Sanborn Map Company’s Petition for Exemption

For Purposes of Operating Small Unmanned Aircraft System

FAA Rules Docket: ____________

Name and Address of Petitioner

Sanborn Map Company, Inc.

1935 Jamboree Drive, Suite 100

Colorado Springs, CO 80920

Counsel for Petitioner

Thomas L. Gemmell

HUSCH BLACKWELL LLP

120 South Riverside Plaza, 22nd Floor

Chicago, Illinois 60606

(312) 526-1523

tom.gemmell@huschblackwell.com

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A. Summary

The Sanborn Map Company, Inc. seeks exemption from the requirements of 14 C.F.R. §§ 

45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b). This exemption will permit Sanborn

to operate a small unmanned aircraft system (UAS) at or below 400’ above ground level from a 

ground control station by a pilot in command having at least a recreational or sport pilot 

certificate and a valid U.S. driver’s license. Furthermore, the exemption will relieve Sanborn 

from the requirement to have a certificate of airworthiness issued for its UAS. This exemption 

will also permit Sanborn to operate the UAS with at least a five-minute power reserve and to 

display any required markings as large as practicable on the aircraft’s surface.

The FAA has previously granted Sanborn’s petition for exemption relating to its Avenger 

UAS in circumstances similar, in all material respects, to those presented herein. See 

Exemption No. 11578.

B. Introduction

The Sanborn Map Company, Inc. (hereinafter referred to as “Sanborn”) is a 148 year-old

design, geospatial and infrastructure management firm with a long and well-recognized history in

mapping and surveying. Sanborn excels in the collection of aerial imagery from manned, fixedwing aircraft for the purpose of making highly accurate aerial maps for a range of clients and

various applications. In addition to operating a fleet of conventional fixed-wing aircraft, Sanborn

has recently acquired a Leptron RDASS4 Unmanned Aircraft System (hereinafter referred to as

the “Leptron RDASS4”). As set forth in this Petition, Sanborn seeks to operate its Leptron 

RDASS4 for the special purpose of aerial surveying, continuing an established legacy that has

always sought the highest standards of operations and safety.

Pursuant to 14 C.F.R. § 11.81 (Petition for Exemptions.), Sanborn provides the following

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information in support of its petition:

C. Background

1. LEPTRON RDASS4

Sanborn seeks an exemption to operate a Leptron RDASS4 for compensation or hire

within the national airspace system (“NAS”)1

. The Leptron RDASS4 is comprised of an

airborne unmanned aircraft and a transportable ground control station. The Leptron RDASS has

a maximum gross weight of approximately 7 pounds, while having a wingspan of 22 inches and

a length of 15 inches (propeller shaft –to propeller shaft). The Leptron RDASS unmanned

aircraft is equipped with four (4) rotors connected to four (4) 2808-38 22V motors driven by a 

Lithium-ion Polymer battery.

Figure 1 depicts the Leptron RDASS4 with registration number displayed in

accordance with 14 C.F.R. Part 45.

1 Sanborn has reserved registration number N516LP, and will submit an Aircraft Registration 

Application upon the grant of the exemptions sought by this petition.

N516LP

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2. Proven Operational History of the Leptron RDASS4 in the NAS. 

The Leptron RDASS4 is currently operating safely within the NAS pursuant to 

approximately fourteen (14) Certificates of Authorization (“COA”) granted by the Federal 

Aviation Administration (“FAA”) to the Middle Tennessee State University; Sinclair Community

College in Dayton, Ohio; the U.S. Army Corps of Engineers (Jacksonville District, for operations

in South Florida); Mississippi State University for the Pearl River Basin; and the University of 

Florida.

D. Basis for Petition

Sanborn, by and through undersigned counsel, pursuant to Federal Aviation Regulations

(FAR) (14 C.F.R. § 11.61)

2 and the FAA Modernization and Reform Act of 2012 (“FMRA”), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems (“Section 333”), hereby

respectfully petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§, 

45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151 (b), 91.405(a), 

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

1. Section 333 

Congress identifies Section 333 as a pathway for “expedited operational authorization” of 

certain unmanned aircraft systems (“UAS”) in the national airspace system (NAS). Section 

332(b)(1) (“expedited operational authorization.”).

3

 Under Section 333 Congress mandates that 

the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of this 

Act or the guidance required by section 334 of this Act” (Section 333(a)) upon consideration of

2 14 C.F.R. § 11.61(b) (“Using a petition for exemption, you may ask FAA to grant you relief 

from current regulations in 14 C.F.R.”)

3 See also www.faa.gov/uas/legislative_programs/section_333/ (noting that Section 333 grants 

the FAA “the statutory flexibility to expedite requirements for the safe operation of certain 

aircraft systems in the NAS.”).

