August 27, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. 

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 the Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), 

Uproarmedia, LLC (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks an 

exemption from the Federal Aviation Regulations ("FARs") to allow for commercial operation for aerial 

photography, aerial videography, precision agriculture, structure inspections, surveying, UAS training, 

and volunteer search and rescue missions.

APPLICANT INFORMATION

Uproarmedia, LLC

PO Box 915

2816 Welhouse Dr

Kaukauna, WI 54130

jpietsch@uproarmedia.com

(920) 358-0877

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

EXTENT OF RELIEF REQUESTED, AND WHY

14 CFR Part 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft 
to be utilized, we request exception. In the restricted environment and under the conditions proposed 

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without said restrictions.

14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to market certain 

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions 

would need to be smaller than required minimum. Understanding the importance of lettering I will mark 

my UAS with the largest possible letters by placing the word "Experimental" or assigned number or 

name, based on request/ruling of FAA, on UAS fuselage. The equivalent level of safety will be provided 

by having the UAS marked on its fuselage as required.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check list prior to each flight an equivalent level of safety will be 

provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is 

no room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will 

be maintained by keeping the flight manual at ground control point where the pilot will have immediate 

access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. 

Normal flight procedures including but not limited to; reviewing weather, flight battery requirement, 

landing and takeoff distances. An equivalent level of safety will be provided by preflight protocol to 

properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, 

and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

We can achieve an equivalent level of safety as achieved by current regulations because our UASs does 

not carry pilot or passenger. While helpful, a pilots' license will not ensure remote control piloting skills.

14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe 

an exemption may be needed. An equivalent level of safety is achieve by the operator receiving live 

flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS 

altitude indicator.
14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately 

manage such documents. An equivalent level of safety will be achieved by keeping these documents; to 

the extent they are applicable to the UAS, at the ground control point where pilot has immediate access 

to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not apply 

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each flight.

Uproarmedia, LLC is seeking relief from all FARs above preventing applicant from conducting commercial 

flights listed within this petition, operated at levels less than 400’ AGL, at a speed less than 50 mph, and 

with a maximum flight time of 30 minutes. 

UAS INFORMATION

Tarot 680Pro

The Tarot 680Pro is a hex copter outfitted with a 3DRobotics Pixhawk flight controller. This UAS weight 

varies depending on which camera is mounted, however it never exceeds 10 pounds. The maximum 

speed is 33.5 mph. Due to the requirements of the flight, this UAS will not be flown at this speed. It also 

has a maximum flight time of less than 30 minutes.

3DRobotics Solo

The 3DRobotics Solo is a quad copter outfitted with a 3DRobotics Pixhawk 2 flight controller. This Solo’s 

weight is 3.3 pounds and it is capable of a maximum speed of 55 mph. Like the 680pro, the flights that 

will be conducted with this UAS will require it to be flown much slower than its maximum speed.

Please review the attached documents for further details.

SAFETY

These limitations and conditions to which Uproarmedia, LLC agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 55lbs.

2. Flights will be operated within line of sight of a PIC and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400’ AGL.

5. Minimum crew for each operation will consist of the PIC, and the Visual Observer.

6. UAS Pilot will be Pilot in Command (PIC). If the PIC deems another operator to be qualified with 

the necessary skills to be the operator, that person can also be designated as operator provided

they have a minimum of 20 hours of flight time with the UAS.

7. Flights will be operated at a lateral distance of at least 50’ from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation.
8. A briefing will be conducted in regard to the planned UAS operations prior to each flight activity. 

It will be mandatory that all personnel involved with the operational duties of the flight be 

present for this briefing.

9. PIC and observer will have been trained in operation of UAS generally and received up-to-date

information on the particular UAS to be operated.

10. Observer and PIC will at all times be able to communicate by voice, radio, and/or text. 

11. Written and/or oral permission from the relevant property holders or property representatives 

will be obtained. 

12. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to 

return to a pre-determined location and land autonomously. 

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

PUBLIC INTEREST

I believe the increased safety achieved by replacing manned aircraft carrying crew and flammable fuel 

with small UASs carrying no passengers, crew, or flammable fuel under the specific guidelines and 

procedures proposed in this petition gives the FAA good cause to find that the UAS operations enabled 

by this petition are in the public interest. Furthermore, by replacing the manned aircraft traditionally 

used for the kinds of operations proposed in this petition, with small UAS, we will be able to provide 

aerial operations services at a greatly reduced cost, making these kinds of services available to a larger 

range of businesses and consumers, thereby increasing the utilization of aerial operations and 

benefitting the economy as a whole. Granting Uproarmedia, LLC an exemption to operate its UASs

commercially furthers economic growth and public safety, providing the FAA good cause to grant this 

petition.

PRIVACY

All flights will occur over private, controlled or approved property with the property representative or 

owner’s prior consent and knowledge. Filming will be of people who have also consented to being

filmed or otherwise have agreed to be in the area where filming will take place.

ATTACHED DOCUMENTS

1. 3DR_Pixhawk_User_Manual.pdf

2. 3DR_Solo_Preflight_Checklist.pdf

3. 3DR_Solo_User_Manual.pdf

Thank you for your time and consideration.

Sincerely,

Jason Pietsch

Uproarmedia, LLC