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March 2, 2016

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Avenue, SE

Washington DC 20590

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and 14 CFR Part 11, 

Sunrise Engineering, Inc., hereby applies for an exemption from the Federal Aviation Regulations 

(FAR) listed below to allow operation of a small Unmanned Aircraft System (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA).

Sunrise Engineering, Inc., will have Richard B. Snyder Jr.as the initial Pilot in Command (PIC) for 

the company. Mr. Snyder is a FAA licensed Private Pilot with a current Third Class Medical 

Certificate and a Professional Land Surveyor and Professional Engineer license in Utah, Arizona, 

and Nevada.

Sunrise Engineering, Inc., requests to use the DJI Inspire 1, DJI Phantom 3 Professional, or DJI 

Phantom 4 UAS to conduct aerial photography, aerial videography, aerial inspections, and other 

UAS flight operations as part of the land surveying and engineering services they provide to both 

their general public and government clients.

(a) Contact Information:

Richard B. Snyder Jr., P.E., P.L.S.

Sunrise Engineering, Inc.

11 North 300 West

Washington, Utah 84780

TEL 435.652.8450

CELL 435.773.5889

FAX 435.652.8416

rsnyder@sunrise-eng.com

http://www.sunrise-eng.com

(b) Specific sections of Title 14 of the Code of Federal Regulations (CFR) from which 

exemption is requested:

14 CFR 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) and (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109
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14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (1) and (2)

14 CFR 91.417 (a) and (b)

(c) Extent of relief and the reason for relief;

Sunrise Engineering, Inc., is seeking the relief necessary to operate a UAS for commercial proposes. The extent 

needed would include the regulations listed below along with any other regulations needed to 

operate a UAS for commercial purposes in airspace regulated by the FAA. While Sunrise 

Engineering, Inc. does not anticipate frequent operations within five miles of an airport we do 

request a way to facilitate such operations without needing to request a separate exemptions for each 

operation.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 21 subpart H: Airworthiness Certificates

Sunrise Engineering, Inc. will operate the UAS in a controlled and safe manner and at slow speed. 

Based on the proposed operations limitations in Section (e) below the UAS safety can be 

maintained.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 45.23 (b): Marking of the Aircraft

It is not possible to comply with this regulation as there is no cockpit or cabin to place markings.

Relief is also requested regarding marking the aircraft for the purpose of identification in the air. 

Given the size of the UAS, Sunrise Engineering, Inc. will try our best to mark the aircraft for the 

purposes of identification and maintain documents with the PIC on the ground to try and meet the 

extent of this regulation.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 61.113 (a) and (b): Private Pilot Privileges and 

Limitations/Pilot in Command.

UAS this size do not carry pilots or passengers. This greatly reduces the risk from catastrophic 

failure and damage compared to manned aircraft with passengers. Sunrise Engineering, Inc. will 

maintain an equivalent level of safety by requiring private pilot qualifications for PIC operation. 

Relief is requested in reference to the need for a commercial pilot certificate.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.7 (a): Civil Aircraft Airworthiness

This regulation would not be applicable if relief is granted from 14 CFR 21 subpart H:

Airworthiness Certificate request above. Applicable documents will be available for inspection from 

the PIC on the ground.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual

Size and payload capacity restrict the possibility of compliance with this regulation. Applicable 

documents will be available for inspection from the PIC on the ground.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.103: Preflight Action
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DJI, the manufacturer of the proposed UAS that would be used, does not have approved takeoff 

and landing distance data. Sunrise Engineering, Inc. will operate in daylight hours under Visual 

Flight Rules (VFR) conditions. Relief from preflight action is requested because safety will be 

provided from the proposed operations limitations in Section (e) below that will meet what was 

intended by the regulation.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.109: Flight Instruction

The UAS is a remotely piloted aircraft and does not have fully functional dual controls. Flight 

control is accomplished through the use of a remote controller that communicates with the aircraft 

via radio communications. 

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.119 Minimum Safe Altitudes

Sunrise Engineering, Inc. intends to operate below the altitudes of 500 feet above ground level 

(AGL) referenced by this regulation. In accordance with current UAS guidelines we request 

operations below 400 feet AGL.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.121 Altimeter Settings

The UAS Sunrise Engineering, Inc. intends to operate are not equipped with a barometric altimeter, 

but instead use GPS for altitude control. Relief is requested to allow the built-in UAS technology to 

be used to maintain the correct AGL altitude.

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.151(a) Fuel Requirements for Flight in VFR 

Conditions

The intended operations will be around 15 minutes, which does not comply with the minimum 30 

minutes of extra fuel for planned VFR flight. The UAS manufacturer has fail safe procedures and 

features built into the systems. Sunrise Engineering, Inc. will cease all operations at 25% battery 

remaining to allow the UAS to return to the PIC on the ground. 