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its “size, weight, speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight.” Section 333(b)(1). If the FAA makes such a determination, 

the FAA “shall [also] establish requirements for the safe operation.” Section 333(c). The FAA 

further may find that the UAS does not require “airworthiness certification under section 44704 of 

title 49, United States Code.” Section 333(b)(2).

2. 49 U.S.C. § 44701

The FAA is further authorized to grant exemptions from its safety regulations and 

minimum standards under 49 U.S.C. § 44701 (“Section 44701”) “if the Administrator finds 

the exemption is in the public interest.” Section 44701(f) (authorizing the grant of 

exemptions from safety regulations and minimum standards under section 44701(a) and (b) and 

sections 44702-44716).4

For the reasons addressed herein, this Petition qualifies for expedited approval of 

Sanborn’s request for exemption under both Sections 333 and 44701.

E. The Leptron RDASS4 UAS Meets the Statutory Criteria for Exemption under

Section 333

Given its small size, light weight, slow speed, limited load capacity, superior 

operational capabilities, and that the operations will be conducted only during the day, under 

visual meteorological conditions (“VMC”), within visual line of sight (“VLOS”) of the Pilot In 

Command (“PIC”) with the assistance of a visual safety observer (“VO”) and not in the proximity 

of airports or populated areas, the Leptron RDASS4 UAS is the very sort of UAS that qualifies 

for expedited approval under Section 333.

1. Section 333(b)(1) Criteria

4 See e.g. 49 USC §44711(a) ((1) prohibiting operations without airworthiness certificate; (2) 

prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations 

in violation of regulations); 49 USC §44704 (issuance of airworthiness certificate); 14 C.F.R.

§91.203 (a)(1) (carry airworthiness certificate)).

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a. Size

The Leptron RDASS measures approximately 22 inches in rotor span and 15 inches in 

length (from prop shaft to prop shaft).

b. Weight

The Leptron RDASS has a maximum gross weight of 7 lbs.

c. Speed

The Leptron RDASS4 has a maximum autopilot limited speed of approximately 12 

Meters per second (m/s). However, Sanborn typically operates the aircraft at below 10 m/s.

d. Operational Capability

The Leptron RDASS4 was specially designed for high or low altitude surveillance, 

photography, and sensor management. Supported by electric batteries that are rechargeable, the 

Leptron RDASS can fly from 20 – 60 minutes (*depending upon atmospheric conditions) and 

carry a variety of cameras or sensors. Other Operational metrics of the Leptron RDASS4 are as 

follows:

Unmanned Aircraft System The Leptron RDASS4 is an UAS that is comprised of an

unmanned aircraft and a transportable ground control station.

Serial No. LEP516

UA Dimensions Rotor Diameter: 22 in. 

Length: 381 mm – 15 inches (propeller shaft to propeller shaft)

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Engine (Propulsive Unit) Engine (Propulsive Unit)

The aircraft uses four (4) electric 2808-38 22V motors

Electric-powered propulsion systems.

a. Type of Motor – four (4) 2808-38 electric motors. Current 

draw range – Total system current draw cruise = 30 Nominal 

Load = .32 Ma per Minute

b. Max Load: =.41 Ma per Minute

Make: LEPTRON-RDASS

Model: 1000

Propeller and Propeller Limits FAA Propeller Type Certificate: None

Propeller Type: four (4) x 1-blade, non-hinged, reinforced 

plastic-ABS and Glass, fixed pitch, tractor

Diameter (Nominal): (4) individual blades x 11 in.

Battery Command & Control Thunder Power Air Vehicle Battery P/N Leptron 6S powers the

motor, and battery command and control.

Airspeed Limits Vne (Never Exceed Speed) 12 m/s)

Vno (Maximum Structural Cruising Speed) 48 knots (25 m/s) Va 

(Maneuvering Speed) 12 knots (25 m/s)

Landing Speed: VTOL – Vertical 1.5 m/s 

Empty Weight C.G. Range 1 inches for or aft of datum

Datum Center of main air frame

Maximum Weight 7 lbs.

Empty Weight 1.5 Kg – 3.3 lbs.

NOTE: Empty Weight excludes weight of battery and payload 

modules.

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Frequencies 2.4 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on the 900Mhz band. If 

video is utilized, uplink, downlink, and video are all on 2.4 GHz.

