### WILLIAMS MULLEN

Direct Dial: 703.760.5204 kromfret@williamsmullen.com

U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington, D.C. 20590 May 15, 2015

Re: Section 333 Exemption Request Dear Sir or Madam: Pursuant to Section 333 oftheFAA Modernization and Reform Act of2012 (the "Reform Act"), EagleView Technologies, Inc. ("Petitioner") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") described in Section VII below, a Certificate of Waiver and Authorization ("COA'') and any other exemptions necessary to allow the Petitioner to operate the small Unmanned Aircraft Systems ("UAS") described in Section IV for commercial aerial data collectionpurposes, as more fully described in Section IX below. I. Background on Petitioner Petitioneris an industry leadingprovider ofaerial imagery, data analytics and GIS solutions servingthe commercial, government and public utility sectors. The company'spatented image capture processes and 3D modeling algorithms coupled with property-centric analytic tools empower end-user workflow in support ofproperty claims, risk management, emergency response, assessment, corridor mapping and more. In January, 2013, Petitionermerged with Pictometry International, creating a unique company with powerful technological solutions in the GIS, measurement and analytical space. The combined company has more than 50 patented technologies to provide scalable, efficient and highly accurate analytical solutions.

8300 Greensboro Drive, Suite 1100 Tysons Corner, VA 22102 T 703.760.5200 F703.748.0244 williamsmullen.com I A Professional Corporation

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15, 2015 Page 2

II. Contact Information The contact information for Petitioner is set forth below: Chris Barrow, CEO EagleViewTechnologies, Inc. 3700 Monte Villa Parkway, Suite 200 Bothell, WA 98021 http://www.eagleview.com/ III. Request for Exemption to Use UAS for Commercial Inspections Petitionerproposes to inspect commercial and residential buildings using the UAS under controlled conditions. The data collectionwill be conducted for commercial purposes, primarily to assist in insurance underwriting and determining insurance claims. The Petitioner also requests the right to utilize the UAS for othercommercial purposes that require aerial data collection, such as monitoring building construction, pre/post disaster imaging and the status of fixed assets in the telecommunication and energy industries. In each case aerial data collection will be conducted under the conditions set forth herein and the Section 333 exemption grant. In thatregard, the airspace will be (i) limited, (ii) predetermined, and (iii) controlled as to access. Petitionerwill limit operations to property whose owners have been notified in advance and have provided consent. Operations will always occur within the line ofsight ofthe UAS operator. Petitioner will take steps to protectthe privacy ofthe property owners and nearby individuals. Given the potential for this exemptionto lead to developments that will save lives and property after a storm or disaster, the Petitionerrequests that this request for exemption be considered on an expedited basis. In that regard, Petitioner notes that the FAA has previously granted exemptions for similar activities for the md4-1000, the AlturaZenith ATX8, the DJI Phantom and the DJI Inspire. 1 IV. Unmanned Aircraft Systems A. Microdrone md4-1000 The md4-1000 is a battery powered quadcopter weighing less than 6kg, including payload. Ithas a maximum speed of26 mph and a maximum flight operating endurance of88

1See, e.g., Asymmetric Technologies (Microdrone md4-l000- Exemption No. 11171), State Farm Mutual Automobile Insurance Company (AlturaZenith ATX8- Exemption No. 11175 and Exemption 11188), Montico Inc. (DJI Phantom 2- Exemption 11230), Erie Insurance (DJI Phantom- Exemption I I293), NextEra Energy, Inc. (DJI Phantom -Exemption I1224), Travelers Companies, Inc. (DJI Phantom- Exemption 11494) Build Imagery, LLC ( DJI Inspire- Exemption 1I204),), CineDrones, LLC (DJI Inspire- Exemption 11279)and USAA (PrecisionHawkExemption 11309).

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 3

minutes. Its flight and navigation controller centers on an inertial measurementunit, consisting ofan accelerometer and a gyroscope for each axis, supplemented by a 3-axis magnetometer, a barometric altitude sensor and a GNSS receiver. With all these sensorreadings put together, the md4-l000 is able to fly self-stabilized with GNSS Position Hold. As soon as there is no input from the operator, the md4-1000 will stay on the spot, waiting for the next command. It is possible to let the md4-1000 hover in the same spot for several minutes. The aircraft is operated using a remote control ground station and is capable ofsetting pre-programmed distance and height limits. In the event ofa loss link, GPS failure or law battery condition, the aircraft canbe programmed to descend and land orreturn to home. B. Aerialtronics Altura ZenithATX8 The Altura ZenithATX8 is a multi-rotor aircraft built with a monocoque carbon airframe. The Zenith has a 5.6 kg take-offweight and a maximumpayload of2.9 kg. The Zenith carries a 16.600 mAhbattery, which facilitates up to 45 minutes offlight-time. Itcan be flown with either a radio ortablet and carries a variety ofpayloads. The Zenith has a maximum cruise speed of20 m/s. It features auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. Specifications include:

• Length x Width: 23.6"x 23.6" • Height: 13.

