Robert C. Suess dba BSS Aerial 2134 S. Midland Dr. #139 Midland, TX 79703 Email: bob@bssaerial.com 432-250-8246
January 15, 2016



### U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave; SE Washington, DC. 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act of2012

Attachments: 1) 2) 3)

References: 3DR Solo User Manual & Safety Guidelines Pre-Flight Checklist Addendum A: Title 14 CFRregulations pertainingto this request

1) FAA Exemption No. 11138, Regulatory DocketNo. FAA-2014-0481 in the matter ofthe petition ofDOUGLAS TRUDEAU.
2) FAAExemptionNo. 11136, Regulatory DocketNo. FAA-2014-0508 inthe matter ofthe petition ofAdvanced Aviation Solutions LLC.
3) FAAExemption No. 11080, Regulatory Docket No. FAA- 2014-0355 in the matter ofthe petition ofFL YING CAM INC.
4) FAAExemptionNo. 11405, Regulatory DocketNo. FAA-2015-0118 in The matter ofthe petition ofBRIAN CHERRY.

Dear Sir orMadam, In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012, I, Robert C. Suess, referred to hereafter as the petitioner, request exemption from the following sections ofTitle 14, Code of Federal Regulations, all or in part, as follows; §§61.113(a); 61.113(b); 91.119(c); 91.121; 91.126(a); 91.127(a); 91.129(a); 91.131(a); 91.151; 91.153; 91.155; 91.157; 91.159; 91.203; 91.205; 91.207; 91.209; 91.215; 91 Subpart E; 23 parts 23.1 to 23.1589; ·

Reliefunder this exemption is·requested in orderto operate small unmanned aircraft systems (UAS) commercially in airspace regulated bythe Federal Aviation Agency (FAA) for thepurposes ofaerial photography, cinematography, videography, mapping, crop surveying, inspections and other flight operations that can be performed safely and more cost effectively with the use ofsmall UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request ofand with the authorization and permission ofclients ortheir authorized agents in orderto facilitate commerce and raise awareness ofthe beneficial uses ofsmall unmanned air systems, so long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner
are drawn from references 1-4.


### TheFARS The petitioner seeks exemption from the above mentioned FARs for the following reasons;
23.1 to 23.1589; Exemption requested.

61.113(a) & (b); The petitioner requests reliefin orderto facilitate the utilization ofpilots who hold a Private Pilots (or greater) certificate. Any pilots operating underthis exemption would be required to comply with any conditions as set forth and in a similarfashion to the previously granted exemptions.
91.119(c); As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closerthan 500 feet to the ground may require that the UAS be operated closerthan 500 feet to essential persons, or objects thatwould not be possible without additional relief. The petitionerrequests modification, waiver or exemption and clarification concerningthe terms "congested areas" and "denselypopulated". The petitionerrequests waiver for this condition to allowreasonable operations in areas ofsubdivisions and neighborhoods if required.
91.121; As discussed in Exemption 1138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does nothave an altimeterbut instead utilizes electronic GPS with barometric sensors for altitude information.
91.126(a); 91.127(a); 91.129(a); Exemption requested includes coordinated operations with ATC controlling agencies approval priorto operations.
91.151(a); As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) priorreliefhas been granted for manned aircraft to operate at less thanthe prescribed minimums, including ExemptionNos, 2689, 5745, and 10650. In addition, similarUAS specific reliefhas been granted in ExemptionNos, 8811, 10808, and 10673 for day time VFR conditions. The UAS provides batterypowerremaining in percentto the PIC. The UAS batteries provide approximately 20 minutes ofpowered flight and include an autonomous return to base feature based on remaining batterypowerwith respect to its current location. Information provided in the operating documents discuss procedures regarding remaining batterypowermanagement. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given thet •

limitations on proposed operations and the location ofthose proposed operations, the FAA found that a reduced minimum reserve for flight in day time VFRconditions was reasonable. 91.203; 91.205; 91.207; 91.209; 91.215; Exemption request.

91 Subpart E; As discussed in Exemption 1138 (DOUGLAS TRUDEAU). The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner's operating documents andthe conditions and limitations specified, describing the requirements for maintenance, inspection and recordkeeping, were sufficientto ensure that safety would not be adversely affected.


### TheUAS The 3DR Solo is a highly successful professional grade small rotorcraft in the quadcopter configuration with an advertised weight of3.9pounds designedprimarilyto carry aloft a high definition camera. 

### It has an advertised maximum speed of48 knots, a range of0.5 miles with a max climb rate of 1,900 feet perminute. It is powered by four electric motors with a distance between motors ofless than 24 inches. Other UAS platforms for future expansion include the DJI Inspire 1.


### Public interest Use ofthe UAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greaterproportions, carrying a crew and flammable fuel. Additionally, use ofthe UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners ortheir designees seeking an enhancedperspective for characteristics, amenities and benefits oftheir desired photographic subjects that cannotbe displayed through ground level videography/photography ormapping. Aerial photography is
a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use ofpesticides and fertilizer and conservation ofwater as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risk. The petitionerwill provide clients with photographic data for these purposes on a "forhire" basis acting as an independent contractor. Liability insurance will be obtained commensurate withthe granting ofthis request for exemption. Flight data including UAS flight time, Control Unit operation time, incident, accident and details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding the use ofthe UAS as part ofthis application. This data maybe submittedto the FAA via traditional means upon request ofthe Administrator as he/she may require.


### Conclusion The petitioner is requesting this exemption for the purposes ofaerial photography, cinematography, videography, mapping, crop surveying, game surveying, inspections and

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other flight operations. The reason for such a general and broad based request is that the petitioner wishes to utilize a business strategy ofhorizontal integration and maximize economies ofscope in orderto capitalize on opportunities as they may ariseinthe future, without the long turnaround time associated with additional exemptions. Thepetitioner's business model is based on the idea ofoffering UAS services to individuals or companies, who wish to employ these services as a safe, effective and legal option to enhance their business or hobby. The petitioner's ownmarketresearch shows pentup demand for these services in multiple markets currently existing as well as newly emerging.

The primary purpose ofseeking this exemption is to obtain the capability to offerthose services while remaining in compliance. The petitionerholds an AIRLINE TRANSPORT PILOTS LICENSE #3342501 with 3 Type ratings and a Flight Instructor Certificate #CFI3342501

Respectfully submitted,

# QM-c~ Robert C. Suess