Rival Services, LLC

14400 Highway 34

Ft Morgan, CO 80701

970-867-9437

June 24, 2015

US Department of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington, DC 20591

Dear Sir or Madam:

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

owner and operator of Small Unmanned Aircraft Systems (UAS’s), request to be exempted from the Federal 

Aviation Regulations (FAR’s) listed below so that Rival Services, LLC, may operate UAS’s commercially within 

airspace regulated by the FAA, 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.

Rival Services, LLC, is owned by Jeff Schneider. The operator of the UAS’s is Chad Lambert. Chad is an FAA 

Commercial rated pilot ASEL, AMEL, Instrument Airplane as well as a Certified Flight Instructor and Instrument 

Instructor. Chad has accumulated 1,600 hours to date. He keeps a current FAA Medical with no limitations and 

has been operating UAS’s for 4 years. Chad will be the sole manipulator of the aircraft. All operations to be 

conducted with the public’s safety and right to privacy strictly adhered to at all times.

As described below, the requested exemption would permit the operation of light weight (less than 55 lbs. total 

take-off weight) UAS’s under controlled conditions for commercial use by Rival Services, LLC, thereby enhancing 

safety and fulfilling the Secretary of Transportation’s responsibility to “establish requirements for safe operation of 

such aircraft systems in national airspace systems.” Section 333(c), of the Reform Act.

Rival Services, LLC, UAS’s is a Quad Copter weighing less than 55 pounds including the payload (DJI Phantom 3 

Professional Quad Copter). They operate at a speed less than 50 knots and have a capability to hover and move in 

the vertical and horizontal plane simultaneously. The Phantom 3 has an auto return to the departure point when 

exceeding the manufacturers recommended distance from the controller, when the signal between the controller 

is lost, or when the battery power is under 25%. The Phantom 3 will be operated within the “line of sight” in a 

protected flight area at 200’ AGL or lower. These operations will not create a hazard to users of the national 

airspace system or the public.

Rival Services, LLC, submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief 

from any currently applicable FAR’s operating to prevent Rival Services, LLC, future commercial use of small UAS’s 

to operate in the national airspace system as described below. The Reform Act Section 332 provides for such 

integration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do so. 

Rival Services, LLC, UAS’s meet the definition of “small unmanned aircraft” as defined by Section 331 and therefore 

the integration of these UAS’s are expressly contemplated by the Reform Act. Rival Services, LLC, would like to 

operate its light weight UAS’s prior to the time period by which the Reform Act requires the FAA to promulgate 

rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system before the completion of the rule making required under 

Section 332 of the Reform Act. In making this determination, the Secretary of Transportation is required to 

determine which UAS’s do create a hazard to users of the national airspace system or the public or pose any threat 

to national security in light of the following:
1. The UAS’s size, speed, weight and operational capability.

2. Operation of the UAS’s in close proximity to airports and populated areas.

3. Operation of the UAS’s within visual line-of-sight of the operator.

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in the National Airspace 

System, the secretary shall establish requirements for the safe operation in national airspace.

Rival Services, LLC, will be using the Phantom 3 at speeds less than 50 knots with the ability to operate in the 

vertical and horizontal plane simultaneously. The Phantom 3 will be operated within “line-of-sight” of the 

operator within a protected flight area and at 200’ AGL or lower. This will not present a hazard to the national 

airspace system or the public.

The small nature of the UAS, combined with the safe guards presented in this document, will allow for the safe 

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

operations of UAS’s to commence immediately. Also, due to the size of the UAS and the areas and altitudes 

operated, approval of this exemption presents no national security issues and absolutely minimal safety concerns 

which have been mitigated through our risk management process. Given the clear direction 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 utilizing UAS’s versus traditional aircraft as well as the economic impact of 

greatly reducing the cost of aerial photography thereby benefitting the greater public good. Accordingly, the 

applicant requests that the FAA grand the exemption without delay.

The following will be considered as the Standard Operating Procedures, or SOP, of Rival Services, LLC.

1. Sorties will only occur between sunrise and sunset.

2. Sorties will be operated in line-of-sight.

3. Sorties will be terminated when wind or weather is deemed “unsafe for flight” based on manufacturers 

limitations.

4. The UAS will weigh less than 55 lbs.

5. Sorties will be operated at less than 200’ AGL

6. The operator will perform pre-flight checks of the flight area to ascertain safety to all persons or property.

7. Consent will be obtained from everyone within the limitations of the video to ensure privacy.

8. All FAA clearances will be obtained and distances from airports strictly adhered to.

9. All UAS’s will have the capability to return automatically to the operator, in a safe manner, with the auto 

return function.

10. Flights will only operate in VFR.

11. UAS flight controllers will display range and battery power remaining.

12. A pre-flight check will be done prior to each sortie.

13. All routine inspections and maintenance will be done in accordance with manufacturer’s

recommendations.

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

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 Rival Services, LLC, 

flights permit exemptions from part 21 because they meet an equivalent level of safety pursuant to Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS’s from airworthiness certificates in 

consideration of weight, size, speed, maneuverability, and proximity to areas such as airports and densely 

populated areas. Rival Services, LLC, meets or exceeds each of these items.

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 UAS operators with a Section 333 Exemption.
14 CFR, Part 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are not 

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

certifications and registrations by Rival Services, LLC.

14 CFR, Part 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 FAR’s this regulation is not applicable.

14 CFR, Part 91.9(b)(2) requires a “Civil Aircraft Flight Manual” in aircraft. As there are no pilots or passengers and 

given the size of the UAS this regulation is not applicable.

The FAA has previously issued exemptions to this regulation in Exemptions 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602, 10700, and 332827.

14 CFR, Part 91.119 Minimum safe altitudes prescribes safe altitudes for operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes under certain conditions. Rival Services, LLC, will only operate its 

UAS’s at or below 200’ AGL. They will be operated in a well-defined area of operation 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 with the owner’s consent.

Approval of these 333 Exemptions allowing commercial use of small UAS’s in the service of aerial photography will 

greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial 

photography requires large aircraft with fuel potentially flying over or in close proximity to populated areas. With 

the use of small battery powered UAS’s, of 55 lbs or less, the risk of injury to people on the ground is drastically 

reduced.

Granting Rival Services, LLC, the above exemption will allow for the expansion of the use of UAS aircraft in the 

future for the safe conduct of free enterprise.

Rival Services, LLC, respectfully requests the FAA grant it’s exemption without delay. The FAA has the authority to 

issue this exemption pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the act).

Sincerely,

Chad R Lambert

clambert@schneiderenergy.com

Rival Services, LLC

14400 Highway 34

Fort Morgan, CO 80701