October 20, 2015

Docket Management Facility

U. S. Department of Transportation

1200 New Jersey Ave.

SE West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations – Sonic Aviation Services LLC

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

Sonic Aviation Services LLC hereby applies for an exemption from the Federal Aviation Regulations

(F ARs) listed below and discussed in Appendix A. Exemption is being sought in order to allow

Sonic Aviation Services to operate its small unmanned aircraft systems (sUAS) in commercial

operations involving aerial applications such as photography, inspections, surveying, and

demonstrations.

sUAS are ideally suited for the commercial operations such as the above because the aircraft has

the capability to deliver high quality data more efficiently and cost-effectively than traditional

methods. Using sUAS can also be safer for workers because in many cases it will avoid putting

workers in situations with potential hazards, eliminating the risk of injuries. They also allow the

safe inspection of hard-to-access or environmentally sensitive areas without the use of trucks and

other utility vehicles. Overall, sUAS can provide significant benefits to workers and customers

over these traditional methods.

Sonic Aviation Services proposes to use sUAS that are rotorcraft and one fixed wing aircraft, which

crafts have a maximum takeoff weight of 10 pounds or less, will be operated at a speed of no

more than 50 knots, and which crafts contain built-in safety features. Proposed operations will

be conducted under controlled conditions in airspace that is (1) limited, (2) predetermined, and

(3) access controlled. Operations under the exemption will be subject to strict operating

parameters to ensure at least an equivalent level of safety to currently authorized operations

using manned aircraft.

The name and mailing address of the petitioner, Sonic Aviation Services, is:

Sonic Aviation Services LLC

Attn: Peter Konrad - President

Addr: 9555 Flower St, Westminster, CO 80021

Ph.: (303) 862-0600

Email: info@coloradoaircam.com

The regulations from which the exemption is requested are listed below. These are more fully

discussed in Appendix A.

14 CFR § 61.113 (a) and (b)

14 CFR § 61.133 (a)

14 CFR § 91.7 (a)

14 CFR § 91.119 (c)

14 CFR § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.405 (a)

14 CFR § 91.407 (a) (1)

14 CFR § 91.409 (a) (1) and (2)

14 CFR § 91.417 (a) and (b)
The Unmanned Aircraft Systems. Sonic Aviation Services will conduct operations with lightweight

rotorcrafts produced by industry leader DJI, models Phantom 3 and Inspire 1. Both weigh under 10 pounds 

with energy sources and equipment. Both models are widely recognized for their reliability. The platforms 

are stable and, with proper training, simple to operate.

These sUAS have common characteristics. Each can be operated by toggle or entirely by a

touch-screen, map-based interface. This means the operator only needs to command the system

where to go, and the system does all the flying for the operator. They can be operated in both

semi and fully autonomous flight modes, with the operator simply clicking on a map to create a

pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum

flight ranges and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly

over.

In addition, the sUAS have built-in intelligent fault handling capabilities which allow them to

detect a system fault while in the air and automatically fly back to its take-offlocation and land.

Faults that can be detected include: loss of communication; exceeding pre-set wind thresholds;

and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the systems easy to

navigate. At any point if the operator is not explicitly commanding the rotorcraft system to

move, the system automatically holds its GPS position. The flight control system employs not

only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature,

wind speed and others to ensure stability so long as wind thresholds are not exceeded.

DJI maintains online product information portals with comprehensive

downloadable operating and maintenance manuals, user guides, flight checklists, safety

information and mission planning instructions. Available also are instructional product and

training videos along with robust online blogs and product forums.

Operating Documents. The comprehensive operation manuals/user guides for each aircraft are

attached as Appendix "B". They are available on the internet at the manufacturers' websites but

are nevertheless being submitted under confidentiality protection request.

Attached also are owner’s manuals are Standard Operating Procedures, Pre-flight Checklist and Post-flight 

Checklist.

The PIC (pilot in command).

The PIC will:

• hold either a current FAA sport pilot certification or higher FAA pilot certification

• hold a valid third-class medical certificate, or valid state-issued drivers license

• in the case of rotorcraft, have accumulated and logged, in a manner consistent with 14

CFR 61.51(b), a minimum of 25 hours of total time as a sUAS rotorcraft pilot and at least

10 hours logged as a sUAS pilot with a similar sUAS type

• in the case of fixed wing aircraft, have accumulated and logged, in a manner consistent

with 14 CFR 61.51(b), a minimum of25 hours of total time as a sUAS fixed wing pilot

and at least 10 hours logged as a sUAS pilot with a similar sUAS type

• have accumulated and logged a minimum of five hours as a sUAS pilot with the make

and model of sUAS to be utilized for operations under the exemption and three take-offs

and landings in the preceding 90 days prior to an operation

• as noted below in "Operating Parameters; Conditions and Limitations", the operator will

not allow a PIC to operate unless the PIC has demonstrated that the PIC is able to safely

operate the sUAS in a manner consistent with how the sUAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Visual observers must have demonstrated that they understand the conditions and limitations of

flight noted below in "Operating Parameters; Conditions and Limitations".

