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skyVuze

SKYVUZE LLC

Owner/UAS Operator: Alexander Sheard

101 W. Browning Rd. Apt. 31

Collingswood, NJ 08108

856-220-6943

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)

To Whom It May Concern:

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization 

and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Alexander Sheard, 

owner SKYVUZE LLC which owns and operates an Unmanned Aircraft System (UAS), 

hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow commercial operation of its 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 are equipped with 

camera(s) 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 newsgatherings.

- Aerial inspection/photography of residential/commercial structures under contract w

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.

SKYVUZE LLC has UAS specific, general liability insurance policy and operates two

(2) DJI Phantom 3-Standards (4) blade quad copters; each weighing 1216 grams.
The UAS has a maximum airspeed of 35.79 miles per hour and uses a remote controller 

operating on frequency range of 5.725 GHz – 5.825 GHz. The Phantom 3 Standard is 

equipped with built-in ground support technology that allows it to fly utilizing global 

positioning system (GPS) for stability, tracking, safe flight mode and a return-to-home 

feature in the event of loss of remote control signal or critical low battery.

All flights start with a pre-flight safety check and all flight data are recorded. The 

Phantom 3 standard 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 Phantom 3 Standard has a flight time of 20-25 minutes and is, therefore, always 

returned to original takeoff point and always flown utilizing visual line of sight (VLOS). 

We have been training on the DJI Phantom 3 Standard for 4 months and have become 

proficient in all aspects of flight and safety of this UAS. Our request for exemption would 

allow us to offer unique aerial photography and videography services to our clientele.

UAS Safety Operating Parameters

We 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 1,000 feet 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 500 feet to any such vessels, vehicles or 

structures. We will conduct a safety assessment of the risk of operating closer to those 

objects and determine that it does not present an undue hazard. Other safety operating

parameters include:

- 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 permissions 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 and never operate UAS in unsafe conditions, high 

wind, low clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly controlled, are away from power 

lines, elevated lights, airports and densely populated areas.

- Also conduct extensive preflight inspections and protocols during which safety carries 

primary importance. 
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skyVuze

The PIC will also have a minimum of five hours logged on this craft and 10 hours 

minimum flying UAS quad copters under varying conditions and environments and will 

follow all safety protocol of SKYVUZE LLC as well as 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 people.

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).

SKYVUZE LLC requests 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. We 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 is 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.

SKYVUZE LLC requests 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. We 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. However, as a safety precaution, we will perform a preflight 

inspection of the UAS before each flight as outlined in the attached operating documents.

SKYVUZE LLC requests 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. We believe an equivalent level 

of safety will be achieved by maintaining a safety/flight manual with the UAS ground 

station.

SKYVUZE LLC requests an exemption from 14 CFR 91.109 Flight Instruction: 

Simulated Instrument Flight and Certain Flight Tests. The regulation states, “No person 
may operate a civil aircraft that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. Although the DJI Phantom 3 Standard is capable of 

dual/linked controls, we will be operating with a single remote controller. 

SKYVUZE LLC requests 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.

SKYVUZE LLC requests an exemption from 14 CFR 91.121 Altimeter Settings, as it is 

inapplicable since the UAS utilizes electronic GPS with a barometric sensor. 

SKYVUZE LLC requests an exemption from 14 CFR 91.151(a) Fuel Requirements for 

Flight in visual flight rules (VFR) conditions. The UAS is 100 percent electric and two 

low battery alerts are issued – per the operating documents, the UAS will be landed at the 

first alert. Also, our 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 to fly to the first point of intended landing and, assuming normal 

cruising speed, land the UAS with 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: DJI 

Phantom 3 Standard Aircraft System.

2. The UAS will not be flown at an indicated airspeed exceeding 35.79 mph.

3. The UAS will be operated at an altitude of no 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. The UAS will be operated at an altitude of no more than 400 feet AGL, as 

indicated by the procedures specified in the operating documents.

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

7. 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.
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skyVuze

8. 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.

9. 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.

10. Any UAS maintenance or alterations 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. 

11. SKYVUZE LLC 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. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 

in an aircraft in which the PIC is rated on.

15. 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 operations.

16. 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.

17. 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).

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

as denoted on a current FAA-published aeronautical chart.

19. 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 three statute miles from 

the PIC.
20. 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.

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

accordance with the operating documents.

22. 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.

23. 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.

24. 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. 

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

operations and activities at all times.

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

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

contracted out to do events.

28. 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. We 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 must 

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, operator trainees or essential 

persons do not present an undue hazard to those persons per 14 CFR 91.119(a).

29. 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.

30. 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 (AFS80) within 24 hours. Accidents will be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB website: 

www.ntsb.gov.

On behalf of SKYVUZE LLC, I would like to thank you for your consideration in 

granting this exemption.
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skyVuze

Signed,

Alexander Sheard

SKYVUZE LLC