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 Sir or Madam:

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

and 14 CFR Part 11, SurvTech Solutions (“SurvTech”) a professional survey and mapping firm 

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

commercial operation of its sUAS, 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 described more fully below, the requested exemption would support an application for

commercial operations and permit the operation of small, unmanned and relatively inexpensive 

sUAS under controlled conditions in limited airspace for aerial imaging purposes. The sUAS 

also will be operated by an individual who has at least a sport pilot’s certification with at least a 

third class medical and sUAS flight training.

Operational Intentions: Aerial Data Collection

1. Precision Photogrammetry and Mapping – These operations would take place with

express written permission from the owner of the property for the purpose of obtaining

detailed terrain and topographic imagery of land features. These operations would be

conducted in airspace no more than 400’ AGL and the sUAS will remain within Visual

Line of Sight of the Pilot in Command at all times.

2. Aerial Imagery of Commercial and Residential Property – These operations would

take place with express written permission from the owner of the property for the

purpose of obtaining quality aerial photos of real estate. These operations would be

conducted in airspace no more than 400’ AGL and the sUAS will remain within Visual

Line of Sight of the Pilot in Command at all times.

We can insure that the combination of the sUAS lightweight, historically demonstrated flight

performance, on board GPS system, fully qualified flight personnel, and strict operation under

the guidelines established, the FAA can have confidence that SurvTech’s operation will have an

equivalent or greater level of safety of manned aircraft performing the same missions.

Also, given the small size of the sUAS involved and the restricted controlled environment within 

which they will operate, the applicant fits within that zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of sUAS to commence immediately. Also due to the size of the sUAS and the 

controlled areas in which the relevant sUAS will operate, approval of the application presents no 
national security issue. Given the following, the grant of the requested exemptions is clearly in 

the public interest.

The sUAS

Model 1: 3DR IRIS +

The IRIS+ is a small quadcopter produced by 3D Robotics Inc. The IRIS+ is a reliable sUAS 

which is controlled with the onboard Pixhawk flight controller. Flight can be guided and 

stabilized using GPS technology. The IRIS+ complies with the requirements set forth by Section 

333 by its small size, weight, speed, and operational proximity to airports and densely populated 

areas. As a result under this exemption the IRIS+ is not deemed airworthy by an airworthiness 

certificate, but rather it is deemed airworthy by the operator conducting a thorough preflight 

inspection of the aircraft. This aircraft will also be registered in accordance to 14 CFR Part 47, 

marked in accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of alternative 

marking due to the unconventional design of a quadcopter. Markings will be as large as 

practicable. 

Aircraft Make and Model: 3D Robotics IRIS+ 

Configuration: Quad copter 

Aircraft Performance/Specifications: 

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a typical 2.4 GHz RC transmitter. The aircraft can also be pre-programmed to conduct 

a mission through the use of a laptop or tablet via a 915 MHz telemetry link. Whenever 

operations are conducted in this matter, the RC Transmitter will be able to take control of 

the aircraft if the need arises. 

● Lost Com: Aircraft will autonomously return to the launch location and safely land. 

● Emergency Procedure: Should the need arise the aircraft can be commanded by a switch 

on the RC transmitter to safely land immediately or return and land at the launch location. 

● Power Supply: 3S 5.1Ah 8C Lithium Polymer Battery 

● Dimensions: 550mm motor to motor 

● Maximum Speed: 44 knots 

● Normal operating speed: Less than 30 knots 

● Weight without payload: 1282g (2.8lb) 

● Weight with payload: 1656g (3.7lb) 

Model 2: Pixhawk Hexa-copter

Aircraft Make and Model: 3D Robotics Pixhawk Hexacopter 

Configuration: Hexa copter

The Pixhawk Hexacopter is a six rotor hexacopter equipped with the 3D Robotics Pixhawk flight 

controller. The hexacopter has upgraded Aimdroix aluminum arms and is equipped with the DJI 

e800 tuned propulsion system. The system is equipped with GPS navigation capabilities and 2.4 

GHz datalink for ground station communication. The Pixhawk Hexacopter complies with the 
requirements set forth by Section 333 by its small size, weight, speed, and operational proximity 

to airports and densely populated areas. As a result under this exemption the Pixhawk 

Hexacopter is not deemed airworthy by an airworthiness certificate, but rather it is deemed 

airworthy by the operator conducting a thorough preflight inspection of the aircraft. This aircraft 

will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 

Subpart C, and accompanied by a letter of alternative marking due to the unconventional design 

of a quadcopter. Markings will be as large as practicable. 

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a typical 2.4 GHz RC transmitter. The aircraft can also be pre-programmed to conduct 

a mission through the use of a laptop or tablet via a 915 MHz telemetry link. Whenever 

operations are conducted in this matter, the RC Transmitter will be able to take control of 

the aircraft if the need arises. 

● Lost Com: Aircraft will autonomously return to the launch location and safely land. 

● Emergency Procedure: Should the need arise the aircraft can be commanded by a switch 

on the RC transmitter to safely land immediately or return and land at the launch location. 

