### John C. Ullom 2 Pelican Circle Half Moon Bay, CA 94019 650-291-9850 skygizmo@skygizmo.com April 1 5\ 

### 2015
U.S. Department ofTransportation Docket Operations 1200 New JerseyAve., SE Washington, DC 20590 ·-,

..".



### Re: 333 Exemption For Commercial Operations Of Unmanned Aerial Systems DearTeam FAA, I hope my application for a Section 333 Exemption finds all of you well. Thank you for considering its merits and forthe service you provide to our nation.
Best Regards



# ~A_ C.



# ~ John Ullom Owner Skygizmo UASTable ofContents

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 23
I. Company Background

John Ullom founded Skygizmo UAS in 2015. He has a Private Pilots License with Single Engine Land and GliderAero 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 SecretaryofTransportation shall determine ifcertain unmannedaircraft systems mayoperate safelyin the nationalairspace system

...In making the determination undersubsection (a), the Secretaryshall determine, ata minimum- (1) which types ofunmannedaircraftsystems, ifany, as 

### a result of theirsize, weight, speed, operational capability, proximityto airports and populatedareas, andoperation within visual line ofsightdo notcreate 

### a hazard to users ofthe nationalairspace system orthe public orpose 

### 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 ofoutdoor 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 overthe same area and therefore believe, flight operations and the safety of, require the same level ofattention regardless ofwhether the UAV is recording an outdoor sporting event, acquiring data for a farmer, or providing cinematography services.
The S1 000+ and the Q500 both meetthe 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 ofsight (VLOS) and remaining below 400ftAGL 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 bythe FAA.

## The Aircraft: DJIS1000+ Design: The S1 000+ UAS is an Octocopter built from a variety ofdurable, lightweight and modular components that aid in its capability to be on mission in a variety ofconditions. As well, the modularity ofconstruction allows for easy exchange ofstructural, propulsion or sensor components- in the field. 

### -As definedby 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 ofdurable, 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 4OperatorTraining: The PIC for all Skygizmo UAS operations will be the owner ofSkygizmo 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 priorto 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 otherthan provided within the above stated documents, a logical and safe solution is to utilize the safety guidance provided for hobbyist use ofan UAS and other model aircraft as identified byAdvisory Circular 91-57 and Section 336 ofthe "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 proximityto6 airports and populated areas in the interim ofofficial 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 ofsafety when compared to manned aircraft performingthe same functions as outlined within 14 C.F.R.:

• All flight crews will: • Be comprised ofa minimum oftwo 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 ofweather 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 overtwo 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 ofany operational airfield • Provide prior notification to airfield operator and airfield airtraffic control tower (when applicable) when operating within five statute miles ofany active airfield; no laterthan 24 hours priorto air operations • Be conducted using a UAS as defined by the FAAthat has a UAV weighing less than 55 lbs; all operations authorized through this exemption request will be done with the eitherthe S1000+ UAS orthe 0500 UAS • Be conducted in Class G and occasionally E airspace and shall not exceed 400 ft AGL • Be conducted VLOS ofthe 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 airvehicles do not encroach within 500 ft ofany paved road, person, vehicle, or structure that is not associated with operations • Abort/Cancel in the event ofdetrimental weatherto include wind speeds exceeding the allowable limits as defined within operations manual ofthe applicable UAS

• All Hobbyist Instruction: • Will be conducted in areas where it will be easyto 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

### • Coverthe FAR's and Conditions that apply to all Skygizmo UAS operations 7



### Emergency Procedures:



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•

•

•



### •

• In the eventthe airvehicle losses GPS signal, automated return to home will immediately commence based on the pre-programmed parameters identified and uploaded prior to initiation offlight. The flight plan is built in such away that hazards are identified priorto launch will allow the PIC to successfully recover control ofthe airvehicle. In the eventthe PIC losses signal with the airvehicle, automated return-to-home and loiterwill commence until signal is regained. The flight plan is built in such a way that all hazards are identified priorto 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. airvehicle maintenance issues), the PIC will immediately abort flight and conduct landing activities; airvehicle inspection will immediately be achieved and the airvehicle will not return to service without proper authorization from a trained maintenance technicial In a "significant" event (i.e. airvehicle crashes and outside assistance is needed), PIC will conduct notification procedures to include county sheriff and fire departments, airfield operator/tower ifapplicable 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 greaterthan that directed bythe 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 ofa crash. As processes are further refined, the operations will only add to an already higher level ofsafety compared to manned flight operations in which serves the public's best interest in the FAA's endeavorto integrate UAS into the NAS.

