UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETI TION FOR EXEMPTION OF: Spurlock Land Surveying

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 21 subpart H, 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING

COMMERCIAL OPERATION OF THE Micr oKopter UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on May 28, 2015

David Spurlock Spurlock Land Surveying 868 Cliff Street Lander, WY 82520 307-330-7777

TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 2

SUMMARY 2

INTRODUCTION AND INTEREST OF PETITIONERS 3

BACKGROUND 3

BASIS FOR PETITION 3

NAME AND ADDRESS OF PETITIONERS 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Spurlock Land Surveying SEEKS EXEMPTION 5

THE EXTENT OF RELIEF Spurlock Land Surveying SEEK AND THE REASON Spurlock Land Surveying SEEKS THE RELIEF 7

THE REASONS WHY GRANTING REQUEST WOULD BE IN THE PUBLIC INTEREST 10

Page 1 of 23THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 12

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 22

CONCLUSION 22

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area Of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTCAM Notice To Airmen PIC Pilot In Command Section 333 FAA Modernization and Re form Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedure UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line Of Sight VMC Visual Meteorological Conditions VTOL Vertical Takeoff And Landing

SUMMARY

David Spurlock, owner of Spurlock Land Surveyi ng, seeks exemption from th e requirements of 14 C.F.R §§ 21 subpart H, 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405( a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMR A). This exemption will permit Spurlock Land Surveying to operate an Unmanned Aircraft Syst em (UAS) for the commerc ial purpose of conducting aerial mapping, photography and educational awareness over certain areas of the United States.

Page 2 of 23INTRODUCTION AND INTEREST OF THE PETITIONER

David Spurlock is the owner of Spurlock Land Surveying founded in 1997 and located in Lander, Wyoming. David Spurlock has 5 years experience with RC fli ghts and currently works as a Professional Land Surveyor providing services for Engineering, Environmental, Oil and Gas Companies and various land owners thorough most of the western states. The objective of Spurlock Land Surveying is to provide high quality imagi ng for a variety of commercial and public uses, specifically targeting:

● Aerial Maps

● Digital Terrain Models

● Planning and As-built construction

● Educational UAV awareness

● Safety and training

● Increasing public knowledge of UAS and promote safe UAS operations.

BACKGROUND Unmanned Aircraft Systems: MicroKopter UAS

Spurlock Land Surveying seeks an exemption to operate MicroKopter UAS systems for compensation or hire within the NAS. The MicroKopter is a ve rtical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) uti lizing electronic tablet, notebook or smart phone systems. The MicroKopter UAS has a maximum gross weight of 4.6 pounds, a length of 31 inches, width of 31 inches, height of 14 inches, and a maximum speed of approximately 55 knots. The MicroKopter UA is equipped with six main ro tors; driven by Lithium Polymer battery powered electric motors. The MicroKopter UA that will be operated by Spurlock Land Surveying 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.

BASIS FOR PETITION

Petitioner, David Spurlock of Spurlock Land Surv eying pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Un manned Aircraft Systems, hereby petition the Administrator to commercially operate the MicroKopt er UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 21 subpart H, 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Spurlo ck Land Surveying’s operation of the MicroKopter UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Spurlock Land Surveying requests re lief from Sections 91.405 (a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements fo r maintenance that only apply to aircraft with an airworthiness certificate.

Page 3 of 23Spurlock Land Surveying submits that the requested reli ef is proper since an equivalent level of safety will be ensured. Spurlock Land Surveying will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintena nce on the UAS using the methods, techniques, and practices prescribed in the operating documents (i .e., Monthly Maintenance Log, and MicroKopter Instruction Manual). Furthermore, Spurlock Land Surveying will document and maintain all maintenance records for the MicroKopter UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitl ed Private pilot privileges and limitations: Pilot in command, is requested by Spur lock Land Surveying to the extent necessary to allow a Pilot in Command (PIC) holding an airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and currency requirement s, that the PIC is able to safely operate the MicroKopter UAS in a manner consistent with th is exemption, including evasive and emergency maneuvers and maintain appropriate distances fr om people, vessels, vehicles and structures. Spurlock Land Surveying seeks relief from Section 91.7 (a), entitled Civil aircraft airworthiness, because the MicroKopter UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. as such, Spurlock Land Su rveying submits that they will ensure that the MicroKopter UAS is in an airworthy condition, prior to every flight , by determining that the UAS are in compliance with the operating documents (i.e ., Monthly Maintenance Log, and MicroKopter Instruction Manual), and that the aircra ft is in a condition for safe flight.

