Submitted electronically

June 26, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Petition for Exemption from Certain Federal Aviation Regulations according 

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

Dear Sir or Madam: 

Leica Geosystems, Inc. (Leica) is applying for an exemption from regulations detailed 

below. The requested exemption would permit commercial operation of Leica’s 

Aibotix X6 for the purpose of aerial inspections and monitoring, aerial geo-mapping, 

aerial imaging and filming,"aerial data collection, crew training and the testing of 

aircraft after maintenance.

BACKGROUND 

With the advent of technological leaps in Geographic Information Systems (GIS), new 

data-driven photogrammetric methods and workflows, and the reduction of safety risks 

and cost using manned aircraft, the demand for small umanned aerial systems (SUAS) for 

commercial purposes has grown. In response to commercial demand for SUAS use, the 

FAA has previously granted to operators the privilege to fly in the National Airspace 

System (NAS). The following approved 333 exemption petitions describe similar uses to 

those that Leica seeks: 

• For aerial inspections: exemption no. 11216, Solusia Air, LLC; exemption no. 

11422, Soar Environmental Consulting; exemption no. 11241, Phoenix Air

• For geospatial mapping: exemption no. 11393, Surveying and Mapping, LLC; 

exemption no. 11397, Colorado Cartographics

• For aerial imaging and filming: exemption no. 11150, AerialCine; exemption no. 

11240, Aerial Flight.

• For aerial data collection, exemption no. 11343, Woolpert; exemption no.

Draganfly Innovations, Inc.
Leica"Section"333"Petition"for"Exemption" 2

• For forensic inspection: exemption No. 11412, Earth Forensic, Inc; exemption no. 

11465, Rimkus Consulting Group, Inc.

In addition, the FAA has previously approved three petitions whose petitioners use of 

the Aibotix X6 for their SUAS operations: exemption no. 11216, Solusia Air; exemption 

no. 11545, Clean Energy Renewables, and exemption no. 11356, Boyd Instrument and 

Supply Company.

In accordance with these previously granted exemptions, Leica respectfully submits its 

petition to the FAA for the use of its Aibotix X6 SUAS for commercial operations in the 

NAS. It its submissions Leica will document an equivalent or greater level of safety than 

possible for similar missions using manned aircraft; the safety systems and procedures it 

will adhere to; the characteristics of the Aibotix X6 aircraft, in particular its failsafe, lostlink and emergency recovery capability; and the public interest served by this proposed 

exemption to certain sections of the Code of Federal Regulations.

DESCRIPTION OF PETITIONER 

Leica Geosystems, Inc. develops, manufactures and distributes civil engineering, 

industrial process equipment, and software products for surveying, mapping, machine 

guidance, metrology, navigation, and image processing. The company is a global 

leader in aerial survey systems for manned aircraft. Leica also trains its users in the 

safe and efficient use of its survey products, including the new SUAS line. In addition 

to the Aibotix X6 survey aircraft, the product range include laser-based measuring 

devices, Global Positioning System (GPS) receivers, handheld measuring devices 

(DISTO), machine vision systems, and 3-D scanning systems. Leica Geosystems, Inc., 

part of Sweden-based Hexagon AB, is enriching its software development to process 

and model geospatial information.

NAME OF PETITIONER 

Bryan Baker

Leica Geosystems, Inc.

5051 Peachtree Corners Cir.

Norcross GA 30092

Telephone: 770-326-9500

eMail: 333LeicaUS@gmail.com
Leica"Section"333"Petition"for"Exemption" 3

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM 

Leica wishes to fly the Aibotix X6, an electric multirotor, as its survey aircraft. Aibotix 

in Germany has delivered more than 300 aircraft since 2011. The flight control system 

used with the aircraft is designed by the company and manufactured in Germany. 

System development is subject to Leica's rigorous design and quality control 

standards, and has undergone continuous improvement since market launch three 

years ago.

