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 PayloadsStatutory 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 i nterest 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 airportmanagement 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’smaintenance 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 remainon 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 inaccordance 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