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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC.

REGARDING THE PETITION FROM:

Tom Sondreal Media Productions

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS (14 CFR) PART 21 SECTIONS 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 

91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 

and 91.417(a) and (b). CONCERNING OPERATION OF SMALL UNMANNED AIRCRAFT SYSTEMS (sUAS) 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted Electronically on February 24, 2016

Tom Sondreal Media Productions

Thomas J. Sondreal – President

817 Barrette ST.

Crookston, MN 56716

Phone: (218) 230-4963

Email: tomsondreal@gmail.com
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Table of Contents:

Glossary of Abbreviations & Terms ................................................................................................. 2

List of Attachments ........................................................................................................................ 2

Exemption Request......................................................................................................................... 3

Proposed Unmanned Aerial System....................................................................................................... 4

Requested Exemptions from Regulations.............................................................................................. 5

Extent of Relief Tom Sondreal Media Productions Seeks and the Reason it seeks such Relief...... 5

Public Interest............................................................................................................................................. 10

Reasons Why the Exemption will not Adversely Affect Safety............................................................. 11

Summary the FAA May Publish in the Federal Register........................................................................ 12

Additional Background Information......................................................................................................... 13

Glossary of Abbreviations & Terms

2D/3D Two-Dimensional and Three-Dimensional

AGL Above Ground Level

AMA Academy of Model Aeronautics

C.F.R. Code of Federal Regulation

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

NAS National Airspace System 

NOTAM Notice to Airman

PIC Pilot in Command

sUAS Small, Unmanned Aircraft Systems

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VLOS Visual Line of Sight

VFR Visual Flight Rules 

VO Visual Observer

List of Attachments:

The following attachments are referenced in the request for exemption which follows. These 

documents provide additional evidence in support of Tom Sondreal Media Productions petition to the 

FAA.

Attachment 1 3DR SOLO User Manual

Attachment 2 Academy of Model Aeronautics (AMA) Safety Code

Attachment 3 FlySafeTraining.org Guidelines / Flight Checklists
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Exemption Request from Tom Sondreal Media Productions

February 24, 2016

United States Department of Transportation

Docket Operations

West Building Ground Floor Room W12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012, 

Public Law 112-95 February 14, 2012

I, Thomas J. Sondreal, am writing on behalf of my company, Tom Sondreal Media Productions, regarding 

the FAA Modernization and Reform Act of 2012 (Reform Act) and the procedures contained within 14 

C.F.R. 11, with a request to be exempted from Part 21, as well as other sections of Title 14 of the Code 

of Federal Regulations, as described in the following pages. The requested exemption will allow Tom 

Sondreal Media Productions to operate small, unmanned aircraft systems (sUAS) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”).

I plan to combine my multimedia skills with aerial imaging and computer animation to provide 

videography services, and two-dimensional (2D) and three-dimensional (3D) visualization services to 

support various industries including, but not limited to, Inspection, Construction, Mining, Agriculture, 

Manufacturing, Insurance, Forestry & Timber, Environmental, Search & Rescue, and Property 

Development. Recognizing the tremendous need, as well as the many public benefits associated with 

offering such services, I am moving forward and amending my business plan to include seeking and 

securing an exemption to commercially operate our sUAS in accordance with the FAA’s safety standards 

and regulations. I believe the operations proposed in the petition which follows will fully qualify for 

approval under Section 333 of the Reform Act. Under this proposal, Tom Sondreal Media Productions

would be permitted to use small, unmanned aerial systems (sUAS) under controlled conditions in 

airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) would provide an 

increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish 

the same purpose. Tom Sondreal Media Productions will utilize small, multi-rotor quad copters, 

equipped with digital cameras. The units will be operated under normal, daytime conditions at a speed 

of no more than 30 knots. The sUAS will always be operated within the visual line-of-sight (VLOS) of the 

pilot in command (PIC) and within a controlled area. Such operations will insure that the sUAS will "not 

create a hazard to users of the National Airspace System or the public." My petition for exemption is 

submitted under the authority of the FAA Modernization and Reform Act. Under this Act, Congress 

directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the 

national airspace system." Under Section 333 of this law, the Reform Act directed the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely in the 

National Airspace System ("NAS") before completion of the rulemaking required under Section 332 of 

the Reform Act. According to the Reform Act, the Secretary has the authority to grant exemptions from 

its safety regulations and minimum standards when a requested exemption is deemed to be in the 

public interest. Anyone requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole, and; (2) would not adversely affect safety. Based on this exemption 

process, I submit the following petition for your consideration. 

