George Skillman Advertising

Owner: George Skillman
170 McCormick Drive Port Deposit, Maryland 21904

george@georgeskillman.com www.georgeskillman.com

U.S. Department of Transportation
Federal Aviation Administration October 22, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam,

Pursu ant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, George Skillman, owner of George Skillman Advertising which owns and operates a small Unmanned Aircraft System (UAS) , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of my UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as r equired by Section 333. Commercial operation of an UAS, as described herein, which is equipped with a 4K
video/still ca mera and sensors, would operate in the following manner:

- Aerial photography and/or video for public and/or private use including rea l estate, architecture, surveying, engineering and other related professional activities.

- Aerial video and/or photography for public and/or private use including television, public events, private events, cinematography and news gathering.

- Aerial inspe ction/photography of residential/commercial structures under contract
with the owners or local government authority.

- Aerial inspection/photography or residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of emergency or natural disaster only when the local authorities or government has requested it by contract or donation. George Skillman Advertising operates one (1) DJI Phantom 3 Professional (4) blade quad copter weighing 2.82 pounds (see attached specifications). The sUAS has a maximum airspeed of 35.79 miles per hour and uses a remote controller operating on frequency ra nge of 2.400

- 2.483 GHZ. The DJI Phantom 3 Professional is equipped with
built

- in ground support technology that allows it to fly utilizing global positioning system (GPS /GLONASS ) providing stability, tracking, safe flight
mode and a return

- to

- home feature in the event of loss of remote control signal orcritical low

- charge battery. I anticipate most use will replace otherwise ground based equipment such as

dollys, jibs and cranes as the DJI Phantom 3 Professional is equipped with a gimble

mounted 4K came ra that behaves much like a steady

- cam and makes it useful for
hand

- held, bladeless recording of video in certain situations. All flights start with a pre

- flight safety check and all flight data are recorded. The DJI
Phantom 3 Professional is equipped with a gimbal mounted camera that sends a live video signal to the controller allowing the person in control (PIC) to monitor real

- time video. Flight data, speed height, distance, battery level and general aircraft conditions are also displayed during operatio n. The DJI Phantom 3 Professional battery provides a flight time of 1 8

- 20 minutes (24 minutes maximum

- allowing for safe return to home point) , always returned to original takeoff point and always flown utilizing visiual line of sight (VLOS). I have been tr aining on the DJI Inspire for 3 weeks and have become proficient in all aspects of flight and safety of this UAS. This request for exemption would allow us to offer unique ground, aerial photography and videography services to

my clientele.

UAS Safety Ope rating Parameters George Skillman Advertising will abide by the following additional operating conditions under this exemption, which ensures a level of safety during UAS flight including operating the UAS below 400 fee t and within a radius of 300 meters f rom PIC always maintaining VLOS and obtaining permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 150 meters to any such vessels, vehicles or structures. I will conduct a safety assessme nt of the risk of operating closer to those objects and determine that it does not present an y hazard. Other safety operating parameters include:

- Scout flight location beforehand.

- Operate the UAS for 15

- 20 minutes per flight.

- Land UAS prior to the ma nufacturers recommended minimum level of battery power.

- Operate the UAS during daylight hours only within VLOS.

- Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if communication with the PIC is lost or battery becomes critically low.

- Always obtain all necessary property permissions and photo releases prior to operation.

- Have procedures in place to abort flights in the event of safety breaches or potential danger.

- Review weather reports prior to flight including wi ndspeed and never operate UAS in unsafe conditions, high wind, low clouds or any condition that may hinder visibility.

- Only operate in safe environments that are strictly controlled, away from electromagnetic interference, power lines, elevated lights, s ignage, airports and densely populated areas.

- Also conduct extensive preflight inspections utilizing a checklist during which safety
is the primary focus

. The PIC ha s 10 hours logged on this under varying wind conditions and environments
and will follow all guidelines of 14 CFR §61.51(b) having the ability to safely operate the

UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from individuals

.Specific Exemptions R equested Given the size, weight, speed and limited operating area associated with the UAS, we feel an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) and (b) (certifications required), subject to certain condition s and limitations, is warranted and meets the requirements for an equivalent level of safety
under 14 CFR Part 11 and Section 333 of P.L. 112

- 95 (Section 333).

- I request an exemption from 14 CFR 45.23 Marking of the Aircraft because the UAS
will not h ave a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can
mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by 14 CFR 45.29(f) so that anyone will see the markings.

- I request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and

Limitat ions: Pilot in Command. The applicant’s UAS do not carry any pilots or passengers nor property. The r isks attendant to the operation of the UAS are far less
than the risk levels inherent in the commercial activities outlined in 14 CFR §61. The operation an d limitations in the flight operation manual (FOM) will equate to the safe operations of the UAS.

- I request an exemption from 14 CFR 91.7(a) which prohibits the operation of an
aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable.

- I request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections since t hey only apply to aircraft with an airworthiness certificate. Nonetheless, I will perform a preflight inspection of the UAS before each flight as outlined in the DJI Phantom 3 Professional’s operating
documents.

- I request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft, however, since there are no pilots or passengers on board the aircraft, and given its size, this regulation is inapplicable. I believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS g round station.

