July 28, 2015

Exemption No. 12179

Regulatory Docket No. FAA–2015–1718

Mr. Jeremy Shick 

Owner

Shick Web Design, LLC

230 East Park Avenue, Suite 31

Lake Wales, FL 33853

Dear Mr. Shick:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 7, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Shick Web Design, LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, videography, and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Shick Web Design, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Shick Web Design, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must 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 UA and/or debris in the event of an accident. The operator must 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 UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

May 7, 2015

U. S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109;119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b)

Dear Sir or Madam,

I, Jeremy Shick, owner of Shick Web Design, LLC, am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that, Shick Web Design, LLC, a Florida Limited Liability Company and owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that Shick Web Design, LLC, may operate small ultra light weight 

unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”).

As described herein Shick Web Design, LLC, is a limited liability company in the State of 

Florida; experienced in flying hobby helicopters for recreational purposes. Shick Web Design, 

LLC has added a hobby grade quad-copter1 UAS to it’s inventory equipped with an HD camera 

with intent for aerial photography/videography/cinematography to enhance real estate listings, 

website design and marketing for those individuals and companies seeking these services 

within the geographical State of Florida, in order to augment real estate listings, and website 

design; following exemption and approval by the FAA. Thereby enhancing their website 

aesthetics and real estate listings.

1 Appendix A - DJI Phantom 3 1 of 19
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Committed to safety with each flight, Shick Web Design, LLC's, exemption request would permit 

operation of ultra light weight, unmanned (piloted by remote control) and comparatively 

inexpensive UAS(s) in tightly controlled and limited airspace. Predetermined in areas away from 

general public, airports, heliports and vehicular traffic for residential and commercial real estate 

photography, and within property boundaries for individual homeowner real estate listing videos/

photos. Currently, similar lightweight, remote controlled UAS's are legally operated by 

unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. 

Shick Web Design, LLC, has personally instilled safety protocols and controls2 to avoid and 

prevent public hazard, as well as manned aircraft hazards/catastrophe.

Granting Shick Web Design, LLC’s, request comports with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes. Further, Shick Web Design, LLC, will conduct it’s 

operations in compliance with the protocols described herein or as otherwise established by the 

FAA. For the reasons stated below, Shick Web Design, LLC, respectfully request the grant of an 

exemption allowing it to operate light weight, remote controlled UAS’s for aerial photography/

videography of residential and commercial real estate in order to enhance real estate listings 

and websites for property owners, realtors and website owners who cannot afford expensive 

manned aircraft for the same purpose. Both of which will promote local economic growth 

through increased employment and increased tax base. Both with public safety in mind by 

keeping heavier manned aircraft containing combustible fuel that that poses potential public 

hazard.

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Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

I. Contact Information:

Shick Web Design, LLC

Attn: Jeremy Shick

230 E. Park Ave, Suite 31

Lake Wales, FL 33853

Office: (863) 614-0040

Mobile: (863) 221-2665

Email: jeremy@ShickWebDesign.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Shick 

Web Design, LLC Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Shick Web Design, LLC seeks and the Reason He Seeks Such

Relief:

Shick Web Design, LLC, submits this application in accordance with the Reform Act, 112 P.L. 95 

§§ 331-334, seeking relief from any currently applicable FARs operating to prevent, Shick Web 

Design, LLC, contemplated commercial cinematic, academic and other flight operations within 

the national airspace system. The Reform Act in Section 332 provides for such integration of 

civil unmanned aircraft systems into our national airspace system as it is in the public’s interest 

to do so. Shick Web Design, LLC’s, light weight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of it’s light weight UAS is 

expressly contemplated by the Reform Act. It would like to operate it’s light weight UAS prior to 

the time period by which the Reform Act requires the FAA to promulgate rules governing such 

craft. Thereby, providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all real estate related UAS aerial video and photography. The 

Reform Act guides the Secretary in determining the types of UAS’s that may operate safely in 

our national airspace system. Considerations include: The weight, size, speed and overall 

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capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated 

areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of 

these items reflect in favor of an exemption for Shick Web Design, LLC. It’s UAS utilizes four (4) 

counter-rotating propellers for balance, control and stability. It’s UAS is equipped with GPS and 

auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55 

pound limit); including camera with gimbal.

