P a g e | 1 © 2015 SkyPixel Media LLC All Rights Reserved. SkyPixel Media LLC
9 9249 S Broadway Suite 200

- 224 Highlands Ranch , Co 80 129 O +1 303 847 1705

www. skypixelmedia .com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

October 3 rd , 2015

Re : Petition of SkyPixel Media LLC ("Petitioner") for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

Dear Madam or Sir

,

SkyPixel Media LLC is petitioning the Federal Aviation Administration (FAA) for an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R Part 11

. The exemption would allow operation of the DJI Phantom 2, DJI S1000+, and Trimble UX5 unm anned aircraft systems (UAS) for the purpose of aerial photography/video acquisition, vertical and horizontal construction inspections, precision farming, real estate, land surveying, emergency search and rescue, and research relative to data acquisition s ystems. This document will outline requested relief from regulations pertaining to this exemption.

SkyPixel Media LLC agrees to operate within the boundaries set forth by this exemption. Along with rules and regulations that the FAA has in place

, SkyPixel Media LLC plans to use additional safety precautions were they see fit to ensure safe sUAS operations. Implementation of lightweight small

unmanned aircraft systems (sUAS) is a tool that can greatly improve the safety standards of our National Airspace System (NAS). sUAS can fly operations that would traditionally require manned aircraft, carrying pilots and gallons of flammable fuel. Please allow SkyPixel Media LLC to offer sUAS operations to promote the safe

, efficient and responsible use of sUAS.

Regards,

Blake Scott CEO and Founder SkyPixel Media LLC 303

- 847

- 1705 info@skypixelmedia.comP a g e | 2 © 2015 SkyPixel Media LLC All Rights Reserved. 

# Table of Contents

Glossary of Abbreviations................................................................................

...... 2

List of Attachments........................................................................................

. .......3

Introduction and Interest of Petitioner...........................................

. ......................3

Unmanned Aerial Systems............... ......................................................................3

Equipment List.......................................................................................................4

Unmanned Aircraft Pilot in Command (PIC)......................... .................................6

Operations of sUAS ..............................................................................................6

Requested Exemptions from Regulations ...........................................................10

Public Interest......................................................................................................13

Conclusion...........................................................................................................13



## Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificat e of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

MAAP Mid Atlantic Aviation Partnership

NAS National Airspace System

PIC Pilot in Command

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VLS Visual Line of SightP a g e | 3 © 2015 SkyPixel Media LLC All Rights Reserved.



## List of Appendixes

Appendix: A

DJI S1000+ Operating Manual

Appendix B:

A2 Flight Control Operating Manual

Appendix C:

Futaba 8FG Operating Manual

Appendix D:

DJI Phantom 2 Operating Manual

Appendix E:

Naza M flight control Operating Manual

Appendix F:

Trimble UX5 User Guide

Appendix G:

SkyPixel Media LLC Standard Operating Procedures and Checklists

Appendix H:

SkyPixel Media LLC sUAS Preflight Form

The eight attachments listed above are referenced in the request for exemption and contain trade secret and commercial proprietary information that SkyPixel Media LLC has not and will not share with others except under appropriate confidentiality agreements. The SkyPixel Media LLC Standard Operating Procedures (SOP) attachment contains operating conditions and procedu res that have been developed exclusively by SkyPixel Media LLC and that are not available to the public. SkyPixel Media LLC is requesting that these a ttachments be treated as proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are protected from public release under the Freedom of Information Act. See 5 U.S.C. 552 et seq

.



# Section 1: Introduction and Interest of Petitioner

SkyPixel Media LLC is a business entity located in Highlands Ranch, Co that intends to use two current DJI model sUAS platforms , and one Trimble model sUAS platform to engage in aerial photography/video acquisition, vertical and horizontal construction inspections, precision farming, real estate, land surveying, emergency search and rescue, and research relative to data acquisitio n systems. SkyPixel Media LLC is committed to offering safe and responsible sUAS flight operations.P a g e | 4 © 2015 SkyPixel Media LLC All Rights Reserved.

It shall be the intent of every sUAS operator to make a responsible effort to not invade a person's

reas onable expectation of privacy when operating the UAS while performing safe flight operations. When operating the sUAS, SkyPixel Media LLC operators will abide by all FAA Regulations for flight and receiv e the proper authorization for flight. 

