**Tech Works Studios LLC, (dba) Skyfilm Drones**

**Valek Sykes Owner 13405 Seymour Myers Blvd unit 5**  **Covington LA 70433 Tel: (504) 722-1504**  **Valek@techworksstudios.com February 15, 2016** 

**To: Federal Aviation Administration ,**

**Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the**  **Reform Act), and 14 C.F.R. Part 11, },Tech Works Stu dios LLC, (dba) Skyfilm**  **Drones, a Louisiana based limited liability company , operating a Small Unmanned**  **Aircraft System ("sUAS") or UA, unmanned aircraft, equipped to conduct aerial**  **photography and survey for various industries, here by applies for an exemption from**  **the Federal Aviation Regulations (FARs) listed belo w to allow operation of our sUAS**  **commercially in airspace regulated by the Federal A viation Administration (FAA), so**  **long as such operations are conducted with and unde r the conditions outlined herein**  **or as may be established by the FAA as required by Section 333.**  **We are asking for these exemptions and any others t hat may apply to our needs:** 

Regulations from which the exemption is requested:

**14 C.F.R. Part 21 14 C.F.R. 45.23 (b)**  **14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)**  **14 C.F.R. 91.9 (b) (2)**

**14 C.F.R. 91.109**

**14 C.F.R. 91.119**

**14 C.F.R. 91.121 14 C.F.R. 91.151(a)**  **14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)** 

**14 C.F.R. 91.215 14 C.F .R. (91.401 - 91.417)** 

**The requested exemption would permit Tech Works Stu dios LLC, (dba) Skyfilm**  **Drones to pursue its commercial interests in provid ing services to consumers**  **interested in aerial data capture using a small adv anced sUAS in the following areas:** 

**• Closed Set and Private Filming and Television Pro duction**  **• Real Estate Photography • Agricultural & Land Surveying**  **• Aerial Mapping • Search and Rescue Operations**  **• sUAS Operator and FilmingTraining**

**• Product Demonstrations • Research and Development**  **• Environmental, Vehicle, Equipment and Building In spection**  **• Security Monitoring**Our Company:

**Tech Works Studios LLC, also (dba) Skyfilm Drones, and Owner Valek X. Sykes has**  **been in the Special Effects fabrication and filming industry for over 16 years and has**  **worked on thousands of productions and projects for the film and entertainment**  **industry as well as other projects in other industr ies including work for the Dept. of**  **Justice, Federal Bureau of Investigation Counterte rrorism Division, and currently**  **teaches a course for the Film dept. at Tulane Unive rsity. Tech Works Studios LLC,**  **designs, fabricates and operates complex equipment, robotics and remotely**  **controlled products for the film, television and en tertainment industries and ALL with**  **a perfect safety record.**

Small Unmanned Aircraft System (sUAS) Equipement

**We are petitioning for exemption to enable Tech Wor ks Studios LLC,**  **(dba) Skyfilm Drones to operate DJI models Phanto m 3 and Inspire multi-rotor**  **equipped with a three-axis gimbaled camera, T.W. mo del 1 and 2 built multi-rotor**  **copters, Yuneec Models Tornado and Typhoon multi-ro tor coptors and any**  **comparable models within the same scope of nomencla ture. All UA models will**  **include our registration number (FA3TTCLNT3) issued by the F.A.A. or any new**  **numbers issued or required.**

**All UA models weigh less than 55 lbs total,( includ ing cinematic and other**  **equipment), travel speed under 87 knots (100 miles per hour), fly under the height**  **to 500 feet above the ground and to limit the radiu s of the distance flown from the**  **operator and will be flown within line of sight of the Pilot**  **( PIC) and or Visual Observer.**

Operations:

**All flights will be within visual line of sight (VL OS) This requires the PIC to be able to**  **use human vision unaided by any device other than c orrective lenses, as specified** 

**on the U.S. driver’s license.**

**All operations will utilize a visual observer (VO) who will hold a valid united states**  **driver’s license. The UA must be operated within th e visual line of sight (VLOS) of**  **the PIC and VO at all times. 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; electronic me ssaging or texting is not permitted**  **during flight operations. The PIC must be designate d before the flight and cannot**  **transfer his or her designation for the duration of the flight. The PIC must ensure that**  **the VO can perform the duties required of the VO.**

