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Water Mapping, LLC

Oscar Garcia-Pineda

1240 Greensward Dr.

Tallahassee, FL 32312

(361) 244-6575

oscar.garcia@watermapping.com

January 8, 2016

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., 

SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Madam, Sir,

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

and 14 CFR Part 11 of Small Unmanned Aircraft Systems (sUAS), Water Mapping, LLC hereby 

applies for ·an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation of Designated sUAS, provided such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

All of these limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure specifically, a safety enhancement to aerial 

imagery and videography conducted by manned aviation operations where WaterMapping LLC 

will work. 

The use of Small Unmanned Aerial Systems (“sUASs”) for aerial imagery and videography by 

WaterMapping, LLC reduces the need to use manned aircraft activities to perform the same 

function. Furthermore, the ability to use sUASs reduces the exposure risk to personnel operating 

in a hazardous environment by negating the need to make reconnaissance entries into areas 

without adequate intelligence. Therefore, it is in the best interest of the Public for the FAA to 

approve the requested exemptions.

We appreciate the attention to this petition. The name and address of the applicant is:

Oscar Garcia-Pineda

Water Mapping, LLC

Director

(361) 244-6575

1240 Greensward Dr. 

Tallahassee, Florida. 32312
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Table of Contents 

1. Glossary of Abbreviations 3

2. List of Attachments 3

3. Introduction and Interest of Petitioner 4

4. Unmanned Aerial Systems 5 

5. Unmanned Aircraft Pilot in Command (PIC) 8

6. Operation of sUAS 9

7. Requested Exemptions from Regulations 13

8. Public Interest 15

9. Conclusion 16
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1. Glossary of Abbreviations 

AGL Above Ground Level 

ATC Air Traffic Control 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System 

NOTAM Notice To Airmen 

PIC Pilot in Command 

PQS Personnel Qualification System 

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SOP Standard Operating Procedures 

sUAS Small Unmanned Aircraft Systems 

VFR Visual Flight Rules 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VLOS Visual Line of Sight

2. List of Attachments

DJI Phantom 2 Operating Manual

DJI S1000 Operating Manual
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3. Introduction and Interest of Petitioner 

With more than 20 years of experience in the field, WaterMapping, LLC provides high-quality 

geoscience services for private and public sector clients. WaterMapping, LLC provides services in 

the areas of GIS and remote sensing, deep-water geophysical exploration of energy resources, 

assessment and monitoring of the coastal and marine environments. We thrive to participate 

intensively with academic institutions as well as with federal agencies such as NOAA, BSEE, 

BOEM, and NASA on a wide range of research projects. We have extensive operational 

experience conducting multidisciplinary surveys in support of coastal and marine environmental 

programs to map and collect physical and biological samples from beaches, marshes, water 

columns, the ocean surface, and the seabed. Projects may include collection of data in difficultto-reach places, and we help our clients to design effective survey paths with our remote 

sensing and aerial photo surveys. WaterMapping, LLC does not currently have any FAA approved 

COAs. However, we will be filing following this exemption request. 

WaterMapping, LLC will provide on-demand commercial UAS operations for public and private 

sectors clients including the following applications below:

• Aerial Videography & Photography/Mapping/Assessment

• Agriculture Survey and Assessments

• Real Estate Videography & Photography/Mapping/Assessment

• Oil Spill Response & Planning Mapping/ Inspection/Assessments

• Offshore Platform Inspection/Assessments

• Pipeline Mapping/ Inspection/Assessments

• Refinery Mapping/ Inspection/Assessments

• SPCC Spill Prevention Control and Countermeasures Mapping/ Inspection/Assessments

• Damage Assessment

• Public Safety Mapping/ Inspection/Assessments/Search and Rescue

• Wind Farm Inspections

So long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. As detailed in this document, the 

requested exemption would permit the operation of sUAS under controlled conditions in 
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airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide 

safety enhancements to the already best practices safety protocols followed by UAVRG, LLC. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.

