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@ SITECH southms.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 112 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

................................ ................................ ..... 103 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"), Subsecti on 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 Navigati on LTD UX5, UX5 HP and ZX5

.

Background Information on the Petitioner
SITECH is a global distribution network for Trimble solutions

- the most reliable an d 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 s U AS operations proposed in this p etition will be subject to the following conditions and limitations. Each of these conditions and limitations is consistent with previously granted small s UAS Section 333 exemptions and FAA guidance. See, e.g., E xemption 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 FAA

2014

- 0804) (“Allied Drones”) . Collectively, these conditions and limitations ensure that the proposed small s UAS operations will not adversely affect safety and will provide at least an equivalent level of safety to the c urrent
rules of large manned aircraft operations.4 Juniper	Unmanned	Inc. Proposed Unmanned Aerial Vehicles

SITECH South Mississippi LLC proposes the following airc raft:

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

a pplicable manufacturer manual. SITECH South will operate its sUAS
under 400 feet A GL 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 3 rd 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. F lights will be conducted with the
consent of property owner and/or developer.

Operations not within C lass

- G airspace or above 200ft AGL , will require written approval from the FAA in the form of a Certificate or
Waiver o f 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 Miss issippi will conduct a briefing before each day's operations, which all participating personnel must attend. A risk

assessmen t 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 R equested

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 aircra ft flight manual... requirements)

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

14 C.F.R. 91.121(a ltimeter 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 2 1 Part H and 91.7(a) Given its small size, operational capabilities, and restricted area in
which the s UAS 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 s UAS satisfy the equivalent level of safety as compared with manned aircraft and meets the criteria in
section 333.

Ea ch 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 exem ption to Clayco, Exempti on 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 i ncident or accident. The risk to an onboard pilot and crew during an incident or accid ent 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
alterati ons 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 s UAS requirem ents 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
lette rs between 2 and 6 inches high as “Limited”, “Restricted”, “Light

Sport”, “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 33 3 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, n o 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 A irplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The s UAS, given its size and configuration
h as 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 s UAS 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

s UAS 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 ba rometric8 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 condu cted 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 Conditio ns, 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 sU AS 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 e xtent 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

s UAS for these flights. Even at these low altitudes, SITECH South ’ s sUA S 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 person s will be within the area of operation during fl ight

, 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 G ranting the Exemption would not Adversely Affect S afety 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 leas t 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 Exemptio n and the Astraeus Exemption.

In general, the risks of any proposed s UAS 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, pr ivate 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 sUA S at all tim es; and the condition to obtain a NOTAM before each sUAS flight ; t he
considerations for non

- participating persons or structures; the prohibition o f flights over conges ted 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 st ated 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 Fed eral 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@ SITECH southms.com