October 22, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave. SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590 

RE: Petition of Schneider Photographic LLC for Exemption Pursuant to 

Section 333 of the FAA Reform Act 

Petitioner’s Name and Address: 

Schneider Photographic LLC 

Owner: Michael Schneider

7702 Westwind Ln. Cincinnati, OH 45242-5008 

513-477-8682

michael@schneiderphotographic.com

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Schneider Photographic LLC LLC, operator of 

Small Unmanned Aircraft Systems(“sUASs”) equipped to conduct aerial 

photography, videography,and data collection hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUASs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited 2) predetermined and 3) controlled. 

The proposed exemption, if granted, would allow Schneider Photographic LLC 

to conduct commercial operations of sUASs meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333. 
Schneider Photographic LLC is a commercial photographic imaging company 

owned and operated by Michael Schneider. The purpose of Schneider 

Photographic LLC is to provide sUAS video and still image data to clients and to 

develop new and innovative sUAS flight applications using the sUAV’s cameras 

and sensors to provide time or cost savings for business, non-profit 

organizations and people in the United States and its territories. 

Michael Schneider has recently (October 2, 2015) completed flight training on 

the Lockheed Martin Indago quadcopter platform through Sinclair College in 

Dayton OH. He has been certified as a qualified pilot in command (PIC) for the 

Indago platform. Also completed was coursework on developing a COA for 

commercial civil applications. This course provides the background information 

needed to apply for the Certificate Of Authorization (COA) required to operate 

Unmanned Aerial Systems (UAS) in the National Airspace System as a public 

entity and reviews the options currently available for private operators. Due to 

the nature of the flight training and the COA Smart coursework through Sinclair 

College, he will bring a professional approach to aviation operations, 

maintenance and airspace integration to company operations. 

Schneider Photographic LLC intends to use the capabilities of sUASs to offer 

numerous services all based on aerial photography and videography flight 

profiles. Schneider Photographic LLC will then process the aerial data collected 

and deliver it to the client’s stated specifications. These specifications might 

include: 

- Aerial Photography/Videography

- Real Estate Photography/Videography

- Construction Site Inspections and Progress Monitoring

- Environmental Monitoring

- Terrain Mapping

- Precision Agriculture 

- Research Operations Carrying Environmental Data Collection Payloads 
Statutory Authority Section 333, titled “Special Rules for Certain Unmanned 

Aircraft Systems”, provides a mechanism for seeking expedited FAA 

authorization of safe civil Unmanned Aircraft Systems (UAS) operations in the 

National Airspace System (“NAS”). Section 333 states that the FAA “shall 

determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the (comprehensive) plan and 

rule making required by section 332(b)(1) of this Act or the guidance required 

by section 334 of this Act.” In section 332(b)(1), Congress has made it clear 

that Section 333 provides a mechanism for “expedited operation authorization” 

if several factors are met. Petitioner meets all requirements to permit FAA 

approval of commercial UAS operations. 

The name and address of the applicant are: 

Name: Schneider Photographic LLC 

Owner: Michael Schneider

Address: 7702 Westwind Ln. Cincinnati, OH 45242-5008 

Phone: 513-477-8682

Email: michael@schneiderphotographic.com

Exemptions are being requested from the following regulations: 

14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 61.3, 14 C.F.R. 91.151(a), 14 

C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 

C.F.R. 91.417(a) and (b). 
AIRCRAFT 

Schneider Photographic LLC will operate the 3D Robotics Solo sUAS. Aircraft 

weight is 3.3 pounds with battery and has a payload capacity of 1.1 pounds 

(500g). Solo is a commercially available, off-the-shelf sUAS. The sUAS will 

weigh no more than 4.4 pounds and will operate no faster than 55 knots 

groundspeed. This is a professionally engineered aircraft having the ability to 

hover, and move about its three axes simultaneously. Because of the sUAS’s 

specifications and flight characteristics, it poses no threat to national security. 

Compared to fixed wing and helicopters, Solo provides reduced personnel to 

operate and maintain, reduced noise levels, zero emissions into the 

environment, and enhanced safety protocols engineered into the aircraft 

system. 
Petitioner is requesting an exemption to enable Schneider Photographic LLC to 

operate a 3D Robotics Solo sUAS that is upgraded to latest version software on 

the sUAV, hand controller, and tablet that runs the Solo App. Solo’s onboard 

computers control navigation, attitude, and data communications in flight 

while sending real-time telemetry and video output. Control inputs are 

received over the 3DR Link secure Wi- Fi network. Solo is optimized for 

capturing aerial video using the GoPro Hero4 camera mounted in the 3 axis Solo 

gimbal. The UAS will not be operated outside parameters set forth in the 

manufacturer’s handbook. 

