# THOMAS 

# & HUTTO-N

50 PARK OF COMMERCE WAY I SAVANNAH, GA 31405 912.234.5300 I WWW.THOMASANDHUTTON.COM

U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJersey Avenue, SE Washington, DC 20590 October21, 2015 ··-·;- -.. r. -.

·- I

Re: Request for exemption status of multiple federal regulations under Section 333 of the FAA Modernization and Reform act of 2012 and Title 14 of the Code of Federal Regulations (C.F.R.) in order to provide aerial surveying and photography services using small, unmanned aerial vehicles.

DearSiror Madam: Thomas & Hutton is submitting the following petition in order to lawfully provide better services to our clients and respectfully requests your consideration in granting an exemption from certain provisions of Title 14 of the Code of Federal Regulations. Within this petition, Thomas & Hutton has included Appendix A which is a summary for publication in the Federal Register, Appendix Bwhich describes the UAV's being proposed for use, Thomas & Hutton's preflight safety checklist and operation and maintenance manuals specific to the UAV's being requested for use within the petition. Thomas & Hutton is a privately held, professional services company providing engineering, surveying, planning. Geographic Information Systems (GIS) and consulting services to public and private clients. Since 1946, Thomas & Hutton has been designing award-winning projects and building strong client relationships. Our passion continues to be creating the highest quality designs and makingclient needsourforemost priority. Thomas & Hutton has locations in Savannah and Brunswick, Georgia, as well as Charleston, Columbia, Greenville and Myrtle Beach, South Carolina, giving us an intimate knowledge of specific design and permitting requirements of the Southeast; and general expertise has allowed us todesign projects across the globe. Thomas & Hutton is proposing the use of three specific small unmanned aerial vehicles to perform various engineering related tasks. The DJI Inspire 1will be used as the primary video and photography UAV while the DJI Phantom 2will be used as a back up to the Inspire 1. The DJI S900 and the Geoblu Surveyor 600 will be used for specific geospatial services related to land planning, surveying and mapping. Detailed specifications for each of the UAV's mentioned above can be found in Appendix B.U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page2

NAME AND ADDRESS OF THE PETITIONER 

### IS:
Petitioner: Thomas & Hutton Benny K. Jones, Jr., P.E. Attn: Address: 50 Park ofCommerce Way, Savannah, Georgia 31405 Office (912) 234-5300 1 Mobile (912) 21Q-0463 jones.b@thomasandhutton.com Phone: Email:

REGULATIONS:
Thomas & Hutton is requesfing relieffrom thefollowing sections:
In orderto provide betterservices to ourclients, weare requesting implementation ofsmall UAVs whichwould require the following exemptionsfrom Title 14 ofthe C.F.R.


## • 14 CFR Part 21 

## • 14 C.F.R. 45.23(b) 

## • 14 CFR 61.113 (a) & (b) 

## • 14 C.F.R. 91.7 (a) 

## • 14CFR9l.9 (b) (2) 

## • 14 C.F.R. 91.103 

## • 14 C.F.R. 91.109 

## • 14 C.F. R. 91.119 

## • 14 C.F.R. 91.121 

## • 14 CFR 91.151 

## • 14 CFR 91.203 (a) & (b) 

## • 14 CFR 91 .405 (a) 

## • 14 CFR 407 (a) (1) 

## • 14 CFR 409 (a) (l) & (2) 

## • 14 CFR 417 (a) & (b)
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Petitioner, an exemption from Part 21 Subpart Hmeets the requirements of an equivalent level ofsafety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAV. In all cases, an analysis of these criteria demonstrates that the UAV operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page3

The sUAV proposed for use by Thomas & Hutton is less than 55 pounds fully loaded, carries neither a pilot nor passenger(s), carries no explosive materials or flammable liquid fuels, and operates exclusively within approved areas. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator in compliance with local public safety requirements. The sUAV proposed for use by Thomas 

### & Hutton will provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

14 C.F.R. 

### § 45.23 (b). Marking of the Aircraft The regulation requires: 

### When marks include only the Roman 

### capital letter "N" and 

### the registration numberis displayed on limited, restricted orlight-sport categoryaircraft, orexperimental orprovisionallycertificated aircraft, the operator must a/so 

### display on that aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 

### inches normore than 6 

### inches high, the words "limited," "restricted," "light-sport," "experimental,"or"provisional,"as 

### applicable. Due to the size of the sUAV requested for use, there is not enough surface space to adhere two inch lettering. The sUAV will be marked "Experimental" as large as possible and will be placed on the fuselage in compliancewith §45.29 (f).

