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 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Request to Amend Exemption Number 11393 (Granted 20 April 2015) issued 

pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations in Regulatory Docket No. FAA-2014-0353-0001 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012, 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 of three additional sUAS, so long as such operations are conducted within and under 

the conditions outlined by the grant of the 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 be published in the Federal Register for the requested amendment. 

Currently, per paragraph 1 of the section of exemption number 11393 named "Conditions and 

Limitations", SAM's exemption is limited to operations using the Allied Drones HometCam, and 

proposed operations of any other aircraft require a petition to amend exemption number 113 93. 

The name and address of the applicant is: 

Surveying And Mapping, LLC 

Attention: Pat Smith 

4801 Southwest Parkway 

Bldg. Two, Suite 1 00 

Austin, TX 78735 

Telephone: (512) 685-3542 

Email: psmith@sam.biz 
The Applicant hereby requests to amend the Exemption, and the issuance of an FAA Form 7711-

1 UAS COA Attachment, to allow the use of the following three sUAS: 

1. 3DRobotics Aero-M aircraft 

2. 3DRobotics Iris+ aircraft, and 

3. Trimble UX5 aircraft. 

(Aircraft numbered 1, 2 and 3 above, collective the "Amendment Aircraft") 

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 the use 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 extent necessary to allow the petitioner to operate a U AS 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 

listed below: 

1. Operations authorized by this 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 including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to 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 U A 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). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 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) of the 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 of the flight. The PIC 

must ensure that the VO can perform the duties required of the 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 available to the Administrator upon 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 operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the 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 operating documents. 

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 only be conducted by a PIC with aVO and must remain at least 

500 feet from other people. The functional test flight must be conducted in such a manner 

so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is 

in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be 

in a condition for safe flight. 
11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, 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 certificate or a valid U.S. driver's license issued by a state, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot cettificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances fi:om persons, vessels, vehicles and structures. PIC qualification flight hours 

and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator's PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC's ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption are permitted under the terms of this 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 must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. U AS 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 of the airport symbol as denoted on the current FAA- published 

aeronautical chart, unless a letter of agreement with that airport's management is obtained 

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 
SIIMC GuRv£VIHG+AERIAL HAPPING+EtroiH!ERI:G "'"'t. ---------·~~··--·----~ 

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 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the 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 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents 

must be made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an 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 of the UA, 

flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk 

of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this 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 

obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 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 of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91. 

Summary 

Approval of this amendment to the granted Exemption and the issuance of an 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 if you 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 

Parkway Two, Suite 100 

Austin, TX 78735 

Direct 512.685.3542 

Attachments: 

Annex A (Aero-M Operation Manual) 

Annex B (Iris+ Operation Manual) 

Annex C (UX5 Operation Manual)