May 5, 2015 Surveying And Mapping, LLC 4801 Southwest Parkway, Building Two, Suite 100, Austin, TX 78735 Ofc 512.447.0575 Fax 512.326.3029 info@sam.biz www.sam.biz TX Firm# 10064300

U.S. Department ofTransportation DocketManagement System 1200 NewJerseyAve., SE Washington, DC 20590



### RE: Request to Amend Exemption Number 11393 (Granted 20 April 2015) issued pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe FederalAviation Regulations in RegulatoryDocketNo. FAA-2014-0353-0001

Dear SirorMadam: Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012, Pub. 

### L. No. 112-95, 126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the 

### "Reform Act") and 14 C.F.R. Part 11, Surveying And Mapping, LLC 

### ("SAM" or 

### "Applicant"), developer and operator of small unmanned aircraft systems (singularly a 

### "sUAS" or cumulatively 

### "sUASs") equipped to conduct professional aerial land surveying and geospatial services, hereby applies for a petition to amend Exemption Number 11393, granted April 20, 2015 (the 

### "Exemption"), to allow commercial operation ofthree additional sUAS, so long as such operations are conducted within and under the conditions outlinedbythe grant ofthe Exemption. As SAM is only requesting to add aircraft to the Exemption, we do not feel that this amendment qualifies as precedent-setting, per guidance located at: http://aes.faa.gov/Petition/faq5a.html. The Applicant respectfully submits that good cause exists so that notice does not need to bepublished in the Federal Registerfor therequested amendment. Currently, per paragraph 1 ofthe section ofexemption number 11393 named "Conditions and Limitations", SAM's exemption is limited to operations usingthe Allied Drones HometCam, and proposed operations ofany other aircraftrequire a petition to amend exemption number 11393. The name and address ofthe applicant is: SurveyingAnd Mapping, LLC Attention: Pat Smith 4801 Southwest Parkway Bldg. Two, Suite 1 00 Austin, TX 78735 Telephone: (512) 685-3542 Email: psmith@sam.bizThe Applicant hereby requests to amend the Exemption, andthe issuance ofan FAA Form 7711- 1 UAS COA Attachment, to allow the use ofthe following three sUAS: 1. 3DRoboticsAero-M aircraft 2. 3DRobotics Iris+ aircraft, and 3. Trimble UX5 aircraft. (Aircraft numbered 1, 2 and 3 above, collectivethe "AmendmentAircraft") In parallel to the Exemption, these aircraft will be used for commercial aerial data collection by Applicant. Aircraft technical data and checklists are attached to this petition, labeled Annex A (Aero-M Operation Manual), Annex B (Iris+ Operation Manual), and Annex C (UX5 Operation Manual). Previously granted exemptions 11379, 11204, 11329, and 11257 allowed for theuse of the Amendment Aircraft, respectively, for commercial purposes, and we feel this petition to amend 11393 is similar in material respects to the aforementioned granted exemptions, and similar in all material respects to Exemption Nos. 11062, 11109, 11112, and 11213, referenced in the Exemption. In accordance with the conditions and limitations granted to SAM under 11393, the applicant requests exemption from the following while operating the Amendment Aircraft:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extentnecessaryto allow thepetitionerto operatea UAS to perform aerial data collection. In accordance with the section of 11393 known as "Conditions and Limitations", SAM hereby requests to operate the Amendment Aircraft while adhering to the conditions and limitations listedbelow: 1. Operations authorized bythis amendment to the Exemption are limited to the 3DRobotics Aero-M, the 3DRobotics Iris+, and the Trimble UX5 Aircraft each when weighing less than 55 pounds includingpayload. Proposed operations ofany other aircraft will require a newpetitionor a petitionto amend this exemption. 2. Operations for the purpose of closed-set motion picture and television filming are not permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitudemustbereported in feet AGL. 5. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be ableto use human vision unaidedby any deviceotherthan corrective

### lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensurethatthe VO can perform the duties required ofthe VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made availableto the Administratorupon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It 

### is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operatormust also present updated and revised documents ifit petitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operatingdocuments. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may onlybe conducted by a PIC with aVO and must remain at least 500 feet from otherpeople. The functional test flight must be conducted in such a manner so as to not pose an unduehazard to persons and property. 9. The operatoris responsible for maintaining and inspectingthe UAS to ensure that it is in a conditionfor safe operation. 10. Priorto each flight, the PIC must conduct a pre-flightinspection and determinethe UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, orequipment. Ifthe inspectionreveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenancehas been performed and the UAS is found to be in acondition for safe flight.11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirementsfor the aircraftand aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificateor avalidU.S. driver's licenseissued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meetthe flight review requirements specifiedin 14 CFR § 61.56 in an aircraft in whichthe PIC is rated onhis orherpilotcettificate. 14. The operatormaynotpermit any PIC to operateunlessthe PIC demonstrates the abilityto safely operate the UAS in a manner consistent withhow the UAS will be operated under this exemption, includingevasive and emergencymaneuvers and maintaining appropriate distances fi:om persons, vessels, vehicles and structures. PIC qualification flight hours and currencymustbelogged in amanner consistentwith 14 CFR § 61.51(b). Flights for the purposes of training the operator's PICs and VOs (training, proficiency, and experience-building) and determiningthe PIC's abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC mustoperatethe UA with appropriatedistance from nonparticipantsin accordancewith 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA- published aeronautical chart, unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airportmanagementmustbemade available to the Administratororany law enforcementofficial uponrequest. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud or when visibilityis less than 3 statutemiles from the PIC. 18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predeterminedlocation withinthe privateorcontrolled-accessproperty. 19. The PIC must abort the flight in the event ofunpredictedobstaclesoremergencies.

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20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommendedbythemanufacturerifgreater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conductedin accordancewith an ATO-issued COA. Theexemption holder may apply for a new or amended COA if it intends to conduct operations that cannotbeconductedundertheterms ofthe attached COA.
22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFRpart45, Subpart C. Markings must be as large as practicable. 23. Documents used bythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents mustbemade availableto the Administratororanylaw enforcement official uponrequest. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. TheUAS maynotbeoperatedbythePIC from anymoving deviceorvehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structuresunless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonpatiicipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipatingpersons; and b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closerto those objects and the PIC has made a safety assessment oftherisk ofoperatingcloserto those objects and determinedthat itdoes not present an unduehazard. ThePIC, VO, operatortrainees oressentialpersons are not considered nonparticipating persons underthis exemption.27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtainedfor each flight to beconducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Unless otherwise specified in this grant ofexemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicableparts of 14 CFR including, butnot limited to, parts 45, 47, 61, and 91. Summary Approval ofthis amendment to the granted Exemption and the issuance ofan FAA Form 771 I-1 UAS COA Attachment, allowing the operation of the aircraft listed in this document, will provide an equivalent level of safety supporting the amendment requested herein. The Amendment Aircraft possess even more enhanced safety features than the Allied Drones HometCam which was approved for use in the Exemption, and when operated within the conditions and limitations outlined in the Exemption are far safer than conventional operations conducted with manned aircraft used for aerial data acquisition. Please let me know ifyou have any questions concerning this request for an amendment to the Exemption.



# u~ Patrick A. Smith, RPLS Associate Surveying and Mapping LLC (SAM) 4801 Southwest Parkway ParkwayTwo, Suite 100 Austin, TX 78735 Direct 512.685.3542 Attachments: AnnexA (Aero-M Operation Manual) Annex B (Iris+ OperationManual) Annex C (UX5 Operation Manual)