March 2, 2015

U.S. Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
Washington, DC 20590

Dear Sir or Madam

Attached please find Bartram Trail Surveying, Inc.’s (BTS) request for an exemption

from the listed Federal Aviation Regulations to allow commercial operation of its Small
Unmanned Aircraft Systems (“sUASs”) for aerial imaging

, for safe and efficient surveying

, and
mapping of secured and controlled vacant and under

- development sites. The exemption request
is exclusively fo r the use of the sUASs and technology manufactured by DJI, an international
manufacturer of sUASs headquartered in Shenzhen, China.

Also attached to this letter is the DJI Phantom FC40 Flight Manual (“Manual”), which
outlines the operating requirements, l imitations, and technical specifications for the DJI system

as well as its accessories. BTS has reviewed the DJI Manual and its online resources and has
found it to be acceptable for sUAS operations on secure project sites. Applicant submits this

Manual as proprietary information pursuant to 14 CFR 11.35(b).

Thank you for your time and consideration, and please let me know if you have any questions.

Sincerely,



## Adam Desguin

Chief Operations Officer Bartram Trail Surveying, Inc.

1501 CR 315 Suite #106 Green Cove Springs , FL 32043 (904)284

- 2224 ext. 142 Adesguin@bartramtrail.netMa rch 2, 2015

U.S. Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the F AA R eform A ct and Part 11 of the Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R . §§ 61.113(a) and (b); 14 C.F.R. §§ 91.7(a); 14 C.F.R. §§ 91.9(b)(2); 14 C.F.R. §§ 91.103; 14 C.F.R. §§ 91.109; 14 C.F.R.§ 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a)(b); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the Reform Act) and 14 C.F .R. Part 11, Bartram Trail Surveying

, Inc

. ( “ BTS ” ), a land surveying, planning and consulting firm, hereby applies for an exemption from the listed F ederal Aviation Regulations ("F ARs") to allow commercial operation for its Small Unmanned Aircraft Systems (“sUASs”) for safe, efficient and up

- to

- date aerial imaging of secured and controlled vacant and under

development sites

, so 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.

As detailed in this document and the attached Flight Manual, the requested exemption
would permit the operation of sUAS under acceptable conditions in airspace that is: limited,
predetermined, controlled as to access, and would provide an increased level of safety to the best
practice s already demonstrated by BTS at each of its sites. 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 su ch aircraft systems in the
national airspace system."

The Name and Address of the applicant is:

Bartram Trail Surveying

, Inc

. Attn: Alexander Traversa Ph: (904)284

- 2224

Email: zantraversa@bartramtrail. net
Address: 1501 County Road 315, Suite 106 Green Cove Springs, FL 32043Regulations from which the exemption is requested:

14 CFR Part 21
14 C.P.R. 45.23(b)
14 CFR 61.113 (a) & (b)
14 C.P.R. 91.7 (a)
14 CFR 91.9 (b)(2)

14 C.P.R. 91.103

14 C.P.R. 91.109

14 C.P.R. 91.119

14 C.P.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)

1. Statutory Authority for Exemptions
The Federal Aviation Act expressively gr ants the FAA the authority to issue exemptions.
This statutory authority by its terms includes exempting civil aircraft, as the term is defined
under section §40101 of the Act that includes sUASs, from the requirement that civil aircraft

must have a curren t airworthiness certificate.

This exemption application is expressly submitted to fulfill Congress' goal in passing Section
333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the national airspace
system (NAS) before completion of the rulemaking required under Section 332 of the Reform
Act. In making this determination, the Secretary is required to determine which types of s UAS s

do not cre ate a hazard to users of the NAS or the public or pose a threat to national security in
light of the following:

 The sUAS’s size, weight, speed, and operational capability

 Operation of the sUAS in close proximity to airports and populated areas; and

 Opera tion of the sUAS within visual line of sight of the operator.

