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US Department of Transportation

Federal Aviation Administration

800 Independence Ave S.W.

Washington, DC 20591

Dear Sir or Madam:

SoundNStyle Inc. dba The Naples Studio / SoundNStyle Inc. dba First Class Aerials 

(“SoundNStyle) is submitting this petition on its own behalf, without legal counsel or 

consultation, in accordance with the terms set forth in Section 333 of the FAA Modernization 

and Reform Act of 2012 (“Reform Act”) and 14 C.F.R. Part 11. SoundNStyle requests an 

exemption from the Federal Aviation Regulations (“FARs”)described below as they pertain

to the operation of small Unmanned Aerial Systems (“UAS”).

SoundNStyle is seeking said exemptions to commercially operate its small UAS within the 

National Airspace System (NAS) for the purpose of providing aerial videography and

photography services. All SoundNStyle flight operations will be performed by a two-person

flight team and will be conducted in accordance with Section 333 of the Reform Act as set 

forth by the Federal Aviation Administration (“FAA”).

Pursuant to 14 C.F.R. § 11.81(f), SoundNStyle is providing the following summary for

publication in the Federal Register to be included at the discretion of the FAA:

Petitioner: SoundNStyle Inc.

Seeking Exemptions from Sections of 14 C.F.R: 14 C.F.R. Part 21, 14 C.F.R. §

45.23(b), 14 C.F.R. § 61.113(a) and (b), 14 C.F.R. § 61.133(a), 14 C.F.R. § 

91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.121, 14 C.F.R. § 91.151(a), 14

C.F.R. § 91.203(a) and (b), 14 C.F.R. § 91.215, 14 C.F.R. § 91.401 through

91.417, 14 C.F.R. § 91.7(a) and (b).

Description of Relief Sought: SoundNStyle is requesting an exemptionfrom sections

of Title 14 of the Code of Federal Regulations to operate small (55 lbs. gross weight 

or less) unmanned aircraft systems under the control oflicensed private pilots.

Our petition is very similar in scope to the exemption granted to Astraeus Aerial under 

Exemption No. 11062 (Regulatory Docket No. FAA-2014-0352) and the associated Summary 

Grants (Regulatory Docket Nos. FAA-2014-0353,FAA- 2014-0354, FAA-2014-0356, FAA2014-0357 and FAA-2014-0358). Where applicable, SoundNStyle will adhere to the terms 

set forth in the Astraeus exemption. When applicable, training, maintenance and 

operations procedures will be modified/updated to comply with future regulations set 

forth by the FAA as UAS law is implemented.
 

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The petitioner contact information is:

SoundNStyle Inc

The Naples Studio / First Class Aerials

501 Goodlette Rd N Suite B306

Naples, FL 34102

Phone: 239.430.2200

Email: drew@thenaplesstudio.com

SoundNStyle is requesting exemptions from the followingregulations:

 14 C.F.R. Part 21

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.113(a) and (b) and 14 C.F.R. § 61.133(a)

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.203(a) and (b)

 14 C.F.R. § 91.215

 14 C.F.R. § 91.401 through 91.417

 14 C.F.R. § 91.7(a) and (b)

GENERAL RESTRICTIONS AND ASSURANCES

Using FAA Notice on National Policy N 8900.227, “Unmanned Aircraft Systems

(UAS) Operational Approval” and Exemption No. 11062 as guidance, SoundNStyle 

will document and implement policies and training to ensure compliance with N 

8900.227 Section14 “Operational Requirements for UAS” and including the 

followingrestrictions:

(a.) All flight operations will be performed by a minimum of two (2) 

individuals: a Pilot in Command (PIC) and a Visual Observer(VO).

(b.) PIC will conduct a pre-flight briefing with VO and client or their 

designee to review flight profile, safety considerations and 

emergencyprocedures.

(c.) PIC will perform a pre-flight inspection of the UAS that includes:

the communications link between the UA and ground control 

station,remaining battery charge, condition of airframe, 

propellers andwiring.

(d.) During flight, PIC and VO will maintain direct communications and

terminate flight operations if they are no longer able to
 

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communicate with each other.

(e.) Unmanned Aircraft (UA) shall not exceed 55 pounds gross vehicle

weight (including any attached cameras, gimbals or other

equipment).

(f.) All flight operations will take place in Class G airspace no further 

than 3⁄4 nm from the PIC, below 400 feet AGL and at airspeeds 

less than 25kts.

(g.) All flight operations will take place under VFR conditions within 

visual line of sight (VLOS) of the PIC. No flight operations will 

take place atnight.

(h.) Flight operations will not be conducted over densely populated 

areas, heavily trafficked roads, at an air show or other

environment that may include other low- flying aircraft.

