IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Environmental Intelligence, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 14 C.F.R. 

§§ Part 21; Part 27; 45.23; 45.29; 91.7; 91.9(b); 91.109(a); 91.119;

91.121; 91.151; 91.203(a) & (b); 91.401 – 91.41

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS  PURSUANT 

TO SECTION 333 OF  THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted March 11, 2016

Prepared For: United States of America 

Department of Transportation 

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., Se

Washington, Dc 20590

Prepared By: Environmental Intelligence

1590 South Coast Highway, Suite 17

Laguna Beach, CA 92651

Contact: Travis Kegel 

traviskegel@enviro-intel.com

 >
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY........................................................................................................................................1

II. CONTACT INFORMATION...................................................................................................................................2

III. MAKE AND MODEL OF AIRCRAFT..................................................................................................................2

IV. PROPOSED OPERATIONS...................................................................................................................................2

Public Interest ...........................................................................................................................................................3

Pilot in Command .....................................................................................................................................................3

V. REQUESTED EXEMPTIONS AND EQUIVALENT LEVEL OF SAFETY .........................................................4

14 C.F.R. 21..............................................................................................................................................................4

14 C.F.R. 45.23 & 45.29...........................................................................................................................................4

14 C.F.R. 91.7...........................................................................................................................................................4

14 C.F.R. 91.9(b) & 91.203 ......................................................................................................................................4

14 C.F.R. 91.109(a) ..................................................................................................................................................5

14 C.F.R. 91.119.......................................................................................................................................................5

14 C.F.R. 91.121.......................................................................................................................................................5

14C.F.R.91.151.........................................................................................................................................................5

14C.F.R. Subpart E 91.401-91.417...........................................................................................................................6

VI. CONCLUSION .......................................................................................................................................................6
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

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I. EXECUTIVE SUMMARY

Environmental Intelligence, LLC (Environmental Intelligence) is an environmental service 

provider that provides, among other services, inspection of lands and structures in association with 

regulatory and safety requirements. Environmental Intelligence intends to operate a small 

unmanned aerial vehicles (sUAV) and unmanned aircraft system (UAS) to conduct aerial data 

collection including aerial surveying, utility inspection, structural inspection, construction 

inspection, public entity support services, educational and research, and wildlife and forestry 

monitoring. The collection of aerial data utilizing UAS will increase the efficiencies of the data 

collection and provide safety enhancements. 

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

14 Code of Feral Regulations (C.F.R). Part 11, Environmental Intelligence, LLC (“Environmental 

Intelligence”) hereby petitions for exemptions from the following: 

 14 C.F.R. § 61.113 (a) & (b)

 14 C.F.R. § 61.133(a)

 14 C.F.R. § 91.7(a)

 14 C.F. R.§ 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151 (a)

 14 C.F.R. § 91.405 (a)

 14 C.F.R. § 407 (a) (1)

 14 C.F.R. § 409 (a) (2)

 14 C.F.R. § 417 (a) & (b)

Environmental Intelligence relies upon the following previously authorized Grants of Exemption 

as their circumstances are similar in all material respects to the exemption currently requested: 

 Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA20140352), 

 Exemption Nos. 11109 to Clayco, Inc. (see Docket No. FAA20140507), 

 Exemption Nos. 11112 to VDOS Global, LLC (see Docket No. FAA20140382), 

 Exemption Nos. 11213 to Aeryon Labs, Inc. (see Docket No. FAA20140642), 

 Exemption Nos. 12645 to Allied Drones (see Docket No. FAA-2014-0804), 

 Exemption Nos. 12697 to Greenblatt (see Docket No. FAA−2015−2417), and 

 Exemption Nos. 13576 to Wiser Consultants LLC (see No. FAA–2015–3703).
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

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II. CONTACT INFORMATION

Environmental Intelligence LLC

Attn: Travis Kegel

1590 South Coast Highway, Suite 17

Laguna Beach, CA 92651

949.497.0931

traviskegel@enviro-intel.com

III. MAKE AND MODEL OF AIRCRAFT

The petitioner is seeking an exemption to commercially operate sUAVs makes and models as 

follows: 

1. DJI - Inspire 1 5. DJI - Spreading Wings S900 

2. DJI - Phantom 3 6. Trimble - UX5

3. DJI - Phantom 4 7. Draganflyer - X4-ES

4. DJI - Spreading Wings S800 8. SenseFly - eBee

Each sUAV separately weighs 55 lbs. or less, with imaging payload and applicable equipment. 

