April 17, 2015 

 Exemption No. 11369 

 Regulatory Docket No. FAA–2015–0109 

Mr. Anthony Sydor 

CEO 

Sydor Aerial Photography, LLC 

1046 Autumn Lakes Circle, 3B 

Mishawaka, IN 46544 

Dear Mr. Sydor: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated January 9, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Sydor Aerial Photography, LLC (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct sUAS flights over construction sites during all phases of development. 

This would also include preliminary property surveying. UAS flights will be used to capture 

aerial photos for the purpose of creating orthomosaics (image maps). 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 
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Airworthiness Certification 

The UAS proposed by the petitioner is a DJI Phantom 2 Vision. 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Sydor Aerial Photography, LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below. 
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Conditions and Limitations 

In this grant of exemption, Sydor Aerial Photography, LLC is hereafter referred to as 

the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 
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22. All aircraft operated in accordance with this exemption must be identified 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. Markings must 

be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 
January 9, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 

61.113(a) & (b); 91.119(c); 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2);91.417(a) & (b).

Dear Sir or Madam: 

 Commercial real estate development is vital to every region's 

economy. From site identification to ceremonial ribbon cutting. Each 

phase of construction can benefit from small unmanned aerial vehicles 

(sUAS).

 As an industry, commercial construction has continually embraced 

technology as a means to improve productivity and output quality. The 

following are a few examples of the advantages that sUAS may 

provide. These examples also serve to satisfy the question; Why the 

sUAS operation would be in the public interest? 

 1) First, and most importantly is safety. In the United States 

construction continues to be one of the most dangerous industries in 

our economy. Allowing sUAS operations on construction sites enables 

safety managers to gain valuable, on demand, aerial images. As a 

result, safety managers can identify possible hazards that may 

jeopardize worker health.

 2) sUAS operations can aid construction site agents in 

 environmental compliance. 

 3) sUAS operations can provide historical visual 
 documentation of construction progress. Additionally, an 

 accurate aerial perspective can serve to resolve schedule 

 disputes.

 4) sUAS operations can enhance stakeholder communication.

 5) sUAS operations can provide Insurance documentation.

 6) sUAS operations can optimize asset management.

 Sydor Aerial Photography LLC Petitions the Federal Aviation 

Administration to conduct sUAS flights over construction sites during 

all phases of development. This would also include preliminary 

property surveying. UAS flights will be used to capture aerial photos 

for the purpose of creating orthomosaics (image maps). The image 

maps will be used to compute volume, create 3D models, DSM’s, 

DTM’s, profile and contour lines.

 Post flight editing of orthomosaics will ensure that images captured 

are only of the proposed / active contruction theatre

 Sydor Aerial Photography LLC is a 100% veteran owned UAV 

company that specializes in aerial photogrammetry with sUAV. Our 

experience in sUAS operations and project completion gives us the 

expertise to conduct safe-flight sUAS operations. Sydor Aerial 

Photography LLC takes a planned tactical approach to data gathering 

by optimizing and reviewing the most efficient flight plan. This 

knowledge base has come through years of piloting, maintaining, and 

repairing sUAS.

 Pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Sydor Aerial 

Photography LLC petitions the FAA to allow safe flight operation of its 

sUAS for the purpose of conducting aerial photography and 

videography of construction sites. Sydor Aerial Photography LLC 

hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of its sUASs, so 

long as such operations are conducted within and under the 
conditions outlined herein or as may be established by the FAA in an 

exemption granted under either Section 333 or Section 49 U.S.C. § 

44701(f).

 Sydor Aerial Photography LLC has set forth conditions that are 

consistent with the equivalent level of safety set forth in Exemption 

11062 and the related exemptions issued to sUAS companies for 

scripted closed set filming for the motion picture and television 

industry.