(i.) No flight operations will be conducted over an open-air 

assembly of people unless a comprehensive safety plan can 

be implemented to mitigate risk of injury to individuals or 

damage to property.

(j.) Flight operations will be terminated when the UA battery reaches a

remaining charge of 25%.

Additional information regarding General Flight Operations, PIC and VO

qualifications may be found in Appendix A: SoundNStyle Equipment and Flight

Operations Overview

BENEFIT TO THE PUBLIC

The requested exemptions will allow SoundNStyle to operate its UASs to provide

commercial photography and videography services to its clients. In addition to

advancing the “safe and expedient integration of UAS into the NAS” as mandated 

by the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-

95), grantingthe requested exemption is in the public interest as:

1. A UAS generates less pollution from exhaust, has a lower noise 

signature and requires a substantially smaller to footprint from which to

operate, making it more cost-effective and environmentally friendly 

than full size, manned fixed-wing aircraft and helicopters.

2. A UAS uses either an electric power source or a significantly smaller 

amountof flammable fuel than a manned aircraft, making it a safer 

platform than itsmanned counterparts. The UAS described herein are 

also more maneuverable and provide a greater safety margin at the 

speeds and altitudes required for aerial cinematography than full size 
 

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fixed- or rotary-wing aircraft.

3. When properly operated within the regulations set forth by the FAA, a 

UAScan be less disruptive to the NAS than its full-sized counterparts 

because it doesnot require airports/runways, fueling apparatus or other 

infrastructure required by manned aircraft.

Thank you for time and consideration of this petition. Please contact us if you 

require any additional information to process this request.

Sincerely,

Drew Townsend, Owner and Pilot

SoundNStyle Inc dba The Naples Studio

SoundNStyle Inc dba First Class Aerials

Attachments:

Appendix A: SoundNStyle Equipment and Flight Operations Overview
 

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APPENDIX A:

SOUNDNSTYLE EQUIPMENT AND FLIGHT OPERATIONS OVERVIEW

SoundNStyle Unmanned Aircraft Systems (UAS)

The SoundNStyle fleet includes a variety of small, Unmanned Aircraft (“UA”) that are built by 

experienced manufacturers and maintained locally by an expert who has experience and 

training on UA’s. The various UA designs allow SoundNStyle to deploy the best equipment 

within each particular flight requirements to remain as least disruptive to the NAS and 

surrounding environment. The following small UAs and related components/equipment make 

up the SondNStyle fleet:

Octocopter – DJI S1000+

Diagonal Wheelbase 1045mm

Frame Arm Length 386mm

Frame Arm Weight (Including 

Motor, ESC, Propeller ) 325g

Center Frame Diameter 337mm

Center Frame Weight (with 

Landing Gear Mounting Base, 

Servos)

1520g

Landing Gear Size 460mm(Length)×511mm(Width)×305mm(Height)

Motor

Stator Size 41×14mm

KV 400rpm/V

Max Power 500W

Weight(with Cooling Fan) 158g

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(with Radiators) 35g

Foldable Propeller

(1552/1552R)

Material High strength performance engineered plastics
 

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Size 15×5.2inch

Weight 13g

Flight Parameters

Takeoff Weight 6.0Kg ~ 11.0Kg

Total Weight 4.4Kg

Power Battery LiPo (6S,10000mAh~20000mAh,15C(Min))

Max Power Consumption 4000W

Hover Power Consumption 1500W (@9.5Kg Takeoff Weight)

Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment 

Temperature -10 °C ~ +40 °C

 

SoundNStyle Flight Team Memebers

The SoundNStyle flight team will including the following individuals for ALL events:

1. A Pilot in Command (PIC), whose primary responsibility will be the safe operation

of the UAS in accordance with the FARs. 

2. A Visual Observer (VO), who will be responsible for ensuring that the UAS is

being operated within the restrictions set forth in the FARs and to provide a

second pair of eyes to mitigate any hazards to safe operations. The VO will 

receive orientation on the FAR and training on the responsibilities of an observer 

such as, but not limited to, flight team communications, properly monitoring the 

airspace and identifying hazards.

3. (Optional – if required and on a project-by-project basis) A Camera

Operator, (CO) who will operate any still or video camera included in 

the UAS. The CO is not considered a part of the flight team, but will be

used when a project requires a moving camera instead of one that it 

locked in a fixed position, or ifterrain, proximity to non-Class G 

airspace or other environmental factors make the addition of a third 

team member prudent.

SoundNStyle Flight Team Qualifications and Responsibilities

Each member of the SoundNStyle team will meet a minimum set of qualifications, including 

training and licenses to ensure team and public safety is kept at the highest priority. During 

operations, flight team members will be responsible for specific tasks to divide the workload 

and further enhance safety.

