### Synergy	UAS	Inc .	Petition	for	Exemption 1 Petition for Exemption

Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704

Petitioner
This petition is submitted pursuant to 14 CFR § 11.81, by Mr. Robert Walker, on behalf of Synergy UAS Inc.

, a California Corporation. Mr. Walker is the President and Chief Executive Officer of Synergy UAS Inc.

Executive Summary Synergy UAS is a commercial Unmanned Aircraft System operator whose principal place of

business is in Chula Vista California. Our business model focuses on providing UAS ser vices
to commercial and reside ntial real estate professionals, aerial mapping for land surveyors and GIS Internet applications, and infrastructure inspection for utility companies. Consult

clients that desire to integrate small UAS systems into their exist ing business’s by providing guidance, training

, and other services

. We also provide our clients with pilots and aircraft to
assist with clients d ata collection and data processing needs.

Unique to this exemption is a request to permit the PIC to possess a student pilot certificate.

The student must pass an aeronautical knowledge test, obtain and record additiona l training covering both relevant subjects included in the recreational or private pilot written tests and those subjects unique to UAS operations

.

Prior Exemption s

Synergy UAS does not hold any exemptions at this time. This petition is based, in part, upon prior exemption s granted pursuant to the following;

• Exemption No. 11138

- Douglas Trudeau, Realtor (Regulatory Docket No. F AA

- 2014

- 0481, Janu ary 5, 2015)

• Exemption 11326

– PPL Electric Utilities Corp. ( Regulatory Docket No. FAA

- 2015

- 0020, April 16, 2015)

• Exemption No. 11394

- Cirrus Exploration Company (Regulatory Docket No. FAA

– 2015

– 0160 , April 20, 2015)

• Exemption No. 11400

- McKenna Long & Al dridge LLP (Regulatory Docket No. FAA

2015

- 0155) 1029	Paseo	Entrada Chula	Vista,	CA	91910 synergyuas@cox.net
619

- 520

- 6718

### Synergy	UAS	Inc .	Petition	for	Exemption 2 Exemption s Requested

Synergy UAS has a diverse fleet to meet the needs of various applications and respectfully requests relief from the following regulations for the purpose of conducting aerial

p hotograp hy, aerial survey and mapping, i nfrastructure inspec tion, training, and consulting using a DJI S900, DJI Phantom I, and Skywalker X

- 8.

The requested exemptions below are nearly identical to those granted by Douglas Trudeau in his exemption 11138, and Cirr us Exploration Company, exemption no. 11394. This petition incorporates by reference prior exemptions as cited in Trudeau’s petition. Those are exemptions include Nos. 11062, 11109, 1 1112, and 11213, issued under Title 1 4, Code of Federal Regulations

.

Rel ief Requested Description Relief Granted Prior Exemption No. 61.51(b) Pilot Logbooks 11138

61. 89 (a)(3)(4) Student Pilot Certificate N one

61.113 Private Pilot Certificate 111 40 91.7(a) Preflight Inspection in lieu of Airworthiness Inspection 11138

91.103 Preflight Action 11062

91.105 Use of Seatbelts 1106 2

91.119 (b) Operation over congested areas None

91.119 (c) Minimum Safe Altitude 11138

91.121 Altimeter Settings 11138
91.151(a) Reserve Fuel (battery) 11140 91.405(a) Preflight Inspection in lieu of an100 hour inspection 11138
91.407(a)(1) Preflight Inspection in lieu of return to service certification 11138

91.409(a)(1) and (2) Preflight Inspection in lieu of annual airworthiness inspection 11138

91.417(a) and (b) Preflight Inspection in lieu of maintenance logbook records 11138

### Synergy	UAS	Inc .	Petition	for	Exemption 3 Reasons for Exemp tion

FAR § 61.5 1 Pilot Logbooks

P rescribes for documentation of, inter alia, (a)(1) ”

... training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review o f this part ” , and (a)(2)”

... The aeronautical experience required for meeting the recent flight experience requirements of this part ”.

