~ 

w~ suzanne turner ASSOCIATES sta-la.com1 22 5 -343 -002 3 

LANDSCAPE ARCHITECTI;RL- 635 Louisiaria Avenue 1 Baion Rouge, LA 70802 

January 4, 2016 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 

Pursuant to Section 333 of the FAA modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, Suzanne Turner Associates, LLC, owner and operator of Small Unmanned Aircraft Systems 

(UAS), requests to be exempted from the Federal Aviation Regulations (FAR's) listed below so that 

Suzanne Turner Associates, LLC may operate UAS commercially in airspace regulated by the Federal 

Aviation Administration, as long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by section 333. 

The name and address of the applicant is: 

Suzanne Turner Associates, LLC 

Attention: Suzanne Turner 

635 Louisiana Avenue 

Baton Rouge, LA 70802 

turner@sta-la.com 

225-343-0023 

Suzanne Turner Associates, LLC (STA), provides landscape architectural consulting, to both private and 

public sectors. STA prepares landscape plans, research documents and construction drawings for various 

sites across the country. STA has routinely over the past two years used an UAS to assist with site 

surveying, aerial imaging, and existing conditions analysis of properties. In those two years, we have 

operated the UAS in a safe manner and have not operated under any circumstances that would be 

considered dangerous, unsafe, or illegal. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use, including landscape architecture, 

land surveying, engineering, and other related professional activities. 

2. Aerial inspection/photography of residential/commercial structures and property under 

contract with the owners or local government authority. 

3. Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines, and cell towers. 
Suzanne Turner Associates, LLC, respectfully requests the grant of an exemption to the following specific 

sections of the Title 14 Code of federal regulations allowing it to operate lightweight UAS for commercial 

use: 

14 CFR 21 (h); 14 CFR 45.23(b); 14 CFR 61.3(a); 14 CFR 91.7(a), 91.9(b)(2), 91.103(b), 

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

91.417(a & b) 

We plan to operate a DJI Phantom 1 which is comprised of an unmanned aircraft (UA or Phantom 1) 

referred to as a quad-copter, with a maximum gross weight of about three (3) pounds. It is equipped 

with four rotors that are driven by electric motors powered by batteries. The UA has a maximum 

airspeed of 16 m/s. 

Given the small size of the UAS involved and the restricted controlled environment within which it will 

operate, the applicant fits within that zone of safety in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commerce immediately. Also, due to the size of the 

UAS and the controlled areas in which it will operate, approval of the application presents no national 

security issue. 

Suzanne Turner Associates, 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 exceptional level of safety to operations. These limitations and conditions to which STA agrees to be 

bound when conducting commercial operations under an FAA issued exemption including: 

• The UAS will weigh less than 55 Ibs. 

• Flights will be operated within line of sight of operator. 

• Flights will only occur in the daytime and clear of clouds. 

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

• Flights will be terminated at 15% battery power reserve. 

• Flights will be operated at an altitude of no more than 400 feet AGL. 

• The UAS will only operate within a controlled area as defined in the procedures. 

• Operator, camera operator, and observers will be trained as to the applicable portion of the 

UAS's manual and Standard Operating Procedures. 

• The operator will post advisor notice around the controlled area. 

• The operator will have been trained in operation of UAS generally, and received up-to-date 

information on the particular UAS to be operated as required. 

• If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to 

a pre-determined location within the security perimeter and land. 

• STA will obtain consent (written or verbal) for any persons who need to be within 100 feet of 

UAS flight operations. 

• Written and/or verbal permission from the relevant property owners will be obtained prior to 

flight. 

• AII required permissions and permits would be obtained from parish, city, or state jurisdictions, 

including local law enforcement, fire, or other governmental agencies. 
14 C.F.R. 61.3(a): Requirement for certificates, ratings, and authorizations. 

Model aircraft operations are for hobby or recreational purposes only. The FAA has partnered with 

several industry associations to promote a campaign to educate the public about using unmanned 

aircraft (UA) safely and responsibly. Individuals flying for hobby or recreation are strongly encouraged 

to follow safety guidelines, which include: 

Fly below 400 feet and remain clear of surrounding obstacles; keep the aircraft within visual line of sight 

at all times; remain well clear of and do not interfere with manned aircraft operations; don't fly within 

five miles of an airport unless you contact the airport and control tower before flying; don't fly near 

people or stadiums; don't fly an aircraft that weighs more than 55 Ibs; don't be careless or reckless with 

your unmanned aircraft, you could be fined for endangering people or other aircraft. 

The statutory parameters of model aircraft operations are outlined in Section 336 of Public Law 112-95 

(the FAA Modernization and Reform Act of 2012). Individuals who fly within the scope of these 

parameters do not require permission to operate their UAS, nor do they require a pilot's license or 

certificate. 

As the UAS is operating an unmanned aircraft within the same guidelines/parameters as the model 

aircraft operations, be it hobby, recreational, or civil, a pilot's license/certificate in inapplicable. 

