Design and Construction

March 10, 2016 Thomas E Perry Shawmut Design and Construction 560 Harrison Avenue Boston, Mass 02118 Telephone: 617 622 7375 Cell: 617 839 4710 Fax: 617 622 8375 Email: tperry@shawmut.com U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Roomwl2-140 1200 New Jersey Avenue, SE, Washington DC 20590 Re: Petition for Exemption 14 CFR, Section 333 (Request for exemption from regulatory provisions to allow the use ofsmall unmanned aircraft) To whom it may concern, Shawmut Design and Construction, a professional construction management firm based in Boston, respectfully request an exemption from several provisions ofTitle 14 ofthe Code ofFederal regulations (C.F.R.) to permit the use of small UAVs on construction sites foraerial data collection that will assist in project logistic plmning and construction progress reporting. 

### Background Information Shawmut Design and Construction is a national Construction Management firm based in Boston, MA with offices in Springfield, MA,Providence, RI, North Haven, CT, New York City, NY, Las Vegas, NV, Los Angeles, CA, and Miami, 

### H... We have developed a specific Shawmut Safe UAV Operational procedures. Our clients look to Shawmut to properly plan, manage, inspect, and report on construction activities. 

### Intended use ofUAVs on construction site:

• Obtain aerial photos ofconstruction sites for use in preparing site logistics and safety plans • Provide progress photos ofconstruction progress • Inspection ofconstruction details

### Regulatory Basis for Exemption Request The requested exemption will permit the operation ofUAV under tightly controlled project sites within the construction fence thus ensuring that the operation ofthe UAV will not have an adverse impact on public safety. Shawmut anticipates that the use ofUAVs will enhance the safe operation ofconstruction sites which will directly benefit the general public surrounding thejob sites as well as construction workers. The safety and efficiency ofconstruction activities is dependent on accurate and timely information that canbe checked and modified ifnecessary. Often, as-built drawings of ajob site and/or satellite photoc; ifavailable, will not show actual conditions. UAVs along with on grade inspections will provide accurate site information that will imp-ove project planning and safe operations. With the use of UAVs, Shawmut will substantially upgrade its capacity to detect sites issues that could become a problem for safe construction activities and construction quality 

### Information on the UAS- DJI Phantom 3 Professional The UAV owned by Shawmut iscurrently registered with the FAA. FAA Registration Numrer: N592DD (see Exhibit "B") FAA Expiration date: 2/28119 Manufacturer and Serial Number: DJI Phantom 3 Professional serial# CE06153932681 Type: Quad-Copter Drone Maximum Take-offWeight: 2.6 lbs Flight Time: 23 minutes max. Maximum Distance: 6600 feet (outdoors, unobstructed) Radio frequency (RF) used for control: 2.4GHZ On-board Camera: 4K video (30 frames per second), t2 Megapixel Photos 

### Air CraftPerformance: The DJI Phantom 3 Professional has manual and Auto Takeoffcapability. When GPS is available, Auto Return Home can be utilized. The Phantom 3 remembers the exact spot that it too offfrom. Auto return Home isactivated by tapping a button on the handheld controller. If the Intelligent Flight BatEry is running low, or ifthe connection with the remote controller is lost for any reason, the aircraft will automatically return back to the point of takeoff and land safely The Phantom 3 has a Beginner mode that can be set to fly within a given distance and altitude so it will stay within desired limits. Vision Positioning Sensors scan the ground beneath the Phantom 3 for (Xltterns, enabling it to identify its position and move accurately. The remote Controller has two sensitive controls sticks, dedicated buttons, and t .2 mile range 

### Intended Operations ofUnmanned Aircraft
2

### Granting an Exemption will not adversely affect safety. Shawmut will conduct UAS operation over client owned or Shawmut controlledjob sites, solely during daylight hours, and at altitudes Jess than 400 feet, which will be well below that which would pose a risk to other aircraft. In general UAV operations are intended to be conducted in areas distant from both congested areas and airports. Shawmut will not operate UAVs within 5 miles ofany airport or a designated no "fly zone" and at a maximum height of400 feet. Shawmut does not want to exercise the privileges ofthe requested exemption outside ofthe United States. The safety ofthose on the ground is protected by the fact that no one will be allowed into a construction area without permission ofShawmut. Security will be established for the flight area as part ofthe preflight control. Each individual within the secure area will be briefed prior to flight and will cmsent to be 