 As described more fully below, the requested exemption would 

permit the operation of small, unmanned and relatively inexpensive 

sUAS under controlled conditions in airspace that is 1) limited, 2) 

predetermined, 3) controlled as to access, and 4) would provide safety 

enhancements to the already safe operations in the fields in which it 

will operate, presently using manned aircraft or ground inspection 

survey teams. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace 

system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Sydor Aerial Photography, LLC

1046 Autumn Lakes Circle, 3B

Mishawaka, IN 46544

Attn: Anthony Sydor, CEO

Regulations from which the exemption is requested:

14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.119(c)

14 C.F.R. 91.151(a)

14 C.F.R. 91.405(a)14 C.F.R. 407(a)(1) 14 C.F.R. 409(a)(2) 
14 C.F.R. 417(a) & (b)

 This exemption application is expressly submitted to fulfill 

Congress’ goal in passing Section 333(a) through (c) of the Reform 

Act. This law directs 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. In making this 

determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS or the public or pose 

a threat to national security in light of the following:

The UAS’s size, weight, speed, and operational capability; 

Operation of the UAS in close proximity to airports and 

populated areas; and operation of the UAS within visual line of 

sight of the operator. 

 Reform Act § 333(b). Lastly, if the Secretary determines that such 

vehicles “may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. at § 333(c)

 The Federal Aviation Act, in addition to the authority granted by 

Section 333 of Reform Act, expressly grants the FAA the authority to 

issue exemptions. This statutory authority by its terms includes 

exempting civil aircraft, as the term is defined under Section 40101 of 

the Act, which includes sUASs, from the requirement that all civil 

aircraft must have a current airworthiness certificate.

 The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of Section 333 or any 

Sections 44702-44716 of the Transportation Act if the Administrator 

finds the exemption in the public interest. 49 U.S.C. § 44701(f). See 

also 49 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R. § 

91.203(a)(1). This authority to grant exemptions reaches such issues 

as authorization of commercial operation of aircraft without a pilot’s 

license.
 Based upon the spirit of Section 333, and the continuing integration 

of small UAS's into the NAS, Sydor Aerial Photography LLC submits 

this petition for review and approval. 

 Sydor Aerial Photography LLC operates a multirotor UA 

(quadcopter) weighing 1160g with payload. Maximum manufacturer’s 

safe flight speed is less than 15 m/s. Sydor Aerial Photography LLC 

will not exceed 10 m/s during UAS operation.

 UA will not exceed 400 ft (AGL) and will only be operated within line 

of sight of the PIC and VO.

 UAS flights will only be performed over proposed / active 

construction sites and only with written permission by the construction 

site operator or governing body overseeing the operation and safety of 

the construction site.

 Sydor Aerial Photography LLC submits “UAS safe flight operations 

manual”, as it pertains to construction site UAS operations 

as Exhibit A.

 Sydor Aerial Photography LLC submits the “UAS manufacturer 

flight and operational manual” as Exhibit B.

 Operational compliance of Exhibit A and B shall insure safe flight 

operations within the construction site theatre. Compliance outlined in 

Exhibit A and B shall also insure safe flight UAS operations within the 

NAS. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Sydor Aerial Photography LLC proposes that the exemption requested 

herein apply to civil aircraft that have the characteristics and that 

operate with the limitations listed herein. These limitations provide for 

an equivalent or even higher level of safety to operations under the 

current regulatory structure because the proposed operations 

represent a safety enhancement to the operations normally conducted 

with manned aircraft.
These limitations and conditions to which Sydor Aerial Photography 

LLC agrees to be bound when conducting commercial operations 

under an FAA issued exemption include:

1. The UAS must weigh less than 25 lbs., including battery 

and camera. Operations will be limited to the aircraft described in 

Exhibit B

2. The UA may not be flown faster than recommended by 

the manufacturer. Sydor Aerial Photography LLC will not operate 

the UA faster than 10m/s.

3. UAS operations will be conducted below 400 ft above 

ground level (AGL). The height of the UA will not exceed 400 ft 

(AGL).

 4. UAS operations will only be conducted in class G 

airspace, unless otherwise approved by the FAA.

 5. The UAS will be operated within visual line of sight 

(VLOS) of the PIC at all times. This requires the PIC to be able 

to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA issued third-class medical 

certificate.

 6. All operations must utilize a visual observer (VO). The 

VO may be used to satisfy the VLOS requirement, as long as the 

PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times.