Spurlock Land Surveying also seeks an exempt ion from the requirements of Section 91.121, entitled Altimeter Settings, as the MicroKopter UA will not have a typical barometric altimeter on board. However, altitude information of the MicroKopt er UA will be provide d to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Spurlock Land Surveying’s ope ration of the MicroKopter UA withinvisual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Spurlock Land Surveying seeks an exemption from the requ irements of Section 91.151(b), entitled Fuel requirement s for flight in VFR conditions. Spurlock Land Surveying submits that safety will not be affected by operation of the MicroKopter UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), w ith enough battery power to fly for a total duration of approximately 20 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, Spurlock Land Surveying provides the following information in support of their petition for exemption:

A. Name and Address Of The Petitioner

David Spurlock, Spurlock Land Surveying 868 Cliff Street, Lander, WY 82520 spurlock.surveing@gmail.com

Page 4 of 23B. The Specific Sections Of 14 C.F.R. From Wh ich Spurlock Land Surveying Seeks Exemption.

1. Spurlock Land Surveying Seeks Exemption Fr om The Requirements Of Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. Spurlock Land Surveying Seeks Exemption Fr om The Requirements Of Section 61.113(a) and (b).

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 certificat e may act as a pilot in command (PIC) of an aircraft that is carrying passengers or propertyfor compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircra ft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in conne ction with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

3. Spurlock Land Surveying Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unl ess it is in an airworthy condition.

4. Spurlock Land Surveying Seeks Exemptio n From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a ), states the following, in part: (a) Each person operating an aircraft shall ma intain the cruising altitude or f light level of that aircraft, as the case may be, by reference to an altimeter th at is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter se tting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area pres cribed in paragraph (a) (1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (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.

5. Spurlock Land Surveying Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraftunder VFR conditions unless (considering wind and forecast weather conditions) th ere is enough fuel to fly to the first point of intended landing and, assuming normal crui sing speed, to fly after that for at least 20 minutes.

Page 5 of 236. Spurlock Land Surveying Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsec tion (a), states the following: Each owner or operator of an aircraft – (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between requ ired inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as pr escribed in part 43 of this chapter[.]

7. Spurlock Land Surveying Seeks Exemption From The Requirements Of Section 91.407(a) (1)

Section 91.407, entitled Operation after maintenan ce, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive mainte nance, rebuilding, or alteration unless-- (1) It has been approved for return to serv ice by a person authorized under § 43.7 of this chapter[.]

8. Spurlock Land Surveying Seeks Exemptio n From The Requirem ents Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the fo llowing: (a) Except as provided in paragraph (c) of this section, no person may ope rate an aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person aut horized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airwor thiness certificate in accordance with part 21 of this chapter.

9. Spurlock Land Surveying Seeks Exemption From The Requiremen ts Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsec tions (a) and (b), stat e the following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for th e periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data accep table to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

Page 6 of 23(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe , each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all item s installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircra ft, including the time si nce the last inspection required by the inspection program under whic h the aircraft and its appliances are maintained.

(v) The current status of applicable airworth iness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive i nvolves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently inst alled engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the follo wing records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2 ) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a regist ered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Sp urlock Land Surveying Seeks And The Reason Spurlock Land Surveying Seeks The Relief.

1. Spurlock Land Surveying Seeks Exemption Fr om The Requirements Of Section Part 21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by the Spurlock Land Surveying, an exemption from Pa rt 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificat e, upon consideration of

Page 7 of 23the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted e nvironment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditi ons of the proposed UAS operations.

2. Extent Of Relief Spurlock Land Surveying Seeks And Th e Reason Spurlock Land Surveying Seeks Relief From Section 61.113 (a) and (b).