# Section 2: Unmanned Aerial Systems

Regarding the Unmanned Aircraft System from FAA Documentation

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners should describe the design and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft performance and performance limitations, operating procedures, and airc raft loading information in as much detail as possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document.

NOTE: The FAA will consider all information and data submitted by the petitioner that describes the UAS deve lopmental and operational history. This could include statistical data or other documentation for the specific design and performance characteristics of the UAS, including the operational history and operational failure modes, obtained through previous Res earch & Development (R&D) and/or flight test activities, e.g. operations conducted under a COA, with a civil airworthiness certificate, or under other authorized operating conditions.

2. Petitioners should describe any procedures they would implement, such as pre

- flight inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the petition, an Aircraft Flight Manual, a Maintenance and Inspection Manual, or similar document.

NOTE: The Aircraft F light Manual and Maintenance and Inspection Manual may be separate documents or combined in a single document

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with FCC requirements upon request

. 

# General Information Pertaining to All Proposed sUAS

SkyPixel Media LLC will operate less than fifty

- five pound sUAS, with the ability to conduct precision data collection, inspections, and aerial mapping, with payloads capable of supporting this mission.

Prior to each flight the SkyPixel Media LLC PIC shall inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveal s a condition that affects the safe operation of the sUAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be incl uded in the preflight inspection. All maintenance and alterations must be properly documented in aircraft records. All discrepancies noted shall be documented as described in the SkyPixel Media LLC SOP ( Section 5, Page 14 ).

Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, shall undergo a functional test flight in accordance with the manufact urer’s manual and SkyPixel Media LLC SOP ( Section 5, Page 10 ). The SkyPixel Media LLC PIC who conducts the functional test flight shall make an entry in the sUAS aircraft logbook of the flight.

SkyPixel Media LLC shall follow the manufacturer’s sUAS aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements, with particular attention t o flight criticalP a g e | 5 © 2015 SkyPixel Media LLC All Rights Reserved.

components that may not be addressed in the manufacturer’s manuals.

SkyPixel Media LLC shall carry out the maintenance, inspections and record keeping req uirements, in accordance with the SkyPixel Media LLC SOP . Maintenance, inspection, and alterations must be noted in the aircraft logbook , including total flight hours, and description of work accomplished. Only personnel who are authorized shall perform such operations

. SkyPixel Media LLC SOP ( Section 9, Page 19 ).

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and Safety Bulletins.

SkyPixel Media LLC technicians will receive and document training referenced in the manufacturer’s operations manual.

SkyPixel Media LLC technicians shall make a record entry in the sUAS logbook or equivalent document of the corrective action taken against discrepancies discovered between inspections.

Before conducting operations, the radio frequency spectrum u sed for operation and control of the sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

# Equipment List

DJI S1000+

SkyPixel Media LLC seeks an exemption to operate a DJI

- S1000+ sUAS for compensation or hire. The DJI

S1000+ is comprised of a multi

- rotor unmanned aircraft and two handheld ground control stations. The DJI

- S1000+ has a maximum gross weight of approximately 24 pounds, diagonal wheelbase of 41.4 inches, and height of approximately 18 inches. The DJI

- S1000+ is equipped with eight rotors driven by eight lithium polymer battery powered electric motors.

Design and operational characteristics are provided in DJI S1000 + Operating Manual ( Section 1, Page 2 ).

SkyPixel Media LLC f light crews shall conduct pre

- flight inspections as documented in DJI S1000+ Operating Manual ( Section 5, Page 10 )

.

DJI Phantom 2

SkyPixel Media LLC seeks an exemption to operate a DJI Phantom 2 sUAS, for compensation or hire. The DJI Phantom 2 is comprised of a quad

- rotor unmanned aircraft and a handheld ground control station. The Phantom 2 has a maxim um gross weight of approximately 2.8 pounds, diameter (rotor span) 23.75 inches, width of 12.5 inches, and height of 8.1 inches. The Phantom 2 is equipped with four rotors driven by four lithium polymer battery powered electric motors.

Design and operation al characteristics are provided in the DJI Phantom 2 Operat ing Manual (Page 35). SkyPixel Media LLC f light crews shall conduct pre

- flight inspections as documented in DJI Phantom 2 Operating Manual (Page 24)

.

