Buffalo Computer Consulting James Anderson 733 Fort Street Buffalo, Wyoming 82834

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave. SE Washington, DC 20590 Re: Exemption from Section 333 ofthe FAA Reform Act

Dear Sir/Madam, November 15, 2015

Pursuant to Section 333 ofthe FAA Mondernization and Reform Act of2012 (the reform act), and 14 C.F.R. Part 11.James Anderson an Associate employed at Buffalo Computer Consulting, LLC (BCC) and operator ofSmall Unmanned Aircraft System (sUAS), would like to request for exemption from the Federal Aviation Regulations (FAR) listed belowto allow BCC to operate sUAS commercially in airspace regulated by the FAA so long as such operations are conducted with and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. Buffalo Computer Consulting, LLC, Heidi J Roberts(owner) and employee Associate James Anderson request exemption to provide services to clients using sUAS in the following areas: Guest Ranch, Farming and Ranch survey, Real Estate, Appraisals, and Special events

. James Anderson will be the sole operator for all sUAS flgihts. James Anderson a native Wyoming resident, with a Wyoming valid driver's license and a sport pilot's license will be the main and only pilot ofthe sUAS. James Anderson and BCC states that all sUAS flights will be over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the UAS radius duringfilming and photography applications. All operations will be perfo

.rmed with the public's safety and right to privacy safeguarded at all times. I, James Anderson will be committed to complyingwith all ofthe rules, guidelines, limitations, and future legislation set forth bythe FAA

. I agree to operate the sUA$ in the mannerthat I have described, and forthe purposes that I have described. With this exemption requestgranted, I will be able to provide a service that our clients do not have easy access to

. We live in a low populated area and this service is not currently available in our area. Buffalo Computer Consulting will be flyingthe 3D Robotics 3DR IRIS weighing less than 55 pounds including payload

. Future UAS will be experimental, 3DR X81RIS, Inspire One or equivalent. These units operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously

. An Auto return to launch point when battery power is under25%. The sUAS will operate within the line ofsight within a protected flight area as described below and at 400 feet AGL or less with an observer located close at hand as to make voice commun ication possible. These operations will not create a hazard to users ofthe nation airspace, public northe environment

. Buffalo Computer Consulting is requesting exemption tothe following specific sections ofthe Title 14 Code of Federal regulations allowing itto operate lightweight sUAS for commercial purposes. Regulations from which exemption is requested: 14 CFR 21, subpart H, 14 CFR 45.23 (b) 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)&(b)

. Buffalo Computer Consulting, LLC submitsthis application in accordance with the Reform 

### Act, 112 P.L. 95 331-334, seeking relieffrom any current applicable FAR's operatingto prevent Buffalo Computer Consulting, LLC future commercial use of small sUAS to operate in the national airspace system. All sUAS will have the capabilityto return automatically to the operator in a safe mannerwith the auto return function checked and working

. Flights will only operate in VFR conditions. sUAS have a function on the control to tell operatorthe distance away from the operator and its battery power remaining. Flight team will communicate byvoice and the use oftwo-way radio. Ifthe area is too big to hear voice from all team members

. 14 CFR part 21 Subpart H: Airworthiness Certificate 14CFR 91.7(a), 91.203(a)(l) Subpart H, entitled Airworthiness Certificates, sets forth requirementsfor procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area ofoperations for Buffalo Computer Consulting, LLC UASs fl ights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAA to exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations

. Buffalo Computer Consulting, LLC meets or exceeds each ofthese elements.As of March 23, 2015 the FAA has stated that itwill automatically grant a "blanket" COA for flights at or under 200 AGL to any UASs operatorwith a section 333 exemption. 14CFR 91

.203(a&b) provides for carrying ofcivil aircraft certifications and registrations. These are inapplicable forthe same reasons stated above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations at Buffalo Computer Consulting operations center

. 14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate

. As no such certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable

. 14CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Buffalo Computer Consulting, LLC operations center

. The FAA has previously issued exemptionsto this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,l0602,10700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft

. It allows helicopters to be operated at lower altitudes in certain conditions. Buffalo Computer Consulting, LLC will only operate its UASs at or below 400AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence ofany persons not essential forthese operations. Flights will only be over private propertythat the owner has consented and all persons within this video area also give consent forthis filming. Compared to flight operations ofconventional and traditional aircraft or rotorcraft weighingfar more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present afar smaller risk to the public. The size ofthese sUAS combined with the safe guards presented below, will allow for the safe operation greaterthan that envisioned by Congress forthe FAA to establish and by exemption allow commercial operations of sUAS to commence immediately. Also dueto the size ofsUAS and the areas and altitudes they will operate approval ofthis exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level ofenhanced safety, reduced emissions utilized sUAS verses traditional aircraft as well as the economic impact ofgreatly reducing the cost ofaerial photography thereby benefitingthe greater public's interest. Accordingly, the applicant requests thatthe FAA grantthe requested exemption without delay.Described below are the responsibilities that will be followed byJames Anderson and Buffalo Computer Consulting, LLC. 1. The current and future sUAS will weigh less that SSibs., 2. Flights will be operated at 400 feet AGL or less

. 3. The sUAS will be operated at less than SO knots 4. Flights will only occur in the daylight ours. 5

. All operations will consist of an observer and remain in full contact with pilot at all times. Both visually and verbally. 6. Operator will examine area priorto flight to insure safety of all persons in the area. 7. Following manufacturers recommendations ofweather conditions. Ifweather and wind deteriorate all flights will be cancelled and reschedu led. 8. sUAS will have the capabilityto return automatically to the operator in a safe mannerwith the auto return function checked and working. 9. Priorto each flight the operator will maintain and inspect the sUAS to ensure it is in full working condition and is safe to fly. 10. Operator will follow manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 11

. The UA must remain clear and give wayto all manned aviation operations and activities at all times

. 12

. All operations shall be conducted over private or controlled access property with permission from the property owner/controlleror authorized representative

. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 13. The PIC will abort any flight in the event of unprecedented obstacles or emergencies. 14

. The sUAS may not be operated bythe PIC from any moving device orvehicle

. 15

. All flights will occur in ordinance with any state or local laws regarding privacy. 16. Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flighttime to safely land the sUAS. 17. lfthe UAS loses communications or loses its GPS signat the UA must return to a predetermined location within the private or controlled-access property

.Granting Buffalo Computer Consulting, LLC this exception will allow us to provide a service to our customers that will benefittheir business and personal matters. Buffalo Computer Consulting, LLC respectfully requests the FAA grant its exception. The FAA has the authorityto issue the exemption sought by Buffalo Computer Consulting, LLC pursuant tothe Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).
Sincerely

Heidi J. Roberts Owner Buffalo Computer Consulting 733 Fort Street Buffalo, Wyoming 82834 hsroberts@collinscom.net 307-684-2272 (office) 307-620
-2229 (cell phone)



# ~.0

**~-**

James Anderson Associate Buffalo Computer Consulting 733 Fort Street Buffalo, Wyoming 82834 typecookie@gmail.com 307
-684-2272 (office)