1 UNITED STATES OF AMERI CA 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 AI RCRAFT SYSTEMS (sUAS)

PURSUANT TO SECTION 333 OF THE FAA MODER NIZATION AND REFORM ACT OF 2012

Submitted Electronically on February 24 , 201 6
Tom Sondreal Media Productions
Thomas J. Sondreal

– President

817 Barrette ST. Crookston, MN 56716 Phone: (218) 23 0

- 4963
Email: tomsondreal@gmail.com2 Table of Contents :

Glossary of Abbreviations & Terms

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

........................... .......................................... 2 Exemption Request....................................................................

........... ........................... ............... 3 Proposed Unmanned Aerial System

.. ... ............... .............................................. ............................ ......... 4 Requested Exemptions from Regulatio ns....................................

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

................................................................... ............................... .......... 1 0 Reasons Why the Exemption will not Adversely Affect Safety.........................

............................. ....... 1 1 Summary the FAA May Publish in the Federa l Register............

............ ............................. ................... 1 2 Additional Background Informat ion.....................................................................

............................. ....... 13

Gl ossary of Abbreviations & Terms

2D/3D Two

- Di mensional and Three

- Dimensional

AGL Above Ground Level

AMA Academy of Model Aeronautics

C.F.R. Code o f Federal Regulation

COA Certificate of Authorization

FAA Fe deral Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

sUAS S mall, Unmanned Aircraft Systems

UA Unmanned Aircraft

U AS 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. The se 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 Aeronauti cs (AMA) Safety Code
Attachment 3 FlySafe Train in g.org Guidelines / Flight Checklists3 

## Exemption Request from Tom Sondreal Media Productions
February 24 , 201 6

United States Department of Transportation Docket Operations

West Bui lding Ground Floor Room W12

- 140

1200 New Jerse y Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012,
Publ ic Law 112

- 95 February 14, 2012

I, Thomas J. Sondreal, am writing on behalf of my company, Tom Sondreal Media Productions , regarding
the FAA Moderniz ation 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 requ ested exemption will allow Tom
Sondreal Media Productions to operate small, unmanned aircraft systems (sUAS) commercially in airspace regulated by the Federal A viation Administration (“FAA”).

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

v ideography 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, Insura nce, 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 seek ing 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 Ac t. 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

t he 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 i s 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

.4 

## Proposed Small, U nmanned Aircraft Systems (sUAS) :

Tom Sondreal Media Productions proposes to utilize a 3 D R SOLO drone for capturing digital images. Th is
multi

- rotorcraft sUAS ha s four motors and propellers in a quadcopter configuration weighing roughly 4 pounds, including camera and payload. It is equipped with an onboard compu ter stabilization controller, Global Positioning System (GPS) and a handheld ground control station. The 3DR SOLO provide s 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 Spec ification s:

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 li fe: 3 hours Extended controller battery life: 6 hours Controller battery: Li

- ion 2600 mAh 7.2 Vdc (5200 m Ah for extended battery)

Power: Electric (rechargeable lithium polymer battery) Battery: Lithium polymer, 5200 mAh, 14.8 Vdc Battery wei ght: 1 lb. (.5 kg) Estimated flight time: 25 minutes , 20 minutes with payload *
Maximum altitude: 400 ft. per FAA regulation, user adjustable (1 22 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.5 

## Requested Exempt ions 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 o f 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 th is aircraft

meet s 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

secu rity for the following reasons:

- The sUAS to be operated by Tom Sondreal Media Production s 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 contro l 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, #97 97, #9797A, #9816 A, and #10700.6 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 be cause 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

r equirements 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, #1016 7 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 are as, 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 differen t 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 wi thout 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 a re 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 Safet y 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 t he operation of th i s sUAS are greatly reduced from the level of risk associated with commercial flight operations i nvolving full

- sized
aircraft.7 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 t he attempt to maintain safety.

