Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 1 of 16

Skylevin LLC

Steven Murray

3224 – C N College Rd

Suite 230

Wilmington NC 28405

650-241-9444

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 

(3)(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.121, 91.203, 91.151

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. Part 11, SkyLevin LLC.,owned by Steven Murray, a licensed ATP Multi/Commercial

SEL Pilot, hereby applies for an exemption from the Code of Federal Regulations (C.F.R), 

Federal Aviation Regulations (FARs) identified, to allow commercial operation of lightweight 

Unmanned Aircraft Systems (UAS) for aerial imaging and video. This exemption is made 

based on information outlined in this petition, to allow commercial operation of a UAS 

aircraft listed below, so long as operations are conducted within and under the conditions 

outlined herein or as may be established by the Federal Aviation Administration (FAA) as 

required by 333.

Aircraft of operation (Specs on Appendix A)

1. DJI Phantom 2 - http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf

2. DJI Phantom 3 Standard - http://download.djiinnovations.com/downloads/phantom_3_standard/en/Phantom_3_Standard_User_Manual_v1.0_en.pdf

3. DJI Phantom 3 Professional - http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

4. DJI Inspire 1 - http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

5. FLYPRO PX400 Pro - http://hobbywow.com/images/pledge/FLYPRO_PX400_UserManual.pdf

6. Yuneec Q500 Typhoon - http://www.yuneec.com/download/20150209080300.pdf

7. Walkera Voyager 3 Drone -

http://www.walkera.com/productinformation/Voyager%203/VOYAGER%203%20Match%20with%20DEVO%20F

12E%20Radio%20Quick%20Start%20Guide-EN.pdf

8. Walkera QR X350 -

http://www.walkera.com/productinformation/X350PRO/X350PRO%20Manual_DEVO_F12E_EN.pdf

9. Walkera QR X800 - http://www.walkera.com/productinformation/X800/QR%20X800+F12E%20guideEN.pdf

10. Walkera Scout X4 Carbon RTF -

http://www.walkera.com/productinformation/SCOUT%20X4/Scout%20X4%20with%20ground%20station-en.pdf
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 2 of 16

1. Types of Operations

The requested exemption would permit the operation of small, unmanned multirotor 

aircraft under controlled conditions to provide the following services to the community;

Real Estate sales advertising

Aerial Survey

Aerial Photo/video

Promotional advertising material

Inspections

Construction Observation

Bridge/Road/Utility Inspections 

Utility Corridor Vegetation Management 

Building Inspection Surveys 

Disaster Response

Aerial observation of structures, land, water, wildlife, vehicles

This exemption would permit operation of an ultra-light weight, unmanned (piloted by 

remote control) in predetermined areas away from the general public, airports, heliports, 

and vehicular traffic. Operations would be conducted within federal guidelines, by a FAA 

Licensed Private Pilot with the assistance of an Observer. Operations would be conducted 

after carefully reviewing, inspecting, and examining the area of aerial operation to ensure 

the safety of persons and property. 

2. REQUESTED RELIEF

SkyLevin LLC. Is also requesting a grant of exemption of the following sections of 

Title 14 of the Code of Federal Regulations:

 14 CFR 21;

 14 CFR 91, et seq;

 14 CFR 45.23 (b);

 14 CFR 61.113 (a) & (b);

 14 CFR 407 (a)(1);

 14 CFR 409 (a)(2);

 14 CFR 417 (a) & (b).

SkyLevin LLC. is also requesting an Exemption from Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation Regulations for the following:

 14 CFR 45.23 (b);

 14 CFR Part 21;

 14 CFR 61.113 (a) & (b);

 91.7 (a);

 91.9 (b) (2);

 91.103 (b);
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 3 of 16

 91.119;

 91.121;

 91.151 (a);

 91.203 (a) & (b);

 91.405 (a);

 91.407 (a) (1);

 91409 (a) (2);

 91.417 (a) & (b).

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)

14 CFR § 91.203 Given the size, weight, speed, and limited operating area 

associated with the UAS aircraft to be utilized, I am asking exemption from 14 CFR Part

21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required),

subject to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under14 CFR Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act U.S.C. 44701 (f) and 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 particular UAS. In all cases, an analysis of these criteria 

demonstrated that the UAS operated without an airworthiness certificate, in the restricted 

environment and under conditions proposed, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. I request an exemption from 14 CFR 91.7 

(a) Civil Aircraft Airworthiness.