**Prior to each flight, the PIC will conduct a pre-fl ight inspection and determine the**  **UAS is in a condition for safe flight. The pre-flig ht inspection will account for all**  **potential discrepancies, e.g., inoperable component s, items, or equipment. If the**  **inspection reveals a condition that affects the saf e operation of the UAS, the aircraft**  **is prohibited from operating until the necessary ma intenance has been performed** 

**and the UAS is found to be in a condition for safe flight.**  **The operator will follow the UAS manufacturer’s mai ntenance, overhaul,**  **replacement, inspection, and life limit requirement s for the aircraft and aircraft**  **components. Each system also has the failsafe function of the a**  **utopilot system, and to exclude**

**the UA from Class B, C and D airspace including a n o fly zone feature. The failsafe** 

**will act when the communication between the Main Co ntroller and the transmitter is**  **lost, the system will automatically trigger Return to Home and or a specific safe**  **landing area and will land safely at the original l aunch point or have the option of an**  **on board parachute deployment system. On board batt ery monitoring will be utilized**  **and all flights will be terminated within 25% of o n board power for safe return.** 

**Any UAS that has undergone maintenance or alteratio ns that affect the UAS**  **operation or flight characteristics, e.g., replacem ent of a flight critical component, will**  **undergo a functional test flight prior to conductin g further operations under this**  **exemption. Functional test flights may only be cond ucted by a PIC with a VO and**  **must remain at least 500 feet from other people. Th e functional test flight will be**  **conducted in such a manner so as to not pose an und ue hazard to persons and**  **property. All maintenance will be documented and re cords will be kept on each UA.**  **All UA flights and operation records will be docum ented and all records will be kept** 

**on file at Tech Works Studios LLC Home office and t he operating documents will be**  **accessible during UAS operations and made available to the any Administrator upon**  **request. These operational records will include fli ght locations, durations , events,**  **dates, pilot, observer, and maintenance.**

**During UA operations, the petitioner will place vis ual safety notifications (DRONE**  **FLYING SAFETY SIGNS) at the operation site to alert any nearby persons that UA**  **operations are in progress.**

**Tech Works Studios LLC, also (dba) Skyfilm Drones o peration of its fleet of small** 

**unmanned aircraft will not "create a hazard to user s of the national airspace system**  **or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of UA,**  **combined with their safety focused operation standa rds, Tech Works Studios LLC,**  **also (dba) Skyfilm Drones Flight operations fall wi thin Congress's contemplated**  **safety zone when it disseminated the Reform Act and the corresponding directive to**  **integrate UASs into the national airspace system. T ech Works Studios LLC, also**  **(dba) Skyfilm Drones’ UAS have a demonstrable safet y record and do not pose any**  **threat to the general public or national security.**

**Tech Works Studios LLC, also (dba) Skyfilm Drones o perators have extensive**  **knowledge of and experience with UA systems, and ha ve a high regard to safety and**  **coordination with general aviation and that they ha ve a high regard to safe**  **operations with an understanding preflight inspecti ons, maintenance and repair,**  **operations within airspace, and Safe Operating Proc edures.** 

**We respectfully request exemption under Section 333 to enable Tech Works Studios**  **LLC, also (dba) Skyfilm Drones to operate safe, low -risk commercial UAS operations** 

**for the activities stated.**

**Sincerely Valek X. Sykes** 

**President / Owner Tech Works Studios LLC, also (dba) Skyfilm Drones** 

### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

**Tech Works Studios LLC, also (dba) Skyfilm Drones r equests an exemption from the**  **following regulations as well as any additional reg ulations that may technically apply**  **to the operation of the sUAS System:** 14 CFR Part 21, Airworthiness Certificates **Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness.**  **Part 21, Subpart H, entitled Airworthiness Certific ates, establishes the procedural**  **requirements for the issuance of airworthiness cert ificates as required by FAR§**  **91.203(a)(1 ). Given the size of the aircraft and t he limited operating area associated**  **with its utilization, it is unnecessary to go throu gh the certificate of airworthiness**  **process under Part 21 Subpart H to achieve or excee d current safety levels. Such an**  **exemption meets the requirements of an equivalent l evel of safety under Part 11 and** 

**Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the**  **Reform Act both authorize the FAA to exempt aircraf t from the-requirement for an**  **airworthiness certificate, upon consideration of th e size, weight, speed, operational**  **capability, and proximity to airports and populated areas of the UAS involved. In this**  **case, an analysis of these criteria demonstrates th at the Wright Aerial UASs**  **operated without an airworthiness certificate, unde r the conditions proposed herein,**  **will be at least as safe, or safer, than a conventi onal aircraft (fixed wing or rotorcraft)** 