Each of above mentioned sUAV make and model have been granted relief from 14 CFR part 21, 

Certification procedures for products and parts, Subpart H—Airworthiness Certificates in 

Exemption Nos. 13563(Regulatory Docket No. FAA–2015–3521) and/or Exemption Nos. 12697 

(Regulatory Docket No. FAA−2015−24170). The manufacturer’s User Manuals1for each sUAV 

include safety protocols to maintain safe flight and include prefight inspections, maintenance, and 

fight capabilities. The detailed safety protocol instructions are provided in the manufacturer’s User 

Manuals and shall be adhered to. 

IV. PROPOSED OPERATIONS

Environmental Intelligence has a long history of providing high quality survey and inspection 

services. Environmental Intelligence seeks this exemption for the following UAS applications: 

 Aerial Surveying 

 Utility Inspection 

 Structural Inspection 

 Construction Inspection 

 Public Entity Support Services 

 Educational and Research Opportunities

 Wildlife and Forestry Monitoring

Surveys and inspections will be limited in scope pursuant to the operational manuals and FAA 

guidelines. Flight time will be limited based on the energy capacity of the on the batteries and 

 

1 The aircraft equipment operation manuals are not required inclusion in this petition following guidelines provided 

in ‘Section 333 Petition Guidance & Checklist.’
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

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operations shall maintain a minimum reserve of 25% battery capacity and have a maximum 

operating speed of 35 miles per hour. All operations will be conducted below 400 AGL feet and 

no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA 

published aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained. In addition, operations shall be no closer than 500 feet to the adjacent building or 

confined space unless the land owner has provided permission, and the Pilot in Command has 

made a safety assessment of the risk from such operations.

Public Interest 

As part of its commitment to safety and innovation, Environmental Intelligence is asking for this 

exemption in part, to reduce the risk of injury to its employees and contractors who participate in 

the proposed survey and inspection services. The current surveying and inspection procedures can 

result in significant injuries to personnel who must climb to elevated positions or require the use 

of conventional aircraft that are orders of magnitude greater in size and risk than the sUAV. Either 

method, manual inspection or conventional aircraft, results in increased risk of injury due to falls, 

entering confined or dangerous spaces, and potential exposure to hazardous materials. As such, it 

is in the best public interest to utilize UAS in lieu of conventional methods to promote safety. 

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.

Pilot in Command

Environmental Intelligence’s UAS unit is under Travis Kegel’s direction. Travis Kegel is a highly, 

highly accomplished, capable, experienced and trusted professional and has a long history of 

providing high quality inspection and mapping services. 

Environmental Intelligence shall retain a Pilot in Command (PIC) holding specializations and 

experience in aviation safety, instruction, flight operations, contracting and maintenance. The PIC 

will hold old either an airline transport, commercial, private, recreational, or sport pilot certificate. 

The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license 

issued by a state, or the Federal government and meet the flight review requirements specified in 

14 CFR § 61.56.

The PIC will be operating the aircraft within line of sight. The PIC will not be distracted by viewing 

the pictures taken during the flight. Rather, once the sUAV is launched, the Pilot in Command’s 

only duty will be to watch the flight of the UAS over the structure and intervene to address flight 

path deviations or other issues that arise during the flight. In addition, the PIC will conduct a preflight inspection of the sUAV and area and will perform frequent visual scans of the area while 

the vehicle is operating.
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

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V. REQUESTED EXEMPTIONS AND EQUIVALENT LEVEL OF SAFETY

In addition to the safety benefits described in Section IV, the use of sUAVs will provide equivalent 

level of safety as they relate to the Code of Federal Regulations (C.F.Rs).

14 C.F.R. 21

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a). 

Given the size, weight, speed and limited operating area of the proposed aircraft (see Part III 

above), an exemption to 14 C.F.R. Part 21 Subpart H is warranted and meets the requirements of 

an equivalent level of safety under 14 C.F.R. Part 11 and Section 333. The proposed UAS operated 

in the restricted environment and under the conditions and limitations proposed by Wiser, will be 

at least as safe, or safer, than a conventional aircraft with an airworthiness certificate issued under 

14 C.F.R. Part 21, Subpart H, and not subject to the proposed limitations and conditions.

14 C.F.R. 45.23 & 45.29

These regulations require each aircraft to display the letter “N” along with the aircraft’s registration 

number in letters at least 3” high and the word “EXPERIMENTAL” in letters at least 2” high near 

the entrance to the cabin, cockpit or pilot station.