14 C.F.R. 45.23(b): Marking of the Aircraft

Furthermore SkyLevin LLC. requests an exemption from §45.23 Marking of the 

aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark 

certain words or phrases. Additionally two -inch lettering is difficult to place on such a small 

aircraft with dimensions smaller than the minimal lettering requirement. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f) in a 

size suitable for the available space. The UAS is equipped with LED lights to aid in visibility.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, 

however SkyLevin LLC. can achieve an equivalent level of safety as achieved by current 

regulations because my UAS does not carry any pilots or passengers. I, the owner of 

SkyLevin LLC., have a Commercial Pilot/ATP License and will ensure all operations are 

conducted by a person with at a minimum a Private Pilots Certificate and meets the medical 

requirements for a sport pilot license.
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 4 of 16

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

An exemption to the part will be needed since there is nowhere to place a copy of a 

flight manual on board the UAS.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

This requires each PIC to take certain actions before flight to insure safety of flight. 

There is no approved flight manual, however the PIC will take actions prior to flight by 

reviewing the weather, flight battery requirements, and ensuring there is a safe location to 

land and depart so as not to cause undue hazard to people or property on the ground. The 

manufactures manual will be used prior to flight to ensure safety.

14 CFR 91.119: Minimum Safe Altitudes

Due to the limitation that operations be conducted at or below 400 feet AGL, an 

exemption will be necessary to meet 91.119. The typical UAS flight will be operated as 

follows:

1) Operate the UAS for less than 60 minutes per flight, land my UAS according to the 

manufacturer’s recommended minimum level of battery power. 

2) Operate my UAS only within visual line of sight (VLOS). 

3) Always obtain all necessary permissions prior to operation. 

4) Procedures in place to abort flights in the event of safety breaches or potential 

danger. 

14 CFR 91.121: Altimeter Setting

The UAS is not equipped with an altimeter setting device. GPS will be used on 

board the UAS to determine altitude by reference to the ground (AGL).

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

An exemption from 91.151 will be necessary as the normal flight time will only be 10-

45 minutes. The UAS is fueled by battery power and a long duration flight is not possible. 

Also since all flights will be conducted Line of Sight (LOS), this requirement is not 

applicable.

14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require the owner/operator to have the aircraft inspected as 

prescribed in subpart E of this part. An equivalent level of safety will be maintained 

because of the small size and limitations of this UAS. Maintenance will be accomplished 

by the operator pursuant to the owners manual. The operator will ensure that the UAS is in 

proper working order prior to each flight, perform necessary maintenance, and keep a log of 

maintenance. The operator is the person most familiar with the UASs operation and is best 

suited to maintain in an airworthy condition to provide equivalent level of safety.
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 5 of 16

3. Commercial and Public Benefits

Granting this exemption will by provide a safe (by way of an unmanned system) and 

efficient means to meet technical problems solvable by elevated data collection instruments. 

Our typical customer base is small to medium size business and individuals who would be 

unable to acquire this service by manned aircraft due to it being cost prohibited. By moving 

these functions to UAS based aircraft not only can more people benefit from this service but 

it will reduce aircraft noise, pollution, reduce airport congestion.

In addition, it will reduce the amount of people and property exposed to the hazards 

of a manned aircraft flying at low altitude with the potential for catastrophic results. There 

are no combustibles on-board the UAS, thus eliminating the risk of explosion and fire due to 

a crash. The operation of this UAS will minimize ecological damage and promote economic 

growth by providing information to companies in the area that would otherwise be 

unavailable. Additionally, this system would eliminate a distraction to air traffic controllers

who must monitor an aircraft that usually wants' to take pictures in the "wrong place at the 

wrong time" thus reducing workload on ATC.

The use of UAS, would allow these services to be provided and thus benefit both the 

community and aviation by:

1. Providing a lower cost to the individual needing these services.

2. Zero emissions from the UAS.

3. Reduced noise over an aircraft.

4. Reduced hazard to people or property on the ground.

The use of a UAV will provide a level of safety at least equal to existing rules and will 

only be operated in a safe environment that is strictly controlled. Operations will only be 

conducted after a careful review of the area and weather conditions. Safety is the number 

one priority.

