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 services 

to commercial and residential 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 existing business’s by providing 

guidance, training, and other services. We also provide our clients with pilots and aircraft to

assist with clients data 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 additional training 

covering both relevant subjects included in the recreational or private pilot written tests and 

those subjects unique to UAS operations. 

Prior Exemptions

Synergy UAS does not hold any exemptions at this time.This petition is based, in part, upon

prior exemptions granted pursuant to the following;

• Exemption No. 11138 - Douglas Trudeau, Realtor (Regulatory Docket No. FAA-2014-

0481, January 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 & Aldridge LLP (Regulatory Docket No. FAA2015-0155)

1029	Paseo	Entrada

Chula	Vista,	CA	91910

synergyuas@cox.net

619-520-6718
Synergy	UAS	Inc.	Petition	for	Exemption 2

Exemptions 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 

photography, aerial survey and mapping, infrastructure inspection, 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 Cirrus 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, 11112, and 11213, issued under Title 14, Code of 

Federal Regulations.

Relief Requested Description Relief Granted Prior 

Exemption No.

61.51(b) Pilot Logbooks 11138

61.89(a)(3)(4) Student Pilot Certificate None

61.113 Private Pilot Certificate 11140

91.7(a) Preflight Inspection in lieu of Airworthiness Inspection 11138

91.103 Preflight Action 11062

91.105 Use of Seatbelts 11062

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 Exemption

FAR §61.51 Pilot Logbooks

Prescribes for documentation of, inter alia, (a)(1) ”...training and aeronautical experience 

used to meet the requirements for a certificate, rating, or flight review of 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 existing 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 lieu 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) Student 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 requirement 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 the 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 knowledge 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 medical 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 this exemption (Phantom 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 observers in actual commercial 

flights but will not receive flight instruction during these operations. The purpose of this 

is to help students gain understanding site environment, communication challenges,

and site safety analysis. The importance of following 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 aeronautical knowledge test as described in §61.94 

(Student Sport Pilot endorsement to operate in class B, C, and D airspace.)

FAR §61.89(a)(3)(4) Student Pilot Privileges and Limitations

Covers 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 aeronautical 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 class 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 will greatly benefit because if 

approved, Synergy 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 student 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 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.”

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 information:

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 connection 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 

fastened.

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 crewmembers 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 allowing, 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 areas. 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 directly 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 missions will require flights in the designated yellow graphic as depicted 

on VFR sectional and Class B charts. 

Our method to mitigate safety hazards 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 outlined 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 500 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 distance of 150 ft. This is not an absolute minimum however. Depending on the 

circumstances, the minimum distance will be extended to distances greater than 150 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

Requires, 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 MSL. 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 begin 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. The FAA has previously granted 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, 

with careful preflight planning, the DJI software allows activation of the automatic return to 

launch when the battery capacity 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 the event the battery reaches a critical level (20%), the 

aircraft will initiate an automatic landing. An emergency landing area or zone will be preidentified and secured so as to mitigate any potential injury to persons on the ground or 

damage to property.

FAR §91.405(a) Required Maintenance

Requires, 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, have discrepancies 

repaired as prescribed in part 43 of the chapter”. 

Synergy UAS requests relief on the grounds that Pilot in Command, prior 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 preflight 

inspection. 

FAR §91.407(a)(1) Operation after Maintenance

Prohibits “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 of the same chapter.”

Synergy UAS request relief on the grounds that our Operating Manual requires all 

maintenance and alterations to be properly documented in the aircraft records. UAS 

maintenance or alterations that affect the UAS operation or flight characteristics 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 aircraft 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 operate 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 requires 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 records, including total flight duration, description 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) Maintenance Records

Prescribe, that “(a) Each registered owner or operator 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 inspections, 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, inspections, 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 records, including total flight duration, description of work accomplished, and the 

signature of the 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 thrive. 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. However, 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 invest 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 20th 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 driver 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 with 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” Association 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 first, 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 drone 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 certificate 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 grant 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 limited 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 certificate no different than a private, commercial, or ATP rated pilot. 

Approval of this petition provides a safety benefit because it provides new entrants a way to 

legally integrate UAS’s under the existing regulatory framework. Our business places great 

emphasis 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 final 

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-public-so-what/

6 “FAA Risks Losing Drone War” Politico Magazine 2014, http://www.politico.com/story/2014/02/federal-aviationadministration-faa-drones-103800.html

7 https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/media/Contend_Corporation_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 received 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 Phantom

DJI Phantom is an 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), which 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, 

Realtor). 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 station 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 originally 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 Aviator. Subsequent to his military 

service, he flew for a major international air carrier and worked in that carriers training 

department as a simulator instructor. He currently holds an ATP with A330, A320, 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 certificate 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 proposed 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 national security. The proposed UAS operations 

will benefit the public by improving 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.

Respectfully 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