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1 At the request of the FAA, SkyTrack, LLC will also be pleased to provide The SkyTrack, LLC Flight Operations Manual 

and/or User and Maintenance Manuals for all units for which this exemption is requested.

11/1/15

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington DC 20590

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

Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 CFR

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

SkyTrack, LLC (SkyTrack), hereby applies for an exemption from Federal Aviation Regulations

(FARs) identified below, to allow commercial operations of small unmanned aerial system (i.e.,

sUAS). 

I. Petitioners Description

This exemption would permit commercial operation by SkyTrack based in Omaha, Nebraska. The 

name and address of the Petitioner is:

SkyTrack, LLC

Attn: Dawn Stock, PG, Owner

7906 South 151 Avenue

Omaha, NE 68138

402-639-6063

402-639-9561

joe.stock@skytrackuav.com

SkyTrack will conduct aerial data collection including photography/videography for search and rescue 

and a range of businesses that include infrastructure inspection and land surveying in construction, 

transportation, environmental, agriculture, resources and utilities, real estate, and roofing.

II. The sUAS

This exemption would permit SkyTrack to use DJI Inspire 1, DJI Phantom 3, DJI S900, 3DR XM-8, and 

Sensefly eBee1. These sUAS all weigh less than 25 pounds, have a built in capability to limit the height 

they fly above ground and the radius of distance they fly from the operator, and have a no fly zone 

feature. Each system also has a failsafe function of the flight system, which means when the 

communication between the main controller and the transmitter is lost, the system will automatically 

trigger return to home and will land safely. All components of the proposed sUASs operate using radio 

frequencies that comply with Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements and are described in the individual sUAS 

manuals.

DJI Inspire

The requested exemption will permit petitioner to operate the DJI Inspire 1, with a maximum
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weight of approximately 7 lbs., inclusive of batteries and technical payload. The FAA has previously 

approved use of the Inspire 1 in Exemption Nos. 12927, 13212, 11673.

DJI Phantom 3

The requested exemption will permit petitioner to operate the DJI Phantom 3, with a maximum

weight of approximately 3 lbs., inclusive of batteries and technical payload. The FAA has previously 

approved use of the Phantom 3 in Exemption Nos. 13217, 13143 and 13150.

DJI S900

The requested exemption will permit petitioner to operate the DJI S900, with a maximum

weight of approximately 8 lbs., inclusive of batteries and technical payload. The FAA has previously 

approved use of the DJI S900 in Exemption Nos. 12815 and 13299.

3DR X8-M

The requested exemption will permit petitioner to operate the 3DR XM-8, with a maximum

weight of approximately 7.7 lbs., inclusive of batteries and technical payload. The FAA has previously 

approved use of the XM-8 in Exemption No. 12842.

Sensefly eBee

The requested exemption will permit petitioner to operate the senseFly eBee, with a maximum

weight of approximately 1.5 lbs., inclusive of batteries and technical payload. The FAA has previously 

approved use of the Sensefly eBee in Exemption Nos. 12197 and 12815.

III. The Crew

The flight crew will consist of a pilot in command (PIC) and a visual observer (VO). Additionally, 

SkyTrack pilots hold, at a minimum, FAA Sport Pilot Licenses with Class III Medical Certificates, or 

U.S. driver’s licenses. If observers are not qualified pilots, they will be trained by SkyTrack pilots to 

understand the proper roles of an observer, communication procedures, proper visual scan techniques, 

operations at non- towered airports, and appropriate sections of the Aeronautical Information Manual.

IV. Operations

To assist the FAA in its safety assessment of SkyTrack’s proposed sUAS operations, below is a 

summary of operational limitations and conditions that will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines:

1. The sUASs will weigh no more than 55 pounds, inclusive of battery and payload.

2. The UAs will not be operated at a speed exceeding 87 knots (100 miles per hour).

3. The sUASs operations under this exemption will be limited to conducting operations for the purpose

of providing aerial data collection and photography/videography operations for search and rescue as 

well as infrastructure inspection and land surveying in a range of business that include construction, 

transportation, environmental, agriculture, resources and utilities, real estate, and roofing.