- I request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and C ertain 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 DJI Phantom 3 Professional currently operat es with a single remote controller.

- I request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation of civil aircraft, but allo ws helicopters to be operated at lower altitudes in
certain conditions. We will not operate our UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level o f safety at least equivalent to or below those in relation to minimum safe altitudes.” Given the size, weight and maneuverability and speed of the UAS, an equivalent or higher level of safety will be achieved.

- I request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable
since the UAS utilizes electronic GPS with a barometric sensor. We request anexemption from 14 CFR 91.151(a) Fuel Requirements for Flight in visual flight rules (VFR) conditions. The UAS electric ally powered (bat tery) and two low battery alerts
are issued

– per the operati on document ation , the

UAS will be landed at the first alert or very shortly thereafter

. Also, the flights will last only 15

- 20 minutes each and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless, considering w ind an forecast weather conditions, there is enough power indicate a full charge on the units battery and land the UAS with 25

- 30 percent battery powe r remaining. Summary We will comply with all of the following conditions and limitations should this grant of exemption be provided:

1 . Operations will be limited to the following aircraft described in the operating
documents which is a quad

- rotor aircraft weighing less than seven pounds: The DJI
Phantom 3 Professional Aircraft System.

2 . The UAS will not be flown at an indicated airspeed exceeding 35 mph.

3 . The UAS will be commercially operated at an altitude of no t more than 400 feet AGL, as indicated by the procedures specified in the operating documents.

4 . The UAS will be operated within VLOS of the PIC at all times.

5 . All operations may utilize a visual observer (VO ) . The UAS will be operated within
the VLOS of the VO at all times. The VO and PIC wil l be able to communicate verbally
at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating
documents.

6 . The operating documents will be accessible during the UAS operations and made
available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.

7 . Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS,
the UAS will not be operated until the necessary maintenance has been performed and the UAS is fo und
to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documents in the aircraft records.

8 . Any UAS maintenance or alterations (none are anticipat ed) that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry into the aircraft records. 9. The pre

- fl ight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items or equipment not already covered in the relevant
sections of the operating documents.

10. I will follow the UAS manufacturer’s aircraf t/component, maintenance, overhaul,replacement, updating of firmware for the entire system, inspection and life limit requirements.

11. I will carry out maintenance, inspections and record

- keeping requirements, in
accordance with the operating documents. Maintenance, inspection and alterations will be noted
in the aircraft records, including total flight hours, description of work accomplished and the signature of the authorized person returning the UAS to service. 12. Each UAS operated will comply with al l manufacturer Safety Bulletins. 13. An authorized person will make an entry in the aircraft record of the corrective
action taken

against discrepancies discovered between inspections.

1 4 . Prior to operations conducted for the purpose of aerial videograph y/cinematography and augmenting real estate listing videos (or similar operations), the PIC will have
accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of five hours as an UAS pilot operating the make and model of the UAS to be used in those operations.

1 5 . The PIC will not operate the UAS for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), unless the PIC has
demonstrated and logged in a manner consistent with 1 4 CFR 61.51(b), the ability to safely operate
the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

1 6

. Any UAS operations will not be conducted during night hours, as defined in 14 CFR 1.1 All operations will be conducted under visual meteorological conditions (VMC).

1 7 . The UAS will not operate within five nautical miles of an airport reference point as
denoted on a current FAA

- published aeronautical chart.

1 8 . The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than .75 statute miles from the PIC.

19 . If a UAS loses communications or loses its GP S signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

2 0 . The PIC will abort a flight in the event of unpredicted obstacles or emergencies in
accordance w ith the operating documents.

21 . The PIC will not begin a flight unless, considering wind and forecast weather conditions, there is enough power to fly at a normal cruising speed to the intended landing point and land the UAS with 30 percent battery power remaining.

2 2 . Before conducting operations, the radio frequency spectrum used for operation and
control of the UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

2 3 . The document s required under 14 CFR 91.9 and 14 CFR 91.203 would be available tothe PIC at the Ground Control Station of the UAS at any time the UAS is operating.
These documents will be made available to the Administrator or any law enforcement official upon request

. 2 4 . The UAS will remain clear and yield the right of way to all manned aviation operations and
activities at all times.

2 5 . The UAS will not be operated by the PIC from any moving device or vehicle.

2 6 . The UAS will not be operated over congested or dens ely populated areas unless
contracted for a specific event

. 2 7 . Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles and structures unless: a. Barriers or structures are present that sufficiently protec t nonparticipating persons
from
the UAS and/or debris in the event of an accident. I will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations will cease immediately. b. The aircraft is operated near vessels, vehicles or structures where the
owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that

it does not present an undue hazard. c. Operations near to the PIC, VO or essential persons do not present an undue hazard to those persons per 14 CFR 91.119(a).

2 8 . All operations will be cond ucted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be
conducted.

29 . Any incid ent, accident or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable certificate of authorization (COA) will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Ac cidents will
be reported to the National Transportation Safety Board (NTSB) per instructions
contained on the
NTSB website: www.ntsb.gov

.

Thank you for your consideration in granting this exemption.

Signed, George Skillman

G e orge Skillman Advertising