Reform Act Section 333 (a). Lastly, if the Secretary determines that such operations "may
operate safely in the national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft in the national airspace system." Id

. § 333( c)

.BTS’s sUASs are electricity powered, multirotor vehicles, weighing fewer than 10lbs.

including payload. They operate under normal conditions at speeds of no more than 25 knots and
have the capability to hover, and move in the vertical and horizontal plane simultaneously. The
sUAS will operate only in t he line of sight at all times and will operate only within the sterile
area described and pre

- established before all flights as outlined in the attached DJI Manual. Such operations will insure that the sUAS will “not create a hazard to users of the nationa l airspace system or the public.” Reform Act Section 333 (b).

Given the small size of the sUASs involved and the restricted environment within which
they will operate, the applicant falls squarely within that zone of safety (an equivalent level of

safet y) in which Congress envisioned that the FAA must, by exemption, allow commercial
operations of sUAS to commence immediately. Also due to the size of the sUAS and the
restricted areas in which the relevant sUAS will operate, approval of the application pre sents no national security issue. 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 safety
surrounding the proposed operations, and the significant pu blic benefit, including reliable and

up

- to

- date aerial imagery, enhanced safety for surveyors and associated contractors

, and
reduction in environmental impac ts, including reduced emissions. E xemptions associated with
allowing the commercial use of sUAS in the public interest. Accordingly, the applicant
respectfully requests that the FAA grant the re quested exemption without delay.

2. Public Interest

This exemption application is expressly submitted to fulfill Congress' goal in passing
Section 333(a) th rough (c) of the Reform Act. This law directs the Secretary of Transportation to
consider whether certain unmanned aircraft systems may operate safely in the national airspace
system (NAS) before completion of the rulemaking required under Section 332 of t he Reform

Act. By granting an exemption the FAA will fulfill Congress’ intent of allowing sUAS to operate
with significant safety precautions in low risk environments.

The use of sUASs in surveying, aerial imaging and mapping can significantly increase

t he quality and accuracy of site surveys and would reduce the cost compared to conventional
methods of aerial imaging. Larger more conventional aircraft are potentially hazardous due to

their size, combustible fuel , and emission of hazardous pollutants . Swi tching to the use of sUASs
would increase the safety of workers and the public.

Additionally use of sUASs would also allow greater access to densely vegetated or
impassable areas. Conventional imaging is limited due to the size of the vehicles used and th e height of surrounding vegetation. UASs would allow for greater precision in imagery that would
require an AGL too low for conventional aircrafts.Lastly use of sUASs at vacant sites and under

- development sites can reduce the risk of

injury by eliminating the need for a large number of workers in a pote ntially hazardous
environment. There are innumerable risks in almost every work place, and especially in the
surveying and construction fields. The implementation of sUASs can reduce the number of
injuries and fatalities on these hazardous sites.

3. Equivalent Level of Safety

BTS 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 un der the current regulatory
structure because the pr oposed operations represent a safety enhancement to the already safe
protocols followed on construction sites and imaging and surveying operations conducted with
helicopters and other conventional aircraft

.

BTS will be bound by the following limitations when conducting its sUAS operation
under an FAA issued exemption:

1. The s UAS will weigh less than 10 lbs.

2. Flights will be operated within line of sight of the Pilot.

3. Maximum total flight time fo r each operational flight will be 10 minutes for multirotor. Flights will be terminated at 25% battery power reserve should that occur prior to the 10

minute limit.

4. Flights will be operat ed at an altitude of 200ft and no more than 400 feet AGL.

5. Mi nimum crew for each operation will consist of the s UAS Operator who will

maintain VLOS with the sUAS at all times.

6. s UAS operators will be trained in flight, operations, and safety procedures as detailed in the Flight Manual

7 . The SUAS will only opera te within a confined "sterile area" as defined in the manual. It requires the establishment of a "Security Perimeter" for the flight operations area.

8 . A brief in g will be cond ucted in regard to the planned s UAS operations prior to each day's production activities. It will be mandatory that all person ne l that will be performing

duties within boundaries of the safety perimeter be present for this briefing.