Operating Parameters; Conditions and Limitations. Grant of the exemptions will be subject

to the following conditions, which provide at least an equivalent or higher level of safety than

under the current conditions. 
These conditions are drawn from Exemptions 11062 through 11067, 11080, 11109 and 11110. 

For purposes of this listing, Sonic Aviation Services is referred to as the operator.

1. Operations authorized by the grant will be limited to the sUASs described above and

manufacturers' upgraded versions.

2. The sUAS must weigh 10 pounds or less, including energy source(s) and equipment.

3. The sUAS may not be flown at an indicated ground speed exceeding 50 knots.

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

(AGL). Altitudes reported to Air Traffic Control must be in feet AGL.

5. The sUAS must be operated within visual line of sight (VLOS) ofthe 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 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 VO and PIC always maintain VLOS capability. The

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

designated before the flight and cannot transfer his or her designation during the

flight. The PIC must ensure that the VO can perform the functions prescribed in the

operating documents.

7. The operating documents and this grant of exemption must be made available to the

Administrator upon request. The operator may update or revise its operations manual.

It is the operator's responsibility to track such revisions and present updated and

revised documents to the Administrator upon request. If there is a discrepancy

between the exemption conditions and limitations and the procedures outlined in the

operating documents, the conditions and limitations herein take precedence and must

be followed. If the operator determines that any update or revision would affect the

basis upon which the FAA grants this exemption the operator must petition the FAA

for amendment to the exemption.

8. Prior to each flight the PIC must inspect the sUAS to ensure it is in a condition for

safe 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 and the sUAS is found to be in a condition for safe flight. The

ground control station must be included in the preflight inspection. All maintenance

and alterations must be properly documented in the aircraft records.

9. Any sUAS that has undergone maintenance or alterations that affect the sUAS

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

must undergo a functional test flight. The PIC who conducts the functional test flight

must make an entry in the sUAS aircraft records of the flight.

10. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable

components, items or equipment not already covered in the relevant sections of the

operating documents.

11. The operator must follow the sUAS manufacturer's aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

12. The operator must carry out its maintenance, inspections, and record keeping

requirements in accordance with the operating documents. Maintenance, inspection,

alterations and status of replacement/overhaul component parts must be noted in the
aircraft records, including total time in service, description of work done,

discrepancies between inspections, and the identification of the authorized person

returning the sUAS to service.

13. Each sUAS operated under this exemption must comply with all manufacturer safety

bulletins.

14. The PIC must possess at least a sport pilot certificate and a current third-class

medical certificate. A current state issued drivers license can be used in lieu of a medical certificate. The 

PIC must also meet the flight review requirements specified

in 14 CFR 61.56 as the sUAS.

15. The operator may not permit any PIC to operate unless the PIC has demonstrated that

the PIC is able to safely operate the sUAS in a manner consistent with how the sUAS

will be operated under the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

16. Maximum flight time for each operational flight will be limited to the amount of time

the sUAS can be flown and still maintain a reserve battery power of no less than 20%.

17. The operator will file a request for a Notice to Airmen (NOT AM) not more than 72

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

18. The radio frequency spectrum used for operation ofthe sUAS must comply with the

FCC or other appropriate governmental oversight agency requirements.

19. All flights must be conducted over property that is private or controlled access

property with permission from the land owner/controller or authorized representative.

Permission will be obtained for each flight, where necessary or appropriate.

20. If the sUAS loses communications or loses the GPS signal, the sUAS must return to a

pre-determined location or take-off point or be recovered in accordance with the

operator's manual.

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

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this grant of

exemption.

23. 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 (Nnumber)

markings in accordance with 14 CFR part 45, Subpart C. Markings must be

as large as possible.

24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the ground control station of the sUAS any time the aircraft is operating. These

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

official upon request.

25. The sUAS must remain clear and yield the right of way to manned aviation operations

and activities at all times.

26. sUAS operations may not be conducted during night, as defined in 14 C.F.R § 1.1.

All operations must be conducted under visual meteorological conditions. Flights

under special visual flight rules are not authorized.
27. The sUAS may not be operated by the PIC from any moving device or vehicle.

28. The sUAS 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.

29. The sUAS may not operate within 5 nautical miles of an airport reference point 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 NOT AM as required by the operator's COA. The letter of

agreement with the airport management must be made available to the Administrator

upon request.

