Fred A. Darnell Jr. Synectric

-Systems, LLC 9521 Willowglen Tr. Charlotte, NC 28215
January 22, 2016 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b).

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 C.F.R . Part11, Synectric Systems, LLC ("The Applicant"), developer and operator of Small Unmanned Aircraft Systems (" s UASs") equipped to conduct Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, win d generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetri c Analysis, Research and development, traffic monitoring, and sporting events, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its SUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. As described more fully below, the requested exemption would permit the operation of small, unmanned, and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would provide safety enhancements to the already safe operations in the infrastructure and business operations industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (The FAA Administrator's) responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the national airspace system ." Section 333(c) of the Reform Act. The name and address of the applicant is:
Synectric Systems, LLC ATTN: Fred A Darnell Jr Ph: (980)722

- 6356 Email: innovation@synectric

-systems.com Address: 9521 Wi llowglen Tr., Charlotte, NC 28215Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2} 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 9 1.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 91.407 (a) (1) 14 C.F.R. 91.409 (a) (2) 14 C.F.R. 91.417 (a) & (b)
This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:
• The UAS's size, weight, s peed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator.
Reform Act§ 333 (a). Lastly, if the secretary determines that such vehicle s "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Jd. §333(C) (emphasis added). 1

The Federal Aviation Act expressly grants the FAA th e authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes sUASs, from the requirements that all civil aircraft must have a current airworthiness certificate.
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

-44716 of this title if the administrator finds the exemption in the public interest. 49 U .S.C. §44701(f) See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203 (a) (1).
Synectric Systems, LLC's sUASs (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including payload. They operate under normal conditions at a speed of no more than 55 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will operate only within the sterile area described in the General Operating Procedures of the Synectr ic Systems, LLC

- Unmanned A ircraft Systems Operations Manual, (hereinafter "The Manual") 2 • Such operations insure that the sUAS does "not create a hazard to users of the national airspace system or the public." 3

1 Applicant interprets this provision to p lace the duty on the administrator to not only process applications for exemptions under §333, but for the Administrator to craft conditions for the safe operation of the UAS. if it should be determined that the co nditions set forth herein do not fulfill t he statutory requirements for approval. 2 Applicant submits this manual as a Confidential document under 14CFR 11.35 (b) as the entire manual contains proprietary information that the applicant has not and will not share with others. The manual contains op erating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Act 5 U.S.C. 552 et. Seq. 3 Reform Act Section 333(b)Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the sUASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emi ssions associated with allowing UASs for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, sol ar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings, Real Estate, Golf Courses, Orthographic Photograph y, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, F ire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, announcements, animal tracking, radiation detection, noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mini ng, volumetric Analysis, Research and development, traffic monitoring, and sporting events, the granting of the requested exemptions is in the public interest. Accordingly, the appli cant respectfully requests that the FAA grant the requested exemption with out delay.
Background Information Synectric Systems, LLC is in the business of consulting on, building, and maintaining mission specific sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspect ion Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photograph y, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracki ng, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.
Synectric Systems, LLCs' clients look to us for safe opera tions of sUAS. We have developed specific safe UAV operational procedures. Increasingly, we have clients looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.
Operations performed by Synectric Systems, LLC include: Precision Agriculture 2D and 3D Mapping Photography Cinematography Aerial Data Collection Visual Inspection

- Primarily: Towers Poles Pipelines Power lines Cables Bridges Chimneys Vertical structuresSolar arrays

Wind generators Power stations and substations Coal a sh ponds Absorbers Buildings Real Estate Golf Courses Orthographic Photography Special Events Construction Progress Public Service

- Primarily: Search & Rescue Law Enforcement Fire Security Disaster Management & Relief Wildfires Floods Hurricanes News broadcasting Tornados Banner towing Announcements Animal tracking Radiation detection Noxious gas detection Forestry & logging Insurance Assessments Surveys Mining Volumetric Analysis Research and development Traffic monitoring Sporting events
As part of this Synectric Systems, LLC is requesting FAA Exemption for sUAS operations for safety, inspection and video capture usage.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at lea st an equivalent or even higher level of safety to operations under the current regulatory structure because the propose d operations represe nt a safety enhancement to the already safe Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, s olar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Min ing, volumetric Analysis, Research and development, traffic monitoring, and sporting events.These limitations and conditions to which Synectric Systems, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight, unless an addendum is released, a corresponding exemption is granted or other appropriate FAA guidelines supersede. 3. Maximum total flight time for each operational flight will be 60 minutes. Flights will be terminated at 25% battery power reserve; should that occur prior to the 60 minute time limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL (Above Ground Level) or, not more than 200 feet above an elevated platform from which the flight is planned. 5. Minimum crew for each operation will consist of the sUAS pilot (Operator) and the Visual Observer (Observer)

