Eric J. Sander

1119 Delaware Ave.

Mendota Heights, MN 55118

phone: 612-900-4967

email: sanderej@gmail.com

October 1, 2015

Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 

CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 

(a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b)

The extent of relief you seek and the reason you seek the relief;

Use of a UAS for commercial purposes is currently not permitted. I am simply petitioning for an 

exemption to provide a commercial service to private land owners and companies who wish to obtain 

and capture Aerial photos and videos of said property for purposes including real estate listings, 

insurance property claims, and general aerial data collection. I would like to be able to accept payment 

for these services therefore making this a commercial use of a UAS. 

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small business owners, real 

estate agents, and others who wish to document their land or property to take advantage of the 

technology that now exists in the form of a UAS and allow them to do so without requiring them to 

procure the required equipment and knowledge to do so themselves. 

Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule;

Being an FAA licensed Private Pilot, I have an understanding of the different uses and safety concerns 

associated with FAA regulated airspace, my exemption granted under Sec 333 would not add undue risk 

to the National Air Space. The specific UAS (Walkera Scout X4) for which I am seeking exemption with is 

one with many safety features, including SAFE technology, GPS waypoint navigation, one key return 

home operation, failsafe return home with loss of signal, and advanced intelligent orientation control to 

prevent loss of orientation problems. When flying this UAS for commercial purpose I would be flying at a 

maximum altitude of 150 feet and flying either vertically for the purposes of taking photos or using a 

pre-planned GPS waypoint route. All operations will involve safety reviews, review of NOTAMS, 

prevailing and forecasted weather -- significant mission planning will be conducted to ensure neither 

people on the ground nor the NAS are in any way compromised. 

In addition my operation will also follow these general guidelines:

I will operate the Scout X4 by Walkera. 

The specifications for the Scout are as follows: 

Remote control: Transmitter 2.4Ghz and Video at 5.8Ghz

Support both Apple IOS and Android based devices
Waypoint mission planning / Designated flight Hybrid, can be changed from 4 for to 8 motors 

2.4G bluetooth datalink ground station (BT-2401A/B FCC / BT-2402A/B CE) 

Flight time: Up to 25 minutes

Flight range: up to 1500 meter Receiver: DEVO-RX707(CE) / RX709(FCC) 

Real time flight data (telemetry) monitoring 

Auto return to home (RTH) Motors: Brushless WK-WS-34-002 ESC: WST-16AH(R/G)

Battery: 6cell 22.2V 5400mAh Li-Po Size: 335x335x275 mm. 

Rotor Blades Length: 233mm Weight with battery: 1770g Flying Weight

The Scout X4 has multiple safety features programmed in to its APM flight control system. These 

features serve to minimize any risk posed by loss of control, loss of transmission signal or loss of 

orientation. These features include, but are not limited to: 

• GPS controlled positioning allows the UAS to "know" it's location, attitude and altitude. 

• RTH (return to home) when triggered, will bring the Scout back and land it autonomously in the event 

the PIC is unable to do so. 

• FAILSAFE will return the UAS and land it autonomously should the control transmission get cut off for 

any reason. 

• GEOFENCE allows the PIC to set a virtual "fence", or boundaries that the Scout cannot cross. By 

default, it is 300 meters lineal and 125 meters vertical. Crossing this boundary will automatically trigger 

the RTH feature.

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system in the 

world and to minimize the risk to the NAS or to persons and property on the ground, MHAP agrees to be 

bound by the following limitations and conditions when conducting commercial operations under a FAA 

issued exemption:

A. For the purposes of ensuring UASs will be operated within the standards that the FAA has allowed in 

the AMA National Model Aircraft Safety Code:

1. UASs will not be flown:

a. In a careless or reckless manner. 

b. At a location where UAS activities are prohibited. 

2. UAS pilots will:

a. Yield the right of way to all human-carrying aircraft. 

b. See and avoid all aircraft and a spotter must be used when appropriate

c. Not fly higher than 400 feet above ground level or within three (3) miles of an airport without 

notifying the airport operator. 

d. Not interfere with operations and traffic patterns at any airport, heliport or seaplane base 

except where there is a mixed use agreement. 

e. Not exceed a takeoff weight of 55 pounds (including payload). 

f. Ensure the aircraft is identified by affixing the owner’s contact information to the outside of 

the UAS. 
g. Not operate UASs while under the influence of alcohol or while using any drug that could 

adversely affect the PIC’s ability to safely control the model. 

h. Not operate UASs carrying pyrotechnic devices that explode or burn, or any device which 

propels a projectile or drops any object that creates a hazard to persons or property. 

3. UASs will not be flown unless: 

a. The aircraft, control system and pilot skills have successfully demonstrated all maneuvers 

intended or anticipated prior to the specific event. 

b. An inexperienced pilot is assisted by an experienced pilot. 