If the radio control link is lost, emergency failsafe will prevent flyaway and perform a 

controlled descent or, if GPS signal is sufficient, return to the takeoff point. The flight 

control system can fly pre-programmed waypoints yet respond immediately to pilot 

stick overrides in case of route adjustment or emergency. Its radio control system 

incorporates telemetry, which is displayed on the pilot’s handheld controller and may 

be announced by voice. The X6 aircraft is optimized for aerial survey. Its software 

includes dynamic points of interest (POI) that enables automatic visual alignment 

towards the POI and geo-fencing for protection, which reduces pilot workload. The 

aircraft is less than four feet in diameter, made of carbon-fiber reinforced polymer in 

a high-visibility color, with protective blade guards surrounding its six rotors. 

Maximum takeoff weight is approximately 15 pounds, and flight time is about thirty 

minutes with its redundant multicell battery system. The aircraft carries no flammable 

liquid fuel. 

RF SPECTRUM 

Radio control and video transmission systems meet FCC requirements for operation 

in the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings 

about interference from devices operating at or near these frequencies or their 

harmonics are documented in the Leica Flight Operations Manual (LFOM), along 

with procedures to ensure radio safety with the SUAS. 

EXTENT OF RELIEF SOUGHT AND WHY 

Petitioner asks for relief from regulations tabled below, which the authority of the 

FAA has previously granted in exemption certificates number 11062 along with six 
Leica"Section"333"Petition"for"Exemption" 4

others described as “in commonality”, and in number 11109, which are for use of 

electric rotorcraft. The Leica Geosystems Flight Operation Manual (LFOM) 

incorporates the conditions and limitations of these grants of exemption, and in some 

cases imposes stricter limits on its own operations. 

CFR CODE CITATIONS 

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 (a) Private pilot 

privileges and 

limitations: Pilot in 

command

Holder of private pilot 

certificate may not act as 

pilot in command for 

compensation or hire. 

Flying for compensation on 

engineering survey missions 

is central to purpose of 

exemption request. 

Characteristics of aircraft, VLOS, 

class G airspace, under 400 ft. AGL, 

trained visual observer in radio 

communication with pilot; remote 

site, industry safety protocols 

enhanced by Leica's flight safety 

plan; pilot in command (PIC) with 

minimum of sport pilot certificate, 

glider certificate, non-powered and 

powered, currency in the aircraft 

listed on the certificate, 3rd class 

medical or valid U.S. driver’s 

license, pilot training, testing, 

proficiency with similar and same 

model UA; and 

inspection/maintenance are defined 

in the Leica Flight Operations 

Manual (LFOM) and will ensure 

equivalent levels of safety if not 

more. 
Leica"Section"333"Petition"for"Exemption" 5

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 (b) Private pilot 

privileges and 

limitations: Pilot in 

command

Holder of private pilot 

certificate may act as pilot in 

command for compensation 

or hire if flight is incidental 

to business or employment 

and does not carry 

passengers for 

compensation or hire. 

Flying for compensation on 

engineering survey missions 

is central to purpose of 

exemption request, not 

incidental to business or 

employment. 

There is no passenger or pilot on 

board the sUAV, thus safety issues 

are different from a manned flight. 

Leica’s aircraft has programmable 

automated safety features and 

emergency responses, has pre-flight 

checks for safety beyond 

commercial manned aircraft, can be 

geographically restricted by 

operator with programmable 

control points, and has 

communications with the PIC 

regarding fuel loss and other flight 

hazards. PIC will have ground 

school training certificate and 

additional 25 hours logged flight 

time and 25 hours classroom and 

field instruction as stated in LFOM. 

91.119 (c) Minimum safe 

altitudes over other 

than congested 

area 

Operating closer than 500 

feet to a person, vehicle, or 

structure may be necessary 

for survey and equipment 

inspection. 

People will not be allowed over, 

under or within 500 feet laterally of 

the aircraft in flight. Some flights 

may require the participation or 

guidance of industry personnel, 

positioned as close as 200 feet. 