NOTE: Tom Sondreal Media Productions will submit a Certificate of Authorization (COA) application as 

part of the exemption sought by this Petition and will apply for FAA drone registration upon ownership.
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Proposed Small, Unmanned Aircraft Systems (sUAS):

Tom Sondreal Media Productions proposes to utilize a 3DR SOLO drone for capturing digital images. This

multi-rotorcraft sUAS has four motors and propellers in a quadcopter configuration weighing roughly 4

pounds, including camera and payload. It is equipped with an onboard computer stabilization 

controller, Global Positioning System (GPS) and a handheld ground control station. The 3DR SOLO

provides the pilot in command (PIC) with an ability to hover and move in vertical and horizontal planes, 

both independently and simultaneously. The proposed aircraft also feature a software application that 

allows the PIC a means of monitoring the flight’s performance via a smart phone or tablet to provide the 

PIC with a real time display of the altitude, battery life, GPS connections and camera view.

3DR SOLO Specifications:

Solo is a quad-rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and APM:Copter flight control software. Solo 

communicates with the controller and Solo app over the 3DR Link secure Wi-Fi connection.

Autopilot: 3DR Pixhawk 2

Flight code: ArduPilot Copter

Control: 3DR Solo Controller

Wireless communication: 3DR Link 1.0

Frequency: 2.4 GHz

Height: 10 in. (25 cm)

Motor-to-motor dimension: 18 in. (26 cm)

Propulsion: 880 KV motors, two clockwise rotating motors and two

counterclockwise rotating motors

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm)

Weight with battery: 3.3 lbs. (1.5 kg)

Controller battery life: 3 hours 

Extended controller battery life: 6 hours

Controller battery: Li-ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery)

Power: Electric (rechargeable lithium polymer battery)

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc

Battery weight: 1 lb. (.5 kg)

Estimated flight time: 25 minutes, 20 minutes with payload*

Maximum altitude: 400 ft. per FAA regulation, user adjustable (122 m)

Range: .5 miles**(.8 km)

Payload capacity: 1.1 lbs. (500 g)

Cruise speed: 5.7 mph (2.5 m/s)

Maximum speed: 55 mph (25.5 m/s)

Maximum climb rate: 11 mph (5.0 m/s)

Maximum descent rate: 5.5 mph (2.5 m/s)

Headwind limitation: 25 mph (11 m/s)

Crosswind limitation: 25 mph (11 m/s)

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4 Full

compatibility with GoPro® HERO 4

Solo app compatibility: iOS 8.0 or later / Android 4.3 or later

Operating temperature: 32° F - 113° F (0° C - 45° C)

Operating relative humidity: 0-85% RH

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed flight time 

applies to elevations less than 2,000 ft above sea level.

**Range varies with location, antenna orientation, background noise and multi-path.
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Requested Exemptions from Regulations:

The specific sections of Title 14 of the Code of Federal Regulations from which Tom Sondreal Media 

Productions requests exemption:

Tom Sondreal Media Productions, requests an exemption from Part 21, Subpart H; and Sections 

45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) 

and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal 

Regulations.

The Extent of Relief Tom Sondreal Media Productions Seeks and the Reason it 

seeks such Relief:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificate, and 14 C.F. R. Section 91.203(a) & (b): Carrying 

Civil Aircraft Certification and Registration

We are seeking an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for issuing and displaying airworthiness certificates as required by 14 C.F.R. Sections 

91.203 (a) & (b). At the present time, no such certificates are available to be issued for airworthiness of 

the sUAS devices utilized by Tom Sondreal Media Productions. Furthermore, the small size of the 

aircraft, coupled with the limited surface area, makes it impractical to display such documentation on 

the sUAS itself. Also, since the sUAS is unmanned, it is unnecessary to display a certificate for 

passengers or crew as required by Section 91.203(b). Furthermore, due to the size, weight, speed and 

limited operating area associated with these aircraft, we request the FAA determine that this aircraft 

meets the conditions of Section 333.