 7. The operator will be bound by and follow Exhibits A & B. 

Any additional requirements identified in the final conditions for 

this exemption will be added to Exhibits A & B . Exhibits A & B 

will be maintained and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and 

limitations in the final exemption and the procedures outlined in 

Exhibits A & B, the conditions and limitations of the exception will 
take precedence and will be followed. Otherwise, the operator 

will follow the procedures as outlined in Exhibits A & B.

 8. The operator will update or revise its Exhibits A & B. It 

will be the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator 

upon request. The operator will also present updated and 

revised documents if it petitions for extension or amendment. If 

the operator determines that any update or revision would affect 

the basis for which the FAA granted this exemption, then the 

operator will petition for amendment to their exemption. The 

operator will contact the FAA’s UAS Integration Office (AFS-80) 

with questions that may arise regarding updates or revisions to 

Exhibits A & B.

 9. Prior to each flight the PIC will inspect the UAS to ensure 

it is in safe flight condition. The procedures for pre-flight 

inspection and functional viability of all UAS components is 

outlined in Exhibit A & B

 10. Any UAS that has undergone maintenance or alterations 

that affect the UAS operation or flight characteristics, e.g., 

replacement of a flight critical component, must undergo two 

functional tests outlined in Exhibit C. The PIC who conducts the 

functional tests will make an entry into the sUAS maintenance 

record. Specific procedures for the sUAS functional tests is 

submitted as Exhibit C.

 11. The operator will comply with the manufacturer's 

recommendations pertaining to maintenance, inspection and 

replacement of UAS components. The maintenance manual, 

submitted as Exhibit C, outlines these components.

 12. The PIC will have at least a current private pilot 

certificate and a current third-class medical certificate. The PIC 

will also meet the flight review requirements specified in 14 

C.F.R. § 61.56 in an aircraft in which the PIC is rated on his/her 

pilot certificate.
 13. Prior to operations conducted for the purpose of 

gathering aerial data, the PIC will have accumulated and logged, 

in a manner consistent with 14 C.F.R. § 61.51(b), a minimum of 

300 flight cycles and 30 hours of total time as a UAS multirotor 

aircraft pilot and at least 20 hours logged as a UAS pilot with a 

similar UAS type. Prior documented flight experience that was 

obtained in compliance with applicable regulations will be used 

to satisfy this requirement. Training, proficiency, and experiencebuilding flights may also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight 

time. During training, proficiency, and experience-building flights, 

all persons not essential for flight operations will be considered 

non-participants, and the PIC will operate the UA with 

appropriate distance from non-participants in accordance with 14 

C.F.R. § 91.119.

 14. Prior to any UAS operations by a grant of exemption the 

PIC and VO will have completed a qualification process outlined 

in Exhibit D. Exhibit D includes basic flight maneuvers, skilled 

flight maneuvers, advanced flight maneuvers, and emergency 

procedures. The qualifying process outlined in Exhibit D will be 

implemented by a qualified person designated by the operator. 

Upon request the record of qualifying completion will be made 

available to the administrator.

 15. Prior to operations conducted for the purpose of 

gathering aerial data, a flight demonstration, administered by an 

operator-approved and qualified pilot will be successfully 

completed and documented. This documentation will be 

available for review upon request by the Administrator. Because 

the knowledge and airmanship test qualifications will be 

developed by the operator, and there are no established 

practical test standards that support a jurisdictional FAA Flight 

Standards District Office (FSDO) evaluation and approval of 

company designated examiners, the Operator will conduct these 

tests In accordance with Exhibit D.
 16. The UAS will not be operated directly over any person, 

except authorized and consenting personnel necessary for the 

purpose, below an altitude that is hazardous to persons or 

property on the surface in the event of a UAS failure or 

emergency.

 17. Regarding the distance from participating persons, 

Exhibit A establishes safety mitigations for authorized and 

consenting personnel. At all times, those persons must be 

essential to the sUAS operation. 

 18. Regarding distance from non-participating persons, the 

operator will ensure that no persons are allowed within 500 ft of 

the area except those consenting to be involved and necessary 

for the sUAS operation.