### 7"- 21.6" tall • Weight: 7.7 lbs., withoutpayload (less than 15 lbs. with payload) C. DJI Phantom The DJI Phantom is a multi-rotor copterthat that will weigh less than 55 lbs. when fully loaded. It will be operated at a maximum speed ofless than 50 mph and a flight time ofno more than 20 minutes. Ifits communications with the PIC is lost, the safety system will allow itto eitherhover in place and slowly descend or to returnto apredeterminedpoint. D. DJI Inspire The DJI Inspire is a multi-rotor copter that will weigh less than 55 lbs. when fully loaded. Itwill be operated at a maximum speed oflessthan 50 mph and a flight time ofno more than 20 minutes. Its safety system will allow it to eitherhover in place and slowly descend if communication with the PIC is lost orto return to a predetermined point.

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 4

E. Precision Hawk Lancaster The PrecisionHawk Lancaster is a fixed-wing vehicle that will weigh less than 55 lbs. when fully loaded. Itwill be operated at no more than 100 mph. Itcontains onboard flight diagnostics that allow itto adjust flight patterns when needed. Each ofthe UAS set forth above have operating manuals, maintenance schedules and training procedures (collectively, the "Operational Documents"). Petitionerwill comply with each ofthe Operational Documents. Copies ofeach can be made available upon request. V. Statutory Authority for Requested Exemptions This petition for exemption is submitted in accordance with Section 333 ofthe Reform Act. Pursuant to Section 333 ofthe Reform Act, the Federal Aviation Administration (FAA) Administrator (the "Administrator") is to permit operation ofan unmanned aircraft system where it does not create a hazard to users ofthe national airspace system (NAS) orthe public orpose a threat to national security. Moreover, the Federal Aviation Act grants the Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides such a requested exemption is inthe public interest. See 49 U.S.C. §§ 106(f), 44701-44716, etseq. A party requesting an exemption must explainthe reasons why the exemption: (i) would benefitthe public as a whole, and (ii) would not adversely affect safety orhow it would provide a level ofsafety at least equal to the existing rules. 14 C.F.R. § 11.81. VI. Safety Measures and Public Interest Benefits As described in more detail in Section IX, the Petitioner will take measures to ensure such operations will not create a hazard to aviation orthe public. Flights will be conducted under 400 feet AGL thereby avoiding interference with users ofthe NAS. Flights will be suspended immediately to yield right-of-way to any other aircraft. Geo-fencing will be utilized when available to ensure that a UAS does not fly outside ofthe intended area. The site will be secured and only authorized personnel will be permitted onthe grounds. Given the size and speed ofthe UAS, the controlled nature ofthe locations being used and the lack ofexplosive materials or flammablejetfuels, the operations will not pose a threat to national security. There are a number ofreasons why granting the Petitioner'srequest to operate the UAS for commercial aerial data collection is in the public interest. For example, use ofUAS in this manner will make conditions for insurance claim representatives safer. Today claim representatives must climb onto a rooffor data collection. Such activities are inherently dangerous as eachyear claim handlers are injured due to falls from roofs. Claim handlers will be able to reduce their exposure to suchhazards by using a UAS. In addition, they will be able to obtainthe data necessary to make accurate assessments ofa roofmore quickly. Similarly,

### WILLIAMS MULLEN U.S. Department ofTransportation Docket Management System May 15,2015 Page 5

utilization ofUAS to inspect construction, telecommunication and energy physical assets will result in enhanced safety for individuals, cost savings and greater efficiencies in large and critical industries. VII. Specific Sections from Which Petitioners Seekan Exemption Based upon the informationprovided and the exemptions thatthe FAAhas already granted pursuantto Section 333, the Petitionerrequests the following exemptions: 14 C.F.R. 

