John C. Ullom 

2 Pelican Circle 

Half Moon Bay, CA 94019 

650-291-9850 

skygizmo@skygizmo.com 

April 15

\ 2015 

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC 20590 

·-, .. ". 

Re: 333 Exemption For Commercial Operations Of Unmanned Aerial Systems 

Dear Team FAA, 

I hope my application for a Section 333 Exemption finds all of you well. Thank you for 

considering its merits and for the service you provide to our nation. 

Best Regards 

~A_ C. ~ John Ullom 

Owner Skygizmo UAS 
Table of Contents 

I. Company Background 

II. Training & Operations 

Ill. Regulations- Exemptions Requested 

Requirements 

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 

• 14 C.F.R. §45.23(b)- Aircraft Marking and Identification 

• 14 C.F.R. §91.7(a)- Civil Aircraft Airworthiness 

• 14 C.F.R. §91.1 03- Preflight Action 

• 14 C.F.R. §91.119- Minimum Safe Altitudes 

• 14 C.F.R. §91.151 (a)- Fuel Requirements for Flight in VFR 

Conditions 

• 14 C.F.R. §91.405(a), § 91.407(a)(1 ), § 91.409(a)(2) and 

§ 91.417(a) & (b)- Maintenance Inspections 

Instruction 

• 14 C.F.R.§61.183(c)(1)(c)(2)(i)(ii)(iii)(iv) & (d) & (e)(1)(2)(3) & (f) & 

(g) & (h)(1 )(2) & (i)(1 )(2) & U) & (k)- Eligibility 

IV. Public Interest 

V. Privacy Concerns 

VI. Summary - Federal Register 

Additional Documentation: 

• Yuneec Q500 UAS Operations Manual 

• DGI S1000 Plus UAS Operations Manual 

2 
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I. Company Background 

John Ullom founded Skygizmo UAS in 2015. He has a Private Pilots License with Single 

Engine Land and Glider Aero Tow ratings. He has been a pilot since he learned to fly 

Hang Gliders in the mid 1980's. 

II. Training & Operations 

Section 333 of "The Reform Act" states: 

" ... the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system ... In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum- (1) which types of unmanned aircraft systems, if any, as a result of 

their size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a hazard 

to users of the national airspace system or the public or pose a threat to national 

security ... " 

Skygizmo will adhere to the specifications and requirements set within the DJI S1000+ 

and Yuneec Q500 Operations manual(s) and FAA guidelines. 

Skygizmo UAS seeks authorization to utilize the OJI S1 000+ and Yuneec Q500 to 

conduct operations for aerial imaging, cinematography, recording of outdoor sporting 

events, and introductory instruction for UAS hobbyists. Though we request the 

authorization to work within multiple industries, the operational area, environment and 

flight operations will not generally change. We fully anticipate conducting operations for 

two or more industries concurrently over the same area and therefore believe, flight 

operations and the safety of, require the same level of attention regardless of whether 

the UAV is recording an outdoor sporting event, acquiring data for a farmer, or providing 

cinematography services. 

The S1 000+ and the Q500 both meet the requirements for determination for exemption 

as each has a maximum weight of less than 25 lbs, maximum speeds of less than 50 

knots and flight durations of less than two hours (battery limited). Operating within visual 

line of sight (VLOS) and remaining below 400ft AGL will be the standard operating 

procedures for Skygizmo UAS and will remain so until further advances in safety of 

flight are introduced to the market and regulated by the FAA. 
The Aircraft: 

DJIS1000+ 

Design: The S1 000+ UAS is an Octocopter built from a variety of durable, 

lightweight and modular components that aid in its capability to be on mission in 

a variety of conditions. As well, the modularity of construction allows for easy 

exchange of structural, propulsion or sensor components- in the field. -As 

defined by OJ/ 

Aircraft Performance/Specifications: 

• Aircraft Type: Octocopter 

• Flight Controls: 

o Primary: GPS Guided Autopilot 

o Backup: Standard RC Transmitter Flight Controls 

• Propulsion: Eight Electric Motors 

• Power Source: Rechargeable Li-Po Battery 

• Max Flight Duration: 15 minutes 

• Max Rotor Tip to Rotor Tip Diameter: 114.5 em 

• Empty Weight: 4.4 kg 

• Max Payload: 5.6 kg 

• RC Frequency: 2.4 GHz 

• Video Transmission Frequency: 5.8GHZ 

Yuneec QSOO 

Design: The 0500 UAS is a Ouadcopter built from a variety of durable, and 

lightweight components. The 0500 UAS has an integrated Camera and Flight 

Controller. 

