UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

GATEWAY GEOSPATIAL, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.23(a) & (c), 

61.101(e)(4) & (e)(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) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF TRIMBLE GATEWING X-100 UNMANNED AIRCRAFT SYSTEM 

AND THE AIRCRAFT APPROVED BY THE SECRETARY OF THE 

DEPARTMENT OF TRANSPORTATION FOR OPERATION UNDER 

SECTION 333 PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on December 16, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................3

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .................................................4

BACKGROUND .................................................................................................................5

BASIS FOR THE PETITION..............................................................................................6

NAME AND ADDRESS OF THE PETITIONER........................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GATEWAY 

GEOSPATIAL, LLC SEEKS EXEMPTION................................................................7

THE EXTENT OF RELIEF GATEWAY GEOSPATIAL, LLC SEEKS AND THE 

REASON GATEWAY GEOSPATIAL, LLC SEEKS THE RELIEF...........................7

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................10

THE REASONS WHY GRANTING GATEWAY GEOSPATIAL, LLC'S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ...............................................................24

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT GATEWAY GEOSPATIAL, LLC'S REQUEST ...............................27

CONCLUSION.................................................................................................................28
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

OEM Original Equipment Manufacturer 

PIC Pilot In Command

RTH Return To Home

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing 
4

SUMMARY

GATEWAY GEOSPATIAL, LLC (hereinafter “Gateway”) by and through undersigned 

counsel, pursuant to the provisions of the Federal Aviation Regulations and the Federal Aviation 

Administration (“FAA”) Modernization and Reform Act of 2012, Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator for an exemption from 

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)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the 

extent necessary to allow the petitioner to operate the Trimble Gatewing X-100 (“Trimble X100”) Unmanned Aircraft System (“UAS”) and the aircraft approved by the Secretary of the 

Department of Transportation for operation under Section 333 (collectively the “subject 

UAS”), as shown in Attachment 1, to perform aerial data collection.

1

 

Gateway submits that operation of these aircraft, which with the exception of the Trimble 

X-100 have already been approved for use by the Secretary of the Department of Transportation 

under Section 333, will maintain the safety of the National Airspace System (“NAS”), as well as 

the safety of persons or property on the ground. 

In support thereof, Gateway states as follows:

INTRODUCTION AND INTERESTS OF THE PETITIONER

Gateway Geospatial, LLC is a small business headquartered in Wildwood, Missouri, just 

west of St. Louis, which has been providing specialized surveying, mapping, and other 

geospatial services since 1996. Gateway offers its private and government clients services in the 

architectural/engineering/construction (AEC), precision agriculture, land use planning, mining, 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard a UA. Examples 

include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, 

etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard a 

UA.
5

materials, mapping, surveying, and forestry markets, as well as others. Gateway will utilize its 

UAS to commercially provide professional geospatial services to clients associated within the 

aforementioned markets. Use of the Trimble X-100 UAS and the aircraft approved by the 

Secretary of the Department of Transportation under Section 333 will provide Gateway a modern 

and efficient means to perform its business operations. Gateway’s employees consist of 

individuals possessing a wealth of experience covering both UAS operation and geospatial data 

acquisition and will ensure that any operation of UAS in connection with a grant of this Petition

is performed safely and in accordance with the guidance set out by the FAA.

BACKGROUND

Unmanned Aircraft Systems

Gateway seeks an amendment to operate the Trimble X-100 UAS and the aircraft 

approved by the Secretary of the Department of Transportation under Section 333 (See 

Attachment 1) for compensation or hire within the NAS pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (Public Law 112-95). The FAA has previously 

approved for Measure, a 32 Advisors Company, LLC (“Measure”) to conduct aerial data 

collection operations utilizing the aircraft approved by the Secretary under Section 333 in Grant 

of Exemption Number 12646.2 As discussed herein, the relief requested by Gateway is in all 

material respects similar to that of Measure; it is similar in all material respects to the relief 

previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213; and the 

 

2 Measure’s Grant of Exemption Condition and Limitation Number 1 stated the following:

Operations authorized by this grant of exemption are limited to the aircraft approved by the Secretary of the 

Department of Transportation for operation under Section 333 (Attachment 1) 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.