Trimble UX5

SkyPixel Media LLC seeks an exemption to operate a Trimble UX5 sUAS, for compensation or hire. The Trimble UX5 is comprised of a fixed

- wing unmanned aircraft and a handheld ground control station. The Trimble UX5 has a maximum gross weight of approximately 5.5 pounds, diameter (wing span) 39.36 inches, width of 25.6 inches, and height of 4.1 inches. The Trimble UX5 is equipped with a single rotor driven by a lithium polymer battery powered electric motor.

Design and operational characteristics are provided in the Trimble UX5 Datasheet (Page 2). SkyPixelP a g e | 6 © 2015 SkyPixel Media LLC All Rights Reserved.

Media LLC f light crews shall conduct pre

- flight inspections as documented in the Trimble UX5 Operating Manual (Page 49

- 51)

. 

# Section 3: Unmanned Aircraft Pilot in Command (PIC)

Regarding the Unmanned Aircraft PIC

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including infor mation such as: the level of airman certificate held; any applicable training related to the operation; and any minimum hours of flight experience required by the PIC(s), both total flight time and the time with the particular UAS. If the operation would u se visual observers, petitioners should describe their roles and qualifications.

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for the operation of the UAS.

All SkyPixel Med ia LLC Flight Crews , including PIC and Visual Observers (VO), will be qualified as directed by SkyPixel Media LLC SOP ( Section 1, Page 1 ).

All flight crewmembers, including SkyPixel Media LLC PIC and VO, will have an understanding of, and comply with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, applicable to the airspace where the sUAS will operate. Specifically all SkyPixel Media LLC flight crew members will receive training on the rules and responsibilities described in 14 C.F.R Part 91 Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including standard ATC phraseo logy and communication.

The SkyPixel Media LLC PIC must possess at least a current private, recreational or sport pilot certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R Section 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

Prior to operations conducted for the purpose of aerial imagery and videography (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R Sect ion 61.51(b), a minimum of 25 hours of total time as a sUAS pilot and at least ten hours logged as a sUAS pilot with similar sUAS type (fixed wing or rotary). Prior documented flight experience that was obtained in compliance with applicable regulations ma y satisfy this requirement. Training, proficiency, and experience building flights are requested to be conducted under this grant of exception to accomplish the required flight cycles and flight time. During training, proficiency, and experience building f lights, all persons not essential for flight operations will be considered non

- participants and the PIC will operate the sUAS with appropriate distance from non

- participants in accordance with 14 C.F.R Section 91.119.

Prior to operations conducted for the purpose of precision agriculture (or similar operations), the SkyPixel Media LLC PIC must have accumulated and logged in a manner consistent with 14 C.F.R Section 61.51(b), a minimum of five hours as a sUAS PIC operating the make and model of the sUAS to be utilized for operations under this requested exemption, and three take

- offs an d landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights are requested to be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During train ing, proficiency, experience building, and take

- off and landing currency flights all personnel not essential for flight operations are considered nonparticipants, and the PIC must operate the sUAS with appropriate distance from nonparticipants in accordanc e with 14 C.F.R Section 91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all time s. This condition and limitation is consistent with all FAA approved Exemptions.P a g e | 7 © 2015 SkyPixel Media LLC All Rights Reserved. 

# Section 4: Operations of sUAS

Regarding the Operation of the Unmanned Aircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should descri be how the proposed operation(s) would not adversely affect safety, or how they would provide a level of safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners should address any plans to implement clearly defin ed operational borders and procedures to ensure public safety, which includes persons and property both in the air and on the ground. This can be described in the petition, in an Operations Manual, or similar document.

NOTE: The FAA will closely examine th e proposed operation(s) with respect to safety of flight, NAS safety considerations, and the safety of the non

- participating persons and property during the operational period and within the operational area.

7. Petitioners should specify the proposed maxi mum operating speed and altitude, and describe minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an Operations Manual, or similar document.

The sUAS shall remain clear and yield the right of way to all other manned aviation operations and activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes reported to ATC will be in feet.

The multi

- rotor sUAS shall not be flown at a ground speed exceeding 45 mph.

SkyPixel Media LLC sUAS Operations will be conducted under vis ual meteorological conditions (VMC). The sUAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

If the sUAS loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with SkyPixel Media LLC SOP (Section 5, Page 12

.

