SUNRISE {~ ENGINEERING 

~larch 2, 2016 

U.S. Department ofTransportation 

Docket ~Ianagement System 

1200 New Jersey A,-enue, SE 

Washington DC 20590 

Dear Sir or ~!adam, 

Pursuant to Section 333 of the FAA ~Iodernization and Reform Act of 2012, and 14 Cr:R Part 11, 

Sunrise Engineering, Inc., hereby applies for an exemption from the Federal A,·iation Regulations 

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

airspace regulated by the Federal A,-iation Administration (FAA). 

Sunrise Engineering, Inc., will haYe Richard B. Snyder J r.as the initial Pilot in Command (PIC) for the 

company. ~Ir. Snyder is a FAA licensed Private Pilot with a current Third Class Medical Certificate 

and a Professional Land Sun·cyor and Professional Engineer license in Utah, Arizona, and Nc,-ada. 

Sunrise Engineering, Inc., requests to usc 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 sun·eying and engineering sen·ices they prm·ide to both their 

general public and gonrnmcnt clients. 

(a) Contact Information: 

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

Sunrise Engineering, Inc. 

11 North 300 \\'est 

Washington, Utah 84780 

TEL 435.652.8450 

CELL 435.773.5889 

FAX 435.652.8416 

rsnyder@sunrisc-eng.com 

http: I I 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 

14 CFR 91.119 

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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; 

Smuise Engimering, Inc., is seeking the relief necessary to operate a UAS for commerrial 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. 

docs 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. 

Smuise Engineeting, Im~, reqmsts relieffrom Title 1.J. CFR 21 subpat1 H: Ainvottbiness Cettijicates 

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. 

Smm'se Engineering, fill~, requests relieffrom Title 1.J. CFR 4 5.23 (b): Marking of the Ain:raji 

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. Gi\·en 

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 Engineen'ng, In~ ., reqms/s relief from Title 1.J. CFR 61.113 (a) and (b): P1ivate Pilot Ptivileges 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. 

S11nrise Engineering, Itu~, reqmsts relieffrom Title 14 Cl-'""'R 91.7 (a): Civil Ain'l'aft Ainvorthiness 

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. 

Smuise Engineen·ng, Inc., reques!J relief from Title 1.J. CFR 91.9 (b) (2): Ci11il Aim-aft 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 relieffrom Title 1.J. CFR 91.103: Preflight Action 

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 

Sunnsc_Eng....l nc_-_Excmptmn Rukm~kmg dnc~ 
proposed operations limitations m Section (e) below that will meet what was intended by the 

regulation. 

Smuise Enginming, l11t"., requests relief fro!IJ Title 14 CFR 91.109: Flight !llJ"!mdioll 

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. 

Smmse E11gineeling, lm:, requests relief from Title 14 CFR 91.119 MimlmiiJJ 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. 

Smuise E11ginming, Im:, req/lests relief from Title f.l. CFR 91.121 AltimeterS etti11gs 

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. 

S umise Enginming, l11c., requt!sts relief jivm Title f.l. CFR 91.151 (a) 1:</tel Requirements for Flight i11 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. 

Sun lise Engineering, Inc., reql!ests reliefjivm Title 1..J. Cf<"""R 91.203 (a) and (b): Can)'ing CiJJil Ainraft Ce~tijications 

and RegistratiollJ 

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 

Smnise Engineen·ng, Im:, req/lests relief fivm Title 1..J. Cf'"""R 91...J.05 {tr), ..J.Ol (a) (!), 409 (a) (1) and (2), and ..J.1 7 

(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 D JI 

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 SUJYeying 

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 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 manem·erable aircraft to perform the same operations. 

Sunnsc_Eng_l nc_· _I ' ' cmptlon_Rulcmakmg Joo. 
(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. \'\!hen 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. l\laximum 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 ha,·e 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 

emergenc1es. 

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 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). 

SunnsL_I:ng_lnc_-_Excmptlon_Rulcmakmg Jr>cx 
These exemptions would allow Sunrise Engineering, Inc. to usc the DJI Inspire 1, DJI Phantom 3 

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

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

of the land surveying and engineering sen-ices 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://\nV\\ .dji.com/ product/inspirc-1/info#download" 

htrp://,vww.dji.com/product/phantom-3-pro/info#downloads 

http:// \v"\vw.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 usc these exemptions outside of the United 

States. 

If you ha,-e any questions after reYiewing our request, please contact Richard Snyder Jr., P.E., P.L.S., 

at the abO\-e noted contact information. 

Sincerely, 

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

Sunrise Engineering, Inc. 

!'unnse_Eng_lnc_-_ExLmpttOn_Rulemakmg.Jc>n