14 C.F.R. 

### § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command This regulation states: 

### (a) Except as 

### provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as 

### pilot in command 

### of an 

### aircraft that is carrying passengers orpropertyforcompensation orhire; normay 

### thatperson, forcompensation orhire, actas 

### pilotin command 

### ofan aircraft. (b) A 

### private pilot may, for compensation orhire, actas 

### pilot in command 

### ofan aircraft in connection with anybusiness oremploymentif: (I) The flightis onlyincidental to thatbusiness oremployment; and (2) The aircraftdoes 

### notcarrypassengers orpropertyforcompensation orhire. The sUAV's being proposed for use byThomas & Hutton do not carry a pilot or passenger(s) nor property. The primary purpose of the proposed sUAV's is for aerial photography and videography, surveying, and inspection and evaluation of civil related infrastructure such as, but not limited to roads, utilities, cellular, radio and water towers and will do so for hire or compensation. The risk associated with this work is far less than that of a commercial pilot carrying passengers and/or property. Because of this, the proposed operations can be achieved with the same level of safety by the Pilot in Command operating under a private pilot's license.U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page 4

14 C.F.R. §91.7(a): Civil aircraft airworthiness This regulation states: a) No person mayoperate a civilaircraft unless itis in an airworthycondition. The regulation requires that no person may operate a civil aircraft unless it 1s 1n airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Thomas & Hutton proposes to follow the manufacturer's operation and maintenance manual as well as the flight safety check list prior to each flight in order to maintain the sUAV's airworthiness and equivalent level o·f safety.
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft This regulation states: (b) No person mayoperate

### a U.S.,-egisteredcivilaircraft- (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, andplacards, or anycombination thereof. The sUAV, given its size and configuration, has no abilityorplace to carrysuch a flight manual on the aircraft; not only because there is no pilot on board, but because there is no room or capacityto carrysuch an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control pointwhere the pilot flying the sUAVwill have immediate accessto it.

14 C.F.R. § 91.103: Preflight action This regulation states: Each pilot in command shall, before beginning a flight, become familiar with all available information concerning thatflight. This information mustinclude- (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advisedbyATC; (b) Forany flight, runway lengths at airports ofintended use, and the following takeoffand landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoffandlanding distance data is required, the takeoffandlanding distance data contained therein: andU.S. DepartmentofTransportation Docket ManagementSystem October21. 2015 Page 5
(2) For civil aircraft other than those specified in paragraph (b)(1) of this section. other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraftgross weight. and windand temperature. Because an FAA approved rotorcraft flight manual will not be provided for the proposed aircraft. an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements. landing and takeoff distances. and aircraft performance data before initiation of flight. An equivalent level ofsafetywill be provided.

14 C.F.R. §91.109: Flight instruction This regulation states: (a) No person may operate a civil aircraft (except a manned free balloon) that is being used forflightinstruction unless thataircrafthas fully functioning dualcontrols. Small UAV's and remotely piloted aircraft. by their design, do not have fully functional dual controls. Flight control is accomplished through the use of

### a control box that communicateswith the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for 

### a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K and 9862A. The equivalent level of safetywill be provided bythe fact that neither

### a pilot nor passengers will be carried in the aircraftand bythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum safe altitudes This regulation states: Except when necessary for takeoff or landing. no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases. the aircraft may not be operatedcloser than 500 feet to anyperson. vessel. vehicle. orstructure. Thomas & Hutton is requesting relief from Section C in order to·provide services related to aerial photography and videography, surveying and inspection. and evaluation of civil related infrastructure such as. but notlimited to. roads, utilities, cellular. radio and watertowers. As set forth herein. except for the limited conditions stated in the Manual. the UAV will never operate at higher than 500 feet above ground level (AGL). It will however be operated in a restricted area with security perimeter. where buildings and people will not be exposed to operationswithout their pre-obtained consent. The equivalent level of safety will be achieved given the size. weight. speed of the UAV as well as the locationwhere it is operated. Noflight will be takenwithout the permission ofthe property owner or local officials. Because of the advance notice to the property owner and participantsU.S. DeportmentofTransportation Docket ManagementSystem October21, 2015 Page 6

of the service being provided, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcroft weighting for more than the maximum 55 pounds proposed herein and the lock of flammable fuel, any risk associated with these operations is for less than those presently presentedwith conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAV will ensure separation between these smoii-UAV operations and the operations of conventional aircraft that must complywith Section91 . 119.