4. Minimum flight crew for each operation will consist of the sUAS PIC and a VO. During operations, 

the PIC and VO will be able to communicate verbally at all times.
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5. The PIC may deem other crew essential to the safe operation of the sUAS to include camera 

operator, instructor, trainee, or person’s necessary for the safe operation of the flight.

6. The PIC will have at minimum, a sport pilot license and a third class medical certificate or a U.S.

driver’s license.

7. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria and

demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS will 

be operated under this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from person’s vessels, vehicles, and structures. In addition to a pilot 

certificate, PICs will also be required to have a minimum of 10 documented hours of flight time (in 

a manner consistent with 14 CFR § 61.51[b]).on the sUAS they will be operating and commanding 

for SkyTrack.

8. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR 

§61.51(b). A record of the PIC training will be documented and made available upon request by the

Administrator. Training operations will only 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 PIC will operate the sUAS with appropriate 

distance from nonparticipants in accordance with 14 CFR §91.119. 

9. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the duties 

required of the VO. 

10. Flights will be operated within visual line of sight (VLOS) of the PIC and VO at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective lenses. 

PIC and VO will at all time be able to communicate verbally. They will not be permitted to use 

electronic messaging or texting to communicate during flight operations. 

11. Flights will be operated at an altitude of no more than 400 feet AGL. All altitudes reported to Air 

Traffic Control (ATC) will be feet AGL. 

12. A briefing will be conducted about the planned sUAS operations prior to each day’s activities. It 

will be mandatory that all personnel who will be performing duties in connection with the 

operations be present for this briefing. 

13. Prior to each flight, the PIC will inspect the sUAS, including the Ground Control Station, to ensure 

it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation 

of the sUAS, the PIC will not operate the sUAS until necessary maintenance has been performed 

and the sUAS is found to be in a condition for safe flight. All maintenance and alterations will be 

properly documented in the sUAS records. 

14. Petitioner will conduct a function flight test on any sUAS that has undergone maintenance or 

alterations that affect the sUAS operation or flight characteristics, e.g. replace of a flight critical 

component. The PIC who conducts the functional flight test will make an entry in the sUAS

records. 
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15. The petitioner will carry out maintenance, inspections, and record keeping requirements, in 

accordance with the sUAS manufacturer’s aircraft/component, maintenance, overhaul replacement, 

inspection, and life limit requirements for the sUAS and sUAS components. Maintenance, 

inspection, alterations, and status of replacement/overhaul components parts will be noted in the 

sUAS records, including total time in service, description of work accomplished, and the signature 

of the authorized person returning the sUAS to service. The authorized person will make an entry in 

the sUAS record of the corrective action taken against discrepancies discovered between 

inspections. 

16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended landing point and prepare to land each 

sUAS with 20% battery life remaining. 

17. Actual total flight time for each operational flight will result in no less than 20% battery reserve. 

18. The sUAS will have the capability to abort a flight in case of unexpected obstacles or emergencies. 

19. The sUAS will be programmed so that if it loses communication or loses its GPS signal, it will 

return to a pre-determined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

20. All operations will be conducted over private or controlled-access property with permission from 

the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

21. sUAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will 

be conducted under visual meteorological conditions (VMC). Flights will not be conducted under 

special visual flight rules (SVFR).

22. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. All 

operations shall be conducted in accordance with an ATO-issued COA. The petitioner will apply 

for a new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the existing COA. 

23. The sUAS will not be operated 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 has been obtained or otherwise permitted by a COA issued to the petitioner. Any letter 

of agreement with the airport management will be made available to the Administrator upon 

request. 