Leica will brief them on safety and 

obtain necessary consent. Industry 

specific safety rules and regulations 

are to be followed. 
Leica"Section"333"Petition"for"Exemption" 6

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to SUAS 

pilot. 

An onboard air pressure sensor and 

software resolve height differences 

as small as one centimeter. Altitude 

is controlled by measuring air 

pressure and the z‐axis 

accelerometer/GPS values. The 

starting point is a relative height 

measurement calculated by the 

flight controller. Altitude above 

ground is displayed on the pilot's 

handheld controller by telemetry, 

and alarms can signal conditions of 

interest. 500 feet AGL is the 

maximum permissible in the 

LFOM, which describes altimeter 

procedures. 
Leica"Section"333"Petition"for"Exemption" 7

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.151 (b) Fuel requirements 

for flight in VFR 

conditions

Rotorcraft under VFR must 

carry enough fuel to reach 

first landing point and then 

another 20 minutes. The X6 

multirotor is designed to fly 

for a maximum of 30 

minutes with its 2 batteries. 

Battery voltage under load is 

displayed on the pilot's handheld 

controller during flight. The X6 

uses 2 lithium polymer batteries of a 

multi‐cell design, connected in 

parallel for redundancy and optimal 

current delivery. Battery chemistry 

does not support adequate current 

discharge below about 3 v per cell. 

Circuitry in the onboard flight 

controller measures voltage and will 

start a failsafe procedure to land 

before summed minimums are 

reached. In the event that one or 

more cells fail, these minimums may 

be reached sooner than expected, 

due to rapid current drain against a 

smaller number of functioning cells. 

Leica pilots are trained to monitor 

voltage and recognize abnormal 

discharge in flight and to land 

sooner than forced. If 20 minutes 

of flight time or 25% of reserve 

voltage under load is reached, pilot 

must commence landing. 
Leica"Section"333"Petition"for"Exemption" 8

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.405 (a) Maintenance 

required

Required inspections and 

discrepancies repaired 

between required 

inspections pertains to 

certificated manned aircraft 

and procedures conducted 

by licensed maintenance 

personnel. In the absence of 

certification requirements 

for SUAS and SUAS 

maintenance personnel, 

reasonable alternatives must 

be developed to maintain 

equivalent levels of safety. 

Leica will document maintenance, 

overhaul, replacement and 

inspection requirements in the 

absence of manufacturer's 

requirements; will document and 

maintain maintenance records and 

technician qualification criteria in 

the LFOM. 

91.405 (b) Maintenance 

records

Qualifications for 

maintenance personnel for 

SUAS were not 

contemplated by these 

regulations, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Qualifications, competence and 

testing for maintenance personnel 

are defined in the LFOM. Leica will 

also abide by USDOT FAA Notice 

N 8900.296.

91.407 (a) 

(1) 

Operation after 

maintenance, 

preventive 

maintenance, 

rebuilding, or 

alteration

There is no authorization 

procedure for a person who 

can approve a return to 

service of an SUAS, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Procedures for the PIC to test then 

approve a return to service after 

maintenance are defined in the 

LFOM. 
Leica"Section"333"Petition"for"Exemption" 9

14 CFR 

PART

SUMMARY OF 

REGULATION

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.409 (a) 

(1) 

Inspections Annuals conducted by a 

qualified inspector require 

authorization criteria for 

that inspector, not yet 

defined for SUAS. A 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Schedules for inspection and 

responsibilities of the PIC and 

qualified technician are described in 

the LFOM. 

91.409 (a) 

(2) 

Inspections Issuance of airworthiness 

certificates for SUAS less 

than 55 pounds operated 

VLOS is not contemplated 

by these regulations.

Airworthiness is the responsibility 

of the PIC and the technician as 

defined in the LFOM. 

91.417 (a) Maintenance 

records

Regulations do not 

contemplate requirements 

or approval processes for 

maintenance and inspection 

of uncertificated SUAS, 

however a reasonable 

alternative must be 

developed to maintain 

equivalent levels of safety. 