4. Unmanned Aerial Systems 

General Information Pertaining to All Proposed sUAS 

WaterMapping LLC will operate less than fifty five pound sUAS, with the ability to conduct aerial 

imagery and videography, with payloads capable of supporting this mission. 

Prior to each flight, the PIC shall inspect the sUAS to ensure it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will be 

prohibited from operating until the necessary maintenance has been performed and the sUAS is

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in aircraft 

records. All discrepancies noted shall be documented as described in the WaterMapping, LLC

Health and Safety Plan.

Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics, e.g. replacement of a flight critical component, shall undergo a functional 

test flight in accordance with the manufacturer’s manual and the WaterMapping, LLC Health 

and Safety Plan. The PIC who conducts the test flight shall make an entry in the sUAS aircraft 

logbook of the flight.

WaterMapping, LLC shall follow the manufacturer’s sUAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention to flight 

critical components that may not be addressed in the manufacturer’s manuals.
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WaterMapping, LLC shall carry out their maintenance, inspections and record keeping 

requirements, in accordance with the operator’s manual. Maintenance, inspection, and 

alterations must be noted in the aircraft log book, including total flight hours, description of 

work accomplished, and the signature of the authorized maintenance technician returning the 

sUAV to service.

Each sUAS operated under the proposed exemption shall comply with all manufacturer System 

and Safety Bulletin.

WaterMapping, LLC technicians will receive and document training referenced in the 

manufacturer’s operations manual. WaterMapping, LLC technicians shall make a record entry in 

the sUAS logbook or equivalent document of the corrective action taken against discrepancies 

discovered between inspections. Before conducting operations, the radio frequency spectrum 

used for operation and control of the sUAS shall comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency requirements. 

DJI Phantom 2

WaterMapping, LLC seeks an exemption to operate DJI Phantom 2 sUAS, for compensation or 

hire. The DJI Phantom 2 is comprised of a quad rotor unmanned aircraft and a handheld ground 

control station. The Phantom 2 has a maximum gross weight of approximately 2.8 pounds, 

diameter (rotor span) of 23.75 inches, width of 12.5 inches, and a height of 8.1 inches. The 

Phantom 2 is equipped with four rotors driven by four lithium polymer battery powered electric 

motors.

The Phantom has software to prevent the UAS from flying into restricted areas, such as airports.

The software creates a five mile safety zone around the restricted area. The operator is notified 

when the Phantom is 330 feet away from a safety zone. If the Phantom is five miles from an 

airport, the UAS cannot fly higher than 400 feet. This height limit decreases as the UAS moves 

closer to the airport so that when the UAS is 1.5 miles away, the Phantom may not fly higher 

than 35 feet. If this occurs, the operator has full control of the Phantom’s movement, except 

that the Phantom will automatically descend to the restricted height. The operator is prevented 

from initiating flight if the Phantom is within 1.5 miles from a restricted area. If the operator 

accidentally flies into a safety zone due to a loss of GPS signal, the Phantom will land 
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immediately once the signal returns. If this occurs, the operator may control the Phantom, with 

the exception that the operator cannot make the UAS ascend in altitude. In addition, the 

Phantom has features that allow the operator to manually set height limitations and limit how 

close a Phantom may fly to a safety zone.

Design and operational characteristics are provided in DJI Phantom 2 Operating Manual (Page 

35). Flight crews shall conduct pre-flight inspections as documented in WaterMapping, LLC 

Environmental Services Health and Safety Plan and DJI Phantom 2 Operating Manual (Page 24). 
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DJI S1000 

WaterMapping, LLC seeks an exemption to operate a DJI-S1000 sUAS for compensation or hire. 

The DJI S1000 is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI-S1000 has a maximum gross weight of approximately 24 pounds, diagonal 

wheelbase of 41.4 inches, and a height of approximately 18 inches. The DJI-S1000 is equipped 

with eight rotors driven by eight lithium polymer battery powered electric motors. 