Synergy UAS acknowledges that training and experience is important and that there needs to
be some form of documentation. In addition to training our own employee’s

, we provide
services to customers desiring to train their own operators on the safe and efficient use of unmanned aircraft. However, since there is no existing training and experience requirement

under the existi ng FAR’s, we do not believe it necessary to maintain logbook entries as detailed in 61.51(b) to document such training.

Synergy UAS proposes to maintain a separate record of training flights that include the date

, location, duration , and make/model in lie u of a pilot logbook. Since all flight will be restricted to day VMC, there is no need to log whether the flight was under night or IFR. Also, since all flights will remain line of sight, there is no need to log cross country flight time.

FAR 61.89(a) Stu dent Pilot Certificate Previous exemptions have been granted requiring the UAS pilot/operator to possess at least a private pilots certificate and class III medical certificate . The proposed sUAS NPRM has eliminated the private pilot certificate requiremen t and proposes to replace it with a UAS
certificate pursuant to proposed FAR § 107.53

. 1 According to the proposed rule, the only requirement for issuance of the UAS certificate is passing a written aeronautical knowledge test administered by the FAA under t he CFR Part 61.

The FAA considered a request by Trudeau to eliminate the requirement of a UAS operator to hold a minimum of a private pilots certificate issued under 61.113. In response, the FAA commented in Exemption 11138, “ the FAA does not possess the authority to exempt the petitioner from the statutory requirement to hold an airman certificate, as prescribed in 49 USC § 44711 “ 2

In keeping within its statutory authorizations, Synergy UAS proposes an exemption that permits a pilot in command to hold a student pilot certificate issued pursuant to § 61.94. That section permits student pilots acting as PIC to fly within Class B, C, & D, airspace provided adequate flight and ground instruction covering the aeronautical knowl edge prescribed under 61.94(a).

1 NPRM sUAS Docket ID: FAA

- 2015

- 0150

- 0017

2 http://www.faa.gov/uas/legislative_programs/section_333/media/trudeau_douglas

- 11138.pdf 2 http://www.faa.gov/uas/legislative_programs/section_333/media/trudeau_douglas

- 11138.pdf

### Synergy	UAS	Inc .	Petition	for	Exemption 4 Synergy UAS hereby petitions to follow along the same path as the proposed rule. That is,
allow student pilots employed and trained by Synergy UAS to hold a Student Pilot Certificate

issued § 61.81, et seq., subject to the following modification;

1. Until FAR § 107.73 becomes a final rule, Synergy UAS believes that an equivalent level of safety is obtained by requiring the student pilot to pass the aeronautical knowledge test covering subjects proposed in the sUAS NPRM part 107

.

2. Hold at least an FAA Class III m edical certificate issued under part 67 of 14 CFR Title

14.

3. Before a pilot is permitted to “fly solo” for commercial purposes, he or she will document at least 25 flights of at least 5 minutes duration on each aircraft approved

under th is exemption (Phanto m and S900), and have a log book endorsement to such. Each pilot will also complete a series of Initial Operating Experience (IOE) flights under the supervision of an instructor pilot prior to being authorized to conduct commercial activity. The length of IOE will be vary depending on pilots proficiency.

4. Recency of experience will be maintained by performing 3 takeoffs and landings every 90 days in compliance with § 61.57(a) , except the 3 take off and landing must include maneuvering flight in manual or GPS assisted modes.

5. Training flights will be dedicated training events under supervision of instructor employee’s of Synergy UAS. No training other than IOE will be conducted during a commercial flight.

6. Students will be encouraged to participate as visual obs ervers in actual commercial flights but will not receive flight instruction during these operations. The purpose of this is to help s tudents gain understanding site environment , communication challenges, and site safety analysis . The importance of followin g proper preflight procedures will be emphasized.

7. For operations within the lateral boundaries of class C and D airspace, student will be given instruction and must pass a eronautical knowledge test as described in § 61.94 (Student Sport Pilot endorsement t o operate in class B, C, and D airspace.)

