U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir or Madam: Pursuant to Section 33 3 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, S

- P Enterprise , seeks an exempt ion from Federal Aviation Regulations (“FARs”) detailed below for the C

- Astral Bramor gEO , SenseFly eBee and AeroM Unmanned Aircraft System ma nufactured by 3D Robotics of California. Except for the aircraft, this application is similar to a previous application to which you granted Exemption 11136 on 5 January 2015. The requested exemption would support an application for a commercial Certific ate of Authorization to use the system to support aerial surveying and mapping as well as UAS Operator training. The AeroM system consists of a lightweight (6.8 lb) battery operated aircraft, a PC

- based ground control station with associated communications equipment and a manual radio controller capable of linking to a second set of instructor controls. The SenseFly eBee is a lightweight (700 g) battery operated aircraft that also uses a PC

based ground control station, used as for mapping and agricultural management processes. The C

- A s tral Bramor gEO is suited for surveying and remote sensing applications in areas where replacement of the standard surveying methods is needed. It is capable of measuring precise results down to 1 cm with a Ground Sampling Distance that starts at 0 ,9 c

. The aircraft are capable of carrying multiple payloads making it an ideal platform for initial UAS Op erator training. S

- P Enterprise would like the opportunity to utilize model aircraft flying fields for instruction
, agricultural man a gement, aerial surveying, real estate surveying , construction surveying, and aerial video photography

. Many of these fi elds operate safely within 2 NM of airports with de

- confliction procedures coordinated with airport management. By adhering to the rules established by these clubs, we feel we can safely train UAS pilots side

- by

- side with model aircraft hobbyists in close proximity to airports. By approving these exemptions, the FAA will create the opportunity to produce professionally trained UAS Operators with both in

depth general knowledge and hands

- on operational experience. The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground

- based Visual Observer (VO) in accordance with FAA Order 8900.1, vol. 16 "Unmanned Aircraft Systems" with the following additional restrictions:

The aircraft will be operated in the fiel d with a Pilot in Command (PIC) and a ground

based Visual Observer (VO) with the following restrictions:

- All operations that occur in Class B, C, D and E airspace will comply with responsible ATC agency restrictions- Without an approved memorandum of understanding with airport management, the aircraft will not be operated within: a) 5 nautical miles (NM) from an airport having an operational control tower; or b) 3 NM from an airport having a published instrument flight procedure, but not having an ope rational control tower; or c) 2 NM from an airport not having a published instrument flight procedure or an operational control tower; or d) 2 NM from a heliport

- All operations will occur at no more than 500' AGL

- Operations will be operated over pri vate or controlled access property with the permission of the land owner or controller

- All required permits will be obtained from state and local government prior to operation

- The aircraft will not be operated over congested areas

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC or VO at all times

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- PIC will file a NOTAM provid ing radial/DME, radius, and a date/time group for each operation

- The PIC will hold a Private Pilot's Certificate and current Class III medical

- The PIC will perform maintenance on the system and will complete a course of maintenance instruction as par t of their initial training. We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation under the guidelines established by the FAA can have confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the same mission. The name and contact information of the applicant are:

S

- P Enterprise Frank Staine

- Pyne Phone: 501

- 773

- 1270 Email: fesp21@gmail.com

The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401

- 91.417)

- 14 C FR 91.103(b)We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarificat i on.

Sincerely

Frank	Staine

- Pyne Owner S

- P	Enterprise