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.com | 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 (reference Exemption No. 14014, 

Regulatory Docket No. FAA-2015-4309) from the requirements of 14 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 System (DJI Phantom 3 Professional) pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption permits RAUCH 

inc. to operate an Unmanned Aircraft System (UAS) at a maximum altitude of 400’ AGL for the 

commercial purpose of performing aerial data collection services to include: aerial imagery, 

videos, topography generation, orthorectification of aerial imagery and wildlife monitoring for 

public safety in certain areas of the United States. 

RAUCH inc. respectfully requests that an amendment to our exemption be granted in order to 

add additional unmanned aircraft systems (UAS) aircraft to our drone inventory, in addition to 

our DJI Phantom 3 Professional, for which we have already received an exemption. The rationale 

for adding these UAS aircraft to our list of permissible UAS aircraft is to facilitate the expansion 

of our range of capabilities with 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 and limitations within Grant of Exemption No. 14014 remain in 

effect except with the anticipated 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.com | 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 petitions to further amend this exemption by requesting all 

UAS aircraft previously approved pursuant to the Section 333 exemption process be granted for 

operations by RAUCH inc. for the same aforementioned purpose. Per the Grant of Exemption 

letter (ref. Exemption No. 12646), dated August 28, 2015, the FAA summarily granted a petition 

submitted by Measure LLC seeking to operate any UAS aircraft that have been previously 

approved by the Secretary of the Department of Transportation pursuant to the Section 333 

exemption process. RAUCH inc. likewise requests the authority to 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 additional UAS aircraft are comparable in 

type, size, weight, speed and operating capabilities to that of the DJI Phantom 3 Professional. For 

any UAS aircraft granted to RAUCH inc. for exemption under Section 333, RAUCH inc. will 

continue to comply with the conditions and limitations as set forth in our grant of exemption to 

include operating our UAS aircraft at or below 400’ for the purpose of aerial data collection. All 

additional UAS aircraft have a maximum gross weight of less than 55 pounds, including payload. 

For the evaluator’s convenience, we are providing as an attachment, a table depicting the main 

operating and performance specifications 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 aircraft under Section 333 of the FAA Modernization and Reform 

Act. As such, we respectfully request that this amendment be reviewed as soon as reasonably 

possible. Please advise us of any additional information that may be required. Thank you very 

much for your consideration. 

Yours truly, 

Dustin Rauch, PE 

Enc. (1) Attachment: Main Operating & Performance Specifications of Additional UAS Aircraft