**with an airworthiness certificate. The UASs will re main less than 55 lbs. GTOW, will**  **not carry a pilot or passenger, will not carry flam mable fuel, and will operate**  **exclusively within an area predisclosed and in comp liance with conditions set forth**  **herein. Operations under this exemption will be tig htly controlled and monitored by**  **both the operator, pursuant to the conditions set f orth above, and by local public**  **safety requirements. The FAA will have advance noti ce of all operations through the**  **filings with the FSDO. Receipt of the prior permiss ion of the land owner, or**  **controlling authority, the size of the aircraft, th e lack of flammable fuel, and the fact** 

**that the aircraft is carried to the location and no t flown there all establish the**  **equivalent level of safety. The UASs construction w ith absorbent material provides at**  **least an equivalent level of safety to that of such operations being conducted with**  **conventional aircraft that would be orders of magni tude larger and would be carrying**  **passengers, cargo, and flammable fuel.** 14 CFR 45.23 Display of marks; general and 45.29 Si ze of marks. **These regulations provide that each aircraft must d isplay "N" and the aircraft's**  **registration number in letters at least 3 inches hi gh. Additionally, the aircraft must**  **display the word "EXPERIMENTAL" in letters at least 2 inches high near the**  **entrance to the cabin, cockpit, or pilot station. T he sUAS does not have an entrance**  **in which the word "EXPERIMENTAL" can be placed, and may not have a registration**  **number assigned to it by the FAA. We propose to ach ieve an equivalent level of**  **safety by including the word "EXPERIMENTAL" in the placard on the top of the**  **aircraft, as shown above, where the PIC, VO and oth ers in the vicinity of the aircraft**  **while it is preparing for launch will be able to se e the designation. Additionally, we**  **feel that the permanent placard discussed in the pr evious paragraph will provide the**  **aircraft's registration information at the ground s tation. Finally, we will display at the**  **ground station a high contrast flag or banner that contains** **the words "Unmanned Aircraft Ground Station" in let ters 3 inches high or greater.** 

**Since the aircraft will operate within 3/4 NM of th e ground station, the banner should**  **be visible to anyone that observes the aircraft and chooses to investigate its point of**  **origin.** 14 CFR 61.113 Private pilot privileges and limitati ons: Pilot in Command and 61.133 Commercial pilot privileges and limitations. **The regulation provides that no person that holds a Private Pilot certificate may act**  **as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows**  **a private pilot to act as pilot in command of an ai rcraft in connection with any**  **business or employment if: (1) The flight is only i ncidental to that business or**  **employment; and (2) The aircraft does not carry pas sengers or property for**  **compensation or hire. Our proposed operations requi re that the PIC must hold at**  **least a Recreational or Sport Pilot Certificate iss ued by the FAA and since the**  **aircraft cannot carry passengers or property, we fe el we meet the intent of 61.113**  **Subparagraph (b) even though the intent of this app lication is to conduct a business.**  14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness

certificate. **As no such certificate will be applicable in the fo rm contemplated by the FARs, this**  **Regulation is inapplicable.** 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. **This regulation provides that no person may operate an aircraft unless a current,**  **approved flight manual is in the aircraft. We assum e that the intent of this**  **requirement is to ensure that flight manual informa tion is available to the aircrew**  **while operating the aircraft. We request an exempti on to this requirement since the**  **aircraft is not only too small to carry documentati on, the documentation would not be**  **available to the crew during flight operations. To obtain an equivalent level of safety**  **and meet the intent of 91.9, we propose that a curr ent, approved sUAS Flight**  **Manual must be available to the crew at the ground station anytime the aircraft is in,**  **or preparing for, flight.** 14 CFR 91.109 Flight Instruction; Simulated instrum ent flight and certain flight

tests **The regulation states that "No person may operate a civil aircraft that is being used**  **for flight instruction unless that aircraft has ful ly functioning dual controls." The sUAS**  **System ground-based control station consists of a s mall hand-held radio transmitter** 

**and while it does not offer a second set of "contro ls", both the student and instructor**  **can, and will, operate the single set of controls s imultaneously. With both student**  **and instructor having "hands-on" the controls durin g flight, we feel that this technique**  **meets the intent 91.109 and provides an equivalent level of safety.** 14 CFR 91.119 Minimum safe altitudes: General.