Aircraft Performance/Specifications: 

• Aircraft Type: Ouadcopter 

• Flight Controls: 

o Primary: GPS Guided Autopilot (Ground Control Station) 

o Backup: Standard Flight Controls (RC Transmitter) 

• Propulsion: Four Electric Motors 

• Power Source: Rechargeable Li-Po Battery 

• Max Flight Duration: 25 minutes 

• Max Rotor Tip to Rotor Tip Diameter: 89.5 em 

• Weight: 1.7 kg (Integrated Camera) 

• RC Frequency: 2.4 GHz 

• Video Transmission Frequency: 5.8GHz 

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Operator Training: 

The PIC for all Skygizmo UAS operations will be the owner of Skygizmo UAS, John 

Ullom. In addition to his Private Pilots License, John Ullom will maintain a third class 

medical certificate. It is not anticipated that Skygizmo UAS will need to hire additional 

PIGs. Should that change prior to the issuances of new regulations for Unmanned 

Vehicle Services, Skygizmo UAS will apply for an appropriate privileges and 

exemptions. Before flying any UAS commercially, the PIC will become familiar with the 

following: 

Pre-Flight Training: 

• Unpacking and assembly 

• Power requirements, set-up and connectivity 

• System end-to-end set-up and test I inspections 

• Preflight, run-up and system checks 

Flight Operations Training: 

• Proper Handling 

• Motor Operations 

• GCS Flight Programming and Test 

• Launch 

• Basic Flight (climb, cruise, descent, landing) 

• Maneuvering 

• Airspace and Landing Zone Operations 

• Flight Reprogramming 

• Flight Monitoring 

• In-Flight Emergency Procedures 

Post Flight: 

• Shut Down Procedures 

• Data Retrieval and Storage 

• End-to-End Test and Maintenance Logs 

• Disassembly 

• Packing, Storage and Transportation 

Operations Execution: 

5 

Given the fact commercial UAS operations are restricted due to the lack of regulations 

other than provided within the above stated documents, a logical and safe solution is to 

utilize the safety guidance provided for hobbyist use of an UAS and other model aircraft 

as identified by Advisory Circular 91-57 and Section 336 of the "Reform Act". Skygizmo 

UAS operations will be conducted in a methodical, efficient and most importantly, safe 

manner adhering to strict guidelines, which address safety, concerns with proximity to 
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airports and populated areas in the interim of official guidance from the FAA as the rules 

and regulations are being further developed. 

The following list provides specific rules and guidelines that all Skygizmo UAS operations will adhere to 

too ensure at least an equivalent or higher level of safety when compared to manned aircraft 

performing the same functions as outlined within 14 C.F.R.: 

• All flight crews will: 

• Be comprised of a minimum of two Skygizmo UAS personal; one serving 

as the Pilot In Command and the other as a Visual Observer 

• Attend pre and post flight mission briefs which will consist of weather 

information, flight information to include operational area and mission 

objectives, hazard mitigation actions and most importantly emergency and 

abort procedures; also included will be any NOTAMs or improvements to 

standard operating procedures through further refinements in operations 

• Communicate over two way radio, cell phone and/or other communication 

devices identified to increase operational efficiencies 

• All flight operations will: 

• At no time fly within one statute mile of any operational airfield 

• Provide prior notification to airfield operator and airfield air traffic control 

tower (when applicable) when operating within five statute miles of any 

active airfield; no later than 24 hours prior to air operations 

• Be conducted using a UAS as defined by the FAA that has a UAV 

weighing less than 55 lbs; all operations authorized through this 

exemption request will be done with the either the S 1 000+ UAS or the 

0500 UAS 

• Be conducted in Class G and occasionally E airspace and shall not 

exceed 400 ft AGL 

• Be conducted VLOS of the qualified PIC and VO 

• Give right-of-way to and avoid flying near manned aircraft at all times 

• Be conducted in rural environments and uncongested urban environments 

• Be conducted with written consent from land owner I managing agency 

• Ensure air vehicles do not encroach within 500 ft of any paved road, 

person, vehicle, or structure that is not associated with operations 

• Abort/Cancel in the event of detrimental weather to include wind speeds 

exceeding the allowable limits as defined within operations manual of the 

applicable UAS 

• All Hobbyist Instruction: 