Pilot in Command (PIC)

The PIC holds the proper licenses/certifications to conduct the flight and has final

authority over all operations (regardless if UA is in the air at the time) and
 

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responsibility for safely operating the UA. A PIC will be designated prior to flight 

operations and only one person will be the designated PIC at any time.

At minimum, the PIC will possess the following:

1. FAA Private Pilot License and required medical certifications

2. The PIC will be qualified to operate the UA by possessing a 

minimum of100 flight cycles and 25 hours of total time as a UA

rotorcraft pilot and at least ten hours logged as a UA pilot with a 

similar UA type.

3. Successful completion of SoundNStyle training on the 

properpre-flight inspection of UAs.

The PIC’s dutiesinclude:

1. Evaluating the environment for hazards

2. Performing pre-flight checks and briefings

3. Safely operating the UA within the FARs

4. Coordinating with the VO to evaluate the operating area for safety

5. Terminating flight operations and landing the UA as soon as 

practicaland safe to do so if unsafe conditions arise.

Visual Observer (VO)

The VO is responsible for overseeing the safety aspects of UAS operations oneach

project and enforcing all FAA regulations set forth in the ReformAct.

At minimum, the VO will demonstrate knowledge of the requirements defined in

14 C.F.R. including: operations near other aircraft, right-of-way and basic VFR, plus

the proper use of pilot/air traffic control phraseology. VOs who are not licensed 

private pilots will also complete a comprehensive SoundNStyle training program 

to ensure that:

 The VO fully understands the FARs as they relate to the safe operation 

ofa UAS and the importance of complying with them,

 The VO is familiar with crew resource management and clearly

understands his/her role as it relates to the PIC,

 The VO is able to accurately read and interpret aeronautical charts,

NOTAMs, COAs, weather forecasts and any other information required 

to ensure safe operations,

 The VO is able to effectively communicate and coordinate with the 

PICto ensure a safe operating environment

 The VO has the opportunity to gain hands-on experience with a PIC,

before participating on a paid project, to validate knowledge and 

address any questions or concerns in an environment that is dedicated 

solely to knowledge transfer between SoundNStyle crew.
 

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SoundNStyle FlightOperations

Pre-flight

The PIC and VO will conduct a pre-flight briefing thatincludes:

 Review aeronautical charts to

o ensure that planned operating area is compliant with FARs

o identify known hazards to navigation
 

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o determine safe divert areas (if applicable)

 Review weather 

forecasts

 Review all Notice to Airmen (NOTAM) that may be active in the operating

area

 When required, obtain a Certificate of Waiver or Authorization (COA) 

fromthe regional ATO

 When required, submit a notice of planned operations to the 

appropriateFlight Standards District Office (FSDO) a NOTAM between 72 

and 48 hours priorto commencing operations

 Perform a pre-flight maintenance check to ensure that the UAS is

functioning according to manufacturer specifications including the 

communicationslink between the UA and ground control station, 

remaining battery charge,condition of airframe, propellers and wiring.

 Inspect the UA to comply with maximum weight limitations of 55 lbs. gross

weight

 Display a sign or other notice indicating that UAS operations are in progress

in the area and identifying SoundNStyle as the owner/operator of the UAS.

The ground control station is a portable unit that is worn by the PIC to

ensure freedom of movement should repositioning be required to maintain 

proper visual line of sight. As such, the notification sign will be placed 

within 10 feet of the PIC’s initial position and moved, as required, and 

never to exceed a distance of 20 feet from the PIC. Additionally, flight 

operations will primarily be conducted withina closed set environment or in 

an area where only authorized and consenting individuals are allowed.

In-flight

The PIC will operate the UAS in accordance with the FARs and SoundNStylepreflight briefing described above to maintain public safety. During flight operations, 

the PIC will:

 Navigate the UAS within the operational area

 Monitor altitude and airspeed

 Maintain visual line of sight (VLOS) with the UA

 Monitor battery charge/remaining flying time

The VO will:

 Monitor UAS operations to cross-check PIC and ensure that the UA stays

within VLOS and within the required altitude and airspeed limitations,

 Monitor the airspace to ensure that aircraft, birds or other airborne

hazards remain out of the operating area,

 Monitor the general operating area to ensure that the UA maintains

proper separation from hazards, restricted or unauthorized airspace and 

that noground hazards, such as unauthorized persons or vehicle enter, the 
 

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operating area,

 Monitor weather conditions to ensure that wind, cloud ceiling or other

factors do not exceed safe operating parameters

 Immediately instruct the PIC to terminate flight operations and assist the 

PICto safely land the UA if any unsafe conditions arise.