# RAUCH

engineering design & development services

Page | 1 110 N. Washington Street - Easton, MD 21601 office: 410.770.9081 | fax: 410.770.3667 email: design@raucheng.co m | web: www.raucheng.com inc.

January 15, 2016

U.S. Department of Transportation

Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Petitioner:

RAUCH inc. Mr. Dustin Rauch, PE, Vice President 110 North Washington Street Easton, MD 21601

Re: Petition to Amend Exemption No. 14014; Docket No. FAA-2015- 4309

Dear Sir or Madam:

On December 17, 2015, RAUCH inc. received an exemption (referen ce Exemption No. 14014, Regulatory Docket No. FAA-2015-4309) from the requirements of 1 4 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)( 1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem (DJI Phantom 3 Professio nal) pursuant to Section 333

of the FAA Modernization and Ref orm Act of 2012 (FMRA). This ex emption permits RAUCH inc. to operate an Unmanned Aircraf t System (UAS) at a maximum altitude of 400’ AGL for the commercial purpose of performing aerial data collection service s to include: aerial imagery, videos, topography generation, orthor ectification of aerial ima gery and wildlife monitoring for public safety in certain ar eas of the United States.

RAUCH inc. respectfully requests that an amendment to our exemp tion be granted in order to add additional unmanned aircraft sy stems (UAS) aircraft to our drone inventory, in addition to our DJI Phantom 3 Professional, for which we have already recei ved an exemption. The rationale for adding these UAS aircraft t o our list of permissible UAS ai rcraft is to facilitate the expansion of our range of capabilities wit h regards to available missions and potential business ventures, as they are a necessity to ensure we remain competitive within the civil engineering industry. We recognize that all conditions a nd limitations within Grant of E xemption No. 14014 remain in effect except with the anticip ated addition of these UAS types.

The additional UAS aircraft are as follows:

DJI Phantom 3 Standard

DJI Phantom 3 Advanced

DJI Matrice 100

# RAUCH

engineering design & development services

Page | 2 110 N. Washington Street - Easton, MD 21601 office: 410.770.9081 | fax: 410.770.3667 email: design@raucheng.co m | web: www.raucheng.com inc.

DJI Inspire I DJI Spreading Wings S1000+ DJI Spreading Wings S900

DJI AGRAS MG-1

3DR Solo Yuneec Typhoon H

Additionally, RAUCH inc. hereby pe titions to further amend this exemption by requesting all UAS aircraft previously approve d pursuant to the Section 333 ex emption process be granted for operations by RAUCH inc. for the same aforementioned purpose. P er the Grant of Exemption letter (ref. Exemption No. 12646), dated August 28, 2015, the F AA summarily granted a petition submitted by Measure LLC seeking to operate any UAS aircraft th at have been previously approved by the Secretary of the D epartment of Transportation p ursuant to the Section 333 exemption process. RAUCH inc. likewise requests the authority t o operate any previously approved aircraft listed in Exemption No. 12646.

There has been no change in the conditions and reasons relative to public interest and safety that was the basis for granting the original exemption. The addition al UAS aircraft are comparable in type, size, weight, speed and opera ting capabilities to that of the DJI Phantom 3 Professional. For any UAS aircraft granted to R AUCH inc. for exemption under Sect ion 333, RAUCH inc. will continue to comply with the condi tions and limitations as set f orth in our grant of exemption to include operating our UAS aircraf t at or below 400’ for the pur pose of aerial data collection. All

additional UAS aircraft have a ma ximum gross weight of less tha n 55 pounds, including payload.

For the evaluator’s convenience , we are providin g as an attachm ent, a table depicting the main operating and performance specifi cations for each UAS aircraft listed above in order to aid in the evaluation process.

With this grant of amendment to our exemption, RAUCH inc. will be in a position to fulfill its

current client’s needs – as well as its future client’s needs – with improved capability and productivity. We currently have a need for expanded operations and markets, hence this request for operating additional UAS a ircraft under Section 333 of the FAA Modernization and Reform Act. As such, we respectfully req uest that this amendment be re viewed as soon as reasonably possible. Please advise us of any additional information that m ay be required. Thank you very much for your consideration.

Yours truly,

Dustin Rauch, PE

Enc. (1) Attachment: Main Opera ting & Performance Specification s of Additional UAS Aircraft