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## THEDOBBINS COMPANY

!Nl:>IJHRlAL LIQUIDATIONS & APPRAISALS SINCE 1975 August 11,2015

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Filed with wvvw.regulations.gov

Re: Petition for Exemption Under Section 333 ofthe FAA ReformActand Part 11 ofthe Federal AviationRegulations

Dear Sir or Madam,

Pursuantto Section 333 ofthe FAAModernization and ReformAct of2012 (the "ReformAct"), P. L. 112-95, "Special Rules for CertainUnmanned Aircraft Systems" and 14 C.F.R. Part 11, The Dobbins Company (d/b/a Sky SightImaging), seeks an exemption from the Federal Aviation Regulations ("FARs") 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 • 404-352-2638Summarized for purposes ofFederal Registerpublication: Applicantseeks an exemptionfrom thefollowing rules:. 14 C.F.R. Part21, 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 unmannedvehicle (55lbs or less) augmenting its landsurveying operations.

Contactinformation for the Applicant 

### is: The Dobbins Company (d/b/a Sky Sight Imaging) 3827 CliffCrest Dr Smyrna, GA 30080 Att: Rick Dobbins rick@lobbinscompanv,_com Previous 333 Exemption for Aerial Data Collection Exemption # 11373 Regulatory Docket# FAA-2015-0060 Sky Sight Imaging (SSI), a division ofThe 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 UAVs, the use ofa SenseFly eBee, a fixed wing UAV 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 additionto aerial datacollection. These operations will be subjectto strict operating and conditions defined by the UAV manufacturer's standards and procedures Upon receipt ofthe exemption contemplated herein, SSI shall obtain a Certificate ofWaiver or Authorization (COA) from the FAApriorto conducting operations inthe national air space. By this petition, SSI seeks an exemptionthat will authorize itto use the eBee for provided its operators comply with any terms and conditions ofthe FAA's anticipated grant ofexemption, including the procedures and requirements set forth in the respective manufacturer's user manuals Under the requested exemption, SSI as operator ofthe eBee, will ensure that the aircraft will be operated an FAA licensed pilot with at least a sportpilot designation and by an individual who has completedthe UAV manufacturer's training program for operation oftheUAS.1. CHARACTERISTICS OF THE AIRCRAFT The eBee is a small and ultra-lightplatformthatperformprecision aerial mapping missions using onboard GPS and relatedproprietary flight management software that allows the operatorto plan safely and efficiently a missionin 3D, and thenmonitor itinreal-time. Anembedded camera, protectedby a foam envelope, takes a collection ofhigh-definition Still images that are used laterto generatephotographs, maps and contour lines ofthe surveyed area. The four main characteristics ofthe UAVs are:

a. Very light weight The vehicles are light enoughthatthe operatorcanlaunch itby hand and let it land on almost any surface withoutrequiring aparachute or landing net (belly land). Theirlow kinetic energy also significantly reduces the risk ofhazardous situations. Finally, wings are detachable and made offlexible foam with no sharp orhard edges and almostno 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 ofcontactwith any object.

c. Semi-automatic flight The artificial intelligence incorporated withinthe UAVs autopilot system continuously analyzes datafrom the Inertial MeasurementUnit and from the onboard GPS and takes care ofall the aspects ofthe flight underthe supervision ofthe operator. d. Option for Manual control. Additionally, the UAVsprovide an override capability that allows the operatorto manually initiate autonomous actions during the flight such as "returnhome", "land" or, "hold and resume the mission". The operator can also suspend automated operations and take manual control ofthe aircraft should itbecome necessary to respond to emergency circumstances, thanks to the remote controllerprovidedwiththe system. 2. APPLICATIONS AND ADDED VALUE OF THEUAVs Mapping applications may include agricultural applications, mining, construction and survey/GIS operations. There are many operational benefits related to the use ofthis solution:

a. The UAV'sbring safety to daily survey operations: there is no need for the humansto access dangerous working areas anymore (mining pits, spoil piles, orrough uneven areas). The missions canbe programmed and reproduced reliably as often as needed for regularly updated maps. b. The UAV's are a cost-effective solution. Itis cheaperto operate a UAS ratherthan an aircraft or other ground systems for the same results

c. Users can save time and workmore efficiently by using a UAV. A mission does not need a long preparationtime or long deployment constraints, orlong waitingtime for perfectweather conditions unlike, for example, the use ofsatellites and aerial photography. Initial results are accessible directly on-site, which is impossible with images providedby satellites ormanned aircrafts.d. Lastly, in mining environments, is the safety factor ofallowing a visual viewofa mine site while keeping the employee a safe distance away. The ability ofUAVto remotely gather data in a safe manner cannot be completed as safe ortimely with any othercurrenttechnology. 3.APPLICABLE LEGAL STANDARD UNDER SECTION 333