Shick Web Design, LLC, considers safety as foremost with each flight. It’s small unmanned 

aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. 

For safety, stability and fear of financial loss it will not fly in winds exceeding 16 kph (10 mph). 

Built in safety systems include a GPS mode that allows it’s UAS to hover in place and return to 

launch location when radio controls are released. When pilot communication is lost UAS is 

designed slowly descend to point of take off. Shick Web Design, LLC does not operate it’s UAS 

near airports, Hospitals nor Police heliports, and does not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions and 

weather. PIC and Spotter are constantly on alert for any manned aircraft (Police/Medical 

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point 

should a manned aircraft approach it’s location or it suspects manned aircraft may approach 

near it’s location. UAS is capable of vertical and horizontal operations, and are flown only within 

the line of sight of the PIC. Utilizing battery power rather than combustible fuels, flights generally 

last between eight (8) to ten (10) minutes, with an altitude under one hundred fifty (150) feet. 

Shick Web Design, LLC, utilizes a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is eighteen (18) to twenty three (23) minutes as 

tested. It does not operate it’s UAS at or below manufacture recommend minimum charge levels 

for operation; preferring to remain well within a safe operating range to insure adequate 

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communication between radio control and UAS to eliminate potential for crash, loss of control or 

hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient 

safe level of operation. Shick Web Design, LLC does not believe in taking risk that may cause a 

crash, that could create hazard to the public/property/manned aircraft, and have no desire to 

lose an investment. Shick Web Design, LLC’s is extremely cautious when operating UAS/ultra 

light weight unmanned aircraft and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of our UAS it falls 

well within Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. Shick Web Design, 

LLC’s UAS, used in hobby flight, has a demonstrable safety record and does not pose any 

threat to the general public or national security.

IV. How Shick Web Design, LLC’s Request Will Benefit the Public As A Whole:

Aerial photography/videography for real estate marketing and web design enhancement has 

been around for a long time through manned fixed wing aircraft and helicopters. For small

budget real estate companies, small business owners and average homeowners, the expense 

of such aerial photography/videography is cost prohibitive. Only large companies and high end 

Realtors or luxury homeowners can afford to absorb such expense. Depriving non-luxury 

homeowners, lower budget Realtors and small businesses from a valuable marketing tool. Shick 

Web Design, LLC's UAS pose no threat since size and lack of combustible fuel alleviates any 

potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Granting Shick 

Web Design, LLC’s, exemption request furthers the public interest by enhancing real estate 

listings and website design. Our ultra light weight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of it’s ultra light weight UAS 

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crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain 

combustible fuel and can cause catastrophic devastation to the public. The public’s interest is 

furthered by minimizing ecological and crash threat by permitting aerial video/photo capture 

through the battery operated ultra light weight UAS’s. Permitting Shick Web Design, LLC, to 

immediately fly within national air space furthers economic growth. Granting this exemption 

request substantially furthers the economic impact for real estate companies and small 

businesses looking to enhance real estate listings, website design and marketing which will help 

stimulate the economy.

V. Reasons Why Shick Web Design, LLC’s Exemption Will Not Adversely Affect Safety

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing

Rule:

Shick Web Design, LLC’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated, permitting Shick Web Design, LLC to log more flight time in FAA controlled 

airspace, will allow it to contribute to the innovation and implementation of new and novel, as of 

yet undiscovered safety protocols that can be embraced by the NAR6, AAR7, and TAR8 for 

development in cooperation with the FAA. In addition, Shick Web Design, LLC submits the 

following representations of enhancements to current aerial videography and photography for 

real estate, website design and marketing: 

• Its UAS weighs less than 5 pounds complete with a small ultra light weight high quality 

integrated camera

• It only operates its UAS below 200 feet (well within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012)

• Its UAS only operates for 8-12 minutes per flight;

• It lands its UAS prior to manufacturer recommended minimum level of battery power;

• It pilots its UAS through remote control only by line of sight of PIC and with a Spotter;

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• Its UAS has GPS, a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost

• It actively analyzes flight data and other sources of information to constantly update and 

enhance safety protocols;

• It only operates in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas;

• It conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance;

• It always obtain all necessary permissions prior to operation; and,

• It has procedures in place to abort flights in the event of safety breaches or potential 

danger. 

