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 and Reform Act of 2012 (the 

Reform Act), and 14 C.F.R. Part 11, },Tech Works Studios 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, hereby applies for an exemption from 

the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS 

commercially in airspace regulated by the Federal Aviation Administration (FAA), so 

long as such operations are conducted with and under 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 that 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 Studios LLC, (dba) Skyfilm 

Drones to pursue its commercial interests in providing services to consumers 

interested in aerial data capture using a small advanced sUAS in the following areas: 

• Closed Set and Private Filming and Television Production 

• 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 Inspection 

• 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 industries including work for the Dept. of 

Justice, Federal Bureau of Investigation Counterterrorism Division, and currently 

teaches a course for the Film dept. at Tulane University. Tech Works Studios LLC, 

designs, fabricates and operates complex equipment, robotics and remotely 

controlled products for the film, television and entertainment industries and ALL with 

a perfect safety record. 

Small Unmanned Aircraft System (sUAS) Equipement 

We are petitioning for exemption to enable Tech Works Studios LLC, 

(dba) Skyfilm Drones to operate DJI models Phantom 3 and Inspire multi-rotor 

equipped with a three-axis gimbaled camera, T.W. model 1 and 2 built multi-rotor 

copters, Yuneec Models Tornado and Typhoon multi-rotor coptors and any 

comparable models within the same scope of nomenclature. 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,( including 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 radius 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 (VLOS) This requires the PIC to be able to 

use human vision unaided by any device other than corrective 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 the 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 messaging or texting is not permitted 

during flight operations. The PIC must be designated 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-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection will account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. 

The operator will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 
Each system also has the failsafe function of the autopilot system, and to exclude 

the UA from Class B, C and D airspace including a no fly zone feature. The failsafe 

will act when the communication between the Main Controller 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 launch point or have the option of an 

on board parachute deployment system. On board battery monitoring will be utilized 

and all flights will be terminated within 25% of on board power for safe return. 

Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, will 

undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights may only be conducted by a PIC with a VO and 

must remain at least 500 feet from other people. The functional test flight will be 

conducted in such a manner so as to not pose an undue hazard to persons and 

property. All maintenance will be documented and records will be kept on each UA. 

All UA flights and operation records will be documented and all records will be kept 

on file at Tech Works Studios LLC Home office and the operating documents will be 

accessible during UAS operations and made available to the any Administrator upon 

request. These operational records will include flight locations, durations , events, 

dates, pilot, observer, and maintenance. 

During UA operations, the petitioner will place visual 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 operation of its fleet of small 

unmanned aircraft will not "create a hazard to users 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 standards, Tech Works Studios LLC, 

also (dba) Skyfilm Drones Flight operations fall within Congress's contemplated 

safety zone when it disseminated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system. Tech Works Studios LLC, also 

(dba) Skyfilm Drones’ UAS have a demonstrable safety record and do not pose any 

threat to the general public or national security. 

Tech Works Studios LLC, also (dba) Skyfilm Drones operators have extensive 

knowledge of and experience with UA systems, and have a high regard to safety and 

coordination with general aviation and that they have a high regard to safe 

operations with an understanding preflight inspections, maintenance and repair, 

operations within airspace, and Safe Operating Procedures. 

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 requests an exemption from the 

following regulations as well as any additional regulations 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 Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR§ 

91.203(a)(1 ). Given the size of the aircraft and the limited operating area associated 

with its utilization, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H to achieve or exceed current safety levels. Such an 

exemption meets the requirements of an equivalent level 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 aircraft from the-requirement for an 

airworthiness certificate, upon consideration of the 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 that the Wright Aerial UASs 

operated without an airworthiness certificate, under the conditions proposed herein, 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

with an airworthiness certificate. The UASs will remain less than 55 lbs. GTOW, will 

not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area predisclosed and in compliance with conditions set forth 

herein. Operations under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the conditions set forth above, and by local public 

safety requirements. The FAA will have advance notice of all operations through the 

filings with the FSDO. Receipt of the prior permission of the land owner, or 

controlling authority, the size of the aircraft, the lack of flammable fuel, and the fact 

that the aircraft is carried to the location and not flown there all establish the 

equivalent level of safety. The UASs construction with 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 magnitude larger and would be carrying 

passengers, cargo, and flammable fuel. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. 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. The 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 achieve 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 others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, we 

feel that the permanent placard discussed in the previous paragraph will provide the 

aircraft's registration information at the ground station. Finally, we will display at the 

ground station a high contrast flag or banner that contains 
the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. 

Since the aircraft will operate within 3/4 NM of the 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 limitations: 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 aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. Our proposed operations require that the PIC must hold at 

least a Recreational or Sport Pilot Certificate issued by the FAA and since the 

aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application 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 form 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 assume that the intent of this 

requirement is to ensure that flight manual information is available to the aircrew 

while operating the aircraft. We request an exemption to this requirement since the 

aircraft is not only too small to carry documentation, 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 current, 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 instrument 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 fully functioning dual controls." The sUAS 

System ground-based control station consists of a small hand-held radio transmitter 

and while it does not offer a second set of "controls", both the student and instructor 

can, and will, operate the single set of controls simultaneously. With both student 

and instructor having "hands-on" the controls during 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 operate closer than 500 feet to the 

items listed. Operations will only be flown over property 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 unit 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 to persons, vehicles and structures 

is minimal compared to umanned aircraft, which should be considered in granting 

the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain 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 cruising altitudes in order to 

prevent conflict with other aircraft. An Above Ground Level altimeter measurement 

above the takeoff point is transmitted via radio from the sUAS on-board computer to 

the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing 

and to fly after that for at least 30 minutes. We feel 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 charge 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 intended landing, a full battery charge 

at launch will ensure that we meet the reserve energy 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 from 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: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness 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 maximum 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 an equivalent level of safety and 

meet the intent of 91.203, 
we propose that documents deemed appropriate for this aircraft by the FAA will be 

collocated with the crew at the ground control station and available for inspection 

upon request. In order to identify the aircraft, we propose that the information found 

on airworthiness and registration certificates be permanently affixed to the aircraft via 

placard containing the following information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations. 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance 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 service." 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. 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 or 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 aircraft, the PIC can ensure an 

equivalent level of safety.