Computer Software Avionics embedded processor – DJI A2 Autopilot, Compass and 

GPS 

Max. Operating Altitude 1,000 ft. AGL (304 M)

Control Surface Movements Four (4) Fixed pitch rotor blades. Variable speed motors and speed 

controllers

Nominal Endurance 30 minutes above 32 °F (0 °C)

15 minutes below 32 °F (0 °C)

Ambient Outside Air Temp Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: 0 °F 

Wind Limitation 40 MPH

Maintenance This Leptron RDASS must be maintained in accordance with the 

Leptron Maintenance Operation Manual, or later FAA accepted 

revision.

e. Proximity of Airports/Populated Areas

Flight operations pursuant to this Petition will be tightly controlled and restricted to

Class G airspace, which is defined as earth surface up to 1,200 feet above ground level and earth 

surface to the base of controlled airspace (Class B, C, D, and E), and not in the proximity of 

airports or populated areas. The Leptron RDASS4 will not be operated within 5 nautical miles 

of the geographic center of a non-towered airport unless a letter of agreement with that airport’s 

management is obtained, such letter to be made available to the Administrator upon request, and 

the operation is conducted in accordance with a NOTAM as required by the operator’s COA. 

Operations will avoid congested or densely populated areas and comply with 14 C.F.R. 91.119.

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f. Visual Line-of-Sight

The Leptron RDASS4 will at all times be flown by Sanborn only in the daytime (not at 

night) under VMC within VLOS of the PIC (typically within a range less than 500 feet) with the 

further assistance of a VO with whom the PIC will have the ability for direct and continuous

verbal communications

5 so as to ensure that the flight operations remain within the PIC’s VLOS 

and prescribed flight boundaries and deconflict with objects in the air and on the ground. Thus, 

pursuant to the FAA’s Interim Operational Approval Guidelines for UAS the proposed 

operations provide an approved method of control and collision avoidance to satisfy the “see and 

avoid” requirement of 14 C.F.R. § 91.113:

While considerable work is ongoing to develop a certifiable “detect, sense, and avoid”

system, no current solution exists. Compliance with the “see and avoid” aspect of 14 

C.F.R. 91.113, Right-of-Way Rules: Except Water Operations, becomes one of the 

primary issues in UAS operational approvals. As a result, alternate methods of 

compliance are required to accomplish the “see and avoid” function. See and avoid risk 

mitigation strategies are normally based on the use of visual observers or other methods 

of segregation.

Interim Operational Approval Guidance 08-01, Unmanned Aircraft Systems Operations in the 

U.S. National Airspace System (March 13, 2008) at 8. Only qualified and current PIC’s and

VOs, as provided in the FOD (as defined below), will be used.

2. Other Factors

a. Leptron RDASS4 Safety Systems 

The Leptron RDASS4 UAS is replete with mechanisms to ensure safe operations and 

protect persons and property on the ground. In addition to having experienced operator/PIC and 

VO, the Leptron RDASS4 UAS has a variety of inherent safety systems, including:

• Redundant Communications: The RDASS has (2) simultaneous 

5 VO will at all times be in proximity of PIC so as to allow direct verbal communications. In 

addition, the PIC and VO will maintain direct communications through cell or push-to-talk 

communications capability throughout the duration of flight.

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communications links that allow for backup and safe operations. This 

includes a 2.4 GHz wireless hand held radio and a 2.4 GHz laptop 

ground control station link. Both links must be terminated to execute a 

‘Lost Communication’ return home logic

• Flight Plan Altitude Settings: The RDASS has the ability for the 

operators to set Maximum and Minimum flight altitudes for a specific 

flight ‘corridor’ for safe operations. 

• Flight Logic: The RDASS has the ability for the operators to set safety 

return logic including: Exceeding a pre-set flight timer, Loss of GPS, 

Loss of Communications, Max and Min Altitude, and Low Voltage. 

• Ground Control Station Warnings: The RDASS GCS has many visual 

operator cues for error conditions such as low RSSI strength, low 

battery, low RPM, low system parameters, and many other real time 

conditions. The system also offers color coded ‘Dashboard’ lights for 

the operator. 

• Double Entry – The RDASS GCS has double entry response window for 

all in-flight parameter changes. This allows the user to not send 

incorrect information without a two verification mouse clicks. 

b. Flight Operations Documents

To ensure consistent safety operations, Sanborn has developed a comprehensive and

detailed set of flight operations documents (FOD) for the Leptron RDASS4 UAS based on 

Sanborn’s extensive use and experience, procedures and notices provided by the UAS 

manufacturer, and guidance the FAA has provided to obtain exemption under Section 333. The 

FOD is comprised of the Sanborn Standard Operating Procedures, the Leptron RDASS Operators 

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Manual, and the Leptron Inspection and Maintenance Manual. See Exhibit A (submitted on a 

confidential basis).

In seeking this exemption, Sanborn proposes to operate the Leptron RDASS4 pursuant to

the following specific operating limitations, as also addressed in the FOD:

1. The UA will not be flown at an indicated airspeed exceeding 87 knots. In no case will 

the UA be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer. 

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

(AGL). Altitude will be reported in feet AGL.

