SkyCanvas AP, October 27 th 2015

**Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012** Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F .R. Part 11, SkyCanvas AP, LLC , operator of Small Unmanned Aircraft Sy stems (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre

-planned, controlled area, photographic and surveying services, hereby applies for an exemption from the listed Fede ral Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federa l Aviation Administration (FAA) as required by §333. SkyCanvas AP's current operation of sUASs for commercial purposes has been halted to comply with recently enacte d federal aviation regu l ations pertaining to sUASs. As described more fu ll y below , the requ ested exemption woul d permit the operation of small, unmanned and re l ative l y inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- s ite safety personnel controlling access, and 4) woul d provide increased safety and enhancements to clients' business operations. The name and address of the applicant is: S kyCanvas AP , LLC Attn: Christopher R. Glass Ph: +1 978 473 1473 Email: skycanvasap@gmail.com Address: 12 Woodcrest Road Manchester, MA 01944 Christopher R. Glass holds an Airline Transpor t Rating Rotorcraft Helicopter Certificate #1846977 With Commercial Fixed wing endorsements to include an Instrument Rating. His certific ate is typed for the Canadair Challenger Jet (CL 600) and the Cessna Citation Jet (C650). He has accumulated over 15,000 hours of flight time. He has never had an accident or incident in the 48 years as a certificated pilot. He has bee n flying the DJI P hantom series UAS recreationally for two years and has accumulated 205 flight hours with out incident. SkyCanvas AP respectfully requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regulations:

 14 CF R 21;

 14 CF R 91, et seq.;

 14 CF R 45.23 (b);

 14 CF R 61.113 (a) & (b);

 14 CF R 407 (a)(l);

 14 CF R 409 (a)(2); 14CF R417(a)&(b).

SkyCanvas AP also respectfully requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulation s from:

 14 CF R 45.23(b);

 14 CF R Part 21;

 14 CF R 61.1 1 3 (a) & (b);

 91.7 (a);

 91.9(b)(2);  91.103(b);

 91.109;

 91.119;

 91.12 1 ;

 91.151(a);

 91.203(a) & (b);

 91.405 (a);

 91.407 (a) **(1 );**

 91.409 (a) (2);

 91.417 (a) & (b).

**I. T**  **he Ex t**  **e nt**  **of Re l** **ie f**  **SkyCanvas AP S e**  **e k** **s a nd**  **t h**  **e Re**  **ason I**  **t Seeks Suc h**  **Re li**  **e f** **:** SkyCanvas AP submits this application in accordance with the R efo rm Act, 112 P.L . 95 §§331
- 334, seeking relief from any currently applicable federal aviation regulations FARs pertaining to UASs (unmanned aircraft systems) and operating to prevent SkyCanvas AP contemplated commercial photographic, mapping, and other flight operations within the U.S. nationa l airspace system. The Reform Act in §332 provides for such integration of civil UASs into o ur national airspace system as it is in the public's interest to do so. SkyCanvas AP’s lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, SkyCanvas AP’s l ight duty UASs are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS physical characte ri stics, safety features, and safe practices identified in §333:

 sUAS weight, sUAS overall size,

 sUAS speed over ground,

 sUAS flight zone characteristics,

- Non
- operation near airports (civilian or military),

- Tightly contro lled operation in populated areas,

 Operation of the UAS by VLOS.

 Coordinatio n by a minimum of 3 persons, 2 staff members of SkyCanvas AP and one safety official from the cl i ent. Specific considerations are outlined below. **1 4 C.F.R. Pa**  **r t 2**  **1 ,**  **Sub p**  **ar t H**  **: A i**  **rwort hin**  **ess Ce r**  **ti fi**  **ca t**  **es** 14 C.F
. R . §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural re quireme nt s for th e issuance of airworthiness certificate s as required by F AR §91.203 (a) (1 )
. Given the size and limit e d ope ratin g area associated with the sUASs, an exemption from Part 21 Subpart H mee t s the requireme nts of an e quival e nt l evel of safety under Part 11 and §333 of th e R efo rm A c t. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act bo t h authorize the FAA to exempt aircraft from the requirement for an airworthiness c e rtificate, upon consideration of the size, w e i ght, speed, operational capability, and proximity to airports and populated areas of the particul ar sUAS. In all cases, an ana l ysis of these criteria demonstrates that th e UAS operated without an airworthiness certific ate , in the res tricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated by SkyCanvas AP is les s than 1.3 kg wit h maximal payload consisting of remote se n sing instrumentation, carri es neither no per sons, carries no explosive or flammable mat e rial s including combustib l e fuels, and operates exclusively within a secured area. Unlike other civil airc raft , operations under this exemption will be tightly controlled and monitored by both the pilot (P I C), ' spotter' role designated to act as both the remote sensing controller and secondary monitor for safety i ssues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for sa fety c oncern s and liaisons to the on

