U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E.

West Building Ground Floor, Room W12-140

Washington, DC 20590

Docket ID: FAA-2015

Petition for Exemption under Section 333 of the FAA Modernization and Reform 

Act and Part 11.81 of the Federal Aviation Regulations

July 23, 2015

Petitioner:

SPH Solutions, LLC

Jim Donlan, President

12780 Lime Kiln Road

Highland, MD 20777

Tel: 410. 952. 1363

Email: jim.donlan@sph-solutions-llc.com

Website: www.sph-solutions-llc.com

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

11.81, SPH, LLC, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow

commercial operation of its small, unmanned aircraft for photogrammetry, surveying, search and rescue, 

inspection, and analyses. All operations shall be conducted within and under the conditions and limitations

outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached 

operator’smanuals.

SPH is a Service Disabled Veteran Owned Small Business (SDVOSB) certified by the U.S. Department of Veteran 

Affairs is an industry leading technical services company that delivers design-driven turnkey solutions to the 

wireless communications, construction, photographic, engineering, real estate and energy sectors, SPH’s mission is 

to focus on its clients’ business objectives to deliver high quality, cost effective sUAS solutions that exceed their 

expectations.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i.

ii.

91.103(b)(2)

91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417
2. Relief sought:

a. SPH Solutions, LLC wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial

purposes to include (but not be limited to) photogrammetry, mapping, surveying, industrial 

inspections andanalyses, search and rescue.

This relief is sought because law currently prohibits commercial use of sUASunless

performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than

55 pounds including payload and energy sources:

i. 3DR Solo (see http://3drobotics.com/solo-drone/)

ii. Matrice (see http://dev.dji.com/en/products/flying-platforms/matrice-100)

iii. DJI Phantom 2 (see http://www.dji.com/product/phantom-2)

iv. DJI Phantom 3 (see http://www.dji.com/product/phantom-3)

v. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use

of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g.,

infrastructure inspections) and due to other dangerous activities that can be

avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and

the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions

from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part

45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All

repair and maintenance work will be conducted or approved by qualified personnel, and will 

require a test flight after such work.Records of all maintenance and repair work will be kept in a 

maintenance log for each aircraft.

c. All flight operations will be conducted by PIC who will maintain line of sight with the aircraft at 

all times during the flight, andwho will remain stationary on the ground during the flight

operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. Relief from certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, is requested by SPH to the 

extent necessary to allow a Pilot in Command (PIC) holding an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the sUAS in a 

manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

2. A Third Class medical certificate issued under 14 CFR 67.

3. A bi-annual flight review under 14 CFR 61.56

4. Successful completion of a UAS knowledge test in a specified form.

5. At least 3 hours of flight experience and 3 takeoffs and landings in make and

model being flown in the prior 90 days. Such cycles and hours may be

gained during flights under this exemption if a safe distance is maintained

from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer as necessary.

iii. A Sensor Operator as necessary.
d. All flight operations will be conducted in accordance with valid Certificates of Authorization.

e. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

SPH Flight Operations and Procedures Manual (FOPM) and Aircraft FlightManuals

(AFM) which include lost communication and other emergency and safety

procedures.

ii. Conducted in VMC conditions during daylight hours.

iii. PIC and VO (if required) will maintain VLOS at all times.

iv. Pre-flight inspections (including ground control station, if any) and safety risk

assessments will be conducted prior to each flight.

v. Flight altitudes will remain below 400 feet above ground level.

vi. Flight ground speeds will not exceed 50 knots.

vii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, ortake

place within 5 nautical miles of an airport without COA and or approval from

Control Tower.

viii. Not be made near persons as required in 14 CFR 91.119 and not over persons on the

ground without their prior permission.

ix. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

x. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes,whichever

occurs first.

xi. Any incidents will be reported within 24 hours of occurrence.

xii. SPH, LLC will maintain liability insurance of at least $1,000,000 issued by a major

aviation insurance underwriter.

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined

and tested lost link procedures.

Please advise us of any additional information or changes that may berequired.

Sincerely, Jim Donlan, Col USMC (ret)

President, SPH Solutions, LLC