The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal crui sing speed to the intended landing point and land the sUAS with 25% battery power remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by serial numbers, registered in accordance with 14 C.F.R part 47, and have identi fication (N

- Number) markings in accordance with 14 C.F.R part 45, Subpart C. Markings will be as large as practicable.

The sUAS documents required under 14 C.F.R 91.9 and 91.203 shall be available to the PIC at the Ground Control Station of the sUAS anyti me the aircraft is operating. Those documents shall be available to the Administrator or any law enforcement official upon request.

Any sUAS incidents, accidents or flight operations that transgress the lateral or vertical boundaries of the operational are a as defined by the applicable COA shall be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.P a g e | 8 © 2015 SkyPixel Media LLC All Rights Reserved.

Unless otherwise specified in this petition, the sUAS PIC, and the sUAS operations shall comply with all applicable parts of 14 C.F.R including, but not limited to, parts 45, 47, 61 and 91.

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory mandate under Section 333 regarding proximity to populated areas. These issues can be addressed in the petition, an Operations Manual, or similar document.

The sU AS shall not be operated over congested or densely populated areas. These areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each wor k site will also be evaluated based on local conditions.

Operations of sUAS may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special
pur pose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary; but never so close to present an undue hazard. This is consistent with Exemption No. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission, and the PIC makes a safety assessment of the risk from operatio ns and determines that it does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all nonparticipating persons unless barriers or structures are presen t that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. SkyPixel Media LLC shall ensure that nonparticipating persons remain under such protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the sUAS, flight operations will cease immediately. This is consistent with Exemption No. 11138.

All operations of sUAS shall be conducted with the permiss ion from the land owner/controller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted.

9. Petitioners should describe if they intend to operate in the proxim ity of any airports, in accordance with the statutory mandate under Section 333 regarding proximity to airports.

The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request. This is consistent with Exemption No 11159.

10. The UAS must be operated within visual line

- of

- sight (VLOS), in accordance with the statutory mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his mand ate.

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC to be able to use human vision to see the sUAS unaided by any device other than corrective lenses, as specified on the PIC’s FAA issued medical certificate.

Al l sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC and VO must be designated before the flig ht and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed inP a g e | 9 © 2015 SkyPixel Media LLC All Rights Reserved.

SkyPixel Media LLC SOP (Section 1, Page 1)

. The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not be conducted during night as defined in 14 C.F.R 1.1.

11. Petitioners should describe any procedures they would implement for conducting a prefli ght safety risk assessment to determine that the UAS is in a condition for safe flight (14 C.F.R § 91.7(b)) and that the planned operation can be completed safely. These procedures can be addressed in the petition, an Aircraft Flight Manual, Operations Man ual, or similar document.

SkyPixel Media LLC will conduct preflight safety risk assessments to determine that the sUAS is in a condition for safe flight (14 C.F.R Section 91.7(b)) and that the planned operation can be completed safely. Specific procedures are addressed in SkyPi xel Media LLC SOP ( Section 5 , Pa ge 10 ), and sUAS Operation Manuals.

12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture and television filming, or pipeline and power line patrol

– petitioners should describe their intended coordination in this regard for their proposed operation(s).

SkyPixel Media LLC operations do not require a notification to Flight Standards District Offices (FSDOs) at this time.

13. The FAA intends to require entities who obtain an exemption under this process to also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS.

SkyPixel Media LLC shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization ( COA) prior to conducting any operations under this requested grant of exemption. Additionally, SkyPixel Media LLC will request a Notice to Airmen (NOTAM) not more than 72 hours, but not less than 48 hours prior to the operation. 

# Section 5: Requested Exemptions from Regulations

Considered Regulation Title Recommended Action

14 C.F.R Part 21.185 Airworthiness

Certificate SkyPixel Media LLC recommends that in consideration of the

size, weight, speed and limited operating area associated with these aircraft and their operation, the Secretary of Transportation determine that these aircraft meet the conditions of Section 333. Relief is not neces sary

.

14 C.F.R. Part 45.23(b) Display of

marks SkyPixel Media LLC sUAS shall be identified by serial number,

registered in accordance with 14 C.F.R part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R part 45, Subpart C. Markings will be as large as practicable. Relief is not necessary.

