October 9 2015

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

R E : 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.

INTRODU C TION

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, stret ching 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 businessU.S. Department of Transportation

November 16 , 2015 Page 2

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 Steadi Drone

Mavrik (Mavrik)

, and the DJI Phantom 3 rotary wing systems to comme rcially provide professional geospatial services to clients associated with land use planning, mining

, utilities to conduct inventories, mapping and inspection servic es, environmental planning

a nd other geomatics applications . Use of these complimentary systems will provide

Remote Geomatics with a suite of safe and efficient platform s to perform its business operations.

AIRCRAFT

Remote Geomatics seeks an exemption to operate the 3 DR 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 Station s (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 gr oss 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 F OR P ETI T I ON

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 3 DR 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:U.S. Department of Transportation

November 16 , 2015 Page 3

N a m e a n d Ad d re ss o f t h e P e t i tione r

.

The n a me a nd a dd r e ss of the Peti t ioner : 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

. 4966U.S. Department of Transportation

November 16 , 2015 Page 4

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

- P O Safety and Disposal

6. Ma vrik Peridoc Maintenance Check

7. DJI Phantom 3 Professional User Manual V1.4

, 8. Remote Geomatics Field Pref light 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 wei ght of approximately 6.8 pounds ; b. The 3DR X8

- M has a maximum gross weight of approximately 7.7 pounds;

c. T he Mavrik has a maximum g ross weight of approximately 6.8 pounds

and

d. T he DJI Phantom 3 has a maximum gross weigh t 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 a n 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 4 00 feet above ground

lev el (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC will be in feet AGL.U.S. Department of Transportation

November 16 , 2015 Page 5

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 h uman 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 beyon d assi sting 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 cond itions and limitations contained in the grant of exemption take precedence and must be followed.

b. T he opera tor will follow the procedures as outlined in the operating

documents.

c. The operator may update or re vise the operating documents.

d. It is the operato r’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request.

e. The opera tor will present updated and revised documents if it petitions for extension or amendment to the grant of exemption.

f. If the o perator 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 questio ns 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 ai rcraft 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.U.S. Department of Transportation

November 16 , 2015 Page 6

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 opera tor 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/ov erhaul

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 wit h 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, r ecreational, 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

PI C 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 P IC 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 main taining appropriate distances from persons, vessels, vehicles

, and structures.

a. The PIC qualification flight hour s will be logged in a manner consistent with 14 C.F.R. § 61.51(b).

b. The VO will c omplete 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.U.S. Department of Transportation

November 16 , 2015 Page 7

e. T raining 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 wi th 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 Fa cility 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

air port management w ill be made available to the Administrator upon request.

19. The UA will not be operated less than 4 00 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 UA S lose s communications or loses its GPS signal, it will return to a pre

determined 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 obstacle s 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 la nd 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 oper ator 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 applic able FAA

rules.U.S. Department of Transportation

November 16 , 2015 Page 8

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.

Mar kings 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 requir ements.

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 operati ons 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 ari ses 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 per sons 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 owne r/controller or authorized representative will be obtained for each flight to be co nducted 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 repor ted to the National Tra nsportation Safety Board (NTSB), per instructions contained on the NTSB We b site: www.ntsb.gov.U.S. Department of Transportation

November 16 , 2015 Page 9

Requested R egulations for Exemption s and Equivalent Level of Safety

14CFR Section61.113(a) a nd (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 aircraf t 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 employ ment if : i. The flight is only incidental to that business or employ ment; 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 Aero 3DR Solo, X8

- M, Mavrik,

and DJI Phantom 3 UA S’ s unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the P IC 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 peo ple, 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 hou rs 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 ensu ring that each UAS is inU.S. Department of Transportation

November 16 , 2015 Page 10

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 oper ating doc uments.

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 operatin g 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 Proce dure

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 operat ing : i. Below 18,000 feet MSL, t he 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; orU.S. Department of Transportation

November 16 , 2015 Page 11

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 depa rture.

2. Remote Geomatics seeks r elief 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 s et 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 downli nk 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 repo rted 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 4 00 feet AGL

.

4. The altitude information of the UA will be pr ovided 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

sp eed

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

.

2. Remote Geomatics seeks r elief 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

da ylight 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 remaini ng

. 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.U.S. Department of Transportation

November 16 , 2015 Page 12

3. Th e 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 UA S dur ing 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

remaini ng.

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 operation s.

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 Phan tom 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 pe rcent 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. O nly the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher

- level inspections and maintenance per theU.S. Department of Transportation

November 16 , 2015 Page 13

oper ating 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 maint enance 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 a ccordance 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), 91.4 09(a)(1), and 91.409(a)(2). The following operating

documents are attache d

.

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 , agri culture, 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 implicat ing 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 plan ning , 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. TheU.S. Department of Transportation

November 16 , 2015 Page 14

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 O f The NAS

1. The 3DR Solo, X8

- M, Mavrik, and DJI Phantom 3 UA S 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 UA S 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. T he 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. T he UAS will only be operated pursuant to the specific conditions and limitations and in accordance with the Federal Aviation Regulations, including the minimum altitude requir ements of 14 C.F.R. § 91.119. T he UA will not be operated closer

than 500 feet t o 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 Modernizatio n 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 Sy stem (NAS). By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while alsoU.S. Department of Transportation

November 16 , 2015 Page 15

advancing the public interests, by allowing Remote Geomatics to safely, efficiently, and economically operate UAS commercially within the NAS.

3. I n 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 commercia lly for the purpose of conducting aerial acquisitions within the N AS

.

Respectfully Submitted

, Remote Geomatics , Inc.

Robin Moore

President

Remote Geomatics

3737 N. Walnut St. Kansas City, MO 64116

T : 816.651.4966