• Will be conducted in areas where it will be easy to maintain safety 

• Be designed to promote a safe attitude in the student and stress 

courteous conduct 

• Will include the fundamentals of Flight, GPS, Data and Control Links, 

Autonomous Systems, and Emergency Procedures 
• Cover the FAR's and Conditions that apply to all Skygizmo UAS 

operations 

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Emergency Procedures: 

• 

• 

• 

• 

• 

• 

In the event the air vehicle losses GPS signal, automated return to home will 

immediately commence based on the pre-programmed parameters identified and 

uploaded prior to initiation of flight. The flight plan is built in such a way that 

hazards are identified prior to launch will allow the PIC to successfully recover 

control of the air vehicle. 

In the event the PIC losses signal with the air vehicle, automated return-to-home 

and loiter will commence until signal is regained. The flight plan is built in such a 

way that all hazards are identified prior to launch and an automated landing in 

the event signal is not regained will be conducted in a safe and responsible 

manner. 

In the event hazardous weather unexpectedly approaches and may affect 

operations, the PIC will immediately abort the operation and conduct landing 

activities 

In the event an in-flight emergency occurs, (i.e. air vehicle maintenance issues), 

the PIC will immediately abort flight and conduct landing activities; air vehicle 

inspection will immediately be achieved and the air vehicle will not return to 

service without proper authorization from a trained maintenance technicial 

In a "significant" event (i.e. air vehicle crashes and outside assistance is needed), 

PIC will conduct notification procedures to include county sheriff and fire 

departments, airfield operator/tower if applicable and any other authority required 

to mitigate situation a "significant" event report will be generated by the PIC, 

verified by the VO. 

By following these strict, mostly self imposed guidelines; Skygizmo, UAS will 

achieve a safety level greater than that directed by the rules in which they seek 

exemption, especially true when you compare the same operating procedures 

against a manned aircraft. UAS's are inherently safer in all facets due to the fact 

that they are much smaller, fly at much lower speeds, there are no human 

operators on board and there is zero fuel to be concerned with in the event of a 

crash. As processes are further refined, the operations will only add to an already 

higher level of safety compared to manned flight operations in which serves the 

public's best interest in the FAA's endeavor to integrate UAS into the NAS. 
Ill. Regulations - Exemption Requested 

Pursuant to 14 C.F.R. § 11.81 (e), Skygizmo UAS seeks exemption from the below 

mentioned regulations and provides reason as to why the exemption should be 

approved based on the level of safety at least equal to that of which the rules require. 

• 14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 

~ Establishes: The procedural requirements for the issuance of airworthiness certificates 

as required by 14 C.F.R. § 91.203(a)(1) 

8 

Given the small size of the UAS, the limited operating areas and meticulous 

procedures defined within the training and operations section (re-iterated below), 

an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the "Reform Act" with 

consideration "of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular UAS." 

• UAS Size: Less than 5 ft 

• UAS Weight: Less than 25 lbs 

• UAS Speed : Less than 50 knots 

• UAS Capacities: 2 hour battery limited flight time (No fuel on board) 

• No operations within one statute mile; Prior notice given to ATC 

tower/Airport Operator w/in five statute miles 

• Operations conducted in Rural areas and uncongested urban areas 

only, with a minimum distance of 500ft from all persons, structures, 

roads, and vehicles other than those that are part of the mission 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Build Imagery, Blue 

Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 

Media and Pictorvision. 

• 14 C.F.R. § 45.23(b)- Aircraft Marking and Identification Requirements 

~ 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capita/letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must a/so display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable. 
9 

Skygizmo UAS will ensure compliance with § 45.29(f) to meet the intent of the 

regulation by placing the word "experimental" on the fuselage of the air vehicle(s). 

NOTE: The FAA has set precedence to this regulation within like given parameters and an 

exemption should be approved on this basis along with previous exemptions: Nos. 10700, 10167 

and 10167 A. Also, see most recent exemption approvals for Build Imagery, Blue Chip UAS, 

Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and 

Pictorvision for further justification of approval. 

• 14 C.F.R. 91.7(a)- Civil Aircraft Airworthiness 

);> States: No person may operate a civil aircraft unless it is in an airworthy condition. 

