1 Juniper	Unmanned	Inc.

Name of Applicant:

SITECH South Mississippi LLC

John Stratton, General Manager

404 Highway 49 South

Richland, Mississippi 39218

601-397-6155

john.stratton@SITECHsouthms.com

Submitters Representative:

Juniper Unmanned

Attn: Matt Tompkins, Darren Robey

3490 Parfet St.

Wheat Ridge, CO 80033

Phone: 303-406-3312, 303-929-3726

matt.tompkins@juniperunmanned.com, 

darren.robey@juniperunmanned.com

Re: Petition for Exemption of SITECH South Mississippi Llc, under Section 333 of 

the FAA Modernization and Reform Act, 49 U.S.C. 44701(±), and 14 Part 11
2 Juniper	Unmanned	Inc.

Table of Contents

Request............................................................................................................ 3

Background Information on the Petitioner................................................... 3

Conditions and Limitations ............................................................................ 3

Proposed Operations ...................................................................................... 4

Exemptions Requested................................................................................... 5

14 C.F.R. Part 21 Part H and 91.7(a)............................................................. 6

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b) ............................ 6

14 C.F.R. 45.23 (b).......................................................................................... 7

14 C.F.R. 91.9 (b) (2)...................................................................................... 7

14 C.F.R. 91.121.............................................................................................. 7

14 C.F.R. 91.151(a) and (b) ........................................................................... 8

14 C.F.R. 61.113 (a) and (b) .......................................................................... 8

14 C.F.R. 91.119.............................................................................................. 9

Reasons Why Granting the Exemption would not Adversely Affect Safety

........................................................................................................................ 10

Summary for Federal Register ..................................................................... 10
3 Juniper	Unmanned	Inc.

Request

On behalf of SITECH South Mississippi LLC, we hereby seek an 

exemption from the Federal Aviation Regulations detailed below, as 

authorized by Section 333 of the FAA Modernization and Reform Act 

("Section 333"), Subsection 44701(±) of the Federal Aviation Act, and 

pursuant to the procedures set forth in Part 11 of the Federal Aviation 

Regulations, to allow SITECH South to operate the Trimble Navigation 

LTD UX5, UX5 HP and ZX5.

Background Information on the Petitioner

SITECH is a global distribution network for Trimble solutions- the most reliable and 

rugged construction technology systems available to the heavy civil construction 

contractor.

SITECH South Mississippi is a limited liability company. SITECH South Mississippi serves 

Warren, Hinds, Madison, Leake, Neshoba, and Kemper counties. 

Conditions and Limitations

The small sUAS operations proposed in this petition will be subject to the 

following conditions and limitations. Each of these conditions and 

limitations is consistent with previously granted small sUAS Section 333 

exemptions and FAA guidance. See, e.g., Exemption No. 11110 (Docket 

FAA-2014-0367) (“Trimble Exemption”); Exemption No. 11062 (Docket 

FAA-2014-0352) (“Astraeus Exemption”); Exemption No. 11109 (Docket 

FAA-2014-0507) (“Clayco Exemption”); Exemption No. 11136 (Docket 

FAA-2014-0508) (“AAS Exemption”); Exemption No. 12645 (Docket FAA2014-0804) (“Allied Drones”). Collectively, these conditions and limitations 

ensure that the proposed small sUAS operations will not adversely affect 

safety and will provide at least an equivalent level of safety to the current 

rules of large manned aircraft operations.
4 Juniper	Unmanned	Inc.

Proposed Unmanned Aerial Vehicles

SITECH South Mississippi LLC proposes the following aircraft:

Trimble Navigation Ltd UX5

Trimble Navigation Ltd UX5 HP

Trimble Navigation Ltd ZX5

Proposed Operations

SITECH South will operate the proposed aircraft to collect aerial 

imagery and video, aerial inspection of infrastructure and collection of 

data for survey purposes. 

SITECH South will operate its sUAS in full compliance with the 

applicable manufacturer manual. SITECH South will operate its sUAS 

under 400 feet AGL and within the visual line of sight of the pilot and 

visual observer. The PIC (Pilot in Command) will hold at least a 

Recreational Pilot Certificate, hold a at least a class 3 medical and be 

familiarized with the sUAS in operation. The Visual Observer will also 

hold a 3rd class medical or state issued drivers license and be 

familiarized with the sUAS being used in the operation. 

The Pilot in Command (PIC) will make himself aware of meteorological 

conditions in the area of operation. Flights will be conducted with the 

consent of property owner and/or developer.

Operations not within Class-G airspace or above 200ft AGL, will 

require written approval from the FAA in the form of a Certificate or 

Waiver of Authorization. The aircraft included in this petition comply 

with FCC signal frequencies and will be limited to 2.4Ghz, 5.8Ghz and 

900Mhz. 