14 C.F.R. §91.121 Altimeter Settings This regulation states: 

### (a) Each person operating an aircraftshallmaintain the cruising altitude orflight level ofthat aircraft, as the case maybe, byreference to an altimeter that is set "to the elevation of the departure airportoran appropriate altimetersetting available priorto departure." The proposed sUAV's do not hove a barometric altimeter, but instead a GPS altitude read out, so on exemption is requested. An equivalent level of safety will be achieved by the operator, pursuant to the operation manual and safety check list, confirming the altitude ofthe launch site shown on the GPS altitude indicatorpriorto takeoff.

14 C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions This regulation states: 

### (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intendedlanding and, assuming normalcruising speed- (I) During the day, to flyafterthatforatleast30 minutes: or (2) Atnight, to flyafterthat foratleast45 minutes. {b) 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 to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 

### 20 minutes. The battery powering the proposed sUAV provides approximately 25 minutes of powered flight which does not meet the 30 minute reserve requirement in 14 CFR §91.151. Given the limitations on the UAV's proposed flight area and the location of its proposed operations within a predetermined area, on adjusted time frame for flights in daylight is requested. No night flights will be performed byThomas & Hutton. Thomas & Hutton believes that on equivalent level of safety con be achieved by limiting flight durations to 75% of battery power, allowing a 25% battery reserve for safe landing purposes. This restriction would be more than adequate to return the sUAV to its planned landing zone from anywhere in its limited operating area. Failsafe features ore built into the sUAV's firmware to ensure flight times do not extend beyond the remaining predetermined battery power.

### U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 

### Page 7

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

### This regulation states: (a) Except

### as providedin §91.715, noperson 

### may operate a civilaircraft unless ithas within it the following: (I) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flightpermit. a copy ofthe applicable operations specifications issued under§21.197(c) of this chapter, appropriate sections of the aircarriermanualrequired byparts 121 and 135 of this chaptercontaining thatportion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an 

### assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number that has been affixed to an aircraft, mayonly

### be obtained upon application to an FAA FlightStandards district office. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph {a) of this section or a special flight authorization issued under §91.715 

### is displayed atthe cabin orcockpitentrance 

### so thatit

### is legible to passengers orcrew. 

### The proposed sUAV fully loaded weighs no more than 55 

### pounds and is operated without an onboard pilot. Because of this, there is no ability or place to carry certification and registration· documents orto displaythem on the sUAV. An es:Juivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAV will have immediate access to them. to the extent theyare applicable to the sUAV.

14 C.F.R. §91.405 (a): Maintenance Required 

### This regulation states: Each owneroroperatorofan aircraft- (a) Shall have that aircraft inspected 

### as prescribed in subpart E of this part and shall between required inspections, except

### as provided in paragraph (c) of this section, have discrepancies repaired

### as prescribedin part43 ofthis chapter: 

### Thomas & 

### Hutton is requesting an exemption from section 14 

### C.F.R. §91.405 

### (a) because currently the FAA has not published maintenance standards that would allow the operator to meetthe maintenance requirements.

### U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page8

14 C.F.R. §91.407 (a) (1): Operation after maintenance, preventive maintenance, rebuilding, or alteration 

### This regulation states: (a) No person may operate any aircraft that has undergone maintenance. preventive maintenance. rebuilding. 

