January 17, 2016 Docket Management Facility US Department of Transportation 1200 New Jersey

Avenue SE West Building, Ground Floor Room W12

- 140 Washington, DC 20590 Re: Re quest for Exemption Pursuant of Section 333 of the FAA Modernization and Reform Act of 2012 and Title 14 of the Code of Regulations Sections 91.7(a), 91.121, 91.151(b), 91.203(a)(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1)(a)(2), and 91.417(a)(b)

Applicant: Dr. Kalb Stevenson P resident Axiom Environmental, Inc 907

- 297

- 9519 Kalb.Stevenson@axiomAK.com

### Summary

Axiom Environmental Inc, pursuant of Section 333 of the FAA Modernization and Reform Act of 2012, request s the exemption from the requirements of Title 1 4 of the Code of Federal Regulations, 91.7 ( a ) , 91.121, 91.151 (b), 91.203(a)(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1)(a)(2), and 91.417(a)(b). These exemptions would allow the operation of an unmanned aircraft s ys t em (UAS) to provide a less invasive technique and a broader range of surveys for environmental, engineering and real estate clients

. This will benefit the compan y by providing another survey technique option for clients as well as providing them with images and data in a more time efficient manner. 

### Back**ground** Axiom Environmental, Inc

. is a consulting firm in Anchorage, Alaska specializing in environmental studies, NEPA writing, engineering support, and environmental permitting. They

provide their clients with excellent service with their exte nsive knowledge in a broad range of environmental , regulatory and lands topics. Axiom Environmental’s goal is to prov ide clients with efficient survey s , data, images , and video with an Unmanned Aircraft Sy stem (UAS). T he UAS will provide video and photographic data that cannot be acquired from any ground

- based camera or tool

. The UAS will be able to operate non

- invasivel y to serve clients by capturing imag es, video and data from the air, and the data may be geospatially

referenced for mapping. At this ti me, the compan y’s intention is to conduct surveys of no more than a maximum of 2 00ft above ground level . The company has no i ntention of flying near airports or highl y congested areas at this time. The technology may be used to carry

out survey s of terres trial lands, rivers, ocean , bridges, well casings , river crossings, riparian habitat, forested habitat, wetland habitat, marine habitat, other habitat, and surveying other structures for engineering or environmental clients . It may also be used to capture aerial images of homes or property for real estate clients and may also be used to serve clients who wish to produce marketing materials for a recreational or tourism business.The UAS may operate over F ederal, S tate, P rivate, N ative / Village c orporatio n lands, or other lands. The company may attempt to notify nearb y landowner s of impending flights if they are to occur near populated areas or property

. Axiom Environmental, Inc. has not ye t acquired the UAS to be used in this work, but it is in the proces s of purchasing a hex a copter (6 blade rotating / hovering), and may later purchase a quad or octocopter. The model may

somewhat resemble in size a HawkEy e M3 Matrice Quadcopter or a Hawkey e Carbon Octocopter. It will be equipped with dual cameras having hi gh resolution in which photo and video will acquire geospational data in the metadata of digital images. Cameras may resemble a Sony

X1000v camera, and may contain other components (C or CS lens, a Red Hen S ys tems VMS

- 333, GPS Antenna, Feature Trigger, pow er connector, power cable, power adapter and battery)

. The company may also later acquire a fixed

- wind UAS for survey s, depending on client needs.



### Hexacopter / Quadcopter / Octocopter The hex a copter (or similar model) complies with Secti on 333 by weighi ng less than 4kg and having a max imum airspeed of 80

- 100 km/h

. Maximum flight time for a single battery would be 1 2

– 30 minutes with possible flight time of up to 4 5 minutes in the event that twin batteries are used

. The aircraft will be registered , and the registration number affixed to the airframe prior to the first non

- recreational flight.
The camera selected to be used with this UAS is likely to have approximately a 4k , 720p resolution and 12 .8 megapixels with a 94 degree field of view. The company hopes to purchase extra safet y features including an auto return to home option and a fail safe feature, in which the UAS returns back to the point of origin, if practicable. L ive feed video is also desired and is likely to be added as an option. T he live feed provides altitude, speed, and distance information. A Red Hen Sy stems VMS

- 333 may be purchased in the future to interface GIS information and data with georeferenced video so that engineering and environmental clients can map or watch video with GIS

- based project features display ed.