Shick Web Design, LLC’s, safety protocols provide a level of safety equal to or exceeding

existing rules. It is important to note that absent the integration of commercial UAS into

our national airspace system, helicopters are the primary means of aerial video and

photography for real estate listings, website design and marketing. While the safety record of 

such helicopters is remarkably astounding, there have been incidents involving loss of life

as well as extensive property damage; it is far safer to operate a battery powered ultra

light weight UAS.

• First, the potential loss of life is diminished because UAS's carry no people on board and it 

only operates it’s UAS in specific areas away from mass populations.

• Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished.

• Third, the small size and extreme maneuverability of its UAS allow it to remotely pilot away 

from and avoid hazards quickly and safely.

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• Lastly, given its small size and weight, even when close enough to capture amazing 

images, its UAS need not be so close to the objects they are focused on through the 

technology and use of post editing software allowing pan and zoom.

Accordingly, its UAS has been experimentally operated for familiarization/competency

and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). 

The size, weight and enclosed operational area of Shick Web Design, LLC’s, UAS 

permits exemption from Part 21 because its UAS meets (and exceeds) an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration 

of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. Shick Web Design, LLC’s current and projected UAS's meet or 

exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

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manual delineating areas of where safety can be defined3. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as its UAS utilizes

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining any such required certifications 

and registrations by Shick Web Design, LLC.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Section 45.23(b) requires that on limited, restricted, or light-sport category aircraft,

markings indicating the aircraft category must be displayed “near each entrance to the 

cabin, cockpit, or pilot station.” Exemption from § 45.23(b) is warranted because Shick 

Web Design, LLC’s UAS has no entrance to the cabin, cockpit, or pilot station on which 

the required marking can be displayed. Shick Web Design, LLC proposes instead to 

display markings to the fullest extent possible in compliance with the location 

requirements of § 45.27(a) and the size requirements of § 45.29(f). Thus, Shick Web 

Design, LLC requests an exemption to § 45.23(b)’s marking requirements. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial

operations. Shick Web Design, LLC, can achieve an equivalent level of safety as 

achieved by current Regulations because its UAS does not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote control piloting 

skills. The risks attended to the operation of my UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing

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Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Shick Web Design, LLC to operate its UAS to meet and exceed current safety levels in 

relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Its UAS will never 

operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. 

Shick Web Design, LLC, will however operate its UAS in safe areas away from public 

and traffic, providing a level of safety at least equivalent to or below those in relation to 

minimum safe altitudes. Given the size, weight, maneuverability and speed of its UAS, 

an equivalent or higher level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] 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. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to Shick Web Design, LLC's, UAS. However, as a safety precaution it will 

inspect its UAS before and after each flight.

F. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 

21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of my UAS permits exemption from Part 21 because my, Shick Web 

Design, LLC’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform 

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement 

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

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legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 

prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate 

will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level 

of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions 

to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any 

damaged hardware. Therefore, an equivalent level of safety will be achieved. 

A Summary The FAA May Publish in the Federal Register:

In summary, Shick Web Design, LLC seeks an exemption from the following Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. 

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 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. § 91.409 (a ) (2); and, 14 C.F.R. §§ 

91.417 (a) & (b) to commercially operate Shick Web Design, LLC's small unmanned vehicle/

lightweight unmanned aircraft vehicle for aerial photography for use in real estate, website 

design and marketing operations, and to develop real estate listings and websites to enhance 

the experience of those searching for real estate and browsing commercial websites. Currently, 

area awareness and real estate aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting Shick 

Web Design, LLC’s, request for exemption will reduce current risk levels and thereby enhance 

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safety. Its UAS does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional real estate video and photographic aircraft with much less 

flight time. Further, it is operated at lower altitudes and in controlled airspace eliminating 

potential public risk flying to and from established air fields. There is no personnel on board 

