### WILLIAMS MULLEN

Direct Dial: 703.760.5204 kpomfret@williamsmullen.com

U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington, D.C. 20590 October 9, 2015

Re: Section 333 Exemption Request Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "ReformAct"), Vickrey & Associates, Inc.("Petitioner") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") described in Section VII below, a Certificate of Waiver and Authorization ("COA'') and any other exemptions necessary to allow the Petitioner to operate the small Unmanned Aircraft Systems ("UAS") described in Section IV for commercial aerial data collectionpurposes, as more fully described in Section IX below.
I. Background on Petitioner Petitioner is a woman-owned small business based in Texas, with offices in San Antonio and Austin. Petitionerhas been in business for 44 years and provides civil engineering consulting and surveying services, includingprogrammanagement, design, and developmentplanning, and the preparation ofcivil site construction documents for commercial, industrial, residential, multifamily, healthcare, municipal and transportation projects. Petitioner also employs an experienced staffofRegistered Professional Land Surveyors and runs multiple, fully-equipped survey crews. II. Contact Information The contact information for Petitioner is set forth below: BrendaVickrey Johnson Vickrey & Associates, Inc. 12940 Country Parkway San Antonio, Texas 78216

8300 Greensboro Drive, Suite 1100 Tysons Corner, VA 22102 T 703.760.5200 F703.748.0244 williamsmullen.com I A Professional CorporationOctober 12, 2015 Page 2 

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III. Request for Exemption to Use UAS for Commercial Uses Petitioner seeks the exemption in order to conduct aerial data collection for commercial customers in a broad range ofindustries, including without limitation, construction, agriculture, energy and utilities, real estate and engineering. In addition, Petitioner will offer aerial data collection services to state and local government. Petitioner expects under the exemption to conduct mapping and surveying operations and to collect data, images and videos ofa variety of assets and features, such as inventory stockpiles, quarries, electric transmission lines and towers. Petitioner also intends to collect aerial datato conduct studies on drainage and other land-use matters. In each case, Petitionerwill take appropriate safety measures withregard to UAS operations. For example, Petitioner will obtain the written consent ofeach landownerprior to beginning operations. Petitioner will cordon offan operations areapriorto each flight. Nonessential individuals will not be allowed into an operations area during a flight unless properly protected. Essential personnel in the operations area will be briefed onthe UAS and the proposed operation. Written consents will be obtained as needed. Petitioner will also utilize the safety measures included with the applicable UAS. Since this exemptionrequest is similarto others that have been granted, the Petitioner requests that this request for exemption be considered on an expedited basis. In that regard, Petitionernotes that the FAA has previously granted exemptions for use ofUAS for similar activities. IV. Unmanned Aircraft Systems Petitioner seeks an exemption for the following platforms. Each ofthe platforms satisfies the requirements necessary to receive an exemption in terms ofsize, weight, speed, operations and safety features. Petitionernotes thatthe FAA has previously granted exemptions for each ofthese UAS. A. 3DRX8-M B. X8+ Quadcopter C. 3DR Solo D. 3DRAero-M E. 3DR Iris+ F. DJI Phantom (all series)

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October 12, 2015 Page 3

G. DJI Inspire 1 H. DJI Spreading Wings S 1 000+ I. senseFly eBee, J. senset1y eBee Ag, K. sensefly eBee RTK L. senseFly eXom M. senseFly swinglet CAM N. _Draganfly X4-ES helicopter system 0. Multirotor G4 7.8 Skycrane
P. Walkera OR ScoutX4 

### Q. Walkera ORTALI H500 R. AltavianNovaR8400 S. AltavianNova F6500
T. Aibotix AibotX6 Hexacopter U. Riegl RiCOPTER with VUX-SYSOctober 12, 2015 Page 4 

