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THE DOBBINS COMPANY 

!Nl:>IJHRlAL LIQUIDATIONS & APPRAISALS SINCE 1975 

August 11,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Filed with wvvw.regulations.gov 

Re: Petition for Exemption 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 of2012 (the "Reform Act"), 

P. L. 112-95, "Special Rules for Certain Unmanned Aircraft Systems" and 14 C.F.R. Part 11, 

The Dobbins Company (d/b/a Sky Sight Imaging), seeks an exemption from the Federal Aviation 

Regulations ("F ARs") and listed below: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 

14 C.F.R. 45.29 

14 C.F .R. 61.23 

14 C.F.R. 61.3 

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. 91.9 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 

14 CFR Subpart E (91.401 - 91.417) 

P. 0. Box 20001 • Atlanta, GA 30325 • 404-352-2638 
Summarized for purposes of Federal Register publication: 

Applicant seeks an exemption from the following rules:. 14 C.F.R. Part 21, 14 C.F.R. 45.23, 14 

C.F.R. 45.29, 14 C.F.R. 61.23, 14 C.F.R. 61.3, 14 C.F.R., 1.113( a) & (b), 14 C.F.R. 61.133( a), 

14 C.F.R. 91. 7(a), 14 C.F.R. 91.9,14 C.F.R. 91.109(a), 14 C.F.R. 91.JJ.9, 14 C.F.R. 91.121,14 

C.F.R. 91.151 (a), 14 C.F.R. 91.203, 14 CFR Subpart E (91.401- 91.417)to operate 

commercially a small unmanned vehicle (55lbs or less) augmenting its land surveying 

operations. 

Contact information for the Applicant is: 

The Dobbins Company (d/b/a Sky Sight Imaging) 

3827 Cliff Crest Dr 

Smyrna, GA 30080 

Att: Rick Dobbins 

rick@lobbinscompanv,_com 

Previous 333 Exemption for Aerial Data Collection 

Exemption # 113 73 

Regulatory Docket# FAA-2015-0060 

Sky Sight Imaging (SSI), a division of The Dobbins Company, is engaged in the business of 

aerial data collection utilizing UAVs including DJI Phantom 2 & Phantom Vision quadcopters 

and subject to a pending 333 amendment, a SenseFly eXom quadcopter in the southeast United 

States. 

This requested exemption would authorize SSI to perform commercial operations, in 

addition to aerial data collection with the above noted U A V s, the use of a SenseFly eBee, a 

fixed wing UA V manufactured by SenseFly, A Parrot Company ("SenseFly") 

The requested exemption would authorize commercial operations using the eBee UAV for 

precision agriculture, land survey and safety applications in addition to aerial data collection. 

These operations will be subject to strict operating and conditions defined by the UAV 

manufacturer's standards and procedures 

Upon receipt of the exemption contemplated herein, SSI shall obtain a Certificate of Waiver or 

Authorization (COA) from the FAA prior to conducting operations in the national air space. 

By this petition, SSI seeks an exemption that will authorize it to use the eBee for provided its 

operators comply with any terms and conditions of the FAA's anticipated grant of exemption, 

including the procedures and requirements set forth in the respective manufacturer's user 

manuals 

Under the requested exemption, SSI as operator of the eBee, will ensure that the aircraft will be 

operated an FAA licensed pilot with at least a sport pilot designation and by an individual who 

has completed the UAV manufacturer's training program for operation ofthe UAS. 
1. CHARACTERISTICS OF THE AIRCRAFT 

The eBee is a small and ultra-light platform that perform precision aerial mapping missions using 

onboard GPS and related proprietary flight management software that allows the operator to plan 

safely and efficiently a mission in 3D, and then monitor it in real-time. An embedded camera, 

protected by a foam envelope, takes a collection of high-definition 

Still images that are used later to generate photographs, maps and contour lines of the surveyed 

area. 