3. The UA will be operated within visual line of sight (VLOS) of the pilot in command (PIC)

at all times (unaided by a device other than corrective lenses).

4. All operations will use a visual observer (VO). The UA will be operated within the 

VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC will 

be able to communicate verbally at all times (electronic messaging or texting will not be 

used 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 duties required of the VO. 

5. UAS operations will not be conducted at night, as defined in 14 CFR § 1.1. All 

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

under special visual flight rules (SVFR) will not be performed.

6. The PIC shall not begin a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation 

and to operate after that for at least five (5) minutes or with the reserve power 

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recommended by the manufacturer if greater.

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

a condition for safe flight. 

8. Prior to each flight the PIC will conduct a pre-flight inspection and determine the UAS is 

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

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

a condition that affects the safe operation of the UAS, the UA will not be operated until 

the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. 

9. The UA will be marked with an identification (N-Number) in accordance with 14 C.F.R.

§ 45.23, such markings to be as large as practicable pursuant to 14 C.F.R. § 45.29(f), and 

identified by a serial number registered in accordance with 14 C.F.R. Part 47.

10. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

11. The UA shall at all times remain clear and yield the right of way to all other manned 

operations and activities.

12. Any time the UA is operating, documents used by the operator to ensure the safe 

operation and flight of the UAS and any documents required under 14 C.F.R. § 91.9 and

§ 91.203 will be available to the PIC at the ground control station (GCS). Such 

documents will be made available to the Administrator or any law enforcement official 

upon request. 

13. The UAS shall not be operated by the PIC from any moving vehicle or device; however 

the UAS may be operated by the PIC from a stationary watercraft.

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

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permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

15. All flight operations will be conducted at least 500 feet from all nonparticipating person, 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator will 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations will be immediately terminated in a manner 

ensuring the safety of nonparticipating person; and

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

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

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

an undue hazard.

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

persons.

16. Any UAS that has undergone maintenance or alternations that affect its operation or 

flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting further operations. Functional test flights will 

only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight will be conducted in such a manner so as to not pose an 

undue hazard to persons or property. 

17. Upon loss of communication or GPS signal, the UA shall return to a pre-determined 

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location within the private or controlled-access property.

18. The PIC is required to abort the flight in the event of unpredicted obstacles or 

emergencies.

19. The PIC will possess either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC will also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot certificate.

20. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to 

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

the requested exemption, including evasive and emergency maneuvers and maintaining 

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

flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs will only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC will operate the UA with appropriate distance from nonparticipants in accordance 

with 14 CFR § 91.119. 

21. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

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

22. The UAS will comply with all manufacturer safety bulletins.

23. All operations will be conducted in accordance with an ATO-issued Certificate of Waiver 

or Authorization (COA). Operator shall follow the conditions and limitations for the 

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FAA’s “blanket” Certificate of Waiver or Authorization (COA) for flights at or below 

200 feet AGL. https://www.faa.gov/news/updates/?newsId=82245. For operations 

outside the blanket parameters, operator will obtain a separate COA specific to the 

proposed operation. 

24. The UA will not be operated within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s management 

is obtained or otherwise permitted by a COA issued to the exemption holder. The letter 

of agreement with the airport management will be made available to the Administrator or 

any law enforcement official upon request.

25. 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 within 24 hours. Accidents will also be reported to 

the National Transportation Safety Board (NTSB). Further flight operations shall not be 

conducted until the incident, accident or transgression is reviewed by UAS Integration 

Office and authorization to resume operations is provided.

26. The UAS shall be operated pursuant to the FOD, such materials to be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy 

exists between the FOD and the conditions and limitations directed by the Administrator

in granting the exemption, the conditions and limitation in the exemption take precedence 

and will be followed.

27. The UAS shall be maintained in accordance with the FOD including the Leptron 

Inspection & Maintenance Manual, including any amendments or updates thereto. All 

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amendments or updates shall be tracked and a record of such amendments or updates 

shall be maintained and made available to the Administrator upon request.

28. Record of the UAS maintenance, preventive maintenance, alternations, status of 

replacement/overhaul component parts, and the total time in service of the UAS shall be 

documented and maintained in accordance with the FOD.

c. Privacy 

Sanborn will comply with all federal, state, and/or local privacy regulations that may 

apply in the areas in which Sanborn will operate the UAS pursuant to this Petition. Further, 

Sanborn’s policy, as outlined in the FOD, is to avoid any operations that might invade 

personal privacy. 

d. Physical Security

In order to ensure its safe and proper use, Sanborn will be the only operator of the UAS 

and the UAS will at all times remain in Sanborn’s custody.

