1110 Hollow Brook Lane • Malabar, FL 32950

Phone: 321-693-5963 Fax: 1-321-766-4088

www.arvideo.com Email: asommer@arvideo.com 

August 21, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Sommer Partnership - DBA A&R Video seeks an exemption from Federal 

Aviation Regulations (“FARs”) detailed below for the Tarot 650 quadcopter and Tarot 690 

Hexacopter. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to support aerial photography and videography. The Tarot 650 

Quad and Tarot 690 Hexa aircraft systems consists of a lightweight (5-8 lb) battery operated 

aircraft, a RC Controller, and associated communications equipment and camera equipped with 

video down link.

Tarot 650 Quad - currently registering

Tarot 690 Hexa - currently registering

The ability to gather high resolution photo and video has been requested by the municipal utility

departments and road planning authorities at State, County and local levels for new and on going 

construction projects. Requests have come from insurance industry and safety inspection 

professionals for an easy to deploy and safe to operate UAV technology to enhance evaluations 

while reducing overall costs. Additionally requests have been made to A&R Video by Real Estate 

professionals for imagery that will enhance the value of the listing when used in promotional 

materials. UAVs offer an extremely versatile way for construction project managers to evaluate 

worker safety, potential routes, potential conflicts and on going construction progress. The very

low noise of a small UAV combined with low altitude high resolution imagery will allow these 

evaluations to be conducted with little or no disruption to the general public for which a big 

manned aircraft would cause if used to obtain the same results.

For Tourism and Real Estate, The ability to obtain imagery that would otherwise be impossible to 

obtain (the UAV has the ability to follow scenic river courses through areas with dense tree 

canopies) or very difficult or costly allows them more freedom to promote the natural wonders of 

their states. This will increase tourism revenue and aid the state and local economies on a more 

environmentally friendly, more economic, and a safer basis. In these wildlife environments, the less 

noise pollution that you can produce, the better it is for the habit of the native species found there.
Typically the aircraft will be operated in the field with both a Pilot in Command (PIC) and a 

ground-based Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS" with the following additional restrictions: 

- All operations will occur in Class G airspace at no more than 400' AGL 

- Operations will only be conducted with permission from the appropriate land owner

- All required permits will be obtained from state and local government prior to operation 

- The aircraft will not be operated at air shows or over an open-air assembly of people 

- The aircraft will not be operated over heavily trafficked roads 

- The aircraft will not be operated within 5 NM of a public airport or heliport 

- Operations will be limited to day, visual meteorological conditions 

- Aircraft will remain within Visual Line of Sight at no greater than 1/4 NM of the pilot in 

command (PIC) at all time 

- While the aircraft is airborne, the visual observer (VO) will be positioned within voice distance to 

the PIC 

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation a 

minimum of 72 hours before any planned flight activity

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC will perform regular maintenance on the system.

Due to the simplicity of the system, we do not anticipate the need for a supplemental pilot.

We submit that the combination of the aircraft's light weight, the autopilot’s demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established in 

8900.227, the FAA can have confidence that the operation will have an equivalent or greater level 

of safety of manned aircraft performing the same mission.

The name and contact information of the applicant:

Sommer Partnership DBA - A&R Video

Attn: Andrew Sommer 

Ph: 321-693-5963

Email: asommer@arvideo.com 

A&R Video is requesting permission to conduct UAV flight operations for :

 State, County, Local level infrastructure inspections & construction industry

projects

 Industrial Inspections and Evaluations

 Insurance Industry Safety and Claims Evaluations

 Real Estate Marketing 

 Environmental study and evaluations

 State, County and Local Law Enforcement with appropriate court oversight

The regulations from which the exemption is requested are as follows: 

- 14 CFR Part 21 

- 14 CFR 91.203 

- 14 CFR 45.23, 45.29 

- 14 CFR 91.9 

- 14 CFR 61.113, 61.133 

- 14 CFR 91.109, 91.119 

- 14 CFR 91.121, 91.151 

- 14 CFR Subpart E (91.401 - 91.417) 

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 
We look forward to working with your office. Please contact us at any time if you require 

additional information or clarification. 

