U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam, 

8 February 2016 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 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 of small unmanned aerial systems (sUAS). 

Terra Intel is a physics and engineering consulting firm that provides geospatial, 

surveying, geophysical and geosciences services to a wide range of industries in the 

United States. The company leverages the capabilities of mapping software, GPS 

systems, surveying equipment, and high-fidelity sensors (e.g. photogrammetry, 

FLIR) to provide services to industries that rely on them for regulatory compliance, 

public safety, and asset management. Being positioned in this highly competitive 

industry requires a significant investment in the aforementioned software and 

hardware products, but to also be aware of forthcoming technological 

developments. The sUAS is among a group of several technological developments 

that Terra Intel considers to be an important tool that will have a positive impacts 

on the way we perform data collection, asset evaluation, environmental monitoring, 

and visual presentation methodologies, all of which are services we provide to our 

customers. 

The requested exemptions would permit Terra 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 that includes remote 

sensing and mensuration by utilizing instruments aboard the sUAS. Examples 

include imagery (photogrammetry, video, infrared, multi- and hyper-spectral, etc.), 

electronic measurement (mapping and surveying, etc.), or any other gathering of 

data by instruments aboard the sUAS. Commercial areas that would benefit from 

the application of sUAS deployed sensors include: the energy sector; mining; 

agriculture; environmental monitoring; and conservation to name a few. 

Terra Intel's sUAS Fleet Specifications 

To satisfy client requirements in a safe and efficient manner, Terra Intel will utilize a 

fleet of twenty- 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 Request 
Docket No. FAA-2015-1602): 

1.) DJI Phantom 3 

2.) DJI Phantom FC40 

3.) DJI Spreading Wings S900 

4.) DJI Spreading Wings S1000 

5.) DJI Spreading Wings 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.) Tarot T15 C/F Folding Octocopter 

18.) Tarot T18 UAV 

19.) TarotT690 

20.) Tarot T810 

21.) Roboflight RF70 (Spade 70") 

22.) Falcon VTOL 

23.) Fire Fly 6 

Specific Sections of Title 14 CFR that Terra Intel wishes to seek exemption 

We are seeking the following specific exemptions. Please see Appendix C for the 

rationale for each requested exemption. 

1. Chapter 1, Subchapter C, Part 21, Subpart H 

2. Chapter 1, Subchapter C, Part 45, Subpart C, §45.23 (a) and (b) 

3. Chapter 1, Subchapter D, Part 61, Subpart A, §61.23(a) and Chapter 1, 

Subchapter D, Part 61, Subpart J, §61.315(c) (2&3) 

4. Chapter 1, Subchapter F, Part 91, Subpart B, §91.119 

5. Chapter 1, Subchapter F, Part 91, 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, Subpart E, §91.405; §91.407; §91.409; 

§91.411; §91.413; §91.415; §91.417; and §91.421 

10. Chapter 1, Subchapter F, Part 9!, Subpart H, §91.703(a)(1), (3), ( 4), (5), and 

(b), §91.705, and §91.706 

Terra Intel, LLC 

Section 333 Exemption Request 
List of supporting 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 of the Modernization 

Act, the FAA may grant and exemption under 49 U.S. C. Section 44701(f) if it has 

determined that such and exemption is in the public interest. 

Currently, various businesses must hire traditional manned aircraft to obtain aerial 

views of their property for inspecting and advertising purposes. These manned 

aircraft pose significant risk to aircraft operators, nearby property, and persons in 

the area. The use of sUAS for asset evaluation would reduce risks to personnel and 

property by allowing for remote aerial review. Further, the uses of sUAS have the 

potential to improve efficiency, resulting in faster and safer delivery of our 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 of an exemption is consistent with 

Congress' intent, reflected in Section 333 ofthe FAA Modernization and Reform Act 

of 2012, that safe systems be permitted in the national airspace prior to the issuance 

of final regulations governing general use of these systems. 

Terra Intel's commitment to safety 

This exemption would permit commercial operations by Terra Intel to conduct flight 

and data collection operations using the sUAS listed above. Terra Intel operation 

under the exemption will be subject to strict operating requirements and conditions 

to ensure an equivalent level of safety 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 Request 
Terra Intel will only operate the sUAS in visual line-of-sight (VLOS) of a pilot and/or 

observer and will operate at sites that are sufficient distance from populated areas 

within the sterile area described in Terra Intel's Flight Operations Operating 

Manual. This will ensure that the sUAS will "not create a hazard to users of the 

national airspace system or the public." Additionally, we will avoid harm to wildlife 

and their natural habitats. 

Terra Intel's crew will consist of pilots who will hold a FAA commercial pilot 

certificate with a first class medical certificate or a sports pilot license 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 that we 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 of 915 MHz. 

In keeping with previous exemptions granted, we will ensure that operations will 

not occur within five (5) miles of an 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 of four-hundred ( 400) feet above ground level (AGL). 

Given the small size of the sUAS and flights conducted over private or controlled 

areas, Terra Intel's operations adhere to the Reform Act's safety requirements. 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 

of FARs, pre-flight inspections, knowledge of flight 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 comply with all regulations governing sUAS operation within 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 property while 

keeping airspace safe. 

Terra Intel, LLC 

Section 333 Exemption Request 
Very 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