# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com 

# JACK CARR MORGAN, PE/PS

August 25, 2015

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

RE: Jack Carr Morgan, PE/PS Petition for Section 333 Exemption

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act and 14 C.F.R. Part 11, Jack Carr Morgan, PE/PS (“Applicant”), Professional Engineer and La nd Surveyor and operator of small unmanned aircraft systems ("UAS") equipped to conduct profes sional aerial topographic land surveying and geospatial services, hereby applies for an exem ption from the listed Federal Aviation Regulations ("FAR") to allow commercial operation of UAS, so long as such operations are conducted within and under the conditions outlined herein.

The requested exemption would permit the operation of small, unmanned U AS to provide safety enhancements to the already safe operations in the mapping and surveying industry currently being conducted using manned aircraft.

Applicant has provided topographic surveys to the Flood Protection community for ove r 35 years. Failures of levees and drainage present serious threats to the publ ic safety. As part of agreements between states and federal governments, topographic surveys a re required every two years to insure integrity of the levees. Because of the extensive levee sys tem in south Louisiana, and the fact that many of the levees are remotely located, the surveys are dif ficult to conduct and expensive for the Levee Boards across the state that oversee the levees in t heir jurisdiction. The levees impact the health of wetlands and other plant and animal life. The use of U AS in commercial/residential areas and in remote rural areas will provide much clearer a nd current information for the Levee Boards than can be reasonably acquired using conventional on-the- ground surveying methods. The levees can also be accessed and surveyed more frequently than is currently fiscally possible using traditional manned aircraft methods.

Applicant uses UAS’s which are battery-powered rotorcraft, weig hing less than 55 lbs. including payload. They will operate only in line of sight of the Pilot i n Charge (PIC). Given the small size of the UAS and the lack of flammable fuel, the approval of the app lication presents no national security issue. Given the significant public benefit, includ ing enhanced safety, reduction in environmental impacts, including reduced emissions associated with a llowing UAS for surveying and mapping operations, the grant of the requested exemption is in the public inter est.

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com The limitations and conditions to which Applicant agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1) Operational Limitations

a) Unmanned aircraft must weigh less than 55 lbs. (25 kg).

b) Visual line-of-sight (VLOS) only; the unmanned aircraft must re main within VLOS of the operator or visual observer.

c) At all times the small unmanned aircraft must remain close enough to the ope rator for the operator to be capable of seeing the aircraft with vision unaided by any devi ce other than corrective lenses.

d) Small unmanned aircraft may not operate over any persons not directly involved i n the operation.

e) Daylight-only operations (official sunrise to official sunset, local time).

f) Must yield right-of-way to other aircraft, manned or unmanned.

g) May use visual observer (VO) but not required.

h) First-person view camera cannot satisfy “see-and-avoid” requirement but can be used as long as requirement is satisfied in other ways.

i) Maximum airspeed of 100 mph (87 knots).

j) Maximum altitude of 500 feet above ground level.

k) Minimum weather visibility of 3 miles from control station.

l) No operations are allowed in Class A (18,000 feet & above) airspace.

m) Operations in Class B, C, D and E airspace are allowed with the required ATC permission.

n) Operations in Class G airspace are allowed without ATC permission

o) No person may act as an operator or VO for more than one unmanned air craft operation at one time.

p) No careless or reckless operations.

q) Requires preflight inspection by the operator.

r) A person may not operate a small unmanned aircraft if he or she knows or has reas on to know of any physical or mental condition that would interfere with the safe oper ation of a small UAS.

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com s) Regarding the Unmanned Aircraft System

t) Applicant proposes that the proposed UAS operation will be safely conduc ted to minimize risk to the NAS or to persons and property on the ground. The design and ope rational characteristics for the types of UAS that Applicant intends to operate will be as described in this application.