Sincerely,

Andrew B Sommer

Appendices:

A. Exemption Request and Equivalent Level of Safety

B. Privacy Issue

C. Safety Case

C-1 Aircraft

D. Aviation Experience
Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

A&R Video requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the Tarot 650 Quad & Tarot 690 Hexa:

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for UAS, we request an experimental 

certificate be issued for the Tarot 650 Quad and Tarot 690 Hexa under either or both of the 

following provisions: 

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses 

for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations 

to show compliance with the airworthiness regulations including flights to show 

compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function 

and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental certificate 

would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the fact that the individual aircraft weigh 5.2 pounds for 

the Tarot 650 Quad, and 7.5 lbs for the Tarot 690 and they are both constructed primarily out of 

plastic and carbon tubing, I propose that the Tarot 650 and Tarot 690 will be at least as safe, if not 

safer, than a conventionally certificated aircraft performing the same missions. 

If an experimental airworthiness certificate is not appropriate for this application, then we request 

an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in 

general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." At 5 - 8 Lbs in weight the Tarot 650 and Tarot 690 are too small to 

carry documentation, do not have an entrance, and are not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground 

control station and available for inspection upon request. In order to identify the aircraft, we 

propose that the information found on airworthiness and registration certificates be permanently

affixed to the aircraft via placard:
Two (2) Aircraft being registered

Tarot Model: 650 Quad

EXPERITMENTAL

N-number goes here

A&R Video

1110 Hollow Brook Lane

Malabar, FL 32950

If found please contact: 321-693-5963

Tarot Model: 690 Hexa

EXPERITMENTAL

N - number goes here

A&R Video

1110 Hollow Brook Lane

Malabar, FL 32950

If found please contact: 321-693-5963

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number 

in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot 

station. The Inspire 1 does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" on 

the top of the aircraft, where the PIC, VO and others in the vicinity of the aircraft while it is 

preparing for launch will be able to see the designation. Additionally, we feel that the permanent 

placard discussed in the previous paragraph will provide the aircraft's registration information 

should it be found on the ground. Finally, we will display at the ground station a high contrast flag 

or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches 

high or greater. Since the aircraft will operate within 1/2 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation; the 

documentation would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

approved Airplane Flight Manual must be available to the crew at the ground station anytime the 

aircraft is in, or preparing for, flight. This manual will include appropriate check lists to ensure 

airworthiness and flight ready status.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as 

pilot in command of an aircraft in connection with any business or employment if: (1) The flight is 

only incidental to that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire.

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over property where we have received the 

permission of the private land owner or in the case of public entity we will fly over the easement or 

right-of-way for State, County and Local survey missions. The land owner (private or public) will 

be briefed of the expected route of flight and the associated risks to persons and property on the 

ground. We maintain that due to the small size of the Tarot 650 and Tarot 690 aircraft and low 

weight @ 5-8 lbs, the hazard to persons, vessels, vehicles, and structures is not comparable to 

manned aircraft and should be considered in granting the exemption. (See appendix C section 6.4.1 

Consideration about risks related to ground impacts)

The aircraft will not be operated over congested areas nor over any open air assembly of persons. 

The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface.

14 CFR 91.121 Altimeter settings. 

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL 

and will not need to maintain hemispherical cruising altitudes in order to de-conflict with other 

aircraft. As such, an appropriate altimeter measurement presented to the pilot should be Above 

Ground Level and should be based on the barometric pressure at the point of launch. To provide an 

equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground prior to every 

flight. Since the aircraft will fly no more than 30 minutes, even rapid changes in barometric 

pressure will have limited effect on the safety of the flight.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of 

the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed 

inspections after every 5 hours. The PIC will document work performed in accordance with 91.417. 