Design and operational characteristics are provided in DJI-S1000 Operating Manual (Page 22). 

Flight crews shall conduct pre-flight inspections as documents in WaterMapping, LLC 

Environmental Services Health and Safety Plan and DJI S1000 Operating Manual (Page 4). 

5. Unmanned Aircraft Pilot in Command (PIC) 

All WaterMapping, LLC flight crews, including PIC and visual observers (VO), will be qualified as 

directed by the WaterMapping, LLC Health and Safety Plan. 

All flight crew members, including the PIC and VO, will have an understanding of, and comply 

with, Title 14 Code of Federal Regulations, and/or Agency directives and regulations, applicable 

to the airspace where the sUAS will operate. Specifically, all flight crew members will receive 

training on the rules and responsibilities described in 14 CFR Part 91 Section 91.111, 91.113, and 

91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including 

standard ATC phraseology and communication. 

The PIC must possess at least a second class airman medical certificate and a WaterMapping, 

LLC Qualification Card for the specified aircraft. Additionally, the PIC must have completed an 

FAA-approved Ground School for Private Pilots, have attended advanced manufacture’s training, 

and have logged a minimum of 25 hours of total time as an sUAS pilot and at least ten hours as 

an sUAS pilot with a similar sUAS type (fixed wing or rotary). 

Prior documented flight experience that was obtained in compliance with applicable regulations 

may satisfy this requirement. Training, proficiency, and experience building flights are requested 

to be conducted under this grant of exception to accomplish the required flight cycles and flight 
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time. During training, proficiency, and experience building flights, all persons not essential for 

flight operations will be considered non-participants and the PIC will operate the sUAS with 

appropriate distance from non-participants in accordance with 14 CFR Section 91.119. 

Prior to operations conducted for the purpose of aerial imagery and videography (or similar 

operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR 

Section 61.51(b), a minimum of five hours as an sUAS PIC operating the make and model of the 

sUAS to be utilized for operations under this request exemption, and three take-offs and 

landings in the preceding 90 days. Training, proficiency, experience building, and take-off and 

landing currency flights are requested to be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, experience 

building, and take-off and landing currency flights, all personnel not essential for flight 

operations are considered non-participants, and the PIC must operate the sUAS with 

appropriate distance from the non-participants in accordance with 14 CFR Section 91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) 

requirements as along as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times. This condition and limitation is consistent with all FAA 

approved exemptions.

6. Operation of sUAS

The sUAS shall remain clear and yield the right of way to all other manned aviation operations 

and activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All 

altitudes reported to ATC will be in feet.

The multi-rotor sUAS shall not be flown at a ground speed exceeding 30 mph.

sUAS operations will be conducted under visual meteorological conditions (VMC). The sUAS will 

not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the PIC.
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If the sUAS loses communications or loses its GPS signal, it must return to a predetermined 

location within the planned operating area and land or be recovered in accordance with 

WaterMapping, LLC Environmental Services Health and Safety Plan.

The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed t the intended 

landing point and land the sUAS with 25% battery power remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by serial 

numbers, registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practical.

The sUAS documents required under 14 CFR 91.9 and 91.203 shall be available to the PIC at the 

Ground Control Station of the sUAS anytime the aircraft is operating. Those documents shall be 

available to the Administrator or any law enforcement official upon request.

Any sUAS incidents, accidents or flight operations that transgress the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to the 

FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the 

National Transportation Safety Board (NTSB) per instructions on the NTSB web site: 

www.ntsb.gov.

Unless otherwise specified in this petition, the sUAS PIC and the sUAS operations shall comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61 and 91.

