Buffalo Computer Consulting 

James Anderson 

733 Fort Street 

Buffalo, Wyoming 82834 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption from Section 333 of the FAA Reform Act 

Dear Sir/Madam, 

November 15, 2015 

Pursuant to Section 333 of the FAA Mondernization and Reform Act of 2012 (the reform act), 

and 14 C.F.R. Part 11. James Anderson an Associate employed at Buffalo Computer Consulting, 

LLC (BCC) and operator of Small Unmanned Aircraft System (sUAS), would like to request for 

exemption from the Federal Aviation Regulations (FAR) listed below to allow BCC to operate 

sUAS commercially in airspace regulated by the FAA so long as such operations are conducted 

with and under the conditions outlined herein or as may be established by the 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 of the 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 during filming 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 complying with all of the rules, guidelines, limitations, 

and future legislation set forth by the FAA. I agree to operate the sUA$ in the manner that I 

have described, and for the purposes that I have described. With this exemption request 
granted, 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 flying the 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 under 25%. The sUAS will operate within the line of sight 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 communication possible. These operations will not create a 

hazard to users of the nation airspace, public nor the environment. 

Buffalo Computer Consulting is requesting exemption to the following specific sections of the 

Title 14 Code of Federal regulations allowing it to 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 submits this application in accordance with the Reform Act, 

112 P.L. 95 331-334, seeking relief from any current applicable FAR's operating to prevent 

Buffalo Computer Consulting, LLC future commercial use of small sUAS to operate in the 

national airspace system. 

All sUAS will have the capability to return automatically to the operator in a safe manner with 

the auto return function checked and working. 

Flights will only operate in VFR conditions. 

sUAS have a function on the control to tell operator the distance away from the operator and 

its battery power remaining. 

Flight team will communicate by voice and the use of two-way radio. If the area is too big to 

hear voice from all team members. 

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(l) Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for 

Buffalo Computer Consulting, LLC UASs flights 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 permit the 

FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. Buffalo 

Computer Consulting, LLC meets or exceeds each of these elements. 
As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for 

flights at or under 200 AGL to any UASs operator with a section 333 exemption. 

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These 

are inapplicable for the same reasons stated above. The equivalent level of safety 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. 

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

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

passengers, and given the size of the 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 exemptions to 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 of any 

persons not essential for these operations. Flights will only be over private property that the 

owner has consented and all persons within this video area also give consent for this filming. 

Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far 

more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far 

smaller risk to the public. 

The size of these sUAS combined with the safe guards presented below, will allow for the safe 

operation greater than that envisioned by Congress for the FAA to establish and by exemption 

allow commercial operations of sUAS to commence immediately. Also due to the size of sUAS 

and the areas and altitudes they will operate approval of this 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 of the Reform 

Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent 

level of enhanced safety, reduced emissions utilized sUAS verses traditional aircraft as well as 

the economic impact of greatly reducing the cost of aerial photography thereby benefiting the 

greater public's interest. Accordingly, the applicant requests that the FAA grant the requested 

exemption without delay. 
Described below are the responsibilities that will be followed by James 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 prior to flight to insure safety of all persons in the area. 

7. Following manufacturers recommendations of weather conditions. If weather and 

wind deteriorate all flights will be cancelled and rescheduled. 

8. sUAS will have the capability to return automatically to the operator in a safe 

manner with the auto return function checked and working. 

9. Prior to 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 way to 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/controller or 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 by the PIC from any moving device or vehicle. 

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 

flight time 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 benefit their business and personal matters. 

Buffalo Computer Consulting, LLC respectfully requests the FAA grant its exception. The FAA 

has the authority to issue the exemption sought by Buffalo Computer Consulting, LLC pursuant 

to the 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)