### § 61.113(a) 14 C.F.R. § 61.23(a) 14 C.F.R. §61.23(c) 14 C.F.R. § 61.101(e)(4) 14 C.F.R. § 61.101(e)(5) 14 C.F.R. §61.113(a) 14 C.F.R. § 61.315(a) 14 C.F.R. §91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1) 14 C.F.R. § 91.409(a)(2) 14 C.F.R. § 91.417(a) 14 C.F.R. § 91.417(b) VIII. Justifications for Each Exemption Request 1. 14 C.F.R. § 61.23(a), 14 C.F.R. § 61.23(c), 14 C.F.R. § 61.101(e)(4), 14 C.F.R. § 61.101(e)(5), 14 C.F.R. §61.113(a) and_14 C.F.R. §61.315(a). Petitionernotes that FAA is nowrequiring the Pilot in Command to hold either an airline transport, commercial, private, recreational or sport certificate pilot license and either a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, orthe Federal government. Petitioner will ensure that its PICs will satisfy each ofthese requirements. Since Petitioners' PICs will be operating UAS underthe same conditions as those previously granted, an equivalent level of safety will be metby granting these exemptions.

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 6

2. 14 C.F.R. § 91.7(a) Civil aircraft wo1ihiness. Section 91.7(a) requires that an operatordetermine an aircraft is in airworthy condition before a flight. Petitioner requests relieffrom this sectionprovidedthat the operator ofthe UAS determines priorto each flight that the aircraft is in compliance with the applicable Operational Documents. Such pre-flight inspection will providethe equivalent level ofsafety as that provided bythis section. Petitionernotes thatthe Administratorhas granted relieffrom this section inprevious exemptions. 3. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas. Section 91.119(c) establishes safe altitudes for operation ofcivil aircraft over areas other than congested areas. The Petitionerrequests relieffrom this section with respect to those participating persons, vehicles, and structures directly involved with data collection. The UAS will never operate at higherthan 400 AGL. 

### It will be operated in a restricted area, where buildings and people will not be exposed to operations withoutprior consent. Relieffrom this section is warranted as operations will be conducted with adequate safetyprovisions as outlined herein and in the applicable Operational Documents. As a result, an equivalent level ofsafety will be met by granting this exemption. Petitionernotes that the Administrator has grantedrelief from this section in previous exemptions. 4. 14 C.F.R. § 91.121 Altimeter Settings. This regulationrequires eachperson operating an aircraft to maintain cruising altitudeby reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure.'' An exemption from section maybe needed ifthe UAS does not have a barometric altimeter but insteadhas a GPS altituderead out. An equivalent level ofsafety will be achieved by the operator, pursuantto the applicable Operational Documents, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorbefore flight. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitioner notes that the Administrator has grantedrelieffrom this section inprevious exemptions. 5. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFRconditions. Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly after that for at least 30 minutes." Complying withthe 30 minute reserve would severely limit the length ofthe Petitioner's UAS flights and hamperthe ability to conduct datacollection. Giventhe limitations onthe UAS's proposed flight area, a longertime frame for flight in daylight conditions is reasonable.

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 7 Operating the UAS in a tightly controlled area, where onlypeople orofficial representatives who have signed waivers will be allowed, does notraise the type ofrisks that this section was intended to address, particularly giventhe size and speed ofthe UAS. Petitionerbelieves that an equivalent level ofsafety canbe achieved bylimiting flights to 50 minutes or 20% ofbattery power, whicheverhappens first. 6. 14 C.F.R. § 91.405(a) Maintenance required; 14 C.F.R. § 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(l) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance records. Maintenance will be accomplished by the operatorpursuantto the applicable Operational Documents. An equivalent level ofsafety will be achieved because the UAS are very limited in size and will carry a small payload and operate only in restricted areas for limitedperiods of time. Ifmechanical issues arise, the UAS will be operating from no higher than 400 feet AGL and can immediately land. As provided in the applicable Operational Documents, the operator will ensure that the UAS is in working orderpriorto initiating flight, performrequired maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suitedto maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. As a result, an equivalent level ofsafety will be met by granting this exemption. Petitionernotes that the Administratorhas granted relief from this section in previous exemptions. 7. Additional Relief. In addition to the exemptions listed above, the Petitionerrequests exemption from such otherrules and regulations as the FAA deems appropriate to enable the operations described herein. Since previous exemptions grantedunder Section 333 ofthe Reform Acthave been effective for two years, the Petitioner also requests that ifthe FAA issues interim orfinal rules applicable to the operation ofany UAS included herein after the Petitioner receives a Grant of Exemptionthat any conditions and limitations required in such Grantthat are more burdensome than the newregulationbe appropriately modified orremoved. IX. Operating Parameters for UAS Use Petitionerproposes that ifthe requested exemptions are granted, it will operate the UAS underthe following conditions: 1. UAS operations will be conducted by a Pilot in Command (PIC). The PIC shall hold an airline transport, commercial, private, recreational, or sportpilotcertificate. The PIC will also hold a currentFAA airmanmedical certificate or a valid U.S. driver's