FAR § 61.89(a) (3)(4) Student Pilot Privileges and Limitations
C overs limitations for pilots holding a student pilot certificate. Synergy UAS seeks exemption
from § 61.89(a) “ A student pilot may not act as pilot in command of an aircraft: (1) That is carrying a passenger; (2) That is carrying property for compensation or hire; (3) For compensation or hire; (4) In furtherance of a business;

### Synergy	UAS	Inc .	Petition	for	Exemption 5 If the exemption to permit a student pilot certificate in lieu of a private pilot certificate is granted, then an exemption from § 61.89(a) (3) and (4) is hereby requested.

The a eronautical knowledge required by a student pilot is adequate to provide the UAS pilot an equivalent level of safety as a student pilot flying solo in cla ss B, C, or D airspace.

Synergy UAS believes that until FAR 107 becomes effective, the FAA can begin the process of drawing existing operators into compliance in an efficient and economic manner by approving this exemption

. Our customers and the public w ill greatly benefit because i f approved, Syne rgy UAS training system will not only comply with all applicable regulations regarding the endorsement of the student pilot certificate and logbook, in the same fashion a certified flight instructor endorses a s tudent pilot to operate in controlled airspace, but also, promote a safety culture that is currently lacking.

FAR § 61.113(b ) Private Pilots
Provides that “ A private pilot may, for compensation or hire, act as pilot in command of an
aircraft in connectio n 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. ”

In the alternative, if our petition to allow our pilots to hold a student pilot certificate is denied and a private pilot certificate is required, then we request exemption to 61.113(b), the same as other operators similarly situated have been granted exemptions.

FAR § 91.103 (b) Preflight action. Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance informa tion:

Our Operation Manual contains procedures for compliance with 91.103(a). Synergy UAS seeks relief from sub

- paragraph (b), because, our multirotor aircraft does not need to use a runway and is not likely to be operating to or from an airport. Our X

- 8 is hand launched and only requires minimal area for landing. Safety conflicts with manned aircraft are completely eliminated because we will not operate in or around airports outside the scope of our operations manual or this exemption.

FAR § 91.105 Flight crewmembers at stations. ( a) During takeoff and landing, and while en route, each required flight crewmember shall

— (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in c onnection with physiological needs; and

### Synergy	UAS	Inc .	Petition	for	Exemption 6 (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

— (1) The seat at the crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be unable to perform required duties with the shoulder harness fasten ed.

Relief is requested to be exempt from 91.105(a) and (b) to the extent crewmembers are required to be seated with seat belts fasten. Our UAS operators may be standing or seated depending on the specific mission. The safety concern for having crewmember s fasten seatbelts is not applicable to unmanned operations.

FAR § 91.119 Minimum Safe Altitudes Prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude all owing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

Synergy UAS intends to abide by this regulation by incorporating it into our company operations and procedures manual.

(b) Over congested are as. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

Synergy UAS does not intend to fly direct ly over open air assembly of persons such as sporting events, public gatherings, etc., where large groups of people are likely to congregate. Flying over open assembly of persons is prohibited in our policy and procedures manual and violates FAR 91.119(a).

However, we do foresee a need for some relief because part of the real estate photography and aerial mapping mission s will require flights in the designated yellow graphic as depicted on VFR sectional and Class B charts.

Our method to mitigate safety h azards to persons and property on the ground is outlined in our policy and procedures manual in greater detail than is presented here . When a mission requires flights within the yellow congested areas, a feasibility check and site safety
assessment as outl ined in our Operating Procedures Manual will be mandatory

.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 5 00 feet to any person, vessel, vehicle, or structure.

### Synergy	UAS	Inc .	Petition	for	Exemption 7 Relief is request from subsection (c) because our flights will by nature be below 500’ AGL. With respect to safe distances from non

- participating personnel, our policy manual prescribes a minimum dist ance of 1 50 ft. This is not an absolute minimum however. Depending on the circumstances, the minimum distance will be extended to distances greater than 1 50 ft from the UAS when the aircraft is operated at higher altitudes near personnel, or when obstacles are such that the proposed flight path demands greater standoff distances.