4. SUMMARY

Granting this exemption is a "win win" situation for individuals in need of this service. 

The community benefits from reduced pollution and noise. The economy benefits by 

creating jobs for small businesses. The consumer benefits from reducing the cost of this 

service. The FAA benefits by regulating the use of UASs so that safety and accountability 

can be maintained and monitored.

Approval of exemptions allowing commercial operations of UASs in the media will

enhance safety by reducing risk associated with conventional aircraft operations. The 

operation of UASs weighting less than 55lbs by a certified pilot will enhance safety to the 

community increase awareness of properly flown UASs, eliminate the risk of collision with 

aircraft operating in the airspace and around airports and provide jobs.

Steven Murray
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 6 of 16

SkyLevin LLC

3224 – C N College Rd

Suite 230

Wilmington NC 28405

650-241-9444

APPENDIX A: AIRCRAFT SPECIFICATIONS

UAV #1 - Phantom 2 Vision

Aircraft

Battery

5200mAh LiPo

Weight (Battery & Propellers Included)

1160g

Hover Accuracy (Ready To Fly)

Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity

200°/s

Max Tilt Angle

35°

Max Ascent / Descent Speed

Ascent: 6m/s; Descent: 2m/s

Max Flight Speed

15m/s (Not Recommended)

Diagonal Length

350mm

Tilting Range Of Gimbal

0°-60°

Base Controller Transmitter

Operating Frequency

5.728GHz-5.8GHz

Communication Distance (Open Area)

CE: 300m; FCC: 500m

Receiver Sensitivity (1%PER)

-93dBm

Transmitter Power

CE: 25mw; FCC: 125mw

Working Voltage

80 mA@6V

Battery

4 AA Batteries
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 7 of 16

UAV #1 - Phantom 3 Standard

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)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Base Controller Remote 

Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

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)
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 8 of 16

-101 dBm ±2 dBm

Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Intelligent Flight Battery Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

UAV #1 - Phantom-3 Pro

Aircraft

Weight (Including Battery)

1216 g
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 9 of 16

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Max Flight Time

Approximately 25 minutes

Operating Temperature

0°C to 40°C

Navigation System

Built-in GPS

Base Controller Remote 

Controller

Operating Frequency

5.725 GHz – 5.825 GHz, 922.7 MHz – 927.7 MHz (Japan)

Max Transmission Distance

FCC: 1000 m; CE: 500 m (outdoors and unobstructed, aircraft's altitude at 4

Operating Temperature

0°C to 40°C

Battery

2600 mAh LiPo 18650

Transmitter Power (EIRP)

 FCC: 19 dBm

 CE: 14 dBm

Working Voltage

600 mA @ 3.7V

Charging Port

Micro USB

Intelligent Flight Battery ( PH3-

4480 mAh-15.2 V )

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 25 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 10 of 16

Aircraft Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

UAV #1 - DJI Inspire 1

Aircraft

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 11 of 16

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

UAV #1 - FlyPro PX400

Quadcopter

Drone Weight (battery including) 2450g

Max takeoff weight 2900g

Package Weight 6900g

Hovering Accuracy Vertical:0.1 m Horizontal:1 m

Max Angular Velocity Pitch:180°/s Yaw:90°/s

Max Tilt Angle 45°

Max Ascent Speed 5m / s

Max Descent Speed 4m / s

Max Speed 20m / s

Max Flight Altitude 1000 m

Max Wind Speed Resistance 10m / s

Max Flight Time Approximately 25 minutes

Motor Model FLYPRO2814
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 12 of 16

Propeller Model FLYPRO1147 Carbon

Operating Temperature Range -10° to 40°C

Diagonal Distance 480 mm

Max Dimensions (Package) 520*435*240 mm

Max Dimensions (Product) 400*400*280 mm

Base Controller Remote 

Control

Operating Frequency 2.4GHz DSSS FM

Transmitting Distance (Outdoor 

And Unobstructed)

1000 m

Battery

Capacity 5400mAh

Voltage 22.2V

Battery Type LiPo 6S

Energy 120Wh

Net weight 630g

Operating Temperature Range -10° to 40°C

Charging Temperature Range 0° to 40°C

Camera(Built-in Image 

Transportation)