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 8

license issued by a state, the District ofColombia, Puerto Rico, a territory, a possession, orthe Federal government. The UAS will be in visual line ofsite (VLOS) ofthe PIC at all times. 2. All UAS operations will utilize a visual observer ("VO"). The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding air traffic and other ground-based obstacles/obstructions. 3. The PIC and VO will be able to communicate verbally at all times. 4. Petitioner will rely onthe UAS vendor(s) to provide a pilot qualification program, including a training program incorporatingproper aircraft operations and safety standards. The PIC and the VO will have obtained the necessary qualifications/training. A record ofcompletion ofthis qualification process will be documented and made available to the Administratorupon request. 5. UAS will not be flown at ground speeds exceeding 50 mph. 6. Flights will be operated at an altitude ofno more than400 feet above ground level. 7. Each UAS operationwill be completedwithin 50 minutes flight time orwith 20% batterypowerremaining, whichever occurs first. At 30%batterythe UAS will enter a return and land sequence; at 20% it will land immediately. 8. UAS will notbe operated over any person (otherthan participating personnel) at an altitude that is hazardous to persons orproperty on the surface in the event ofa UAS failure or emergency. UAS will be operated at a distance from participatingbuildings ofat least 10 feet. Operations will be conducted at least 500 feet from nonparticipating persons orbuildings, unless barriers are in place to provide adequate protection. 9. The UAS will abort the flight in the event ofunpredicted obstacles oremergencies in accordance with the applicable Operational Document. 10. The UAS will remain clear and yield the right ofwayto all other manned operations and activities at all times. 11. UAS operations will notbe conducted during night. 12. The UAS will notbe operatedby the PIC from any moving device or vehicle.

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15,2015 Page 9

13. The UAS 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. 14. The applicable Operational Documents and all documents required under 14 C.F.R. § 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents will be made available to the Administratorupon request. 15. Any incident, accident, orflight operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA will be repmied to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB). 16. The operator will follow the procedures as outlined in its applicable Operational Documents. 17. Priorto each flight, pilot will inspectthe UAS to ensure it is in condition for safe flight. Ifthe inspectionreveals a discrepancy, the aircraft will be prohibited from operating until the necessary maintenance has beenperformed and the UAS is found to be in a condition for safe flight. 18. Operations will notbe conducted over congested or densely populated areas. 19. All operations will be conducted overprivate or controlled-access property with permission from the land-owner/controller or authorized representative. Permission from the land-owner/controller will be obtained for each flight to be conducted. 20. All maintenance and alterations will be properly documented in the aircraft records. 21. Any UAS that undergoes maintenance oralterations that affect the UAS operation or flight characteristics will undergo a functional flight test in accordance with the applicable Operational Documents. 22. Petitioner will institute a rigorous maintenance programto ensure airworthiness ofthe UAS. Operator will follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 23. Each UAS will comply with all manufacturer Safety Bulletins.

### WILLIAMS MULLEN U.S. Department ofTransportation DocketManagement System May 15, 2015 Page 10

X. Summary to be Published in Federal Register Petitioner: EagleView Technologies, Inc. Sections of 14 C.F.R. Affected: § 61.23(a); § 61.23(c); § 61.101(e)(4);§ 61.101(e)(5); §61.113(a);, 61.315(a); § 91.7(a); §91.119(c); § 91.121; §91.151(a); §91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b). Description of ReliefSought: Petitioner seeks relieffrom the requirements of 14 C.F.R. § 61.23(a); 14 C.F.R. § 61.23(c); 14 C.F.R. § 61.101(e)(4); 14 C.F.R. § 61.101(e)(5); 14 C.F.R. §61.113(a);_14 C.F.R. § 61.315(a); § 91.7(a);14 C.F.R. § 91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to conduct inspections for commercial purposes using small unmanned aircraft systems (UAS) subjectto operating procedures that meet or exceed those that FAArequires for similar operations. XI. Conclusion Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Actregarding size, weight, speed, operating capabilities, proximity to airports andpopulated areas, operation within visual line ofsight, and national security, provide more than adequatejustificationfor the grant ofthe requested exemption allowing operation ofPetitioner's UAS for the purposes set forth herein. Please contact Petitioner's outside counsel, Kevin D. Pomfret at 703-760-5204 or kpomfret@williamsmullen.com with any questions aboutthis filing.



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