24. The sUAS will 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 PIC. 

25. All sUAS operated in accordance with this exemption will be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 
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26. The sUAS will remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

27. The sUAS will not be operated by the PIC from any moving device or vehicle. 

28. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures; unless one of the following three conditions is met: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the sUAS and/or debris in the event of an accident. The petitioner will ensure 

nonparticipating persons remain under such protection. If a situation arises, where 

nonparticipating persons leave such protection and are within 500 feet of the sUAS, the 

PIC will ensure that flight operations cease immediately. 

b. The sUAS is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard 

c. Operations nearer to the PIC, VO, operator trainees, or essential persons do not present 

an undue hazard to those persons. 

29. Documents used by the operator to ensure the safe operation and flight of the sUAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the sUAS any time the sUAS is operating. These documents will be made available 

to the Administrator or any law enforcement official upon request. 

30. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA to the FAA’s sUAS

Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: 

www.ntsb.gov .

31. If operations require notification of Flight Standards District Offices (FSDOs), such as for pipeline 

and powerline patrol, such notification will be done as required prior to operations. Additionally, all 

required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies prior to operating a 

sUAS.

V. Privacy and Public Interest

All flights will occur over private or controlled-access property with the property owner’s prior 

consent and knowledge. Photography/videography will be of people who have also consented to being 

photographed or otherwise having agreed to be in the area where the aerial photography/videography 

operations will take place. 

The planned sUASs use will increase ground safety for aerial geospatial analysis and aerial 
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photography/videography for a range of business . The enhanced safety and reduced environmental 

impact achieved using a sUAS with the specifications described by the petitioner, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the sUAS operation enabled by this exemption is in the public interest. 

Additionally, the FAA has previously approved a numerous sUAS for work similar to that of SkyTrack 

in Exemption Nos.: 

1. Exemption No. 13212 (Aerial mapping/surveying, line of sight surveying, telecommunications 

structural mappings/inventory audits, utility system inspections, construction 

monitoring/inspections, migratory bird nest evaluations/monitoring, wildlife and forestry surveys, 

environmental site assessments, and commercial real estate photography); 

2. Exemption No. 13167 (Aerial photography, aerial video and cinematography, power line, bridge, 

roof and pipeline inspection, real estate sales, special events, and thermal imagery); 

3. Exemption No. 13165 (Precision aerial surveying, construction observation/inspection, mining 

surveying/inspection, aerial photography, utility monitoring, agricultural monitoring and product 

demonstrations); 

4. Exemption No. 13117 (Aerial photography and/or video for real estate, architecture, land surveying, 

engineering and other professional activities; television, public events, cinematography and news 

gathering; aerial inspection/photography of residential/commercial structures, utility infrastructure; 

live video to assist with search and rescue operations; training in the use and application of a 

sUAS); 

5. Exemption No. 13108 (Phase I environmental site assessment, inspections, damage assessments, 

situation reports, and evaluations); 

VI. FAR Relief Requested and Equivalent Level of Safety

SkyTrack LLC requests exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of the DJI Inspire, DJI Phantom, DJI S900, 3DR XM-8, and 

Sensefly eBee, to allow sUAS operations for aerial data collection. Petitioner understands that if it 

satisfies the requirements under Section 333, then there is no need for relief under 14 CFR Part 21 

(airworthiness certificate), and under 14 CFR §§ 45.23(b) and 91.7(a). Petitioner further understands 

that operations of a sUAS does not require exemptions under 14 CFR § 91.9(b)(2) (civil aircraft

marking and manual requirements) and based on the FAA memorandum "Interpretation regarding 

whether certain required documents may be kept on unmanned aircraft's control station." If the 

Administrator determines that the Petioners may be subject to those requirements, the Petitioner 

reserves the right to supplement this request. Petitioner also understands that the FAA allows operations 

under Section 333 by a PIC who holds a minimum of a recreational or sport certificate, and that a 

driver's license satisfies the medical requirement under Part 61.