Relief from Section 61.113 (a) and (b) entitled Private pilot priv ileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requeste d since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Spurlock Land Surveying submits that an equivalent level of safety will be maintained because no PIC will be allowe d to operate the MicroKopter UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the MicroKopter UAS in a manner consistent with the operations specifications as described in this exemp tion, including evasive and emergency maneuvers, as well as maintaining appropriate distances fr om people, vessels, vehicles and structures.

Further, Spurlock Land Surveying submits that all flights of the Micr oKopter UAS, conducted by the PIC pursuant to the grant of this Petition:

(1) will be incidental to Spurlo ck Land Surveying’s business; and

(2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief Spurlock Land Surveying Seeks And Th e Reason Spurlock Land Surveying Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircra ft airworthiness, is re quested to the extent required to allow Spurlock Land Surveying to determine that the MicroKopter UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Mainte nance Log, and MicroKopter Instruction Manual).

Page 8 of 23Spurlock Land Surveying seeks the requested re lief because the MicroKopter UA does not require an airworthiness certificat e in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Spurlock Land Surveying will ensure that the Mi croKopter UAS is in airworthy condition based upon its compliance with the operating docume nts (i.e., Monthly Maintenance Log, and MicroKopter Instruction Manual) prior to every fl ight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

4. Extent Of Relief Spurlock Land Surveying Seeks And Th e Reason Spurlock Land Surveying Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the MicroKopter UAS, which u tilize a barometric pressure sensor, GPS equipment, and a radio communications telemetr y data link to downlink altitude information from the UA to the PIC at the ground control st ation (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Spurlock Land Survey ing seeks the requested relief because the MicroKopter UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the pr oposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivale nt level of safety will be maintained since the MicroKopter UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

5. Extent Of Relief Spurlock Land Surveying Seeks And Th e Reason Spurlock Land Surveying Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requ irements for flight in VFR conditions, is requested to the extent required to allow flight s of the battery powered MicroKopter UA during daylight hours in visual meteorol ogical conditions (VMC), under vi sual flight rules (VFR), for a total duration of 16 minutes to th e first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 minutes. Spurlock Land Surveying seeks the requested relief because without an exemption from Section 91.151(b ), the flight time duration of the battery powered MicroKopter UA will severely constrain th e practicality of any aerial mapping or still photo flight operations that Spurlock Land Su rveying proposes to c onduct pursuant to this Petition. Significantly, as set forth below, the t echnical specifications of the MicroKopter UAS, the MicroKopter operating documents, and S purlock Land Surveying’s proposed operating limitations, ensure that Spurlock Land Surv eying will safely operate the battery powered MicroKopter UA during daylight hours in vi sual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 16 minutes to the first point of intended landi ng and, assuming normal cruising speed, to fly after that for at least 4 minutes.

Page 9 of 236. Extent Of Relief Spurlock Land Surveying Seeks And Th e Reason Spurlock Land Surveying Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), And 91.417(a) & (b).

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, S purlock Land Surveying requests relief from these Sections because the MicroKopter UAS does not re quire an airworthiness certificate. As set forth more fully below, the MicroKopter UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Spurlock Land Surveying will use trained technicians to perform maintenance, al terations, or preventive maintenance on the UAS using the methods, techniques, and practices pr escribed in the UAS ope rating documents (i.e., Monthly Maintenance Log, and MicroKopter In struction Manual). Furthermore, Spurlock Land Surveying will document and maintain all maintenance records for the MicroKopter UAS.

D. The Reasons Why Granting Spurlock Land Surveying’s Request Would Be In The Public Interest; or How It Would Benefit The Public As A Whole.

Granting the present petition will further th e public interest by allowing Spurlock Land Surveying to safely, efficiently, and econo mically perform aerial mapping, photography and inspections of prairie, wilderness, real estate, construction areas and landscapes over certain areas of the United States. Furthermore, it will benefit the public as a whole by increasing awareness of UASs and uses fo r increasing productivity. Additiona lly, use of th e MicroKopter UAS will decrease congestion of the NAS, and reduce pollution. Notably, the benefits of Spurlock Land Surveying’s proposed operation of the MicroKopter UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From De creased Congestion Of The NAS.