Equivalent Level of Safety

We contend that granting this exemption will not adversely affect safety or pose a threat to national 

security for the following reasons:

- The sUAS to be operated by Tom Sondreal Media Productions weigh less than 4.0 lbs. fully loaded, 

carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and operate 

exclusively within a secured and controlled area.

- Our proposed operations will be controlled and monitored by the Pilot in Command (PIC) in 

accordance with the Operator’s Manuals (Attachment 1). An equivalent level of safety will be achieved 

by keeping the Operator’s Manual documents at the ground control point where the Pilot in Command 

(PIC) flying the sUAS will have immediate access to assure airworthiness. 

The FAA has issued numerous exemptions to this regulation. Examples of such exceptions include: 

#9565, #9665, #9789, #9789A, #9797, #9797A, #9816A, and #10700.
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14 C.F.R. Section 45.23(b): Aircraft Marking and Identification Requirements

We are seeking an exemption from the aircraft marking and identification requirements of 14 C.F.R. 

Section 45.23(b). We believe this exemption is justified because the proposed sUAV has no entrance to 

a cabin, cockpit, or pilot station on which the required words could be placed. Also the required size of 

the letters being 2” – 6” high exceeds the available space on the 3DR SOLO. Due to these limitations, we 

request relief from the associated marking and identification requirements of Section 45.23(b). 

Equivalent Level of Safety

We propose an equivalent level of safety for exemptions to the aircraft marking and identification 

requirements of §§ 45.23(b) by having the 3DR SOLO identified on the aircraft by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C with the largest lettering possible. Additionally, Tom 

Sondreal Media Productions will ensure compliance with any future requests of sUAS marking by the 

FAA.

The FAA has issued the following exemptions to the aircraft marking requirements of Section 45.23(b): 

#10700, #8738, #10167 and #10167A.

14 C.F. R. Section 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

We are seeking an exemption from private pilot regulation on the basis that the 3DR SOLO will be 

operated within controlled and restricted areas, and all flights will be planned and coordinated in 

advance, thus making a commercial pilot certificate unwarranted. 

Additionally, the skills required to fly a sUAS such as the ones proposed by Tom Sondreal Media 

Productions are considerably different than the skills required of a certified commercial pilot.

Furthermore, Section 61.113(a) limits private pilots to being in command of non-commercial flights. 

Section 61.113(b) provides for exceptions that allow a private pilot to command an aircraft without 

passengers or property, in connection with business or employment if "the flight is only incidental to 

that business or employment." This exception likely does not apply to the proposed operations under 

this petition for exemption since the flights are not incidental to the proposed aerial photography and 

video or image gathering, but rather essential to it. Therefore, this petition seeks an exemption to § 

61.113(a)'s commercial limitation and/or § 61.113(b)'s requirement that the flight be incidental to the 

business to benefit from the exception.

Equivalent Level of Safety

Since our 3DR SOLO aircraft will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety to § 61.113 (a) and (b), by requiring the PIC operating the sUAS to have 

training on operating the sUAS as defined in the 3DR SOLO operations’ manual (Attachment 1) and Pilot 

Training and Safety Guides (Attachments 2 and 3).

Unlike a conventional aircraft that carry a pilot and passengers, the 3DR SOLO is remotely controlled 

with no passengers on board. Furthermore, the risks associated with the operation of this sUAS are 

greatly reduced from the level of risk associated with commercial flight operations involving full-sized 

aircraft.
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Lastly, Tom Sondreal Media Productions PIC will have the final authority to abort any flight operation in 

the interest of safety. Abort signals will be determined ahead of time along with the observer. In the 

event of signal loss, power loss, or mechanical failure, the PIC will keep the safety of property and 

people as the highest priority. The aircraft may be crashed, or destroyed, in the attempt to maintain 

safety.

