraft sUA MaxTakeoffWeight 61bs 9oz Category Land Engine Manufacturer Sunny Skies Engine Model Designation MC4012 KV400 Engine Serial-Numbers None Number of Engines 4 Engine Power Output 6.31bs Thrust per Motor Engine Type Electric

To the best of the undersigned's knowledge the informationprovided above is correct, the described UA is not currently registered in another country, andthe undersigned is the aircraft's

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