a. Airworthiness assessment SenseFly has demonstratedtheirrespective airworthiness throughmany and varied national international projects, involving state/federal agencies oruniversities (among others the NewMexico State University: https://newscenter.nmsu.edu/Articles/viewII 0208/nmsu-uasflighttestcenter- conducts-ebee-airworthiness-assessment, and the US Army Corps of Engineers ("USACE")NewOrleans, who coordinatedwiththe Department ofArmy andthe FAA to obtain all authorizations required inorderto operatethe 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 ofSight "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 ofthe exemptionto SSI will be subjectto the following operating conditions; the operator proposes the following conditions and/or limitations, whichwere accepted by the FAA. 1. The UAV will weigh less than 55 lbs. Operations will be limitedto the SenseFly eBee andthe Trimble UX5. 2. Flights will be operatedwithin visual line ofsight (VLOS) ofa Pilotin Command (PIC) and/orVisual Observer (VO). 3. Maximumtotal flight time for each operational flight will be 30 minutes. 4. Flights will be operated at an altitude ofno more than400 feet AGL. 5. The UAS will only operate within a confined, preprogrammed survey area. 6. Pilot and observerwill have beentrained in operation ofUAV andreceivedup to- date information onthe particularUAS to be operated as required in the UserManuals. 7. PIC and VO will at all times be able to communicateby voice and/ortext.8. All lands from the relevantproperty holders will be in direct control ofthe SSI and all requiredpermissions and permits will be obtained from territorial, state, county orcity jurisdictions, including local lawenforcement, fire, or other appropriate governmental agencies. 9. Ifthe UAV looses communications or looses its GPS signal, the UAS will have capabilityto return to a pre-determined locationwithinthe Survey Areaand land. 10. The UAV will have the capability to abort a flight in case ofobstacles oremergencies. 11. Priorto each flight the PIC must inspectthe UAV to ensure it is in a condition for safe flight. All maintenance and alterations mustbe properly documented inthe aircraftrecords. 12. The operatormust follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. Whenunavailable, aircraft maintenance, component, overhaul, replacement, and inspection/maintenancerequirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual: 13. Ifplanned operations occurwithin 5miles ofCommercial Services Airport as definedby the FAA, the operatormust obtain anAir Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting any operations. This COAwill also require the operatorto request a Notice to Airman (NOTAM) not more than 72 hours in advance, butnot less than 48 hours priorto the operation. 14. Before conducting operations, the radio frequency spectrum used for operation and control of the UAV must comply withthe Federal Communications Commission (FCC) orother appropriate government oversight agency requirements. 15. The UAV must remain clear and yieldthe right ofway to all othermanned operations and activities at all. 16. UAV operations may notbe conducted during night. 17. The UAV cannotbe operated by the PIC from any moving device orvehicle. 18. The UAV may notbe operated less than 500 feet belowor less than 2,000 feethorizontally from a cloud orwhen visibility is lessthan 3 statute miles from the PIC. 19. The UA V may not operate in Class B, C, orD airspace without written approval from the FAA. The UA V may not operate within 5 nautical miles ofthe geographic centerofa nontowered airport as denoted on a currentFAA-published aeronautical chartunless a letter of agreement withthat airport's management is obtained. 20. Any 1) incident, 2) accident, or 3) flight operationthattransgresses the lateral orvertical boundaries ofthe operational area as definedby the applicable COAmustbe reported to the Federal AviationAdministration's (FAA) UAS Integration Office (AFS-80) within 24 hours.Accidents mustbe reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: www.ntsb.gov. Further flight operations may notbe conducted until the incident, accident, ortransgression is reviewed by AFS-80 and authorizationto resume operations is provided. The agreementto this requested exemptionwould authorize SSI the ability to provide SAFE, reliable and accurate land mapping informationto safeguardthe SSI employees withthe use of the latest innovative technology associated withremotely piloted aircraft. 

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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 ofthe 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 ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203(a). Given the size ofthe UAVs, their very light weight and the limited operating area associated with its utilization, it is unnecessary to go through the certificate ofairworthiness 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 ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe UAS involved. An analysis ofthese 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 ofthe 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 ofairworthiness 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 ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in therestricted environment and underthe 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 ofsafety will be achieved by keeping a hard copy ofthe user manual in close proximity to the operator. The equivalent level ofsafety 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 UAVwill see the identification ofthe 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 manufacturerwill achieve The equivalent level ofsafety during the in-flight training or affiliate providing the training as described in the manufacturer's training program and through the use ofexperienced and qualified instructors familiar with the UAVs operations. 14 CFR § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil 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 ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Compared to flight operations with aircraft weighing far more than those proposed herein and the lack offlammable 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 altimeterthat is set"

... to the elevation ofthe 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 ofsafety 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 ConditionsThe 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 ofsafety is already achieved with the specific procedure preventing the UAVs accepting a takeofforder 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) ofthis 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 ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAVwill have immediate access to them, to the extentthey are applicable to such UAV. The FAA has issued numerous exemptions to this regulation. A representative sample ofother 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 A07and 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 forthe issuance ofan 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 ofapproval ofthe aircraft for return to service. SSI proposes that the maintenance ofthe 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 ofsafety will be achieved because these smallUAVs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. 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 ofany 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 ofsafety.