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Water Mapping, LLC Oscar Garcia

- Pineda 1240 Greensward D r. 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 ( s UAS), Water Mapping, LLC hereby applies for ·an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of Designated s UAS, 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 t hese limitations provide for at least an equivalent or even higher level of safety to operations under the current regulator y 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 withou t 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

### 2 | P a g e Table of Contents

1. Glossary o f 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 1 3

8. Public Interest 1 5

9. Conclusion 1 6

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1. Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Av iation 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 Operatin g Manual

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3. Introduction and Interest of Petitioner

W ith more than 20 years of experience in the field, WaterMappin g , LLC provides high

- quality geoscience services for private and public sector client s

. WaterMappin g , 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 surve ys 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 difficult

to

- 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 Es tate 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 ou tlined 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) res ponsibilities 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 Info rmation Pertaining to All Proposed sUAS

WaterMapping LLC will operate less than fifty five po und 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 condit ion 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 incl uded 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 main tenance technician returning the

sUAV to service.

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and Safety Bulletin.

WaterMappin g , LLC techni cians will receive and document training referenced in the manufacturer’s operations manual. WaterMappin g , LLC technicians shall make a record entry in the sUAS logbook or equivalent document of the corrective action taken against discre pancies 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 re quirements.

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 restr icted 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 t han 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 P hantom 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 P hantom 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 manual ly 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 (P age 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 ma ximum 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 Pi lot 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 Qualif ication 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 f lights 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 n on

- 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 mu st 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, profic iency, 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 wi th 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. T his 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 oper ated 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

acco rdance 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% batt ery 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 Administr ator 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 com ply 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 sp ecial 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.

Oper ations 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 structu res 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 non

participating 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 o wner/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 denote d 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 m anagement 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 unai ded 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 prescri bed 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 co nduct 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 lette r 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 exempti on. 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 (N

Number) 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 pet ition.

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 condition s 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 Req uired 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 f rom 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, operat ion 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