- s it e safety officials. These enhancements to current safety practices and regulations, which already apply to civ il aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operation s conducte d with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H . Lastly, application of these same crite ria demonstrates that there is no intrin s i c cre dibl e threat to national security po se d by the UAS, due to its size, s peed of operation, lo cation of operation, l ack of int rinsi c exp l osive materials or flammable liquid fuels, and inability to carry a substantial exte rn a l loa d. **1 4 C.F.R.**  **§45.23 (** **b ). Ma**  **rking of th e**  **Air c**  **raft** The regulation re quires: When marks include only th e Roman ca pita l l e tt e r "N" and the registration number is displayed on limite d , re st rict e d or light

- sport category aircraft or exp erime ntal or provisiona ll y certificate d aircraft, the operator must a l so display on that aircraft n ear eac h e ntrance to th e cabin , cockpit, or pilot station, in l ette r s n ot l ess than 2 in c h es nor more than 6 inch es high, the words " limite d; ' "restricted;' "light

- sport;' " experimental;' or "provisional;' as applicable. Even though the sUAS will have no airworthiness certificate, an exe mpti on may be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which t he word "Experimenta l " can be placed
. G iven the size of the sUAS, two - inch lettering will be impossible. The wo rd "Expe rimental" will be placed on the frame in compliance wit h §45.29 (f) at a size suitable forthe available space. The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 ( f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as "Expe rimental." The FAA has issued the following exe mpti ons to this regulation to Exem

ptions Nos. 10700, 8738, 101 67 and 101 67A. Further markings includ e the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sky
. **14 C.P.**  **R. §6**  **1.11 3**  **(a) & (b): Private**  **Pilot Pri** **v il**  **eges and Limitations: Pilot in**  **Command.** §61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, th e proposed ope rations can achieve the equivalent lev el of safety of current operations by requiring a ground crew member to have a private pilot's license rather than a comme rcial pilot's lic ense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance
. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemp lated by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present l evel of safety achieved by 14 C.P.R. §61.1 1 3 (a) & (b). **1 4**  **C.P.R. §91.7(a): C**  **ivil aircraft airworthiness.**  The regulation requires that no person may operate a civil aircraft unl ess it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for det ermining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subset of which are provided in enclosed s upplemental material, an equivalent level of safety will be provided. **14 C.F.R.**  **§91.9 (b)**  **(2): C**  **i v** **il Aircraft Flight Manual**  **in t**  **h e**  **Aircraft.** §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unles s th e re is available in the aircraft a current approved airp l ane or Rotorcraft F li ght Manual, approved manual material, markings, and p l acards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a physical flight manual on the aircraft. The equivalent level of safety will be ma intained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to his regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, and 10700. **14 C.F.R.**  **§9 1.10**  **3: Preflight action**  This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirement s, landing and takeoff distances and airc raft performance data before initiation of flight. Further, we have proprietary manuals c reated with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to. **14 C.P.R. §91.1**  **09: Flight in s**  **truction**§91.103 provides that no person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction unles s that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual cont rols. Flight control is accomp l ished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inh ere nt in the remote controls utilizing digital communi cati on s wh i ch is paired to the sUAS making it n early impossible to unintentionally or intentionally h ave the control commun i cations interrupted.

**1 4 C.F.R.**  **§9 1.119**  **: M**  **in imum**  **safe altitudes**  §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the h e li co pt er complies with any route or altitudes prescribed for helicopters by the FAA. As this exempti o n is for a sUAS that closely mimic s the behavior of a h elicopter, and the exemption reque sts authority to operate at altitudes up to 400 AG L, an exemption may be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b eyo nd unaided visual line of sight, whichever i s closer. It will however be operated in a res tricte d area with sec urity officials tasked with ensuring pub l i c sa f

e ty , and where buildings and people will not be exposed to operations without their pre

