## Ansync Labs

January 12 , 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Regarding: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Fed eral Aviation Regulations: 14 CFR Part 21; 14 CFR 48.15; 45.21; 45.23(b); 61.101 (e) (4) & ( 5); 61.113 (a) & (b);

61.315 (c) (2) (3) (5) (7) ; 91.7 (a); 91.9 (b) (2); 91.103 (a) & (b); 91.109; 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1) ; 91.409 (a) (1) & (2); 91.417 (a) & (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Ansync
Labs herein after known as the operator, hereby applies for an exemption from the listed Federal Aviation Regulations (“FAR’s”) to allow testing of the operators Unmanned Aircraft Systems (UAS), so long as operations are within the specifications outlined or as may be established by the FAA as required by Section 3 33.

Ansync Labs is an electrical and manufacturing design firm based in El Dorado Hills, California. Ansync Labs is currently research ing and d eveloping prototype hobby USA’s . The exemptions requested ar e needed to test prototype or exhibit for clients USA’ s as they are built and modified throughout the design process. The requested exemption would permit the testing and exhibition of prototype s and potentially t esting of production UAS’s . UAS ’ s would operate within and adhere to the following
limitations:

 The UAS’s will weigh less than 55 lbs. , at this time total estimated weight is 5.9 lbs.

 Flights will be operated at an altitude of no more than 400 feet AGL

.

 Average targeted airtime will be 20 minutes, maximum airtime not to exceed 4 0 minutes

.

 UAS’s have a maximum speed of 20 mph

.

 The UAS’s will only o perate over open empty fields

.

 Only one UAS will be operated at a time

.

 If the UAS loses communications or loses its GPS signal, the UAS return s to a pre

- determined
location.

 UAS will be operated either entirely by software with an operator with either a private, recreational, or sports pilot ’ s license present and able to take over control if necessary or only by an operator with either a private, recreational or sports pilot ’ s license.

 Every UAS flight will be accompanied by a visual observer who will have a fire extinguisher on hand during the entire operation.The name and contact information of the applicant are:

Ans ync Labs 5090 Robert J Mathews Pkwy El Dorado Hills, CA 95762
Sam Miller

916

- 933

- 2850 sam@ansync.com

Ansync Labs requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of its UAS’s.

14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203(a) (1). The Federal Aviation Act (49 U.S.C. 44701(f)) and Section 333 of the Reform Act both au thorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed , operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer than conventional aircraft (fixed wing or rotorcraft) operating w ith an airworthiness certificate without the restriction and conditions proposed.

The UAS to be operated will be less than 55 lbs. and carry neither pilot nor passenger. The UAS will be powered with a single lithium ion battery which will be used in conjunction with fail safe circuitry to prevent any overheating or damage to the battery. Beyond this the UAS will have no explosive materials or flammable liquid fuels. All UAS flights will be at an altitude of no more than 400 feet AGL. Flight will be operated within line of sight of the operator. In addition to the operator there will be an observer who will have a fire extinguisher in the area of flight at all times. Application of these criteria
demonstrates that there is no subs tantial threat to national security.

The Secretary of Transportation has previously determined that these aircraft meet the conditions of Section 333. Therefore, the FAA has found that request of relief form 14 CFR part 21, and any associated
noise certifi cation and testing requirements of part 36, is not necessary.

This has been stated in exemptions to this regulation in Exemptions Nos. 12990, 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11260, 11253, 11250 and 11230.

14 CFR 48.15 Requirement to Regis ter

The requirement in part states: No person may operate a small unmanned aircraft th at is eligible for registration under 49 U.S.C. 44101

- 44103. At this point in time the UAS is currently being developed and may go through several revisions and iterations to register each UAS before a test flight could occur would greatly inhibit developm ent. An exemption is being requested for any UAS’s that will be flow n only for test or client exhibition

purposes. When and if Ansync Labs begins to produce, for the purpose of selling, fully assembled UAS

units

, Ansync Labs will file an AC Form 8050

- 6 (Deal er’s Aircraft Registration Certificate) per 14 CFR

47.61.14 CFR 45.21 Identification and Registration Marking: General

In part this regulation stipulates that: Except as provided in §45.22, no person may operate a U.S.

