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March 6, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

 Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 

61.113(a)&(b); 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).

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and 14 C.F.R. Part 11, Tri-State Aerial Solutions, (“Tri-State Aerial Solutions”) 

Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to offer on-demand 

commercial UAS operations for a host of industries and applications and to perform the 

purposes listed below, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA in an exemption granted under either Section 333 or Section 49 

U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

predetermined; and 3) would provide safety enhancements in the fields in which it will 

operate, which now depend upon conventional aircraft or humans climbing high on 

dangerous structures, and working adjacent to treacherous infrastructure. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of 

such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.
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Name and address of applicant:

Tri-State Aerial Solutions

Attn: Jason T. Snyder (Private Pilot)

Email: jtsnyder85@gmail.com

Address: 1236 12th Street, Nitro, WV 25143

Background

Tri-State Aerial Solutions is under Jason T. Snyder’s direction. Jason T. Snyder is a 

private pilot (Private Pilot Certificate #2742561 issued 27DEC2002) and a highly 

accomplished, capable, experienced and trusted professional.

Tri-State Aerial Solutions is an aerial photography firm specializing in safe and 

efficient industrial inspection applications.

Tri-State Aerial Solutions employs professionals in the fields of photography, 

inspection and safety management. They have a combined 29 years of flight and safety 

management experience and are experienced with the systems, characteristics and safety 

features of the sUAV equipment they operate. Aerial photography has become an 

important element in their inspection process and safety management. Tri-State Aerial 

Solutions aims to provide the highest quality visuals while practicing safety measures such 

as pre-flight safety check lists, pre-flight site walkthroughs and tours, pre-flight 

photography shot list and planning, and adherence to the regulations and parameters set 

forth by the FAA.

Regulations from which the exemption is requested:

 14 CFR Part 21

 14 C.F.R. 45.23(b)

 14 CFR 61.113 (a) & (b)

 14 C.F.R. 91.7 (a)

 14 CFR 91.9 (b) (2)

 14 C.F.R. 91.103

 14 C.F.R. 91.109

 14 C.F. R. 91.119

 14 C.F.R. 91.121

 14 CFR 91.151 (a)

 14 CFR 91.203 (a) & (b)

 14 CFR 91.405 (a)

 14 CFR 407 (a) (1)

 14 CFR 409 (a) (2)

 14 CFR 417 (a) & (b)
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Introduction:

Tri-State Aerial Solutions requests the agency issue a summary grant process for 

this application. Tri-State Aerial Solutions has identified recently approved exemption 

numbers whereby the FAA has already granted a previous exemption similar to these

requests for the following:

 Commercial purposes

 Type of sUAVs (UAS)

 Title 14 Exemptions 

Description of Type, Make and Models of sUAV/UAS Requested:

Tri-State Aerial Solutions is seeking an exemption to commercially operate sUAV’s 

makes and models as follows: 

Blade Chroma; DJI Inspire 1; DJI Phantom 3

Each sUAV weighs 55 lbs. or less, with payload. 

Purposed Commercial Operation: 

This exemption request, once granted would allow Tri-State Aerial Solutions to 

operate a small unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to 

conduct structural inspections, flare stack inspection, utility-power generation system 

inspections and patrolling, aerial inspection, photography and videography of residential 

and commercial real estate, aerial inspection, photography and videography of utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, and videography, precision agriculture with on 

board sensors, wildlife and forestry monitoring, aerial surveying, construction site 

inspection and monitoring, public entity support operations, aerial imaging for safety, 

monitoring and comparing work efforts and completion percentages, and security of 

controlled environment of various sites, aerial video and live video feed to assist with 

search and rescue operations under the authority and support of local authority officials, 

aerial video and photography for public and private use, public events, training to persons 

individually or belonging to both private and public organizations to increase awareness 

and improve safety for current and future UAS operations within the NAS, risk 

management and assessment, mining, disaster and catastrophe events.
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Public Benefit as a Whole:

Tri-State Aerial Solutions proposes the use of its sUAV provided equivalent or 

augmented levels of safety for each of the uses proposed herein: 

The present systems of photography and videography and mapping of inspecting 

the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, 

are now conducted by either a person climbing on the roofs and structures that are steep, 

tall, slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must 

climb on the roofs or require the use of aircraft that are orders of magnitude greater in size 

than the sUAV. Either method, manual inspection or large conventional aircraft, results in 

increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders 

and dealing with confined and dangerous spaces, or increased risk from low altitude 

flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from 

storms or other disasters, such as earthquakes or fires. Such flights are, of course, 

significantly more expensive than those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of the 

conventional aircraft at the inspection site because the aircraft must be flown to and from 

the site. By contrast, the sUAV is carried to the site and transits no other property. 