3. Sanborn’s History of Safe Operations Flying the Leptron RDASS4 UAS

Sanborn has amassed nearly 10,000 fixed-wing flight hours in the past four years of 

aerial surveying with only one accident and has conducted local test flights of the Leptron 

RDASS4 UAS by FAA certified pilots checking operations, flight deconfliction and safety 

procedures of over 50 hours.

4. Lack of Threat to the NAS, Public, or National Security 

Those reasons addressed, including meeting Section 333(b)(1) criteria, Sanborn’s

established record of safety, operations pursuant to the FOD, and the other factors discussed, 

demonstrate that the Leptron RDASS4 UAS will be operated safely in the NAS without creating

a hazard to other aircraft or persons or property on the ground or pose a threat to national 

security. 

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For all of these reasons, Sanborn’s proposed operations using the Leptron RDASS4 qualify 

for expedited approval of the sought exemption pursuant to Section 333 for the specified uses and 

under the proposed operating requirements and restrictions.

F. Sanborn’s Operations Pursuant to This Petition Qualify for Exemption Under 

Section 44701. 

Granting Sanborn’s request for exemption would benefit the public and have no 

adverse effect on safety. Accordingly, Sanborn’s operations pursuant to this Petition also 

qualify for an exemption from the FAA’s related safety regulations under Section 44701.

1. Public Interest Benefits

The public would greatly benefit from granting Sanborn’s petition for exemption so it 

can use the Leptron RDASS4. The Leptron RDASS4 is a battery powered UAS that serves as a

safe, efficient, and economical alternative to manned aircraft traditionally use for aerial surveying. 

No pilot or crew need be airborne, thereby providing for superior safety to persons and property 

in the air and on the ground than that provided by manned aircraft performing the same 

operations. Granting the exemption would also reduce the number of manned aircraft in the 

NAS and, as a result, reduce the environmental impact of such operations, as well as provide for 

better aerial imaging and production and, as a result, a more robust economy. Using the Leptron 

RDASS4 also provides the benefit of greater operational flexibility and reduced cost when 

compared to manned aircraft.

(a) Increased Aircrew Safety and Reduced Risk to Persons/Property On Ground

Because the Leptron RDASS4 is unmanned, the proposed operations eliminates the risk to 

pilot and crew associated with flying such aerial-surveying missions at low altitude, in confined 

airspace. Further, given its small size and weight and low airspeed, using the Leptron RDASS4 also 

reduces the risk of damage or injury to persons or property on the ground, and in the air, were there 

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to be a mishap. 

(b) Reduced Environmental Impact

Using the Leptron RDASS4 UAS instead of manned aircraft also benefits the public by 

eliminating or greatly reducing air and noise pollution associated with traditional aerial surveying

operations. Because it is battery powered (using rechargeable batteries) and uses electric motors,

the Leptron RDASS4 UAS consumes no fuel and generates no air pollution, and creates very little 

noise. As a result, the public is benefited as a result of reduced environmental impact, reduced 

operator and other human exposure, and greater fuel conservation, which serves additionally

to support our government’s specific efforts to reduce the U.S.’s carbon footprint.6

(c) Fewer Manned Aircraft In NAS and Reduced Need for ATC Handling

The Leptron RDASS4 also does not require a runway or helipad to takeoff or land and 

will not be operated within the proximity of any airports. As such, fewer aircraft will need to be

handled by air traffic control during ground, takeoff, departure, arrival, and landing phases. 

Operations pursuant to this Petition (unmanned, VLOS, below 400’ AGL, and not within 

proximity of airports) will further reduce the number of manned aircraft flying or transiting at or 

above 500’ AGL to and from the areas of surveying operations as well as congestion around

airports due to aircraft arrival and departure.

(d) Superior Aerial Imagery and Increased Benefit to U.S. Economy

Better aerial footage can also be obtained using the small and nimble Leptron RDASS4 than 

can be obtained using manned aircraft or other ground-based methods. Due to its small size and 

superior flight performance characteristics, the Leptron RDASS4 allows for images to be taken from 

certain locations and angles and with better precision than using manned aircraft. As a result, less 

6 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental

Protection Agency’s regulatory efforts to phase out the use of fossil fuels. 

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time is needed in the air to obtain the desired footage, which in addition to providing the benefit of 

fewer aircraft in the NAS and associated reduced risk to objects and persons and property in the air 

and on the ground, reduced noise, etc., allows for the production of surveys, which benefits

consumers. This additionally ensures that companies such as Sanborn and its customers remain 

competitive and profitable, thereby providing their employees greater job stability, which 

ultimately contributes further to the U.S. economy through increased consumer spending. 

(e) Increased Operational Flexibility and Reduced Cost

Using the Leptron RDASS4 also provides the benefit of greater operational flexibility and 

reduced cost when compared to manned aircraft. Instead of each time having to hire a manned 

aircraft at thousands of dollars/hour, subject to the pilot’s schedule and availability, Sanborn can 

operate the Leptron RDASS4, which it has purchased and outfitted at lower combined cost, 

innumerable times and at the convenience of Sanborn’s and its customers’ schedules.