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

persons (persons other than the PIC, VO, operator trainees or essential persons)

vessels, vehicles and structures, unless:

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

from the sUAS 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 ofthe sUAS,

flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not

present an undue hazard to those persons per§ 91.119(a).

31. 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 Website: www.ntsb.gov.

The Public Interest. The public interest in granting this exemption request is served by, among

others, the following:

• Congress has established a national policy that favors early integration of sUAS into

the NAS -pending completion of the statutorily required rulemaking for such

integration, exemption requests such as this one by Sonic Aviation Services (and many others)

are integral in developing and in moving this policy along

• The use of sUAS improves public safety and reduces risk by alleviating the public's

exposure to danger and emissions associated with traditional aerial methods (full size

aircraft) that carry passengers and flammable fuel

• Allowing the commercialization of the NASby sUAS will provide additional job and

career opportunities for our nation's population

• Resulting ecological and environmental benefits such as precision inspections and

assessments of fuel-laden pipelines, rights-of-way, energy production platforms, along

with coastal marine environment observations for conservation purposes

• Harnessing the power of new technologies and providing challenges to our nation's

entrepreneurs and developers

Summary for publication. For publication in the Federal Register Sonic Aviation Services provides

the following summary. An exemption is requested from the following regulations in order to

allow commercial operations of its unmanned aircraft systems involving aerial applications such

as photography, inspections, surveying, and demonstrations.

14 CFR § 61.113 (a) and (b)
14 CFR § 61.133 (a)

14 CFR § 91.7 (a)

14 CFR § 91.119 (c)

14 CFR § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.405 (a)

14 CFR § 91.407 (a) (1)

14 CFR § 91.409 (a) (1) and (2)

14 CFR § 91.417 (a) and (b)

**********

Conclusion. Given the small size of the sUASs involved and the restricted environment within

which they will operate, this petition falls squarely within that equivalent level of safety in which

Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs

to commence immediately.

Too, given the clear direction in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, the strong equivalent level of safety surrounding the proposed operations,

and the significant public benefit of the various applications, including enhanced safety,

reduction in environmental impacts by fuel laden vehicles, including reduced emissions, the

public value of the unmanned aerial vehicle industry, the grant of the requested exemption is in

the public interest.

Sonic Aviation Services seeks an exemption from the listed and discussed FARs to operate

commercially the small unmanned aircraft systems in the aerial operations set forth herein.

Thank you.

Sincerely,

Peter Konrad, President

Sonic Aviation Services LLC
APPENDIX A

14 CFR § 61.113(a) and (b); 61.133(a): Private Pilot Privileges and Limitations: Pilot in

Command; Commercial Pilot Privileges and Limitations

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Section 61.133(a)

requires an individual with a commercial pilot's license to be pilot in command of an aircraft for

compensation or hire. Unlike a conventional aircraft that carries a pilot, passengers, and cargo,

the sUAS proposed for use by Sonic Aviation Services are remotely controlled with no passengers or

cargo on board.

Sonic Aviation Services respectfully requests exemptions from these requirements based on the

particular characteristics of the sUAS that will be used. The risks associated with the operation of

the sUAS described above (given the size, speed, operational capabilities and lack of

combustible fuel) are much lower than the risks associated with commercial operations

contemplated by Part 61 with conventional aircraft. Accordingly, a sport pilot, adequately

trained in the proper use of sUAS, possesses the requisite skills and knowledge of the NAS and

FAA regulations to assure the safe operation ofthe sUAS. In addition, Sonic Aviation Services will use

the identified sUAS with a high degree of control and various built-in technical capabilities that

strictly limit the potential for operation outside of the operating conditions set forth in this

Petition.

Sonic Aviation Services emphasizes sUAS training and flight experience for those PICs who will

operate these aircraft in the proposed commercial applications. By requiring extensive flight

experience with these aircraft prior to conducting commercial operations, these PICs will have a

better grasp of the handling of the aircraft than they would by holding a commercial pilot license

for an entirely different type of airborne system.

Given the inherently lower-risk nature ofthe sUAS and these training, experience and safety

features, Sonic Aviation Services proposes that operators should not be required to hold a commercial

pilot certification. Instead operators should be required to hold only a sport pilot certification

and have the experience with the sUASs as indicated in this Petition.

The risks associated with the operation of the sUAS identified herein (given their size, weight,

speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of

risk associated with commercial operations contemplated by Part 61 with conventional aircraft

(rotorcraft or fixed wing) that allowing operations of the sUAS as set forth above meets or

exceeds the present level of safety provided under 14 CFR § 61.113 (a) and (b) and does not rise

to the level of requiring a commercial pilot to operate under§ 61.133(a).

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the sUAS identified herein with a sport pilot's certificate, under the

conditions set forth in this Petition. The FAA has granted exemption to conduct similar

operations in Exemptions 11062 through 11067, 11080, 11109 and 11110.

