October 9 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

REQUEST

Remote Geomatics LLC (Remote Geomatics) seeks exemption to operate an Unmanned 

Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). from the requirements of 14 C.F.R.

61.113(a) & (b), 

91.7(a),

91.121, 

91.151(a)(1),

91.405(a),

91.407(a)(1),

91.409(a)(1) & (a)(2), and

91.417(a)& (b), 

This exemption will permit Remote Geomatics to commercially operate four (4) 

Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial acquisitions 

within the National Airspace System (NAS) for compensation or hire.

INTRODUCTION 

Remote Geomatics LLC is a multi-specialty architectural/engineering firm that has 

assisted public and private clients since 2013, offering transportation, traffic, civil, 

structural, water resources, levee, and river engineering, as well as services in energy 

corridors, architecture, environmental science, surveying, grants, planning, geospatial, 

and GIS. Our superb project managers build long-term relationships with clients while 

reliably solving their problems, stretching their dollars, and masterfully navigating 

regulations.

Our firm was founded by Robin Moore, who instituted many of the practices we follow: 

working with clients as a partner; offering smart, creative solutions; conducting business 
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with the utmost integrity; and providing employees challenges and the opportunity to 

advance and invest in their company.

Remote Geomatics will use the 3drobotics (3DR) Solo and X8-M , the SteadiDrone 

Mavrik (Mavrik), and the DJI Phantom 3 rotary wing systems to commercially provide 

professional geospatial services to clients associated with land use planning, mining,

utilities to conduct inventories, mapping and inspection services, environmental planning 

and other geomatics applications. Use of these complimentary systems will provide 

Remote Geomatics with a suite of safe and efficient platforms to perform its business 

operations.

AIRCRAFT 

Remote Geomatics seeks an exemption to operate the 3DR Solo, X8-M, Mavrik, and DJI 

Phantom3 for compensation or hire within the NAS. The 3DR Sole, X8-M, Mavrik, and 

DJI Phantom3 are rotary wing UAS’s, all are electrically powered propeller driven 

systems. Unmanned Aircraft (UA) with transportable Ground Control Stations (GCS). 

The 3DR Solo has a maximum gross weight of approximately 6.8 pounds, the X8-M has 

a maximum gross weight of approximately 7.7 pounds, the Mavrik has a maximum gross 

weight of approximately 6.8 pounds, the DJI Phantom 3 has a maximum gross weight of 

approximately 6.0 pounds . All four systems are equipped with propeller systems driven 

by a Lithium Polymer battery powered electric motor.

The 3DR Solo, X8-M, Mavrik, and DJI Phantom3 will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking with markings as large as practicable.

BASIS FOR PETITION

Remote Geomatics, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, petitions the Administrator to 

commercially operate the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 within the 

National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R. 

61.113(a) & (b), 

91.7(a),

91.121,

91.151(a)(1),

91.405(a),

91.407(a)(1),

91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

In accordance with 14 C.F.R. § 11.81, Remote Geomatics provides the following 

information in support of its petition for exemption:
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Name and Address of the Petitioner.

The name and address of the Petitioner:

Remote Geomatics

3737 N. Walnut St.

Kansas City, MO 64116

Phone: 816.651.4966

Robin Moore

President

Remote Geomatics

3737 N. Walnut St.

Kansas City, MO 64116

T: 816.651.4966
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The following documents contain proprietary information and are to be held in a separate 

file pursuant to 14 C.F.R. § 11.35(b).

1. 3DR Solo User Manual

2. 3DR Solo Setup Guide 

3. 3DR x8M Operation Manual V3

4. Mavrik: Mavrik Manual Mavrik Quick Start Guide

5. Mavrik LI-PO Safety and Disposal

6. Mavrik Peridoc Maintenance Check

7. DJI Phantom 3 Professional User Manual V1.4, 

8. Remote Geomatics Field Preflight and Safety Checklist

9. Remote Geomatics Flight Log

10. Remote Geomatics UAS Flight Safety Procedure

Description of Proposed Operations and Safety Procedures

1. In order to maintain the highest possible degree of safety and consistency the key 

safety and operational restrictions are incorporated to our daily Flight and safety 

checklist, thus ensuring full compliance by the PIC and VO.

