William J. Daniel III

Lowe Engineers, LLC 990 Hammond Drive, Suite 900 Atlanta, GA 30328 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington DC 20590 RE: Exemption Request Per Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Pursuant to S ection 333 of the FAA Mod e rni z a tion a nd Re fo r m A ct of 20 1 2 (the " R e fo r m Act " ) a nd 14 C. F .R. P a rt 11, William J. Daniel III DBA ‘ Lowe Engineers, L LC’ s e e ks a n e x e mption from the F e d e ra l Aviation R e g ulati o ns (" FARs") list e d b e low to allow commercial operation of designated UAS when such operations are conducted within the circumstances outlined below. The specific sections of Title 14 of the Code of Federal Regulations from which Lowe Engineers, LLC requests an exemption from are 14 CFR Part 21 subpart H; 14 CFR 61.113 (a) & (b); 14 CFR 91.7 (a); 14 CFR 91.9 (b)(2); 14 CFR 91.103; 14 CFR91.109; 14 CFR91.119 (c); 14 CFR91.121; 14 CFR 91.151 (a); 14 CFR91.203 ( a) & (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (2); & 14 CFR 91.417 (a) & (b). The requested exemption would permit Lowe Engineers, LLC commercial operation of a light weight unma nned UAS, eBee RTK senseFly, a survey-grade mapping d rone. It would be used for Aerial Mapping and Survey, which includes flying a designated project area in a series of parallel flight

- paths and taking photographs to create geo

- referenced 2D orthomosaics, 3D point clouds, triangle models and Digital Elevati on Models. Lowe Engineers, LLC intends to perform project analysis and commercial operations of aerial photography and surveying using the eBee RTK senseFly . W eighing 1.61 lbs and powered by rechargeable lithium

- polymer battery, the UAS will be operated under controlled conditions at a low altitude in limited airspace
. Using senseFly’s intuitive software makes it easy to plan and simulate the mapping mission. Once you import your preferred base map and define the area you want to cover, eMotion software will automatically generate a full flight plan, calculating the eBee RTK’s required altitude and displaying its projected trajectory . It has a 2.4 GHz radio link that communicates with eMotion flight planning software via the USB ground modem. I t has a br ushless electric motor which is low noise and low pollution. Safety features include shock absorbent foam plus low weight equating to low impact energy resulting in minim al hazard to people and property along with automated controls giving the operator ful l control of the situation at any given point in time
. The operation of UAS typically involves two people. The operator is responsible for flying, monitoring the position and flight dynamics while maintaining a visual line

- of

- sight (VLOS) of the UAS while keeping it within factory limits such as battery life and range to ensure safe operation. The observer isresponsible for monitoring the airspace for any hazards, such as other aircraft, and instruct the operator

before and during flight as necessary to e nsure a safe distance and no conflicts. The operator will be an individual who has passed an FAA approved or equivalent ground training exam and training program for the eBee RTK senseFly as well as continually receive up

-to - date training on a regular basi s . Using the UAS will benefit the public as a whole by reducing environmental impacts such as emissions and noise. To attain a high level of safety, Lowe Engineers, LLC agrees to observe all necessary safety precautions. Strict adherence to all safety ope rating procedures will be achieved with the use of checklists containing : review of hardware and software to ensure it is operating within defined parameters, pre -flight checklist, take

- off checklist, landing checklist, emergency procedures, system mainten ance and service schedules. Maintenance and inspections will be performed in accordance with t he UAS Manufacturers User Manual. F light times will be limited to a maximum of 30 minutes and will cease upon alert to the operator at a determined battery voltage as well as automatically “return home” upon lost radio control or low battery voltage. Flights will be operated at an altitude of more than 300 feet above ground level at all times . A safety briefing will be performed prior to each flight. All flights will be logged. Verbal or written permission and permits will be obtained, when appropriate, from territorial, state, county, city jurisdictions, law enforcement, fire or other governmental agencies. All operations will occur i n Class G airspace during daylight hours and will exceed a 5

- mile radius of any Airport Reference Point (ARP). Lowe Engineers, LLC will obtain a Certificate Waiver or Authorization (COA) from the FAA Air Traffic Organization upon approval of this petition.