### oralteration unless- 

### (I) It has been approved forreturn to service bya person authorized under §43.7 of this chapter; 

### Currently there are no authorized personnel approved by the FAA to authorize the sUAV's return to service under this regulation as it relates to maintenance. preventative maintenance. rebuilding or alterations. Thomas & 

### Hutton proposes to follow the manufacturer's maintenance manual. For major repairs. Thomas & 

### Hutton will use repair facilities of. or suggested by. the manufacturer.

14 C.F.R. §91.409 (a) (1) and (2): Inspections 

### This regulation states: (a) Except as provided in paragraph (c) of this section. no person may operate an aircraft unless. within the preceding 12 calendarmonths. ithas had- (I) It has been approved forreturn to service bya person authorized under§43.7 of this chapter; and (2) An inspection for the issuance ofan airworthiness certificate in accordance with part21 ofthis chapter. 

### Reason for request for relief: Currently there are noauthorized personnel approved by the FAA to inspect the sUAV's every 12 months before returning to service as described in this section. Thomas & 

### Hutton proposes to follow the manufacturer's operation and maintenance manual and pre-flight safety checklist priortoeveryflight.

14 C.F.R. §91.417 (a) and (b): Inspections 

### This regulation states: (a) Except for work performed in accordance with §§91.411 and 91.413. each registered owner

### oroperatorshall keep the following records. for the periods specifiedin paragraph (b) ofthis section: (I) Records of the maintenance. preventive maintenance, and alteration and records of the 100--hour. annual. progressive. and other required 

### or approved inspections. 

### as appropriate. for each aircraft (including the airframe) and each engine. propeller. rotor. andappliance ofan aircraft. The records mustinclude-

### U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page9

(i) A description (or reference to data acceptable to the Administrator) of the workperformed; 

### and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature, andcertificate 

### numberofthe person approving the aircraft forreturn to service. (2) Records containing the following information: (i) The total time in service ofthe 

### airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts of

### each airframe, engine, propeller, rotor, 

### andappliance. (iii) The time since last overhaul ofall items installed on the aircraft which 

### are required to be overhauledon a specified time basis. (iv) The current inspection status of the aircraft. including the time since the last inspection required by the inspection program under which the aircraftandits appliances are maintained. (v) The current status of applicable airworthiness directives (AD) 

### and safety directives including, for each, the method of compliance, the 

### AD or safety directive number and revision date. If the 

### AD or safety directive involves recurring action, the time 

### and date when the next action 

### is required. (vi) Copies ofthe forms prescribed by §43.9(d) of this chapterfor each major alteration to the airframe 

### and currentlyinstalled engines, rotors, propellers, andappliances. (b) The owneroroperatorshallretain the following records for the periodsprescribed: (I) The records specifiedin paragraph (a)

### (I) ofthis section shall be retained until the work 

### is repeated or superseded by other work or for 

### I year after the work 

### is performed. (2) The records specified in paragraph (a}{2) of this section shall be retained and transferred with the 

### aircraftat the time the aircraft

### is sold. (3) A list ofdefects furnished to 

### a registered owner or operator under §43. 

### II of this chapter shall be retained until the defects 

### are repaired 

### and the 

### aircraft is approved forreturn to service. 

### Thomas & 

### Hutton believes that because the sections mentioned above (and Part 43) only apply to aircraft with an airworthiness certificate, an exemption is applicable. Thomas & 

### Hutton will document all maintenance and repairs as directed by the manufacturer's operation and

### U.S. DepartmentofTransportation Docket ManagementSystem October21, 2015 Page10

maintenance manual as well maintain copies of repair records for the duration of the life of the sUAV.
In conjunction with the requested exemptions above. Thomas & 

### Hutton agrees to the following operational limitations suggested bythe FAA's Small UAV NPRM:



### • •



### •

•

• 

### • •

• • 

### • • 

### • • •

• • • Unmanned aircraft mustweigh less than 55 lbs. (25 kg)

. Visual line-of-sight (VLOS) only; the unmanned aircraft must remai,n within VLOS of the operatororvisual observer. At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device. otherthan corrective lenses. Small unmanned aircraft may not operate over any persons not directly involved in the operation. Daylight-onlyoperations (official sunrise to official sunset, local time)

. Mustyield right-of-wayto otheraircraft. manned orunmanned

. First-person view camera cannot satisfy "see-and-avoid" requirement but can be used as long as requirement is satisfied in otherways. Maximum airspeed of 100 mph (87 knots)

. Maximum altitude of 500 feet above ground level. Minimumweathervisibility of three (3) miles from control station