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.203 (a) and (b): Carrying Civil Aircraft 

Certifications and Registrations

This regulation would not be applicable if relief is granted from 14 CFR 21 subpart H: 

Airworthiness Certificate request above. Applicable documents will be available for inspection from 

the PIC on the ground

Sunrise Engineering, Inc., requests relief from Title 14 CFR 91.405 (a), 407 (a) (l), 409 (a) (1) and (2), and 417 

(a) and (b): Maintenance Inspections

This regulation would not be applicable if relief is granted from 14 CFR 21 subpart H: 

Airworthiness Certificate request above. Sunrise Engineering, Inc. will follow the Safety Guidelines 

for the DJI Inspire 1, DJI Phantom 3 Professional, or DJI Phantom 4.

(d) Reasons why granting the request would be in the public interest and benefit the public;

Aerial photography, aerial videography and aerial inspections have been used in the land surveying 

and engineering industries for a long time. These services were conducted using conventional 

aircraft. The cost for these services can make it unaffordable for many clients. These flight 

operations also had many other hurdles including flight altitudes, proximately to landing strips, 

duration of flights, weather and cloud levels. Using UAS to provide these services will allow flights

to happen cheaper and closer to the ground resulting in more affordable and higher quality aerial 
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photography, aerial videography and aerial inspections flown more often. UAS are also more 

environmentally friendly then traditional aircraft because they don’t run on fossil fuels and they

produce less noise. UAS also add another level of safety by not requiring larger and less 

maneuverable aircraft to perform the same operations.

(e) Reasons why granting the exemption would not adversely affect safety and how the 

exemption would provide a level of safety at least equal to the existing rule;

Following are limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under this exemption. These proposed operation limitations should provide 

an equivalent or higher level of safety than using conventional aircraft to conduct similar operations.

1. The UAS pilot will be a designated Pilot in Command (PIC) and hold a FAA Private Pilot 

license, current Third Class Medical Certificate, and a valid state driver's license.

2. Flights will be operated within visual line of sight (VLOS) of the PIC.

3. Minimum crew for each operation will consist of the UAS PIC, the Visual Observer (VO) 

and may include but not be limited to a Camera Operator.

4. A briefing will be performed regarding the planned UAS operations prior to each day's flight 

consisting of all the days' production activities.

5. The PIC and VO will have been trained in operation of UAS and receive up-to-date

information for the particular UAS to be operated.

6. The PIC and VO will be able to communicate by voice, radio, and/or cell phone at all times.

7. If another operator is needed the new operator will be qualified with the necessary skills to 

be PIC, possess a FAA Private Pilot license or other appropriate license, current Third Class 

Medical Certificate or other appropriate certificate, and a valid state driver's license.

8. When operating within five nautical miles of an airport Sunrise Engineering, Inc. with get 

the approval of the airport management prior to operations.

9. The UAS will weigh less than 55 lbs.

10. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour).

11. The UAS would be operated in daylight hours under Visual Flight Rules (VFR).

12. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL).

13. Maximum flight time for each operational flight will be 15 minutes. Flights will be 

terminated at 25% battery power reserve.

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

return to a pre-determined location within a designated location and land autonomously.

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

or emergencies.

16. The Safety Guidelines for the DJI Inspire 1, DJI Phantom 3 Professional, or DJI Phantom 4 

will be followed by the PIC.

17. Sunrise Engineering, Inc. will conduct pre-flight inspections, maintenance, and repairs as 

need to insure that the UAS is keep in working order.

(f) Summary for publishing in the FEDERAL REGISTER

Pursuant to Section 333 and Title 14 Code of Federal Regulations Part 11, Sunrise Engineering, Inc., 

hereby applies for an exemption and specific relief from the following Federal Aviation Regulations:

14 CFR 21 subpart H; 14 CFR 45.23 (b); 14 CFR 61.113 (a) and (b); 14 CFR 91.7 (a); 14 CFR 91.9 

(b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a);14 CFR 
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91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) and (2); and 14 

CFR 91.417 (a) and (b).

These exemptions would allow Sunrise Engineering, Inc. to use the DJI Inspire 1, DJI Phantom 3 

Professional, or DJI Phantom 4 Unmanned Aircraft System to conduct aerial photography, aerial 

videography, aerial inspections, and other small Unmanned Aircraft System flight operations as part 

of the land surveying and engineering services they provide to both the general public and 

government.

(g) Additional Information

Links to DJI Inspire 1, DJI Phantom 3 Professional, or DJI Phantom 4 UAS documents and 

manuals

http://www.dji.com/product/inspire-1/info#downloads

http://www.dji.com/product/phantom-3-pro/info#downloads

http://www.dji.com/product/phantom-4/info#downloads

(h) Request to exercise the privileges of the Exemption outside the United States

At this time Sunrise Engineering, Inc. does not request to use these exemptions outside of the 

United States.

If you have any questions after reviewing our request, please contact Richard Snyder Jr., P.E., P.L.S.,

at the above noted contact information.

Sincerely, 

Richard B. Snyder Jr., P.E., P.L.S.

Sunrise Engineering, Inc.