- o btained consent and training. The eq uival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e re it i s o p erated . No flight operation will be take n without th e permission of th e property owner in t

he case of private prope rty o r loc a l officials in the case of public prope rty or private property with public interests. B ecau se of th e a dvanc e notice to the property owner and participants in the remote sensing activity, all affected individu a l s will be aware of the planned flight operations. Compared to flight operations with aircraft o r rotorcraft weighting far more than the maximum 1.3 kg of SkyCanvas’s sUASs proposed herein and the lack of flammable fuel, any risk associate d with these operations i s far l ess t han t hose presently pre se nt ed with conventiona l aircraft operating at or below 500 AGL. In addition, the low

- altitud e operations of the sUAS will e n sure separation between these s mall

- UAS operations and the operatio ns of conventiona l aircraft that must comply with §91.119.
**14 C.F.**  **R .**  **§ 91.**  **1 21 Altime**  **t er Settings**  §91.121 requires each person operating an aircraft to maintain cruis in g a ltitud e by refe rence to an altimeter that is set " ... to the e l evati on of the departure airport or an appropri ate a ltimete r setting available before d eparture." A s th e sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be ne e d e d
. An equiva lent lev e l of safety wi ll b e achieved by th e operator, confirming the altitud e of th e launc h s ite s hown on the GPS altitude indicator b efo re flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurat e dete c tion of height. **14 C.F.R.**  **§9 1.15l**  **(a): Fue**  **l Requirements for**  **Flig ht**  **in VFR Conditions**  §9 1.1 5 1 (a) prohibits an individual from beginning "a flight in an airp l an e und er VF R conditions unl ess (considering wind an d fo recast weather conditions) there i s enough fuel to fly to thefirst point of int e nd ed landing, and, assuming normal cruising sp eed

- (1) During the d ay, to fly after

that for at least 30 minutes; or (2) At night, to fly after that for at l east 45 minutes:' The batt ery powering the sUAS provides approximately 20 minutes of powered flight in hover mo de with out payload. SkyCanvas AP’s sUAS will not be able to meet the 30 minute reserve requirement in 14 CPR §9 1.15 1. Operating the small UAS, in a tightly controlled area where on ly people and property owners or official representatives who have s i gned waivers will be allo we d , with less than 30 minutes of reserve powe r , does not enge nd e r the ty pe of risks that Sectio n 9l.l51(a) was intended to alleviate give n the size and speed of the s mall UAS. SkyCanvas AP believes that an equivalent level of safety can be achieved by limiting flights to >> 15 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exe mption s h ave been granted to other operation s, includin g Ex em ptions 2689F, 5745, 10673 , and 10808.
**1 4 C.P.**  **R . §9**  **1. 2**  **0 3 (a)**  & **(b): Ca r**  **ry in**  **g C i** **v il**  **A ir**  **craft Cert i**  **fica ti**  **on a nd**  **Reg i**  **st r**  **a t**  **ion** The regulation provides in pertinent 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
. .. (b) No person may operate a civi l aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew . The sUAS fully loaded weighs no mo re than l.3kg and is operated without an o nboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS
. An equivalent level of safety wi ll be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exem ptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. **1 4 C.P.**  **R. §9**  **1. 405 (a); 4**  **0 7 (a) (**  **1 );**  **4 0**  **9 (a) (2);**  **4 1**  **7(a) & ( b**  **): Mai nt**  **e n**  **a n**  **ce I**  **ns p**  **ect i**  **o n**  **s** These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter
. .. ;' and others shall inspect o r maintain the aircraft in com pliance with Part 43
. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these sma ll UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 40 0 feet AGL. The operator will ensure that the UAS is in working order prior to ini tiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suite d to maintain the aircraft in an airworthy condition to provide the equiva l ent level of safety. An exemption granted to SkyCanvas AP wo ul d permit its operation of lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited airspace. SkyCanvas AP utilizes local business' safety officers in specifically determi ned areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goa l s. Technical enhancements to current safety controls will a llow SkyCanvas AP to operate exceeding current safety specifications, and stay ahead of, ormeet, new ones being imp l emented by the FAA and Department of Transportation. Further, SkyCanvas AP conducts its operations in compliance with protocols described h ere in or as otherwise established by the FAA.
**II. C**  **o m**  **me rci**  **a l and Publi**  **c Benefit**  **s** We at SkyCanvas AP believe that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system) and efficient means to meet technical problem s so lvable by elevated data collection instruments. SkyCanvas AP’s client base are ty pically small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection 

### by photographic, videographic or lidar based s urveying. By mo ving these functions onto sUA S base d a ir craft, the potential for l oss of life or prop e rty i s diminished due to the gr eater contr o l in a smaller and safe r aircraft that holds no persons. Second, th ere are n o reac tiv e or combustible mat e rial s on board the sUAS and thus the pot e nti a l for fire or explosions i s greatly diminished. Third , the s mall size and extreme man e uverability of SkyCanvas AP’s UASs allow the PIC to avo i d hazards. Lastly, du e to the nature of the remot e se nsing instrumentation onbo ard, the sUAS can mainta in quite a safe dis t ance between the aircraft and the objec t (s) undergoing sc rutiny. Accor dingly, SkyCanvas AP’s UASs have operated and will contin ue to operate at and above current safety levels.