The sUAS shall not be operated over congested or densely populated areas. These areas include, 

but are not limited to, the yellow areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each work site will also be 

evaluated based on local conditions.
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Operations of sUAS may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles, or structures that perform an essential function in connection with 

these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator 

trainees and essential persons are permitted when operationally necessary; but never so close 

to present an undue hazard. This is consistent with Exemption No. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, 

vehicles or structures owned by the land owner/controller when the land owner/controller 

grants such permission, and the PIC makes a safety assessment of the risk from the operations 

and determines that it does not present an undue hazard to persons or property. This is 

consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all non-participating persons unless 

barriers or structures are present that sufficiently protect non-participating persons from the 

sUAS and/or debris in the event of an accident. WaterMapping, LLC shall ensure that nonparticipating persons remain under such protection. If a situation arises where non-participating 

persons leave such protection and are within 500 feet of the sUAS, flight operations will cease 

immediately. This is consistent with Exemption No. 11138.

All operations of sUAS shall be conducted with the permission from the land owner/controller or 

authorized representative. Permission from the land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

The sUAS will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management will be 

made available to the Administrator upon request. This is consistent with Exemption No. 11159.

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC to 

be able to use human vision to see the sUAS unaided by any device other than corrective lenses, 

as specified on the PIC’s FAA issued medical certificate. 
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All sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate 

verbally at all times. The PIC and the VO must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must ensure that the VO 

can perform the functions prescribed in WaterMapping, LLC Health and Safety Plan. 

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not 

be conducted at night as defined in 14 CFR 1.1. 

WaterMapping, LLC will conduct preflight safety risk assessments to determine that the sUAS is 

in a condition for safe flight (14 CFR Section 91.7(B)) and that the planned operations can be 

completed safely. Specific procedures are addressed in WaterMapping, LLC Health and Safety 

Plan and the sUAS Operators Manual. 

Should operations require a notification to the Flight Standards District Office, such as pipeline 

or power line patrol, WaterMapping, LLC will notify the appropriate office via letter of intent at 

least 72 hours prior to the operation. 

WaterMapping, LLC shall obtain an Air Traffic Organization issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this requested grant of 

exemption. Additionally, WaterMapping, LLC will request a Notice to Airmen (NOTAM) not more 

than 72 hours, but not less than 48 hours prior to the operation.
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7. Requested Exemptions from Regulations

Considered Regulation Title Recommended Action

14 CFR Part 21.185 Airworthiness 

Certificate

WaterMapping, LLC recommends that in 

consideration of the size, weight, speed and 

limited operating area associated with these 

aircraft and their operation, the Secretary of 

Transportation determines that these aircraft 

meet the conditions of Section 333. Relief is 

not necessary.

14 CFR Part 45.23 (b) Display of marks WaterMapping, LLC sUAS shall be identified by 

serial number, registered in accordance with 

14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR 

part 45, Subpart C. Markings will be as large as 

practical. Relief is not necessary.

14 CFR Part 61.113(a) Private pilot privileges 

and limitations

The FAA has found in previous grants of 

exemption that a PIC with a private pilot 

certificate operating a sUAS would not 

adversely affect operations in the NAS or 

present a hazard to persons or property on the 

ground. Request relief with limitations and 

conditions specified in this petition.

14 CFR Part 61.133(b) Commercial pilot 

privileges and 

limitations

The FAA has found in previous grants of 

exemption that a PIC with a private pilot 

certificate operating a sUAS would not 

adversely affect operations in the NAS or 

present a hazard to persons or property on the 

ground. Request relief with limitations and 

conditions specified in this petition.

14 CFR Part 91.7(a) Civil Aircraft 

Airworthiness

WaterMapping, LLC recommends that in 

consideration of the size, weight, speed and 

limited operating area associated with this 

aircraft and its operation, the Secretary of 

Transportation determines that these aircraft 

meet the conditions of Section 333. Relief is 

not necessary.
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14 CFR Part 91.9(b)(2) 

& (c.)

Civil Aircraft Flight 

Manual, Marking, and 

Placard Requirements

The FAA has previously determined that relief

from these sections is not necessary. Relevant 

materials may be kept in a location accessible 

to the PIC in compliance with the regulations. 

Relief is not necessary.

14 CFR Part 91.103 Preflight Action WaterMapping, LLC will perform. Relief is not 

necessary.