“Attachment 1” included 324 different UAS models approved for operation under Section 333 at the time of 

submission.
6

reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also 

apply to the present situation. Additionally, granting Gateway’s Petition for Exemption would 

be in the public interest.

BASIS FOR THE PETITION

Gateway, by and through undersigned counsel, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to operate the subject UAS within the National Airspace System (NAS), and for 

an exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(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) & (a)(2), and 91.417(a) & (b). In consideration of their size, weight, speed, and 

limited operating area, Gateway’s operation of the Trimble X-100 UAS and the aircraft approved 

by the Secretary of the Department of Transportation under Section 333 meets the conditions of 

FMRA Section 333.

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Gateway Geospatial, LLC

17336 Orrville Road

Wildwood, Missouri 63005

The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com
7

B. The Specific Sections Of 14 C.F.R. From Which Gateway Seeks Exemption.

Gateway seeks exemption from the following sections of Title 14 of the Code of Federal 

Regulations:

 61.23(a) & (c), entitled Medical certificates: Requirement and duration

 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and limitations

 61.113(a), entitled Private pilot privileges and limitations: Pilot in command

 61.315(a), entitled What are the privileges and limitations of my sport pilot 

certificate

 91.7(a), entitled Civil aircraft airworthiness

 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested areas

 91.121, entitled Altimeter settings

 91.151(a)(1), entitled Fuel requirements for flight in VFR conditions

 91.405(a), entitled Maintenance required

 91.407(a)(1), entitled Operation after maintenance, preventative maintenance, 

rebuilding, or alteration

 91.409(a)(1) & (a)(2), entitled Inspections

 91.417(a) & (b), entitled Maintenance records

C. The Extent Of Relief Gateway Seeks And The Reason Gateway Seeks The Relief.

1. Extent of Relief Gateway Seeks And The Reason Gateway Seeks Relief From 

Section 61.23(a) & (c).

Relief from Sections 61.23(a) & (c), entitled Medical certificates: Requirement and 

duration, is requested to the extent necessary to allow an adequately certificated PIC holding an 

FAA-issued medical certificate or U.S. issued driver’s license, to conduct the proposed UAS 

flight operations for compensation or hire.
8

This relief is requested since the limitations set forth in Section 61.23(a) state that the 

holder of a recreational pilot, private pilot, commercial pilot, airline transport pilot certificate, or 

flight instructor certificate must also hold the appropriate FAA-issued medical certificate to 

exercise the privileges of the pilot certificate. The relief is further requested since the limitations 

set forth in Section 61.23(c) state that the holder of a sport pilot certificate must also hold a U.S. 

issued driver’s license when exercising the privileges of the certificate in a light sport aircraft.

2. Extent of Relief Gateway Seeks And The Reason Gateway Seeks Relief From 

Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a).

Relief from Sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and

limitations; Section 61.113(a), entitled Private pilot privileges and limitations: Pilot in 

command; and Section 61.315(a), entitled What are the privileges and limits of my sport pilot 

certificate, is requested to the extent necessary to allow a PIC holding a sport pilot, recreational 

pilot, or private pilot certificate, as well as an airman medical certificate or U.S. issued driver’s 

license, and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire, subject to the conditions and limitations below.

This relief is requested since the limitations set forth in Sections 61.101(e)(4) & (e)(5) 

state that no person who holds a recreational pilot certificate may act as pilot in command of an 

aircraft for compensation or hire or in furtherance of a business. Relief is requested from 

61.113(a) since the limitations set forth in that section state that no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or hire, act as pilot in command 

of an aircraft. Relief is requested from 61.315(a) since the limitations set forth in that section

only allow a person who holds a sport pilot certificate to act as pilot in command of a light-sport 

aircraft.
9

3. Extent of Relief Gateway Seeks And The Reason Gateway Seeks Relief From 

Section 91.7(a).

Relief from Section 91.7(a), entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Gateway to determine that the subject UAS are in an airworthy 

condition prior to every flight by ensuring that the subject UAS are in compliance with their

operating documents. Gateway seeks the requested relief because the subject UAS do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

4. Extent of Relief Gateway Seeks And The Reason Gateway Seeks Relief From 

Section 91.119(c).

Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than 

congested areas, is required because all proposed operations of the subject UAS will take place 

at an altitude at or below 400 feet AGL. This relief is requested since the limitations set forth in 

Section 91.119(c) state that no person may operate an aircraft below 500 feet above the surface. 

Additionally, relief from Section 91.119(c) is requested to the extent necessary to allow 

operations to be conducted closer than 500 feet to persons, vessels, vehicles, or structures, under 

certain conditions. This relief is requested since the limitations set forth in Section 91.119(c)

prohibit operating an aircraft closer than 500 feet to a person, vessel, vehicle, or structure. 

5. Extent Of Relief Gateway Seeks And The Reason Gateway Seeks Relief

From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the subject UAS, because the subject UAS’ altitude reporting equipment may be 

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before 

each flight. Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. 
10

6. Extent Of Relief Gateway Seeks And The Reason Gateway Seeks Relief 

From Section 91.151(a)(1).

Relief from Section 91.151(a)(1), entitled Fuel requirements for flight in VFR conditions, 

is requested to the extent required to allow flights of the subject UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR). Gateway seeks the 

requested relief because without an exemption from Section 91.151(a)(1), the flight time 

duration of the subject UAS will severely constrain the practicality of any aerial acquisition and 

research flight operations that Gateway proposes to conduct pursuant to this Petition.

7. Extent Of Relief Gateway Seeks And The Reason Gateway Seeks Relief 

From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b).

Gateway requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b) to the extent necessary to allow the proposed operations in accordance with the 

conditions and limitations set forth below. Since the aforementioned Sections only apply to 

aircraft with an airworthiness certificate, Gateway requests relief from these Sections because the 

subject UAS do not require an airworthiness certificate. 

D. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Gateway Seeks Exemption.

1. Reasons Why The Subject UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and operating limitations associated with the 

unmanned aircraft and their operation, Gateway’s operation of the subject UAS meets the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. In seeking this exemption, Gateway submits that the Trimble 

X-100 UAS and the aircraft approved by the Secretary of the Department of Transportation 
11

under Section 333 can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the subject UAS; (b) the pilot certification

requirement; and (c) the specific operating limitations. Additionally, the UAS and proposed 

operations requested in this petition are similar in all material respects to relief previously 

requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 12301, and the reasons 

stated by the FAA for granting those Exemptions also apply to the present situation.

a. The Aircraft Approved By The Secretary Of The Department Of 

Transportation Under Section 333 Have Already Been Determined To 

Be Safe By The FAA.

Gateway proposes that it may safely operate the aircraft approved by the Secretary of the 

Department of Transportation for operation under Section 333, as listed in Attachment 1, within 

the NAS because the proposed aircraft have already been determined to be safe for operation in 

previous grants of exemption and will be operated pursuant to the conditions and limitations set 

out below, which are similar in all material respects to all other grants of exemption allowing 

aerial data collection operations. 

b. The Trimble X-100 UAS Is Safe For Use Based Upon Its Size, Weight, 

Speed, And Operational Limitations.

The technical specifications of the Trimble X-100 are set forth at pages 42-44 of the 

Trimble X-100 User Manual, attached hereto as Exhibit A. Exhibit A contains proprietary 

information and is to be held in a separate file. A complete description of the specifications of 

the Trimble X-100 UAS Ground Control Station is provided at pages 99-101 of the Trimble X100 User Manual. The subject UAS is compliant with all Federal Communications Commission 

(FCC) requirements. The Trimble X-100 UAS was the subject of a previous grant of exemption, 

No. 10808, where it was found to be safe for domestic operations consisting of research and 

development, crew training and market surveys associated with ground surveys without meeting 
12

the fuel requirements for VFR. Further, the Trimble UX5 UAS, most recently approved for use 

under Section 333 in Exemption No. 12785, is in all material respects similar to the Trimble X100 AUS. Gateway proposes that the Trimble X-100 is likewise safe for the operations proposed 

herein, when conducted pursuant to the conditions and limitations listed below.

i. The Trimble X-100 UAS’ Autonomous Flight Features And 

Failsafes Enable It To Remain Within A Defined Operational 

Area.

