Spyker Aerial Services, LLC

16422 Rhinefield Street

Tomball, TX. 77377

September 11, 2015

U.S. Department of Transportation,

Docket Management Systems,

1200 New Jersey Avenue SE,

Washington, DC 20590

RE: Section 333 Petition for an exemption from parts 21; 43; 61; 67; §§ 45.11; 45.21; 45.22(d); 45.23(b);

47.16; 91.9(b) and (c); 91.103; 91.109; 91.119; 91.121; 91.151; 91.203(a) and (b); 91.205(b); 91.215, 91.319; 

91.405; 91.407; 91.409; 91.413; and 91.417 of Title 14, Code of Federal Regulations

Electronic Submittal – Via FDMS Website

Dear Sir or Madam,

This letter serves as a petition for exemption from specific rules contained in Title 14 of the Code of Federal 

Regulations (14CFR), with regards to operation of a small, unmanned aircraft (sUAS) to allow Spyker Aerial 

Services, LLC commercial operation in the industries listed below.

The requested exemption would permit Spyker Aerial Services, LLC to pursue its commercial interests in providing 

services to clients using small advanced sUAS with a focus on the following areas of interest;

 Oil and Gas Infrastructure and structural Monitoring and Inspection Services (onshore and offshore)

 Aerial Surveying

 Industrial Facility Inspections

 Conservation Reviews

 General Video and Photography assignments

 Inspection of Wind and Solar power generation

 Inspection of Telecom structures

 Amusement park rides

 Search and Rescue Operations in cases of emergency or natural disaster only when the local authorities or 

government has requested

 Spill response for Oil companies to provide accurate data of incident in real time

 Real Estate and business marketing photography and videography

 Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority

In addition to the waiver authority, provided in Section 333 of the Modernization Act, the FAA may grant an 

exemption under 49 U.S.C. Section 44701(f) if it has determined that such an exemption is in the public interest.

Each commercial interest has an inherent risk to associated tasks performed by personnel. For example;

Wind power generation – Individuals have to rappel each blade to visually inspect. This risk of equipment failure is 

removed with a sUAS providing the visual inspection.

Oil and Gas – Individuals may have to climb high towers and or equipment to do visual inspections. If conducted 

solo and the individual were to fall or have a medical emergency, it would be difficult to for Emergency Medical 

Service personnel to respond. With our focus on safety, we intend to implement all of the Operational Limitations,

outline in Proposed Part 107 of the Notice of Proposed Rulemaking (NPRM), at a minimum. These limitations will 

ensure the same level of safety offered by the rules for which the exemption is sought. By adhering to the 
Operational Limitations, the proposed sUAS operation will minimize risk to the NAS, and to persons and property 

on the ground.

The Regulations we are requesting exemption from;

21; 43; 61; 67; §§ 45.11; 45.21; 45.22(d); 45.23(b); 47.16; 91.9(b) and (c); 91.103; 91.109; 91.119; 91.121; 91.151; 

91.203(a) and (b); 91.205(b); 91.215, 91.319; 91.405; 91.407; 91.409; 91.413; and 91.417 of Title 14, Code of 

Federal Regulations (14 CFR). 

An exemption would allow Spyker Aerial Services, LLC to broadly evaluate assets and operations with sUAS, 

resulting in a safer and more efficient inspection and monitoring scheme in the resource industries. The grant of an 

exemption is consistent with Congress’ intent, reflected in Section 333 of the FA Modernization and Reform Act of 

2012, that safe systems be permitted in the national airspace prior to the issuance of final regulations governing 

general use of these items.

Spyker Aerial Services, LLC shall conduct operations with one of the following sUAS:

DJI Inspire 1

DJI Phantom Professional

DJI S-1000

Furthermore, our commitment to safety is foremost in our operations:

• Personnel will act as an Observer for 20 assignments and will have 10 hours of flight time prior to being given 

assignments.

• Each assignment will be accompanied by a pre-flight checklist (See Attached).

• Operators shall wear a highly visible vest with wording on the back that reads;

“Pilot”

Do not disturb

While in flight

In Conclusion, due to their light weight, sUAS generally pose a significantly low risk to people and the property on 

the ground. The size, weight, speed, and capability of the DJI product line will not create a hazard to the users of 

the NAS or the general public, nor will it pose a threat to national security. Granting this request for exemption 

would not adversely affect safety, rather it would give opportunities to reduce risk to the personnel of the 

industries serviced.

The sUAS’s listed in this request will be registered with the FAA. Upon award of exemption, a “blanket” 200-foot 

Certification of Waiver or Authorization would be requested.

Sincerely,

Jose M. Soliz 

Owner, Spyker Aerial Services, LLC 

jose.soliz@spykerusa.com