2. No Adverse Safety Effects

Granting Sanborn’s Petition will also not adversely affect aviation safety or pose any 

undue risks to the public. The operations pursuant to this Petition will be in accordance with 

Sanborn’s FOD and in compliance with all applicable public safety requirements. Accordingly, 

and as detailed herein, granting the requested exemption would not adversely affect safety. 

Indeed, as detailed below, operations pursuant to the limitations and guidelines addressed herein 

and in the FOD will provide an equivalent or even higher level of to those regulations from 

which Sanborn seeks exemption. 

The FAA has previously granted Sanborn’s petition for exemption relating to its Avenger 

UAS in circumstances similar, in all material respects, to those presented herein. See 

Exemption No. 11578. See also Exemption Nos. 11062, 11109, 11112, 11213.

For all of these reasons, Sanborn’s operations pursuant to this Petition also qualify for an 

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exemption under Section 44701.

G. Exemptions Sought By Sanborn And Reasons For The Requested Relief

Pursuant to Section 333, Sanborn seeks an exemption from the requirements of 14 C.F.R.

§§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 

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

1. Section 45.27(a). Location of marks; nonfixed-wing aircraft.

Section 45.27, entitled Location of marks; nonfixed-wing aircraft, subsection (a) states 

(emphasis added):

(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

To the extent subsection 45.27(a) may be deemed to apply to the Leptron RDASS4 UAS, 

Sanborn seeks an exemption from the subsection (i.e., that the marks be displayed on both surfaces 

of the cabin, fuselage, boom, or tail) because the Leptron RDASS4 UA is of insufficient size to 

accommodate any such marking. Thus marking the Leptron RDASS4 UA as required by this 

subsection would not be possible.

An equivalent level of safety can be provided instead by marking the Leptron RDASS4 

UA, as may be applicable, with lettering as large as practicable (14 C.F.R. § 45.29(f)) on its 

largest available surface so as to permit such marking to be displayed to pilot, crew, and 

others both when the Leptron RDASS4 UA is on the ground and airborne. 

2. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in 

command.

Sanborn seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled

Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) state 

(emphasis added):

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(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command 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.

In general, subsections 61.113 (a) and (b) prohibit a private pilot from conducting 

commercial operations. Sanborn seeks exemption from the subsections because the UAS will

not carry a pilot, passengers or property (other than a camera). As addressed, the Leptron 

RDASS4 is a very light, remotely controlled UAS with no persons or property on board. The 

area of operations is generally remote or sparsely populated. Each flight is planned and fully 

coordinated in advance in accordance with those procedures provided in the FOD. Thus the risk

associated with the proposed operations is so diminished from that associated with commercial 

operations contemplated by Part 61, that allowing a PIC having, for example, a private pilot 

certificate, rather than a commercial certificate, the minimum flight hour and qualification 

criteria, and operating according to the limitations and guidelines provided herein, provides a 

level of safety that exceeds that provided by a pilot having a commercial certificate operating a 

conventional aircraft as required under the regulations. Further, the FAA now allows for 

commercial UAS operations under the sought exemption by those who hold a recreational or 

sport airman certificate. See https://www.faa.gov/news/updates/?newsId=82485. As addressed 

herein, the PIC pursuant to this Petition will possess at least a recreational or sport pilot 

certificate. The PIC will also hold a current FAA airman certificate or a valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. The PIC will also meet the flight review requirements specified in 14 CFR 

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

The FAA has previously granted Sanborn’s petition for exemption relating to its Avenger 

UAS in circumstances similar, in all material respects, to those presented herein. See 

Exemption No. 11578. See also Exemption Nos. 11062, 11109, 11112, 11213.

3. Section 91.7(a). Civil Aircraft Airworthiness.

Either finding that Sanborn meets the Section 333 criteria or exemption from the 

airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a) 

inapplicable. 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) states (emphasis added):

“No person may operate a civil aircraft unless it is in an airworthy condition.” There is no FAA 

standard by which such a determination of airworthiness can be made. Nonetheless, given the

limitations and procedures, as contained herein, and in the FOD, for maintaining the aircraft and 

checking it before each flight to ensure that it is in peak operational condition, an equivalent 

level of safety will be provided.

4. Section 91.105. Flight crewmembers at stations.

Sanborn seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight 

crewmembers at stations, states (emphasis added):

(a) During takeoff and landing, and while en route, each required flight crewmember 

shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological needs; 

and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during 

takeoff and landing, keep his or her shoulder harness fastened while at his or her 

assigned duty station. This paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

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(2) The crewmember would be unable to perform required duties with the shoulder 

harness fastened.