MicroKopter UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing the amount of manned aircraft needed to pe rform aerial acquisitions, an exemption allowing the use of a MicroKopter UAS would reduce the amount of manne d aircraft in the NA S, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing ai rcraft will be reduced. MicroKopter UAs do not require an airport to takeoff or land. Like wise, a reduction of manned aircraft conducting aerial mapping, photography and inspection missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arri val, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The MicroKopter UAS.

Conducting aerial acquisitions with the MicroK opter UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial mapping and still phot ography flight operations. By using battery power and electric motors, the MicroKopter UAS produces no air pollution, and is the most viable environmentally conscious alternative to th e internal combustion engi ne aircraft that are

Page 10 of 23typically utilized for aerial ma pping and photography. The Micr oKopter UA, while reducing the carbon footprint of aerial acquisitions, also el iminates noise pollution, as the UAs are propelled by battery powered electric moto rs, rather than an internal combustion engine. By using the MicroKopter 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 complete ly eliminated. Aside from the lack of flight crew members located onboard the aircraft, the MicroKopter UA (weighing approximately 4.6 pounds respectively, at its maximu m gross weight with a length of 31 inches and width of 31 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft.

3. Performing Aerial mapping and Photography Operations With The MicroKopter UAS Will Benefit The Economy.

In addition to being safe and efficient, the Micr oKopter UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As su ch, operation of the MicroKopter UAS will allow United States base d companies, like Spurlock Land Surveying, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owne d and operated companies must adopt new and alternative technology in order to remain co mpetitive. Operating the battery powered MicroKopter UAS is one such technology that no t only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned ai rcraft. By operating the MicroKopter UAS, companies such Spurlock Land Surveying, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Impr oved financial performance of U.S. companies, through commercial use of the Mi croKopter UAS, provides a stab le workforce that increases consumer spending; improves loca l, state, and federal tax reve nues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. Additionally, by allowing operation of th e MicroKopter , Spurlock Land Surveying will be able to more easily work with local and state agencies to showcase the usefulness and wildness of a very tourism based economy, ther efor improving the economy of both state and local businesses.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Spurlock Land Surveying’s proposed operation of the MicroKopter UAS will not implicate any privacy issues. Specifically, the MicroKopter UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and MicroKopter Instruction Manual), which requires property owner involvement as we ll as local law enforcement notification, and in accordance with the Federal Aviation Re gulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 16

Page 11 of 23E. The Reasons Why Granting The Exemption Wo uld Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Le ast Equal To That Provided By The Rule From Which Spurlock Land Surve ying Seeks Exemption.

1. Reasons Why The MicroKopter UA Meets Th e Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unm anned aircraft and its operation, Spurlock Land Surveying's operation of the MicroKopter UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate inaccordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS w ill create a hazard to users of the NAS or the public, or otherwise pose a threat to na tional security. Specifically, FMRA Section 333 states the following, in part:

(i) In General Notwithstanding any other require ment of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transpor tation shall determine if certain unmanned aircraft systems may operate sa fely in the national airspace system before completion of the plan and rulemaking requir ed by section 332 of this Act or the guidance required by section 334 of this Act.

(ii) Assessment of Unmanned Aircraft Systems. – In making the determination under subsection (a), the Secretary shall determine, at a minimum –

1. which types of unmanned aircraft systems, if any, as a resultof their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

2. whether a certificate of waiver, certificate of auth orization, or airworth iness certification under section 44704 of title 49, Un ited States Code, is required for the operation of unmanned aircraft systems id entified under paragraph (1).

(iii) Requirements for Safe Operation, – If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the sa fe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Spur lock Land Surveying submits that the MicroKopter UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the MicroKopter UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

Specifications Of The MicroKopter UAS Demonstrates Its Safe Characteristics.

Page 12 of 232. The MicroKopter UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national securi ty considering its size, weight, speed, and operati onal capability.

(i) Technical Specifications Of The MicroKopter UAS. The technical specifications of the MicroKopter UAS are set forth by the Micr oKopter Specifications and Data Sheet.

(ii) The MicroKopter UAS Autonomous Flig ht And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. Th e MicroKopter UAS may be operated in both manual and fully autonomous flight modes. A complete de scription of the flight and navigational modes of the MicroKopter UA S is provided herewith as “Exhibit A”.