14 C.F. R. Section 91.7(a): Civil Aircraft Airworthiness

We are seeking an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be certified in 

an airworthy condition to be operated. Since there is currently no airworthiness certificate to be issued 

for the proposed sUAS, no FAA regulatory standard currently exists for determining airworthiness.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the proposed sUAS operation’s manual for 

maintenance (Attachment 1). Furthermore, the PIC will conduct thorough pre- and post-flight checklists 

(Attachment 3) to assure airworthiness of the aircraft. The FAA has issued the following exemptions to 

this regulation: #8738, #9299, #9299A, #9565, #9565B, #10167, #10167A, #10602, #32827, and #10700.

14 C.F. R. Section 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

We are seeking an exemption from Section 91.9(b)(2) which requires a flight manual be carried onboard 

all civil aircraft. Given its small size and load capacity, the proposed 3DR SOLO sUAS has no ability to 

carry such a manual on the aircraft itself, not only because there is no pilot on board, but because there 

is no room to carry such an item on the proposed aircraft.

Equivalent Level of Safety

This requirement can be equally satisfied by keeping a copy of the sUAS 3DR SOLO operations/user 

manual (Attachment 1) at the ground control point where the pilot flying the sUAS will always have 

immediate access to these documents. Thus, we request an exemption from § 91.9(b)(2)'s flight manual 

requirements, on the basis that the sUAS manual be available at the control point during each 

operation. The FAA has issued the following exemptions to this regulation: #8607,#8737, #8738, #9299, 

#9299A, #9565, #9565B, #10167, #10167A, #10602, #32827, and #10700.

14 C.F. R. Section 91.103(b): Preflight Action

We are seeking an exemption from Section 91.103, which requires a PIC to become familiar with specific 

information before each flight, including information contained in the FAA- approved Flight Manual on 

board the aircraft. Since an approved FAA flight manual is not available for the proposed sUAS, an 

exemption is being sought.

Equivalent Level of Safety

An equivalent level of safety will be provided by adopting and conducting a comprehensive pre- flight 

checklist as part of each flight (Attachment 3). The PIC will take all actions, including reviewing weather, 

flight battery requirements, landing and takeoff distances, and aircraft performance data, before 

initiating any and all flights. Furthermore, a briefing will be conducted by the PIC with the visual 

observer/camera operator and all others involved in the production activities.
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14 C.F.R. Section 91.109: Flight Instruction

We are seeking an exemption from 14 C.F.R. § 91.109, which provides that no person may operate a civil 

aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. Remote-controlled aircraft, by their design, do not have fully functional 

dual controls as a norm. Instead, flight control is accomplished through the use of a control unit that 

communicates with the sUAS via radio frequencies. Dual control is technically feasible, but not standard 

for sUAS.

Equivalent Level of Safety

Given the relatively small size and slow speed of the proposed sUAS, an equivalent level of safety 

training and flight instruction can still be performed without dual controls because no pilot or 

passengers are aboard the sUAS, and all persons will be a safe distance away should the sUAS 

experience any difficulties during flight instruction. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. A representative sampling of such exemptions include #5778K & #9862A.

14 C.F. R. Section 91.119: Minimum Safe Altitudes

We are seeking an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. This 

section establishes the minimum safe altitudes under which aircraft may not operate, including 500 feet 

above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. 

Section 91.119(d) already allows helicopters to be operated at less than the minimums prescribed, 

assuming the pilot operating the helicopter complies with routes and altitudes assigned for helicopters 

by the FAA. We anticipate that our sUAS will routinely need to be operated within a range of 

approximately 50 - 100 feet from the subject(s) being photographed or recorded. Accordingly, due to 

the nature of our proposed operations, the PIC and the designated observer may, at times, be less than 

500 feet away from structures during the operation, and an exemption is therefore required. Lastly, we 

will operate our sUAS below 300 feet above ground AGL at all times.

Equivalent Level of Safety

When compared with flight operations involving aircraft weighting more than the maximum 55 lbs., 

along with the lack of flammable fuel, any risk associated with our proposed operations are far less than 

those presently conducted with conventional aircraft. A comparable level of safety will be achieved 

based on the small size, light weight, and relatively slow speed of our proposed sUAS, as well as the 

controlled locations where the aircraft will be operated. Our 3DR SOLO will routinely be operated in a 

restricted area, where people will not be exposed to operations without their pre-approved consent. No 

flight will be taken without the permission of the property owner and/or local officials. Because of the 

advance notice to the property owner and participants, all affected individuals will be aware of the 

planned flight operations. Furthermore, by operating at such low altitudes, our proposed sUAS will not 

interfere with other aircraft that are subject to the minimum safe altitude regulations.