### Ill. Regulations
- Exemption Requested Pursuantto 14 C.F.R. 

### § 11.81(e), Skygizmo UAS seeks exemption from the below mentioned regulations and provides reason as to whythe exemption should be approved based on the level ofsafety at least equal to that ofwhich the rules require.



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

**~** Establishes: The procedural requirements for the issuance ofairworthiness certificates as required by 14 C.F.R. § 91.203(a)(1) 8

Given the small size ofthe 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 ofan equivalent level ofsafety under Part 11 and Section 333 ofthe "Reform Act" with consideration "ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe 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 Operatorw/in five statute miles • Operations conducted in Rural areas and uncongested urban areas only, with a minimum distance of500ftfrom all persons, structures, roads, and vehicles otherthan those that are part ofthe mission NOTE: The FAA has recentlysetprecedence to this regulation within like given parameters and an exemption shouldbe approvedon this basis. See exemption approvals forBuild Imagery, Blue Chip UAS, AstraeusAerial, AerialMOB, 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 ofthe Aircraft, states: When marks include only the Roman capita/letter "N"and the registration numberis displayed on limited, restricted orlight-sport categoryaircraftor experimental orprovisionallycertificated aircraft, the operatormusta/so display on thataircraftneareach entrance to the cabin, cockpit, orpilotstation, in letters notless than 2 inches normore 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 ofthe airvehicle(s).
NOTE: The FAA has setprecedence to this regulation within like given parameters andan exemption shouldbe approvedon this basis along with previous exemptions: Nos. 10700, 10167 and 10167 A. Also, see most recent exemption approvals forBuild Imagery, Blue Chip UAS, AstraeusAerial, AerialMOB, HeliVideo Productions, RC Pro Productions, Snaproll Media and Pictorvision for furtherjustification ofapproval.


### • 14 C.F.R. 91.7(a)- Civil Aircraft Airworthiness );> States: No person mayoperate a civilaircraft unless it is in an airworthycondition. 

### Currentlythere is no airworthiness certificate for eitherthe 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/orthe manufacturerwill conduct any maintenance performed. By applying the prescribed operations, inspection and maintenance procedures within the operations section and operations manual, an equivalent level ofsafety will be achieved. NOTE: The FAA has setprecedentbypreviouslyissuing 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 forBuild Imagery, Blue Chip UAS, AstraeusAerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media andPictorvision for furtherjustification ofapproval.


### • 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 mustinclude- (paragraphs a, b, 1 and2) 

### 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: Aspreviouslystated, airtraffic control andairport operator will be notifiedpriorto anyoperations being executed within five statute miles NOTE: The FAA has recentlysetprecedence to this regulation within like given parameters andan exemption shouldbe approvedon this basis. See exemptionapprovals forBuild Imagery, Blue Chip UAS, AstraeusAerial, AerialMOB, HeliVideo Productions, RC Pro Productions, Snapro/1 Media andPictorvision. 14 C.F.R. 91.119 

### (c)- Minimum Safe Altitudes 10



### >- States: Except when necessary for takeofforlanding, no person may operate an aircraft below the following altitudes: (c) Overotherthan congestedareas. An altitude of500 feet above the surface, except over open water orsparselypopulated areas. In those cases, the aircraft may not be operated closer than 500 feet to anyperson, 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 ofintended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatforatleast 30 minutes; 

### This regulation is written based on the capabilities of a traditional aircraft which have flight times ofseveral hours or greater; therefore, with the majority of UAS's which have flight times of only an hour or less, this regulation would effectively denythe ability ofthe airvehicle 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 ofsafety. NOTE: The FAA has setprecedentbypreviouslyissuing 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, AstraeusAerial, Aerial MOB, HeliVideo Productions, RC Pro Productions, SnaprollMedia and Pictorvision forfurther justification ofapproval.

• 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 ofthis partand shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribedin part43 ofthis 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 forreturn to service bya person authorized under§ 43. 7 ofthis chapter11


## > 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 calendarmonths, it has had-(2) An inspection for the issuance ofan 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 workperformed in accordance with§§ 91.411 and 91.413, each registered owneroroperatorshallkeep the following records for the periods specified in paragraph (b) ofthis section: (paragraphs 1 (i-iii), 2 (i-vi)); (b) The owneror operatorshall retain the following records for the periods prescribed: (paragraphs 1-3) 

### Due to the fact neither the S1 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 ofthe air frame without the manufacturer making such changes and verifying the flight its airworthiness. All inspection and maintenance will be documented and maintained in-house. These actions will meet the intent ofthe regulation exemption is being requested and lead to the equivalent level ofsafety. NOTE: The FAA has recentlysetprecedence to this regulation within like given parameters and an exemption shouldbe approvedon this basis. See exemption approvals forBuild Imagery, Blue Chip VAS, AstraeusAerial, AerialMOB, HeliVideo Productions, RC Pro Productions, Snaproll Media andPictorvision.