We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an 

equivalent level of safety.
8900.227 Paragraph 16(c)(4) PIC Medical and Paragraph 16(e)(1) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or observer. The aircraft weighs 6.5 

pounds and is constructed out of plastic and carbon tubing. Requiring the crew to meet the same 

medical requirements as a commercial pilot carrying passengers in a large aircraft is an 

unnecessary burden. 

We propose that the minimum medical requirements be vision corrected to 20/20 and a valid, stateissued driver's license. Due to the size and weight of the aircraft, the greatest hazard of our 

proposed operation will be driving to the launch site. A licensed driver is medically qualified to 

operate a much larger vehicle. The 20/20 vision requirement will ensure that the PIC and VO can 

see and avoid air traffic. Given the unlikely event that both the PIC and VO become medically

incapacitated while the aircraft is in flight, the Inspire 1 will recover autonomously to the landing 

location designated prior to launch without crew intervention.
Appendix B

PRIVACY POLICY

One area of notable concern requiring attention regarding public and civil use of UAS technologies 

is personal privacy. A&R Video believes that an individual’s privacy is guaranteed by our 

Constitution and the Fourth Amendment and is sacrosanct and the potential for UAS technology to 

usurp those rights is very real. As with all new technology, we must move slowly in its application 

as we seek to include it in our daily lives. There are many emotional issues to overcome in the use 

of UAS technologies and part of our job in the UAS community is to ensure we educate and gain 

the trust of all people and to ensure we are ever mindful of their privacy concerns. Through 

demonstrated and responsible use and communication with the public, we can show that UAS can 

be used in a safe and effective manner in our National Airspace System.

A&R Video will comply with all federal, state, and/or local privacy policies or rules that may apply 

in particular areas where the Tarot 650 & 690 are used. Further, because we will only fly over 

property with the permission of the appropriate land owner, the likelihood that we will collect 

private information of an unknown person is minimal. Imagery will be reviewed in a secure 

location to ensure that only the requested imagery was obtained and any imagery that is considered 

private will be destroyed within 72 hours.
Appendix C

Safety Case

The Tarot 650 Quadcopter and Tarot 690 Hexacopter Aircraft have been custom constructed in 

house at A&R Video by Andrew Sommer. As PIC, Andrew Sommer has over 40 years experience 

constructing and flying a wide variety Radio Controlled Aircraft both fuel powered internal 

combustion engine and battery powered electric configurations. The components chosen for the 

construction are the finest available at the time of construction. (see Appendix C -1 with build 

components)

Each aircraft, Tarot 650 and Tarot 690, presently has over 20 hours of testing completed in various 

flight configuration to ensure safe, reliable and predicable flight performance in a variety of 

temperature and wind conditions. Having constructed and tested these aircraft in house there is the 

added advantage of a thorough understanding of each and every component that is used and how to 

competently test and evaluate them for safe flight. After any maintenance the aircraft will be test 

flown to ensure safe and reliable operation. 

Autopilot

The autopilot system used on the A&R Video Tarot 650 & Tarot 690 Aircraft is the DJI Naza V2 

M autopilot. The NAZA V2 M was introduced in 2013 and has had a very reliable and safe 

history. They have constantly sought to improve the capabilities and safety of the autopilot system 

to include a function that will not allow it to fly too close to airports. This function cannot be 

overridden and is hard coded into the software.

Operations

While the autopilot system supports functions at over 1.5 nautical miles (NM), with the exception 

request being sought by A&R Video, all flight operations will be within 1/4 NM of the pilot. This 

will allow line of sight operations in an extremely safe manner. It will allow for the pilot-incommand to maneuver the UAV in any needed manner to maintain a safe distance from other 

aircraft or people that may come within the safety envelope established before flight.

A&R Video will submit a written Plan of Activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of proposed filming. The PIC will also have a hand held 

radio to maintain contact with the closest ATC tower and / or local manned traffic. If there is an 

airport in the area that is not towered, then the radio will be tuned to the appropriate CTAF. It will 

be monitored 30 minutes before flight operations begin with warning calls that operations will 

begin at 15 min, 10 min, 5 min, and one minute intervals.

