November 21, 2015

US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC  20590

RE:     Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the  

           Federal Aviation Regulations from: 14 CFR21 subpart H

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 CFT Part 11, Dave Young, Owner of Cimarron Mapping Services LLC and operator of

Unmanned Aircraft Systems (UAS’s), is petitioning for an exemption from the listed Federal

Aviation Regulations to be allowed commercial operation of designated UAS’s provided such

operations are conducted in compliance with all current and future Federal Aviation

Regulations established by the FAA as required by Section333.

14 CFR Part 21, Subpart H, 14 CFR 45.23(b), 14 CFR 61.101(e) (4) and (5), 14 CFR 61.113(a) and

(b), 14 CFR 61.315(a), 14 CFR 91.7(a), 14 CFR 91.9(b) (2), 14 CFR 91.103, 14 CFR 91.109,           

14 CFR 91.119(c), 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.203 (a) and (b),                             

14 CFR 91.405(a), 14 CFR 91.407(a) (1), 14 CFR 91.409(a) (1) and (2),14 CFR 91.417(a) and (b)

Airworthiness

The fleet of UAS’s that will be used are as follows: DJH Phantom 2 Vision+ Plus V.3 and the DJI

Phantom 3 Pro. Both models are unmanned aircraft with a transportable ground station and

equipped with 4 rotary props that run on battery power and weigh less than 55 pounds each,

with payload (camera).  

 There is no flammable fuel involved that could cause injury or fire or harm humans,

animals or the environment.
Conditions and Limitations

These limitations provide for an exceptional level of safety to operations to which Dave Young

and Cimarron Mapping LLC agrees to be bound when conducting commercial operations under

an FAA issued exemption including:

1. Operate only in VFR conditions and will not be operated less than 500 feet

below or less than 2,000 feet horizontally from a cloud or when visibility is

less than 3 statute miles from the PIC.

2. 5 nautical miles from an airport having an operational control tower; or 3

nautical miles from an airport with a published instrument flight procedure,

but not an operational tower; or 2 nautical miles from an airport without a

published instrument flight procedure or an instrument flight procedure or

an operational tower; or 2 nautical miles from a heliport with a published

instrument flight procedure.

3. The UAS will weigh less than 55 lbs.

4. Flights will be operated within line of sight of operator.  

5. Maximum total flight time for each operational flight will be 30 minutes.

6. Flights will be terminated at 15% battery power reserve.

7. Flights will be operated at an altitude of no more than 400 feet AGL.

8. UAS operator will be trained and certified in the proper safety and

operations of the UAS. Prior to each flight, the PIC will conduct a pre‐flight

inspection and determine the UAS is in a condition for safe flight. Any

maintenance or alterations that affect the UAS operation or flight

characteristics will undergo a functional test flight prior to conducting further

operations under this exemptions.

9. The UAS will only operate within a controlled area as defined in the

Procedures. All flight operations will be conducted at least 500 feet from all

nonparticipating persons, vessels, vehicles and structures. The UAS will not

be operated by the PIC from any moving device or vehicle.

10. The operator will post advisor notice around the controlled area. All

operations shall be conducted over private or controlled‐access property

with permission from the property owner or authorized representative.

11. The operator will have been trained in operations of UAS and generally

received up‐to‐date information on the particular UAS to be operated as

required.

12. If the UAS loses communications or loses its GPS signal, the UAS will have

capability to return to a predetermined location within the Security

Perimeter and land.
13. The UAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.

14. The UAS’s are registered according to the current FAA Small UAS Certificate

of Registration requirements.

        

    Log books will be kept up‐to‐date with any maintenance or alterations to a UAS and   

accessible to any authorities.

        General Information/Public Interest     

1. The UAS will be involved in the most current and cost effective Aerial Data Collection

including remote sensing and measuring, photogrammetrics , precision geographical

surveying including infrastructure for real estate, land surveying of vacant and

developed properties to support civil engineering and other related professional

activities.

 No manned aircraft and no fossil fuels means less risk to people and the environment.

The UAS will give more data over a larger area, in less time and can result in a quicker

response time for entrance or exit strategies in the instance of a natural disaster or

other emergencies meaning more lives can be saved.

2. Aerial inspection/photography/data collection of residential/commercial utility

infrastructure for commercial/residential construction under contract with the owners

or local government authority including but not limited to wind farms and cell towers.

3. Aerial/video and/or photography for public and/or private use including television,

public events, cinematography and newsgathering.

 Keeping the public aware of what is happening in other communities near them. This

could include traffic reports, bad weather or flooding, road closures and transportation

emergencies.

4. Aerial Imaging for collecting data for environmental impact assessment studies and

management.

 The images could show harmful chemical dumping from upstream businesses. The

sooner the source location is discovered the less impact it could have downstream.

            
Summary

Cimarron Mapping Services LLC is located in a rural section of Oklahoma where UAS capabilities

are practical for commercial operations in Civil Construction by providing photogrammetry,

surveying, mapping, tracking, imaging and inspection as well as search and rescue. Being

located in an area that relies on community volunteers to provide services in case of fire,

accidents or natural disasters, UAS is the most practical and effective way to the acquire

necessary data.

I would appreciate your consideration and respectfully ask that the FAA grant the requested

exemption. If any part of this request needs to be modified, please inform this applicant on how

to amend and satisfy the requirements to equal the safety needed.

Sincerely,

 Dave Young

 Cimarron Mapping Services LLC

 2157 Bears Glen Rd.

 Cleveland, OK  74063

 Oklahoma Drivers License # L082118634

 Expiration Date 05/31/2016

 FAA Small UAS Certificate of Registration

 Certificate Holder: Dave Young

 UAS Certificate Number:  FA3L3ALYNY

 Expires 12/21/2018