 19. If the UAS loses communications or loses its Global 

Positioning System (GPS) signal, the UAS will be programmed 

to return to a pre-determined location within the security 

perimeter and land or be recovered in accordance with the 

Exhibit A&B.

 20. The UAS will abort the flight in the event of unpredicted 

obstacles or emergencies in accordance with the Exhibit A&B

 21. Each UAS operation will be completed within 20 

minutes of flight time or with 30% battery power remaining, 

whichever occurs first.

 22. The operator will obtain an Air Traffic Organization 

(ATO) issued Certificate of Waiver or Authorization (COA) prior 

to conducting any operations under an exemption. The operator 

will request a Notice to Airman not more than 72 hours in 

advance, but not less than 48 hours prior to the operation.

 23. All aircraft operated in accordance with this exemption 

will be identified by serial number, registered in accordance with 

14 C.F.R. Part 47, and have identification (N- Number) markings 
in accordance with 14 C.F.R. Part 45, subpt.C. Markings will be 

as large as practicable.

 24. The operator will develop procedures to document and 

maintain a record of the UAS maintenance, preventative 

maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These 

procedures will be added to Exhibit C.

 25. Each UAS operated under this exemption will comply 

with all manufacturer safety bulletins, firmware, software updates 

and will be documented and updated in Exhibit A & B.

 26. Before conducting operations, the radio frequency spectrum 

used for operation and control of the UA will comply with the 

Federal Communications Commission (FCC).

 27. The documents required under 14 C.F.R. §§ 91.9 and 

91.203 will be available to the PIC at the ground control station 

of the UAS any time the aircraft is operating. These documents 

will be made available to the administrator, or governing body 

upon request.

 28. The UAS will remain clear and yield the right of way to 

all other manned operations and activities at all times (including, 

but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

 29. UAS operations will not be conducted during night, as 

defined in 14 C.F.R. § 1.1. Operations will only be conducted 

under visual meteorological conditions (VMC). 

 30. The UAS will not be operated by the PIC from any 

moving device or vehicle.

 31. The UA will not be operated less than 500 ft below or 

less than 2,000 ft horizontally from a cloud or when visibility is 

less than 3 statute miles.
 32. The UA will not operate in Class B, C, or D airspace 

without written approval from the FAA. The UA will not operate 

within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart 

unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management will be made available 

to the Administrator upon request.

 33. Incidents, accidents 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 Federal 

Aviation Administration’s (FAA) UAS Integration Office (AFS-80) 

within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained 

on the NTSB web site: www.ntsb.gov. Further flight operations 

will not be conducted until the incident or accident is reviewed by 

AFS-80 and authorization to resume operations is provided.

14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and 

Limitations: Pilot in Command

Sections 61.113(a) & (b) limit private pilots to non-commercial 

operations. Because the UAS will not carry a pilot or passengers, the 

proposed operations can achieve the same level of safety of current 

operations by requiring the PIC operating the aircraft to have a private 

pilot’s license rather than a commercial pilot’s license in order to 

safely operate sUAS. As outlined in Exhibit A, all sUAS operations are 

carefully pre-planned flights with written approval from proposed / 

active construction site operating agents prior to any operations. The 

level of safety provided by the requirements included in Exhibits A & B 

exceeds that provided by a single person holding a commercial pilot’s 

certificate operating a manned aircraft. The risks associated with the 

sUAS operation within the operational area are so diminished from the 

level of risk associated with commercial operations contemplated by 

Part 61 that allowing operations of the sUAS as requested with a 
private pilot as the PIC meets and exceeds the present level of safety 

achieved by 14 C.F.R. § 61.113(a) & (b). 

The FAA has granted exemptions for private pilots to conduct similar 

operations in Exemptions 11062 through 11067 and 11080.

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

Section 91.119 sets forth safe altitudes for operation of civil aircraft. 

Section 91.119(c) allows helicopters to be operated at less than the 

minimums prescribed, providing that the person operating the 

helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is similar 

to a helicopter, and the exemption requests authority to operate at 

altitudes up to 400 ft AGL, an exemption will be needed to allow 

operations. Because the aerial data sets do not require flights greater 

than 400 ft (AGL), Sydor Aerial Photography LLC will not operate the 

UA at or greater than 400 ft (AGL).