14 C.F. R. Section 91.7(a): Civil A ircraft 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 fol lowing 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

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

14 C.F. R. Section 91.9(b)(2): Civil Aircraf t Flight Manual in the Aircraft We are seeking an exemption from Section 91.9(b)(2) which requires a flight manu al be carried onboard
all civil aircraft. Given its small size and lo ad capacity, the proposed 3DR SOLO sUAS ha s 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 s uch 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, #1016 7A, #10602, #32827, and #10700.

14 C.F. R. Sect ion 91.103(b): Preflight Action We are seeking an exemption from Section 91.103, which requires a PIC to become familiar wi th 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 Leve l 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, land ing 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.8 14 C.F.R. Sec tion 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. Du a l control is technically feasible, but not standard
for sUAS.

Equivalent Level of Safe ty 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 d ual 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 functiona l dual controls for a number of aircraft and for flight instruction in experimental aircraft. A representative sampling of such exempt ions include #5778K & #9862A.

14 C.F. R. Section 91.119: Minimum Safe Altitudes We are seeking an exemption from the min imum 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 a reas. 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 rou tinely 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 weightin g 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 sm all 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 wi thout 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 fligh t 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. Secti on 91.121: Altimeter Settings We are seeking an exemption f rom 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 exempt ion to this requirement because the proposed sUAS does not have a barometric altimeter. Instead, the 3DR SOLO

use s a GPS

- based altitude display systems.9 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 th is 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 indicato r to constantly monitor the sUAS’s height, thus ensuri ng 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 cond ucted 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 ha s 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 s afety will be achieved by limiting our flights to under 2 0 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 a t 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 2 0 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 m aintenance 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 th i s manual, the operator will ensure that the proposed sUAS is in proper working condit ion 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 provid e 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 exce ed 2 0 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.10 

## 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 pro fessionals 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 techni ques are combined with aerial imaging, Tom Sondreal Media Productions will enhance the quality of the tools and outcomes
available to cl ients in need of such services. The provision of 2D and 3D solutions using aerial imagery will continue to grow as the F AA 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 exemptio n 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 captu re 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 air craft 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 method s 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 aircra ft at low levels or in populated areas puts the general public
at increased risks of harm. The small 3DR SOLO s UA S can fly safely in populated areas under controlled

situations.11 

## Reasons why Tom Sondreal Media Productions Exemption will not adversely
Af fect Safety, or how the Exemption will Provide a Level of Safety at least Equal to the Existing Rule :

Tom Sondreal Media Productions offer s the following summary of its proposed operations to ensure, at a minimum, an equivalent level of safety to operatio ns 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 airspa ce where the sUAS will operate.

- Minimum crew for each operation w ill 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 user s of the National Airsp ace 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 P IC 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 perimete r 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 operat ion , as re quired 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 operatio ns 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 ex ceed 1,000 feet.

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

inv olved 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 2 0 minutes.

- Flights will be term inated 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 char ged and available at all times.

- The pilot will establish takeoff and landing zones by a space no sma ller 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 sa fe operation of the aircraft.

- Written and/or verbal permission from the relevant property holders will be obtained w hile gathering digital imagery.12 - All required permissions and permits will be obtained from territorial, state, county or city jurisdictions,
includin g local law enforcement, fire, or other app ropriate 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 the m of the location, estimated fligh t time and elevation of flight.

- All operations will be conducted over private or controlled

- access property with permission from the
landowne r or authorized representative.

- We will obtain a Certificate of Waiver for Au thorization (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 instruc tions 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 doc umented 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, inspecti on 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 Regulat ions. 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 (2 D) 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

. S ince 1988 TSMP has been serving corporate, government, small business and non

- profit clientele in the fields of

correct ions, 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 Fam ily 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 be came certified as an ASNT Level II NDT inspecto r 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 geo referencing capabilities to the TSMP portfolio of prof essional service s

.

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 wi th all government laws and regulations, thus assuring the highest

s tandards of safety and quality.

Respectfully Submitted ; Thomas J. Sondreal , President

, Tom Sondreal Media Productions

.