Conventional aircraft carry flammable fuels that are not carried by the sUAVs and emit 

pollutants associated with internal combustion engines. The sUAVs proposed herein are 

battery powered and have no emissions.

Aircraft and Equivalent Level of Safety to the Existing Rule:

Tri-State Aerial Solutions 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 at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the operations conducted with conventional aircraft or 

with humans climbing up and around structures. These conditions are drawn from 

Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112, and 11213 and 

as recent as 11857.

These limitations and conditions to which Tri-State Aerial Solutions (referred to as 

“operator”) agrees to be bound when conducting commercial operations under an FAA 

issued exemption include: 
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1) Operations authorized by this grant of exemption are limited to the 

aircraft described in the Operator’s manual, which is a multi-rotor 

weighing up to 55 pounds. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant. 

2) The UA may not be flown at an indicated airspeed exceeding 30 mph 

(10 mph during inspections). 

3) The UA must be operated at an altitude of no more than 200 feet above 

ground level (AGL), as indicated by the procedures specified in the 

Operator’s manual. All altitudes reported to ATC must be in feet AGL. 

4) The UA must be operated within visual line of sight (VLOS) of the 

Aircraft Operator at all times. This requires the Aircraft Operator to be 

able to use human vision unaided by any device other than corrective 

lenses. 

5) The Exemption Holder’s Manuals must be amended to include all 

conditions and limitations required by the FAA. The Manuals must be 

maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the 

exemption and the procedures outlined in the Exemption Holder’s 

Operator’s manual, the conditions and limitations in the exemption take 

precedence and must be followed. Otherwise, the Aircraft Operator 

must follow the procedures as outlined in its Aircraft’s manual. The 

Exemption Holder may update or revise its Manuals. It is the Exemption 

Holder’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The Exemption 

Holder must also present updated and revised documents if it petitions 

for an extension or amendment of this exemption. If the Exemption 

Holder determines that any update or revision would affect the basis 

upon which the FAA granted this exemption, then the Exemption 

Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to 

ensure it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been 

performed, and the UAS is found to be in a condition for safe flight. The 

Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the 

aircraft records.

7) Any UAS that has undergone maintenance or alterations that affect the 

UAS operation or flight characteristics, e.g., replacement of a flight 
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critical component, must undergo a functional test flight in accordance 

with the Exemption Holder’s Manuals. The Aircraft Operator who 

conducts the functional test flight must make an entry in the UAS 

aircraft records of the flight. The requirements and procedures for a 

functional test flight and aircraft record entry must be added to the 

Exemption Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, 

and life limit requirements, with particular attention to flight critical 

components that may not be addressed in the manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, and 

record keeping requirements in accordance with the Operator’s 

Manuals. Maintenance, inspection, and alterations must be noted in the 

aircraft logbook, including total flight hours, description of work 

accomplished, and the signature of the authorized technician returning 

the UAS to service.

10) The authorized technicians must receive and document training 

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record 

entry in the UAS logbook or equivalent document of the corrective 

action taken against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have 

logged at least 25 hours of total time as a UA rotorcraft pilot and at least 

ten hours logged as a UA pilot with a similar UA type and 5 hours in the 

make and model.