14 C.F. R. Section 91.121: Altimeter Settings

We are seeking an exemption from 14 C.F.R. Section 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. We are requesting an exemption to this 

requirement because the proposed sUAS does not have a barometric altimeter. Instead, the 3DR SOLO

uses a GPS-based altitude display systems.
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Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures contained in the 3DR SOLO

Operation’s Manual (Attachment 1). As prescribed in this Manual, the operator will confirm the altitude 

of the launch site shown on the GPS altitude indicator before flight. Furthermore, the PIC will use the 

GPS altitude indicator to constantly monitor the sUAS’s height, thus ensuring operation at safe altitudes.

14 C.F. R. Section 91.151(a): Fuel Requirements for Flight in VFR Conditions

We are seeking an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flights conducted under 

visual flight rules (VFR) conditions. Unlike civil aircraft, the proposed sUAS is battery-powered. 

Therefore, the requirements under Section 91.151(a) are not applicable to the 3DR SOLO aircraft. The 

battery powering the proposed sUAS only has approximately 20-25 minutes of powered flight, therefore 

an exemption from the 30-minute reserve requirement is necessary. Additionally, we are not planning, 

nor proposing to fly our 3DR SOLO at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved by limiting our flights to under 20 minutes or 30% of 

battery power, whichever happens first. The proposed sUAS is programmed to automatically issue two 

“low battery” alerts – one at 30% power and one at 15% power. We will land either before or upon 

hearing the first alert that is issued at 30% power remaining. This restriction will be more than adequate 

to return our sUAS to its planned landing zone from anywhere within its limited operating area. 

Operating the 3DR SOLO with less than 20 minutes of reserve battery does not compare to the type of 

risks that Section 91.151(a) was intended to alleviate given the size and speed of the sUAS. Furthermore, 

operation will be limited to controlled areas where only people and property owners, or official 

representatives who have signed waivers, will be allowed. This request for exemption falls within the 

scope of prior exemptions. A representative sample of such exemptions include: #10673, #2689F, 

#5745, #10673, and #10808. 13 14 C.F. R. Section 91.405(a), 407(a)(1), 409(a)(2), 417(a) & (b)

14 C.F. R. Section 91.405(a), 407(a)(1), 409(a)(2), 417(a) & (b): Maintenance Inspections

We are seeking an exemption from the maintenance inspection requirements of 14 C.F.R. §§ 91.405(a); 

91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b). These regulations specify maintenance and inspection 

standards are only applicable to aircraft with an airworthiness certificate. Since the proposed sUAS will 

not have such a certificate, an exemption to this regulation is required.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the 3DR SOLO Operation’s Manual. As provided in this manual, the operator will ensure 

that the proposed sUAS is in proper working condition prior to initiating flight. We will routinely 

perform required maintenance and keep a log of any maintenance required. As the operator, we are 

most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. If mechanical issues arise, our sUAS will land immediately. 

Additionally, the UA's small size, carrying capacity, and the fact that flight operations will only take place 

in restricted areas for periods of time not to exceed 20 minutes or until 30% battery power remains, 

create less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft 

performing the same operation. 
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How Tom Sondreal Media Productions Request will benefit the Public as a

Whole:

Granting Tom Sondreal Media Productions exemption will benefit the overall public interest in the 

following ways: 

- It will fill an emerging need in society for the provision of 2D and 3D aerial imaging services that 

provide businesses and professionals with realistic visualizations of both past and projected scenes.

- The use of 2D and 3D modeling, animation and rendering has been used for decades in manufacturing, 

product development and creative services. As these visually- advanced techniques are combined with 

aerial imaging, Tom Sondreal Media Productions will enhance the quality of the tools and outcomes 

available to clients in need of such services. The provision of 2D and 3D solutions using aerial imagery 

will continue to grow as the FAA opens the door to other aerial imaging providers who abide by high 

standards of safety and quality.