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Each ofthe UAS set forth above have operating manuals, maintenance schedules and training procedures (collectively, the "Operational Documents"). Petitioner will comply with each ofthe Operational Documents. Copies ofthe Operational Documents are available upon request. V. Statutory Authority for Requested Exemptions This petition for exemption is submitted in accordance with Section 333 ofthe Reform Act. Pursuantto Section 333 ofthe Reform Act, the Federal AviationAdministration (FAA) Administrator (the "Administrator") is to permit operation ofan unmanned aircraft system where it does not create a hazard to users ofthe national airspace system (NAS) orthepublic orpose a threat to national security. Moreover, the Federal AviationActgrants the Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides such a requested exemption is in the public interest. See 49 U.S.C. §§ 106(£), 44701-44716, et seq. A party requesting an exemptionmust explainthe reasons why the exemption: (i) would benefitthe public as a whole, and (ii) would not adversely affect safety or how it wouldprovide a level ofsafety at least equal to the existing rules. 14 C.F.R. § 11.81. VI. Safety Measures and Public Interest Benefits As described in more detail in Section IX, the Petitionerwill take measures to ensure such operations will not create a hazard to aviation orthe public. For example, flights will be conducted under400 feet AGL thereby avoiding interference with users ofthe national airspace system ("NAS"). Flights will be suspended immediatelyto yield right-of-way to any other aircraft. Geo-fencing will be utilized when available to ensure that a UAS does not fly outside of the intended area. Operations will also not create a hazard to the public as Petitionerwill only operate the UAS overunpopulated areas. As described above, the operations area will be secured and only authorized personnel will be permitted onthe grounds. Giventhe size and speed ofthe UAS, the controlled nature ofthe operations area and the lack ofexplosivematerials or flammablejetfuels, the operations will notpose a threat to national security. There are a number ofreasons why granting the Petitioner'srequest to operatethe UAS for commercial aerial datacollection is in the public interest. Granting the exemptionwill further public interest by allowing Petitionerto safely, efficiently and economically integrate UAS into land development, project management and surveying. An exemptionwill save our customers bothtime and money. In addition, in many instances, it will allow our customers to obtain higher-quality informationthan they currently are able to receive at a cost-efficientprice. This will likely result inthe development ofnew applications and uses for the data.October 12, 2015 Page 5 

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VII. Specific Sections from Which Petitioners Seekan Exemption Based upon the informationprovided and the exemptions thatthe FAAhas already granted pursuantto Section 333, the Petitionerrequests the following exemptions: 14 C.F.R. § 61.23(a) 14 C.F.R. § 61.23(c) 14 C.F.R. § 61.101(e)(4) 14 C.F.R. § 61.101(e)(5) 14 C.F.R. § 61.113(a) 14 C.F.R. § 61.315(a) 14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a) 14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1) 14 C.F.R. § 91.409(a)(2) 14 C.F.R. § 91.417(a) 14 C.F.R. § 91.417(b) VIII. Justifications for Each Exemption Request 1. 14 C.F.R. § 61.23(a), 14 C.F.R. § 61.23(c), 14 C.F.R. § 61.101(e)(4), 14 C.F.R. § 61.101(e)(5), 14 C.F.R. §61.113(a) and 14 C.F.R. § 61.315(a). Petitionernotes that FAA requires the Pilot in Command (PIC) to hold either an airline transport, commercial, private, recreational or sport certificatepilot license and either a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, aterritory, a possession, orthe Federal government. Petitioner will ensure that its PICs will satisfy each ofthese requirements. Since Petitioner's PICs will be operating UAS under the same conditions as those previously granted, an equivalent level of safety will be metby granting these exemptions. 2. 14 C.F.R. § 91.7(a) Civil aircraft worthiness. Section 91.7(a) requires that an operator determine an aircraft is in airworthy condition before a flight. Petitionerrequests relieffrom this section provided that the operator ofthe UAS determines priorto each flight that the aircraft is in compliance with the applicable Operational Documents. Such pre-flight inspection will provide the equivalent level ofsafety as that providedby this section. Petitionernotes that the Administratorhas grantedrelieffrom this section in previous exemptions.October 12, 2015 Page 6 