91.119(c) Minimum Safe Altitudes

Section 91.119(c) limits the distance aircraft can be operated in proximity to any person, structure, 

vessel, or vehicle in sparsely populated areas to greater than 500 feet. Typical work done by SkyTrack 

would include inspection, survey assessment or photography of persons, vessels, vehicles or structures

and would require a closer proximity. SkyTrack sUAS will be operated in a limited are with predefined boundaries with the consent of the landowner or persons. Prior to and during operation of the 

sUAS, the PIC and VO will assess the area for safety and ensure all non-essential persons remain clear 

of the flight area. Additionally, the low altitude will ensure no interference with conventional, manned 

aircraft. Due to the small size of the sUAS, these protections will ensure the equivalent level of safety
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of minimal safe altitudes. Compared to flight operations for manned aircraft and the lack of flammable 

fuel, any risk associated with the proposed sUAS operations is far less than conventional aircraft 

operating at or below 500 AGL. In addition, the low altitude operations will ensure separation with 

conventional, manned aircraft..

91.121 Altimeter Settings

Section 91.121 requires all aircraft to maintain cruising altitude by reference to an altimeter setting. All 

SkyTrack sUAS will have an automatic altitude setting of zero before every flight. During operations, 

sUAS will always fly below 400 feet ASL and will not need to maintain cruising altitudes to avoid 

conflict with other aircraft. All SkyTrack sUAS having control options for visual positioning, GPS, and 

barometer to monitor altitude. PIC will verify the zeroing of the altitude prior to every flight and

monitor altitude during operations until the unit is safely landed.

91.151(a)(1) Fuel Requirements for Flight in VFR Conditions

Section 91.151(a)(1) requires all day VFR flights to being with enough fuel to fly to the first point of 

intended landing plus 30 minutes. sUAS fuel source is their battery, which last between 15 and 50 

minutes. All SkyTrack PICs will achieve an equivalent level of safety by virtue of keeping the sUAS in 

VLOS as well as flight planning all flights to return to the landing site with a minimum of 20 percent 

reserve power.

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) Maintenance Inspections

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, 

conduct detailed inspections after every two hours of flight. Required preflight and maintenance 

activities are included in the User Maintenance Manuals and will be followed prior to, during, and after 

each flight as required. SkyTrack PICs will document inspection and maintenance work performed in 

accordance with 91.417. Due to the size, construction, and simplicity of the aircraft, the PIC can ensure 

an equivalent level of safety for SkyTrack sUASs. Additionally, operation is restricted to altitudes no 

higher than 400 AGL, for a limited time. If mechanical issues arise, the PIC can land the sUAS 

immediately.

VII. Federal Register Summary?

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed: Petitioner seeks an exemption from the 

following rules: 91.119(c), 91.121, 91.151(a)(1), 91 .405(a), 91.407(a)(l), 91.409 (a)(1)&(2), 

91.417(a)&(b) to operate commercially a small unmanned aircraft system (sUAS) that is 55 pounds or 

less.

Approval of the exemption requested by petitioner will allow commercial operation of a (1) DJI Inspire 

1, (2) DJI Phantom 3, (3) DJI S900 (4) 3DR XM-8, and (5) senseFly eBee for the purpose of providing 

aerial data collection including photography/videography for search and rescue and a range of 

businesses that include infrastructure inspection and land surveying in construction, transportation, 

environmental, agriculture, resources and utilities, real estate, and roofing..

Approval of exemptions allowing commercial operations for sUASs will enhance safety by reducing 

risk. Conventional manned flight operations, using jet, or piston aircraft, sometimes operate at low in 

close proximity to people and structures; and resent the risk associated with vehicles that weigh 

approximately 6,000 pounds, carrying large amounts of fuel or other flammable liquid. Such aircraft 

must fly to and from the job location. In contrast, as sUAS weighing less than 55 pounds and powered 
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by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board. The sUAS is carried to the job location, not flown. The sUAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights.

The operations of sUASs weighing less than 55 pounds and, conducted in accordance with the 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested

VIII. Conclusion

Petitioner is prepared to amend or modify any part of this request to satisfy the need for an equivalent 

level of safety. If additional information is required, or you have any questions regarding this petition, 

please contact the undersigned. We look forward to working with your office.

Sincerely,

Dawn Stock

Owner, SkyTrack, LLC

402.639.6063

402.639.9561

Joe.stock@skytrackuav.com

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