ROWE

1 Juniper Unmanned	Inc. December 11th, 2015

United States Department of Transportation

Federal Aviation Administration

Docket Management System

1200 New Jersey Avenue, NE Washington, DC 20590

Name of Applicant : Rowe Professional Services Company, ROWE Professional Services

Company dba Air Land Surveys and The Rowe Group, P.C.

Attn: Greg Lemke

Phone: 810

- 762

- 6800

Email: glemke@rowepsc.com

540 S. Saginaw St., Suite 200

Flint, MI 48502

Submitted by:

Juniper Unmanned

Attn: Darren Robey, Matt Tompkins

Phone: 303

- 406

- 3312 , 303

- 929

- 3726

3490 Parfet St.

Wheat Ridge, CO 80033

matt.tompkins@juniperunmanned.com

, darren.robey@juniperunmanned.comROWE

2 Juniper Unmanned	Inc. Re: Petition for Exemption of Rowe Professional Services Company, ROWE Professional Services Company dba Air Land Surveys and The Rowe Group, P.C. under Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 44701 (±), and 14 Part 11

Table of Contents

Request

................................ ................................ ................................ ................................ ....................... 3

Background	Information	on	the	Petitioner

................................ ................................ ............................. 3

Conditions	and	Limitations

................................ ................................ ................................ ....................... 3

Proposed	Unmanned	Aerial	Vehicles

................................ ................................ ................................ ....... 4

Proposed	Operations

................................ ................................ ................................ ................................ . 4

Exemptions	Requested

................................ ................................ ................................ .............................. 5

14	C.F.R.	Part	21	Part	H	and	91.7(a)

................................ ................................ ................................ ......... 6

91.405(a),	91.407(a)(1),	91.409(a)(1)(2),91.417(a)(b)

................................ ................................ ............ 6

14	C.F.R.	45.23	(b)

................................ ................................ ................................ ................................ ...... 7

14	C.F.R.	91.9	(b)	(2)

................................ ................................ ................................ ................................ ... 7

14	C.F.R.	91.121

................................ ................................ ................................ ................................ .......... 7

14	C.F.R.	91.151(a)	and	(b)

................................ ................................ ................................ ........................ 8

14 C.F.R.	61.113	(a)	and	(b)

................................ ................................ ................................ ....................... 8

14	C.F.R.	91.119

................................ ................................ ................................ ................................ .......... 8

Public	Interest

................................ ................................ ................................ ................................ ............. 9

Reasons	Why	Granting	the	Exemption	would	not	Adversely	Affect	Safety

................................ ...... 10

Summary	for	Federal	Register

................................ ................................ ................................ ................ 11ROWE

3 Juniper Unmanned	Inc. Request
On behalf of ROWE , we hereby seek an exemption from the Federal Aviation Regulations detailed below, as authorized by Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(±) of the Federal Aviation Act, and pursuant to the procedures
set forth in Part 11 of the Federal Aviation Regulations, to allow ROWE to operate the DJI Phantom 3, DJI Phantom 3 Professional, 3D
Robotics X8

- M, and Trimble ZX5

.

Background Information on the Petitioner
ROWE is a Flint, Michigan based leading professional services firm, driving infrastructure and development projects for public, private, governmental, tribal, and not

- for

- profit clients. ROWE provides civil engineering, surveying, aerial photography and mapping, landscape architecture, planning, and land development products. The addition of sUAS to this offering will greatly assist in reducing risk and greatly increase safety in ROWE ’s aerial operations.

Conditions and Limitations
The small s U AS operations proposed in this p etition will be subject to the following conditions and limitations. Each of these conditions and limitations is consistent with previously granted small s UAS Section 333 exemptions and FAA guidance. See, e.g., Exemption No. 11110 (Docket

FAA

- 2014

- 0367) (“ Trimble Exemption”); Exemption No. 11062 (Docket

FAA

- 2014

- 0352) (“Astraeus Exemption”); Exemption No. 11109 (Docket

FAA

- 2014

- 0507) (“Clayco Exemption”); Exemption No. 11136 (Docket

FAA

- 2014

- 0508) (“AAS Exemption”) ; Exemption No. 12645 (Docket FAA

2014

- 0804 ) (“Allied Drones”) . Collectively, these conditions and limitations ensure that the proposed small s UAS operations will not adversely affect safety and will provide at least an equivalent level of safety to the current
rules of large manned aircraft operat ions.ROWE

4 Juniper Unmanned	Inc. Proposed Unmanned Aerial Vehicles The proposed aircraft, DJI Phantom 3 and Phantom 3 Professional, 3D
Robotics X8

- M and Trimble ZX5, all have safety features to assist in low risk operation. Each of these aircraft have been included in granted exempt ions.

Proposed Operations
ROWE will operate the proposed aircraft to collect aerial imagery and video, aerial inspection of infrastructure and collection of data for

survey purposes.

