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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) C** **ontact I** **nformation :**  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 91.1090900006481e9b6f8

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) E** **xtent 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 S ection (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 relieffrom 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 Action0900006481e9b6f8

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 CF R 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) **R easons 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

. The se services were conducted using conventional aircraft. The cost for these services can make it unaf fordable for many clients

. These flight operations also had many other hurdles including flight alt itudes , 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 aerial0900006481e9b6f8

photography, aerial videography and aerial inspections flown more often. UAS are also more environmentally friendly then traditional aircraft because they don’t run on fo ssil 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) R** **easons why**  **granting the**  **exemption would**  **not adversely**  **affect safety**  **and how**  **the exemption would provide a le** **vel 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 communicat ions 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) S** **ummary 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 CFR0900006481e9b6f8

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 Inform** **ation**
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.