The operator will maintain records 

according to the procedures 

specified in the LFOM. 

91.417 (b) Maintenance 

records

Retaining and transferring 

records of maintenance and 

defects according to 

standards prescribed for 

authorized maintenance and 

inspection is not 

contemplated in the 

regulations for SUAS. A 

reasonable alternative is 

necessary to maintain 

equivalent levels of safety. 

Records and documentation will be 

kept for all maintenance performed, 

defects, and for all components 

specified in the LFOM. 
Leica"Section"333"Petition"for"Exemption" 10

PILOT IN COMMAND AND CREW 

The Pilot In Command (PIC) must hold a transport, commercial, private, recreational, 

sport pilot, glider (powered or non-powered) airman's certificate, and be in 

compliance with the training and testing specified in the LFOM. The PIC must also 

hold a current FAA airman medical certificate or if qualified as a sport pilot, a valid 

U.S. driver’s license issued by a State, the District of Colombia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC must be in compliance 

with the training and testing specified in the operator’s manual. They must remain in 

radio communication with a visual observer who is in compliance with the training 

and testing specified in the operator’s manual. The pilot must be able to acquire the 

aircraft with their own vision, unaided except by prescription refraction lenses. They

must at minimum meet the eye-testing standards for a third-class airman medical 

certificate or valid driver’s license according to the issuing State. They must operate 

within visual line of sight only, and be able to see the attitude and orientation of the 

aircraft themself. If GPS, magnetometer, or other assisted flight modes are 

compromised, certain safety features may not operate, and the pilot must understand 

by their training and experience how to recover control. 

OPERATION OF THE UNMANNED AIRCRAFT 

The aircraft will be under the operational control of the petitioner. 

1. The aircraft used for survey operations by Leica will be only the Aibotix 

X6 as described in the Leica Flight Operations Manual (LFOM), unless 

the FAA approves an amendment to this petition for use of a different 

aircraft. 

2. The PIC will hold a transport, commercial, private, recreational, sport 

pilot or glider (powered or non-powered) airman certificate, and must 

meet the medical and vision standards, and the flight review 

requirements, appropriate to that certificate, according to 14 CFR § 

61.56. 

3. Unless permission is obtained from the FAA, the FSDO or ATC, Leica

pilots will operate at least three (3) nautical miles outside populated areas, 

at less than 400 feet AGL, in class G airspace, in daylight hours only and 
Leica"Section"333"Petition"for"Exemption" 11

within visual line of sight of the PIC, five (5) nautical miles or more away 

from airports as denoted on current FAA-published charts, and use a 

LFOM-qualified visual observer in radio communication with the PIC.

4. Manufacturer’s limitations of the aircraft will not be exceeded, and Leica’s 

operations will adhere to power reserves and the lower operational limits 

described in the LFOM. 

5. Preflight inspection by the PIC, and inspection and maintenance 

procedures will be followed according to the LFOM, and will be properly 

documented and signed for by an authorized technician who has 

completed training specified in the LFOM. 

6. Test flights by the PIC in connection with maintenance requirements will 

be documented. 

7. Manufacturer systems and safety bulletins will be followed, and flight 

critical components will be monitored and replaced when specified in the 

LFOM. 

8. Discrepancies discovered between inspections will be documented by 

Leica maintenance personnel. 

9. If visibility is less than three (3) statute miles from the PIC, the aircraft 

may not be operated less than 500 feet below a cloud, or less than 2000 

feet horizontally from a cloud.

10. The PIC must follow emergency procedures as described in the LFOM in 

event of lost link, degraded navigation signals, or appearance of 

unauthorized persons within the secure flight perimeter.

11. A commercial Certificate of Authorization will be obtained by FAA’s 

designated procedure before any operations that require it are conducted. 

Notices to Airmen will be filed in accordance with FAA requirements, 

and permissions from ATC or local FSDO's will be sought as the FAA 

shall specify. 

12. An N-Number will be obtained for all aircraft operated.

13. RF spectrum will be used in compliance with FCC requirements.
Leica"Section"333"Petition"for"Exemption" 12

14. Documents required by 14 CFR 91.9 and 91.203 will be available to the 

PIC at the point of flight and control, and will be produced upon request 

by any authority.

15. The aircraft will remain clear of and yield right of way to all manned 

aviation operations and activities at all times. 

16. The PIC will operate the aircraft from a stationary ground position and 

not from any moving device or vehicle.

17. No operations over congested or densely populated areas is allowed, 

unless ATC and FSDO approval is obtained, whether or not these areas 

are depicted on aeronautical charts. 

18. The safety of people and property is paramount, and no operations may 

be conducted within 500 feet of unprotected non-participants or their 

property unless conducted according to safety procedures in the LFOM

that are approved by the FAA. 

19. All operations will be conducted over controlled-access property, for 

which permission has been obtained prior to flight, and for which safety 

briefings have been completed according to the LFOM. 

20. All incidents, accidents, and transgressions of allowed flight boundaries 

will be reported as required by FAA and NTSB. 

BENEFIT TO THE PUBLIC 

Approval of exemptions allowing commercial operations of SUASes throughout the 

industries Leica Geosystems serves will enhance safety by reducing risk. By removing 

the use of conventional jet fueled aircraft weighing in tons for lightweight, battery 

operated sUAVs in restricted areas for aerial inspection, geo-mapping and image and 

film capture, is more environmentally sound and safe. The use of the Aibotix X6, 

which is powered by batteries, provides a smaller environmental footprint, increases 

safety by decreasing manpower and separates the aircraft operators form the craft. It 

further protects the public by being used in restricted environments and reducing 

impact hazards.
Leica"Section"333"Petition"for"Exemption" 13

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY 

The survey aircraft will be operated in accordance with safety protocols defined in the 

LFOM, for which we request approval by the FAA according to its authority granted 

by Congress in Section 333 of the FAA Modernization and Reform Act of 2012. 

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and 

weight are a small fraction of any manned aircraft, and its safety systems reflect best 

design practices in the SUAS industry. 

In addition, Leica will keep the approved LFOM at its ground control station. The PIC 

will have immediate access to it. Previous exemptions granted by the FAA concerning 

Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft 

Flight Manual is kept at the ground control station of a UAS, where the PIC can 

immediately access it.

When properly operated by a trained pilot, a well-designed SUAS can stay clear of 

people and property on the ground and in the air. Procedures, airmanship skills, 

training and testing requirements for SUAS personnel in the LFOM will let the 

operator achieve safety levels in the NAS and on the ground, which are equivalent to 

or greater than in manned aviation. 

SUMMARY FOR PUBLICATION 

The following summary may be published in the Federal Register: 

Petitioner requests an exemption from: 

14 CFR Parts 61.113 (a) and (b) 

14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 

(a) (1), 91.409 (a) (2), 91.417 (a) 

in order to operate a small unmanned aircraft system (SUAS) for purposes of aerial 

inspections and monitoring, aerial geo-mapping, and aerial imaging and filming and 

aerial data collection. The pilot in command will be appropriately qualified with a 

current FAA approved pilot certificate for SUAS operation and specialized training.
Leica"Section"333"Petition"for"Exemption" 14

Aerial survey and inspection, geospatial mapping, and film and image capture are 

conventionally done by manned aircraft operations that use liquid fuel and weigh 

upwards of 5,000 lbs. These operations involve flying the aircraft to and from the 

operation’s location. An Aibotix X6 weighs less than 15 pounds, is less than four feet 

in diameter, is equipped with flight control and safety features that prevent flyaway 

and minimize risk, compared to that of a manned aircraft, to people and property 

allowed within the zone of operations and outside it. 

No flight operations outside the secured areas are allowed, and no impacts to privacy 

are foreseen.