. No operations are allowed in Class A (18.000 feet & 

### above) airspace

. Operations in Class B. C. D and Eairspace are allowedwith the required ATC permission

. Operations in Class G airspace areallowedwithout ATC permission

. No person may act as an operator or VO for more than one unmanned aircraft operation at one time. Nocareless or reckless operations

. Requires preflight inspection bythe operator. A person may not operate a small unmanned aircraft if he orshe knows or has reason to know of any physical or mental condition that would interfere with the safe operation of · a small UAV.
Public benefit as a whole: 

### By granting Thomas & 

### Hutton an exemption to the above provisions of Title 14 of the Code of Federal Regulations. Thomas & 

### Hutton will be able to safely. efficiently, and economically provide commercial services to theirclients while providing an equivalent level ofsafety. Much of the work that Thomas & 

### Hutton is involved in ties to local. state. and federal projects requiring financial supporttypicallyfunded bytaxdollars. The use ofthe sUAVwill limit the amount of time employees and sub-consultants are needed to perform the tasks associated with these type of projects. In turn. this decrease in manpower will limit associated risks with job as well as loweroverall costs which in turn can bepassed alongtothe tax payers.U.S. DepartmentofTransportation ·Docket ManagementSystem October21, 2015 Page 11

Due to lower costs associated with using a sUAV, Thomas & Hutton is able to perform inspection and evaluation flights more frequently during the construction process and in turn, provide timely inspections indicting potentialdefects priorto public use. Limiting the use of conventional aircraft to perform frequent photography and site inspections will be a benefit to the public by eliminating the risk of large scale accidents as well as noise and air pollution. Small UAV's are lightweight, virtually silent, and pose a much smaller risk in the event of anaccidentdueto the lackofflammablefuels and excessiveweight. Reasons the exemptions would not adversely affect safety or how the exemption would provide a level of safety at least equalto the existing rule:
1. Flights performed byT&H will be conducted overclient owned land; generally lowto nonpopulated areas. 2. Clients will be made aware of scheduled flights and all personnel within the property will beawareof UAV flights. 3. Flights will beconducted atrelativity lowaltitudes no higherthan500 feet AGL.
4. T&H will conductdayflights only. Nightflights will bestrictly prohibited.
5. T&H will use a visual observer (YO) atall times. 6. T &H will fly the UAVwithin a visual line ofsight (VLOS).
7. T&H will perform preflight inspections beforeeveryflight. 8. Preflight safety checks and inspections will be performed and documented prior to all flights.

BTR/kts Enclosures Sincerely,

# THOMAS~z;p

# ~K. Jones. Jr.

### Appendix A 

### (Federal Register Publication Summary)

Petitioner: Thomas & Hutton Exemptions requested:


## • 14 CFR Part 21 

## • 14 C.F.R. 45.23(b) 

## • 14 CFR 61.113 (a) & (b) 

## • 14 C.F.R. 91.7 (a) 

## • 14 CFR 91.9 (b) (2) 

## • 14 C.F.R. 91.103 

## • 14 C.F.R. 91.109 

## • 14 C.F. R. 91.119 

## • 14C.F.R.91.121 

## • 14 CFR 91.151 

## • 14 CFR 91.203 (a) & (b) 

## • 14 CFR 91.405 (a) 

## • 14 CFR 407 (a) (1) 

## • 14 CFR 409 (a) (1) & (2) 

## • 14 CFR 417 (a) & (b) Description of Requested Relief: Pursuant to 14 C.F.R. Part 11. the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitionerseeks an exemption from the following rules:
14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151 (a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned aerial vehicle (551bs or less) in engineering related operations. Approval of the exemptions requested above would allowthe petitionerto perform commercial operations as it relates to the field of civil engineering while decreasing many of the risks associated with conventional aircraft. The use of helicopters and fixed-wing aircraft limits the ability to obtain close up inspection video and photographs, presents an increase in risk associated with this type of aircraft due to their size, weight and fuel as well as increases the overall cost and scheduling associated with using this type of aircraft. Conventional aircraft require physical operators to be on board during the flight which in turn adds risk to the loss of life in the eventofan accident. In comparison, the small unmanned aerial vehicles proposed for use weigh less than 55 lbs., do not carry combustible fuels and do not require the physical presence of a pilot or passenger to aid in the flight. Transportation of the sUAV to and from the site is done by automotive transportationwhich limits the cost and risks associatedwith flying to and from a specific site. The operation of small UAVs, weighting less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safetysupporting the grantofthe exemptions requested herein, including exempting the petitioner from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conductedwith traditional aircraft.