### in the area. All others will be excluded from the area. Shawmut intends to only to operate the UAS within visual line of sight (VLOS) so the PIC is able to scan the space in which it is operating to see and avoid other aircraft or objects aloft or on the ground

. Potential hazard for flying the UAS over construction sites are above ground pole mounted power lines. The pre-flight plan will identify all hazards and provide a safe strategy for avoiding such hazards

. The operation ofthe small UAVs conducted in strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant exemption requested herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft re'Jlirements and allowing commercial operations. The light weight craft to be used by Shawmut weighs less than (3) lbs., will operate at slow speeds, close to the ground, in a controlled environment, and not over people or houses. Shawmut intends to use commercially available UAV components. These UAV systems will be tested for quality and safety before being used in the field on constructionjob sites. Shawmut intends to perform routine maintenance to verify that the UAV will remain in safe and operational condition. Additionally, refer to App!ndix "A" for Shawmut's Safety Operations & 

### Procedures Checklist. 

### Unmanned Aircraft PIC Shawmut intends to use a dedicated stafffor UAV operations. All operations will be within visual line-ofsight (i.e., no more than approximately 1000 feet from the manipulator ofthe controls, or pilot in command (PIC). Shawmut intends to use a ground-based visual observer to work alongside the PIC. Using an IPAD device that is connected to the flight remote cootroller, the observer will instruct the PIC to position the UAV for construction site photos. This allows the PIC not to take his eyes offofthe UAV while in flight. Key factors needed by the PIC are knowledge ofthe airspace within which the operations shall take place, experience with the UAV that will be flown, and familiarity with the activities ofcorntruction andjob site safety. Minimum requirements forthe PIC (Thomas E. Perry) include: I

. Having undergone a qualification process as specified in the Flight Procedures Manual consisting ofa video training, and knowledge & 

### skill instruction ofthe aircraft to be u;ed

. 2. A minimum of5 

### hours as a UAV pilot with the make and model ofthe UAVs to be 

### utilized for operation under the exemption and (3) take-offs and landings in the preceding 90 days. 3. OSHA I0 Construction Safety Certification 4. Basic Life Support (BLS) Certification 5

. U.S. Driver's license issued by the State ofMassachusetts 36

. Familiar with NPFA-24 1, Standard for Safeguarding Construction, Alterations, and Demolition Operations

.


### List ofSections from 14 CFR thatShawmut is seeking Exemption Notes regarding: 14 C.F.R Pan 21. Subpart H In accordance with the statutory criteria provided in Section 333 ofPL 112-95 in reference to 49 USC 44704, and in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its OJl!ration, we request that this aircraft exefll>tion meets the conditions ofSection 333. Therefore, ifgranted Section 333 relief of 14 CFR part 21, and any associated noise criteria certification and testing requirements of pan 36, is not necessary. Notes Regarding : 14 C.F.R. § 45

.23 (b)

. Marking of the Aircraft Given the size of the UAV, two-inch lettering will be impossible. UA Will be identified by !!!rial number, registered in accordance with 14 CFR, part 47, and have an identification (N-number) markings in accordance with 14 CFR, pan 45, Subpart C

. Markings will be as large as practicable. Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airoorthiness Shawmut'srequest is based on the fact that no airworthiness certificate will be issted for the UAS

. Shawmut's UAS will not require an airworthinesscertificate in acrordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be Issued, exemption from § 91.7(a) is not necessary. Notes regarding: 14 CFR § 91.9(b) (2) Civil aircraft flight manual, marking & placard Certifications required, tre original intent ofthese regulations was to display an aircraft's Airworthiness, certification, arw:J registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) isnotnecessary. Notes Regarding: §91.109 Flight instruction; Simulated instrument &certain flight tests Small UASs, by their design, do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. Aircraft being considered for use by Shawmut allow the UAS Instructor to place the aircraft into 'loiter' mode (fixed altitude stationary hold)

. In the event ofthe student losing control, the UAS Instructorcan quickly and via alternate equipment (equipment not in the hands ofthe student) place the aircraft into a mcde that then allows the instructor to bring the aircraft back into control and back to the predetermined and/or safe landing location. DFAMdoes Notes Regarding § 14 CFR 91.119(b) Relief from§ 14 CFR 91.119(b), operation over congested areas, is not applicable, because the Shawmut Design and Construction operations will only be conducted within the secured area of a constructionjob site described above.