2. Remote Geomatics proposes to commercially operate the UAS for the special 

purpose of conducting aerial acquisitions within the NAS, pursuant to the 

following specific operating limitations.

3. Proposed Operations will be limited to the following aircraft described in the 

operating documents, which are fixed and rotary wing, propeller driven aircraft 

with the following characteristics:

a. The 3DR Solo has a maximum gross weight of approximately 6.8 

pounds;

b. The 3DR X8-M has a maximum gross weight of approximately 7.7 

pounds;

c. The Mavrik has a maximum gross weight of approximately 6.8 pounds 

and 

d. The DJI Phantom 3 has a maximum gross weight of approximately 6.0 

pounds. 

e. All four systems are equipped with propeller systems driven by a 

Lithium Polymer battery powered electric motor.

4. UAS operations under this proposed exemption will be limited to conducting 

operations for the purpose of aerial acquisitions.

5. The UA will not be flown at an indicated airspeed exceeding 80 knots or not 

exceeding the manufacturer’s recommendations. 

6. The UA will be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents. All altitudes reported to ATC will be in feet AGL.
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7. The UA will 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.

8. The use of first person view (FPV) by the pilot in command PIC or visual 

observer (VO) will not be permitted.

9. All operations will utilize a visual observer (VO). The VO will be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The VO and PIC will be able to communicate verbally at all times. Electronic 

messaging or texting will not be permitted during flight operations. The PIC will 

be designated before the flight and will not transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can perform the functions 

prescribed in the operating documents.

10. The VO will not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

will not be permitted to operate the camera or other instruments.

11. The operating documents and the grant of exemption will be accessible during 

UAS operations and made available to the Administrator upon request.

a. If a discrepancy exists between the conditions and limitations contained 

in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of 

exemption take precedence and must be followed. 

b. The operator will follow the procedures as outlined in the operating 

documents. 

c. The operator may update or revise the operating documents. 

d. It is the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. 

e. The operator will present updated and revised documents if it petitions 

for extension or amendment to the grant of exemption. 

f. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator will

petition for amendment to the grant of exemption. 

g. The FAA’s UAS Integration Office (AFS-80) will be contacted if 

questions arise regarding updates or revisions to the operating 

documents.

12. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for 

safe flight.

a. 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. 

b. The Ground Control Station will be included in the preflight inspection.
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c. All maintenance and alterations will be properly documented in the 

aircraft records.

13. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

will undergo a functional test flight. The PIC who conducts the functional test 

flight will make an entry in the aircraft records.

14. The pre-flight inspection will account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

a. The operator will follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit 

requirements.

b. The operator must carry out its maintenance, inspections, and record 

keeping requirements, in accordance with the operating documents. 

c. Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts will be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service.

d. Each UAS operated under this exemption will comply with all 

manufacturer Safety Bulletins.

e. The authorized person will make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between 

inspections.

15. The PIC will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will 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 will 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 certificate. This is per 

exemption as granted in Docket 11238 Dated March 26, 2015.

16. The operator will not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

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

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles, and structures. 

a. The PIC qualification flight hours will be logged in a manner consistent 

with 14 C.F.R. § 61.51(b). 

b. The VO will complete the operator’s training requirements. 

c. The record of training will be documented and made available upon 

request by the Administrator. 

d. Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building), will be permitted under 

the terms of the exemption. 
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e. Training operations will only be conducted during dedicated training 

sessions. 

i. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with14 

C.F.R. § 91.119.

17. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized.

18. The UA will not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published Airport Facility Directory ( AFD) or air 

reference point ( ARP) unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the 

airport management will be made available to the Administrator upon request.

19. The UA will not be operated less than 400 feet below or less than 2,000 feet 

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

PIC.

20. If the UAS loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents.

21. The PIC will abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 20% battery power 

remaining.

23. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations will be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

a. Note as of March 22 2015 the FAA granted a “blanket” COA for flights 

at or below 200 feet to any UAS operator with a Section 333 exemption. 