SITECH South Mississippi will conduct a briefing before each day's 

operations, which all participating personnel must attend. A risk 

assessment will be conducted, evaluating obstructions and other 

potential hazards. SITECH South will file a NOTAM prior to operations. 
5 Juniper	Unmanned	Inc.

All operations will be conducted during daytime in Visual Metrological 

Conditions (VMC). 

In addition, SITECH South Mississippi will conduct a pre-flight 

inspection of aircraft and ground equipment. These inspections will be 

conducted according to manufacturer manuals. 

Under the requested exemption, SITECH South Mississippi LLC will operate its sUAS 

within the United States.

Exemptions Requested

14 C.F.R. Part 21 (h) (airworthiness certification)

14 C.F.R. 45.23(b) (marking of the Aircraft)

14 C.F.R. 61.113(a) and (b) (private Pilot Privileges and Limitations)

14 C.F.R. 91.7(a) (b) (civil aircraft airworthiness)

14 C.F.R. 91.9(b) (2) (civil aircraft flight manual... requirements)

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes)

14 C.F.R. 91.121(altimeter settings)

14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions)

14 C.F.R. 91.405(a) and (b) (maintenance required)

14 C.F.R. 91.407(a)(1) (operation after maintenance)

14 C.F.R. 91.409(a) (inspections)

14 C.F.R. 91.417(a) and (b) (maintenance records)
6 Juniper	Unmanned	Inc.

14 C.F.R. Part 21 Part H and 91.7(a)

Given its small size, operational capabilities, and restricted area in 

which the sUAS will operate, an exemption from Part 21, Subpart H, 

Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as 

SITECH South Mississippi LLC sUAS satisfy the equivalent level of 

safety as compared with manned aircraft and meets the criteria in 

section 333. 

Each sUAS (including payload) is less than 55 pounds, carry no 

explosive materials or flammable liquid fuels, and would operate 

outside controlled airspace, with no passengers or crew on board. As 

the FAA has found in granting an exemption to Clayco, Exemption No. 

11109, page 10.

The limited weight significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event 

of an incident or accident. The risk to an onboard pilot and crew 

during an incident or accident is eliminated with the use of a sUAS for

aerial operations.

91.405(a), 91.407(a)(1), 91.409(a)(1)(2),91.417(a)(b)

In support of ENTER NAME’s request for an exemption from 14 C.F.R. 

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

ENTER NAME will adhere to the following inspection and maintenance 

program: 

SITECH South Mississippi LLC must carry out its maintenance, 

inspections, and record keeping requirements in accordance with the 

aircraft manufacturer manuals. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight 

hours, description of work accomplished, and the signature of the 

authorized sUAS maintenance personnel returning the sUAS to service.

SITECH South will follow the manufacturer's sUAS requirements 

relating to components, maintenance, overhaul, replacement, 

inspection and life limits. 
7 Juniper	Unmanned	Inc.

14 C.F.R. 45.23 (b)

Section 45.23(b) requires that certain experimental, provisionally 

certified aircraft or light-sport category aircraft to be marked with 

letters between 2 and 6 inches high as “Limited”, “Restricted”, “LightSport”, “Experimental”, or “Provisional” near each entrance to the 

cabin, cockpit or pilot station. The sUAS included in this exemption will 

have no airworthiness certificate, should this 333 exemption be 

approved, is not of a size on which 2 inch lettering is possible and 

does not have a cabin or pilot station on which the word 

“Experimental” can be placed. For these reasons, SITECH South

respectfully requests an exemption from this regulation.

14 C.F.R. 91.9 (b) (2) 

Section 91.9 (b) (2) requires that, no person may operate a U.S.-

registered civil aircraft ... (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, and placards, or 

any combination thereof. The sUAS, given its size and configuration 

has no ability or place to carry a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate 

access to it. For these reasons, SITECH South respectfully requests an 

exemption from this regulation.

14 C.F.R. 91.121

SITECH South Mississippi’s sUAS are equipped with a GPS altimeter.

Information such as, real-time telemetry data, altitude, speed, and 

sUAS attitude are displayed to operators.

Moreover, the sUAS will be operated within the visual line of sight of 

the pilot in command and visual observer and below 400 feet AGL. 

Because the proposed aircraft are not equipped with a barometric 
8 Juniper	Unmanned	Inc.

altimeter, and instead use a GPS altitude, the ability to maintain 

required altimeter settings outlined in 14 C.F.R. 91.121 is not feasible. 

Therefore, relief from 14 C.F.R. 91.121 is requested. 

14 C.F.R. 91.151(a) and (b)

In support of SITECH South’s request for an exemption from 14 C.F.R. 

