U.S. DepartmentofTransportation Docket Management System 1200 New JerseyAvenue SE Washington, DC 20590

RE: Exemption Request Section 333 ofthe FAA Reform Act

Dear Sir or Madam, 8 February 2016

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, Terra Intel, LLC, a consulting firm located in Golden, CO hereby applies for an exemption from the Federal Aviation Regulations (FAR) identified below, to allow commercial operations ofsmall unmanned aerial systems (sUAS).

Terra Intel is a physics and engineering consulting firm thatprovides geospatial, surveying, geophysical and geosciences services to a wide range ofindustries in the United States. The companyleverages the capabilities ofmapping software, GPS systems, surveying equipment, and high-fidelity sensors (e.g. photogrammetry, FLIR) to provide services to industries thatrely on them for regulatory compliance, public safety, and assetmanagement. Being positioned in this highly competitive industry requires a significantinvestmentin the aforementioned software and hardware products, butto also be aware offorthcoming technological developments. The sUAS is amonga group ofseveral technological developments thatTerra Intel considers to be an importanttool thatwill have a positive impacts on the waywe perform data collection, asset evaluation, environmental monitoring, and visual presentation methodologies, all ofwhich are services we provide to our customers.

The requested exemptions would permitTerra Intel to pursue its commercial interests in providing services to clients using advanced sUAS in rural or sparsely populated areas. We intend to conduct aerial data collection thatincludes remote sensing and mensuration byutilizing instruments aboard the sUAS. Examples include imagery (photogrammetry, video, infrared, multi- and hyper-spectral, etc.), electronic measurement (mapping and surveying, etc.), or any othergathering of data byinstruments aboard the sUAS. Commercial areas thatwould benefit from the application ofsUAS deployed sensors include: the energy sector; mining; agriculture; environmental monitoring; and conservation to name a few.

Terra Intel's sUAS FleetSpecifications

To satisfy clientrequirements in a safe and efficient manner,Terra Intel will utilize a fleet oftwenty- three (23) commercially available UAS. The UAS's listed below have been previously

**approv~d** for operations (Exemption No. 12646- Regulatory

Terra Intel, LLC Section 333 Exemption RequestDocket No. FAA-2015-1602):
1.) DJI Phantom 3 2.) DJI Phantom FC40 3.) DJI SpreadingWings S900 4.) DJI SpreadingWings S1000 5.) DJI SpreadingWings S1000+ 6.) DJI S800 7.) DJI S800 EVO 8.) DJI T600 9.) DJI F550 Flamewheel 1

0.) Tarot FY690S Hexacopter 11.) Tarot Quadcopter 12.) Tarot 680pro 13.) Tarot690 14.) Tarot 900 15.) Tarot960 16.) TarotT

-15 17.) TarotT15 C/F Folding Octocopter 18.) TarotT18 UAV 19.) TarotT690 20.) TarotT810 21.) Roboflight RF70 (Spade 70") 22.) Falcon VTOL 23.) Fire Fly 6



### Specific Sections ofTitle 14CFR thatTerra Intelwishes to seekexemption

We are seekingthe following specific exemptions. Please seeAppendix Cfor the rationale for each requested exemption.

1. Chapter 1, Subchapter C, Part 21, Subpart H 2. Chapter 1, Subchapter C, Part45, Subpart C, §45.23 (a) and (b) 3. Chapter 1, Subchapter D, Part 61, SubpartA, §61.23(a) and Chapter 1, Subchapter D, Part61, Subpart

### J, §61.315(c) (2&3) 4

. Chapter 1, Subchapter F, Part 91, Subpart B, §91.119 5. Chapter 1, Subchapter F, Part91, Subpart B, §91.121 6. Chapter 1, Subchapter F, Part 91, Subpart B, §91.151 7. Chapter 1, Subchapter F, Part 91, Subpart C, §91.203 8. Chapter 1, Subchapter F, Part 91, Subpart C, §91.205 9. Chapter 1, Subchapter F, Part 91, SubpartE, §91.405; §91.407; §91.409; §91.411; §91.413; §91.415; §91.417; and §91.421 10. Chapter 1, Subchapter F, Part9!, SubpartH, §91.703(a)(1), (3), (4), (5), and (b), §91.705, and §91.706

Terra Intel, LLC Section 333 Exemption RequestList ofsupporting information:
Appendix A: sUAS Safe Operational Description Appendix B: Terra Intel's sUAS Fleet Specification and FAA Exemption Number Appendix C: Specific Exemption Requests and Rationale Appendix D: sUAS Safe Flight Operational Procedural Checklist Appendix E: sUAS Flight Log-book Record Entry Form Appendix F: sUAS Maintenance Log-book Entry Form