The Trimble X-100 UAS is enabled to enter autonomous flight under certain contingency 

situations or at the command of the PIC. The subject UAS autonomous features include the 

following: a GPS Position and Altitude Hold when initiated by the Ground Control Station; a 

Return To Home (RTH) function; and Flight Limits (i.e., pre-set limitations that restrict the 

distance and height of the UAS flight operations). A complete description of the autonomous 

features and failsafes of the Trimble X-100 UAS is provided at pages 197-207 of the Trimble X100 User Manual, attached hereto as Exhibit A.

c. Flight Operations Of The Subject UAS Are Limited To The Line Of 

Sight Of A Certificated Pilot In Command With A Safety Observer.

Gateway will only utilize pilots who possess at least an FAA-issued sport pilot certificate 

and current and valid FAA-issued airman medical certificate or valid U.S. issued driver’s license

to act as a pilot in command (PIC) of the subject UAS. Additionally, a safety observer will assist 

all pilots during flight operations.

d. Flights Of The Subject UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Gateway proposes to commercially operate the subject UAS

for the special purpose of conducting aerial acquisitions within the NAS, pursuant to the 

following specific operating limitations:
13

1. Operations authorized by this grant of exemption are limited to the Trimble Gatewing 

X-100 Unmanned Aircraft System and the aircraft approved by the Secretary of the 

Department of Transportation (Attachment 1) for operation under Section 333 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 grant. 

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). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the 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 of the flight. The PIC 

must ensure that the VO can perform the duties required of the 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 if it 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 
14

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 a VO 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 inspecting the 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. If the

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 limit requirements for the aircraft and aircraft 

components.

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

bulletins.

13. Under this grant of exemption, 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 certificate or a valid U.S. driver’s license issued by a state, 

the District of Columbia, 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 or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to 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 from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.51(b). Flights for the purposes of training the operators, PICs, and VOs

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

this exemption are permitted under the terms of this 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 
15

are considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 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 of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s management 

is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official 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 visibility is less than 3 statute miles from the PIC.

18. For tethered UAS operations, the tether line must have colored pennants or streamers 

attached at not more than 50 foot intervals beginning at 150 feet above the surface of the 

earth and visible from at least one mile. This requirement for pennants or streamers is not 

applicable when operating exclusively below the top of and within 250 feet of any 

structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

21. 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 by the manufacturer if greater.

22. 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 under the terms of the attached COA.

23. 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 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the UAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the
16

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

25. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

26. The UAS may not be operated by the PIC from any moving device or vehicle.

27. 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 of an accident. The operator must 

ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately in a manner ensuring the 

safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

28. 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.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the 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. If this exemption permits operations for the 

purpose of closed-set motion picture and television filming and production, the following 

additional conditions and limitations apply.

30. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

31. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards District 

Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification 
17

may be waived with the concurrence of the FSDO. The plan of activities must include at 

least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation 

of the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and the 

altitudes essential to accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, 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.

2. Reasons Why An Exemption From The Requirements Of Sections 61.23(a) & 

(c) Would Not Adversely Affect Safety.

Gateway submits that an equivalent level of safety established by Sections 61.23(a) & (c) 

will be maintained because no PIC will be allowed to operate the subject UAS unless that PIC 

holds either a valid FAA-issued medical certificate or a valid U.S. issued driver’s license. 

Additionally, no PIC will be allowed to operate the subject UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able 
18

to safely operate the subject UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, 

and structures.

Considering Gateway’s proposed area of operations, the relatively small size of the 

subject UAS, and the operating limitations set forth in this Petition, as well as the parallel nature 

of sport pilot, recreational pilot, and private pilot medical requirements, relating to the proposed 

operations, Gateway submits the additional requirements of at least a third-class airman medical 

certificate would not correlate to Gateway’s proposed operations.

3. Reasons Why An Exemption From The Requirements Of Sections 

61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect 

Safety.

Gateway submits that an equivalent level of safety established by Sections 61.101(e)(4) 

& (e)(5), 61.113(a), and 61.315(a) will be maintained because no PIC will be allowed to operate 

the subject UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the subject UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles, and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 take-offs and 

landings in the preceding 90 days (for currency purposes).

