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

in	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);	

91.119(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	flight	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	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	

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	powered	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	specified	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	system	(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 on	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	will	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	agreement	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 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.	Aerial	photography	is	a	

valuablemarketing	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	risks.	

The petitioner	will	provide	clients	with	photographic	data	for	these	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	means,	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	long	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	enhance	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	request,	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 obtain	the	capability	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