ROWE will operate its sUAS in full compliance with the a pplicable
manufa cturer manual. ROWE will operate its sUAS under 400 feet A GL
and within the visual line of sight of the pilot and visual observer

. The

PIC (Pilot in Command) will hold at least a Recreational Pilot
Certificate , hold a at least a class 3 medical and be familiarized with the sUAS in operation. The Visual Observer will also hold a 3 rd class
medical or state issued drivers license and be familiarized with the sUAS being used in the operation.

The Pilot in Command (PIC) wi ll make himself aware of meteorological conditions in the area of operation. F lights will be conducted with the
consent of property owner and/or developer.

Operations not within C lass

- G airspace or above 200ft AGL , will require written approval from the FA A in the form of a Certificate or

Waiver o f Authorization

. The aircraft included in this petition comply with FCC signal frequencies and will be limited to 2.4Ghz, 5.8Ghz and
900Mhz.

ROWE will conduct a briefing before each day's operations, which all participating personnel must attend. A risk assessment will be conducted, evaluating obstructions and other potential hazards

. ROWE will file a NOTAM prior to operations . All operations will be conducted during daytime in Visual Metrological Conditions (VM C).ROWE

5 Juniper Unmanned	Inc. In addition, ROWE will conduct a pre

- flight inspection of aircraft and ground equipment. These inspections will be conducted according to
manufacturer manuals.

Under the requested exemption, ROWE will operate its sUAS within
the United States.

Exemptions R equested

14 C.F.R. Part 21 (h) (airworthiness certification)

14 C.F.R. 45.23(b) (marking of the Aircraft)

14 C.F.R. 61.113(a) and (b) (private Pilot Privileges and Limitations)

14 C.F.R. 91.7(a) (b) ( civil aircraft airworthiness)

14 C.F.R. 91. 9(b) (2) (civil aircraft flight manual... requirements)

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes)

14 C.F.R. 91.121(a ltimeter settings)

14 C.F.R. 91.151 (a) and (b) (fuel requirements in VFR conditions)

14 C.F.R. 91.405 (a) and (b) (maintenance required )

14 C.F.R. 91.407(a)( 1 ) ( operation after maintenance )

14 C.F.R. 91.409(a) ( inspections )

14 C.F.R. 91.417(a) and (b) (maintenance records)ROWE

6 Juniper Unmanned	Inc. 14 C.F.R. Part 2 1 Part H and 91.7(a) Given its small size, operational capabilities, and restricted area in
which the s UAS will operate, an exemption from Part 21, Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as

ROWE ’s s UAS satisfy the equivalent level of safety as compared with
manned aircraft and meets the criteria in section 333.

Each sUAS (including payload) is less than 55 pounds, carry no explosive materials or flammable liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. As the FAA has found in granting an exem ption to Clayco, Exemption No. 11109, page 10.

The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event
of an i ncident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a sUAS for aerial operations.

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b) In support of ROWE ’s request for an exemption from 14 C.F.R. 91.405(a), 91.407(a)( 1 ), 91.409(a)( 1 ) and (2), and 91.417(a) and (b),
ROWE will adhere to the following inspection and maintenance

program:

ROWE must carry out its maintenance, inspections, and record keeping requirements in accordance with the aircraft manufacturer manuals. Maintenance, inspection, and alterations must be note d in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized sUAS maintenance personnel returning the sUAS to service.

ROWE will follow the manufacturer's s UAS requirements relating to

compo nents, maintenance, overhaul, replacement, inspection and life
limits.ROWE

7 Juniper Unmanned	Inc. 14 C.F.R. 45.23 (b) Section 45.23(b) requires that certain experimental, provisionally certified aircraft or light

- sport category aircraft to be marked with
letters between 2 and 6 inc hes high as “Limited”, “Restricted”, “Light

Sport”, “Experimental”, or “Provisional” near each entrance to the cabin, cockpit or pilot station. The sUAS included in this exemption will
have no airworthiness certificate

, should this 333 exemption be

approve d, is not of a size on which 2 inch lettering is possible and does not have a cabin or pilot station on which the word “Experimental” can be placed. For these reasons, ROWE respectfully requests an exemption from this regulation.

14 C.F.R. 91.9 (b) (2)
Se ction 91.9 (b) (2) requires that, n o person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight

Manual is not required by §21.5 of this chapter, unless there is
available in the aircraft a current approved A irpla ne or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The s UAS, given its size and configuration
h as no ability or place to carry a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 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 pilot flying the s UAS will have immediate

access to it. For these reasons, ROWE respectfully requests an exemption from this regulation.

14 C.F.R. 91.121
ROWE ’s sUAS are equipped with a GPS altimeter

. Information such as,

real

- time telemetry data

, altitude, speed, and s UAS attitude are displayed to operators

. Moreover, the sUAS will be operated within the visual line of sight of the pilot in command and visual observer and below 400 feet AGL. Because the proposed aircraft are not equipped with a barometricROWE

8 Juniper Unmanned	Inc. altimeter, and instead use a GPS altitude, the ability to maintain required altimeter settings outlined in 14 C.F.R. 91.121 is not feasible. Therefore, relief from 14 C.F.R. 91.121 is requested.