### Specific Exemptions

Axiom Environmental Inc, pursuant of Section 333 of the FAA Modernization and Reform Act of 2012, requests the exemption from the following requirements of Title 14 of the Code of Federal Regulatio ns : 91.7(a), 9 1.121, 91.151(b), 91.203(a)(b), 91.405(a), 91.407 (a)(1), 91.409(a)(1)(a)(2), and 91.417(a)(b) . We request this exemption in order to operate a hex a copter or other UAS as a minimally invasive and efficient method for survey s , georeferenced video capture, data and image capture

. Considering the weight, speed, size, and limited area associated with the UAS , an exemption for 14 CFR part 21, Subpart H is justified. T he UAS meets the requirements of Section 333 and does not need an airworthines s certificate. We will , however, apply for the Certificate of Authorization. We request an exemption from 91.7(a), 91.405(a), 91.407 (a)(1), 91.409(a)(1)(a)(2), and 91.417(a)(b). These sections relate to the maintenance of aircrafts and consider them to be airworth y b y obtaining an airworthiness certificate. Seeing as we feel we should be exempt from the airworthiness certificate the maintenance described under these regulations relating to the certificate is inapplicable. We will maintain monthly
ma intenance logs and conduct pre

- flight inspections. We request an exemption from 91.151(b) which states , No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to f ly

.. . This section does not relate to our hex a copter due to it being battery

operated. Safet y measures will be taken into consideration that will equal the existing regulation. We request an exemption from 91.203(a) (1) and (b) stating that the airwor thy certificate is needed in order to operate the aircraft and that the certificate needs to be visible in the cockpit. These regulat ions do not seem fit because our UAS is not required to obtain an airworthiness certificate. In addition, there is no coc kpit in which to place the certificate

.

### Safety

Our request for exemption from 91.7(a), 91.405(a), 91.407 (a)(1), 91.409(a)(1)(a)(2), and 91.417(a)(b) shall not adversel y affect safet y , and we shall in accordance with the regulations make certain the quad copter is in compliance with a Monthly Maintenance Lo g in addition to accurately using the manufacturer’s manual to ensure the aircraft is airworth y prior to every

flight by conducting pre

- flight inspections. Our request for exemption from 91.151(b) shal l not adversel y affect safety. We will make certain that the battery is fully charged prior to take o ff and will land immediately when the battery

has reached the minimum percentage level of sa fet y as directed in the manuafacturer’s manual. In addition, the quad

- or octo copter has its own safety features to reassure safe landings if the pilot should be disconnected. Our request for exemption from 91.203(a)(1) and (b) shall not adversely affect safety. We will hav e the certificate with us at the groun d station at all times during the flight. In addition, we will have a form of identification on the quad copter.
With these exe mptions, we will comply by the regulati ons to maintain safety by :  F lying our aircraft within safet y zones  F lying onl y during th e day and in visible sight (VSR)  Avoiding airports  Ensuring airworthiness by conducting pre

- flight inspections  Ensuring maintenance is up to date  En suring battery

is at 100% prior to take off  Ensuring we land when the battery has reached the minimum percentage level of safet y  Registering the aircraft, affixing the registration number to the aircraft, and
e nsuring there are other identification markings on the aircraft  Using the global positioning s ys tem (GPS) within the UAS to monitor altitude  Obtain ing a Certificate of Authorization (COA) A certificated pilot under 14 CFR Part 61, subpart J (61.301

- 61.327) w/ driver license (as medical license) to comply (until new rules under part 107 released)  Ensuring the safet y of the ground crew, pilot, and other pers ons prior, during, and post flight  Ensuring the safet y of the public by never fl yi ng too low (except for takeoff and landing) 

### Public Benefit Our exemptions will benefit the public by creating a safer and less invasive e nvironment for survey s survey s in a time efficient manner. The data, images and video captured will be valuable to various clients. Some clients may be public entities, such as local, state or federal government; helicopters are expensive and consume fuel, and the use of the UAS can save th ese clients money , reduce carbon emissions, and capture still valuable data. By complying in equal terms as the regulations, the operating crew will have more hands on expe rience and knowledge of the UAS which would provide a better assistance to public qu estions and comments. The more efficient we are able to be , the more data we will be able to collect in which our clients may choose to publicize. Inaddition, we will be able to assist in projects that will contribute to the improvement of our community

. The UAS will allow us to survey

areas which would either be difficult or time consuming to travel to therefore increasing gathered information of our environment

. Thank y ou for y our time and consideration

. Sincerel y,

Dr. Kalb Stevenson President Axiom Environmental, Inc 907

- 297

- 9519 Kalb.Stevenson@axiomAK.com