Currently there is no airworthiness certificate for either the OJI 81 00+ or the 

Yuneec 0500 UAS; however, daily pre and post flight inspections will be 

accomplished in accordance with manufactures maintenance manual(s) and 

guidance. During flight, the PIC will adhere to§ 91.7(b) and abort air operations 

immediately upon identification of an in flight emergency. Trained maintenance 

technicians and/or the manufacturer will conduct any maintenance performed. By 

applying the prescribed operations, inspection and maintenance procedures 

within the operations section and operations manual, an equivalent level of safety 

will be achieved. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91. 7(a): Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

Also, see most recent exemption approvals for Build Imagery, Blue Chip UAS, Astraeus Aerial, 

Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media and Pictorvision for 

further justification of approval. 

• 14 C.F.R. 91.103- Preflight Action 

);> States: Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include- (paragraphs a, 

b, 1 and 2) 

A pre-flight mission brief must be attended by all crew members. This "PMB" will 

contain weather and all flight information including emergency and abort 

procedures. In addition, the PIC will verify air vehicle is ready for flight by 

coordinating with the maintenance technician during pre-flight inspection. 

The exemption requested for this section is specifically addressed toward the 

requirements, which do not apply to UAS operations such as runways and air 

traffic control integration. 

NOTE: As previously stated, air traffic control and airport operator will be notified prior to 

any operations being executed within five statute miles 

NOTE: The FAA has recently set precedence to this regulation within like given 

parameters and an exemption should be approved on this basis. See exemption 
approvals for Build Imagery, Blue Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo 

Productions, RC Pro Productions, Snapro/1 Media and Pictorvision. 

14 C.F.R. 91.119 (c)- Minimum Safe Altitudes 

10 

>- States: Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

All Skygizmo UAS operations will be conducted at 400 ft AGL or below in 

uncontrolled Class G and occasionally E airspace. As a UAS are inherently safer 

than traditional aircraft due to their small size, lightweight, battery operated vs 

fuel and no human on-board; Skygizmo UAS will not operate within 500 ft to any 

improved roads, vehicles persons or structures (other than those being inspected 

as part of the flight operation or consenting participants). In addition, 

objects/hazards will be identified and geo-located prior to flight to be utilized 

within the flight planning stages to ensure this objective is met. 

• 14 C.F.R. 91.151(a)- Fuel Requirements for Flight in VFR Conditions 

>- States: No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed- (1) During the day, to 

fly after that for at least 30 minutes; 

This regulation is written based on the capabilities of a traditional aircraft which 

have flight times of several hours or greater; therefore, with the majority of UAS's 

which have flight times of only an hour or less, this regulation would effectively 

deny the ability of the air vehicle to operate. 

To meet the intent, Skygizmo.com, will operate its air vehicles to no less than 

25% remaining battery power to ensure safe landing and retrieval of the air 

vehicle. This 25% buffer and the ability to quickly and safely land a UAS in nontraditional environments, ensures at least an equal level of safety. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.151 (a): Exemption 

Nos. 10673, 2689F, 5745, 10673 and 10808. Also, see most recent exemption approvals for 

Build Imagery, Blue Chip UAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro 

Productions, Snaproll Media and Pictorvision for further justification of approval. 

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) -

Maintenance Inspections 

>- 91.405(a) States: Each owner or operator of an aircraft-(a) Shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter 

>- 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless-(1) It has been 

approved for return to service by a person authorized under§ 43. 7 of this chapter 
11 

> 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person 

may operate an aircraft unless, within the preceding 12 calendar months, it has had-(2) 

An inspection for the issuance of an airworthiness certificate in accordance with part 21 

of this chapter. No inspection performed under paragraph (b) of this section may be 

substituted for any inspection required by this paragraph unless it is performed by a 

person authorized to perform annual inspections and is entered as an "annual" 

inspection in the required maintenance records. 

> 91.417(a) & (b) States: (a) Except for work performed in accordance with§§ 91.411 and 

91.413, each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: (paragraphs 1 (i-iii), 2 (i-vi)); (b) The owner or 

operator shall retain the following records for the periods prescribed: (paragraphs 1-3) 

Due to the fact neither the S 1 000+ UAS nor the 0500 UAS at present has an 

airworthiness certificate, these regulations cannot be complied with as written 

and therefore an exemption is necessary. Pre/Post and routine inspections (not 

to exceed 50 flight hours) and maintenance will be conducted in accordance with 

the manufacturer's guidance as stated in the operations and maintenance 

manuals. In addition, to meet the intent of these regulations, Skygizmo UAS, will 

maintain daily logs of pre and post flight inspections and have maintenance 

performed by trained technicians and/or the manufacturer themselves. In the 

event maintenance is required, trained technicians will verify the air vehicle is in 

flight readiness status prior to releasing to PIC for use in operations. 