(iii) The MicroKopter UAS Is Designed For Auto matic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navi gation. When the Control Link is lost, the MicroKopter UA will remain sta tionary, in flight, for 3 seconds or more. If, after 3 seconds, the MicroKopter UA does not reacquire control link da ta from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home pos ition (i.e., failsafe mode) via GPS, and will descend to the takeoff positi on and shutdown. A complete description of the Failsafe Functions of the MicroKopter UA S attached herewith as “Exhibit A”.

(iv) The MicroKopter GCS And Its Operation. A complete description of the operation and specifications of the MicroKopter GCS and fli ght control software is provided at pages 4 through 60 of the MicroKopter User Manual. Micr oKopter User Manual is attached hereto as “Exhibit B”.

b. Flight Operations Of the MicroKopter UAS is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Spurlock Land Surveying will only utilize certificat ed pilots to act as a pilot in command (PIC) of the MicroKopter UAS. Additionally, a safety obs erver will assist all pilots during flight time.

c. Flights Of The MicroKopter UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Spur lock Land Surveying proposes to commercially operate the MicroKopter UAS for the special purpose of conducting aerial mapping and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemp tion will be limited to the following aircraft described in the operating documents, rotorc raft UASs weighing less than 55 pounds maximum gross weight: MicroKopter Unmanned AircraftSystems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial mapping, photography and inspection.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

Page 13 of 234. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the ope rating documents unless a special request is made and approved by ATC. All altitudes re ported to ATC must be in feet AGL.

5. The UAs 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 vi sion unaided by any device other than corrective lenses, as specified on the PIC’s FAA- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always mainta ins VLOS capability. The SO and PIC must be able to communicate verbally at all times. El ectronic messaging or texting is not permitted during flight operations. The PIC must be designa ted before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties be yond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles /obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exem ption must be accessibl e during UAS operations and made available to the Admin istrator upon request. If a di screpancy exists between the conditions and limitations contained in the gran t 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. Otherwise, the operator must follow the procedures as outlined in its operating documents . The operator may update or re vise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revi sion would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if ques tions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the sa fe 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 sa fe flight. The Ground Control Station must be included in the preflight in spection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or altera tions that affect the UAS operation or flight characteristics, e.g. replacement of a flight crit ical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

Page 14 of 2312. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the rele vant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/com ponent, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, in spections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the airc raft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must co mply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in th e aircraft record of the corrective action taken against discrepancies discov ered between inspections.

17. The PIC must meet possess at least a current medical certificate.

18. The operator may not permit any PIC to op erate unless the PIC meets the operator’s qualification criteria and demonstrates the ab ility to safely operate the UAS in a manner consistent with how the UAS wi ll be operated under the exem ption, including evasive and emergency maneuvers and maintaining appropria te distances from persons, vessels, vehicles and structures. PIC qualification flight hours mu st be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, trai ning operations may only be conducted during dedicated training sessions. Duri ng training, proficiency, and expe rience-building flights, all persons not essential for flight operations are considered non-participants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 20 operations must be conducted under visual meteorol ogical conditions (VMC ). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual f light rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical mile s of an airport reference point as denoted on a current FAA-published aeronautical chart 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 ag reement with the airport management must be made available to the Administrator upon request.

21. 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 th an 3 statute miles from the PIC. 2

Page 15 of 2322. If the UA loses communications or loses its GP S signal, it must return to a pre-determined location within the planned ope rating area and land or be rec overed in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flightunless (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 25% battery power remaining.

25. The operator must obtain an Air Traffic Organi zation (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any ope rations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours pr ior to the operation. All operations shall be conducted in accordance with airspace requireme nts in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must 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 must be as large as practicable.

27. Before conducting operations, the radio frequenc y spectrum used for operation and control of the UA must comply with the Federal Communi cations Commission (FCC ) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Ad ministrator or any law enforcement official upon request. 21

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or esse ntial persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that suff iciently protect nonparticip ating 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 situ ation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

Page 16 of 23b. The aircraft is operated near vessels, vehicles or structures where th e owner/controller of such vessels, vehicles or stru ctures has granted permission a nd 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;

c. Operations nearer to the PIC, SO, operator trainees or essential pe rsons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conduc ted over private or controlled-a ccess property with permission from the land owner/controller or authoriz ed representative. Permission from land owner/controller or authorized representative w ill be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transg resses the lateral or vertical boundaries of the operational area as defined by the applicab le COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Ac cidents must be reported to the National Transportation Safety Board (NTSB) per inst ructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 21 Subpart H Would Not Adversely Affect Safety.

