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# SKYCRAFT LLC

Req uest for Section 333 Exemption

Commercial Film & Video

August 19, 20152 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 P hantom 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) & § 61.12 3 : 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 th e 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 a lways have extra crew on set. We w ill have dedicated observers out during flights, and to
the maxi mum extent possible stay below 4 00’ 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. airworth iness certificates: Instru ment and equipment requirements. Specifically items (5) and (7) through (17).

• We do not plan to fly at night initially

.3 g) §91.207: Emergency locator transmitters

h) §91.125: ATC transponder and altitude reporting equipment an d 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

. W e 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 exemp tion 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 desire d 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 tour ism , 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, t he 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 restrictio ns, NOTAMS, TFR’s, restricted airspace, and helicopter
corridor charts. Our aircraft will be flown to the maximum extent possible below 4 00’ AGL, outside of any cont rolled 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 R egister 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

.4 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

. W e comply with 14 CFR to the maximum extent possible. Furthermore, our operations will be safe

, planned, and will not pose any inv a sive 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. Gonzal es Owner | Skycraft LLC5 Certifications and Training  Our pilots all hold current FAA Commercial Pilot certificates and a minimum of FAA Second Class
medica ls.  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. T hese 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
instr uctor, 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 fl ying 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 oper ating 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 pl ans 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 communication s 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 p rivileges out of the United States.