. 6. The sUAS pilot will be a specially trained staff member of Synectric Systems, LLC. knowledgeab le of the airspace within which the operation will take place and how that airspace fits into the NAS. 7. The sUAS pilot will be the Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on site, that person can also be designated as PIC. 8. The sUAS will only operate within defined boundaries as outlined in the Manual. 9. A briefing will be conducted in regard to the planned sUAS operations prior to each mission. It will be

man datory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 10. If required, t he operator will file a FAA form 7711

- 1, or its equivalent, as modified in light of the requested exemption, w ith the appropriate Flight Standards District Office (FSDO). 11. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may b e reduced to 30 feet based upon an equivalent level of safety determination, as required by the General Operating Procedures section of the manual. With the advanced permission of the relevant FSDO, operations at closer range can be approved. 12. If the missio n falls outside of any blanket FAA CoW, t he operator will submit a written Plan of Activities to the FSDO three days before the proposed mission as required in Section 8.1 of the Manual. Items will include:

a. Dates and times for all flights; b. Name and phone n umber of the operator for the UAS mission conducted under this petition of exemption;

c. Make, Model, and serial or N

- number of UAS to be used; d. Name and certificate numbers of UAS PICs involved in the mission;

e. A Statement that the operator has obtained permis sion from property owners or property owners' representatives and/or local officials to conduct the mission; f. The list of those who gave permission made available to the inspector upon request; g. Signature of exemption

- holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which the mission will be conducted and the altitudes essential to accomplish the operation. 13. Pilot and observer will have been trained in operation of UAS generally and received up to date information

on the particular UAS to be operated as required in the Safety Training Sections of the manual. 14. Observer and pilot will at all times be able to communicate by voice. 15. Written and/or oral permission from t he relevant property holders will be obtained. 16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. If the sUAS loses communications or loses its GPS signal, the UAS will have the capability to return to a predetermined location within the security Perimeter and land. 18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.1 4 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)
Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a)(1). Given the size and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Av iation Act (49U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airp orts and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot no r passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both th e operator and observer, pursuant to the Manual's policies, and under and in compliance with local public safety requirements, to provide security for the area of operations as is now done with conventional Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasti ng, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.
The FAA will have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Vis ual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographi c Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, a nimal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, provide a greater degree of safety to the publi c and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by t he UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires:

When ma rks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "Restricted," "Light

-sport," "experimental," or "Provisional," as applicable.
Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to a cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Giventhe size of the sUAV, two

- inch lettering wil l be impossible. The word "Experimental" will be placed on the

fuselage in compliance with §45.29 (f).
The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29(f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. §61 .113 (a) & (b) : Private Pilot Privileges and Limitations: Pilot in Command.
Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by re quiring the PIC operating the aircraft to have specially trained staff operate this small UAS. Unlike a conventional aircraft that carrie s the pilot and passengers, the sUAS is remotely controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilots certificate operating a conventional aircraft. The risks associated wit h the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested by specially trained staff as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113(a) & (b).

14 C.F.R. §91.7(a) : Civil aircraft airworthiness.
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificat e issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Manual for maintenance and use of safety checklists prior to each flight, as set forth in Sections 9 .1 and 9.6, an equivalent level of safety will be provided.

14 C.F.R. §91.9 (b) (2) : Civil Aircraft Flight Manual in the Aircraft.
Section 91.9 (b) (2) provides:

No person may operate a U.S.

- registered civi l aircraft ... (2) For which an airplane or rotorcraft Flight Manual is not required by §2 1 .5 of this chapter, unless there is available in the aircraft a current Approved airplane or rotorcraft Flight Manual, approved manual material, markings, and plac ards, Or any combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it.
The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607 8737, 8738, 9299, 9299A, 9565, 95658, 10167A, 10602, 32827, and 10700.
14 C.F.R. §91.103: Preflight Action
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA ap proved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed. Anequivalent level of safety will be provided as set forth in Safety section of the Manual. The PIC will take all actions including reviewing weather, fli ght battery requirements, landing and takeoff distances, and aircraft performance data before initiation of flight.