Spurlock Land Surveying submits that the equiva lent level of safety established by Section 61.113(a) and (b) will be maintained becaus e the UAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area.

Unlike other civil aircraft, the proposed operat ions in this petition for exemption will be controlled and monitored by the operator, pursuant to the Manual's requirements. These safety enhancements, which already apply to civil ai rcraft operated in connection with existing inspection operations, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same cr iteria demonstrates thatthere is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

3. Reasons Why An Exemption From The Re quirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Spurlock Land Surveying submits that the equiva lent level of safety established by Section 61.113(a) and (b) will be maintained beca use no PIC will be allowed to operate the MicroKopter UAS unless that PIC has demons trated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the MicroK opter UAS in a manner consistent with the exemption, including evas ive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Page 17 of 23Considering Spurlock Land Surveying’s propo sed area of operations, and the operating limitations set forth-above; the parallel natu re of private pilot aeronautical knowledge requirements to those of comm ercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the MicroKopter UAS, Spurlock Land Surveying submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills ne cessary for Spurlock Land Surveying’s specific proposed flight operations. The FAA has previous ly granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Spurlock Land Surveying will not allow any PIC to operate the MicroKopter UAS unless that PIC has demonstrated, by meeting minimum flight -hour requirements or the MicroKopter UAS training and currency requirements, that the PIC is able to safely operate the MicroKopter UAS in a manner consistent with this exemption, including evasive and 23 emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS ro torcraft 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 requirement s, the PIC must accomplish 3 takeoffs and landings in the preceding 90 da ys (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Spurlock Land Surveying’ s proposed operations. The Administrator has held that prior documented flight experience that was obtaine d in compliance with applicable regulations would ensure safe operatio ns, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations ), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimu m hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requir ements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight expe rience that was obtained in compliance with applicable regulations would satisfy this requi rement. Training, proficiency, and experiencebuilding flights can also be condu cted under the grant of exemption to accomp lish the required flight time. During training, proficiency, and expe rience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Page 18 of 23Exemption No. 11138 at page 15. Accordingly, Spurlock Land Surveying will ensure safe operations by not allowing any PIC to operate the MicroKopter UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the MicroKopter UAS in a ma nner consistent with the exemption, including evasive and emergency maneuvers and maintaini ng appropriate distances from people, vessels, vehicles and structures.

4. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 24 Not Adversely Affect Safety.

The equivalent level of safety established by Se ction 91.7(a) will be maintained because prior to every flight, Spurlock Land Surveying will ensure that the MicroKopter UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety:

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the MicroKopter UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, wh ich downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Spurlock Land Surveying’s operation of the MicroK opter UA within visual line of sight, at or below 500 feet AGL, will ensure a level of sa fety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously granted relief from Se ction 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety:

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the MicroKopter UAS; (2) the limitations on the proposed fli ght operations; and (3) the location of the proposed flight operations. Accordingly, Spurlock Land Surveying will ensure that it will safely operate the battery powered MicroKopter UA during da ylight hours in VFR conditions, with enough battery power to fly for a total duration of 16 minutes to the firs t point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the MicroKopter UAS; the limitations on the proposed flight operations; and the location of the proposed operati ons, will ensure an equivalent level of safety established by 14 C. F.R. Section 91.151(b). Furthermore, safety will

Page 19 of 23be ensured as the MicroKopter UAS provides a udible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery le vel, the MicroKopter UAS will descend and land automatically. Significantly, previous exempt ions granted by the FAA concerning Section 91.151 establish that safety is no t adversely affected when the technical characteristics and operating limitations of the UAS ar e considered. Relief has been granted for manned aircraft to operate at less than the minimums prescr ibed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previ ously granted relief from Section 91.151 specific to UAS, in circumstances similar, in al l material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. Reasons Why An Exemption From The Requirements Of Sections91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b ) Would Not Adversely Affect Safety:

In seeking this exemption, Spurlo ck Land Surveying 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), a nd 91.417(a) & (b) will be met because Spurlock Land Surveying will use trained technici ans to perform maintenance, alterations, or preventive maintenance on the UAS using the met hods, techniques, and pract ices prescribed in the operating documents (i.e. Operations Manua l, Monthly Maintenance Log, and MicroKopter Instruction Manual). Furthermore, Spurlock Land Surveying will document and maintain all maintenance records for the MicroKopter UAS.