14 C.F.R. Part 61.113(a) Private pilot

privileges and limitations The FAA has found in previous grants of exemption that a PIC

with a private, recreational or sport pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a h azard to persons or property on the ground. Request relief with limitations and conditions specified in this petition.P a g e | 10 © 2015 SkyPixel Media LLC All Rights Reserved.

14 C.F.R. Part 61.133(b) Commercial

pilot privileges and limitations The FAA has found in previous grants of exemption that a PIC

with a private, recreational or sport pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.7(a) Civil Aircraft

Airworthiness SkyPixel Media LLC recommends that in consideration of the

size, weight, speed and limite d operating area associated with this aircraft and its operation, the Secretary of Transportation determines that these aircraft meet the conditions of Section 333. Relief is not necessary

.

14 C.F.R. Part 91.9(b)(2) &(c) Civil Aircraft

Flight Manual, Marking, and Placard Requirements The FAA has previously determined that relief from these

sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. Relief is not necessary

.

14 C.F.R. Part 91.103

14 C.F.R. Part 91.109(a) Preflight Action

Flight Instruction SkyPixel Media LLC will perform . Relief is not necessary

.

SkyPixel Media LLC will conduct all flight training through procedures specified in Training Instruction during dedicated training sessions. Based on previous decisions made by the FAA for sUAS petitions regarding this regulation, relief is not
necessary.

14 C.F.R. Part 91 .119(c) Minimum Safe

Altitude Aircraft will be operated below 400 AGL, but not over congested

areas. Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 121 Altimeter

Settings The proposed aircraft have a barometric a ltimeter and GPS

derived altitude capabilities. SkyPixel Media LLC recommends that the altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations. Request relief with limitations and conditions specified in this petit ion.

14 C.F.R. Part 91.151(a) Fuel

Requirements in VFR Prior relief has been granted for manned and unmanned aircraft

to operate at less than prescribed minimums. Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.203(a) and (b) Certifications

Required Original intent of these regulations was to display an aircraft’s

airworthiness, certification and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandu m subject, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, relief is not necessary

.P a g e | 11 © 2015 SkyPixel Media LLC All Rights Reserved.

14 C.F.R. Part 91.405(a) Maintenance

Required Request relief with limitations an d conditions specified in this

petition.

14 C.F.R. Part 91.407(a)(1) Operation after

Maintenance Request relief with limitations and conditions specified in this

petition.

14 C.F.R. Part 91.409(a)(1) and (2) Inspections Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.417(a) and (b) Maintenance

Records Request relief with limitations and conditions specified in this

petition.



# Public Interest

SkyPixel Media LLC operations of sUAS to perform aerial photography/video acquisition, vertical and horizontal construction inspections, precision farming, real estate, land surveying, emergency search and rescue, and research relative to data acquisition systems , will reduce risk to life and property by decreasing the requirements of personnel to operate manned aircraft to perform these tasks. SkyPixel Media LLC will use battery

- powered sUAS that serve as safe and efficient alternatives to the manned aircraft commonly utilized to conduct precision agriculture inspections/data collections and aerial mapping. Also, the flight data, inspection results, recorded observations and lessons learned from these operations will be comp iled to further enhance its current safety program.

The applicant proposes that the exemptions requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at leas t an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to aerial photography/video acquisition, precision agriculture inspections/data collections a nd aerial mapping, which is currently being conducted by manned aircraft.



# Conclusion

SkyPixel Media LLC seeks exemption from the requirements of 14 C.F.R § 61.113(a), 61.133(b), 121, 91,119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), and (2) and 91.417(a).

As set forth above, SkyPixel Media LLC seeks exemption pursuant to 14 C.F.R § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation of the above

- named sUAS commercially for the purpose of conducting aerial photography/video acquisition, vertic al and horizontal construction inspections , real estate, land surveying, emergency search and rescue, and research relative to data acquisition systems in non

- congested areas. By granting this Petition, the FAA will allow SkyPixel Media LLC to safely, effectively and efficiently operate sUAS commercially.P a g e | 12 © 2015 SkyPixel Media LLC All Rights Reserved.

Submitted on October 3 rd , 2015

Regards,

Blake Scott

CEO and Founder

SkyPixel Media LLC

9249 S. Broadway Suite 200

- 224

Highlands Ranch, C O 80129