**Ill. F**  **l i**  **g h**  **t Capabi l** **it i**  **e s a**  **n d**  **Ch a**  **ra c**  **t eris**  **ti c**  **s of**  **SkyCanvas 's**  **UAS s**  

### Persuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and cha

r acteristics of the sUAS. SkyCanvas AP’s UAS s utili zes four (4 ) counter

rotating propellers paired oppositely to each other for balance, control and stability. The total s pan of the sUAS i s 590m m a ll owing for stab l e flight or l anding even with the sudden onset of d etrime ntal e nvi ronmenta l conditions. The sUAS's hav e a maxima l un i t+ payload ma ss of l.3 kg, including cinematic/photographic e quipment. They are capable of verti cal and horizontal operations but, i n practice, is operated only w i thin unaided VLOS of the PIC. In addition to the PI C, SkyCanvas employs a spotter (VOS role)
. Both are within unaided verbal communication range. These per so nn el are suppleme nted by safety off i cial s provided by the client who ar e instructed t o cordon off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the event of loss of visua l of the UAS, the PI C can change flight controls from Cartesian (X,Y,Z) based controls to radial (r, a ,h) based cont rols which a ll ows the PIC to utilize one controller axis to recall the VAS to the PI C' s position without concern to the cur rent heading of the sUAS. In the event of loss of sight of the sUAS into an area containing hazards or possible hazards, the PI C ha s a heads

-up - display containing a live video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in 20kph wind gusts extreme environmental condition beyond the range of conditions within the scope for sUAS operation. All of SkyCanvas AP ’s sUASs utilize LiPo (lithium polyme r) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between twelve (12 ) to fifteen (15 ) minutes allowing the staff to work with small flight areas per phase. The maximum flight time is ~ 23 minutes, however practical safe operation limits this to ~12
- 15 minutes to give am p le time to control the sUAS to a saf e landing zone. SkyCanvas AP further restricts flight time by not operating it s sUASs with less than twenty five percent battery capacity
. Further safety management systems in place include a GPS mode that allows SkyCanvas AP’s sUASs to hover in place if communication with the PIC is lost and optionally follow a set of way points at a set speed and height to a 'home base'predesigned safe l anding zone
. **I V. Reasons Why an Exempt** **i on**  **to MSAeria l**  **Wi ll**  **Not Adversely Affect Safety Standards**SkyCanvas AP contends that operation of it's sUASs will not "create a hazard to users of the

national airspace system or th e public:' as stated in 112 P. L. 95 §333 (b). Given the diminutive size and weight of SkyCanvas AP’s sUASs, combined with their operation in cordoned off and well

controlled areas, SkyCanvas AP 's sUASs falls within Co ngress' s contemplated safety zone. SkyCanvas AP’s sUASs have an established safety record bolstered by multi

-point preflight checkli st, awareness of their surroundings and intimate knowledge of the behavior of the sUAS platform in many weather conditions. This safety record and impl emented operational pra ctices demonstrate an awareness of public safety. SkyCanvas AP’s operations routinely provide a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules. SkyCanvas AP does not operate its s UASs on or near airports and generally has only operated its fleet on private grounds with co rdoned off areas or areas under the control of the property owner I client with assistance by safety officials em ployed by the business. SkyCanvas AP determines the areas needed to fulfill the clients ' goals and only operates its s UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially 

### by the RC UAS trade and hobby groups and recently codified by relevant FA Rs. SkyCanvas AP standardized on the foll owing practices to ensure safe operation of it's UASs:
• Work with on - site personnel to plan the flight goa l s
• Work with on - site personnel to restrict access to non

- esse ntial persons
• Operation by unaided VLOS operation only
• Operation in phases 12

- 15 minutes in length
• Operation to minimal 25% battery power
• Operation of d evi ce to GPS aided readout to 4 00ft at maximum
• Pre
-programmed fail