In general, Section 91.105 requires pilot and crew to be at their duty stations and 

harnessed during flight. Sanborn seeks exemption from the Section 91.105 because the Leptron 

RDASS4 UA is by definition an unmanned aircraft, having neither pilot nor crew so as to be 

stationed or harnessed as required by the regulation. An equivalent or even higher level of safety

can be provided instead by using an unmanned aircraft controlled by a PIC who at all times is 

located at and controls the UAS from the GCS. 

5. Section 91.119(c). Minimum safe altitudes.

Sanborn seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum 

safe altitudes: General, subsection (d) states (emphasis added):

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes:

***

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over other than 

congested areas. Sanborn seeks exemption from subsection 91.119(c) because, pursuant to this 

Petition, the Leptron RDASS4 UA will at times be operated below 400’ AGL.

An equivalent or even higher level of safety can be provided instead by, as provided 

herein, operating so as to deconflict with manned vehicles operating above 500’ AGL, within the 

VLOS of the PIC with the assistance of a VO so as to ensure the safety of and deconfliction with 

any persons or property in the air and on the ground, including participating and nonparticipating personnel, away from who the UA would generally be restricted as addressed 

herein. Further the Leptron RDASS4 UAS flight operations will be monitored at all times by

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both the PIC and VO and will be in compliance with local public safety requirements, so as to 

prevent access to the restricted areas of operation. 

The FAA has previously granted Sanborn’s petition for exemption relating to its Avenger 

UAS in circumstances similar, in all material respects, to those presented herein. See 

Exemption No. 11578. See also Exemption Nos. 11062, 11109, 11112, 11213.

6. Section 91.121(a)(1)(iii). Altimeter settings. 

Sanborn seeks an exemption from 14 C.F.R. 91.121(a)(1)(iii). Section 91.121, entitled

Altimeter settings, states in relevant part (emphasis added):

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

***

(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

Subsection 91.121(a)(1)(iii) requires persons operating an aircraft to maintain altitude by 

reference to an altimeter set “to the elevation of the departure airport or an appropriate altimeter 

setting available before departure.” Sanborn seeks exemption from subsection 91.121(a)(1)(iii) 

because the Leptron RDASS4 UA does not use or have on board a typical barometric altimeter 

as contemplated by the regulation. Instead, the Leptron RDASS4 UAS has a laser altimeter to 

maintain altitude. 

An equivalent level of safety will be provided instead by operating the UA below

400’ AGL within the VLOS of the PIC (with the assistance of a VO) with laser altimeter

information downlinked from the UA to the PIC to maintain altitude and ensure safety. Prior to 

each flight, a zero altitude/AGL will be established at the launch site, as confirmed for accuracy 

by the PIC. 

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7. Section 91.151(b). Fuel requirements for flight in VFR conditions.

Sanborn seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions, states (emphasis added):

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first 

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

least 20 minutes.

The Leptron RDASS4 is an unmanned aircraft, and thus would not begin a flight with a 

person in it as the regulation contemplates. To the extent the regulation applies to the Leptron 

RDASS4, an equivalent level of safety can be achieved instead by limiting the Leptron RDASS4 

flights so there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five (5) minutes or with the reserve power recommended by the 

manufacturer if greater. Given that the Leptron RDASS4 UA, has a maximum weight of 

approximately 7 pounds and will fly at approximately 12m/s, will be operated within the VLOS of 

the PIC, this restriction would provide more than enough battery reserve to accommodate a safe 

return to the landing zone from anywhere in the operating area with no adverse effect on the 

safety of persons and property in the air or on the ground. 

See also e.g. Exemption Nos. 2689, 5745, 10650 (granted exemption to manned aircraft to 

operate at less than the minimums prescribed in Section 91.151) and Exemption Nos. 8811, 

10808, 10673 (granted similar relief for UAS for day VFR conditions). 

8. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b). 

Maintenance inspections and recording.

Section 91.405(a), entitled Maintenance required, states:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter;

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Section 91.407(a)(1), entitled Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, states:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter;

Section 91.409 (a)(1) and (2), entitled Inspections, states:

(a) Except as provided in paragraph (c) of this section, no person may operate 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 authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any 

inspection required by this paragraph unless it is performed by a person authorized to 

perform annual inspections and is entered as an “annual” inspection in the required 

maintenance records.

Section 91.417(a) and (b), entitled Maintenance records, state:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the 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 acceptable to the Administrator) of the work 

performed; and

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

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service.

(2) Records containing the following information:

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(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 items installed on the aircraft which are required 

to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its appliances 

are maintained.

(v) The current status of applicable airworthiness 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 involves 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 installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this 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 registered 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.