14 CFR Part 91.109(a) Flight Instruction WaterMapping, LLC will conduct all flight 

training through procedures specified in 

Training Instruction during dedicated training 

sessions. Based on previous decisions made by 

the FAA for sUAS petitions regarding this 

regulation, relief is not necessary.

14 CFR Part 91.119(c) Minimum Safe Altitude Aircraft will be operated below 400 AGL, but 

not over congested areas. Request relief with 

limitations and conditions specified in this 

petition.

14 CFR Part 121 Altimeter Settings The proposed aircraft have a barometric 

altimeter and GPS derived altitude capabilities. 

WaterMapping, LLC recommends that the 

altimeter be set to zero feet AGL rather than 

local barometric pressure or field altitude 

before flight. Considering the limited altitude 

of the proposed operations, request relief with 

limitations and conditions specified in this 

petition.

14 CFR Part 91.151(a) Fuel Requirements in 

VFR

Prior relief has been granted for manned and 

unmanned aircraft to operate at less than 

prescribed minimums. Request relief with 

limitations and conditions specified in this

petition.
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14 CFR Part 91.203(a) 

and (b)

Certifications Required Original intent of these regulations was to 

display an aircraft’s airworthiness, certification 

and registration documents so they would be 

easily available to inspectors and passengers. 

Based on the FAA Memorandum subject, 

“Interpretation regarding whether certain 

required documents may be kept at an 

unmanned aircraft’s control station,” dated 

August 8, 2014, relief is not necessary.

14 CFR Part 91.405(a) Maintenance Required Request relief with limitations and conditions 

specified in this petition.

14 CFR Part 

91.407(a)(1)

Operation After 

Maintenance

Request relief with limitations and conditions 

specified in this petition.

14 CFR Part 

91.409(a)(1) and (2)

Inspections Request relief with limitations and conditions 

specified in this petition.

14 CFR Part 91.417(a) 

and (b)

Maintenance Records Request relief with limitations and conditions 

specified in this petition.

8. Public Interest

WaterMapping, LLC operations of sUAS to perform aerial imagery and videography will reduce 

risk to life and property by decreasing the requirements of personnel to operate manned 

aircraft to perform these tasks. WaterMapping, LLC will use battery-powered sUAS that serve as 

safe and efficient alternatives to the manned aircraft commonly utilized to conduct aerial 

imagery and videography. Also, the flight data, inspection results, recorded observations and 

lessons learned from these operations will be compiled to further enhance its current safety 

program.

The applicant proposes that the exemptions requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations listed herein. The limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to aerial imagery 

and videography conducted by manned aircraft.
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A Summary That Can Be Published In The Federal Register, Stating: The Rules From Which 

WaterMapping, LLC Seeks Exemption:

WaterMapping, LLC seeks exemption from the requirements of 14 C.F.R. §§ 61.113(a), 

61.133(b), 121, 91.119(c), 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a)

& (b) to operate commercially a small unmanned vehicle (55lbs or less) in the Coastal and 

Marine research, Agricultural 3d Mapping Service Operations, Oil and Gas Exploration and

Pipeline Inspection..

9. CONCLUSION

As set forth above, WaterMapping, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation 

of the DJI Phantom and DJI S1000 sUAS commercially for the purpose of conducting aerial 

imagery and videography over other than congested areas. By granting this Petition, the FAA will 

allow WaterMapping, LLC to safely, effectively, and efficiently operate sUAS commercially.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight,

speed, operating capabilities, proximity to airports and populated areas, operation within visual 

line of sight, and national security – provide more than adequate justification for the grant of 

the requested Exemptions allowing WaterMapping, LLC to use the DJI Phantom and S1000 for 

and during the management, research, and educational operations of coastal, marine and land 

environments.

Submitted on 1/18/2016.

Respectfully submitted,

Water Mapping, LLC

Oscar Garcia-Pineda

1240 Greensward dr.

Tallahassee, FL 32312

oscar.garcia@watermapping.com