Unscheduled maintenance will be accomplished in the event of a mechanical or 

structural failure during flight. Upon completion of unscheduled maintenance, 

documentation will be provided to the Pilot In Command to sign off and verify that 

the air vehicle is once again ready for flight and accept the level of risk 

associated with returning the air vehicle to flight status. At no time will there be 

changes made to the air vehicle which would impact the structural integrity of the 

air frame without the manufacturer making such changes and verifying the flight 

its air worthiness. 

All inspection and maintenance will be documented and maintained in-house. 

These actions will meet the intent of the regulation exemption is being requested 

and lead to the equivalent level of safety. 

NOTE: The FAA has recently set precedence to this regulation within like given parameters and 

an exemption should be approved on this basis. See exemption approvals for Build Imagery, Blue 

Chip VAS, Astraeus Aerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snaproll 

Media and Pictorvision. 

• 14 C.F.R. 61.183 -Instructor Eligibility Requirements 

> States: To be eligible for a flight instructor certificate or rating a person must: 

(a) Be at least 18 years of age; 

(b) Be able to read, speak, write, and understand the English language. If the applicant is 

unable to meet one of these requirements due to medical reasons, then the Administrator 

may place such operating limitations on that applicant's flight instructor certificate as are 

necessary; 

(c) Hold either a commercial pilot certificate or airline transport pilot certificate with: 
(1) An aircraft category and class rating that is appropriate to the flight instructor rating 

sought; and 

12 

(2) An instrument rating or privileges on that person's pilot certificate that is appropriate to 

the flight instructor rating sought, if applying for--

(i) A flight instructor certificate with an airplane category and single-engine class rating; 

(ii) A flight instructor certificate with an airplane category and multiengine class rating; 

(iii) A flight instructor certificate with a powered-lift rating; or (iv) A flight instructor 

certificate with an instrument rating. 

(d) Receive a logbook endorsement from an authorized instructor on the fundamentals of 

instructing listed in Sec. 61.185 ofthis part appropriate to the required knowledge test; 

(e) Pass a knowledge test on the areas listed in Sec. 61.185(a)(1) of this part, unless the 

applicant: 

(1) Holds a flight instructor certificate or ground instructor certificate issued under this 

part; 

(2) Holds a current teacher's certificate issued by a State, county, city, or municipality that 

authorizes the person to teach at an educational/eve/ of the 7th grade or higher; or 

(3) Is employed as a teacher at an accredited college or university. 

(f) Pass a knowledge test on the aeronautical knowledge areas listed in Sec. 61.185(a)(2) 

and (a)(3) of this part that are appropriate to the flight instructor rating sought; 

(g) Receive a logbook endorsement from an authorized instructor on the areas of 

operation listed in Sec. 61.187(b) of this part, appropriate to the flight instructor rating 

sought; 

(h) Pass the required practical test that is appropriate to the flight instructor rating sought 

in an: 

( 1) Aircraft that is representative of the category and class of aircraft for the aircraft rating 

sought; or 

(2) Flight simulator or flight training device that is representative of the category and class 

of aircraft for the rating sought, and used in accordance with an approved course at a 

training center certificated under part 142 of this chapter. 

(i) Accomplish the following for a flight instructor cet1ificate with an airplane or a glider 

rating: 

(1) Receive a logbook endorsement from an authorized instructor indicating that the 

applicant is competent and possesses instructional proficiency in stall awareness, spin 

entry, spins, and spin recovery procedures after providing the applicant with flight training 

in those training areas in an airplane or glider, as appropriate, that is certificated for 

spins; and 

(2) Demonstrate instructional proficiency in stall awareness, spin entry, spins, and spin 

recovery procedures. However, upon presentation of the endorsement specified in 

paragraph (i)(1) of this section an examiner may accept that endorsement as satisfactory 

evidence of instructional proficiency in stall awareness, spin entry, spins, and spin 

recovery procedures for the practical test, provided that the practical test is not a retest 

as a result of the applicant failing the previous test for deficiencies in the knowledge or 

skill of stall awareness, spin entry, spins, or spin recovery instructional procedures. If the 

retest is a result of deficiencies in the ability of an applicant to demonstrate knowledge or 

skill of stall awareness, spin entry, spins, or spin recovery instructional procedures, the 

examiner must test the person on stall awareness, spin entry, spins, and spin recovery 

instructional procedures in an airplane or glider, as appropriate, that is certificated for 

spins; 