This sUAS has an adjustable built-in capability to set a maximum Above Ground 

Level (AGL) altitude for the flight. The aircraft’s Wi-Fi controller has a 1/2 mile 

line of sight maximum distance. If communication between the sUAS and the 

controller is lost (lost link), the sUAS will initiate a return to the takeoff point 

until it reacquires the signal. 

These factors are beneficial for, and in the best interest of, the public. 

Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

OPERATIONS 

Maximum Airspeed and Altitude 

The drone may not be operating at airspeeds greater than the maximum 

airspeeds recommended by the manufacturer (55 knots) and may not exceed 

400 feet AGL. 

Airport Restrictions 

Flight operation may not be within 5 nautical miles of an airport reference 

point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not listed in the ARP, the center of the airport symbol as denoted on 

the current FAA- published aeronautical chart, unless a letter of agreement 

with that airports management is obtained or otherwise permitted by a COA 

issued to the exemption holder. This letter of agreement with the airport 
management must be available to the Administrator or any law enforcement 

official upon request. 

Visibility and Clouds 

The aircraft may not be operated less than 500 feet below or 2000 feet 

horizontally from a cloud or when visibility is less than 3 statue mile from the 

PIC. 

Reserve Flight Time 

The pilot in command should not begin a flight unless (considering wind and 

forecast weather conditions) there is enough available battery power (or 

additional batteries) for the aircraft to conduct the intended operation. All 

Schneider Photographic LLC pilots/ operators will terminate flights when 

remaining battery power level reaches 20%, or 20 minutes flight time is 

reached, whichever comes first after takeoff. 

Visual Line of Sight 

The aircraft 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. 

Visual Observer 

All operations must utilize a visual observer (VO). The aircraft must be 

operated within the 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 required duties of the VO. 
Obstruction Clearances 

All flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless: 

 • Barriers or structures are present that sufficiently protect 

nonparticipating persons from the aircraft an/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 aircraft, 

flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons: and 

 • 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. 

Additional Operational Clarifications 

Aircraft may not operate over any persons not directly involved in the operation. 

Daylight-only operations (official sunrise to official sunset, local time). 

Must yield right-of-way to other aircraft, manned or unmanned. 

Must use visual observer (VO) on all commercial operations. 

First-person view camera not authorized for pilot use on commercial operations. 

Clients may view first person while pilot flys normally. 

No operations are allowed in Class A (18,000 feet & above) airspace. 
Operations in Class B, C, D and E airspace are allowed with the required ATC 

permission. 

Operations in Class G airspace are allowed without ATC permission 

No person may act as an operator or VO for more than one unmanned aircraft 

operation at one time. 

No careless or reckless operations. 

Operational preflight inspection required. 

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

EXEMPTIONS 

Schneider Photographic LLC requests exemptions from the following regulations 

as well as any additional regulations that may technically apply to the 

operation of the sUAV System: 14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 

61.3, 14 C.F.R. 91.151(a), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 

91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). 

AIRWORTHINESS CERTIFICATION (14 CFR Part 21) 

To ensure airworthiness, the Pilot in Command will perform a thorough 

preflight prior to any flight operation. The preflight inspection will be 

performed in accordance with the latest 3D Robotics Solo User Manual to 

ensure the aircraft is safe for flight and has the necessary battery power to 

accomplish the assigned flight. Any damage or malfunction that poses a hazard 

to flight will be documented and corrected prior to operation. The UAS carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within visual line of site of the operator. 

Operations under this exemption will be tightly controlled and monitored by 

the operator. 
The sUAS will be maintained in accordance with the manufacturer’s 

maintenance instructions. sUAS maintenance records will be kept on all lifelimited parts of each airframe, engine, rotors, controllers, and other 

appliances. Only manufacturer's authorized replacement parts will be used. 

By nature of these conditions, this UAS provides a greater degree of safety to 

the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14CFR Part 21. 