- registered aircraft unless that aircraft displays nationality and registration marks in accordance with the requirements of this section and §§45.23 through 45.33.(b) Unless otherwise authorized by the FAA, no person may place on any aircraft a design, mark, or symbol that modifies or confuses the nationality and registration marks.

Given that at this time UAS’s will be tested only within open fields surrounding Ansync Labs and that the UAS will only be flown for test or exhibition for potential clients while at all times in the visual field of the operator a lack of marking will present no safety hazard. As the UAS is developed and modified it would be cumbersome to mark every UAS that would be used simply for testing or exhibition purposes. However any UAS to be sold would be marked appropriately.

14 CFR 45.23 (b). Marking of the Aircraft

45.23 (b) requires the following: When marks include o nly the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certified 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.

Although, assuming the previous requested exemption is grant ed, the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have none of the mentioned entrances. If any fully assembled and fully operational UAS is sold it will have the word “Experimental” placed on its main body. The size will be either 2 inch lettering or as close as possible to that size given at this stage the final form of the UAS body design in not yet determined.

14 CFR 61.101(e) (4) & (5)

. Recreational pilot privileges and limi tations

The regulation states in part: (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as p ilot in
command of an aircraft

– (4) For compensation or hire; (5 ) In furtherance of a busines s

...

Any UAS flown by Ansync Labs will not carry a pilot or passengers, the pr oposed operations are limited in scope and do not present the same level of danger as a traditional aircraft. T h e UAS will weigh significa ntly less than 55lbs and in many cases will be c ontrolled by software with a pilot for backup. In all flights, including ones not run exclusively by softwar e, the fligh ts will not exceed 4 0 m inutes and the
UAS retains a return to home function. The risks associated with th e operation of the UAS are
diminished from the level of risk ass ociated with the operation of a commercial operations contemplated with Part 61 when drafted, that allowing operations of the UAS as requested with a private

, recreational or sport pilot as the PIC exceeds the present level of safety achieved by 14 CFR 61.101 (e ) ( 4 ) & (5 ).14 CFR 61.113 (a) & (b). Private pilots Privileges an d Limitations: Pilot in Command

Sections 61.113 (a) & (b) limit pilots to non

- comm ercial operations. Any UAS flown by Ansync Labs will

not carry a pilot or passengers, the pr oposed operations are limited in scope and do not present the
same level of danger as a traditional aircraft. T h e UAS will weigh significantly less than 55lbs and in many
cases will be c ontrolled by software with a pilot for backup. In all flights, including ones not run exclusively by softwar e, the flights will not exceed 4 0 m inutes and the UAS retains a return to home
function. The risks associated with th e operation of the UAS are diminished from the level of risk

ass ociated with the operation of a commercial operations contemplated with Part 61 when drafted, that allowing operations of the UAS as requested with a private

, recreational or sport pilot as the PIC exceeds the present level of safety achieved by 14 CFR 61. 113 (a) & (b). The FAA has issued the following exemption to this regulation to exemptions to this regulation to Exemption No. 11282.

14 CFR 61.315 (c) (2) (3) (5) (7). What are the privileges and limits of my sport pilot certificate?

This section limits sport pil ots to non

- commercial operations stating they may not act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire, or in the
furtherance of a business. Additionally the y may not carry more th an one passenger, fly at night and
other limitations that are far outside the scope of a UAS flight. In particular an exemption is needed as Ansync Labs intends to make use of employees with private, re creational or sport pilot ’ s certificates as

PIC ’ s. See 61.113 (a) & (b), and 61.101 (e ) (4) & (5) above exemption requests for explanation. Additionally an exemption from the restriction prohibiting night fli ghts in requested. The UAS will have multiple LED indicators that will be in lin e of sight of the operator

, will op erate in open fields

, and , as
pre viously stated, altitude and GPS data will be visible on a laptop

.