2) Operator Certification and Responsibilities

a) Pilots in Charge (“PIC”) of small UAS are considered “operators”.

b) Operators are required to:

c) Pass an initial aeronautical knowledge test at an FAA-approved knowledge t esting center, when such test is available.

d) Be vetted by the Transportation Security Administration.

e) Obtain an unmanned aircraft operator certificate with a small UAS ra ting, when such certificate is available. In the meantime, operators will hold either a Commercial, Private, Recreational, or Sport Pilot’s license.

f) Pass a recurrent aeronautical knowledge test every 24 months, when test is available.

g) Be at least 17 years old.

h) Make available to the FAA, upon request, the small UAS for inspe ction or testing, and any associated documents/records required to be kept under the proposed rule.

i) Report an accident to the FAA within 10 days of any operation that results i n injury or property damage.

j) Conduct a preflight inspection, to include specific aircraft and control stat ion systems checks, to ensure the small UAS is safe for operation.

k) The Operator Certification and Responsibilities described in this Application are required of any PIC or other operator, including visual observers, who will be directly responsible for the operation of the UAS.

l) Operators will be required to provide a valid driver’s license or pass the physical requirements associated with the active pilot license the operator hol ds..

3) Aircraft Requirements

a) FAA airworthiness certification will not be provided; however, operator m ust maintain small UAS in condition for safe operation, and prior to flight must inspec t the UAS to ensure that it is in a condition for safe operation. Aircraft Registrati on is required (same requirements that apply to all other aircraft).

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com b) Aircraft markings are required. Because the aircraft is too smal l to display markings in standard size, the aircraft will display markings in the largest practicable manner.

c) The Applicant assures that the Radio Frequency (RF) spectrum used for control of the UAS and associated equipment that is part of the UAS will be in compli ance with Federal Communications Commission (FCC) or other appropriate government ov ersight agency requirements. Applicant will be able to provide the FCC approva l letter or show compliance with FCC requirements upon request.

d) FAA airworthiness certification will not be provided; however, operator m ust maintain small UAS in condition for safe operation and prior to flight must inspec t the UAS to ensure that it is in a condition for safe operation. Aircraft Registrati on is required.

4) Regarding the Operation of the Unmanned Aircraft

a) Applicant assures that the intended UAS operation will not adverse ly affect safety, and the following will describe how a level of safety will be pr ovided that is at least equivalent to that provided by the rule from which exemption is sought. Applicant descr ibes plans to implement clearly defined operational borders and procedures to ens ure public safety, which includes persons and property both in the air and on the gr ound. Applicant will address the proposed operation with respect to safety of flight, NAS safety considerations, and the safety of the non-participating persons and property during the operational period and within the operational area.

5) Regarding Safety of the Operation of the Unmanned Aircraft

a) Applicant assures the proposed maximum operating speed and altitude , and minimum flight visibility and distance from clouds for intended operation wi ll be as described in this application. Potential hazards will consist primarily of inter ference with existing trees, towers, and power lines. All towers and power lines above 100 fee t AGL will be mapped in advance of operation, and verified visually prior to ascent. O peration elevation will generally be above the trees. In some situations such as bridge s tructure assessment, very close proximity will be required to gather the level of detai l required. In those unusual situations, there will be an increased possibility of impact dama ge to the UAS itself because of proximity to the structure, but the light weight a nd fragility of the UAS and the requirement that no unassociated persons or property are below the aircraft, will reduce the potential damage to only the UAS itself. As with all operat ions, each situation will be assessed prior to ascent to determine the appropriate level of additional or special precaution that the specific operation warrants.

6) Regarding Air Space Restrictions

a) Applicant is requesting a general exemption to operate a UAS in Class G airspace without ATC permission, and in Class B, C, D, and E airspaces with the r equired ATC permission. No operation will be allowed in Class A airspace. Operations w ill generally be over restricted-access public property, including levees, flood wa lls, pump stations, treatment plants, wetlands, and open water. In all cases, no flights wi ll be over persons or properties not associated with the operation.

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com b) Applicant assures that before conducting operations which have exis ting requirements to notify Flight Standards District Offices (FSDOs) prior to operations, Applicant will notify affected FSDO in advance with detailed flight plan and descript ion of proposed operation.

c) Applicant will occasionally need to operate UAS within a five- mile radius of airports. When flown within 5 miles of an airport, the operator of the aircraf t will provide the airport operator and the airport air traffic control tower, if present , with prior notice of the operation.

7) Regarding Preflight Procedures

a) Applicant assures procedures described in this Application will be imple mented for conducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight and that the planned operation can be completed safe ly. Operators are required to conduct a preflight inspection, to include specific aircraft and control s tation systems checks, to ensure the small UAS is safe for operation.