Since the MicroKopter UAS wi ll be inspected as prescribed by the operating documents, Spurlock Land Surveying will maintain the equiva lent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of th e MicroKopter User Manual is attached hereto as Exhibit A and B; a copy of the Mi croKopter UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not advers ely affect safety because Spurlock Land Surveying will use trained technicians to pe rform maintenance, alterations or preventive maintenance on the UAS using the methods, t echniques, and practices prescribed by the operating documents.

Furthermore, the exempti on sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because al l maintenance of the MicroKopter UAS will be performed by trained te chnicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Previous exemptions 26 granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteris tics and operating limitations of the UAS are considered. In c onsideration of Spurlock LandSurveying proposed operating limitations, the operating documents, and the technical aspects of the MicroKopter UAS, Spurlock Land Surveying submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405( a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances

Page 20 of 23similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

8. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA M odernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , Spurlock Land Surveying requests that the FAA prescribe special conditions for the intend ed operation of the MicroKopter UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Pa rt 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe opera tion of the UAs for the limited purpose of conducting aerial mapping, photography and inspections over certain areas of the United States for compensation or hire. FMRA Section 333 se ts forth the requirements for considering whether a UAS will create a hazard to users of th e NAS or the public, or otherwise pose a threat to national security; and further, provides th e authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the MicroKopter UAS, since the airworthiness regulat ions of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Sp ecial Conditions, stat es the following:

If the FAA finds that the airworth iness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds nece ssary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Spurlock Land Surveying intended operation of the MicroKopter UAS, which contain such safety st andards that the Admini strator finds necessary to establish a level of safety equivalent to th at established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Page 21 of 23F. A Summary That Can Be Published In The Fe deral Register, stating the Rules From Which Spurlock Land Surveying Seeks Exemption:

Spurlock Land Surveying seeks exemption fromthe requirements of 14 C.F.R Sections 21 Subpart H, 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemptions Spurlock La nd Surveying Seeks:

This exemption will permit Spurlock Land Surv eying to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial mapping, photography and inspections over certain ar eas of the United States.

Any Additional Information, Views, Or Argu ments Available To Support Spurlock Land Surveying Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Tran sportation to determine if certain UAS may operate safely in the NAS. As such, Spurlock Land Surveying’s request for exemption may be granted pursuant to the authority of FMRA Se ction 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requi rements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pos e a threat to national security; and further, provides the authority for such UAS to operate without ai rworthiness certification. As discussed in detail above, Spurlock Land Surveying will operate the MicroKopter UAS safely in the NAS, without crea ting a hazard to users of the NAS , or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Spurlock Land Surveying se eks 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 MicroKopter UAS commercially, without an airworthiness certificate, for the limited purpose of conduc ting aerial mapping and photography over certain areas of the United States. By granting this Pet ition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Moderniz ation and Reform Act of 2012, while also advancing the interests of the public, by al lowing Spurlock Land Surveying to safely, efficiently, and economically operate the Mi croKopter UAS commercially within the NAS.

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Spurlock Land Surveying respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 21 Subpart H, 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405( a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Spurlock Land Surveying to operate the MicroKopter UAS commercially for the purpose of conducting ae rial mapping, photography and inspections over certain areas of the United States.

Page 22 of 23Spurlock Land Surveying only utilizes safe and reliable MicroKopter UA Ss an industry leader in small UAS production. MicroKopter UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a pr edetermined and set distance. Inaddition, MicroKopter software provides real-time altitude and location inform ation to the PIC via the linked monitor (smart phone, notebook and/or tablet devices)

Dated: May 28, 2015

Respectfully,

David Spurlock Spurlock Land Surveying 868 Cliff Street, Lander, WY 82520

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