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 To ledo and Cleveland** 

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

September 21, 2015

Attn: U.S. Department of Transportation Dockett Management Sy stem 1200 New Jersey Avenue, SE We st Building Ground Floor Room W1 2
- 140 Wa shington, DC 20590

Petitioner: Gar cia Surveyors, Inc. Richard Henr y, Vice President PO Box 2628 Wh itehouse, Ohio 43571 Phone: (419)877
- 0400 Fax: (888)316
- 3943 E
- ma il: rhenr y@ garciasurveyors.com

Re: Request for exemption under Section 333 of the FAA Reform Act and Part 11 of th e 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 To ledo and Cleveland** 

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

To whom it may

concern: P ursuant 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 sy stems seek s 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 auth orize commercial operations of Unmanned Aircraft S ystems (UAS) for sur veying and mapping applications in the National Airspace Sy stem (NAS). These ope rati ons will me et 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 lev el 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 To ledo and Cleveland** 

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

**Characteristics of the A ircraft System:**  The aircraft sy stem 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 p revio us 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 com pared to similar operations conducted by aircraf t 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 l anding (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 ma inte n an ce programs d esigned specifically for the DJI Matrice 100. Those programs will be enhanced by the inflight mo nitoring s ys tems and the expertise of our pilot in command . If the on board sensors detect a critical situation at any time the aircraft will automatically in itiate 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 rec ords will be kept by Garcia Surveyors, Inc. All ma intenance and repairs will be performed by an authorized ma nufactures representative at the recommended maintenance schedules. Please find attached in annex A the Aircraft Flight Manual and Maint ena nce a nd Inspection Manual.

 Pilots in Command will complete a ma nufacturer’s authorized training course for each specific model of UAS and will maintain currenc y b y performing and documenting a minimum of three takeoffs (launch es) 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 me dical 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 To ledo and Cleveland** 

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

 All observers will , at a minimum , have docu me nted 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 Inf ormation Manual.

 All Observers will be required to obtain and keep current a Transportation Wo rk er Identification Credential (TW IC) to verif y their background and will hold a valid FAA class 2 me dical certificate.

 All observers will maintain constant con tact 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.

 Al l 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 operat ional 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 W aiver of Authorization from the FAA Air Traffic Organization to address airspac e 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 Surv ey ors, 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 To ledo 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 com bustible 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 b y the fact that all individuals holding a private pilot certificate or TW IC 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 eq uivalent 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 ass uredly in line with previous Grants of Exemption granted by the FAA under Section 333.

Respectfully Submitted,

Richard Henr y, V.P. Garcia Surveyors, Inc.