14 C.F.R. 91.151(a) and (b) In support of ROWE ’s request for an exemption from 14 C.F. R. 91.151(a) and (b), the proposed sUAS are battery

- powered and are operated for a maximum 25 minutes, this makes the fuel requirements of 14 C.F.R. 91.151(a) and (b) impossible to meet. All operations will be conducted according to manufacturer recommende d battery flight

times.

14 C.F.R. 61.113 (a) and (b) ROWE requests an exemption from 14 C.F.R. 61. 113 (a ) and (b) to the extent necessary to permit ROWE to conduct commercial sUAS operations using PICs who hold, at least, an FAA recreational pilot certificate. ROWE requests that the FAA exempt ROWE and its PICs from this requirement since the use of a recreational pilot as the PIC for the sUAS operations under this exemption will b e as safe or safer than the use of a commercial pilot for manned aircraft operations. Unlike conventional aircraft, the sUAS proposed in this exemption are remotely controlled, operated in Visual Metrological Conditions, with no crew or passengers, below 4 00ft AGL, are low weight, and battery

powered. The fulfillment of the additional requirements for a recreational pilot to become qualified as a commercial pilot would not lead to any additional safety benefits when sUAS operations are
involved.

14 C.F.R. 9 1.119
ROWE seeks an exemption from the requirement in 14 C.F.R. 91.119, subsection (b), that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or structure in an area other than populated or congested, and not closer than 500 feet to any person, vehicle, or structure. ROWE requests anROWE

9 Juniper Unmanned	Inc. exemption from this regulation to the extent necessary to permit
ROWE to conduct its sUAS operations at altitudes lower than those permitted by 14 C.F.R. 91.119, since such altitudes are one of the key benefits of using s UAS for these flights. Even at these low altitudes,
ROWE ’s sUAS operations will be conducted at a level of safety at least equal to that which would be achieved by larger manned aircraft.

ROWE will make every reasonable effort to ensure that no unauthorized person s will be within the area of operation during flight

,
a nd will provide notice to adjacent buildings and furnish proctors as may be necessary to ensure that unauthorized persons do not come within the parameters in which the sUAS will be operated. Combined with the technological capabilities of the sUAS and tha t the sUAS will be operated within the visual line of sight of the pilot and observer,
ROWE submits that its operational limitations provide an equivalent level of safety to that provided in 14 C.F.R. 91.119.

Public I nterest
ROWE ’s sUAS operations will substantially benefit public and private organizations which have an interest in gathering critical data and information to support their operations. Depending on the use

- case, these scenarios may include:

T he collection of survey data to assist in the construction of critical infrastructure such as, roads, bridges , utilities, schools, environmental
remediation

, construction monitoring
, progress tracking, surveying, inspection, and infrastructure improvement . In these services ROWE serves both private and public entities.

The use of sUAS by ROWE would greatly decrease risk compared to large manned aircraft operations.ROWE

10 Juniper Unmanned	Inc. Reasons Why G ranting the Exemption would not Adversely
Affect S afety

Throughout this Petition, ROWE has explained many reasons why granting an exemption from each section of the FAR from which relief is sought would result in sUAS operations that provide a level of safety at least equal to, or greater than, that provided by the rule from which exemption is sought.

Mo reover, the many conditions and limitations proposed in this Petition also ensure at least an equivalent level of safety, as the FAA concluded in the Trimble Exemption and the Astraeus Exemption.

In general, the risks of any proposed s UAS operation interf ering with a manned aircraft is minimized by the low altitude at which the sUAS will operate; the locations at which the sUAS will operate (e.g., Class G airspace, private or controlled access property, away from airports); the small size/low weight and re latively slow speed of the sUAS; the restriction of sUAS operations to VMC and daytime conditions; the requirement for the PIC to maintain VLOS of the sUA S at all times; and the condition to obtain a NOTAM before each sUAS flight ; t he
considerations for no n

- participating persons or structures; the prohibition on flights over conges ted or densely populated areas, among other conditions and limitations

. These parameters, conditions, and limitations proposed in the Petition provide substantial protection against interference with manned aircraft operations or with the safety of persons or property on the ground. In addition, under the proposed
conditions a nd limitations stated above, ROWE will coordinate

, as warranted, with the FAA, with local airports, and with property owners to ensure that all sUAS operations under the exemption are at least as safe as manned aircraft operations used for similar purposes

.ROWE

11 Juniper Unmanned	Inc. Summary for Federal Register Should the FAA determine that publication of a summary is required,

ROWE submits the following summary to be included in the Federal Register:

Rowe Professional Services Company, ROWE Professional Services Company dba Air L and Surveys and The Rowe Group, P.C. seek an exemption to operate the DJI Phantom 3 and Phantom 3 Professional,
3DR X8

- M, and Trimble ZX5 unmanned aircraft systems to perform aerial data collection for inspection, survey, photographic and video

services.

Sincerely,

Rowe Professional Services Company, ROWE Professional Services

Company dba Air Land Surveys and The Rowe Group, P.C.

Greg Lemke

540 S. Saginaw St., Suite 200

Flint, MI 48502