August	31,	2015

Synapse	Communications,	LLC Andrew	Pelter

- Member 23679	Calabasas	Road	#168 Calabasas,	CA		91302

- 1402

Email:	synapsegc@hotmail.com

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

Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	2012 References:	1)	FAA	Exemption	No.	11138,	Regulatory	Docket	No.	FAA20140481 In	the	matter	of	the	petition	of	DOUGLAS	TRUDEAU

2)	FAA	Exemption	No.	11136,	Regulatory	Docket	No.	FAA

– 2014

– 0508 i n	the	matter	of	the	petition	of	ADVANCED	AVIATION	SOLUTIONS LLC

3)	FAA	Exemption	No.	11080	Regulatory	Docket	No.	FAA20140355 in	the	matter	of	the	petition	of	FLYING	CAM	INC

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	of	2012,	I	Cody Anderson,	referred	to	hereafter	as	the	petitioner,	request	exemption	from	the following	sections	of	Title	14,	Code	of	Federal	Regulations	§§61.113(a);	61.113(b); 9 1.119(c);	91.121;	91.151(a);	91.405(a);	91.407(a)(1);	91.409	(a)(1);	91.409(a)(2); 91.417(a)	&	(b);

In	order	to	operate	small	unmanned	aircraft	systems	(UAS)	commercially	in airspace	regulated	by	the	Federal	Aviation	Administration	(FAA)	for	the	purposes	of aerial	photography,	cinematography,	videography,	mapping,	crop	surveying, inspections	and	other	fl ight	operations	that	could	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	he rein	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

13. The	FARs	The	petitioner	seeks	exemption	from	the	above	mentioned	FARs	for	the following	reasons; 61.113(a)	&	(b);	The	petitioner	requests	relief	in	order	to facilitate	the	utilization	of	pilots,	who	hold	a	PRIVATE	PILOT	(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	UA	be	operated closer	than500	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	and responsible	operations	in	areas	of	subdivisions	and	neighborhoods	if	required. 91.121	As	discussed	in	Exemption	11138	(DOUGLAS	TRUDEAU)	is	inapplicable since the	UAS	does	not	have	an	altimeter	and	instead	utilizes	electronic	GPS	with	a barometric	sensor	for	altitude	information.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	daytime,	VFR conditions.	The	UAS	provides	battery	power	remaining	in	percent	to	the	PIC.	The	UA batteries	provide	approximately	25	minutes	of	p owered	flight.	Information provided	in	the	operating	documents	discusses	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	specif ied	level.	Given	the	limitations	on	proposed	operations and	the	location	of	those	proposed	operations,	The	FAA	found	that	a	reduced minimum	power	reserve	for	flight	in	daytime	VFR	conditions	was	reasonable. 91.405(a);	91.407(a)(1);	91.409	(a)(1)	&	(2);	91. 417(a)	&	(b)	As	discussed	in Exemption	11138	(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.The	UAS The	3DR	“Solo”	UA	is	a	is	a	consumer	grade small	rotorcraft	in	the	quadcopter configuration	with	anadvertised	weight	of	less	than	875g	designed	primarily	to carry	aloft	a	high	definition	camera.	It	has	an	advertised	maximum	speed	of	less than	30	knots	(15m/s)	and	a	maximum	climb	rate	of	less	than 1200	feet	per	minute (6	m/s).	It	is	powered	by	four	electric	motors	with	a	distance	between	motors	of less	than	14	inches	(350mm)	It	utilizes	an	internal	inertial	measuring	unit(IMU)with	integrated	barometric	sensor	augmented	with	global	positioning	syste m	(GPS)

to	maintain	its	geospatial	orientation	and	position.	It	is	controlled	primarily	through an	FCC certified	radio	control	(RC)	unit.	Real	time	video	information	is	transmitted back	to	a	ground	control	station	allowing	the	operator	and/or	PIC	camera	imagery and	control	camera	angle.	It	has	Failsafe	modes	of	operation	for	either	loss	of	RC	or GPS	signal. Altitude	can	be	limited	by	the onboard	flight	controller	and	maximum altitude	can	be	preprogrammed	by	the	PIC.	Battery	life limits	flight	times	to approximately	15	minutes.	The	onboard	flight	controller	will	warn	the	pilot via	external	lighting	and	audio cues	before	reaching	a	low	battery	state.	An automatic termination	of	flight	and	landing	will	be	initiated	when	the	battery reaches	a	predetermined	low state.	It	is	anticipated	that	flights	will	usually	last	less than	10	minutes.	This	quadcopter	is	based o n	the	Phantom	and	shares	many characteristics.	More	information	is	available	at	this	link,	and	in	the	manual (Exhibit) http://3drobotics.com/kb/solo