91Page

14 CFR § 91.7(a): Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of the named

aircraft without an airworthiness certificate, no standard will exist for airworthiness of the

aircraft. Given the size of the aircraft and the requirements that the operator has agreed to as

relates to airworthiness, as set forth herein and in the various operating documents, an equivalent

level of safety will be achieved by ensuring compliance with the aircraft manuals and operating

documents for each flight. The FAA has granted exemptions to conduct similar operations in

Exemptions 11062 through 11067, 11080, 11109 and 11110.

14 CFR §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c)

prohibits operations below 500 feet above the surface, or closer than 500 feet to any person,

vessel, vehicle or structure. As this exemption requests authority to operate at altitudes up to 400

AGL, an exemption may be needed to allow such operations. The equivalent level of safety will

be achieved given the size, weight, speed ofthe sUAS as well as the location where it is
operated. No flight will be taken without the permission of the property owner or local officials,

where required. Because of the advance notice to the property owner and participants, all

affected individuals will be aware of the planned flight operations as set forth in the plan of

operations. Sonic Aviation Services therefore requests a waiver from Section 91.119( c) for all

participating persons, i.e., persons associated with the operations.

Sonic Aviation Services will also ensure that non-participating persons are kept at least 500 feet from

the operating area, or seek approval from the Administrator for less separation if an equivalent

level of safety can be achieved. Compared to flight operations with aircraft or rotorcraft

weighting far more than the maximum 25 pounds proposed herein and the lack of flammable

fuel, any risk associated with these operations is far less than those risks associated with the

conventional methods. In addition, the low-altitude operations of the sUAS will ensure

separation between these sUAS operations and the operations of any conventional aircraft that

must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate

altimeter setting available before departure." As the sUAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety

will be achieved by the operator confirming the acquisition of GPS signals and an initial ground

level altitude of zero prior to take-off. The FAA has granted exemptions to conduct similar

operations in Exemptions 11062 through 11067 and 11080.

14 CFR § 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 battery powering the named sUAS rotorcrafts provides approximately 25 minutes or less of

powered flight in the case ofthe rotorcrafts and 40 minutes in the case of the 3DR fixed wing

craft. To meet the 3 0 minute reserve requirement in 14 CFR § 91.151, s U AS flights would not

be able to effectively fly. Sonic Aviation Services believes that an exemption from 14 CFR §91.151(a)

is safe and falls within the scope of prior exemptions.

Operating the sUAS in a controlled area with a limitation on the flight upon reaching 20% of

battery power does not engender the type of risks that Section 91.151(a) was intended to alleviate

given the size and speed of the sUAS. Sonic Aviation Services believes that an equivalent level of

safety can be achieved in this manner. This restriction would be more than adequate to return the

sUAS to its planned landing zone from anywhere in its limited operating area. Similar

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673,

and 10808.

14 CFR §91.405 (a); 407 (a) (1); 409 (a) (1) and (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. Given that these

sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will

not apply to Sonic Aviation Services. Maintenance will be accomplished by Sonic Aviation Services

pursuant to Sonic Aviation Services' operations manuals and practices along with manufacturer 

specifications.

An equivalent level of safety will be achieved because these small UASs are very limited in size

(less than 25 pounds), will carry a small payload and operate only in restricted areas for limited

periods oftime with no flammable fuel. If mechanical issues arise the sUAS can land

immediately and will be operating from no higher than 400 feet AGL.

As provided herein Sonic Aviation Services will ensure that the sUAS is in working order prior to

initiating flight, perform a preflight safety checklist, perform required maintenance, and keep a
log of any maintenance performed. Moreover, Sonic Aviation Services is most familiar with the aircraft

and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level

of safety.
APPENDIX B

• DJI Phantom 3 

Phantom 3 Professional Release Note

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Release_Note_en_9.9.pdf

Phantom 3 Professional Quick Start Guide (EN) v1.2

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_v1.2.pdf

Phantom 3 Professional User Manual (EN) v1.4

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

Phantom 3 Professional In the Box (EN)

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_In_the_Box_en_0901.pdf

Phantom 3 Safety Guidelines and Disclaimer 

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en_201509.pdf

• DJI Inspire 1

Inspire 1 Release Note

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Release_Notes_en_0908.pdf

Inspire 1 Disclaimer & Warning

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Disclaimer_and_Warning_en.pdf

Inspire 1 Quick Start Guide (EN) v1.4

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_v1.4_en.pdf

Inspire 1 User Manual (EN) v1.4

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

Inspire 1 Safety Guidelines v1.0

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf

Inspire 1 Maintenance Manual v1.0

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf

Inspire 1 In the Box

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_In_the_Box_en.pdf