14 CFR Part 21 Subpart H: Airworthiness Certificates, 14 CFR 91.7(a), 91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR 91.201(a)(1). The size, weight, and defined area of 

operations for SCI UAS flights permits exemption from Part 21 because Suzanne Turner Associates, LLC 

meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the ACT (49 U.S.C. 44701(f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from the 

airworthiness certificate requirement in consideration of weight, size, speed, maneuverability, and 

proximity to areas such as airports and dense populations. STA meets or exceeds each of these 

elements. 

14 CFR 91.203 (a, b) provides for carrying of civil aircraft certifications and registrations. They are 

inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by 

maintaining such certifications and registrations at Suzanne Turner Associates, LLC, or with the UAS 

operator. 

14 CFR 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this regulation is inapplicable. 

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots of passengers, 

and given the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining an operator manual at the flight operations center. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 10700, and 32827. 
14 CFR 91.103(b): Preflight actions 

14 CFR 91.103 states that each pilot in command shall, before beginning a flight, become familiar with 

all available information concerning that flight. This information must include: (b) For any flight, runway 

lengths at airports of intended use, and the following takeoff and landing distance information. This 

subparagraph is not applicable due to our off airfield operations. 

14 CFR 91.109: Flight instructions; Simulated instrument flight and certain flight tests 

14 CFR 91.109 and all the subparagraphs address the operation of a civil manned aircraft in conjunction 

with training and flight tests. The UAS to be used by Suzanne Turner Associates, LLC is not designated in 

this category. 

14 CFR 91.121: Altimeter Settings 

14 CFR 91.121 regarding altimeter settings is inapplicable because Suzanne Turner Associates, LLC UAS 

utilizes GPS systems and internal gyroscopes to provide spatial stability and a reference datum. 

14 CFR 91.151: Fuel Requirements for Flight in VFR Conditions 

14 CFR 91.151 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. 

The battery powering the UAS provides approximately 15 minutes of powered flight, which is less than 

the reserve requirement alone by FAR. Given the limitations on the UAS's flight envelope, proposed 

AOR size, battery life, and its ability to land immediately, it is reasonable to allow an exception. 

An equivalent level of safety can be achieved by limiting flights to 25% of battery power. This restriction 

would be more than adequate to return the UAS to its planned landing zone in the AOR. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10573, and 

10808. 

14 CFR 45.23: Marking of the Aircraft 

Applicable Codes of Federal regulations require aircraft to be marked according to certain specifications. 

SCI UAS's are unmanned; do not have a cabin, cockpit, or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is impractical to place on such small aircraft. However, STA will 

place a label with our name and address on its fuselage as required by 14 CFR 45.29(f) so that the 

operator can see the markings on the UAS. The FAA has previously issued exemptions to this regulation 

through Exemptions 8738, 10167, 10167A, and 10700. 

14 CFR 91.119: Minimum Safe Altitudes 

14 CFR 91.119 prescribes safe altitudes for the operation of civil aircraft. Suzanne Turner Associates, LLC 

will only operate its UAS below 400 AGL, in a defined area of responsibility that has been carefully 

reviewed for hazards and minimizes the presence of any persons not essential to the program. Flights 

will only be conducted over private property with consent of the owner. The equivalent level of safety 

will be achieved given the size, weight and speed of the UAS as well as the location where it is operated. 
14 CFR 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 the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as prescribed 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." 

These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

to an UAS should its requested exemption be granted. As an equivalent level of safety, STA requires its 

operators to conduct a preflight, through flight, and post flight inspection of the UAS to ensure its flight 

worthiness. Each UAS is flown in compliance with the applicable manufacturer's manual to include all 

software update cycles as well as flight checklists. In the event of a malfunction, the UAS can land 

immediately. 

The small size of the UAS utilized by Suzanne Turner Associates, LLC, combined with the safety protocols 

already in place, will allow for a greater level of safety in which Congress envisioned that the FAA must, 

be exemption, allow commercial operations of UAS's to commence immediately. 

Summary 

Usage of unmanned aircraft systems is in the public interest because it allows companies to reduce 

costs, remain competitive, and become more environmentally friendly. UAS's do not carry harmful fuel 

which can be dangerous to the environment if they crash. They are virtually noiseless, and since they are 

unmanned, there is no danger to personnel who may have to work in difficult or unsafe environs; they 

are safe on the ground. 

Suzanne Turner Associates, LLC is seeking exemption from the following rules: 

14 CFR 21 (h); 14 CFR 45.23(b); 14 CFR 61.3(a); 14 CFR 91.7(a), 91.9(b)(2), 91.103(b), 

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

91.417(a & b) 

The combination of the aircraft's light weight, limited flight times, limited flight altitudes, historically 

demonstrated safe flight performances, and qualified operators who operate under strict guidelines, the 

FAA can have confidence that granting these exemptions will in no way diminish the safety conscious 

culture established over the two years that the UAS has been in usage at Suzanne Turner Associates, 

LLC. 

Sincerely, 

Suzanne Turner, Principal