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## suzanne turner ASSOCIATES sta-la.com 1 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