Beyond the specific benefits associated with providing 2D and 3D solutions using aerial imagery, the 

granting of Tom Sondreal Media Productions exemption request will also provide the following general 

public benefits: 

- The operation of ultra-light, UAS aircraft significantly improves public safety and reduces risks by 

alleviating human exposure to the dangers associated with current aerial image capture methods such 

as full-size helicopters. The public's interest is also advanced by reducing human exposure to death or 

serious injury associated with manned aircraft performing such services.

- The light-weight UAS aircraft proposed by Tom Sondreal Media Productions are battery powered. 

Thus, unlike civil aircraft, they create no emissions. Furthermore, if a small UAS such as the one 

proposed by Tom Sondreal Media Productions would crash, there would be no fuel to ignite or explode. 

With these factors in mind, the public's interest is advanced by minimizing the ecological impact of an 

accident and by reducing human exposure to potentially harmful emissions associated with manned 

aircraft. 

- There is also a financial benefit to the public. Current methods of capturing aerial imagery are 

expensive, and oftentimes cost-prohibitive for many individuals and organizations. Granting exemptions 

such as the one proposed by Tom Sondreal Media Productions will make such services affordable to a 

wider group of prospective customers. Approval will help fulfill Congress' goal in passing Section 333 of 

the Reform Act, namely, the FAA Administrator's assessment of whether certain UAS may operate safely 

in the National Airspace System before completion of the rulemaking required under Section 332 of the 

Reform Act. 

- Lastly, the current methods of capturing aerial imagery are limited in terms of accessing certain 

spaces. For example, flying traditional aircraft at low levels or in populated areas puts the general public 

at increased risks of harm. The small 3DR SOLO sUAS can fly safely in populated areas under controlled 

situations.
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Reasons why Tom Sondreal Media Productions Exemption will not adversely 

Affect Safety, or how the Exemption will Provide a Level of Safety at least Equal 

to the Existing Rule:

Tom Sondreal Media Productions offers the following summary of its proposed operations to ensure, at 

a minimum, an equivalent level of safety to operations conducted under current regulatory guidelines. 

Pilot in Command (PIC) and Visual Observer (VO)

- All members of Tom Sondreal Media Productions flight crew, including PIC and VO, will have an 

understanding of, and comply with, Title 14 Code of Federal Regulations, and/or Agency directives and 

regulations, applicable to the airspace where the sUAS will operate.

- Minimum crew for each operation will consist of two operators: the UAS pilot in command (PIC) and a 

visual observer (VO). 

- All flights will be conducted within visual line-of-sight (VLOS) of the pilot in command (PIC), as well as 

the visual observer, and will not create a hazard to users of the National Airspace System (NAS) or the 

public.

- Tom Sondreal Media Productions will include no less than $1 million general liability coverage involving 

any property or personal incidents.

- A briefing of the flight crew will be conducted by the PIC in regards to the planned sUAS operations 

prior to each flight. It will be mandatory that all personnel who will be performing duties within the 

safety perimeter be present for this briefing.

- The UAS pilot and visual observer will have been trained in operation of the 3DR SOLO and will have 

received up-to-date information on the particular it’s operation, as required in the Operations Manual.

- The PIC and VO will be able to communicate verbally at all times.

Operations of sUAS

- The sUAS will remain clear and yield the right of way to all other manned aviation operations and 

activities at all times.

- Flights will be operated at an altitude of no more than 300 feet above ground level, and the radius 

distance from the controller to the sUAS will not exceed 1,000 feet.

- The sUAS will stay at least 100 feet away from people, animals, buildings, structures and vehicles not 

involved in the project operation.

- The 3DR SOLO will be operated under normal conditions, only during daylight hours, at speeds of 5 to 

30 knots.

- If the sUAS loses communications or loses its GPS signal, it will return to a pre- determined location 

within the planned operating area or be recovered.

- The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with Tom Sondreal Media Productions safety guidelines.

- Maximum total flight time for each operational flight will be 20 minutes.