14) If the UAS loses communications or loses its GPS signal, the UA must 

return to a pre-determined location within the private or controlledaccess property and land or be recovered in accordance with the 

Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of unpredicted 

obstacles or emergencies, including unauthorized people entering the 

flight area, in accordance with the Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight unless 

(considering wind and forecast weather conditions) there is enough 

power to fly to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes.
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17) All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 CFR part 

47, and have identification (N- Number) markings in accordance with 

14 CFR part 45, Subpart C. Markings must be as large as practicable.

18) Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be 

available to the Operator at the Ground Control Station of the UAS any 

time the aircraft is operating. These documents must be made available 

to the Administrator or any law enforcement official upon request. 

20) The UA must remain clear and yield the right of way to all other 

manned operations and activities at all times (including, but not limited 

to, ultra-light vehicles, parachute activities, parasailing activities, hang 

gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any moving 

device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14 

CFR 1.1.

23) All operations must be conducted under visual meteorological 

conditions (VMC). The UA may not be operated less than 500 feet below 

or less than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the Operator.

24) During operations the UA may not operate within 5 nautical miles of the 

geographic center of an airport as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance 

with a NOTAM, if as required by the Operator’s COA. The letter of 

agreement with the airport management must be made available to the 

Administrator upon request.

25) The UA may not be operated over congested or densely populated areas 

unless the conditions set for in #26 are satisfied. These populated areas 

include but are not limited to the yellow areas depicted on World 

Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), 

or Terminal Area Charts (TAC). However, aeronautical charts may not 

reflect pertinent local information. Ultimately, it is the Operator’s 

responsibility to maintain the minimum safe altitudes required by § 

91.119 (d) (1). 
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26) Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from debris in the event of an accident. 

The Aircraft Operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 30 

feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where 

the land owner/controller has granted permission and/or the 

Aircraft Operator has made a safety assessment of the risk of 

operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an undue 

hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or 

authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be 

conducted.

28) Any incident, accident, or flight operation that transgresses the lateral 

or vertical boundaries of the operational area as defined by the 

applicable COA must be reported to the FAA’s UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

Equivalent Level of Safety:

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command; 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the Tri-State Aerial 

Solution’s sUAV is remotely controlled with no passengers or property of others on board. 

Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in 

command of an aircraft for compensation or hire. 

Tri-State Aerial Solution’s UAV respectfully proposes that operator requirements 

should take into account the characteristics of the particular UAS. Tri-State Aerial 

Solution’s UAV has a high degree of pre-programmed control and various built-in technical 

capabilities that strictly limit the potential for operation outside of the operating conditions 

set forth in the exemption application. Tri-State Aerial Solution’s UAV has navigation and 
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control system comprised of a Ground Control Station (GCS) and auto-pilot system that can 

be pre-programmed to set operational boundaries. All flights are pre-programmed with 

precision GPS guidance. In the case of unplanned events, the operator may input preprogrammed evasive maneuvers from the control unit, and the onboard autopilot executes 

those maneuvers. Pre-programmed operator interventions include initiation of holding at 

present position; suspension of mission; fly back to launch point; abort mission and land 

immediately; and emergency power cut off and land (Flight Termination System). 

Additional automated safety functions and safety enhancing features of the Tri-State Aerial 

Solution’s sUAVs may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft down in 

flight in the event of a loss of control or un-commanded deviation from the 

flight path. 

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph (while 

imaging) nor above 200 feet above AGL. 

In addition to these safety features, operators of the Tri-State Aerial Solution’s sUAV are

required to hold a private pilot certification. 

The risks associated with the operation of the Tri-State Aerial Solution’s sUAV (given its 

size, speed, operational capabilities, and lack of combustible fuel) are so diminished from 

the level of risk associated with conventional aircraft operations contemplated by Part 61 

with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as 

set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 

61.113(a) & (b).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of 

the UAS without an airworthiness certificate, no standard will exist for airworthiness of the 

UA. Given the size of the aircraft and the requirements that the operator has agreed to as it 

relates to airworthiness, as contained in the manual, an equivalent level of safety will be 

achieved by insuring compliance with the manuals prior to each flight. The FAA has 

granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 

11080 and 11110.
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14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter 

and the exemption requests authority to operate at altitudes up to 200 AGL, an exemption 

may be needed to allow such operations. 

