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 of Transportation Docket Management System 

1200 New Jersey Ave; SE 

Washington, DC. 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of2012 

Attachments: 

1) 

2) 

3) 

References: 

3DR Solo User Manual & Safety Guidelines 

Pre-Flight Checklist 

Addendum A: Title 14 CFR regulations pertaining to this request 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 

in the matter of the petition of DOUGLAS TRUDEAU. 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 

in the matter of the petition of Advanced Aviation Solutions LLC. 

3) FAA Exemption No. 11080, Regulatory Docket No. FAA- 2014-0355 

in the matter of the petition ofFL YING CAM INC. 

4) FAA Exemption No. 11405, Regulatory Docket No. FAA-2015-0118 

in The matter of the petition of BRIAN CHERRY. 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under 

Section 333 of the FAA Modernization and Reform Act of2012, I, Robert C. Suess, referred to 

hereafter as the petitioner, request exemption from the following sections of Title 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; · 

Relief under this exemption is·requested in order to operate small unmanned aircraft systems 

(UAS) commercially in airspace regulated by the Federal Aviation Agency (FAA) for the 
purposes of aerial photography, cinematography, videography, mapping, crop surveying, 

inspections and other flight operations that can be performed safely and more cost effectively 

with the use of small 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 of and with the 

authorization and permission of clients or their authorized agents in order to facilitate commerce 

and raise awareness of the beneficial uses of small unmanned air systems, 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. The conditions identified and proposed by the petitioner 

are drawn from references 1-4. 

TheFARS 

The petitioner seeks exemption from the above mentioned F ARs for the following reasons; 

23.1 to 23.1589; Exemption requested. 

61.113 (a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots who 

hold a Private Pilots (or greater) certificate. Any pilots operating under this exemption would 

be required to comply with any conditions as set forth and in a similar fashion to the previously 

granted exemptions. 

91.119(c); As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UAS be operated closer than 

500 feet to essential persons, or objects that would not be possible without additional relief. 

The petitioner requests modification, waiver or exemption and clarification concerning the 

terms "congested areas" and "densely populated". The petitioner requests waiver for this 

condition to allow reasonable operations in areas of subdivisions and neighborhoods if 

required. 

91.121; As discussed in Exemption 1138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter but 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 prior to operations. 

91.151(a); As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS 

LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos, 2689, 5745, and 10650. In addition, similar UAS 

specific relief has been granted in Exemption Nos, 8811, 10808, and 10673 for day time VFR 

conditions. The UAS provides battery power remaining in percent to the PIC. The UAS 

batteries provide approximately 20 minutes of powered flight and include an autonomous 

return to base feature based on remaining battery power with respect to its current location. 

Information provided in the operating documents discuss procedures regarding remaining 

battery power management. Those documents contain a condition in which the PIC will 

initiate a landing procedure when battery remaining reaches a specified level. Given the 
t • 

limitations on proposed operations and the location of those proposed operations, the FAA 

found that a reduced minimum reserve for flight in day time VFR conditions 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 and the conditions and limitations specified, describing the requirements for 

maintenance, inspection and recordkeeping, were sufficient to 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 of 3.9 pounds designed primarily to carry aloft a 

high definition camera. It has an advertised maximum speed of 48 knots, a range of 0.5 miles 

with a max climb rate of 1,900 feet per minute. It is powered by four electric motors with a 

distance between motors of less than 24 inches. Other UAS platforms for future expansion 

include the DJI Inspire 1. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in 

order to facilitate commerce could lead to economic growth. Operations for this petition will 

enable service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities and benefits of their desired photographic subjects that cannot be 

displayed through ground level videography/photography or mapping. 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 of pesticides and 

fertilizer and conservation of water 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 petitioner will provide clients with photographic data for 

these purposes on a "for hire" basis acting as an independent contractor. Liability insurance 

will be obtained commensurate with the granting of this 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 of the UAS as part of this application. This data may be 

submitted to the FAA via traditional means upon request of the Administrator as he/she may 

require. 

Conclusion 

The petitioner is requesting this exemption for the purposes of aerial photography, 

cinematography, videography, mapping, crop surveying, game surveying, inspections and 
. . 

other flight operations. The reason for such a general and broad based request is that the 

petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future, 

without the long turnaround time associated with additional exemptions. The petitioner's 

business model is based on the idea of offering 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 own market research shows pent up demand for these 

services in multiple markets currently existing as well as newly emerging. 

The primary purpose of seeking this exemption is to obtain the capability to offer those 

services while remaining in compliance. The petitioner holds an AIRLINE TRANSPORT 

PILOTS LICENSE #3342501 with 3 Type ratings and a Flight Instructor Certificate 

#CFI3342501 

Respectfully submitted, 

Robert 

QM-c~ C. Suess