The four main characteristics of the UAVs are: 

a. Very light weight The vehicles are light enough that the operator can launch it by hand and let 

it land on almost any surface without requiring a parachute or landing net (belly land). Their low 

kinetic energy also significantly reduces the risk of hazardous situations. Finally, wings are 

detachable and made of flexible foam with no sharp or hard edges and almost no internal 

strengthening structure. 

b. Electric-powered The UAVs are electric-powered. A brushless engine technology makes it 

silent and reliable. The propeller can easily flex away in case of contact with any object. 

c. Semi-automatic flight The artificial intelligence incorporated within the UAVs autopilot 

system continuously analyzes data from the Inertial Measurement Unit and from the onboard 

GPS and takes care of all the aspects of the flight under the supervision of the operator. 

d. Option for Manual control. Additionally, the UAVs provide an override capability that allows 

the operator to manually initiate autonomous actions during the flight such as "return home", 

"land" or, "hold and resume the mission". The operator can also suspend automated operations 

and take manual control of the aircraft should it become necessary to respond to emergency 

circumstances, thanks to the remote controller provided with the system. 

2. APPLICATIONS AND ADDED VALUE OF THE UAVs 

Mapping applications may include agricultural applications, mining, construction and 

survey/GIS operations. There are many operational benefits related to the use of this solution: 

a. The UAV's bring safety to daily survey operations: there is no need for the humans to access 

dangerous working areas anymore (mining pits, spoil piles, or rough uneven areas). The missions 

can be programmed and reproduced reliably as often as needed for regularly updated maps. 

b. The UA V's are a cost-effective solution. It is cheaper to operate a UAS rather than an aircraft 

or other ground systems for the same results 

c. Users can save time and work more efficiently by using a UAV. A mission does not need 

a long preparation time or long deployment constraints, or long waiting time for perfect weather 

conditions unlike, for example, the use of satellites and aerial photography. Initial results are 

accessible directly on-site, which is impossible with images provided by satellites or manned 

aircrafts. 
d. Lastly, in mining environments, is the safety factor of allowing a visual view of a mine site 

while keeping the employee a safe distance away. The ability ofUAV to remotely gather data in 

a safe manner cannot be completed as safe or timely with any other current technology. 

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333 

a. Airworthiness assessment 

SenseFly has demonstrated their respective airworthiness through many and varied national 

international projects, involving state/federal agencies or universities (among others the 

New Mexico State University: https:/ /newscenter.nmsu.edu/ Articles/view II 0208/nmsu-uasflighttestcenter- conducts-ebee-airworthiness-assessment, and the US Army Corps of 

Engineers ("USACE") New Orleans, who coordinated with the Department of Army and the 

FAA to obtain all authorizations required in order to operate the eBee UAS). Moreover, 

SenseFly has obtained flight approvals for the eBee from the national civil aviation authority in 

many countries, including: 

Switzerland (flight approval for Visual Line of Sight "VLOS" operations) 

Canada (flight approval for VLOS operations) 

Australia (flight approval for VLOS operations) 

France (flight approval for Extended-VLOS operations) 

Germany (flight approval for VLOS operations) 

United Kingdom (flight approval for VLOS operations) 

Norway (flight approval for VLOS operations) 

Sweden (flight approval for VLOS operations) 

Denmark (flight approval for VLOS operations) 

Grant of the exemption to SSI will be subject to the following operating conditions; the operator 

proposes the following conditions and/or limitations, which were accepted by the FAA. 

1. The UAV will weigh less than 55 lbs. Operations will be limited to the SenseFly eBee and the 

Trimble UX5. 

2. Flights will be operated within visual line of sight (VLOS) of a Pilot in Command (PIC) 

and/or Visual Observer (VO). 

3. Maximum total flight time for each operational flight will be 30 minutes. 

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

5. The UAS will only operate within a confined, preprogrammed survey area. 

6. Pilot and observer will have been trained in operation ofUAV and received up to- date 

information on the particular UAS to be operated as required in the User Manuals. 

7. PIC and VO will at all times be able to communicate by voice and/or text. 
8. All lands from the relevant property holders will be in direct control of the SSI and all 

required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

9. If the UAV looses communications or looses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Survey Area and land. 

10. The UA V will have the capability to abort a flight in case of obstacles or emergencies. 

11. Prior to each flight the PIC must inspect the UA V to ensure it is in a condition for safe flight. 

All maintenance and alterations must be properly documented in the aircraft records. 

12. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance, component, overhaul, replacement, and inspection/maintenance requirements must 

be established and identified in the operator's manual. At a minimum, the following must be 

included in the operator's manual: 

13. If planned operations occur within 5 miles of Commercial Services Airport as defined by the 

FAA, the operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations. This COA will also require the 

operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not 

less than 48 hours prior to the operation. 

14. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UAV must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

15. The U A V must remain clear and yield the right of way to all other manned operations and 

activities at all. 

16. UAV operations may not be conducted during night. 17. The UAV cannot be operated by 

the PIC from any moving device or vehicle. 

18. The UAV may 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. 

19. The UA V may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA V may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport's management is obtained. 

20. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within 24 hours. 
Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided. 

The agreement to this requested exemption would authorize SSI the ability to provide SAFE, 

reliable and accurate land mapping information to safeguard the SSI employees with the use of 

the latest innovative technology associated with remotely piloted aircraft. 

;ttf)!L 

Rick Dobbins, COO 

The Dobbins Company ( d/b/s Sky Sight Imaging) 
ANNEXA 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

SSI requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the SenseFiy eBee: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

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 of the UAVs, their very light weight and the limited operating area associated with 

its utilization, it is unnecessary to go through the certificate of airworthiness process 

under Part 21 Subpart H in order to achieve or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the Reform Act. The Federal Aviation Act 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 UAS involved. An 

analysis of these different criteria demonstrates that the UAVs operated without an 

airworthiness certificate, under the conditions proposed in that exemption, will be at 

least as safe, or safer, than a conventional aircraft with an airworthiness certificate. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to 

the cabin, cockpit, and or pilot station. Given the size of the UAVs, this requirement is 

impossible to match. A suitable letter size will be selected. 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness 

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 UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS 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. 

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements 

The equivalent level of safety will be achieved by keeping a hard copy of the user 

manual in close proximity to the operator. 

The equivalent level of safety will be provided by having the UAVs marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

UAV will see the identification of the UAS as "Experimental." The FAA has issued the 

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

10167A. 

14 C.F.R. § 91.109(a): Flight Instruction 

The 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."The 

manufacturer will achieve The equivalent level of safety during the in-flight training or 

affiliate providing the training as described in the manufacturer's training program and 

through the use of experienced and qualified instructors familiar with the UAVs 

operations. 

14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. The exemption 

requests authority to operate at altitudes up to 400 AGL, it will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Compared to flight operations with 

aircraft weighing far more than those proposed herein and the lack of flammable fuel, 

any risk associated with these operations is far less than those presently presented with 

conventional aircraft. 

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 UAV may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption is requested. 

An equivalent level of safety will be achieved by the operator confirming the altitude of 

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

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 
The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing 

and to fly after that for at least 30 minutes. As the UAVs are electric-powered, this 

requirement is inapplicable. In any event, given the contemplated operations, FMC 

believes that an equivalent level of safety is already achieved with the specific 

procedure preventing the UAVs accepting a takeoff order is the battery level is below a 

given value. Moreover, the manufacturers have integrated low and critical battery level 

warnings and implemented a "return to home" action in these situations. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• 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. 

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UAV will have immediate access to them, to the 

extent they are applicable to such UAV. 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 Subpart E (91.401 - 91.417): Maintenance, Preventive Maintenance, and 

Alterations 

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with Parts 39 and 43. 

Paragraphs 91 A07 and 91 .409 require the aircraft to be "approved for return to service 

by a person authorized under 43.T' after maintenance and inspection. Section 91.409 

requires an annual inspection for the issuance of an airworthiness certificate. Section 91 

A 17 requires the owner or operator to keep records showing certain maintenance work 

that has been accomplished by certificated mechanics, under Part 43, or licensed pilots 

and records of approval of the aircraft for return to service. 

SSI proposes that the maintenance of the UAVs will be accomplished by the owner or 

the operator according to the manufacturers user manual 

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 herein. An equivalent level of safety will be achieved because these small 
UAVs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAV can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will 

ensure that the UAS 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.