8) Regarding Certificate of Waiver or Authorization

a) The Applicant understands that the FAA intends to provide “blanket” Certificate of Waiver or Authorization (COA) as part of the UAS Exemption process for c ertain generic conditions and air spaces. If the Applicant desires to work in air space not included in the “blanket” COA, Applicant will acquire the appropriate approval s from the FAA Air Traffic Organization prior to conducting operations in the NAS.

9) Regarding Exemptions from Specific Regulations

In seeking this authorization, Applicant will require exemptions f rom regulations with which he cannot fully comply. The table below provides specific informa tion regarding regulations from which Applicant requires exemption.

i) 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

(1) Subpart H, entitled Airworthiness Certificates, establishes t he procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203 (a) (1). Given the size and limited operating area associat ed with the aircraft to be utilized by the Applicant, an exemption from P art 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Secti on 333 of the Reform Act. Section 44701 (t) of the Act and Section 333 of the Re form Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate upon consideration of the size, weight , speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS's operated without an airworthiness certificate, in the restricted environment and under the conditions proposed herein will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certifica te without the restrictions and conditions proposed.

(2) The UAS's to be operated hereunder are less than 55 lbs. fully loa ded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Safety

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com Checklist. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the Applicant pursuant to the Sa fety Checklist's requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional aerial mapping and surveying. These safety enhancements, which already apply to civil aircraft operated in c onnection with mapping and surveying operations, provide a greater degree of safety to the public and property owners than conventional operations conducted with airwort hiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, applic ation of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of ope ration, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

ii) 14 C.F.R. § 45.23 (b). Marking of the Aircraft

(1) This regulation requires:

(a) "When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport categor y aircraft or experimental or provisionally certificated aircraft, the opera tor must also display on that aircraft near each entrance to the cabin, coc kpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the wor ds "limited," "restricted," "light-sport," "experimental," or " provisional," as applicable."

(2) Even though the UAS's will have no airworthiness certificate, a n exemption may be needed as the UAS's will have no entrance to the cabin, cockpit or pilot stati on on which the word "Experimental" can be placed. Given the size of the UAS's, two-inch lettering will be impossible. The FAA has issued the fo llowing exemptions to this regulation in Exemptions Nos. 10700, 8738, 10167 and 10167A.

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

(1) Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS' s will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operat ions by requiring the PIC's operating the UAS's to have a private pilot's license rather than a commercial pilot's license to operate this UAS's. Unlike a conventional aircraft t hat carries the pilot and passengers, the UAS's are remotely-controlled with no l iving thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the UAS's are so diminished from the level of risk associated with commer cial operations contemplated by Part 61 when drafted, that allowing operations of the UAS's as requested with a private pilot as the PIC exceeds the presen t level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

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

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com (1) The regulation requires that no person may operate a civil airc raft unless it is in airworthy condition. As there will be no airworthiness certif icate issued for the aircraft, should this exemption be granted, no FAA regulatory standar d will exist for determining airworthiness. Given the size of the aircraft a nd the requirements contained in the Safety Checklist for maintenance and use of t he Safety Checklist prior to each flight, an equivalent level of safety will be provided.

v) 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

(1) Section 91.9 (b) (2) provides:

(a) "No person may operate a U.S.-registered civil aircraft ...

(b) For which an Airplane or Rotorcraft Flight Manual is not requir ed by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, marki ngs, and placards, or any combination thereof."

(2) The UAS's, given their size and configuration have no ability or place to carry such 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 UAS's.

(3) The equivalent level of safety will be maintained by keeping the flight manual at the ground control point to which the UAS's pilots flying the UA S's will have immediate access. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

vi) VI. 14 C.F.R. § 91.103: Preflight action

(1) This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA-approved rotorcraft fli ght manuals will not be provided for the aircraft, an exemption will be needed. The PIC wil l take all actions including reviewing weather, flight battery requireme nts, landing and takeoff distances and aircraft performance data before initiation of flight.

vii) VI. 14 C.F.R. § 91.105 Flight crewmembers at stations

(1) This regulation requires each crew member to take certain act ions before flight to insure the safety of flight. As no crew members will be aboard the aircraft, the crew members do not require safety belts or harnesses.

viii) VII. 14 C.F.R. § 91.109: Flight instruction

(1) Section 91.109 provides that no person may operate a civil aircraf t (except a manned free balloon) that is being used for flight instruction unless t hat aircraft has fully functioning dual controls.