FAR § 91.121 Altimeter Settings
R equires, in pertinent part, 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 setting available before departure. "

Synergy UAS requests relief because the UAS system is incapable of adjusting the altimeter setting and the telemetry system does not report altitude in MS L. Furthermore, this section is not applicable because all altitude reports to a local ATC facility, when necessary, will be referenced in feet above ground level (AGL) from the control station.

FAR 91.151(a) Reserve Fuel Prescribes that “ no person may be gin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes [emphasis added] ”

.
Synergy UAS SOP requires that no takeoff is permitted unless the battery capacity is sufficient to takeoff, fly the intended mission, and land with at least 20% battery capacity remaining. Th e FAA has previously grante d exemption 11138, which required a minimum 30% battery reserve remaining.

Synergy believes that 20% represents a realistic reserve capacity that allows mission durations of 18 minutes for the DJI S900 and 10 minutes for the DJI Phantom. Furthermore, wit h careful preflight planning, the DJI software allows activation of the automatic return to launch when the battery c apacity reaches a predetermined battery level. The telemetry system transmits a visual “ low battery warning ” when the capacity reaches this predetermined level alerting the pilot to either manually or automatically return the aircraft to the launch point.

This predetermined level is set during preflight planning and depends of the route of flight, distance to home, and altitude. In th e even t the battery reaches a critical level (20%) , the aircraft will initiate an automatic landing. An emergency landing area or zone will be pre

identified and secured so as to mitigate any potential injury to persons on the ground or damage to property.

FAR § 91.405(a) Required Maintenance
R equires, in pertinent part, “ that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required

### Synergy	UAS	Inc .	Petition	for	Exemption 8 inspections, except as provided in paragraph (c) of the same section, h ave discrepancies repaired as prescribed in part 43 of the chapter ”

.
Synergy UAS requests relief on the grounds that Pilot in Command , p rior to each flight, will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the pref light inspection.

FAR § 91.407(a)(1) Operation after Maintenance
P rohibits “ any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under § 43.7 o f the same chapter. ”

Synergy UAS request relief on the grounds that our Operating Manual requires a ll maintenance and alterations to be properly documented in the aircraft records. U AS maintenance or alterations that affect the UAS oper ation or flight charact eristics will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry in the aircraft records prior to the aircraft is released to return to service.

FAR 91.409(a) Inspections Prescribes that “ no person may operate an airc raft unless, within the preceding 12 calendar months, it has had

— (1) an annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) that no person may ope rate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ”

Synergy UAS requests relief on the grounds that our Operating Manual requir es the operator
to carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft recor ds, including total flight duration , descrip tion of work accomplished, and the signature of the authorized person returning the UAS to service. Additionally, our SOP requires compliance manufacturer Safety Bulletins and Notices.

FAR 91.417(a) and (b ) Maintena nce Records Prescribe, that “ (a) Each registered owner or o perator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved in spections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.

Synergy UAS requests relief on the grounds that our Operating Manual requires the operator
to carry out its maintenance, ins pections, and record keeping requirements, in accordance

### Synergy	UAS	Inc .	Petition	for	Exemption 9 with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft recor ds, including total flight duration , description of work accomplished, and the signature of t he authorized person returning the UAS to service. Additionally, our SOP requires compliance with manufacturer Safety Bulletins and Notices.

Public Economic Interest and Benefit

According to a leading unmanned vehicle trade organization, a new industry is being born and is poised to t h rive. AUVSI’s The Economic Impact of Unmanned Aircraft Systems Integration in the United States report shows the economic benefit of UAS integration. 3

These estimates have received some criticism regarding accuracy. Howev er, Synergy UAS views these estimates as just that, an estimate. Ultimate accuracy remains unclear due to many factors. What is clear, is that the AUVSI study highlights the point that there benefits to society in terms of economic impact, tax revenue, and jobs.