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3. 14 C.P.R.§ 91.119(c) Minimum safe altitudes over congested and other areas. Section 91.119(c) establishes safe altitudes for operation ofcivil aircraft over areas other than congested areas. The Petitionerrequests relieffrom this section withrespect to those participating persons, vehicles, and structures directly involved with data collection. The UAS will never operate at higher than 400 AGL. Itwill be operated in a controlled area, where buildings and people will not be exposed to operations withoutprior consent. Relieffrom this section is warranted as operations will be conducted with adequate safety provisions as outlined herein and in the applicable Operational Documents. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitionernotes that the Administratorhas grantedrelief from this section inprevious exemptions. 4. 14 C.P.R.§ 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 ofthe departure airport or an appropriate altimeter setting available before departure." An exemption from this section may be needed if the UAS does not have a barometric altimeterbut instead has a GPS altitude read out. An equivalent level ofsafety will be achievedby the operator, pursuantto the applicable Operational Documents, confirming the altitude ofthe launch site shown on the GPS altitude indicatorbefore flight. As a result, an equivalent level ofsafety will be metby granting this exemption. Petitioner notes that the Administratorhas granted relieffrom this section inprevious exemptions. 5. 14 C.P.R.§ 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 VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first pointofintended landing, and, assuming normal cruising speed- (1) Duringthe day, to fly afterthat for at least 30 minutes." Complying with the 30 minute reserve would severely limit the length ofthe Petitioner's UAS flights and hamperthe ability to conduct data collection. Given the limitations on the UAS's proposed flight area, a longertime frame for flight in daylight conditions is reasonable. Operatingthe UAS in a tightly controlled area, where onlypeople or official representatives who have signed waivers will be allowed, does notraise the type ofrisks thatthis section was intended to address, particularly given the size and speed ofthe UAS. Petitionerbelieves that an equivalent level ofsafety canbe achieved by limiting flights to 50 minutes or 20% ofbattery power, whicheverhappens first.October 12, 2015 Page 7 

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6. 14 C.F.R. § 91.405(a) Maintenance required; 14 C.F.R. §91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(l) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance records. Maintenance will be accomplished by the operatorpursuantto the applicable Operational Documents. An equivalent level ofsafety will be achieved because the UAS are very limited in size and will carry a small payload and operate only inrestricted areas for limitedperiods of time. Ifmechanical issues arise, the UAS will be operating from no higher than 400 feet AGL and can immediately land. As provided in the applicable Operational Documents, the operator will ensure that the UAS is in working orderpriorto initiating f1ight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suitedto maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety. As aresult, an equivalent level ofsafety will be met by granting this exemption. Petitioner notes that the Administrator has grantedrelief from this section inprevious exemptions. 7. Additional Relief. In addition to the exemptions listed above, the Petitionerrequests exemption from such otherrules and regulations as the FAA deems appropriate to enablethe operations described herein. Since previous exemptions granted under Section 333 ofthe Reform Acthave been effective for two years, the Petitioner also requests that ifthe FAA issues interim or final rules applicable to the operation ofany UAS included herein afterthe Petitionerreceives a Grant of Exemption that any conditions and limitations required in such Grant that are more burdensome than the new regulationbe appropriately modified or removed. IX. Operating Parameters for UAS Use Petitionerproposes that ifthe requested exemptions are granted, it will operate the UAS under the following conditions: 1. UAS operations will be conductedby a PIC. The PIC shall holdan airline transport, commercial, private, recreational, or sportpilotcertificate. The PIC also will hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, aterritory, a possession, orthe Federal government. The UAS will be in visual line ofsite (VLOS) ofthePIC at all times. 2. All UAS operations will utilize a visual observer ("VO"). The VO will notperform any other duties beyond assisting the PIC with seeing and avoiding air traffic and other ground-based obstacles/obstructions.October 12, 2015 Page 8 