Considering Gateway’s proposed area of operations, and the operating limitations set 

forth above; the parallel nature of sport pilot, recreational pilot, and private pilot aeronautical 
19

knowledge requirements, with respect to the proposed operations, to those of commercial pilot 

requirements (See Exemption Nos. 11062 and 11213); and the airmanship skills necessary to 

safely operate the subject UAS, Gateway submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for Gateway’s specific proposed flight operations.

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that 

was obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during Gateway’s proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 take-offs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct Gateway’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Gateway will ensure safe operations by not allowing any PIC to operate the 

subject UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 
20

requirements, that the PIC is able to safely operate the subject UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

4. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Gateway will ensure that the subject UAS are in an airworthy condition 

based upon the subject UAS’ compliance with their respective operating documents, and as 

stated in the conditions and limitations herein.

5. Reasons Why An Exemption From The Requirements Of Section 91.119(c) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained 

because in any operation to be conducted closer than 500 feet from any nonparticipating persons, 

barriers or structures will be present to sufficiently protect any nonparticipating persons from 

debris in the event of an accident during operation of the subject UAS, which weigh less than 

fifty-five (55) pounds and will be operated below an altitude of 400 feet AGL. The 

nonparticipating persons will be required to remain in the area of protection, and if any 

nonparticipating person leaves the area of protection and is within 500 feet of the subject UAS, 

flight operations will cease immediately.

Additionally, any operation to be conducted closer than 500 feet from persons, vessels, 

vehicles, and structures would first require the permission of the land owner/controller and a 

safety assessment of the risk of operating closer to those objects by the PIC.
21

6. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude of the subject UAS will be reported to air traffic control (ATC) in feet above ground 

level (AGL), and Gateway will operate the subject UAS within visual line of sight, at or below 

400 feet AGL. Prior to each flight, a zero altitude initiation point is automatically established by 

the UAS at ground level. 

7. Reasons Why An Exemption From The Requirements Of Section 

91.151(a)(1) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 91.151(a)(1) as a result of (1) the technical specifications of the subject UAS; (2)

the limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, Gateway will ensure that it will safely operate the subject UAS during 

daylight hours in visual metrological conditions (VMC) under visual flight rules (VFR), with 

enough power for the subject UAS to fly after the first point of intended landing for at least five 

(5) minutes.

In addition to the level of safety established by the technical specifications of the UAS; 

the limitations on the proposed flight operations; and the location of the proposed operations, the 

subject UAS warnings to the PIC when the UA has low power remaining. Together, these factors 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(a)(1).

Previous exemptions granted by the FAA concerning Section 91.151, establish that safety 

is not adversely affected when the technical characteristics and operating limitations of the

subject UAS are considered. Relief has also been granted for manned aircraft to operate at less 
22

than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. 

8. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety.

In seeking this exemption, Gateway submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because all 

maintenance, alterations, and preventive maintenance of the subject UAS performed by Gateway

will be in accordance with the methods, techniques, and practices prescribed in the operating 

documents. Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM 

maintainers will perform higher level inspections and maintenance per the operating documents 

and OEM standards. Gateway will document and maintain all maintenance records for the 

subject UAS. 

Since the subject UAS will be inspected as prescribed by the operating documents, 

Gateway will maintain the equivalent level of safety established by Sections 91.405(a),

91.409(a)(1), and 91.409(a)(2). The following operating document is attached hereto, identified 

as Exhibit A: The Trimble Gatewing X-100 UAS User Manual. The foregoing exhibit contains

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). All 

other operating documents for the subject UAS have been previously submitted to the FAA and 

will not be included with this Petition.

Additionally, an equivalent level of safety established by Sections 91.407 (a)(1), 

91.417(a), and 91.417(b) will be maintained because Gateway will document and maintain all of 

the maintenance records for the subject UAS. 
23

 9. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Gateway requests that the FAA

prescribe special conditions for the intended operation of the subject UAS, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) 

& (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b). Such special conditions will permit safe operation 

of the subject UAS for the limited purpose of conducting aerial acquisitions within the NAS for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the subject UAS, since the airworthiness regulations of 14 C.F.R. Part 

21 do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.
24

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Gateway’s intended operation of the subject UAS, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.23(a) & 

(c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

E. The Reasons Why Granting Gateway’s Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Gateway to 

safely, efficiently, and economically provide professional geospatial data collection services to 

clients in both the public and private sectors. Additionally, use of the subject UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of Gateway’s proposed operation of the subject UAS will be realized 

without implicating any privacy issues. 

