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 333 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 manufactured 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 Certificate 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 PCbased ground control station, used as for mapping and agricultural management 

processes. The C-Astral 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 Operator training. S-P Enterprise would like the opportunity to 

utilize model aircraft flying fields for instruction, agricultural management, aerial 

surveying, real estate surveying, construction surveying, and aerial video photography. 

Many of these fields 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 indepth 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 field with a Pilot in Command (PIC) and a groundbased 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 operational 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 private 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 providing 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 part 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 CFR 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 clarification. 

Sincerely

Frank	Staine-Pyne

Owner

S-P	Enterprise