Sanborn Map Company ’s Petition for Exemption For Purposes of Operating Small Unmanned Aircraft System

FAA Rules D ocket :

____________

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, 22 nd Floor Chicago, Illinois 60606 (312) 526

- 1523 tom.gemmell@huschblackwell.com

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- 3A. 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 u nmanned a ircraft s ystem (UAS) at or below 400’ above ground level from a ground control station by a pilot in command having at least a recreatio nal 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 is sued 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

. T he FAA has previously granted Sanborn’s petition for e x e m p t i on relating to its Avenger
UAS in circumstances similar, in all material respects, to those presented herein

. See Exemption No. 11578.
B. I ntroduction
The Sanborn Ma p 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, fixed

wing 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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- 3information in support of its petition:
C. B ackground
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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- 32. 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 33 3(a) ) upon consider ation 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.”). 4 CHI

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- 3its “ size, weight, speed, operat ional capability, proximity to airports and populated areas, and operation within visual line of sig ht

. ” Section 333(b) (1 ). I f the FAA makes such a determination,
the FAA “ shall [also] establish requirements for the safe operation

. ” Section 33 3(c)

. T he 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
T he 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 q ualifies 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
G iven 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 sig ht ( “ VLOS ” ) of the P ilot In
C ommand ( “ 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 US C §44711 ( a ) ((1) prohibiting operations without airworthiness certificate; (2) pr ohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in violation of regulations) ; 49 US C §44 7 04 (issuance of airworthiness certificate); 14 C.F.R. §91

. 203 ( a ) ( 1 ) (carry airworthiness certificate)). 5 CHI

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- 3a. 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
T he 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 va riety of cameras or sensors

. Other Operational metrics of the Leptron RDASS4 are as follows:
Unmanned A ircra f t Sys tem The Leptron RDASS4 is an UAS that is comprised of an unmanned aircraft and a transportable ground control station.
Serial No. LEP516
UA D ime ns i ons Rotor Diameter: 22 in. Length : 381 mm

– 15 inches (propeller shaft to propeller shaft)

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- 3Engine (Propulsive U nit ) 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 e lectric motor s. Current draw range

– Total s ystem current draw cruise = 30 Nominal Load = .32 Ma per M inute
b. Max Load : =.41 Ma per Minute
Make: LEPTRON

- RDASS
Model: 1000 Propeller a nd Propeller Limit s 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)
Land ing 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 e xcludes weight of battery and payload modules.

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- 3Frequencies 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, downl ink, and video are all on 2.4 GH z. 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
F light o pe r a t i ons pursuant to t h i s Petition w i l l be t i g h t l y con t r o ll ed 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 a irport’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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- 3f

. Visual Line

- of

- Sight
T he 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 wit hin 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 communication s 5 so as to ensure that the flight operations remain w i t h i n 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. C ompliance 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 observe rs 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 S afety Systems
T he 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. 9 CHI

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- 3communications 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 Communicati on’ 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 para meter 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 (FO D ) 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 10 CHI

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- 3Manual, and the Leptron Inspection and Maintenance Manual. S ee 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 4 00 f ee t 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 operate d 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
b e 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 (consid ering 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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- 3recommended by the manufacturer if greater.
7. The opera tor 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 insp ection 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 p erformed 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. P art 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 ti mes remain clear and yield the right of way to all other ma nned 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 devic e ; 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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- 3permission 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 operat ions 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 asses sment 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

on ly 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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- 3location within the private or controlled

- access property

. 18. The PIC is required to abort the f light in the event of unpredic ted obstacles or emergencies.
19. The PIC will possess either an airline transport, commercial, priv ate, 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 PI C will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate

. 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 maintain ing 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 onl y 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 fro m 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 manuf acturer safety bulletins.
23. All operations will be conducted in accordance with an ATO

- issued Certificate of Waiver or Authorization (C OA). Operator shall follow the conditions and limitations for the
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- 3FAA’s “blanket” Ce rtificate 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 denote d on the current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made ava ilable 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
Off ice 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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- 3amendments 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 us e , 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
T hose 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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- 3For 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 Peti tion 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 P ersons/ Property On G round
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, g iven its small size and weight and low air speed , 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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- 3to be a mishap

. (b) Reduced Environmental Impact
U sing the Leptron RDASS4 UAS instead of manned aircraft also benefit s the public by eliminating or greatly reducing air and noise pollution associated with traditional aerial surveying operations

. Because it is battery power ed (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 enviro nmental impact, r educed
operator and other human exposure , and greater fuel conservation, which serves additionally

to su pport our g overnment’s specific effort s 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 a ir t raffic c ontrol during ground, takeoff, departure, arrival, and landing phases. Operations pursuant to this Peti tion (unmanned, VLOS, below 4 00 ’ 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. E conomy
B etter 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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- 3time 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 benefit s

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. econom y 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 c o m p li ance w i t h all applicable pub li c s a f e t y r e q u i r e m en t s
. Accordingly, and as detailed herein, g ranting 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 a n equivalent or even higher level of to those regulations from
which Sanborn seeks exemption

. T he FAA has previously granted Sanborn ’s petition for e x e m p t i on 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, 11 213

. For all of these reasons, Sanborn ’s operations pursuant to this Petition also qualify for an
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- 3exemption under Section 44701

. G
. Exemption s 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 e q u i v a l ent l e v el of s a f e t y 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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- 3(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 com pensation 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, subs ec t i ons 61