Remote Geomatics will operate aircraft that weighs less than 55 lbs., will 

conduct operations under VFR rules and conditions within VLOS of the 

PIC and restrict flight from airports and heliports as per applicable FAA 

rules.
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24. All aircraft operated in accordance with the exemption will be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification 

(N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. 

Markings will be as large as practicable.

25. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA will comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.

26. The UA will remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

27. The UAS will not be operated by the PIC from any moving device or vehicle.

28. The UA will not be operated over congested or densely populated areas.

29. Flight operations will be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, operator trainees or essential 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. 

b. The operator will ensure that nonparticipating persons remain under such 

protection. 

c. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations will cease 

immediately and/or;

d. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission 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, and

e. Operations nearer to the PIC, VO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a).

30. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. 

a. Permission from the land owner/controller or authorized representative 

will be obtained for each flight to be conducted and will be documented 

as part of the project execution plan.

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

boundaries of the operational area as defined by the applicable COA will 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.
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Requested Regulations for Exemptions and Equivalent Level of Safety

14CFR Section61.113(a) and (b).

1. Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

command, subsections (a) and (b) prescribe the following, in relevant part:

a. No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act 

as PIC of an aircraft.

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if:

i. The flight is only incidental to that business or employment; and 

ii. The aircraft does not carry passengers or property for 

compensation or hire.

2. Remote Geomatics submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the Aero3DR Solo, X8-M, Mavrik, 

and DJI Phantom 3 UAS’s unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate the 

3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS’s in a manner consistent 

with the operations specifications as set forth herein, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures.

3. Further, Remote Geomatics submits that all flights of the 3DR Solo, X8-M, 

Mavrik, and DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant of 

this Petition: (1) will be incidental to Remote Geomatics business; and (2) will 

not carry passengers or property for compensation or hire.

4. Specifically, the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption). In addition to the 

hour requirements, the PIC will accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes).

14CFR Section 91.7(a).

1. Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition.

a. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow Remote Geomatics to determine 

that the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS are in an 

airworthy condition prior to every flight by ensuring that each UAS is in 
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compliance with the operating documents (UAS DOCUMENTS ) and 

that the aircraft are in a condition for safe flight.

b. Remote Geomatics seeks the requested relief because the 3DR Solo, X8-

M, Mavrik, and DJI Phantom3 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

prior to every flight, Remote Geomatics will ensure that the 3DR Solo, 

X8-M, Mavrik, and DJI Phantom 3 UAS are in an airworthy condition 

based upon manufacturer’s operating documents.

2. The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Remote Geomatics will ensure that the UAS are in 

an airworthy condition based upon the aircraft’s operating documents (i.e., the 

User Manual, Maintenance Procedures).

3. Remote Geomatics seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the 3DR Solo, X8-M, Mavrik, and DJI Phantom3 UAS’s 

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Remote Geomatics submits that it will ensure that the 3DR 

Solo, X8-M, Mavrik, and DJI Phantom 3 UAS’s are in an airworthy condition, 

prior to every flight, by determining that the UAS being used is in compliance 

with the operating documents and that the aircraft is in a condition for safe flight 

as below in the supporting documents:

f. 3DR Solo User Manual

g. 3DR Solo Setup Guide 

h. 3DR x8M Operation Manual V3 

i. Mavrik: Mavrik Manual Mavrik Quick Start Guide 

j. Mavrik LI-PO Safety and Disposal

k. Mavrik Peridoc Maintenance Check

l. DJI Phantom 3 Professional User Manual V1.4, 

m. Remote Geomatics Field Preflight and Safety Checklist 

n. Remote Geomatics Flight Log 

o. Remote Geomatics UAS Flight Safety Procedure

14CFR Section 91.121.

1. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part:

a. Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating:

i. Below 18,000 feet MSL, the current reported altimeter setting of 

a station along the route and within 100 nautical miles of the 

aircraft;

ii. If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of 

an appropriate available station; or
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iii. In the case of an aircraft not equipped with a radio, the elevation 

of the departure airport or an appropriate altimeter setting 

available before departure.