**14 CFR Part 21 subpart H : Airworthiness Certificates**  **.** Because of the small area in which the UAS will be operated , speed of operation, lack of explosive or flammable liquids and materials, along with the petite size causing inability to carry an external load , it meets the safety requirements under Part 11 and Section 333 of the Reform Act. **14 CFR 61.113 (a) & (b) : Private Pilot Priviledges and Limitations: Pilot in Command**  **.** The proposed UAS does not carry pilots, passengers or property, therefore it falls well under the risk levels outlined in 14 CFR 61. **1 4 CFR 91.7 (a): Civil Aircraft Worthiness** **, 14 CFR 91.103:**  **Preflight Action & 14 CFR 91.109**  **: Flight Instruction.**  Operators of the UAS will be required to complet e an aviation fundamentals course as well as they must have passed the SenseFly’ s training program. The operator will take actions such as reviewing weather, flight battery requirements, landing and take

- off distances and aircraft performance before each f light. This along with the multitude of safety features the UAS contains result in meeting the requirements under Part 11 and Section 333 of the Reform Act.**14 CFR 91.9 (b)(2) :**  **Civil Aircraft Flight Manual in the Aircraft.**

Due to the size and configura tion of the UAS, it has no ability to carry a fligh t manual on the aircraft. **14 CFR 91.119 (c)**  **: Minimum Safe Altitudes.** The proposed UAS will never operate at higher than 400 feet AGL and flights will take place in a controlled environment where buildings and people will not be exposed to operations without their prior consent. **14 CFR91.121 : Altimeter Settings.**  The proposed UAS does not have a barometric altimeter, but instead a GPS altitude readout, therefore the exemption is needed. **14 CFR 91.151 (a) : Fuel Requirements for Flight in VFR Conditions.**  Op e ra t in g t h e U AS i n a t ig h t l y c o n t ro ll e d a r e a w h e re o n l y p e op l e a n d p ro p e rt y o w n e rs o r o ffi c i a l re p r e s e n t a t ive s w h o h a ve s i g n e d w a iv e rs w i ll b e a l l o w e d d o e s n ot e n g e n d e r t h e t y pe o f r i s k s t h a t S ect i o n 91
. 151 ( a ) w a s in t e n d e d t o a ll e v i a t e g ive n t h e s i z e a n d s p ee d o f t h e s m a l l U AS. **14 CFR91.203 (a) & (b) :**  **C a**  **r r** **yi n**  **g Civil**  **Ai r** **c r** **a f**  **t C**  **e r** **t i**  **f ication**  **and R**  **e gi**  **s t**  **r a**  **t ion**  **.** T h e U AS fu lly l o a d e d w e i g h s w e ll u n d e r t h e p ro p o s e d 5 5
- l b l im it a n d i s o p e ra t e d w it h o ut a n o nb o a r d p i l o t . As s u c h , t h e re i s n o a bil it y o r p l a c e to ca r ry ce rt ifi ca t i o n a nd re g i st ra t i o n d o c u m e nt s or to d i s p l a y t h e m o n t h e U AS
. **14 CFR 91.405 (a) ; 91.407 (a) (1); 91.409 (a) (2);**  **91.417 (a) & (b) :**  **M ai**  **nt e**  **nan c**  **e I**  **n s**  **p ec** **t io**  **n s**  G ive n t h a t t h e s e s ect i o n s a pp l y o nly t o a i rc r a f t w it h a n a i r w o rt h in e s s ce rt ifi ca t e, t h e s e s e ct i o n s w ill n o t a p p l y . In Conclusion, this exemption request along with all associated safety considerations adequately satisfy criteria under Part 11 and Section 333 of the Reform Act, providing ample justification to grant c o mm e rc i a l o p e rat i o n s o f t h e proposed U AS. Sincerely,

William J. Daniel III, PLS CP