Shick Web Design, LLC’s UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. Shick Web Design, LLC’s operation of its UAS, weighing less than 5 

pounds and traveling at lower speeds within limited areas will provide an equivalent level of 

safety as that achieved under current FARs. Accordingly, Shick Web Design, LLC respectfully 

request that the FAA grant it’s exemption requested and it is willing to cooperate in sharing 

information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Jeremy Shick, Owner

Shick Web Design, LLC

230 E. Park Ave, Suite 31

Lake Wales, FL 33853

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Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Appendix A

DJI Phantom 3

Product Image
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Appendix B

Shick Web Design, LLC

UAV Protocols and Controls
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Protocols and Controls

Aerial Photography and Videos

Safety for public on the ground as well as manned aircraft above is an essential and 

utmost consideration for aerial videos and photography. As such, safety protocols and 

controls must be implemented through pre-flight preparation and during flight.

Pre-Flight Protocol:

• Check batteries with voltage meter to insure fully charged and ready for use.

• Inspect batteries for damage or leakage that may affect proper operation.

• Inspect propellers for cracks, chips or damage that may cause sudden loss of 

propulsion or unmanageable/uncontrolled flight.

• Check weather forecasts for wind advisory or other conditions that my impact 

flight.

• Consult five (5) mile radius map for airport vicinity.

• Contact respective airport to advise of estimated flight time, estimated flight 

duration, estimated elevation of flight, and any other pertinent information.

• Inspect flight area for

• vicinity of public safety helipads/heliports

• vicinity of medical helipads/heliports

• vicinity of light poles

• vicinity or utility wires

• vicinity of trees

• flocks of birds that may cause interference and potential flight impact

• vicinity of any elevated obstructions that may pose potential flight hazard

• vicinity of roadways with moderate to heavy traffic that can be distracted

• public gatherings that may attract viewers

• optional point of control for best visual site of UAS while in flight

• Takeoff and landing

• inspect area for best and safest point of takeoff and landing

• if in a subdivision or area that is within 150 feet of a residential street, post 

warning sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain 

Back 150 Feet “

Flight Protocol:

• takeoff and land from same location

• remain alert to birds, sound or aircraft, curious public, and approaching vehicles

• do not allow anyone to engage in conversation or distract the remote control pilot

• restrict flight to minimal elevation sufficient to acquire desired results

• remained prepared for emergency landing at all times

• pay attention to flight time

• if possible set a timer as a safety alert

• land UAS and shut down propulsion immediately following landing

Post Flight:

a. disconnect battery to prevent accidental activation of propulsion system
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

b. secure UAS in a safe location

c. remove all warning signs from public access areas

Emergency or Suspected Hazard:

• Immediate land UAS at safest and closet ground location in the event

• manned aircraft is heard or seen in vicinity of flight

• there is a public gathering within established safety boundary wanting to 

observe flight

• pilot is being distracted from focusing on flight and safety

• sudden change in weather (wind bursts)

• sudden increase in vehicular traffic in vicinity of flight

• birds enter into proximity of flight

• any sudden unsafe event that can cause collision, distraction or interruption of 

control
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Appendix C

Shick Web Design, LLC

Safety/Flight Manual
Shick Web Design, LLC - Lake Wales, FL - Section 333 Exemption Petition 

Safety Flight Manual

Aerial Photography and Video

Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial 

videos and photography. Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative.

Date:____________________ Location:______________________________________

Pre-flight Inspection: ___ Yes ___No Comment: _______________________________

Proximity to airport: _________________ (see attached map pin pointing approximate location of flight)

Airport notified: ___ Yes __ No Date:_______________ Time: ______________

Phone Number: ___________________ Contact Name: ________________________

Nearest major intersection: _______________________________________________

Proximity to medium traffic road: ___________________________________________

Proximity to heavily traveled roadway road: __________________________________

Proximity to congested population: _________________________________________

Elements (circle) (circle) Comment

Weather Good Fair

Visibility Good Fair

Wind Speed Low Medium

Approx. Takeoff Time

Approx. Landing Time

Estimated Elevation

Safety Concerns:

Additional Comments:

Unedited flight video/photos available for FAA upon written request within 180 days of flight: __ Yes ___ No