● Power Supply: 6S 20000mAh Lithium Polymer Battery 

● Dimensions: 700mm motor to motor 

● Maximum Speed: 35 knots 

● Normal operating speed: Less than 30 knots 

● Weight without payload: 4574g (10.1 lbs) 

● Weight with payload: 5254g (11.5 lbs) 

Model 3: eBee

Aircraft Make and Model: SenseFly eBee 

Configuration: Hexa copter

The eBee is a small (37.8-inch wingspan) and ultra-light (maximum takeoff weight of 1.7

pounds) platform made of flexible EPP foam that performs precision aerial mapping missions

with an on-board GPS and related flight management software (eMotion2) that allows the

operator to safely and efficiently plan a mission in 3D and monitor it in real-time. The eBee 

complies with the requirements set forth by Section 333 by its small size, weight, speed, and 

operational proximity to airports and densely populated areas. As a result under this exemption 

the eBee is not deemed airworthy by an airworthiness certificate, but rather it is deemed 

airworthy by the operator conducting a thorough preflight inspection of the aircraft. This aircraft 

will also be registered in accordance to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 

Subpart C, and accompanied by a letter of alternative marking due to the unconventional design 

of a quadcopter. Markings will be as large as practicable. 

● Ground Control Station (GCS): The aircraft will be primarily controlled through the use 

of a typical 2.4 GHz RC transmitter. The aircraft can also be pre-programmed to conduct 

a mission through the use of a laptop or tablet via a 2.4 GHz data link. Whenever 

operations are conducted in this matter, the RC Transmitter will be able to take control of 

the aircraft if the need arises. 

● Lost Com: Aircraft will autonomously return to the launch location and safely land. 
● Emergency Procedure: Should the need arise the aircraft can be commanded by a switch 

on the RC transmitter to safely land immediately or return and land at the launch location. 

● Power Supply: 3S 2150mAh Lithium Polymer Battery 

● Dimensions: 960mm wingspan 

● Maximum Speed: 48 knots 

● Normal operating speed: Less than 40 knots 

● Weight with payload: 725g (1.6 lbs) 

Aircraft manuals and operations checklist will be included as additional information to this 

petition for exemption.

Mandatory Operating Conditions, Limitations, and Procedures 

SurvTech proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations and 

procedures provide for an exceptional level of safety to operations. These limitations and 

conditions to which SurvTech agrees to be bound when conducting commercial operations under 

an FAA issued exemption including:

1. The sUAS will weigh less than 55 lbs.

2. The sUAS, depending on the model in operation, will have a maximum operating speed 

of no more than 50mph.

3. Flights will be operated within Visual Line of Sight (VLOS) of operator.

4. Maximum total flight time for each operational flight will be 30 minutes or less.

5. Flights will be terminated at 20% battery power reserve.

6. Flights will be operated at an altitude of no more than 400 feet AGL

7. sUAS operator will be trained and certified in the proper safety and operations of the 

sUAS.

8. Minimum crew for each operation will consist of the sUAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

9. The operator will post an advisory notice at the controlled area.

10. The operator will have been trained in operation of sUAS generally and received up-todate information on the particular sUAS to be operated as required.

11. A safety briefing will be performed prior to each day’s flights consisting of all the day's 

flight activities.

12. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport. 

13. Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies as appropriate to flight operations.
14. If the sUAS loses communications with the remote controller or loses GPS signal, the 

sUAS will have the capability to return to a predetermined location within a designated 

location and land autonomously.

15. The sUAS will have the capability to abort a flight in case of emergencies with an 

automated “Return Home and Land” function.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies such as low battery.

17. Operations shall not occur over congested, actively, or densely populated areas. 

18. Permission from landowner is required before commencing any flight. 

19. Operations will only occur during Visual Flight Rules Meteorological Conditions 

(VMC). 

20. The sUAS will remain clear of manned aircraft and yield right of way. 

21. A flight test will be conducted after any major repair or alteration. 

22. A preflight check will be conducted before each flight to assure airworthiness. 

23. Operations will be limited to daylight hours. 

Public Interest

The proposed sUAS operations in this petition provide an “equivalent level of safety” if not a 

safer alternative to manned remote sensing operations. The sUAS do not carry persons onboard, 

they do not contain combustible fuel sources, and are less expensive to operate than manned 

platforms. Because they are battery powered, the sUAS do not contribute harmful emissions to 

the atmosphere. These sUAS attributes will benefit the public as a whole when performing 

remote sensing operations.
The name and contact information of the applicant:

SurvTech Solutions

10220 U.S. Highway 92 East

Tampa, Florida 33610

dobrien@survtechsolutions.com

(813) 621-4929

Regulations from which the exemption is requested are as follows and described fully in 

Appendix A:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103(b)(2)

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) & (b)

14 CFR 91.405(a)

14 CFR 407(a) (1)

14 CFR 409(a) (2)

14 CFR 417(a) & (b)

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and

is prepared to modify or amend any part of this request to satisfy the need for an equivalent

level of safety. We look forward to working with your office. Please contact us at any time if

additional information or clarifications are needed.