- safes that ensure specific b e havior per i ss u e
• Two main roles s upplemented by on

- s it e safety p e rsonn e l
• E mpl oy contro ll ed life cycle management of compon ent s to guard against multiple failures
• Preform a site check day(s) before flight to identify pot enti al issues
• Subscribe to relevant local weather and safety a l erts SkyCanvas AP has experi ence in similar fields and has ad apted this experience in it's use of UASs to increase safety. In co mbination to th e ever expanding knowledge reposito ri es from hobbyist s and experts alike, SkyCanvas AP i s constantly evo l ving it 's practice s when th e re is a clear benefit to ope ration s or increas ed safety e l ement. **A. Summary** Pursuant to 14 C.F
. R. Part 11 , the following summary i s provid e d for publication in the Federal Register, sho uld it b e d eter min ed that publication is needed: SkyCanvas AP {applicant) see k s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109;91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 91.409 (a) {2)

and 91.417 (a) & (b) to operate commercially a small unmanned ve hicle (1.3kg or less) in elevated photographic and re mo te sensing ope rati ons. Approval of exemptions allowin g commercial operation s of sUASs in the media indu st ry will e nhan ce safety by reducing risk associated wit h conventional aircraft ope rations and othe r means of elevated re mo te sensing involving persons. The public benefit se r ved by approval of this petition i s increased aware n ess o f characteri stics of difficult imaging targets. A sUAS we i ghing fewer than 1.3kg and powered by sealed batteries eliminates virtually all associate d risk inherent in operating convention al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed d ata. The operation of sma ll UASs, we ighting less than 55lbs., co ndu cted in the stri c t conditions outlined above, will provide an equival e nt l e vel of safety supporting the grant of the exemptions requested herein, including exempting the app li cant from the requirements of Part 21 and a llowing c ommerc ial operations. 

### The FAA has b een given the authori ty t o i ssu e the exemption to SkyCanvas AP purs u ant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval of this petition. Best regards, Christopher R. Glass Attached: Supplement A: Physical Characteristics of UAS Attached: Supplement B: Flight Operation and Procedure Manual

### Supplement A: Physical Characteristics of SkyCanvas’s UAS **s**

Dear Sir or Madam, Please find in this document specifications related to UAS’s subject to consideration for exemption. All specifications are given by the manufacturer. It is of note that these specifications in some instances constitute the maximal values discovered by t he manufacturer and averaged over several test units. SkyCanvas AP utilizes these metrics when forming safe and sustainable flight operations and in no way do the specifications extrema contained herein constitutes normal SkyCanvas AP flight parameters. 

### SkyCanvas AP UAS 1: DJI Phantom 2 Vision Plus


### Aircraft **Supported Battery** DJI 5200mAh LiPo Battery **Weight (Battery & Propellers Included)** 1242g **Hover Accuracy (Ready To Fly)** Vertical: 0.8m; Horizontal: 2.5m **Max Yaw Angular Velocity** 200°/s **Max Tilt**  **able Angle**  35° **Max Ascent / Descent Speed** Ascent: 6m/s; Descent: 2m/s **Max Flight Speed** 15m /s (Not Recommended) **Diagonal Motor -**  **Motor Distance** 350mm 

### Remote Control **Operating Frequency** 5.728 GHz
- 5.85 GHz **Communication Distance (Open Area) CE Compliance: 400m**  **; FCC Compliance: 800m**  **Receiver Sensitivity (1%PER)**

**- 93dBm**  **Transmitter Power CE Compliance: 25m** **W; FCC Compliance: 100m W**  **Working Voltage 120 m** **A@3.7V Built**  **- In LiPo Battery Working Current/Capacity**  **3.7V, 2000m Ah**  

### SkyCanvas AP UAS 2:DJI Phantom 3 Professional



### Aircraft **Weight (Including Battery And Propellers)** 1280 g **Diagonal Size (Including Propellers)** 590 mm **Max Ascent Speed** 5 m/s **Max Descent Speed** 3 m/s **Hover Accuracy** Vertical: +/
- 0.1 m (when Vision Positioning is active) or +/
- 0.5 m Horizontal: +/
- 1.5 m **Max Speed** 16 m/s (ATTI mode, no wind) **GPS Mode** GPS/GLONASS


### Remote Controller **Operating Frequency** 2.400 GHz
- 2.483 GHz **Video Output Port** USB **Operating Temperature** 0°C
- 40°C **Battery** 6000 mAh LiPo 2S **Mobile Device Holder** For tablet or phone **Receiver Sensitivity (1%PER)** 

