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,

Pursuant 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 required by Section 333. 

Commercial operation of an UAS, as described herein, which is equipped with a 4K 

video/still camera and sensors, would operate in the following manner: 

- Aerial photography and/or video for public and/or private use including real 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 inspection/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 range 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 or 
critical 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 gimblemounted 4K camera 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 operation. The DJI Phantom 3 Professional battery provides a 

flight time of 18-20 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 training 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 Operating 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 feet and within a radius of 300 meters from 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 assessment of the risk 

of operating closer to those objects and determine that it does not present any hazard. 

Other safety operating parameters include:

- Scout flight location beforehand.

- Operate the UAS for 15-20 minutes per flight.

- Land UAS prior to the manufacturers 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 windspeed 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, signage, airports and 

densely populated areas.

- Also conduct extensive preflight inspections utilizing a checklist during which safety 

is the primary focus.

The PIC has 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 Requested

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 conditions 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 have 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 

Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots or 

passengers nor property. The risks 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 and 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 they 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 ground station.

- I request an exemption from 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 DJI Phantom 3 Professional currently operates 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 allows 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 of 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 an 
exemption from 14 CFR 91.151(a) Fuel Requirements for Flight in visual flight rules 

(VFR) conditions. The UAS electrically powered (battery) and two low battery alerts 

are issued – per the operation documentation, 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 wind 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 power 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 not 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 will 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 found 

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 anticipated) 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-flight 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 aircraft/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 all 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.

14. Prior to operations conducted for the purpose of aerial 

videography/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.

15. 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 14 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.

16. 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).

17. The UAS will not operate within five nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart.

18. 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 GPS signal, it will return to a 

predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

20. The PIC will abort a flight in the event of unpredicted obstacles or emergencies in 

accordance with 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.

22. 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.

23. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to 
the 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.

24. The UAS will remain clear and yield the right of way to all manned aviation 

operations and

activities at all times.

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

26. The UAS will not be operated over congested or densely populated areas unless 

contracted for a specific event.

27. 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 protect 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).

28. All operations will be conducted 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 incident, 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. Accidents 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

George Skillman Advertising