- user

- manual/ Risk	mitigation The	petitioner	has	reviewed	FAA	exemptions	reference’s	13 Conditions	and Limitations	section	and	believes	that	the	procedures	specified	therein	are reasonable	and	will	be utilized	in	order	to	manage	and	mitigate	risk	and	ensure public	safety.	A	preflight	checklist	will be	developed	and	employed	to	ensure	that	the	UA	airworthiness	wi ll	be	verified before	launch. Airworthiness	will	be	maintained	by	performance	of	routine inspections	before	each	flight, maintaining	flight	and	maintenance	logs	to	record	time	on	failure prone components. The	petitioner	request	that	in	a	manner	similar	to reference	3,	he	be allowed	to	operate within	5	miles	of	an	airport	provided	that; “The	UA	may	not	operate	in	Class	B,	C,	or	D	airspace	without	written approval	from	the	FAA.	The	UA	may	not	operate	within	5	nautical	miles	of	the geographic	center	of	a	nontowered	airport	as	denoted	on	a	current	FAA published aeronautical	chart	unless	a	letter	of	agreement	with	that	airport’s	management	is obtained,	and	the	operation	is	conducted	in	accordance	with	a	NOTAM	as required	by	the	operator’s	COA.	The	letter	of	agree ment	with	the	airport management	must	be	made	available	to	the	Administrator	upon	request.” Operations	within	5	miles	of	an	airport	are	not	anticipated	to	be	routine	but	the petitioner	is requesting	a	mechanism	to	facilitate	such	activities	without	requesting a	new	and	separate exemption(s)	should	the	need	arise.	Operations	within	class	B airspace	are	not	requested	due	to the	lack	of	mode	C	transponder. Public	interest Use	of	the	UAS	in	lieu	of	a	manned	aircraft	would	enhance	safety	and reduce	the environme ntal	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	petitio n	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.	Aerial	photography	is	a valuablemarketing	tool	that	can	lead	to	increased	commerce	and	enhance	personalphotography.	Crop surveying	applications	could	lead	to	decreased	use	of	pesticides

and	fertilizer	and	con servation 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	risks. The petitioner	will	provide	clients	with	photographic	data	for	the se	purposes	on	a ‘for	hire’	basis acting	as	an	independent	contractor.	A	visual	observer	will	be utilized.	Liability	insurance	will	be obtained	commensurate	with	the	granting	of	this request	for	exemption.	Flight	data	including	UA flight	time,	Control	Unit operation time,	incident,	accident,	and	details	concerning	any	deviations rom	normal	operations	will	be	available	to	FAA	for	use	in	collecting	data	regarding the	use	of UAS	as	part	of	this	application.	This	data	may	be	submitted	to	FAA	via traditional	me ans,	e.g. COA	Monthly	Reports,	or	other	means	as	required.

Conclusion

The	petitioner	is	requesting	this	exemption	for	the	purposes	of	“aerial	photography, cinematography,	videography,	mapping,	crop	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	lo ng	turnaround	time associated	with	additional exemptions	The	petitioner's	business	model	is	based	on	the	idea	of offering	ad	hoc small	UAS	services	to	individuals	or	companies	who	wish	to	employ	these services	as	a	safe,	effective,	and	legal	option	to	enha nce	their	business	or	hobby.	The petitioner’s own	market	research	shows	pent	up	demand	for	these	services currently	exists	in	the	real	estate market	and	other	markets	are	just	beginning	to emerge.	Although	videography	and	photography are	included	in	the	re quest,	the primary	objective	will	be	aerial	survey	of	farm	crops	for	precision agriculture.	The	petitioner	has	identified	universities	and	other	agencies	that	could benefit	from the	operation	requested	in	this	application. A	quick	internet	search	will	show that	many	are	currently	operating	similar	UAS	in exactly	this	fashion	without,	it	is	assumed,	FAA	authorization.	The	petitioner	has refrained	from engaging	in	commercial	use	of	the	UAS.	The primary	purpose	of seeking	this exemption	is	to o btain	the	capabi lity	to	offer	those	services	while remaining	in	compliance.	The	petitioner	has over	30	years of incident	free	flight	experience in	the	radio	control	model	aircraft	hobby. Respectfully	submitted,

Andrew	Pelter

Synapse	Communications,	LLC Andrew	Pelter

– Member