2. Remote Geomatics seeks relief from Section 91.121, entitled Altimeter settings, 

which is required to allow flight operations of the 3DR Solo, X8-M, Mavrik, and 

DJI Phantom 3 UAS because before each flight, the altitude reporting equipment 

will be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude. The 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 

UAS utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the 

UA to the PIC at the ground control station (GCS).

3. In order to maintain a level of safety equivalent to Section 91.121 reporting will 

be ensured as the altitude of the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 

will be reported to air traffic control (ATC) in feet above ground level (AGL), 

and Remote Geomatics will operate the 3DR Solo, X8-M, Mavrik, and DJI 

Phantom 3 within visual line of sight (VLOS), at or below 400 feet AGL.

4. The altitude information of the UA will be provided to the PIC via a barometric 

pressure sensor, GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path 

and altitude. Prior to each flight, a zero altitude initiation point will be 

automatically established by the UAS at ground level.

14CFR Section 91.151(a)(1).

1. Section 91.151, entitled Fuel requirements for flight in visual flight rules (VFR)

conditions, subsection (a)(1), states the following, in relevant part:

a. No person may begin 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.

b. During the day, to fly after that for at least 30 minutes.

2. Remote Geomatics seeks relief from Section 91.151(a)(1) entitled Fuel 

requirements for flight in VFR conditions, to the extent required to allow flights 

of the battery powered 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 during 

daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR) to fly for a total duration of 18- 40 (Rotary ,fixed wing) minutes to 

the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least ten minutes or 20 percent battery power remaining. Remote 

Geomatics seeks the requested relief because without an exemption from Section 

91.151(a)(1), the flight time duration of the battery powered 3DR Solo, X8-M, 

Mavrik, and DJI Phantom3 will severely constrain the practicality of any aerial 

acquisition and research flight operations that Remote Geomatics proposes to 

conduct pursuant to this Petition.
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3. The technical specifications of the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 

UAS, as well as Remote Geomatics proposed operating limitations, will ensure 

safe operation of the battery powered 3DR Solo, X8-M, Mavrik, and DJI 

Phantom 3 UAS during daylight hours in VMC, under VFR, with enough battery 

power to fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least ten minutes or 20 percent battery power 

remaining.

4. A grant of this exemption would ensure an equivalent level of safety established 

by 14C.F.R. Section 91.151(a)(1) as a result of (1) the technical specifications of 

the UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. 

5. Remote Geomatics will ensure that it will safely operate the battery powered UA 

only during daylight hours in visual metrological conditions (VMC) under visual

flight rules (VFR), with enough battery power for the 3DR Solo, X8-M, Mavrik, 

and DJI Phantom 3 to fly for the specific system duration to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 

ten minutes or 20 percent battery power remaining.

14CFR Section 91.405(a). 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only

1. Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) only apply to aircraft with an airworthiness certificate, Remote Geomatics

requests relief from these Sections because the 3DR Solo, X8-M, Mavrik, and 

DJI Phantom 3 UAS do not require an airworthiness certificate. As set forth more 

fully below, the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS meet the 

conditions of Section 333 of the FMRA for operation without an airworthiness 

certificate.

2. All maintenance, alterations, or preventive maintenance of the 3DR Solo, X8-M, 

Mavrik, and DJI Phantom 3 UAS will be performed by Remote Geomatics in 

accordance with the methods, techniques, and practices prescribed in the 

operating documents:

a. 3DR Solo User Manual

b. 3DR Solo Setup Guide 

c. 3DR x8M Operation Manual V3 

d. Mavrik: Mavrik Manual Mavrik Quick Start Guide 

e. Mavrik LI-PO Safety and Disposal

f. Mavrik Peridoc Maintenance Check

g. DJI Phantom 3 Professional User Manual V1.4, 

h. Remote Geomatics Field Preflight and Safety Checklist 

i. Remote Geomatics Flight Log 

j. Remote Geomatics UAS Flight Safety Procedure

3. Only the Original Equipment Manufacturer (OEM) or qualified OEM 

maintainers will perform higher-level inspections and maintenance per the 
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operating documents and OEM standards. Remote Geomatics will document and 

maintain all maintenance records for the 3DR Solo, X8-M, Mavrik, and DJI 

Phantom 3 UAS.