4

### Thank for considering ourpetition for exemption

. If

### you have any question or require additional information, please call me direct @ 

### 617 839 4710

. Sincerely,

# ~a{J~u~ Thomas E Perry Director ofEngineering · · · 10n Shawmut Design and Construction 560 Harrison Avenue Boston, Ma tperry@

### shawmut.com Cell: 617 839 4710 Office: 617 622 7275



### 5

# Exhibit "A" Shawmut Safety Operations & 

### Procedures Checklist: 

### Area and Environment
'. Anunal.., ( Chcd. for wire-; L People I**by<;tamler~** C Property in the v1cmity l S1te 1s :1\\ay from nones..,entwl participants [ Ability to mamt:un a<kquatc buffer lone'> between aircraft and rxrsonnel; Mmimite**dc~trture**... and**landmg<~** over populated area-, U Tal-e into account local topography. ensuring a vhtblc hne of

...ighttoward-; the UAVat all times. Ensure the telemetry connectiOn j.., not ob'otructcd. (' lnve

...tigatc potential alternative landing site-, in ca'oc tal-c-off '>lle is obstructed. G P-,ychological con,idcration (arc you well rc:,ted, m
...hed. arc you being prcssurt:d by client) 

### r Weather considerations Temperature 

### o Vi-;tbility
o Precipitation 

## r Wind Speed
o Upper wind-; I at altitude C Notify any bystanders or nearby properly owner-; ofyour intentions**(pcrmi~ton)** (**D1~cuss** flight plan with your co-pilot or spotter 

## r If flying m controlled**airs~tce.** have you notifietl airspace authority
1.. Shawmut will not lly in cmtrolled airspace
o Can you reach nuthoritks


### n Do ) ou need to mamtain communication? L F1N Aid Kit**<~locked,** readily accc...sJbk and visible to anyone in the area. EquipmcntiUAVIDrone


### r Wall.-nround l Crack 111 JOints ,md structural membe1" L Loose ord.unagcd screw-;, ties. fa-;tenl!rs

. straps 6

# Exhibit 

# "A" (continued)
[" Loo-;e ordamaged wiring L**Loo~c** ordamaged connection-; (solder, plug-,, etc.) 

### r**ln~pccl** prop mounh and**~crews** and apply**~ltght** coumcr pre-;surc on anm to chccl.. for loo-.enetl**component~** C Clean FPV (Camera) Len-. and**in~urc** it i.., '>ecured and connects are firmly auach:d C Camera**selling~** are correct**(~till** im:1ge..,, video, frameratc) Baucry I Bauene-; arc fully charged, properly -.eateu and Secured**Fail-~ali:** equipment functioning
o RTH (return to hom:) Firmware Airport Proximity Detection Functioning 

## r Prop-. arc smooth and free ofdamage I defect (check blade.**~urfacc** and hub) L Prop adapter-. are tight I secure 

## c- Check RC tran'imittcr**!-~how..,** the right range and centering for all**~tick~** Mi.-...,ion plan

( 1 All**action~** and**contingencie~** for the mission planned. [ Contingency planning shoulu include -;afc routes in the event of a system failure, d:gratkd performance, or lo..,t communkation link. if**~uch** a f:ul..,afc**exi..,t~.** t**Mi~sion plan~**  and flight plmt'> should be shared with other**o~rators** in the vicinity.
Public Awarene..,s

L Be courteous :md pol itc [' You arc an amba-.sador anu your actions will affect other pilob ard the industry in general Be profe-.-.ional I appear profe"isional
Pre Flight [ Verifying all**tran~mitter,** on-board aircraft ami camera batterie'> are full) charged: (confirm**voltage~)** Ensure no frequency conllicts with both video and tran'>mttter I receiver