Granting an Exemption is in the Public Interest

In addition to the waiver authority provided in Section 333 ofthe Modernization Act, the FAA maygrant and exemption under 49 U.S.C. Section 44701(f) ifithas determined that such and exemption is in the public interest.
Currently, various businesses musthire traditional manned aircraftto obtain aerial views oftheirpropertyfor inspecting and advertising purposes. These manned aircraft pose significant risk to aircraft operators, nearbyproperty, and persons in the area. The use ofsUAS for asset evaluation would reduce risks to personnel and propertyby allowing for remote aerial review. Further, the uses ofsUAS have the potential to improve efficiency, resulting in faster and safer delivery ofour services, all while reducing risk to human, property

### loss,and environmental impacts.

An exemption would allow Terra Intel to broadly evaluate assets and operations with sUAS, resulting in safer and more efficient inspection and monitoring in the
resource industries. Accordingly, the grant ofan exemption is consistentwith Congress' intent, reflected in Section 333 ofthe FAA Modernization and Reform Act of2012, that safe systems be permitted in the national airspace prior to the issuance offinal regulations governing general use ofthese systems.

Terra Intel's commitmentto safety

This exemption would permitcommercial operations byTerra Intel to conductflight and data collection operations using the sUAS listed above. Terra Intel operation underthe exemption will be subjectto strict operatingrequirements and conditions to ensure an equivalentlevel ofsafety to currently authorized operations using manned aircraft and under conditions as maype modified by the FAA as required by Section 333.

Terra Intel states that all sUAS flights will occur over private or controlled access property, will do so with the property owner's consent and knowledge, and only people who have consented or agreed will be in the area where flights will take place. ,

Terra Intel, LLC Section 333 Exemption RequestTerra Intel will only operate the sUAS in visual line-of-sight (VLOS) ofa pilot and/or observer and will operate at sites thatare sufficient distance from populated areas within the sterile area described in Terra Intel's Flight Operations Operating Manual. This will ensure thatthe sUAS will "notcreate a hazard to users ofthe national airspace system orthe public." Additionally, we will avoid harm to wildlife and their natural habitats.

Terra Intel's crewwill consistofpilots who will hold a FAA commercial pilot certificate with a first class medical certificate or a sports pilotlicense with a Class III Medical Certificate, plus a Visual Observer (VO). We will would follow the manufacturers supplied pilot operations manuals and maintenance manuals for each individual sUAS thatwe intend to fly from the approved list. We will utilize the Pilot Operations Handbook for the Roboflight RF-70 (available upon request) for
our maiden flight, and will obtain and follow the handbooks for each sUAS we intend to fly from the approved list. We will utilize the recommended communication radio frequency of915 MHz.

In keeping with previous exemptions granted, we will ensure that operations will not occurwithin five (5) miles ofan airport. All sUAS operated by Terra Intel will weigh less that fifty-five (55) pounds, including payload (i.e. sensors, camera, lenses, and stabilization gimbals), and operate at speeds below 87 knots, and will not exceed altitudes offour-hundred (400) feet above ground level (AGL).

Given the small size ofthe sUAS and flights conducted over private or controlled areas, Terra Intel's operations adhere to the Reform Act's safetyrequirements. All flight operations will be supervised and monitored by a FAA licensed pilot, which demonstrates Terra Intel's commitment for safe operations with an understanding ofFARs, pre-flight inspections, knowledge offlight operations and difference in airspace classification, maintenance and repair, as well as being trained to high safety standards.

Terra Intel intends to pursue business opportunities in Canada and Mexico. We intend to complywith all regulations governing sUAS operationwithin Canada and Mexico and we will not conduct any cross-border operations. We will also comply with all International Traffic in Arms Regulations (ITAR) and Export Control laws.

We respectfully request exemption under Section 333 to enable Terra Intel to operate efficient, limited, low-risk commercial sUAS operations for the activities stated, respecting at all times the space and privacy or citizens and propertywhile keeping airspace safe.

Terra Intel, LLC Section 333 Exemption RequestVery Respectfully,

# ~~~ CEO and Cofounder Terra Intel, LLC P.O. Box 814 Golden, CO 80402 Business: (501) 231-9035 Email: mike.hanley@terra-intel.net

Terra "Intel, LLC Section 333 Exemption Request