. 113 ( a ) and ( b ) prohibit a p r i v a t e p il o t from conducting

co m m e r c i al ope r a t i on s . Sanborn seeks exemption from the subsections because t he UA S w i l l

not ca rr y a p il o t , passe n g e r s 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 f li g h t is p l anned and fully

coo r d i na t ed i n a d v ance in accordance with those procedures provided in the FOD

. Thus t he r i s k

assoc i a t ed w i t h the proposed ope r a t i on s is so d i m i n i shed fr om that ass o c i a t ed w i t h co m m e r c i al

ope r a t i ons con t e m p l a t ed by P a r t 61, t hat a ll o w i ng 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 e x ceeds t hat p r o v i ded by a pilot having a co mm e r c i al ce r t i f i ca t e op e r a t i n g a

con v en t i onal a i r c r a f t 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 cu rrent 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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- 3§ 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate

. T he FAA has previously granted Sanborn’s petition for e x e m p t i on 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, 11 213

. 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 .” T here is no FAA standard by which such a determination of airworthiness can be made. Nonetheless, given t he limitations and procedures , as con t a i ned herein, and in t he FOD , for maintaining the aircraft and checking it before each flight to ensure that it is in peak operational condition, an e q u i v a l ent
l e v e l o f s a f e t y w il l be p r o v i ded.
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 shoul der harness; or 22 CHI

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- 3(2) The crewmember would be unable to perform required duties with the shoulder harness fastened. In general, S ec t i on 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 e q u i v a l ent or even higher l e v el of s a f e t y

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.
S ec t i on 91

. 119(c) e s t ab li shes s a f e a l t i t ud e s f or ope r a t i on o f c i v i l a i r c r a f t over other than congested areas

. Sanborn seeks exemption from subsection 91.119(c) because, pursuant to this Petition, t he Leptron RDASS4 UA w il l at times be ope r a t ed below 4 00 ’ A G L

. An e q u i v a l ent or even higher l e v el of s a f e t y can be provided instead by, as provided herein, ope r a t ing 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 non

participating personnel, away from who the UA would generally be restricted as addressed
herein

. Further t he Leptron RDASS4 UAS flight operations will be m on i t o r ed at all times by 23 CHI

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- 3bo t h t he PIC and VO and will be i n c o m p li ance w i t h l ocal pub li c s a f e t y r e q u i r e m en t s , so as to prevent access to t he restricted a r eas o f ope r a t i on.
T he FAA has previously granted Sanborn’s petition for e x e m p t i on 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, 11 213

. 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) r e q u i r es persons ope r a t i n g a n a i r c r a f t t o m a i n t a i n a l t i t ude by

r e f e r ence t o an a l t i m e t er s e t “t o t he e l e v a t i on o f t he depa r t u r e a i r p o r t or an ap p r op r i a t e a l t i m e t er

s e tt i n g a v a il ab l e b e f o r e dep a rt u r e
. ” 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 altit ude.
A n e q u i v a l ent l e v el of s a f e t y w i l l be p r o v i ded instead by operating the UA below
4 00 ’ A G L 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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. 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 lea st 20 minutes

. T he Leptron RDASS4 is an unmanned aircraft, and thus would not begin a flight with a person in it as the regulation contemplates. T o the extent the regulation applies to the Leptron
RDASS4 , a n e q u i v a l ent l e v el of s a f e t y can be ach i e v ed instead by l im i t i ng the Leptron RDASS4
f

l i g h t s 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 ; 25 CHI

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- 3Section 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 ch apter; 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 oth er 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 Administra tor) 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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- 3(i) The tot al 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 air craft 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 mainta ined. (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 insta lled 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 super seded 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. In general, t hese r e g u l a t i ons r e q u i r e t h a t an airworthy certificated a i r c r a f t be i nspec t ed as
p r e s c r i bed i n 14 C.F.R. Part 91, S ubpa r t E (Maintenance, Preventive Maintenance, and Alterations), any d i sc r epanc i es be r e pa i r ed and the aircraft be approved for return to service a s
p r e s c r i bed i n P a r t 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 e q u i v a l ent l e v el of

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- 3s a f e t y can be provided instead by requiring, as provided herein, that inspections and m a i n t enance
be acc o m p li shed according t o t he inspection, maintenance, and preflight sections of the FOD including the Leptron Inspection & Maintenance Manual

. A s p r o v i ded i n t he FOD , among
other things , the UAS will be inspected prior to each flight to confirm that it is in good

w o r k i n g o r der, any maintenance or repairs will be p e r f o r m ed and l o g ged , 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, the reby 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 4 00 ’ 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 w eight, slow speed and l o w
- a l t i t ude

ope r a t i ons 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 i s significantly reduced when compared to that p r esen t ed by using manned ai r c r a f t to condu ct the same operations

. T he FAA has previously granted Sanborn’s petition for e x e m p t i on 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, 11 213

.

H
. A Summary That Can Be Published In The Federal Register, s tating:
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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- 3RDASS4 for compens ation in the National Airspace S ystem. In relation to Sanborn’s current aerial surveying and mapping operations, such exemptions will increase safety, reduce risk to person and pro perty 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 person s on - board. Sanborn’s customer s 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 RD ASS4 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 limi ted to the greater of the power needed to conduct the intended operation plus an a dditional 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. C onclusion
A ccordingly, a s 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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- 3C.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) , 91.40 5(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, 22 nd Floor Chicago, Illinois 60606 Tel: (312) 526

- 1523 Fax: (312) 655

- 1501 tom.gemmell@huschblackwell.com Attorneys for Petitioner

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- 3