Sincerely,

David O'Brien

SurvTech Solutions

Attachments:

3DR_IRIS_Plus_Operations_Manual.pdf

3DR_Pixhawk_Hexacopter_Operations_Manual.pdf

Sensfly_eBee_Operations_Manual.pdf

Appendices:

A. Exemption Request and Equivalent Level of Safety
Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

SurvTech Solutions requests an exemption from the following regulations as well

as any additional regulations that may technically apply to the operation of its sUAS.

14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203(a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701(f)) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of 

these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs fully loaded, carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a controlled area as set out in the Procedures. Unlike other civil aircraft, operations under

this exemption will be tightly controlled and monitored by the operator, pursuant to the

Procedures requirements. Lastly, application of these same criteria demonstrates that there is

no credible threat to national security posed by the sUAS, due to its size, speed of operation,

location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry

a substantial external load.

14 CFR § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit,

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the sUAS

will have no airworthiness certificate, an exemption may be needed as the sUAS will have no

entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the sUAS, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29(f). The equivalent level of safety will be

provided by having the sUAS marked on its fuselage as required by §45.29(f) where the operator

working with the sUAS will see the identification of the sUAS as "Experimental." The FAA has

issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and

10167 A
14 CFR §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Procedures for maintenance

and use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9(b) (2) provides:

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 such 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 operator flying the sUAS will have immediate access to it. The FAA has issued the following

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658,

10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103(b): Preflight action

This regulation requires that each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must include —

(b) for any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft and because

runways are not needed for takeoff and landing operations, an exemption will be needed. An

equivalent level of safety will be provided as set forth in Procedures. The operator will take all

actions including reviewing weather, flight battery requirements, landing and takeoff locations

and aircraft performance data before initiation of flight.

14 CFR §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. sUAS and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. The FAA has approved exemptions for flight training

without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the

size and speed of the aircraft.

14 CFR §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at

altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth

herein, except for the limited conditions stated in the Procedures, the sUAS will never operate at

higher than 400 AGL. The equivalent level of safety will be achieved given the size, weight,

speed of the sUAS as well as the location where it is operated. In addition, the low-altitude

operations of the sUAS will ensure separation between these sUAS operations and the

operations of conventional aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate

altimeter setting available before departure." As the sUAS may not have a barometric altimeter,

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety

will be achieved by the operator, pursuant to the Procedures and Operation Manual, confirming

the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed - (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

The battery powering the sUAS provides approximately 40 minutes of powered flight or less 

depending on the model. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS 

flights would be limited to approximately 10 minutes in length. Given the limitations on the 

sUAS's proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant 

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with FAR 91.151(a)). Operating the sUAS, in a tightly controlled area, with less than 30 minutes 

of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the sUAS. Additionally, limiting sUAS flights to 10 minutes 

would greatly reduce the utility for which the exemption will be granted. Applicant believes that 

an equivalent level of safety can be achieved by limiting flights to 30 minutes or 20% of battery 

power whichever happens first. This restriction would be more than adequate to return the sUAS 

to its planned landing zone from anywhere in its limited operating area. Similar exemptions have

been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91 .715, no person may operate a civil aircraft unless it has within it

the following: (1) an appropriate and current airworthiness certificate ... (b) No person may

operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than
55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display them on the sUAS. An equivalent level of

safety will be achieved by keeping these documents at the ground control point where the

operator flying the sUAS will have immediate access to them, to the extent they are applicable to

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample

of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A,

and 10700.

14 CFR §91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided

in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this

chapter... ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given

that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. Maintenance will be accomplished by the operator

pursuant to the flight manual and operating handbook as referenced in the Procedures. An

equivalent level of safety will be achieved because these sUAS are very limited in size

and will carry a small payload and operate only in controlled areas for limited periods of time. If

mechanical issues arise the sUAS can land immediately and will be operating from no higher

than 400 feet AGL. As provided in the Procedures, the operator will ensure that the sUAS is in

working order prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 CFR

45.23(b); 14 CFR §§ 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121;

91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.409(a) (2) & 91.417(a) &

(b) to operate commercially a small unmanned vehicle (55lbs or less) for the purpose of

inspection, monitoring, mapping and photographing attached equipment and engineering

studies involving communication towers, wind turbine tower facilities and power transmission

tower operations.

Approval of exemptions allowing commercial operations of sUASs will create a level of safety 

by reducing risk. Conventional aerial imaging and associated tasks involve risks to personnel 

and/or utilizing low flying manned aircraft both of which create potential risks to such personnel. 

In contrast, a sUAS weighing fewer than 55 lbs and powered by batteries eliminates virtually all 

of that risk. The sUAS will carry no passengers or crew and, therefore, will not expose personnel 

to any of the risks described above. The operation of a sUAS, weighing less than 55 lbs, 

conducted in the strict conditions outlined above, will provide a level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate 

at slow speeds, close to the ground, and in a controlled environment.