- Flights will be terminated at 30% battery power reserve should that occur prior to the 20-minute 

limit. Additionally, a minimum of one reserve battery will be kept fully charged and available at all times.

- The pilot will establish takeoff and landing zones by a space no smaller than ten (10) feet by ten (10) 

feet, and clear of overhead and lateral obstructions.

- The PIC will also check the area to determine if there are any potential radio frequencies or electrical 

transmissions that could interfere with the safe operation of the aircraft.

- Written and/or verbal permission from the relevant property holders will be obtained while gathering 

digital imagery.
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- All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies.

- A log book will be kept for each flight to document routine matters such as the flight date, purpose, 

weather conditions and any maintenance issues or unexpected adverse incidents.

- The pilot will operate the 3DR SOLO in safe environments that are strictly controlled, away from power 

lines, lights, airports and populated areas.

- The pilot will contact respective airports if operations will be within 3 nautical miles to advise them of 

the location, estimated flight time and elevation of flight.

- All operations will be conducted over private or controlled-access property with permission from the 

landowner or authorized representative.

- We will obtain a Certificate of Waiver for Authorization (COA) before conducting any operations. Tom 

Sondreal Media Productions will also request a Notice to Airmen (NOTAM) when required between 48 

to 72 hours prior to the operation.

- Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office 

(AFS-80) with 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB website: www.ntsb.gov.

Maintenance of sUAS

Prior to each flight, the PIC will inspect the sUAS to ensure it’s in a safe condition for flight. If the 

inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be prohibited 

from operating until the necessary maintenance has been performed. The Ground Control Station will 

be included in the preflight inspection. All maintenance and alterations will be properly documented in 

aircraft records.

- Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight 

characteristics will undergo a functional test flight. The PIC who conducts the functional test flight will 

make an entry in the sUAS aircraft logbook of the flight.

- Tom Sondreal Media Productions will follow the manufacturer’s sUAS aircraft/component, 

maintenance, overhaul, replacement, inspection and life limit requirements.

Tom Sondreal Media Productions safety protocols will provide a level of safety at least equal to existing 

rules and, in some instances, greater than existing rules.

A summary the FAA may publish in the Federal Register: 

Tom Sondreal Media Productions, requests an exemption from Part 21 and §§ 45.23(b), 61.113(a) and 

(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations. The proposed 

exemption will allow Tom Sondreal Media Productions to operate its small, unmanned aerial system 

(sUAS) as a safe and cost effective means of capturing digital imagery (still photographs and video 

footage) in providing two-dimensional (2D) and three-dimensional (3D) visualization and animation 

services to support various industries including, but not limited to, Inspection, Construction, Mining, 

Agriculture, Manufacturing, Insurance, Forestry & Timber, Environmental, Search & Rescue, and 

Property Development. All proposed aerial imaging operations would be conducted by Tom Sondreal 

Media Productions under controlled conditions in airspace that is: 1) limited, 2) predetermined, and 3) 

access controlled.
13

Additional Background Information to Support Tom Sondreal Media Productions

Request:

Tom Sondreal Media Productions, (TSMP) is currently located in the State of Minnesota. Since 1988

TSMP has been serving corporate, government, small business and non-profit clientele in the fields of 

corrections, health care, agriculture, tourism, manufacturing and education. Providing marketing and 

multimedia production, TSMP has specialized in multi-camera videography, live-streaming and graphics 

creation for clientele across the nation. Growing up in a Family business of heavy equipment 

manufacturing, combined with sixteen years as a University of Minnesota, Senior Media Producer, Tom 

Sondreal recently followed his intuitive mindset and became certified as an ASNT Level II NDT inspector 

providing service to the structural steel construction and fabrication industries. With his wide and varied 

skill sets, Sondreal now plans to move his services from the ground into the air by adding UAS 

Videography and georeferencing capabilities to the TSMP portfolio of professional services.

The Tom Sondreal Media Productions team is committed to positively advancing the aerial imaging 

industry. They are experienced business professionals looking to meet an emerging market need. They 

desire to do so in full compliance with all government laws and regulations, thus assuring the highest 

standards of safety and quality.

Respectfully Submitted; Thomas J. Sondreal, President, Tom Sondreal Media Productions.