Spectrum Geomatix, LLC

939 NW 176th Ave.
Beaverton, OR 97006
Tel: (541) 250

- 9526

O ct 9 , 2015

US Department Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, Spectrum Geomatix, LLC, owner and operator of Small Unmanned Aircraft Systems (UASs), requests to be exempted from the Federal Aviation Regulati ons (FAR) listed below so that Spectrum Geomatix, LLC may operate UASs commercially in airspace regulated by the FAA., as long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Spectrum Geomatix, LLC (a geomatics company ) is owned by Ryan Benz, Jonathan Burnett

, and

Richard Gabriel

. They are all Oregon resident s with Oregon driver’s licenses

. Someone with a sport pilots certificat e or higher will be PIC at all times

. All operations will be performed with the public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for safe operation of such aircraft systems in national airspace systems.” Section 333(c), of the Reform Act.

Spectrum Geomatix UASs (The 3dr solo quadcopter ) are rotorcraft weighing less than 55 pounds including payload. They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. It has an auto return to launch poi nt when battery power is under 1 5%. The UAS will operate within the line of sight within a protected flight area as

described below and at 400 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public

nor the environment.

Spectrum Geomatix, LL C respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial

use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 9 1.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

Spectrum Geomatix, LLC submits this application in accordance with the Reform Act ,112 P.L. 95 331-334, seeking relief from any currently applicable FAR’S operating to prevent Spectrum Geomatix, LLC future commercial use of small UASs to operate in the national airspace system as described below.T he reform Act section 332 provides for such integration of civil unmanned aircraft i nto our national

airspace system as it is in the public’s interest to do so. Spectrum Geomatix, LLCs UASs meet the definition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these UASs are expressly contemplated by th e Reform Act. Spectrum Geomatix, LLC would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to

deter mine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability Operation of the UASs in clo se proximity to airports and populated areas Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace System, the secretary sh all establish requirements for the safe operation in national airspace.

Spectrum Geomatix, LLC u se rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots and have the capability to operate in the vertical and horizontal p lane simultaneously. The UASs will operate only within the line of sight of the operator within a protected flight area and at 400 feet AGL

or less. These will not present a hazard to the national airspace nor the public.

The very small nature of the se UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction giv en in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly red ucing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on oper ations of Spectrum Geomatix, LLC,

 Flights will only occur in the daylight hours,

 Flights will be operated in the line of sight of the operator(PIC) and Observer,(VSO)

 Flights will be terminated at any time weather and wind deteriorate to “unsafe for fli ght” by manufacturers recommendations,

 The UASs will weigh less t han 55 lbs.,

 Flights will be operated at 4 00 feet AGL or less.

 Crew will be at a minimum of operator(PIC) and an observer and/or camera operator(VSO),

 Operator and crew will remain in contact during the flight operation,

 The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area,

 All required FAA clearances, will be obtained and distances from airports strictly observed. All UASs will have the capability to return automatically to the operator in a safe manner with the

auto return fu nction checked and working.

 Flights will only operate in VFR conditions.

 UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining.

 Flight team will communicate by voice and the use of two-way radio if the area is too big to hear

voice from all team members.

 UASs will be used for videography and stereographic scene reconstructio n

 I n the event of an unscheduled landing all UASs will be recovered to prevent environmental

contamination from lithium batteries

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Spectrum Geomatix, LLC UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the

Refor m Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. S pectrum Geomatix , LLC meets or exce eds each of these elements

A s of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA for flights at or under 200 AGL to any UASs operator with a section 333 exemption. 14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at Spectrum Geomatix, LLC operations center.

14C FR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifica tions and registrations at Spectrum Geomatix, LLC operations center.

The FAA has previously issued exemptions to this regulation in Exemptions No’s
8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe alt itudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Spectrum Geomatix, LLC will onl y operate its UASs at or below 4 00AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Electric UASs under 55 lbs operate with a much smaller environmental footprint and with a lower risk of human injury or prope rty damage than manned counter parts that are powered by highly volatile liquid fuel

.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety by reducing the overall risk associated with traditionalaircraft. Small autopilot equipped UASs weighing 55 lbs or less and flying below 400 ft AGL have fewer

mechanical parts, lower mass and redundant electronic sensors that all comb ine to improve the operational risk management conditions relative to conventional manned aircraft when operating in similar

roles

.

Spectrum Geomatix, LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Spectrum Geomatix, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely

Spectrum Geomatix

, LLC

Jonathan Burnett

939 NW 176 th Ave.
Beaverton, OR 97006
Tel: (541) 250

- 9526 j onathan. burnett@spectrumgeomatix.com