9. All onsite personnel will consent to the sUAS flyover on site by waiver, and the operator will obtain additional verbal or written consent of all persons who will be allowed within 100ft of the flight operation.10 . The operator will submit a written Plan of Activities for each site.

11

. The o perator will have been trained in the operation of s UAS generally and received

up

- to

- date information on the particular UAS to be operated.

12 . Written and/or oral permission from the relevant property holders will be obtained.

13 . All required permissi ons and permits will be obtained from territorial, state, county, or city jurisdictions, including local law enforcement, fire, or other appropriate government agencies.

14. If the s UAS loses communications or it loses its GPS signal, the s UAS will have capability to return to a pre

- determined location within the Security Perimeter and land.

15 . Th e SUAS will have capability to abort flight in case of unpredictable obstacles or emergencies.

4. Description of Specific Regulations

14 C.F.R. Part 21, Su bpart H: Air worthiness certificates 14 C.F.R. Section 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR Section 91.203 (a) (1). Given the size and limited operating area associated with aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under

Part 11 and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in a restricted environment and under the conditions proposed will be at least as safe, or safer, than conventional aircraft (fixed wing or rotorcraft) operating with an airworthines s certificate without the retractions and conditions proposed.

The sUAS to be ope rated here under is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable materials liquid fuels, and

operates e xclusively withi n a secured area as set out in M anual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide secur ity for the area of operation as is currently done on

active construction sites. The FAA will have advance notice of all operations.

These safety enhancements, which already apply to civil aircraft operated in connection to motion picture and television production, provide a greater degree of safety to public and property owners than conventional operations conducted with airworthiness certificates issuedunder 14 C.P.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that

ther e is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F .R. Sec tion 45.23 (b). Marking of the A ircraft

The regulation requires: When marks include only the Roman capital letter ''N" and the registration of the number is displayed on limited, restricted or in a light

- sport category aircraft or experimental or provisional ly certified aircraft, the operator must also display on the aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light spot," "experimental, " or "provisional," as applicable.

Even though the sUAS will have no airworthiness certificate, and exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "experimental" can be placed. Given the size of the sUAS, the two inch lettering will be impossible. The word "experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on it fuselage as required by §4 5.29 (f) where the operator, observer and others working with the sUAS will see the identification of the sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to exemptions to this regulation to Exemptions Nos. 10700, 8738

, 10167A.

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

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed opera tions can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have logged 50 hours of flight experience along with 200 take

- offs and 200 landings with a DJI sUAS before flying at a site , rather than h ave a commercial pilot’s license to operate this small s UAS. Unlike a conventional aircraft that carries a pilot and passengers, the sUAS is remotely controlled with no living thing onboard. The area of operation is controlled and restricted, and all fligh ts are planned and coordinated in advance. The level of safety provided by the requirements included in the manual exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with the operation of a commercial operations contemplated with Part 61 when drafted, t hat allowing operations of the sUAS as requested with a pilot who has met the minimum requirements outlined in the Manual and has logged a sufficient number of flights exceeds the present level of safety achieved by 14 C.P.R. §61,113 (a) & (b).14 C.P.R. §91.7 (a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworth y condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the manual for maintenance and use of safety check lists prior to each flight, as set forth in the manual and equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual , marking and placard in the Aircraft

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot onboard, but because there is no room or capacity to carry su ch an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the operator flying the sUAS will have access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilo t in command to take certain actions before flight to insure the safety of the fl ight. An exemption is needed from this requirement as the pilot will take all actions including reviewing weather, flight battery requirements, landing and takeoff

distances a nd aircraft performance data and all other actions outlined in the Flight Manual, before initiation of flight. These actions will provide an equivalent level of safety.