4. Remote Geomatics submits that the equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because all maintenance, alterations, or preventive maintenance of the UAS 

performed by Remote Geomatics will be in accordance with the methods, and 

practices required in the operating documents.

5. Since the UAS will be inspected as prescribed by the operating documents, 

Remote Geomatics will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating 

documents are attached.

a. 3DR Solo User Manual

b. 3DR Solo Setup Guide 

c. 3DR x8M Operation Manual V3 

d. Mavrik: Mavrik Manual Mavrik Quick Start Guide 

e. Mavrik LI-PO Safety and Disposal

f. Mavrik Peridoc Maintenance Check

g. DJI Phantom 3 Professional User Manual V1.4, 

h. Remote Geomatics Field Preflight and Safety Checklist 

i. Remote Geomatics Flight Log 

j. Remote Geomatics UAS Flight Safety Procedure

The Public Interest

1. Granting the present Petition will further the public interest by allowing Remote 

Geomatics to safely, efficiently, and economically perform aerial acquisitions 

and mapping within the NAS, commercially, in support of government entities, 

engineering , agriculture, railroad industry, utilities, oil and gas industries, 

environmental, and shoreline mapping. The use of the 3DR Solo, X8-M, Mavrik, 

and DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of Remote 

Geomatics proposed operation of the 3DR Solo, X8-M, Mavrik, and DJI 

Phantom 3 UAS will be realized without implicating any privacy issues.

2. The 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 will provide safe, efficient, 

and economical aerial acquisition and mapping operations to further each of 

these fields, all of which are critical to the well-being of the general public.

3. The specific operations that Remote Geomatics will perform with the 3DR Solo, 

X8-M, Mavrik, and DJI Phantom 3 UAS demonstrate how the requested 

exemption will directly benefit the above-referenced industries and the public, as 

a whole. In land use planning, engineering and mapping and industrial 

operations, the UAS will be used to aid in inspections, survey and plan new 

worksites, conduct volumetric analysis, and perform right of way analysis. The 
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UAS may also be used to aid in environmental management of coastal and tidal 

areas, to map and monitor protected habitat and species.

The Public Will Benefit From Decreased Congestion Of The NAS

1. The 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS are battery powered 

and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the 

use of UAS would reduce the amount of manned aircraft in the NAS, reduce 

noise and air pollution, and increase the safety of life and property in the air and 

on the ground.

2. The 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS do not require an airport 

to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

survey missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

3. The UAS to perform aerial acquisitions, the substantial risk to life and property 

in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. 

4. The UAS will only be operated pursuant to the specific conditions and limitations 

and in accordance with the Federal Aviation Regulations, including the minimum 

altitude requirements of 14 C.F.R. § 91.119. The UA will not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure, which is not directly 

involved in the operation so that privacy will not be of a concern.

5. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Remote Geomatics Seeks Exemption:

a. Remote Geomatics seeks exemption from the requirements of 14 C.F.R. 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

CONCLUSION

1. This exemption will permit Remote Geomatics to commercially operate 

Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial 

acquisitions within the National Airspace System (NAS).

2. Remote Geomatics seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 

commercially, without an airworthiness certificate, for the limited purpose of 

conducting aerial acquisitions within the National Airspace System (NAS). By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also 
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November 16, 2015

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advancing the public interests, by allowing Remote Geomatics to safely, 

efficiently, and economically operate UAS commercially within the NAS.

3. In accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, Remote Geomatics respectfully requests 

that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit operation of 

the 3DR Solo, X8-M, Mavrik, and DJI Phantom 3 UAS commercially for the 

purpose of conducting aerial acquisitions within the NAS.

Respectfully Submitted,

Remote Geomatics, Inc.

Robin Moore

President

Remote Geomatics

3737 N. Walnut St.

Kansas City, MO 64116

T: 816.651.4966