FLIGHT CREW TRAINING AND CERTIFICATIONS (14 CFR 61.3, 14 CFR 61.113) 

The aircraft does not carry passengers for compensation or hire. Copies of the 

PIC certificates and training records will be kept on file at Schneider 

Photographic LLC. Michael Schneider has recently (October 2, 2015) completed 

flight training on the Lockheed Martin Indago quadcopter platform through 

Sinclair College in Dayton OH. He has been certified as a qualified pilot in 

command (PIC) for the Indago platform. This training also supports the 3DR Solo 

quadcopter platform, as all quadcopters operate on the same flight 

characteristics. Also completed was coursework on developing a COA for 

commercial civil applications. This course provides the background information 

needed to apply for the Certificate Of Authorization (COA) required to operate 

Unmanned Aerial Systems (UAS) in the National Airspace System as a public 

entity and reviews the options currently available for private operators. 

Ongoing pilot training and certification through Sinclair College will be 

maintained. Also, pilots/operators will hold a valid driver's license or at least a 

third class medical certificate. Any research operation that is carrying a sensor, 

must have a commercial pilot as the pilot in command. The Schneider 

Photographic LLC pilot/ operator is in charge and controls the entire flight and 

will not transfer responsibility for operational control of the sUAS aircraft to 

any other person (unless the flight is specifically for training purposes and not 

for hire). 

Prior to operations for hire, the PIC must have accumulated and logged a 

minimum of 10 hours of Solo sUAS time and have at least 30 hours total flight 

time. Designation as a Schneider Photographic LLC pilot/operator will remain 
on file. The PIC is responsible for the safe and efficient operation of the 

aircraft. Specific duties include all preflight preparation and inspection, in 

flight operation, post flight requirements, and all procedures including but not 

limited to: 

• Impact of Weather Conditions

• Risk Management

• Operational Flight Safety

• Post Flight Data/Imagery Transfers 

For Visual Observers, completion of the online exam is required before field 

operations. The curriculum serves as an information baseline to ensure visual 

observers are familiar with potential Schneider Photographic LLC operations 

and can be effective in field flight operations. The Visual Observer will possess 

a current valid driver’s license issued in the United States. 

FUEL REQUIREMENTS (14 CFR 91.151) 

The sUAS is powered by a battery, which provides up to 20 minutes of powered 

flight when a camera payload is utilized. Because of the absence of flammable 

operating fluids, the sUAS does not pose the same level of risk as a 

conventional aircraft. All Schneider Photographic LLC pilots/ operators will 

terminate flights when remaining battery power level reaches 20%, or 20 

minutes flight time is reached, whichever comes first after takeoff. 

Since no flights conducted by Schneider Photographic LLC will require 

traditional petroleum based fuel, and those flights will be for less than 25 

minutes, Schneider Photographic LLC requests relief from 14CFR 91.151. 

MAINTENANCE (91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b)) 

Schneider Photographic LLC will keep maintenance records on all airframes 

that the company owns. Aircraft maintenance records must include the current 

status of the life-limited parts of each airframe, engine, rotors, and 

appliances. 
Each aircraft operated under this exemption must comply with all 

manufacturer safety bulletins. 

Schneider Photographic LLC will track all life limited components mentioned 

above. When engines, rotors, controllers, or other drone equipment is 

replaced, maintenance records must accurately reflect the changes and track 

individual and total times. Any aircraft that has undergone maintenance or 

alterations that affect the aircraft 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 will be conducted in such 

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

All maintenance will be done is accordance with 3D Robotics guidelines. 

Schneider Photographic LLC must follow the 3D Robotics maintenance, 

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

and aircraft components. 

CONCLUSION 

Schneider Photographic LLC plans to use the capabilities of sUASs to offer 

numerous services all based on standard aerial photography and videography 

flight profiles. Schneider Photographic LLC will then process the aerial data 

collected and deliver it to the client’s specific specifications. 

With operation being directed by a trained and certified operator, Schneider 

Photographic LLC understands and intends to comply with every applicable 

regulation to the operation of sUASin the NAS. Each exemption for which we 

seek relief, will allow for safe and efficient commercial operations that are far 

superior to those conducted by manned aircraft. 

Schneider Photographic LLC proposed exemptions and operational limitations 

are very closely aligned with other exemptions already granted. Schneider 

Photographic LLC should be permitted to conduct small UAS operations in 
accordance with its manuals and all other operating parameters deemed 

necessary and appropriate by the FAA. 

Please don’t hesitate to contact me at your convenience with any questions 

regarding this request. 

Thank You,

Michael Schneider, Owner, Schneider Photographic LLC