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3. The PIC and VO will be able to communicate verbally at all times. 4. Petitioner will rely on the UAS vendor(s) to provide apilotqualificationprogram, including atraining program incorporating proper aircraft operations and safety standards. The PIC andthe VO will have obtainedthe necessary qualifications/training. A record ofcompletion ofthis qualificationprocess will be documented and made available to the Administratorupon request. 5. UAS will not be flown at ground speeds exceeding [50 mph]. 6. Flights will be operated at an altitude ofno more than 400 feet above ground level. 7. Each UAS operation will be completed within 50 minutes flight time or with 20% battery power remaining, whichever occurs first. At 30% battery the UAS will enter a return and land sequence; at 20% it will land immediately. 8. UAS will not be operated over any person (otherthan participatingpersonnel) at an altitude that is hazardous to persons orproperty on the surface in the event ofa UAS failure or emergency. UAS will be operated at a distance from participatingbuildings ofat least 10 feet. Operations will be conducted at least 500 feet from nonparticipating persons orbuildings, unless barriers are in placeto provide adequate protection. 9. The UAS will abortthe flight in the event ofunpredicted obstacles oremergencies in accordance withthe applicable Operational Document. 10. The UAS will remain clear and yield the right ofway to all othermanned operations and activities at all times. 11. UAS operations will not be conducted during night. 12. The UAS will not be operated by the PIC from any moving device orvehicle. 13. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 14. The applicable Operational Documents and all documents required under 14 C.F.R. § 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents will be made available to the Administratoruponrequest.October 12, 2015 Page 9 

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15. Any incident, accident, or f1ight operationthat transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB). 16. The operatorwill follow the procedures as outlined in its applicable Operational Documents. 17. Priorto each flight, pilot will inspectthe UAS to ensure it is in condition for safe f1ight. Ifthe inspection reveals a discrepancy, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 18. Operations will not be conducted over congested or densely populated areas. 19. All operations will be conducted overprivate or controlled-access property with permission from the landowner/controller or authorizedrepresentative. Permission from the landowner/controller will be obtained for each flight to be conducted. 20. All maintenance and alterations will be properly documented in the aircraftrecords. 21. Any UAS that undergoes maintenance or alterations that affect the UAS operation or f1ight characteristics will undergo a functional f1ight test in accordance with the applicable Operational Documents. 22. Petitioner will institute arigorous maintenance programto ensure airworthiness ofthe UAS. Operatorwill follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 23. EachUAS will comply with all manufacturer Safety Bulletins. X. Summary to be Published in Federal Register Petitioner: Vickrey & Associates, Inc. Sections of 14 C.F.R. Affected: §61.23(a); §61.23(c); §61.101(e)(4);§ 61.101(e)(5); §61.113(a); 61.315(a); §91.7(a); §91.119(c); §91.121; §91.151(a); §91.405(a); §91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F.R. § 61.23(a); 14 C.F.R. §61.23(c); 14 C.F.R. §61.101(e)(4); 14 C.F.R. §61.101(e)(5); 14 C.F.R. §61.113(a); 14 C.F.R. §61.315(a); §91.7(a);14 C.F.R. §91.119(c); 14 C.F.R. § 91.121; 14October 12, 2015 Page 10 

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C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to use small unmanned aircraft systems (UAS) for aerial data collection as described in Section III. XI. Conclusion Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Actregarding size, weight, speed, operating capabilities, proximity to airports andpopulated areas, operation within visual line ofsight, and national security, provide more than adequatejustificationfor the grant ofthe requested exemption allowing operation ofPetitioner's UAS for the purposes set forth herein. Please contact Petitioner's outside counsel, Kevin D. Pomfret, at 703-760-5204 or kpomfret@williamsmullen.com with any questions about this filing.

KDP/kmb

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