Video Recording Modes 1920*1080 Full HD

Recording Frame Rate 30FPS

Video Format MOV

Pixel 13Million

Resolution 4032*3024

Image Format MJPG

FOV Lens 170°C

Operating Temperature Range -10° to 40°C

The Max Transmission Distance 1000m

Ground Station APP

Mobile Device System 

Requirements

Android 4.0 or later with Google 

Services Framework

- See more at: http://www.iflypro.com/en-flypro-px400-PRO-world-s-first-auto-follow-and-fpvdrone.htm#sthash.BoANX4oz.dpuf
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 13 of 16

UAV #1 - QR X350 Premium

Model QR X350 Premium

Main Rotor Dia 233mm

Overall (L x W x H):303 x 303 x 176mm

Weight 1650g (Battery included)

Radio DEVO-F12E (White)

Receiver BTR-2401(FCC) / BTR-2402(CE)

Brushless Motor: WK-WS-34-002A

Battery 29.6V 3000mAh 10C(8S) LiPo

Base Controller

2.4G Bluetooth Datalink: BTR-2401(FCC) & BT-2401B(FCC) / Andriod

BTR-2401(FCC) & BT-2403B(FCC) / BTR-2402(CE) & BT-2404B(CE) - Apple IOS system

BTR-2402(CE) & BT-2402B(CE) /Andriod

BTR-2401(FCC) & BT-2403B(FCC)/IOS

BTR-2402(CE) & BT-2404B(CE) - Apple IOS system

Flight Time:

Approximately 25 minutes

Working environment:

-10°C~ +40°C
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

steve@f1ll.com

Page 14 of 16

TALI H500 Specifications

Main Rotor Dia. || 233mm

Overall (L x W x H) || 471 x 536 x 270mm

Weight || 2020g(Battery included)

Takeoff Weight || <2500g

Base Controller

Remote || DEVO F12E

Receiver || DEVO-RX705

Brushless Motor || WK-WS-34-001

Brushless ESC || WST-15AH (R/G)

Main Controller || FCS-H500

Battery || 22.2V 5400mAh Li-Po

UAV # - Scout X4 

Spec

Main Rotor Dia 346mm

Overall (L x W x H):473 x 463 x 300mm

Weight 3650g (Battery included)

GROUND STATION SPECIFICATIONS:

Transmitter DEVO F12E(black version)

Receiver FCS-RX701(FCC)/FCS-RX702(CE)

Brushless Motor WK-WS-42-002

Brushless ESC Voyager 3 (R/B)

Battery 29.6V 3000mAh 10C(8S) LiPo x2
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 15 of 16

UAV # - YUNEEC Q500: 4 Rotor, Electric Driven, Quad-Copter:

o Flight Time Up to 25 Minutes

o Dimension 16.5x16.5x9.5in

o Diagonal Length Without Rotor Blades 22.2in

o Propeller/Main Rotor Diameter 13.0in

o Weight Without Battery and Payload 40.0oz

o Battery 5400mAh 3S 11.1V LiPo (included)

o Transmitter 10 Channel 2.4GHz with 5.8 GHz video downlink

o Flight Modes Smart Mode and Manual Mode

o Maximum Speed 12MPH

o Maximum Flying Height Default 400ft Above Ground Level

o Maximum Rotation Rate 650 per second

o Maximum Roll Angle 350

o Radio Control Frequency Band 2.4 GHz

o Operating Temperature Range -5

0C to 800 C

GROUND STATION SPECIFICATIONS:

o Operating System Andriod

o Number of Channels 10

o Control Transmission Distance/Range (Optimum Conditions)

FCC Compliance Up to 800m (2624 ft) CE Compliance: Up to 400m (1312.34 ft)

Warning You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times

o Robust Radio Control Modulation Yuneec Protocol

o Video link Frequency Band 5.8 GHz

o Video Transmission Distance/Range (Optimum Conditions)

FCC Compliance Up to 600m (1968.5 ft) CE Compliance Up to 300m (984.252 ft)

Warning You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times

o Flight Systems Telemetry Data On Screen Display (OSD) Yes

o LED Backlit LCD Screen Capacitive Multi-Touch 

4.5"
Steve Murray Request for Exemption for Commercial UAS Operation August 10, 2015

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Page 16 of 16

o Tactile (Vibrating) and Audible Feedback Yes

o Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh