Rich Henry – mobile (419) 779-7053 rhenry@garciasurveyors.com Page 1 of 5

3864 Center Rd. Suite A12 Brunswick, OH 44212 Ph. (330) 460-0760 – Fax (888) 316-3943

Brunswick, OH - Whitehouse, OH - Paulding, OH - Fort Wayne, IN

www.garciasurveyors.com

DBE Certified with ODOT - ODOT Prequalified for Right-of-Way Development

MBE/EDGE Certified with the State of Ohio - MBE Certified with the Cities of Toledo and Cleveland

Licensed in Ohio, Michigan, Indiana, Illinois, and Wisconsin

September 21, 2015

Attn:

U.S. Department of Transportation 

Dockett Management System

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

Petitioner:

Garcia Surveyors, Inc.

Richard Henry, Vice President

PO Box 2628

Whitehouse, Ohio 43571

Phone: (419)877-0400

Fax: (888)316-3943

E-mail: rhenry@garciasurveyors.com

Re:

 Request for exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations.
Rich Henry – mobile (419) 779-7053 rhenry@garciasurveyors.com Page 2 of 5

3864 Center Rd. Suite A12 Brunswick, OH 44212 Ph. (330) 460-0760 – Fax (888) 316-3943

Brunswick, OH - Whitehouse, OH - Paulding, OH - Fort Wayne, IN

www.garciasurveyors.com

DBE Certified with ODOT - ODOT Prequalified for Right-of-Way Development

MBE/EDGE Certified with the State of Ohio - MBE Certified with the Cities of Toledo and Cleveland

Licensed in Ohio, Michigan, Indiana, Illinois, and Wisconsin

To whom it may concern:

 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Garcia Surveyors, Inc, an operator of the DJI Matrice 100 unmanned aircraft systems seeks an exemption 

from the following Federal Aviation Regulations:

 14 CFR 21

 14 CFR 45.23

 14 CFR 45.29

 14 CFR 61.101(e)(4)

 14 CFR 61.113

 14 CFR 61.133(a)

 14 CFR 61.315(a)

 14 CFR 91.7 (a) &(b)

 14 CFR 91.9(b)(2)

 14 CFR 91.109(a)

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151(a)

 14 CFR 91.203(a) & (b)

 14 CFR Subpart E 91.401-91.417

The requested exemption would authorize commercial operations of Unmanned Aircraft Systems (UAS) 

for surveying and mapping applications in the National Airspace System (NAS).These operations will 

meet the Interim Operational Approval Guidelines 08-01 for Unmanned Aircraft Systems Operations in 

the U.S. National Airspace System dated March 13, 2008. Garcia Surveyors, Inc. believes that the 

requested relief is proper since an equivalent level of safety can be ensured.
Rich Henry – mobile (419) 779-7053 rhenry@garciasurveyors.com Page 3 of 5

3864 Center Rd. Suite A12 Brunswick, OH 44212 Ph. (330) 460-0760 – Fax (888) 316-3943

Brunswick, OH - Whitehouse, OH - Paulding, OH - Fort Wayne, IN

www.garciasurveyors.com

DBE Certified with ODOT - ODOT Prequalified for Right-of-Way Development

MBE/EDGE Certified with the State of Ohio - MBE Certified with the Cities of Toledo and Cleveland

Licensed in Ohio, Michigan, Indiana, Illinois, and Wisconsin

Characteristics of the Aircraft System:

The aircraft system that will be utilized in these operations is the DJI Matrice 100, which is 

airworthy and compliant with a significant level of safety. In fact, the many previous 333 Grants of 

Exemption by the FAA for operations of the DJI Matrice 100 and similarly designed DJI platforms 

underscore that the operations of the DJI Matrice 100 will not adversely affect safety when 

compared to similar operations conducted by aircraft that have been issued an airworthiness 

certificate under 14 C.F.R., Part 21, Subpart H. The DJI Matrice 100 is designed with extensive 

automated control features, redundant systems, and integrated fail-safes which enhance takeoff 

(launch), flight, and landing (recovery) in many conditions. Further details of these features are 

found in Annex A attached hereto and made a part of this exemption request. To maintain 

airworthiness Garcia Surveyors, Inc. will follow the inspection and maintenance programs 

designed specifically for the DJI Matrice 100. Those programs will be enhanced by the inflight 

monitoring systems and the expertise of our pilot in command. If the on board sensors detect a 

critical situation at any time the aircraft will automatically initiate a preprogrammed safety 

procedure. 

Operational Procedures and Risk Mitigation:

 Pre-flight inspections and system checks will be performed and documented by the Pilot in 

Command (PIC) prior to each take-off (launch). All pre-flight inspection records will be kept 

by Garcia Surveyors, Inc. All maintenance and repairs will be performed by an authorized 

manufactures representative at the recommended maintenance schedules. Please find 

attached in annex A the Aircraft Flight Manual and Maintenance and Inspection Manual.

 Pilots in Command will complete a manufacturer’s authorized training course for each 

specific model of UAS and will maintain currency by performing and documenting a minimum 

of three takeoffs (launches) and landings (recoveries) with the specific UAS within the 

previous ninety (90) days; and will have flight reviews and maintain currency in manned 

aircraft per 14 C.F.R., “Flight Review” and 61.57, “Recent Flight Experience: Pilot in 

Command.

 Pilots in Command will hold a minimum of a private pilot’s certificate and a valid FAA Class 2 

medical certificate.

 All PIC’s will be trained in all specific details of the UAS being operated including normal, 

abnormal, and emergency procedures.
Rich Henry – mobile (419) 779-7053 rhenry@garciasurveyors.com Page 4 of 5

3864 Center Rd. Suite A12 Brunswick, OH 44212 Ph. (330) 460-0760 – Fax (888) 316-3943

Brunswick, OH - Whitehouse, OH - Paulding, OH - Fort Wayne, IN

www.garciasurveyors.com

DBE Certified with ODOT - ODOT Prequalified for Right-of-Way Development

MBE/EDGE Certified with the State of Ohio - MBE Certified with the Cities of Toledo and Cleveland

Licensed in Ohio, Michigan, Indiana, Illinois, and Wisconsin

 All observers will, at a minimum, have documented training of the rules and responsibilities 

as described in 14 C.F.R. 91.111, 14 C.F.R. 91.113, knowledge of air traffic and radio 

communications including ATC and pilot phraseology, and a knowledge of the appropriate 

sections of the Aeronautical Information Manual.

 All Observers will be required to obtain and keep current a Transportation Worker 

Identification Credential (TWIC) to verify their background and will hold a valid FAA class 2 

medical certificate.

 All observers will maintain constant contact with the Pilot in Command and will be responsible 

for additional monitoring the airspace for other aircraft and hazards, advising the PIC before 

and during flight operations of all such observed risks, and monitoring the controlled 

operating area.

 All areas of operation will be reconnoitered by the Pilot in Command prior to operations with 

special attention being given to fixed objects that could interfere with flight operations and 

public safety issues.

 In the controlled environment under the operational conditions in Annex A, operations will 

remain within visual line-of sight (VLOS) and below 400 feet AGL. In addition Garcia 

Surveyors, Inc. will obtain a Certificate of Waiver of Authorization from the FAA Air Traffic 

Organization to address airspace requirements and provide notification by a Notice to Airman 

(NOTAM).

 Garcia Surveyors, Inc. will follow all existing requirements to notify and coordinate with Flight 

Standards District Offices (FSDO’s) prior to any operations for pipeline and powerline

surveying and mapping.

Conclusion:

 Garcia Surveyors, Inc. believes it is in the public interest to use the DJI Matrice 100 in lieu of 

the comparatively hazardous operations conducted with conventional fixed wing and rotary 

aircraft. Garcia Surveyors, Inc. believes this offers a net safety benefit and will achieve an 

advanced level of safety. Approval of this will also benefit the public interest by allowing better, 

safer, and more cost efficient information gathering for both Garcia Surveyors, Inc. and the public. 
Rich Henry – mobile (419) 779-7053 rhenry@garciasurveyors.com Page 5 of 5

3864 Center Rd. Suite A12 Brunswick, OH 44212 Ph. (330) 460-0760 – Fax (888) 316-3943

Brunswick, OH - Whitehouse, OH - Paulding, OH - Fort Wayne, IN

www.garciasurveyors.com

DBE Certified with ODOT - ODOT Prequalified for Right-of-Way Development

MBE/EDGE Certified with the State of Ohio - MBE Certified with the Cities of Toledo and Cleveland

Licensed in Ohio, Michigan, Indiana, Illinois, and Wisconsin

 Conventional aerial imagery and inspection techniques using manned aircraft involve heavy 

aircraft that must transit from airports to the operational area, carry significant amounts of 

combustible fuel, and a one or more crew. Manned aircraft are also at risk of fuel spillage and fire 

in the event of an incident or accident. By contrast, the DJI Matrice 100 is safe economical and 

efficient. The DJI Matrice 100 is light weight, does not require combustible fuel, carried (not 

flown) to the area of operation, removes the need for an airborne crew, and poses less risk to 

people and infrastructure on the ground; as well as other aircraft.

 No national security issue is raised by the granting of this exemption request. Given the size, 

load carrying capacity, speed at which the DJI Matrice 100 operates, and the fact that it carries no 

explosives or dangerous materials; the DJI Matrice 100 poses no threat to national security. Any 

other security concerns are ameliorated by the fact that all individuals holding a private pilot

certificate or TWIC card are subject to a security screening by the U.S. Department of Homeland 

Security.

 The grant of the requested exemption is in the public interest based on the high and 

equivalent level of safety of the proposed operations. The significant public benefit including the 

enhanced safety and cost savings to be realized as a result of the use of the DJI Matrice 100 for 

areal imagery, data collection, and inspections is most assuredly in line with previous Grants of 

Exemption granted by the FAA under Section 333.

Respectfully Submitted,

Richard Henry, V.P.

Garcia Surveyors, Inc.