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: Request 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

President

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, requests the exemption from the requirements of Title 14 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 system (UAS) to provide a less invasive technique and 

a broader range of surveys for environmental, engineering and real estate clients. This 

will benefit the company by providing another survey technique option for clients as well 

as providing them with images and data in a more time efficient manner.

Background

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 extensive 

knowledge in a broad range of environmental, regulatory and lands topics. Axiom 

Environmental’s goal is to provide clients with efficient surveys, data, images, and video

with an Unmanned Aircraft System (UAS). The 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-invasively to serve clients by capturing images, video 

and data from the air, and the data may be geospatially referenced for mapping. At this 

time, the company’s intention is to conduct surveys of no more than a maximum of 200ft 

above ground level. The company has no intention of flying near airports or highly 

congested areas at this time. The technology may be used to carry out surveys of 

terrestrial 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 Federal, State, Private, Native / Village corporation lands, or 

other lands. The company may attempt to notify nearby landowners of impending flights

if they are to occur near populated areas or property. Axiom Environmental, Inc. has not 

yet acquired the UAS to be used in this work, but it is in the process of purchasing a 

hexacopter (6 blade rotating / hovering), and may later purchase a quad or octocopter. 

The model may somewhat resemble in size a HawkEye M3 Matrice Quadcopter or a 

Hawkeye Carbon Octocopter. It will be equipped with dual cameras having high 

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 Systems VMS-333, GPS Antenna, Feature 

Trigger, power connector, power cable, power adapter and battery). The company may

also later acquire a fixed-wind UAS for surveys, depending on client needs.

Hexacopter / Quadcopter / Octocopter

The hexacopter (or similar model) complies with Section 333 by weighing less than 4kg

and having a maximum airspeed of 80-100 km/h. Maximum flight time for a single 

battery would be 12 – 30 minutes with possible flight time of up to 45 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 safety features including an auto return to home option and a failsafe 

feature, in which the UAS returns back to the point of origin, if practicable. Live feed 

video is also desired and is likely to be added as an option. The live feed provides 

altitude, speed, and distance information. A Red Hen Systems 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 displayed. 
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 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). We request this exemption in order 

to operate a hexacopter or other UAS as a minimally invasive and efficient method for 

surveys, 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. The UAS meets the requirements 

of Section 333 and does not need an airworthiness 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 airworthy by 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

maintenance 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 fly... This section does not relate to our hexacopter 

due to it being battery operated. Safety 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 airworthy certificate 

is needed in order to operate the aircraft and that the certificate needs to be visible in the 

cockpit. These regulations do not seem fit because our UAS is not required to obtain an 

airworthiness certificate. In addition, there is no cockpit 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 adversely affect safety, and we shall in accordance with the 

regulations make certain the quad copter is in compliance with a Monthly Maintenance 

Log in addition to accurately using the manufacturer’s manual to ensure the aircraft is 

airworthy prior to every flight by conducting pre-flight inspections.

Our request for exemption from 91.151(b) shall not adversely affect safety. We will 

make certain that the battery is fully charged prior to take off and will land immediately

when the battery has reached the minimum percentage level of safety as directed in the 

manuafacturer’s manual. In addition, the quad- or octocopter 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 have the certificate with us at the ground station at all times during the flight. In 

addition, we will have a form of identification on the quad copter.

With these exemptions, we will comply by the regulations to maintain safety by:

 Flying our aircraft within safety zones

 Flying only during the day and in visible sight (VSR)

 Avoiding airports

 Ensuring airworthiness by conducting pre-flight inspections

 Ensuring maintenance is up to date

 Ensuring battery is at 100% prior to take off

 Ensuring we land when the battery has reached the minimum percentage level of 

safety 

 Registering the aircraft, affixing the registration number to the aircraft, and 

ensuring there are other identification markings on the aircraft

 Using the global positioning system (GPS) within the UAS to monitor altitude

 Obtaining 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 safety of the ground crew, pilot, and other persons prior, during, and 

post flight

 Ensuring the safety of the public by never flying too low (except for takeoff and 

landing)

Public Benefit

Our exemptions will benefit the public by creating a safer and less invasive environment 

for surveys surveys 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 these 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 

experience and knowledge of the UAS which would provide a better assistance to public 

questions 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. In addition, 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 you for your time and consideration.

Sincerely,

Dr. Kalb Stevenson

President

Axiom Environmental, Inc

907-297-9519

Kalb.Stevenson@axiomAK.com