### Appendix 8 

### (Unmanned Aerial Vehicles Planned for Use)
Manufacturer: DJI Model #T600- Inspire 1 Weight (with Battery): 6.5 LBS MaxSpeed: 

### 49.2 MPH Max Flight Altitude: 400' AGL Max Flight Time: 18 Minutes

### Appendix B

### (Unmanned Aerial Vehicles Planned for Use)
Manufacturer: DJI Model

### # T 600 Phantom 2: Weight (with Battery and GoPro Camera): 

### 2.7 LBS Max Speed: 

### 33.6 MPH Max Flight Altitude: 400' AGL Max FlightTime: 25 MinutesManufacturer: DJI Model

### # Spreading Wings S900 Weight (with Battery and Camera): 18 LBS Max Flight Altitude: 400' AGL Max FlightTime: 18 Minutes

### Appendix B(Unmanned Aerial Vehicles Planned for Use)
Manufacturer: Geoblu Model: Surveyor 600 Weight: 8.5 Lbs Max Speed: 35 MPH Max Flight Altitude: 400' AGL Max Flight Time: 12 Minutes 

# SURVEYOR600 UAVAERIAL MAPPING SOLUTION

6RotorY-Frame Configuration

AUW (all upweight): 8.5 lbs Wheelbase (tip-to-tip): 650mm Powerplant: 6brushless motors, 580kv, coaxial configuration Maxspeed: 35mph Featuring: Waypoint Navigation Control Ground StationApp/iPad Mini (included) GPS Point-of-Interest Flight Return-to-Home

- Failsafe GraupnerMX-20; 12channel TX/RX Stabilized Camera Gimbal

- providing "motion-free" imagery 7" LCD Monitorw/tripod (59")- offering"Thru the LensViewing" Remote ShutterTrigger 3-10,000mah Flight Batteries DC BatteryCharger/ PowerSupply/BatteryChecker PelicanTransportCase "Hubsan" quadcoptertrainer Bench/FlightTested ··camera Package included SonyA6000-24mpcamera Sony 16mmfixedfocal lens 2extra batteries

# i!i THOMAS 

# & HUTTON UAV Preflight Inspection Log Project 

## I Job Number: Location: Date:

In Office Prep

## I Inspection: Area to be flown -is itwithin 5 miles ofairport? permission tofly; make note ofATe's name, dateand time permission is granted. Obtain permission in writing (email) when possible Batteries Charged- Both UAV and Radio Controller GoPro Camera- batteries charged (Phantom 2) MemoryCard- emptyand extra cards in case? Extra blades in case? Battery charger and cables in case? Confirm that all parties involved are aware ofplanned flight
==VISUALLY INSPECTTHE AIRFRAME == Cracks (especially in high stress areas likejoints) Loose or damaged screws 

### I fasteners 

### I bands 

### I straps 

### I ties Loose ordamaged wiring Loose ordamaged connections (solder, plugs, etc) Inspect prop mounts & screws & apply slight counter pressure on arms tocheck for loosened construction For FPV, inspect/clean FPV and/orGopro camera lens and ensure that cameras are secured Battery/batteries fully charged, properlyseated & secured Props are smooth and free ofdamage/defect (check blade, surface, & hub) Tighten prop adapters (careful notto overtighten which maydamage prop) On Site

- Preflight Check

== POWER UP== Verify all transmittercontrols move freely in all directions Verify transmitterthrottle to zero Scan for nearby people oranimals Position UAV on level ground, clear ofobsticals Power on UAV, Radio Controller,Tablet (or LCD and GoPro) Verify battery in UAV, Radio Controller and Tablet

### I LCD is fully charged and secure Ensure LED indicators and audibletones are correct Stand clear- audibly, loudlyannounce theword "CLEAR!" ==TAKE OFF== Increase throttleslightly listeningfor any abnormalities Short 20-30 second hoverat3-5 feet