14 C.F.R. §91 .119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) a llows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sU AS that is a helicopter and the exe mption requests authority to operate at altitudes up to 400AGL, or not more than 200 feet above an elevated platform from which operation is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited condition s stated in the Manual the UAS will never operate at higher than 400’ AGL. It will, however, be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre

-obtained consent. The eq uivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner, representatives of the property owner or local officials. Because of the advanced notice to the property owners and participants in the mission, all affected individuals will be aware of the planned flight operations as set forth in the General Operating Procedures Section of the Manual. Compared to fl ight operations with aircraft or rotorcraft weighing far more than the maximum 55 l bs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, win d generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and developm ent, traffic monitoring, and sporting events. The FAA will have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events industries. In addition, the low

- altitude ope rations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Alti meter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting available before departure ." As the sUAS may not have a barometric altimeter, but instead a GPS altitude sensor, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and safety checklist, confirming the altitude of the l aunch site shown on the GPS altitude indicator before flight.

14 C.F.R. §91 .151 (a) : Fuel Requirements for Flight in VFR ConditionsSection 91. 151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes." The battery powering the sUAS provides approximately 30

-37 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 C.F.R. §9 1.151, sUASs flights would be extremely limited in duration. Given the limitations on t he UAS's proposed flight area and the location of its proposed operations within a predetermined area, a shorter reserve time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 C.F.R. §91.151 (a ) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or offic ial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.15 1 (a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUASs flights to 20 minutes would greatly reduce the utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808.

14 C.F.R. § 91.202 (a) and (b) : Carrying Civil Aircraft Certification and Registration
The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following:

a. An appropriate and current airworthiness certificate ... (b) No person may operate a civil aircraft unless the airworthiness certificate require by paragraph (a) of this section or a special flight authorization issues und er §91. 715 is displayed at the cabin or cockpit entrance so tha t it is legible to passengers and crew.
The UAS fully loaded weighs no more than 55 lbs

. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An e quivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to t his regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1}; 409 (a) (2}; 417 (a) & (b) : Maintenance Inspections
These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in Part 43 of this chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Ma intenance will be accomplished by the operator pursuant to the flight manual and operating handbook as references in the Manual (See Sections 8.6 and 9). An equivalent level of safety will be achieved because these small UASs are very limited in size and w ill carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400ft AGL. As provided in the Manual, the operator will ensure tha t the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airwort hy condition to provide the equivalent level of safety.Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:
Applicant seeks an exemption from the following rules:
14 C.F.R. Part 21, 14 C. F.R. 45.23(b), 14 C.F.R. 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 C.F. R. 91.9 (b) (2), 14 C.F.R. 91.103, 14 C.F.R. 91.109, 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) & (b), 14 C .F.R. 91.405 (a), 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a) (2), 14 C.F.R. 91.417 (a) & (b) to operate commercially a small unmanned vehicle (551bs or less) in motion picture and television operations.
Approval of exemptions allowing commercial opera tions of sUASs in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind gene rators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.
The FAA will have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D a nd 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurri canes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, using jet or piston powered aircraft, operate at extremely low altitudes just feet from the infrastructure being inspected and in extreme proximity to people and structures; and present the risks associate d with vehicles that weigh in the neighborhood of 4,0001bs, carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the work location. In contrast, a sUAS weighing fewer than 55lbs. and powered by batteries eliminates virtually al l of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the worksite and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.
The operation of small UASs, weighing less than 55lbs., conducted in the strict conditions outlines above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine hel icopters operating in close proximity to the ground and people.

Privacy
All flights will occur over private or controlled access property with the property owner's prior consent and knowledge. Precision Agriculture, 2D and 3D Mapping, Photography, Cinem atography, Aerial Data Collect ion, Visual Inspection Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildi ngs. R eal Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hur ricanes, news broadcasting, and torn ados. Banner towing, Announcements, animal tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.The FAA wi ll have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspectio n
- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings . Real Estate, Golf Courses, Orthographic Photograph y, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracki ng, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events operations will be performed for people who have also consent ed for work to be performed or otherwise have agreed to be in the area where UAS flight will take place.

Conclusion Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’ s UAS in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, h urricanes, news broadcasting, and tornados. Banner towing, Announcements, anima l tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research an d development, traffic monitoring, and sporting events. The FAA will have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection

- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service

- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadc asting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events industries pursuant to the Manual appended hereto.

Sincerely,

Fred A Darnell Jr. Synectric Systems, LLC