As a California company, Synergy UAS will be a participant in the economic development of the state. We will provide jobs, pay taxes, and i nvest capital . AUVSI predicts annual employment in California will reach 15,000 jobs, and total spending and economic impact will
reach $1.5B by 2021. 4

Public Safety Interest and Benefit

According to several news media sources, illegal UAS activity is a growing concern. The state of this emerging industry is analogous to the turn of the 20 t h Century when the automobile replaced the horse and buggy . During that period, people started buying and using Henry Ford’s automobiles . There were no paved roads, street signs, traffic lights, or rules of the road. The people who drove their cars safely followed common sense. Unfortunately, there were accidents because others either ignored common sense or ignored basic laws of physics. Until the streetlight was invented, when two cars approached an intersection, the prudent driver would stop and let the other car pass first. Often times, neither driver wanted the other to go first. Order had to be established . The public demanded basic rules of the road. Even then, accidents continued to occur in great numbers . The accident rate began to decrease after dr iver education became commonplace. This coupled with advances in technology made driving safer.

3 “

AUVSI’s findings show that in the first three years of integration more than 70,000 jobs will be created in the United
States w ith an economic impact of more than $13.6 billion. This benefit will grow through 2025 when we foresee more than 100,000 jobs created and economic impact of $82 billion ”. “The Economic Impact of Unmanned Aircraft Systems Integration in the United States” A ssociation for Unmanned Vehicle Systems International, 2013.
4 Id.

### Synergy	UAS	Inc .	Petition	for	Exemption 10 The UAS industry is at the same cross roads the automobile was 100 years ago. While we await FAA regulations to help sort out who goes firs t, illegal activity is underway and can be mitigated as we develop training standards.

This petition plays a small but significant role in helping to bridge the gap between illegal operators fulfilling a public need and the FAA ’s statutory mandate for public safety . Our business model plays a significant role to help clients integrate UAS systems into their existing workflow . There is a lot of confusion regarding the status of regulation and patience is waning. 5

“ The result, observers and drone users warn, could be a Wild, Wild West in the nation’s skies. As
small dron e operators grow used to flying them without the FAA’s permission, they could become less inclined to obey any rules the agency puts in place. And with the cost of the technology continuing to drop, the drones could eventually become far too ubiquitous for the agency to police.” 6

Past exemptions denied requests to eliminate the need to possess a private pilots certificate. The Airline Pilots Association (ALPA) takes the view that since commercial UAS is a commercial enterprise, a commercial pilots certific ate should be required. The FAA has rejected this argument and granted exemptions on the condition the UAS operators possess
or obtain an airline transport, commercial, private, recreational, or sport pilot certificate. 7

Synergy UAS recognizes that any gr ant of exemption will require some form of airman
certificate. Our research has not found any request or denial for use of a Student Pilot
Certificate. Pursuant to 14 CFR § 61, a student pilot certificate is an airman certificate. The
holder can exercise lim ited privileges and provides the agency appropriate jurisdiction to hold the certificate holder accountable to the Federal Aviation Regulations.

A student pilot who violates the FAR’s is subject to the same enforcement action against his
or her certifica te no different than a private

, commercial , or ATP rated pilot.

Approval of this petition pro vides a safety benefit because it provides new entrants a way to legally integrate UAS’s under the existing regulatory framework. Our business places great empha sis on safe operating practices to a greater degree than the current status quo

.

Even after FAR § 107 is published, Synergy UAS foresees the need for UAS businesses to establish training and safety standards. We are hopeful that FAR § 107 will become a fin al rule even before this petition is fully considered. However, we believe that even if our request to permit student pilots rendered moot as a result of publication of the final rule, the industry

5 “ FAA Says Commercial Drone Operations Are Illegal... Public Says So What ? ” Geo Spatial Solutions, February 28,
2014. http://geospatial

- solutions.com/faa

- commercial

- drones

- are

- illegal

- publi c

- so

- what/

6
“ FAA Risks Losing Drone War ” Politico Magazine 2014, http://www.politico.com/story/2014/02/federal

- aviation

administration

- faa

- drones

- 103800.html
7 https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/media/Contend_Corpo ration_11400.pdf

### Synergy	UAS	Inc .	Petition	for	Exemption 11 will eventually establish training and operating standards similar to civil and military aviation does today.