91.151(a) and (b), the proposed sUAS are battery-powered and are 

operated for a maximum 25 minutes, this makes the fuel requirements 

of 14 C.F.R. 91.151(a) and (b) impossible to meet. All operations will 

be conducted according to manufacturer recommended battery flight 

times. 

14 C.F.R. 61.113 (a) and (b)

SITECH South requests an exemption from 14 C.F.R. 61.113 (a) and 

(b) to the extent necessary to permit SITECH South to conduct 

commercial sUAS operations using PICs who hold, at least, an FAA 

recreational pilot certificate. SITECH South requests that the FAA 

exempt SITECH South and its PICs from this requirement since the 

use of a recreational pilot as the PIC for the sUAS operations under 

this exemption will be as safe or safer than the use of a commercial 

pilot for manned aircraft operations. Unlike conventional aircraft, the 

sUAS proposed in this exemption are remotely controlled, operated in 

Visual Metrological Conditions, with no crew or passengers on board, 

below 400ft AGL, are low weight, and battery-powered. The fulfillment 

of the additional requirements for a recreational pilot to become 

qualified as a commercial pilot would not lead to any additional safety 

benefits when sUAS operations are involved.
9 Juniper	Unmanned	Inc.

14 C.F.R. 91.119

SITECH South Mississippi LLC seeks an exemption from the 

requirement in 14 C.F.R. 91.119, subsection (b), that an aircraft must 

remain at least 1,000 feet above any congested area or open air 

assembly of persons, and subsection (c), that an aircraft must remain 

at least 500 feet above any person or structure in an area other than 

populated or congested, and not closer than 500 feet to any person, 

vehicle, or structure. SITECH South requests an exemption from this 

regulation to the extent necessary to permit SITECH South to conduct 

its sUAS operations at altitudes lower than those permitted by 14 

C.F.R. 91.119, since such altitudes are one of the key benefits of using 

sUAS for these flights. Even at these low altitudes, SITECH South’s

sUAS operations will be conducted at a level of safety at least equal to 

that which would be achieved by larger manned aircraft.

SITECH South will make every reasonable effort to ensure that no 

unauthorized persons will be within the area of operation during flight, 

and will provide notice to adjacent buildings and furnish proctors as 

may be necessary to ensure that unauthorized persons do not come 

within the parameters in which the sUAS will be operated. Combined 

with the technological capabilities of the sUAS and that the sUAS will 

be operated within the visual line of sight of the pilot and observer, 

SITECH South submits that its operational limitations provide an 

equivalent level of safety to that provided in 14 C.F.R. 91.119.
10 Juniper	Unmanned	Inc.

Reasons Why Granting the Exemption would not Adversely Affect Safety

Throughout this Petition, SITECH South Mississippi has explained 

many reasons why granting an exemption from each section of the 

FAR from which relief is sought would result in sUAS operations that 

provide a level of safety at least equal to, or greater than, that 

provided by the rule from which exemption is sought. 

Moreover, the many conditions and limitations proposed in this 

Petition also ensure at least an equivalent level of safety, as the FAA 

concluded in the Trimble Exemption and the Astraeus Exemption. 

In general, the risks of any proposed sUAS operation interfering with a 

manned aircraft is minimized by the low altitude at which the sUAS 

will operate; the locations at which the sUAS will operate (e.g., Class 

G airspace, private or controlled access property, away from airports); 

the small size/low weight and relatively slow speed of the sUAS; the 

restriction of sUAS operations to VMC and daytime conditions; the 

requirement for the PIC to maintain VLOS of the sUAS at all times; 

and the condition to obtain a NOTAM before each sUAS flight; the 

considerations for non-participating persons or structures; the 

prohibition of flights over congested or densely populated areas, 

among other conditions and limitations. These parameters, conditions, 

and limitations proposed in the Petition provide substantial protection 

against interference with manned aircraft operations or with the safety 

of persons or property on the ground. In addition, under the proposed 

conditions and limitations stated above, SITECH South Mississippi will 

coordinate, as warranted, with the FAA, with local airports, and with 

property owners to ensure that all sUAS operations under the 

exemption are at least as safe as manned aircraft operations used for 

similar purposes.

Summary for Federal Register

Should the FAA determine that publication of a summary is required, 

SITECH South Mississippi submits the following summary to be 

included in the Federal Register:
11 Juniper	Unmanned	Inc.

SITECH South Mississippi seek an exemption to operate the Trimble 

Navigation Ltd UX5, UX5 HP and ZX5 small unmanned aircraft systems

to perform aerial data collection for inspection, survey, photographic 

and video services.

Sincerly,

John Stratton, General Manager

SITECH South Mississippi LLC

404 Highway 49 South

Richland, Mississippi 39218

601-397-6155

john.stratton@SITECHsouthms.com