(2) UAS's and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a cont rol box that communicates with the aircraft via radio communications. The F AA has approved

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com exemptions for flight training without fully functional dual contro ls for a number of aircraft and for flight instruction in experimental aircraf t. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the f act that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

(1) Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters, powered parachutes and weight-shift-contro l aircraft to be operated at less than the minimums prescribed bec ause their low speed and responsive controls allow operations to be conducted, "wi thout hazard to persons or property on the surface ...".As UAS possess simila r flight and control characteristics, and as the exemption requests authority to opera te at altitudes up to 400 feet AGL, an exemption may be needed to allow such operations. As s et forth herein, except for the limited conditions stated in the Safety Che cklist, the UAS's will never operate at higher than 400 feet AGL.

(2) Compared to flight operations with aircraft or rotorcraft we ighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those present ly presented with conventional aircraft operating at or below 500 feet AGL in the mapping and surveying industry. In addition, the low-altitude operations of the U AS's will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

x) 14 C.F.R. § 91.121 Altimeter Settings

(1) This regulation requires each person operating an aircraft to mai ntain cruising altitude by reference to an altimeter that is set "... to the elevation of t he departure airport or an appropriate altimeter setting available befo re departure." As the UAS's 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 achieved by the operator confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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

(1) 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."

(2) The current battery technology powering UAS's is much more limited than th at of combustion powered flight. As such, the Applicant's UAS's cannot pres ently and likely may never will meet the reserve requirement in 14 CPR § 91.151. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame fo r flight in daylight

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com VFR conditions is reasonable. As no night flight will occur, t hat portion is inapplicable.

(3) Applicant believes that an exemption from 14 CPR § 91.151 (a) falls w ithin the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Marti n Corporation to operate without compliance with FAR 91.151 (a)). Operat ing the UAS's in a tightly controlled area where only people and prope rty 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, speed and limited oper ating area of the UAS's.

(4) Applicant believes that an equivalent level of safety can be ac hieved by limiting flights based on expected battery life, currently 20 minutes, or 20% of battery power when future technology expands the battery life. This restric tion would be more than adequate to return the UAS's to their planned landing zone from anywhere in its limited operating area.

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

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

(1) The regulation provides in pertinent part:

(a) "(a) except as provided in § 91.715, no person may operate a civil aircra ft unless it has within it the following:

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

(b) No person may operate a civil aircraft unless the airworthine ss certificate required by paragraph (a) of this section or a special flig ht authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

(2) The UAS's fully loaded weigh no more than 55 lbs. and are operated w ithout an onboard pilot. As such, there is no ability or place to carry cer tification and registration documents, or to display them on the UAS's.

(3) An equivalent level of safety will be achieved by keeping these documents at the ground control point where the UAS's pilots flying the UAS's w ill have immediate access to them, to the extent they are applicable to the UA S's. The FAA has issued numerous exemptions to this regulation. A representative sample of other exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

xiii) 14 C.F.R. § 91.405 (a): Maintenance Inspections

(1) 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 requir ed inspections, except as provided in paragraph (c) of this section, have discrepancies

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com repaired as prescribed in part 43 of this chapter ...," and others shall inspec t or maintain the aircraft in compliance with Part 43.

(2) Given that these sections and Part 43 apply only to aircraft wi th an airworthiness certificate, these sections will not apply to the UAS's as proposed to be operated by the Applicant. Maintenance will be accomplished by the Applican t pursuant to the flight manual and operating handbook. An equivalent level of safety w ill be achieved because these UAS's are very limited in size and w ill carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS's can land immediately and w ill be operating from no higher than 400 feet AGL. The Applicant will ensure tha t the UAS is in working order prior to initiating flight, perform required mainte nance, and keep a log of any maintenance performed. Moreover, the Applicant is th e person most familiar with the aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety.

xiv) 14 C.F.R. § 91. 407 (a) (1): Maintenance Inspections

(1) 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 requir ed inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...," and others shall inspec t or maintain the aircraft in compliance with Part 43.