Exempted Aircraft

DJI S900 DJI S900 is a multirotor an electrically powered UAS designed for aerial photography and video. The system consists of a ground control station, camera gimbal, HD camera, and video monitor. The S900 maximum weight including payload is 8 kg (17.6 lbs ), which falls

well below the 55 lbs. limit for sUAS class aircraft. This system will be used in real estate, utility infrastructure, and 3D modeling applications.

The S900 has rece ived approval for use in Exemption 11326 (PPL Electric Utilities Corp), and Exemption 11400 ( McKenna Long & Aldridge LLP ) . Our proposed use is similar in all material respects as those being used in Exemption Nos. 11062, 11109, 11112, and 11213

.

DJI Phant om DJI Phantom is a n electrically powered multirotor UAS designed for aerial photography and video. The system consists of a ground control station, camera gimbal, GoPro camera, and iPhone video monitor. The Phantom’s maximum weight is 1.3 kg (2.8 lbs), wh ich is within the sUAS class and within the micro UAS weight limit (4.4 lbs) under the proposed NPRM § 107. This system will be used in the same applications as the S900.

The DJI Phantom has received approval for use in Exemption 11138 ( Douglas Trudeau,

R ealtor ). Our proposed application of the Phantom will be in similar in all material respects as Exemption Nos. 11138, 11062, 11109, 11112, and 11213

.

Sky Walker X

- 8

The X

- 8 is a fixed wing, electrically powered flying wing UAS designed for aerial mapping and surveying. The aircraft is made of durable foam and has a maximum weight of 3.2 kg (8 lbs ),

which falls below the 55lbs limit for sUAS class aircraft. This system utilizes the 3DR Pixhawk Flight Controller and APM flight planning software. The ground s tation consists of a 2.4Ghz

remote control box, which permits manual or autonomous control during flight. The APM also allows for computer guided waypoint navigation for precise ground tracks necessary for aerial mapping applications. The X

- 8 was originall y designed as a hobby grade model aircraft. However, Synergy UAS chose to install the 3DR flight control system, which makes it a commercially viable UAS.

The Sky Walker X

- 8 flying wing has been the subject of an exemption request by Trumbull

Unmanned.

### Synergy	UAS	Inc .	Petition	for	Exemption 12 Conclusion

Mr. Walker is a career pilot and flight instructor with over 36 years experience. He soloed at 16, became a CFI at 18, and then served as an operations pilot for a major defense contractor before serving 7 years active duty as a Naval Aviato r. Subsequent to his military service, he flew for a major internation al air carrier and worked in that carriers training department as a simulator instructor. He currently holds an ATP with A330, A 320, and B737 type ratings. He also possesses a Commercial Pilot Rotorcraft, Flight Engineer Turbojet, Airframe & Powerplant Mechanics certificate, and has held Certified Flight Instructor certificates. As a principal in the organization, Mr. Walker is well suited to establish and administer standardized training to employee’s and potential clients in UAS operations using the aircraft described in this exemption.

With respect to the student pilot certificate request, a student pilot certificate is generally issued in conjunction with an FAA Class III medical cer tificate for sport and private pilot students. If approved, this exemption can be viewed as a naturally efficient method to draw existing non

- compliant UAS operators into a safety culture that eases the transition towards the regulatory environment as prop osed by FAR Part 107.

Synergy UAS’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS and n ational security. The proposed UAS operations will benefit the public by improv ing safety and reducing risk to humans. This Petition for Exemption provides the FAA adequate justification for granting the requested exemptions allowing Synergy UAS to provide training and perform aerial work using small UAS.

Thank you for your prompt consideration of our requested exemptions. Should you have any questions, or if you need any additional information, please do not hesitate to contact us at your convenience.

R espectfully Submitted

,

______________________ Robert Walker, President Synergy UAS Inc.

Appendix

- Supporting Manufacturer Documents

Spreading Wings S900 User Manual DJI Phantom User Manual SkyWalker X

- 8 User Manual Synergy UAS Operating Manual