### July 20, 2015

Exemption No. 11393A Regulatory Docket No. FAA

-2014

-1097

Mr. Patrick A. Smith Associate Surveying and Mapping, LLC 4801 Southwest Parkway, Building Two, Suite 100 Austin, TX 78735

Dear Mr. Smith:

This letter is to inform you that we have granted your petition for an amendment. It explains the basis for our decision, describes its effect, and lists any changes to the original conditions and limitations.

By letter dated May 5, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Surveying and Mapping, LLC (hereinafter petitioner or operator) for an amendment
to your current exemption. That exemption from §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR) allows the petitioner to operate a UAS to perform aerial data collection

. You requested an amendment to add the 3DRobotics Aero

-M, 3D Robotics Iris+, and Trimble UX5.

In your petition, you indicate that there has been no change in the conditions and reasons relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested amendment to the exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. The unmanned aircraft authorized in the original grant are comparable in type, size, weight, speed and operating capabilities to those in this petition

.

### 2

Airworthiness Certification

In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 11393 remains valid and is in the public interest. Therefore, under the authority contained in 49 U.S.C

. 106(f), 40113, and 44701, delegated to me by the Administrator, the operator is granted an amendment to add new aircraft to its UAS operations.

The operator shall add this amendment to its original exemption.

Conditions and Limitations

All conditions and limitations within Grant of Exemption No. 11393 remain in effect except as follows. Condition No. 1 has been updated to reflect the additional aircraft

. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Allied Drones HornetCam, 3DRobotics Aero

-M, 3D Robotics Iris+, and Trimble UX5 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresMay 5, 2015 Surveying And Mapping, LLC
4801 Southwest Parkway, Building Two, Suite 100, Austin, TX 78735 Ofc 512.447.0575 Fax 512.326.3029 info@sam.biz www.sam.biz TX Firm# 10064300

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590



### RE: Request to Amend Exemption Number 11393 (Granted 20 April 2015) issued pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations in Regulatory Docket No. FAA-2014-0353-0001

Dear Sir or Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, Pub. 

### L. No. 112-95, 126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the 

### "Reform Act") and 14 C.F.R. Part 11, Surveying And Mapping, LLC 

### ("SAM" or 

### "Applicant"), developer and operator of small unmanned aircraft systems (singularly a 

### "sUAS" or cumulatively 

### "sUASs") equipped to conduct professional aerial land surveying and geospatial services, hereby applies for a petition to amend Exemption Number 11393, granted April 20, 2015 (the 

### "Exemption"), to allow commercial operation ofthree additional sUAS, so long as such operations are conducted within and under the conditions outlined by the grant ofthe Exemption.

As SAM is only requesting to add aircraft to the Exemption, we do not feel that this amendment qualifies as precedent-setting, per guidance located at: http://aes.faa.gov/Petition/faq5a.html. The Applicant respectfully submits that good cause exists

so that notice does not need to be published in the Federal Register for the requested amendment.

Currently, per paragraph 1 ofthe section of exemption number 11393 named "Conditions and Limitations", SAM's exemption is limited to operations using the Allied Drones HometCam, and proposed operations ofany other aircraft require a petition to amend exemption number 11393.

The name and address ofthe applicant is:

Surveying And Mapping, LLC Attention: Pat Smith 4801 Southwest Parkway Bldg. Two, Suite 1 00 Austin, TX 78735 Telephone: (512) 685-3542 Email: psmith@sam.bizThe Applicant hereby requests to amend the Exemption, and the issuance ofan FAA Form 7711- 1 UAS COA Attachment, to allow the use ofthe following three sUAS:

1. 3DRobotics Aero-M aircraft 2. 3DRobotics Iris+ aircraft, and 3. Trimble UX5 aircraft.

(Aircraft numbered 1, 2 and 3 above, collective the "Amendment Aircraft")

In parallel to the Exemption, these aircraft will be used for commercial aerial data collection by Applicant. Aircraft technical data and checklists are attached to this petition, labeled Annex A (Aero-M Operation Manual), Annex B (Iris+ Operation Manual), and Annex C (UX5 Operation Manual). Previously granted exemptions 11379, 11204, 11329, and 11257 allowed for theuse of the Amendment Aircraft, respectively, for commercial purposes, and we feel this petition to amend 11393 is similar in material respects to the aforementioned granted exemptions, and similar in all material respects to Exemption Nos. 11062, 11109, 11112, and 11213, referenced in the Exemption. In accordance with the conditions and limitations granted to SAM under 11393, the applicant requests exemption from the following while operating the Amendment Aircraft:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extentnecessaryto allow thepetitionerto operate a UAS to perform aerial data collection.

In accordance with the section of 11393 known as "Conditions and Limitations", SAM hereby requests to operate the Amendment Aircraft while adhering to the conditions and limitations listed below:

1. Operations authorized by this amendment to the Exemption are limited to the 3DRobotics Aero-M, the 3DRobotics Iris+, and the Trimble UX5 Aircraft each when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a
new petition or a petitionto amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitudemust be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective

### lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required ofthe VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If

a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It 

### is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents ifit petitions for extension

or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner
so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspectingthe UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificateor a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his orher pilot cettificate.

14. The operatormay notpermit any PIC to operate unless the PIC demonstrates the abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances fi:om persons, vessels, vehicles and structures. PIC qualification flight hours and currencymustbe logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator's PICs and VOs (training, proficiency, and experience-building) and determiningthe PIC's abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operatethe UA with appropriate distance from nonparticipants in accordancewith 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA- published aeronautical chart, unless a letter ofagreement with that airport's management is obtained

or otherwise permitted by a COA issued to the exemption holder. The letter ofagreement with the airport managementmust be made available
to the Administratoror any law enforcementofficial upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibilityis less than 3 statute miles from the PIC.

18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-accessproperty.

19. The PIC must abort the flight in the event ofunpredictedobstacles or emergencies.

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20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended bythe manufacturer ifgreater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted underthe terms ofthe attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used bythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any time the aircraft is operating. These documents must bemade availableto the Administratoror any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. TheUAS maynot be operatedby the PIC from anymoving device orvehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonpatiicipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipatingpersons; and

b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determinedthat it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons underthis exemption.27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's 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.

Unless otherwise specified in this grant ofexemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

Summary

Approval ofthis amendment to the granted Exemption and the issuance ofan FAA Form 771 I-1 UAS COA Attachment, allowing the operation of the aircraft listed in this document, will provide an equivalent level of safety supporting the amendment requested herein. The Amendment Aircraft possess even more enhanced safety features than the Allied Drones HometCam which was approved for use in the Exemption, and when operated within the conditions and limitations outlined in the Exemption are far safer than conventional operations conducted with manned aircraft used for aerial data acquisition.

Please let me know ifyou have any questions concerning this request for an amendment to the Exemption.



# u~ Patrick A. Smith, RPLS Associate Surveying and Mapping LLC (SAM) 4801 Southwest Parkway Parkway Two, Suite 100 Austin, TX 78735 Direct 512.685.3542

Attachments:

Annex A (Aero-M Operation Manual) Annex B (Iris+ Operation Manual) Annex C (UX5 Operation Manual)