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. No flight will be taken without the permission 

of the property owner, facility owner, and/or local officials. Because of the advance notice 

to the property owner and participants, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented by conventional 

aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the 

low-altitude operations of the sUAS will ensure separation between these small-UAS 

operations and the operations of conventional aircraft that must comply with Section 

91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure airport 

or an appropriate altimeter setting available before departure.” As the Tri-State Aerial 

Solution’s sUAV, in manual or emergency mode, will not have a barometric altimeter 

display, but instead a GPS altitude display, an exemption will be needed. The operator will 

achieve an equivalent level of safety. The FAA has granted exemptions to conduct similar 

operations in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 
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Tri-State Aerial Solutions believes that an exemption from 14 CFR §91.151(a) falls 

within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, 

in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS.

Tri-State Aerial Solutions believes that an equivalent level of safety can be achieved 

by limiting flights to 15 minutes or 25% of remaining battery power whichever happens 

first. This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have been 

granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and 

Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections

These regulations require that an aircraft Operator or owner “shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided 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. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Tri-State Aerial Solutions. Maintenance will be 

accomplished by the operator or manufacturer pursuant to the flight manual and operating 

handbook as referenced in the Manuals attached as an equivalent level of safety will be 

achieved because these small UASs are very limited in size and will carry a small payload 

and operate only in defined areas for limited periods of time. If mechanical issues arise, the 

UAS can land immediately and will be operating from no higher than 200 feet AGL. As 

provided in the Aircraft Flight Operations Manual the operator will ensure that the UAS is 

in working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Additionally, the operator and manufacturer are most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. The FAA has granted exemptions for similar 

operations in Exemptions 11062 through 11067, 11080 and 11110.
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Federal Register Publication:

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Tri-State Aerial Solutions seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito 

and insect control, aerial surveying, construction site inspection and monitoring, public 

entity support operations, aerial video and live video feed to assist with search and rescue 

operations under the authority and support of local authority officials, aerial video and 

photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering, training to persons individually or 

belonging to both private and public organizations to increase awareness and improve 

safety for current and future UAS operations within the NAS, special events: including high 

schools, colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production, surface mining, closed set filming, disaster and 

catastrophe events.

Summary:

Approval of exemptions allowing commercial operations of sUAVs for Tri-State 

Aerial Solutions to operate an unmanned aircraft system (UAS) to conduct structural 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection, photography and videography of residential and commercial 

real estate, aerial inspection, photography and videography of utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, pipeline 

inspection and patrolling, and videography, precision agriculture with on board sensors, 

wildlife and forestry monitoring, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial imaging for safety, monitoring and 

comparing work efforts and completion percentages, and security of controlled 

environment of various sites, aerial video and live video feed to assist with search and 

rescue operations under the authority and support of local authority officials, aerial video 

and photography for public and private use, public events, training to persons individually 

or belonging to both private and public organizations to increase awareness and improve 
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safety for current and future UAS operations within the NAS, risk management and 

assessment, mining, disaster and catastrophe events.

Conventional operations, using jet or piston powered aircraft, ladders or placing 

people on roofs or tall, hazardous or weakened structures, exposes them to higher risks 

than those created by use of a sUAVs. Conventional aircraft that operate at extremely low 

altitudes just feet from the subject being inspected and in extreme proximity to people and 

structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., 

carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft 

must fly to and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. 

and powered by batteries eliminates virtually all of that risk given the reduced mass and 

lack of combustible fuel carried on board. The sUAV is carried to the target area and not 

flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of 

the exemptions requested herein. These lightweight aircraft operate at slow speeds, close 

to the ground, and in areas that are under the control of the customer for the operations 

and, as a result, are far safer than conventional operations conducted with helicopters 

operating in close proximity to the ground and people or the use of individuals to climb the 

structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

Tri-State Aerial Solution’s UAS for the purposes outlined herein and are consistent with 

exemptions already granted, including Exemptions number 11171 through 11174, 11176, 

11177, 11062, 11109, 11112, and 11213 and as recent as 15151.

Sincerely,

Jason T. Snyder (Private Pilot Certificate #2742561 issued 27DEC2002)

Tri-State Aerial Solutions

1236 12th Street

Nitro, WV 25143