The FAA has previously granted exemptions to conduct similar 

operations in Exemptions 11062 through 11067 and 11080.

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

Conditions

Section 91.151(a) prohibits an individual from beginning “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; or 2) At night, to fly 

after that for at least 45 minutes.”

The 5200mAh lithium polymer smart battery powering the sUAS 

provides approximately 25 minutes of flight. In order to meet the 30-

minute reserve requirement in 14 C.F.R. § 91.151, the sUAS flights 

would not be able to operate. Given the powered flight limitations of 

the sUAS within the restricted flight area of proposed / active 

construction sites, a longer time frame for flight is reasonable.
Sydor Aerial Photography LLC believes that an exemption from 14 

C.F.R. § 91.151(a) falls within the scope of prior approved 

exemptions. Ex. Exemption 10673. Flight operations via the sUAS 

within the confines of proposed / active construction sites with less 

than 30 minutes of reserve fuel, does not apply to the original intent of 

Section 91.151 (a), given the sUAS size and speed.

Sydor Aerial Photography LLC believes that an equal level of safety 

can be achieved by limiting flights to 20 minutes or 30% of battery 

power whichever occurs first. Limiting sUAS flights to 20 minutes or 

30% battery power allows the PIC adequate time to return the UA to 

its pre-determined home landing position.

Similar exemptions have been approved for other sUAS operations, 

including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 

11062 through 11067 and 11080.

14 C.F.R. § 91.405 (a); 407(a)(1); 409(a)(2); 417(a) & (b): 

Maintenance Inspections

These regulations require that an aircraft operator or owner “shall 

have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph 

(c) of this section, have discrepancies repaired as prescribed in Part 

43 of this chapter...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

The above mentioned sections and Part 43 apply only to aircraft with 

an airworthiness certificate, therefore these sections do not apply to 

Sydor Aerial Photography LLC. Operational maintenance will be 

performed as outlined in Exhibit C. Due to the size of the UA and its 

camera an equal level of safety will be achieved. In the event of 

mechanical issues, during flight operations, the UA can be safely 

landed. Refer to Exhibit B failsafe procedures. As provided in Exhibits 

A and B the operator will ensure that the sUAS is in working order 

before the start of any sUAS operations. In addition, the PIC will 

perform required maintenance, and keep a log of any maintenance 

performed. Since the operator is the person most familiar with the 

entire sUAS best suited to maintain the aircraft in an airworthy 
condition to provide the equivalent level of safety. As outlined in 

Exhibit C annual inspection, maintenance will be performed by an 

independent third party not affiliated with Sydor Aerial Photography 

LLC.

The FAA has granted exemptions for similar operations in Exemptions 

11062 through 11067 and 11080.

 To satisfy 14 C.F.R. Part 11, the following summary is provided for 

publication in the Federal Register.

Sydor Aerial Photography LLC seeks an exemption from the following 

rules:

14 C.F.R. §§ 61.113(a) & (b); 91.119(c); 91.151(a); 91.405(a); 

91.407(a) (1); 91.409(a)(2); and 91.417(a) & (b) 

 Sydor Aerial Photography LLC seeks approval, of the before 

mentioned exceptions, in order to commercially operate sUAS for the 

purpose of image mapping and aerial photography of proposed 

construction sites and operational construction sites.

 Sydor Aerial Photography LLC believes it's petition for exception 

satisfies the criteria provided in Section 333 of the Reform Act of 2012

(size, weight, speed, operating capabilities, proximity to airports and 

populated areas, operation within visual line of sight, and national 

security) provide adequate justification for the grant of the requested 

exemptions allowing commercial operation of sUAS for the purpose of 

aerial data gathering over MSWLFs.

Sydor Aerial Photography LLC further believes that it's petition for 

exception exceeds the level of safety established in the exemptions 

already granted, including Exemptions 11062 through 11067 and 

11080.

Sincerely,

Anthony Sydor