All flights will be conducted at or under 400 feet above ground level (AGL). If there are any 

manned aircraft within 3 NM, either operations will cease or if in contact with ATC, all operations 

will be conducted at 100 feet AGL with approval from local ATC. If there is manned activity with 

line of site of anyone associated with operations, all operations will cease until 10 minutes after the 

last sighting of any manned aircraft. Once the airspace is clear of manned aircraft, operations will

continue with coordination from local ATC.
Appendix C-1

Aircraft Components

AIRCRAFT # 1 : Tarot 650 Quadrotor

Tarot 650 airframe - carbon fiber 

Tiger Motor MN 3110-17 700kv motors (4)

Lumenier 30 amp ESCs - Simon K (4)

Lumenier 10 x 5 carbon props (4)

DJI NAZA V2 Controller

FrSky Taranis 9x Radio Control 2.4 ghz

Fatshark 250 milliwatt 5.8 ghz video transmitter - for camera down link

Tarot 2D 2 axis brushless camera gimbal 

GoPro Hero 4 Black camera

HK Multistar 8000 mah Lipo Flight Battery

AUW 5.5 lbs

Average flight time: 8.5 minutes with 2 minute reserve

AIRCRAFT # 2 : Tarot 690 Hexarotor

Tarot 690 airframe - carbon fiber

Cobra 2221-16 960 kv motors (6)

Lumenier 30 amp ESCs - Simon K (6)

Xoar 10 x 4 wood props (6)

DJI NAZA V2 Controller 

FrSky Taranis 9x Radio Control 2.4 ghz

Fatshark 250 milliwatt 5.8 ghz video transmitter - for camera downlink

DYS 3 axis brushless camera gimbal 

GoPro Hero 4 Black camera

HK Multistar 8000 mah batter7 2x in parallel 16,000 mah total 

AUW 7.5 lbs

Average Flight time: 12.5 minutes with 2 minute reserve
Appendix D

PRIVACY ACT INFORMATION - NOT FOR PUBLIC RELEASE

AVIATION EXPERIENCE

As the A&R Video pilot, I, Andrew Brian Sommer, have manned and unmanned aviation 

experience. I hold an FAA license for commercial pilot and instrument rating, airplane single engine 

land. I graduated from the Florida Institute of Technology with a degree in Air Commerce Flight 

Technology in 1983. Pursuant to this degree, I learned how to operate multiple fixed wing manned 

prop driven aircraft. After graduation I did not a pursue commercial position in the aviation industry 

and moved on to my present position as owner operator of a photo / video production company, 

A&R Video in partnership with my wife Rowena Sommer. 

With the advent of GPS and stabilization technology in the early 2000s, I decided to integrate my 

passion for aviation with my professional imaging business. From 2010 to the present I have studied 

all the various emerging technologies relating to small UAV operations. Experimenting in the safe 

environment of Academy Of Model Aeronautic (AMA) sanctioned airfields. Now with this industry

maturing explosively, I feel there is a need for experienced UAV Pilots and UAV operations who 

have a clear understanding for a higher level of competency and safety need when flying near the 

public and adjacent to manned airspace. I would like to take a leading position in this growing 

industry. 

I have been flying radio controlled aircraft since 1975 building and learning to fly my first aircraft at 

age 15 while still in high school. Over the past 40 years I have constructed and successfully operated 

dozens of radio controlled aircraft of all types of configurations. Over this time I estimate I have 

well over 2000 flight hours on radio control aircraft. In that time I have instructed approximately 20 

individuals in the safe operation of radio control aircraft conducting side by side training and 

evaluation prior to allowing solo operations by the trainees. 

Pilot Name Total Manned 

Hours

Total Unmanned 

First Name Last Name Hours

Andrew Sommer 210 2000+ (40 years)

NOTE: As of 8/21/2015 Andrew Brian Sommer's commercial certificate uses the old Social Security number 

system. A request for a new number to be issued has been submitted to the FAA Oklahoma City office. 

PRIVACY ACT INFORMATION - NOT FOR PUBLIC RELEASE