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The subject UAS serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of the subject UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, and 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The subject 

UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial survey missions would result in fewer aircraft that must be handled by air 
25

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

3. The Public Will Benefit From The Safety And Efficiency Of The Subject 

UAS.

Conducting aerial acquisitions with the subject UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial survey flight operations. By using battery power and electric motors, or in 

some cases small unleaded gasoline engines, the subject UAS produce substantially smaller 

quantities of air pollution, if any at all, and are the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are 

typically utilized for aerial acquisitions, and burn approximately 20-30 gallons per hour of leaded 

aviation fuel. The subject UAS, while reducing the carbon footprint of aerial acquisitions, also 

reduce noise pollution, as they are propelled by battery powered electric motors or small unleaded 

gasoline powered engines, which produce minimal amounts of noise in comparison to traditional 

aircraft engines.

By using the subject UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flightcrew members located onboard the aircraft, the subject UAS, has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with a 

wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

Additionally, using the subject UAS to perform aerial acquisitions will increase the level 

of safety and efficiency for Gateway’s employees, associated contractors, and public employees by 
26

minimizing exposure to a number of hazards typically encountered in a field environment, such as 

bridges, wetland areas, and steep terrain, as well as lowering the number of incidents and 

associated costs, such as maintaining a certain level of insurance, that normally coincide with 

operations in a hazardous field environment. 

4. Performing Aerial Acquisition Operations With The Subject UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the subject UAS are also an economical alternative 

to using manned aircraft to conduct aerial acquisitions. As such, operation of the subject UAS 

will allow United States based companies, like Gateway, to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, 

U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operation of UAS such as those in this petition is one such technology that 

not only allows companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operational cost of a traditional manned aircraft. 

By operating UAS, companies such as Gateway, can remain competitive and profitable, 

and therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the subject UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and abroad. 

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Gateway’s proposed operation of the subject UAS will not implicate any privacy issues. 
27

Specifically, the subject UAS will only be operated pursuant to the specific conditions and 

limitations set forth herein, and in accordance with the Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the subject UAS

will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, that is not 

directly involved in the operation unless specific conditions are met.

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which Gateway Seeks Exemption:

Gateway Geospatial, LLC seeks exemption from the requirements of 14 C.F.R. Sections 

61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Gateway Seeks:

This exemption will permit Gateway Geospatial, LLC to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions 

within the National Airspace System (NAS).

G. Any Additional Information, Views, Or Arguments Available To Support 

Gateway’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, Gateway’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Gateway will operate the subject UAS safely in the NAS,

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 
28

national security. Additionally, with the exclusion of the Trimble X100, the subject UAS have 

all been previously approved for use under Section 333.

CONCLUSION

As set forth herein, Gateway Geospatial, LLC seeks an exemption pursuant to 14 C.F.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the Trimble Gatewing X-100 UAS and the aircraft approved by the 

Secretary of the Department of Transportation (Attachment 1) for operation under Section 333

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

acquisitions within the National Airspace System (NAS). By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Gateway to 

safely, efficiently, and economically operate the subject UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Gateway Geospatial, LLC respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit Gateway Geospatial, LLC to operate the Trimble Gatewing X-100 UAS and the aircraft 

approved by the Secretary of the Department of Transportation (Attachment 1) for operation 

under Section 333 commercially for the purpose of conducting aerial acquisitions within the 

NAS.
29

Dated: December 16, 2015 Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner 
30