Due to the small size and lack of entrance on the proposed aircraft, Environmental Intelligence 

will display the registration number, if applicable, on the aircraft as large and prominently as 

possible. Should no registration number be assigned, the company name, address and contact 

information will be displayed on the aircraft. Additionally, any registration information will be 

kept together with all user and operation manuals at the ground control station and will be 

immediately accessible to the PIC at all times during flight operations. Given that the aircraft will 

be operated within VLOS of the PIC at all times, the ground control station will be easily located 

by any observer seeking the point of origin of flight operations.

14 C.F.R. 91.7

This regulation provides that no person shall operate a civil aircraft unless it is in an airworthy 

condition.

It is our understanding that, due to the size and operational conditions proposed herein, an 

airworthiness certificate may not be required and therefore and exemption from this subpart would 

not be necessary. However, should an exemption be deemed necessary, it should be granted based 

on the inherent safety of these aircraft and the proposed operational limits. Additionally, 

Environmental Intelligence will follow all manufacturer maintenance schedules and perform preflight safety checks before every flight.

14 C.F.R. 91.9(b) & 91.203

It is Environmental Intelligence’s understanding that an exemption from these subparts is no longer 

necessary in light of the FAA Memorandum “Interpretation regarding whether certain required 
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

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documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014. However, 

should an exemption be deemed necessary, Environmental Intelligence will keep all documents 

required under these subparts at the ground control station during flight operations.

14 C.F.R. 91.109(a)

This regulation provides that no person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.

Environmental Intelligence will perform all training and test flights in a controlled area containing 

no uninvolved personnel. This combined with the fact that the aircraft involved carry no crew or 

flammable fuel means that an equivalent level of training can be safely performed.

14 C.F.R. 91.119

This subsection limits the operation of aircraft over water or sparsely populated areas to no closer 

than 500 feet to any person, vessel, vehicle or structure.

Environmental Intelligence will meet an equivalent level of safety required by this regulation by 

operating only over private or controlled access areas with the permission of the landowner or 

controlling authority. Furthermore, Environmental Intelligence will operate over only those 

persons involved with the operation and will inform all involved persons of the proposed flight 

operations. Permission to fly over vessels, vehicles or structures will only be performed with 

authorization from the owner after the proposed operation and associated risks have been fully 

explained. FAA has granted exemptions to conduct similar operations in Exemptions 11062 

through 11067, 11080 and 11110.

14 C.F.R. 91.121

This subsection requires that 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.

The proposed aircraft utilize a combination of an onboard GPS and barometer which is reported 

to the PIC through radio telemetry. The altitude reading will be initialized and verified by the PIC 

on the ground before takeoff. This will provide a reliable method of tracking altitude. This along 

with the limited operational area and conditions, including LOS requirements, provide an 

equivalent level of safety and this exemption should, therefore, be granted. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.

14C.F.R.91.151

This regulation prescribes that no person may begin a flight in an airplane under VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and continue to fly for at 

least 30 minutes longer.

The aircraft proposed all contain redundant safety systems that, in the event of a system failure, 

the aircraft will fly to a predetermined safe zone to land. Environmental Intelligence will maintain 

a minimum reserve of 25% battery capacity. All flight times will be calculated to this reserve 
Petition for Exemption: Environmental Intelligence, LLC March 11, 2016

Environmental Intelligence, LLC

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requirement. The current battery power levels are constantly reported to the PIC through radio 

telemetry. Should the PIC see that the battery is rapidly discharging, the flight will be immediately 

aborted and the aircraft will be inspected. These procedures create an equivalent level of safety 

and this exemption should, therefore, be granted. Similar exemptions have been granted to other 

operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, 

through11067, 11080 and 11110

14C.F.R. Subpart E 91.401-91.417

This subpart deals with maintenance, preventative maintenance and alterations of the aircraft. As 

the proposed aircraft do not contain the types of systems typically maintained by a certified aircraft 

mechanic, Environmental Intelligence proposes that maintenance be performed by the aircraft 

owner per the schedule and requirements provided by the manufacturer. This combined with the 

system's built in safety features and performance of preflight checks creates an equivalent level of 

safety. Additionally, the proposed aircraft's small size, weight and limited operation area mean that 

danger to persons or property are extremely limited. For these reasons, this exemption should be 

granted. The FAA has granted exemptions for similar operations in Exemptions 11062 through 

11067, 11080 and 11110.

VI. CONCLUSION

This exemption request, once granted would allow Environmental Intelligence to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) for aerial data collection. For 

the above reasons, these requested exemptions should be granted and Environmental Intelligence 

should be allowed to perform UAS operations per the manuals and any other conditions or 

parameters the FAA deems necessary and appropriate.

Respectfully submitted,

Travis Kegel