1

# Exhibit 

# "A" (continued)

0 Checking all control surfaces for sign!-> of damage. loose hinges, and overall condition; Looking
over the wing/rotors to ensure they :1re in good structural condition and properly secured: 0 Check motor/engine and mounting allached to the airframe; 0 Study propellers I mounting hard\\ are (tight) I rotor blades for chips and deformation; 0 Check the landing gear for damage and function 0 Test electrical connections, plugged in and secure 0 Ensure photo I video equipment mounting sy-.tt:m is secure and operational. 0 Check location of GPS equipment controlling the autopilot. 0 Check the IMU movements in the ground control software. 0 UAV in stabilization mode, ensure control surfaces move towards the**corn:~ct** positions 0 UAVI Drone is in a level location safe for takeoff 0 If using Video recorder turn on camera system 0 Camera settings are correct (still images, video, framerate) 0 SD camera memory clear and inserted into the camera
L Action I Start filming 0 All tr:m-.miuer controls move freely inall directions l All tran-.mitter trims in neutral positton C Alltran-;milter switches incorrect position( typically away) 0 Transmitter throttk to zero Rallio tran-;mitter on [ Connect I power on battery to airframe ( En-.urc Jed indtcators and audible tones are correct Tuner on (if appltcablc) FPV, confirm video is in monitor C Scan lor nearby cars I people I animals 0 Say

..CLEAR!" 

### r Arm flight controller [ Increase throttle slightly listening forany abnormalities [ Short**20 30** **~econd** hover at 3-5 feet (listen for vibrations I loo;c item'>) [ Confirm Voltage levels arc correct 

### 8

# Exhibit 

# "A" (continued)

Inflight
C.: 

### Ba.,ic-.: Ifflying manually, ah\ .lY" keep your fm!.!er<, on the controller/transmiller. [ Never let the UAV out ofyour s1ght even for a -.econd. l 

### Climb to a •,afc altitude 

### ;m "Y from potenuat h.1zardo., and to reduce noise pollution. C. 

### Keep a1rcraft at a :-.ale operating dl':ltancc from people. electric utility lines and buildings. 0 If the UAV mu'it**L~** 

### flm\n mer hmtdmgo., or pcopk, use a tight\\cight UAV and maintain a safe altitude for 1ecovery and make every effort to minimi1c expo!:>urc. l 

### Spotter: U-;e a o.,potter \\ henever poo.,..,rhle and appropriate,**e~pecially** 

### when flying by 

### First Person View (FPV). 0 Do not fly UAVs ''ithin dt..,lance del 1ncd by local**J;~y."** 

### ol any privatc/comn"Crcial airport/hclipad Do not fly around a pre-e·w.tmg UAV flying o.,rte ''ithout a freqtrncy-managcrnent agreement. C· 

### Do not interfere \\ith op:rationo., and traffrc pattern'> at any airport C 

### Landing:**Regardle~~** 

### of\\hethcr ofa manual or automated UAV landing. scan landing area for potential**ob~truction** 

### hazard!:>. L 

### Announce out loud ,;Prepanng to Land''. 

## r Carefully l:md tlx: aircraft a\\ay from ob-,tru<.'ttom and people**Po~t-fl**

### ight


### r Shutting Down: Turn the po''er off to the aircraft and/or d1scmnectthc batteries. 0 Turn offthe transmiltcr.
[. 1 

### Turn the power offto the photo equrpment. Vt..,ually check aircraft for**~ign-.** 

### of dunage and/or exce-.-;ivc \\ear. Remove Lhc unused fuel ifapplicable. Secure Lhe arrcraft l 

### Check pictures: Verify th:ll the UAV camera actually took. the ptctures. l 

### Log Flight

9

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# _____________________ _ REGISTRATION NOT TRANSFERABLE UNITED STATES OF At.I£R ICA 

# I This eertific:.ato OEPARTI.IENT OFTRAHSPORTATIOH-f£OERAL AVIATIOtl AOMINISTRATION must be inthe airCERTIFICATE OF AIRCRAFT REGISTRATION craft when operated

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# I AIRCRAFT SERIAl NO REGISTRATION MARKS N 59200 CE061 539232681 MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT OJI PHANTOM 3 PROFESSION ICAOAtn:raltAddress Code 51722444 Thll cettilialle II lnuedlor I SHAWMUT DESIGN AND CONSTRUCTION re;lalraliollpucposea 

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