(2) Given that these sections and Part 43 apply only to aircraft wi th an airworthiness certificate, these sections will not apply to the UAS's as proposed to be operated by the Applicant. Maintenance will be accomplished by the Applican t pursuant to the flight manual and operating handbook. An equivalent level of safety w ill be achieved because these UAS's are very limited in size and w ill carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS's can land immediately and w ill be operating from no higher than 400 feet AGL. The Applicant will ensure tha t the UAS is in working order prior to initiating flight, perform required mainte nance, and keep a log of any maintenance performed. Moreover, the Applicant is th e person most familiar with the aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety.

xv) 14 C.F.R. § 91. 409 (a) (1) & (2): Maintenance Inspections

(1) 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 requir ed inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...," and others shall inspec t or maintain the aircraft in compliance with Part 43.

(2) Given that these sections and Part 43 apply only to aircraft wi th an airworthiness certificate, these sections will not apply to the UAS's as proposed to be operated by

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com the Applicant. Maintenance will be accomplished by the Applican t pursuant to the flight manual and operating handbook. An equivalent level of safety w ill be achieved because these UAS's are very limited in size and w ill carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS's can land immediately and w ill be operating from no higher than 400 feet AGL. The Applicant will ensure tha t the UAS is in working order prior to initiating flight, perform required mainte nance, and keep a log of any maintenance performed. Moreover, the Applicant is th e person most familiar with the aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety.

xvi) 14 C.F.R. § 91. 417 (a) & (b): Maintenance Inspections

(1) 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 requir ed inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...," and others shall inspec t or maintain the aircraft in compliance with Part 43.

(2) Given that these sections and Part 43 apply only to aircraft wi th an airworthiness certificate, these sections will not apply to the UAS's as proposed to be operated by the Applicant. Maintenance will be accomplished by the Applican t pursuant to the flight manual and operating handbook. An equivalent level of safety w ill be achieved because these UAS's are very limited in size and w ill carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the UAS's can land immediately and w ill be operating from no higher than 400 feet AGL. The Applicant will ensure tha t the UAS is in working order prior to initiating flight, perform required mainte nance, and keep a log of any maintenance performed. Moreover, the Applicant is th e person most familiar with the aircraft and best suited to maintain the ai rcraft in an airworthy condition to provide the equivalent level of safety.

The name and address of the applicant ("Applicant") is:

Jack Carr Morgan, PE/PS Attention: Jack Morgan 118 Farrar Lane Waveland, Mississippi 39576 Telephone: (504) 452-7694

Email: JMorganPEPS@Hotmail.com

# Jack Carr Morgan, PE/PS
118 Farrar Lane, Waveland, Mississippi 39576 Phone (504) 452-7694

Email: JMorganPEPS@Hotmail.com

SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publica tion in the Federal Register, should it be determined that publication is needed:

Approval of exemptions allowing commercial operations of UAS's i n the mapping and surveying industry will enhance safety by reducing risk associated with conv entional mapping and surveying operations, using manned aircraft operating at low altitudes and in proximity to people and structures. UAS weighing fewer than 55 lbs. and powered by batter ies eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS are carried to the mapping or surveying site and not flown. The UAS crew remains in control from the ground, not exposed to the risks associated with manned aircraft flights.

The operation of UAS's, weighing less than 55 lbs., conducted in t he strict conditions outlined above, will provide an equivalent level of safety supporting the g rant of the exemptions requested herein, including exempting the Applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds and close to the ground, as a result, are far safer than conventional operations conducte d with turbine helicopters or other manned aircraft operating in close proximity to the ground and people.

Satisfaction of the criteria provided in Section 333 of the Refor m Act - size, weight, speed, operating capabilities, proximity to airports and operation withi n visual line of sight and national security - provide more than adequate justification for the g rant of the requested exemptions allowing commercial operation of Applicant's UAS's in the mapping and survey ing industry.

Applicant seeks an exemption from the following rules:

14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.105 (a) & (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); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to operate commercially small unmanned aircraft systems (55 lbs. or less) in mapping and surveying ope rations.

The aircraft will be operated solely in the continental United States.

The aircraft used will be a mixture of professional-grade aircraft, i ncluding but not limited to DJI Phantom 3, DJI S1000, and other comparable aircraft by the same and other manufacture rs. Aircraft are small all-electric drones that provide prec ision 3D mapping, real-time thermal infrared and high definition photographic and video capabilities. The systems deploy quickly in nearly every environment due to their light weight. The DJI aircraft have been previously approved by the FAA under this exemption process on numerous occasions, and any other brand and type aircra ft used will have also been previously approved. All aircraft will be regis tered with FAA before deployment.

Very truly yours,
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Jack Carr Morgan, PE/PS