14 CFR 91.7(a). Civil Aircraft Airworthiness

The regulation requires that no person operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

14 CFR 91.9(b) (2). Civil Aircraft Flight Manual in the Aircraft

The regulation stipulates: No person may oper ate a U.S

– registered civil aircraft ... (2) for which an Airplane or Rotorcraft F light Manuel is not required by 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual materi al, markings and placards, or any
combination thereof. Assuming the registration exemption is provided this will not apply to any UAS’s used for testing and exhibition of prototype or in development UAS’s. If and when production of fully
assembled UAS’s oc curs any test flights for those units will require an exemption. When and if UAS’s are produced for sale a test procedure manual will be developed. The test procedure manual would be kept on the test site near the operator of the UAS. The test procedure ma nual would not be able to be kept on the UAS’s given its size. Additionally even if it were possible to place the manual in the UAS it would defeat the purpose of the manual as the UAS carries no onboard pilot.14 CFR 91.103 (a) & (b). Preflight Action

Th e regulation requires that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

– (a) weather forecasts, fuel requirements, alternatives available..., any know traffic delays ... advised by ATC.

- (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information...

An exemption will be needed as runways are not necessary for the UAS and there will be no A TC. The operator will take into account weather conditions, battery requirements and landing/takeoff locations before flight initiation.

14 CFR 91.109. Flight Instruction

The regulation stipulates that no person may operate a civil aircraft (except a manned free balloon ) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS’s and remotely piloted aircraft, by their design do not have fully functioning dual controls. Equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the UAS and by the size and speed of the UAS. The FAA has approved exemptions for flight training without f ully functioning dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption
Nos.5778K & 9862A.

14 CFR 91.119. Minimum Safe Altitudes

91.119 establishes safe altitudes for operation of civil aircraft. The UAS will not operate at an altitude more than 400 feet AGL, an exemption may be needed for such operations. Equivalent level of safety provided by the following facts: 1.The size, weight, speed and location of where the UAS is to be operated do not lend themselves to the
same level of concern as a traditional aircraft. 2. The low altitude operation of the UAS will ensure appropriate separation between the UAS and the operation of traditional aircraft that must comply with Section 91.119.

14 CFR 91.121. Altimeter Settings

91.121 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 settin g available before departure.” The UAS will not necessarily reach a cruising altitude depending on the goal of the testing at the time. Thus an exemption may be needed. Altimeter and GPS date will be viewable on a laptop. The UAS will not operate more 400 feet AGL.

14 CFR 91.151(a). Fuel Requirements for Flight in VFR Conditions

Section 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 fue l to fly to the first point of the 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 current anticipated batterylife for the UAS is 20 minutes, a 4 0 minute fight time is a potential goal that may never be achieved. As it

stands compliance with this requirement is impossible an exemption is needed. Given the limitations of the flight area ( exact measurements are not availabl e) if the UAS were to land in any point within the open fields it would be within walking distance and reached in a matter of minutes. Additionally UAS flights would be for testing or exhibition only carrying neither pilot nor passengers. Equivalent level of safety is also maintained as the operator can via laptop see the remaining battery power, the UAS will
also have a return to home function that will initiate based on distance from home location and remaining battery power.

14 CFR 91.203 (a) & (b). Carrying Civil Aircraft Certification and Registration

The regulation states in part: (a ) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it the following: (1) an appropriate and current airworthiness certificate... (2) An effective U.S. registration certificate ... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) .... Is displayed at the cabin or cockpit entrance...

Assuming previous exemption requests regarding 14 CFR Part 21 and 14 C FR 48.15 are granted this will
be a non

- issue. However when an d if fully assembled UAS’s are produced for sale, Ansync Labs will obtain the necessary Dealer’s Certificate via AC Form 8050

- 6. The UAS will not be able to carry said certificate. Instead if it applies to the UAS being flown certification will be in the f light area near the
operator.

14 CFR 91.405(a); 407(a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections

The 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...”
Given that these sections and part 43 apply to aircraft with an airworthiness certificate, these secti ons do not apply to applicant.

As these are new UAS’s that are currently being designed no maintenance guidelines exist. However, given the small size, the speed, and limited area of operation the UAS can be landed immediately should the UAS experience an operational issue in flight.

Ansync Lab’s respectively requests that the FAA grant the requested exemptions and are prepared to modify or amend any part of this request to satisfy the need for compliance with an equivalent level of safety. We look forward to working with the FAA. Please contact us at any time if additional information
or clarifications are needed.

Sincerely, Ansync Labs

Sam Miller

Owner