ATTACHMENT 1
31

1. 2AgEagle

2. 3D Robotics Aero-M

3. 3D Robotics Iris

4. 3D Robotics Iris+ 

5. 3D Robotics X8

6. 3D Robotics DIY Quad Kit

7. 3DRobotics Fixed Wing

8. 3DRobotics Multirotor

9. 3DRobotics Quadrotor

10. 3DR Solo

11. 3DR Spektre

12. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

13. 3D Robotics Solo

14. 3DRobotics X8+

15. 3D Robotics X8-M

16. 3D Robotics Y6

17. ACS XX8L

18. Aerial Mob Heavy Lifter

19. Aerial Mob Light Lifter

20. Aerial Remote Mineral Detection System (ARMDS)
32

21. Aerialtronics Zenith with integrated Airware system

22. Aerialtronics Altura Zenith ATX8

23. Aerigon

24. Aerobo

25. AeroCine Kopterworx Hammer X12

26. AeroLogix GeoStar

27. Aeromao AeroMapper 300

28. Aeromao Talon

29. Aeromao Aeromapper EV-2

30. Aeronavics SkyJib 8 v.2 Heavy Lifter

31. Aeronavics X4 Titanium

32. AeroVironment Shrike

33. AeroVironment Puma

34. Aervonics Sky Jib frame with a DJI A2 flight system

35. Aeryon Sky Ranger

36. Aeryon Scout

37. AgEagle 

38. AgEagle Robotic

39. AgGasser

40. AgScout
33

41. AgScout Mini

42. Agribotix Hornet Drone

43. Agribotix Enduro Quad

44. AgriView VK Ranger EX

45. Aibot

46. Aibotix X-6 

47. Air Rover AR-3000

48. AirCover QR-425s

49. AirRobot AR 100

50. AirRobot AR 180

51. AirRobot AR200

52. Air-X

53. Align M690

54. Allied Drones Chaos X-8

55. Allied Drones HornetCam

56. Allied Drones HV44

57. Altavian Nova F6500

58. Altavian Nova R8400 

59. Altus X-4

60. Altus X-8
34

61. American Drones, LLC Eagle 

62. Apprentice

63. Arch Aerial OCTO multi-rotor UAS

64. Arris hexacoper

65. AR-960 Hex Rotor

66. AR-540 Quad Rotor

67. ARF-MikroKopter OktoXL

68. ARF-MikroKopter OktoXL + 

69. ArrowLite

70. AscTec Falcon

71. AscTec Falcon 8

72. Astraeus Aerial Cinema System V.3CS

73. ATI AgBot

74. ATI AgGasser

75. ATI Thor X4

76. Atlantic RC Aircraft LC04

77. Auburn Trimble UX5

78. Auburn War Eagle

79. Auburn EasyStar

80. Auburn
35

81. AV44

82. AV-900

83. Birdseyeview Aerobotics Firefly 6

84. Bixler 3DR Plane

85. Blade 350QX

86. Blade 350 QX3

87. Bixler 2 

88. Boomerang Carbon Fiber Frame (The Identified System) 

89. Bormatec Maja UAV

90. BOSH Technologies Super Swiper

91. Bumblebee-S

92. C-Astral Bramor gEO

93. CarbonCore Octocopter 1000

94. Carbon Core Cortex Quadcopter

95. CCO w/Wkm M 

96. Chameleon Pro

97. CinesStar 

98. Cinestar 6

99. Cinestar X8

100. Cinestar 8
36

101. Cinestar 8 HL

102. Cinestar 8 Okto XL 

103. Coaxial Quad Multirotor VAO1-V1

104. Coaxial Quad Multirotor VAO2-V2

105. CopelandRED LLC Delta Wing Aircraft

106. CyberQuad Maxi

107. DAx8

108. DJI Flame Wheel F450

109. DJI Flame Wheel F550

110. DJI Inspire

111. DJI Inspire 1

112. DJI Inspire 2

113. DJI M P330z 

114. DJI Matrix

115. DJI Matrice 100

116. DJI Phantom

117. DJI Phantom 1

118. DJI Phantom 2 

119. DJI Phantom 2+

120. DJI Phantom 2 Vision
37

121. DJI Phantom 2 Vision+ 

122. DJI Phantom Vision + 

123. DJI Phantom 3 

124. DJI Phantom FC40 

125. DJI Spreading Wings S900 

126. DJI Spreading Wings S1000 

127. DJI Spreading Wings S1000+

128. DJI S800

129. DJI S800 EVO

130. DJI T600