14 C.F.R. §91.109: Flight instruction

Section 91.103 provides that no person may op erate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

sUASs and remotely controlled aircraft, by their design do not have fully functioning

dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functioning dual controls for a number of aircraft and for flig ht instruction in experimental aircraft. See exemption Nos.5778K & 9862A. The equivalent level of safetyprovided by that neither a pilot nor passengers will be carried in the aircraft and by the size and

speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operations of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed provided the person operating the helicopter c omplies with any route or altitudes prescribed for helicopters by the

FAA. This exemption is for the sUAS that fl i e s similarly to a helicopter and the exemption requests authority to operate at altitudes of up to 400 AGL, or not more than 200 above an

elev ated platform from which filming is planned, an exemption is may be needed to allow such operations. As set forth by herein, except for the limited conditions stated in the Manual, the sUAS will never operate higher than 400 AGL. It will however be operate d in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS

as well as the lo cation where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of th e planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk of associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the surveying and mapping industry. In addition, the low

- altitude operations of the sUAS will ensure separation between these small SUAS operations and the oper ations of conventional aircraft that must comply with Section

91.119.

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 ele vation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety

will be achieve d by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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

Section 91.151 (a) prohibits and individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) ther e is enough fuel to fly to the first point of intended landing, and assuming normal cruising speed

- (1) Duri ng theday, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes."

The battery powering the sUAS provides approximately 15 minutes of powered flight. To compensate the 30 minute reserve requirement in 14 C FR §91.151, sUAS flights would be limited to approximately 10 minutes in length or 25% battery, whichever comes first , which would allow for a third of its battery power for emergency use. Given the limitations on the SUAS's proposed flight area and the lo cation of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

BTS believes that an exemption from 14 CFR (a) falls within the scope of prior exemptions. See Exemption 1067 3 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the small sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers wi ll be allowed, wit h less than 3 0 minutes of reserve fuel, does not engender the type of risk that Section 91.151 (a) was intended to alleviate given the size speed of the small sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for whic h the exemption will be granted.

BTS believes that an equivalent level of safety can be achieved by limiting flights to 10

minutes or 25 % of battery power

, whichever happens first. This restriction would be more than adequate to return the sUAS to its la nding zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cockpit entrance so that it is legible to passengers or cre w.

The sUAS fully loaded weighs no more than 10 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or display them on the sUAS.

An equivalent level of safety will be achi eved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them; to the extentthey are applicable to the sUAS . The FAA has issued numerous exemptions to this regulation. A

representative sample of other exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9816A, 10700.

14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (b)

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 4 3 of this chapter. .. ," and others shall inspect or maintain the aircraft in compliance with part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to BTS . Maintenance will b e accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual. An equivalent level of safety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate onl y in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance preformed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivale nt level of safety.

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:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, s ubpart H; 14 C.F.R45.23 (b); 14 C.F.R. §§ 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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercia lly a small unmanned vehicle (10 lbs or less) in the Surveying and 3d Mapping Service Operations.

Approval of exemptions allowing commercial operations of sUASs in the surveying and 3d mapping/scanning industry will enhance safety by reducing risk. Conve ntional operations using jet or piston aircraft operate at extremely low altitudes just feet from the equipment and structures; and present the risks associated with vehicles that weigh in the neighborhood of 3,000

- 5,000 lbs., carrying large amounts of jet A or other fuel in most cases helicopters operating with 140 gallon fuel tanks. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.The operations of small sUASs, weighing less than 55 lbs., conducted in the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant of the Part 21 and allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground and in a restricted environment, as a result, are far safer than conventional operations conducted with a piston and or turbine aircraft operating close to the ground.

Public Acknowledgement/Privacy

All Flights will occur only once the property owner has authorized operations to be

conducted. Images t aken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to populated areas and or close proximity to airports and operations within visual line of sight provides more than ad equate justification for the grant of the requested exemptions allowing commercial operation of applicant's sUAS in the

S urveying and 3D m ap p ing service operations.

Sincerely,



### Bartram Trail Surveying, Inc.

Attn: Alexander Traversa Ph: (904)284

- 2224

Email: zantraversa@bartramtrail. net
Address: 1 501 County Road 315, Suite 106 Green Cove Springs, FL 32043