**The regulation states that over sparsely populated areas the aircraft cannot be**  **operated closer than 500 feet to any person, vessel , vehicle, or structure. Since the**  **typical mission of the sUAS would be photography or survey of persons, vessels,**  **vehicles or structures it would be necessary to ope rate closer than 500 feet to the**  **items listed. Operations will only be flown over pr operty or persons where permission**  **has been obtained and careful pre-planned has been performed. The aircraft will be**  **operated at a low altitude allowing, if a power uni t fails, an emergency landing**  **without undue hazard to persons or property on the surface. Therefore we maintain**  **that due to the small size of the UAS, the hazard t o persons, vehicles and structures**  **is minimal compared to umanned aircraft, which shou ld be considered in granting**  **the exemption.** 14 CFR 91.121 Altimeter settings. **The regulation requires that aircraft shall maintai n cruising altitudes by reference to**  **an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly** 

**below 600 feet AGL and will not need to maintain cr uising altitudes in order to**  **prevent conflict with other aircraft. An Above Grou nd Level altimeter measurement**  **above the takeoff point is transmitted via radio fr om the sUAS on-board computer to**  **the display screen held by the PIC, providing a con stantly updated AGL readout.**  14 CFR 91.151 Fuel requirements for flight in VFR c onditions. **The regulation provides that no person may begin a flight in an airplane under day**  **VFR conditions unless there is enough fuel to fly t o the first point of intended landing**  **and to fly after that for at least 30 minutes. We f eel the intention of this paragraph is**  **to provide an energy reserve as a safety buffer for delays to landing. The sUAS are**  **battery operated and** the **maximum duration of flight from a single battery ch arge is**  **12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will**  **never fly more than 1/2 NM from the point of intend ed landing, a full battery charge** 

**at launch will ensure that we meet the reserve ener gy requirement of this paragraph.**  **We request an exemption to the word "fuel" and ask for an equivalent interpretation**  **with the word "energy". We also request exemption f rom the 30 min reserve and ask**  **that our reserve will be to fly the mission to the point of intended landing and have at**  **least a 20% battery reserve after that.** 14 CFR 91.203(a) & (b) Civil aircraft: Certificatio ns required. **The regulation provides that an airworthiness certi ficate, with the registration number**  **assigned to the aircraft and a registration certifi cate must be aboard the aircraft.**  **Additionally, subparagraph (b) provides that the ai rworthiness certificate be**  **"displayed at the cabin or cockpit entrance so that it is legible to passengers or**  **crew." With our largest vehicle, the RF-70, at a ma ximum gross weight of 13 pounds,**  **the sUAS is too small to carry documentation, does not have an entrance, and is not**  **capable of carrying passengers or crew. To obtain a n equivalent level of safety and**  **meet the intent of 91.203, we propose that documents deemed appropriate for th**  **is aircraft by the FAA will be**

**collocated with the crew at the ground control stat ion and available for inspection**  **upon request. In order to identify the aircraft, we propose that the information found**  **on airworthiness and registration certificates be p ermanently affixed to the aircraft via**  **placard containing the following information plus t he word "EXPERIMENTAL" to**  **satisfy the requirement of 14 CFR 45.23.** 14 CFR Subpart E (91.401- 91.417)- Maintenance, Pre ventive Maintenance,

Alterations. **The regulation provides that the operator is primar ily responsible for maintaining the**  **aircraft in an airworthy condition, including compl iance with part 39 and 43.**  **Paragraphs 91.407 and 91.409 require that the aircr aft be "approved for return to**  **service by a person authorized under 43.7" after ma intenance and inspection. It is**  **our intention that the PIC perform maintenance and inspection of the aircraft and "be**  **authorized to approve the aircraft for return to se rvice." The PIC will ensure that the**  **aircraft is in an airworthy condition prior to ever y flight and in addition, conduct**  **detailed inspections after every two hours of fligh t. Maintenance performed by the**  **PIC is limited to repairing small cracks, replacing a propeller, checking electrical**  **connections and updating software and firmware for the on-board computer. All other**  **maintenance will be performed by the manufacturer o r their designated repair facility.**  **The PIC will document work performed in accordance with 91.417. We feel that due**  **to the size, construction, and simplicity of the ai rcraft, the PIC can ensure an**  **equivalent level of safety.**