U) Log at feast 15 hours as pilot in command in the category and class of aircraft that is 

appropriate to the flight instructor rating sought; and 

(k) Comply with the appropriate sections of this part that apply to the flight instructor 

rating sought. 
Due to the fundamentally different nature of Manned Aerial Systems and Unmanned Aerial Systems, 

these regulations cannot be complied with as written and therefore an exemption is requested. 

Skygizmo UAS will develop a syllabus and instructional protocols similar to those that are used in the 

Manned Aircraft Instructional industry. 

IV. Public Interest 

13 

The public's best interest is achieved by the safe integration of UAS's into the NAS. 

With the ongoing exemption process, the FAA has to identify those exemption requests 

with the public's best interest in mind and select the companies who will be able to 

achieve this in a safe and responsible manner. Two of the main problems the public has 

with UAS are the fear of what they will be used for and whether or not they are safe to 

fly within the same airspace as commercial airliners. 

Skygizmo UAS will operate in such a manner as to provide a positive example of how 

Unmanned Aerial Systems can add to the quality of life and benefit all Americans. By 

flying with respectful and courtesy and teaching those values to prospective hobbyists, 

among who will be the future Pilots In Command for the Unmanned Aerial Services 

industry, Skygizmo UAS hopes to be part of making the services it will provide, a 

ubiquitous part of life in America. 

Skygizmo UAS will provide any additional information requested and will diligently work 

with the FAA to make this approval a reality as it is in the best interest and safety of the 

public as directed by Congress. 

V. Privacy Concerns 

As previously stated, one of the main concerns the public has with the integration of 

Unmanned Aerial Systems into the NAS is privacy and spying. Skygizmo UAS 

understands and shares those privacy and oversight concerns. Skygizmo UAS will meet 

or exceed the specifications found in Executive Order 12333, DoD Directive 5240.1-R 

and AFI 14-104. Although the regulations do not apply to private commercial entities, 

knowledge and application of these regulations will assist and ensure any and all 

privacy concerns will be minimal and immediately mitigated. Before any recording is 

provided to a customer or the public, any imagery that violates the privacy of any person 

or entity will be scrubbed. 
14 

VI. Summary - Federal Register 

Pursuant to Section 333 of PL 112-95 commonly known as the "FAA Modernization and 

Reform Act of 2012" or "The Reform Act", John Ullom, d/b/a Skygizmo UAS, hereby 

applies for authorization to conduct commercial unmanned aerial systems (UAS) 

operations that include aerial imaging, cinematography, recording of outdoor sporting 

events, and introductory instruction for UAS hobbyists, within the United States National 

Airspace System (NAS); within Class G and occasionally E airspace. 

Rules in which Skygizmo UAS seeks exemption: 

• 14 C.F.R. Part 21 Subpart H 

• 14 C.F.R. § 45.23(b) 

• 14 C.F.R. § 91.7(a) 

• 14 C.F.R. § 91.103 

• 14C.F.R.§91.119 

• 14C.F.R.§91.151(a) 

• 14 C.F.R. § 91.405(a) 

• 14 C.F.R. § 91.407(a)(1) 

• 14 C.F.R. § 91.409(a)(2) 

• 14 C.F.R. § 91.417(a) & (b) 

• 14 C.F.R. § 61.183(c)(1 )(c)(2)(i)(ii)(iii)(iv) & (d) & (e)(1 )(2)(3) & (f) & (g) & 

(h)(1)(2)(i) & (1)(2) & U) & (k) 

Throughout this exemption request, Skygizmo UAS has shown how it will ensure the 

public's best interest is at hand and assist the FAA with their charge to: " ... safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace 

system ... " as directed by Congress. Skygizmo UAS has also shown how the approval of 

this request will meet and exceed " ... at least an equivalent level of safety ... " for the 

regulations they seek exemption.