- 101 dBm ±2 dBm **Transmitter Power (EIRP)** CC: 20 dBm E: 16 dBm **Working Voltage** 1.2 A @7.4 V

**S u**  **pp l**  **ement B**  **: S u**  **mm a**  **r y**  **S ec**  **tio n**  **s of Flig**  **h t**  **O pe**  **r atio**  **n s**  **an d**  **P r**  **oce du**  **re Ma n**  **ua l**  **( F**  **OP M** **) Dea**  **r Sir or Madam ,**  

### I. **I ntroduction**  **This manual describes the n**  **otable roles, tasks, and operations performed by SkyCanvas AP**  **. The aim**  **i s**  **to d**  **ocument everything that is needed to be done du r**  **i n**  **g a m i**  **ssion, so**  **it can**  **act as a r**  **efe r**  **ence poin t**  **for team m**  **e m**  **bers.**

### I **I. R o**  **les and R e**  **spon s**  **ibi l**  **iti es** 

**As mu**  **c h a**  **s i**  **s po**  **ss i** **b l**  **e, SkyCanvas AP**  **s ta**  **ff att**  **e mpt t**  **o h**  **ave r**  **e dund**  **a ncy in**  **ex p**  **e r**  **t i**  **se a nd**  **s kill**  **set r**  **e la**  **te d**  **to ope r**  **at i**  **o n**  **s of th**  **e U A**  **S. P**  **il ot**  **in Co**  **m ma**  **n d**  **( PI**  **C)**
• Piloting the UAV. This will i n clud e:

- Takeoff

- Norma l F li ght

- F light durin g eme rge n cy proc e dur es

- Landi ng • Assem bli ng the UAV • Perfo rms pre - flight checks of the firmwar e • Performs pre

- flight checks of the hardware • Preforms pre

- flight checks of the software **Spotter**


### • Relays notable flight parameters such as flight times, battery strength, metrics from the UAS. • Primary communication link between pilot and on

- site safety personnel • Will hold physical documents related to current flight • Preforms pre

- flight checks of the data collection equipment • Monitors ground and greater above

- ground environment for safety concerns 

### Ill **. P**  **re -**  **Fligh t Chec**  **kl is**  **t A.**  **B e**  **f o**  **r e**  **P ower A**  **ppl ie**  **d**


### • Check f or physical damage and any missing hardware , • Check all elec tronic s present and connected/ check cord connections are tight. • Confirm all batteries charged, • Check all rotors and moving parts for debris that would prevent proper operation. • Check weather patterns the night beforehand. • Check data collection equipment for proper operation. • Check data collect i on equipment for i ssues that woul d impact safe operation of fl i ght pac kage.
**B. Aft**  **e r Po**  **we r**  **So ur**  **ce Appli**  **e d** 


### • Confirm proper power reading of battery, • Run hardware based systems check, • Run software based systems check, • Check flight LED array, • Confirm proper radio link to flight controller, • Confirm proper radio link to data collection device controlle r , • Calibrate Compass on UAS • Confirm desired behavior of emergency fail safes

### • Check with on

- site safety personnel for any changes in goals/flight path.



### IV. **Flight -**  **time Checklist**

• Check with on - site safety personnel for a safe flight area for first flight • Check for ground hazards at home

-base and rectify • Confirm 

### > 8 satellite GPS lock • Initialize rotors and check for proper operation • Perform controlled flight to hover mode ap proximately 3m above ground • Perform controlled multi

- axis roll procedure to check for proper orchestrated rotor operation • Perform controlled multi

- axis (if applicable) control procedure of data collection package • Land the UAS and check for proper de

- initialization of rotors • Perform controlled flight to hover mode approximately 5m above ground • Execute Mission 

### V. Standing **Procedures**

• The Pilot, Spotter, and Technician will be the only SkyCanvas AP staff members in the forward flight area. On
- site personnel will be within verbal range and behind SkyCanvas AP staff. • When 30% power remains pilot maneuvers UAS back to home base. • Fl ight time is limited to approximately 15 minutes and goals will be planned in phases to be accomplished during this time. • Fl ight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 350ft whichever is l ess. • Fl ight time is limited to operation in safe environmental conditions, • Fl ight staff will maintain prox imity so as to be in clear and unaided verbal range, • The PIC will announce a ll mo vements to SkyCanvas AP staff and on

- site staff so that non

PI C staff members can identify possible safety concerns before operation of the UAS to the next waypoint or position