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

### > States: To be eligible fora flight instructorcertificate orrating a person must: (a) Be atleast 18years ofage; (b) Be able to read, speak, write, and understand the English language. Ifthe applicantis unable to meetone ofthese requirements due to medicalreasons, then the Administrator mayplace such operating limitations on thatapplicant's flight instructorcertificate as are necessary; (c) Hold eithera commercialpilotcertificate orairline transportpilot certificate with:(1) An aircraft categoryandclass rating that is appropriate to the flight instructorrating sought; and 12

(2) An instrument rating orprivileges on thatperson's pilotcertificate that is appropriate to the flight instructorrating sought, ifapplying for-- (i) A flight instructorcertificate with an airplane categoryandsingle-engine class rating; (ii) A flight instructorcertificate with an airplane categoryandmultiengine class rating; (iii) A flight instructorcertificate with a powered-liftrating; or(iv) A flight instructor certificate with an instrumentrating. (d) Receive a logbook endorsement from an authorizedinstructoron the fundamentals of instructing listed in Sec. 61.185 ofthispartappropriate to the required knowledge test; (e) Pass a knowledge test on the areas listedin Sec. 61.185(a)(1) ofthis part, unless the applicant: (1) Holds a flight instructorcertificate orgroundinstructorcertificate issued underthis part; (2) Holds a current teacher's certificate issuedby

### a State, county, city, ormunicipality that authorizes the person to teach atan educational/eve/ofthe 7th grade orhigher; or (3) Is employedas a teacheratan accredited college oruniversity. (f) Pass a knowledge test on the aeronauticalknowledge areas listed in Sec. 61.185(a)(2) and (a)(3) ofthis part that are appropriate to the flight instructorrating sought; (g) Receive a logbook endorsement from an authorizedinstructoron the areas of operation listedin Sec. 61.187(b) ofthis part, appropriate to the flight instructorrating sought; (h) Pass the requiredpractical test that is appropriate to the flight instructorrating sought in an: (1) Aircraft that is representative ofthe categoryandclass ofaircraft for the aircraftrating sought; or (2) Flightsimulatororflight training device thatis representative ofthe categoryandclass ofaircraft forthe rating sought, and usedin accordance with an approved course ata training centercertificated underpart 142 ofthis chapter. (i) Accomplish the following fora flight instructorcet1ificate with an airplane ora glider rating: (1) Receive a logbook endorsement from an authorizedinstructorindicating that the applicantis competentandpossesses instructionalproficiencyin stall awareness, spin entry, spins, andspin recoveryprocedures afterproviding the applicant with flight training in those training areas in an airplane orglider, as appropriate, that is certificated for spins; and (2) Demonstrate instructionalproficiencyin stall awareness, spin entry, spins, andspin recoveryprocedures. However, upon presentation ofthe endorsementspecified in paragraph (i)(1) ofthis section an examinermayaccept that endorsementas satisfactory evidence ofinstructionalproficiencyin stallawareness, spin entry, spins, andspin recoveryprocedures for the practical test, provided that the practical testis nota retest as a result ofthe applicant failing the previous test fordeficiencies in the knowledge or skill ofstallawareness, spin entry, spins, orspin recoveryinstructionalprocedures. Ifthe retestis a result ofdeficiencies in the abilityofan applicant to demonstrate knowledge or skill ofstallawareness, spin entry, spins, orspin recovery instructionalprocedures, the examinermust test the person on stallawareness, spin entry, spins, andspin recovery instructionalprocedures in an airplane orglider, as appropriate, that is certificated for spins; U) Log atfeast 15 hours as pilotin commandin the categoryand class ofaircraft that is appropriate to the flight instructorrating sought; and (k) Comply with the appropriate sections ofthis 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 similarto 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 ofthe main problems the public has with UAS are the fear ofwhat 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 ofthe 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 imagerythat 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 howthe approval of this request will meet and exceed "

...at least an equivalent level of safety

..." for the regulations they seek exemption.