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SKYCRAFT LLC

Request for Section 333 Exemption 

Commercial Film & Video

August 19, 2015
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August 19, 2015 

The following letter constitutes an exemption Request under Section 333 of the FAA Modernization and 

Reform Act of 2012 for Skycraft LLC and its subsidiary, Skycraft Studios, to perform commercial services 

for real estate, weddings, events, and for use in independent films that may generate revenue. The UAS 

system that we will use and will be referenced in this document are the DJI Phantom 3 Professional

Edition. 

Point of Contact:

Nathaniel Gonzales

19741 E. Bellewood Dr.

Centennial, CO 80015

(909) 227-1797

nate@skycraftstudios.com

1. Specific sections of 14 CFR from which we seek exemptions. 

a) §61.3(a)(1) & §61.123: Requirement for certificates, ratings, and authorizations 

• There are no ratings for UAS operators as of yet, so our operator would like to use his current 

FAA private pilot certificate in lieu of the lack of UAS certificates to operate commercially. 

b) §61.13: Issuance of airman certificates, ratings, and authorizations 

c) §91.7: Civil aircraft airworthiness. No person may operate a civil aircraft unless it is an airworthy 

condition 

• There are no certifications for the airworthiness of UAS to date, so we are looking to rely on our 

field maintenance training and schedule to ensure our aircraft are in an airworthy condition 

before all flights. 

d) §91.113: Right of Way rules (see and avoid)

• We always have extra crew on set. We will have dedicated observers out during flights, and to 

the maximum extent possible stay below 400’ AGL and away from controlled airspace. Should 

we need to film near the 5 mile restricted area, we will contact the tower first per FAA 

instruction.

e) §91.203(a)(1) & §91.203(a)(2): Civil Aircraft: Certifications Required 

f) §91.205(b): Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument 

and equipment requirements. Specifically items (5) and (7) through (17). 

• We do not plan to fly at night initially.
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g) §91.207: Emergency locator transmitters 

h) §91.125: ATC transponder and altitude reporting equipment and use a. We do not currently have 

transponders on our aircraft but could install them if necessary.

i) §91.319: Aircraft having experimental certificates: Operating limitations Specifically §91.319(e)

2. Extent of relief we seek and the reason we seek the relief

The request for these exemptions is for the use of our Unmanned System to assist in providing a 

variety of commercial services in the United States. We currently do not offer aerial photography 

or videography as an independent service to our customers. Our UAS is strictly a supplemental tool 

that will be used to enhance our films and videos that we either produce for businesses or submit 

to film festivals. We are seeking the exemption because we wish to use aerial photography and 

videography in a commercial manner without legal issue. 

3. How our request would benefit the public as a whole

Our company will be able to offer enhanced videos and documentaries that are highly desired by 

the general public. One example is operating a commercially legal UAS enhances our ability to help 

businesses grow through a more diversified looking video that may be unique and sometimes 

necessary for their specific industry. We also may be hired by a city to produce promotional videos 

that increase tourism, in which aerial shots of the specified city would almost be necessary a part of 

said video.

4. Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule

As we will fly mostly in the state of Colorado, the majority of areas to be covered are usually

remote, sparsely populated, and we thoroughly plan before each flight. We operate both our single 

engine aircraft and our UAS vehicles with the utmost care with routine pre-flight inspections and 

with the foreknowledge of the surrounding residential terrain and aviation airspace. We check 

current sectional charts for airspace restrictions, NOTAMS, TFR’s, restricted airspace, and helicopter 

corridor charts. Our aircraft will be flown to the maximum extent possible below 400’ AGL, outside 

of any controlled airspace and outside of 5 miles from any airport IAW §91.126(d), but at all times 

at a minimum safe altitude to allow for obstacle and terrain clearance. Should we need to fly closer 

than five miles from an airport we will establish and maintain radio communications with the 

controlling agency at any applicable airfields. 

5. Summary to publish in the Federal Register

Skycraft LLC & Skycraft Studios seeks an exemption from regulations of 14 CFR to commercially 

include aerial photography and videography in some of our productions without being subject to 

fine or other legal action as it pertains to the current regulations set forth by the FAA.
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6. Additional information, views, or arguments available to support our request

We will be establishing a standard operating procedures within our company for any future 

operators to enable safe and effective use of our unmanned system at all times. Our operations and 

these standards are based on our years of civil aviation single engine flight experience (Piper Archer 

III & Cessna 172) and FAA issued private pilot license. We comply with 14 CFR to the maximum 

extent possible. Furthermore, our operations will be safe, planned, and will not pose any invasive 

threat to manned aircraft or pedestrians on the ground.

7. Reasons why you want to exercise the privileges of our exemption outside the United States 

We do not currently intend on exercising these privileges out of the United States.

Thank you for your time and consideration of our request.

Respectfully,

Nathaniel J. Gonzales

Owner | Skycraft LLC
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Certifications and Training 

 Our pilots all hold current FAA Commercial Pilot certificates and a minimum of FAA Second Class 

medicals. 

 Many of our pilots hold CFI, MEI, and ATP certificates as well as current military qualifications on 

unmanned aircraft. 

 Our pilots have completed rigorous training for the systems we operate including academics, 

simulators, and flight training. These courses, developed by Aviation Unmanned in conjunction with 

manufacturers, provide our pilots the best training possible to operate our systems. This also 

includes emergency procedure training and evaluation, experience building with a qualified 

instructor, and initial/recurring flight evaluations. 

Currency and Proficiency 

 Our pilots maintain currency and proficiency in accordance with a company specific Aircrew 

Proficiency Program. If crewmembers lapse on currency, they are not able to perform flying duties 

until completion of either (depending on how long they have been non-current): at least one flight 

with a qualified instructor or re-training and completion of a flight review by a qualified instructor. 

Flight Operations 

 Each flight is operated under the crew concept, and there are always two fully qualified pilots in 

the crew. The Pilot in Command is responsible for flying the aircraft and ensuring the safety of flight 

operations, the Second in Command is responsible for operating the payload and providing input to 

the PIC. In the event of PIC incapacitation the SIC can step in and safely land the aircraft. 

 We abide by a “sterile cockpit” rule anytime one of the following three criteria are met: 

 Presets or Landing checklists have started 

 Altitude is less than 150’ AGL or 

 Aircraft position is 0.25 nm or less from the ground control station. 

Regulations Adherence 

 Our crews are required to adhere to 14 CFR §91.17 (Alcohol or Drugs) and 14 CFR §121.471 (Flight 

time limitations and rest requirements: All flight crewmembers) 

Aircraft 

 The systems we will use to perform these inspections are proven, reliable systems. 

 Our aircraft have detailed Lost Comm plans that, in the event of a loss of communication, will 

bring the aircraft back at a specific altitude, position, and airspeed. 

 We can set them to automatically land in a cleared area or hover over the cleared area while we 

work to get the communications back. 

 We always set the Lost Comm plan routing to avoid populated areas and major roads 

7. Reasons why you want to exercise the privileges of our exemption outside the United States 

We do not currently intend on exercising these privileges out of the United States.