In general, these regulations require that an airworthy certificated aircraft be inspected as

prescribed in 14 C.F.R. Part 91, Subpart E (Maintenance, Preventive Maintenance, and 

Alterations), any discrepancies be repaired and the aircraft be approved for return to service as

prescribed in Part 43 (Maintenance, Preventive Maintenance, Rebuilding, and Alterations) and 

that any work on the aircraft be recorded and such records maintained. 

Sanborn seeks an exemption because, as addressed, the Leptron RDASS4 UA will 

operate pursuant to this Petition without airworthiness certification. An equivalent level of

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safety can be provided instead by requiring, as provided herein, that inspections and maintenance

be accomplished according to the inspection, maintenance, and preflight sections of the FOD

including the Leptron Inspection & Maintenance Manual. As provided in the FOD, among 

other things, the UAS will be inspected prior to each flight to confirm that it is in good 

working order, any maintenance or repairs will be performed and logged, and, upon any work 

being performed on the UA, the UA will be checked and approved for flight by qualified Sanborn

personnel before being returned to service. No pilot or crew need be airborne flying a heavy, 

fuel-ladened aircraft, thereby providing for superior safety to persons and property in the air and 

on the ground. Further, all flights will be conducted during the day below 400’ AGL within the 

VLOS of the PIC with the assistance of a VO so as to ensure deconfliction with objects in the air 

and on the ground. Given the Leptron RDASS4 UA’s light weight, slow speed and low-altitude

operations there is little risk of any damage to persons or property in the air or on the ground should 

a maintenance issue present itself when airborne. Accordingly, any risk associated with using the 

Leptron RDASS4 UAS as proposed is significantly reduced when compared to that presented by 

using manned aircraft to conduct the same operations.

The FAA has previously granted Sanborn’s petition for exemption relating to its Avenger 

UAS in circumstances similar, in all material respects, to those presented herein. See 

Exemption No. 11578. See also Exemption Nos. 11062, 11109, 11112, 11213.

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

The Rules From Which Sanborn Seeks Exemption:

The Sanborn Map Company, Inc. seeks exemption from the requirements of 14 C.F.R. §§ 

45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b), 91.405(a), 

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

A Brief Description Of The Nature Of The Exemption Sanborn Seeks:

Approval of the above mentioned exemptions will allow Sanborn LLC to operate the Leptron 

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RDASS4 for compensation in the National Airspace System. In relation to Sanborn’s current 

aerial surveying and mapping operations, such exemptions will increase safety, reduce risk to 

person and property on the ground, decrease carbon emissions, reduce the need for Air Traffic 

Control handling, and provide better aerial surveying footage. The Leptron RDASS4 runs on 

rechargeable batteries and does not carry any persons on-board. Sanborn’s customers will also 

benefit from greater operational flexibility and lower costs as Sanborn can operate the Leptron 

RDASS4 at a lower cost than traditional manned aircraft doing the same job.

Specifically, Sanborn is seeking exemptions to allow:

(1) The Leptron RDASS4 to be marked with its registration number as large as 

practicable on its largest available surface;

(2) At least a recreational or sport pilot certificated airman with a valid U.S. driver’s 

license to operate the Leptron RDASS4 as the Pilot in Command;

(3) Operate the Leptron RDASS4 even though it has not been certified as airworthy;

(4) Allow the Pilot in Command to control the Leptron RDASS4 from the controls that 

are located at the ground control station;

(5) Operate the Leptron RDASS4 below 400’ AGL;

(6) Operate the Leptron RDASS4 with a laser altimeter instead of a barometric altimeter; 

(7) Conduct operations limited to the greater of the power needed to conduct the 

intended operation plus an additional five minutes or the reserve power recommended by the 

manufacturer; and

(8) Conduct inspections and maintenance in accordance with the Leptron Maintenance 

Operations Manual and Sanborn’s Flight Operations Documents.

I. Conclusion

Accordingly, as set forth above, Sanborn Map Company, Inc. seeks an exemption

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 

2012, to permit safe operation of the Leptron RDASS4 UAS commercially, without an

airworthiness certificate, for the special purpose of conducting aerial imaging operations. By

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

Section 333 of the FAA Modernization and Reform Act of 2012 to expedite approval of 

operations of certain UAS in the NAS, while also advancing the interests of the public.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Sanborn Map Company, Inc. respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

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C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii), 91.151(b),

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

Dated: June 18, 2015 Respectfully submitted,

Husch Blackwell LLP

/s/ Thomas L. Gemmell

Thomas L. Gemmell

HUSCH BLACKWELL LLP

120 South Riverside Plaza, 22nd Floor

Chicago, Illinois 60606

Tel: (312) 526-1523

Fax: (312) 655-1501

tom.gemmell@huschblackwell.com

Attorneys for Petitioner

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