# SUNRISE**{~** ENGINEERING**~larch** 2, 2016 U.S. Department ofTransportation Docket**~Ianagement** System 1200 NewJersey 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 ofa small Unmanned Aircraft System (UAS) commercially in airspace regulated by the Federal A,-iation Administration ( FAA). Sunrise Engineering, Inc., will haYe Richard B. SnyderJr.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
. SnyderJr., 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 rsny der@ sunrisc

-eng.com http: 

### I Iwww.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

!1**NO ~'~Wf:~--W~'Sffil~ft'?fu~u~~~**  ·TEL 435.652.8450 · FAX 435.652.8416 WWW.Sltllrise-eng

.com14 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 ofreliefand the reason for relief; 

### Smuise Engimering, Inc., is seeking the reliefnecessary to operate a UASfor commerrialproposes. 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 ofan 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

### 45.23 (b): Marking 

## of theAin:raji It is not possible to comply with this regulation as there is no cockpit or cabin to place markings
. Reliefis also requested regarding marking the aircraft for the purpose ofidentification 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 ofsafety by requiring private pilot qualifications for PIC operation. Reliefis requested in reference to the need for a commercial pilot certificate. 

### S11nrise Engineering,**Itu~,** 

### reqmsts relieffrom Title 14 

### Cl-'""'R 91.7 

### (a): CivilAin'l'aftAinvorthiness This regulation would not be applicable ifreliefis 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): 

### Ci11ilAim-aft FlightManual 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: 

### PreflightAction DJI, the manufacturer ofthe proposed UAS that would be used, does not have approved takeoffand landing distance data. Sunrise Engineering, Inc
.will operate in daylight hours underVisual Flight Rules (VFR) conditions. Relief from preflight action is requested because safety will be provided from the

Sunnsc_Eng....lnc_-**_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 ofa remote controller that communicates with the aircraft via radio communications. 

### Smmse E11gineeling, lm:, requests relief from Title 14 CFR 91.119 MimlmiiJJ SafeAltitudes Sunrise Engineering, Inc
. intends to operate below the altitudes of500 feet above ground level (AGL) referenced bythis 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 AltimeterSetti11gs The UAS Sunrise Engineering, Inc. intends to operate are not equipped with a barometric altimeter, but instead use GPS for altitude control. Reliefis requested to allow the built

-in UAS technology to be used to maintain the correct AGL altitude. 

### Sumise Enginming, l11c ., requt!sts relief jivm Title f.l. 

### CFR 91.151(a) 1:</tel 

### Requirementsfor 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. 

### Sunlise Engineering, Inc., reql!ests reliefjivm Title 1..J. Cf<"""R 

### 91.203 ( a) and(b): Can)'ing CiJJilAinraft**Ce~tijications** 

### andRegistratiollJ This regulation would not be applicable ifreliefis 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 ifreliefis 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 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 offlights, 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_lnc

_·

_I' ' cmptlon

_Rulcmakmg Joo.(e) Reasons why granting the exemption would not adversely affect safety and how the exemption would provide a level ofsafety 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 ofsafety 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 ofsight (VLOS) ofthe PIC. 3. Minimum crew for each operation will consist ofthe 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 ofall 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. Ifanother 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 ofan 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 ofno 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 ofunpredicted 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 conductpre-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 ofFederal Regulations Part 11, Sunrise Engineering, Inc., hereby applies for an exemption and specific relieffrom 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>cxThese 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 ofthe 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 ofthe Exemption outside the United States At this time Sunrise Engineering, Inc. does not request to usc these exemptions outside ofthe United States. Ifyou ha,-e any questions after reYiewing our request, please contact Richard SnyderJr., P.E., P.L.S., at the abO\-e noted contact information. Sincerely,

Richard B. SnyderJr., P.E., P.L.S. Sunrise Engineering, Inc.

!'unnse_Eng_lnc_-_ExLmpttOn_Rulemakmg
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