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall 

avoid endangerment of life and property of others.

5. A successful radio equipment ground-range check in accordance with manufacturer’s 

recommendations will be completed before the first flight of a new or repaired model aircraft. 

6. UASs must use the radio-control frequencies currently allowed by the Federal Communications 

Commission (FCC). 

7. UASs will not knowingly operate within three (3) miles of any pre-existing flying site without a 

frequency-management agreement. 

8. Excluding takeoff and landing, no UASs may be flown outdoors closer than 25 feet to any individual, 

except for the PIC and the PIC's helper(s) located at the takeoff site.

9. Under no circumstances may a pilot or other person touch a UAS in flight while it is still under power, 

except to divert it from striking an individual. 

10. The PIC of the UAS shall: 

a. Maintain control during the entire flight, maintaining visual contact without enhancement 

other than by corrective lenses prescribed for the pilot. 

b. Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the 

procedures outlined in AMA Document #550. 

c. Fly using the assistance of autopilot or stabilization system only in accordance with the 

procedures outlined in AMA Document #560. 

11. The flying area must be clear of all utility wires or poles and an SUAV will not be flown closer than 50 

feet to any above-ground electric utility lines. 

12. The flying area must be clear before the engine is started, except for PIC and the spotter.

In addition to the above rules outlined by the AMA National Model Aircraft Safety Code and in an effort 

to enhance the safety offered by the already safe operations mentioned above, I also agree to be bound 

by the following limitations and conditions: 

1. Flights will be operated within VLOS of the PIC. 

2. Maximum total flight time for each operational flight will be 18 minutes. Flights will be terminated at 

25% battery power reserve should that occur prior to the 18 minute limit. 

3. The UAS will only operate in tightly controlled and limited airspace. 

4. A briefing will be conducted in regard to the planned UAS operations prior to each flight. It will be 

mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing. 

5. The PIC and the PIC’s helper(s) will have been trained in operation of UAS and received up-to-date 

information on the particular UAS to be operated. 
6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice.

7. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the security perimeter and safely land. 

8. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

9. All flights will be conducted on private property and with the written and/or oral permission of the 

property owner(s). 

10. Flights will always be conducted in areas that are clear of all people, except for the PIC and the PIC's 

helper(s). 

11. All flights will be conducted outdoors in visual meteorological conditions (VMC) and never during 

severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from operating within visual line-ofsight (VLOS) at all times or in weather conditions that dramatically affect the UAS’s flight (e.g. high 

winds). 

13. If an operation occurs in an area where people could inadvertently enter the area, an operational 

border will be established with traffic cones. If it’s not feasible to use traffic cones due to interference 

with the photography/videography, the PIC's helper(s) will be responsible for keeping a safe perimeter 

around the operation.The operation will cease immediately and be rescheduled if it’s impossible to 

establish a safe perimeter around the operation. 

14. The PIC will be responsible for logging all flights to ensure the comprehensive preventative 

maintenance plan can be followed, as described in the “Preventative Maintenance” section below. 

15. The UAS will not be routinely operated in the proximity of any airports. In any cases where the UAS 

must be operated within three (3) miles of an airport, the airport operator will be notified before the 

operation commences. The operation of UASs, weighing less than 6 lbs., conducted in the strict 

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

exemptions requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, 

and in a tightly controlled environment. As a result, they offer a much safer way to capture aerial 

photography and videography. Furthermore, the proposed operations represent a safety enhancement 

to the already safe operations that have been granted by the FAA for the establishment of the AMA 

National Model Aircraft Safety Code.

I appreciate the FAA’s consideration of this petition for exemption.

Summary for the Federal Register

I, Eric J. Sander, am seeking an exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 

61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 

(a)(1); 14 CFR 91.409 (a)(1); 14 CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) for the purpose of 

conducting commercial operation of a UAS.

Any additional information, views, or arguments available to support your request

I am fully aware of the preflight safety checks and procedures required for the safe operation of the 

Walkera Scout X4 and all operations will be checklist driven to ensure consistent use and application of 
safety procedures. All flights will be operated in conditions allowing Visual Flight Rules and in winds less 

than 10 MPH.

Free flights will not be conducted during commercial operation. All said operations will be to a strict 

pre-programed flight plan and make use of all available fail safe options.

My FAA Issued Private Pilot License Certificate Number is 3707448 and was issued on 1 JUN 2013.

I completed my Basic Phase 3 of the Wings Pilot Proficiency program on 31 March 2015.

I understand and will comply with all the health and safety regulations for PIC’s and will be the only 

operator under this exemption. 

More information about the features of the Walkera SCOUT X4 QUAD can be found here:

http://www.supaquad.com/features---specs.html