131. Draganflyer Guardian

132. Draganflyer X4ES

133. Draganflyer X4P

134. Draganflyer X6

135. Drone-Fleet Carbon Fiber V5

136. DT-18 

137. DYS D800-X8

138. Eagle VTOL

139. Eagle V2

140. E-Flite Apprentice
38

141. Event 38 E384

142. F-450

143. Falcon VTOL

144. Fire Fly 6

145. First Aerial Responder UAV

146. Flame Wheel G4 7.8 Skycrane 

147. Flying-Cam 3.0 SARAH

148. Foxtech Kraken 130 V2

149. FreeFly Systems ALTA RTF

150. FreeFly Systems Octocopter Airframe (Legacy)

151. G4 models

152. GeoStar 

153. GerMAP G180

154. GerMAP G220

155. goFarm GF-1 

156. Gryphon Dynamics X8 

157. GT80X 

158. Harris 18 HL

159. HEFF

160. Helicopters West DJI Inspire
39

161. Helicopters West SkyJib 8 

162. Helios 960

163. Hawkeye Mk-III 

164. HexaCrafter HC-1100 

165. HexaCrafter HO-1250

166. HH Blade 350QX2 AP

167. Hobbyking “Bixler” Fixed Wing Trainer

168. HoneyComb AgDrone

169. Horizon Hobby Blade 350 Qx2 quadcopter

170. Hoverfly LiveSky, BigSky 60 and H-Frame

171. Hubsan X4 micro drone 

172. HVP 14301 MultiRotor

173. Identified System

174. IMT Global xFold Cinema

175. Indago

176. Industrial Aerobotics SD02

177. InovalDrone:Inova One

178. InstantEye Mk-2

179. InstantEye Mk-2 Gen2

180. Intuitive Aerial Aeragon
40

181. K130 Octocopter

182. KongCopter X8

183. Kopterworx Hammer X12

184. Latitude HQ-4 Hybrid Multirotor

185. LB700 

186. Leading Edge Precision Vision 10

187. Leptron Avenger

188. Lewis Realty Associates Hexacopter 650

189. Liberty 1

190. Lockheed Martin Desert Hawk III

191. Lockheed Martin Indago 

192. MaxFlight

193. Microdrones MD4-200

194. Microdrones MD4-1000

195. Microdrones MD4-3000

196. Mikrokopter 2.5

197. MLB Company Super Bat

198. Monarch Ag

199. MU-1H 

200. Multirotor G4 7.8 Skycrane
41

201. Multirotor G4 Eagle

202. Nighthawk

203. Nighthawk VTOL

204. OktoXL 6S12

205. PAG X4

206. Parksone Radian RTF

207. Parrot Bebop drone

208. Parrot PF 725100 Bebop Drone 14MP

209. Parrot Skycontroller

210. Patriot X4

211. Patriot X8

212. Finwing Penguin V2

213. Phoenix

214. Phoenix VTOL 

215. Phoenix 60

216. Phoenix 60LE

217. Pixhawk

218. Precision Drone Pacesetter 

219. PrecisionHawk

220. PrecisionHawk Hawkeye Mk-III
42

221. PrecisionHawk Lancaster

222. Precision Lancaster MK3

223. PreNav 1.0

224. Prioria Hex

225. Prioria’s Maveric

226. Pulse Aerospace, PA 01 Vapor

227. Pulse Aerospace Pulse Vapor 35 

228. Pulse Vapor

229. Puma AE DDL

230. PV 14817 Multi Rotor

231. PV HL1

232. PV HL2

233. Q1 

234. Quadcopter LLC MikroKopter 

235. Quiet UAV

236. Qube

237. Range Video RVJet

238. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift 

Prof. Multi Rotor

239. RCTimer Hexacopter

240. RDASS
43

241. REHawk 500

242. REHawk 680

243. RF-70

244. Riegl RiCopter

245. RITEWING Z3 Spade 47”

246. Ritewing Drake 60”

247. RITEWING Z3 Spade 70”

248. RITEWING Z4 Spade 52”

249. RMAX

250. Roboflight RF-70

251. Ronin Octo-Ashley

252. Ronin Octo-Mary Kate

253. Rotomotion SR-15 

254. Scout X4

255. SD02

256. Seahawk 1.2 

257. SelectTech Geospacial’s EH-4

258. SenseFly eBee 

259. SenseFly eBee RTK

260. SenseFly eXom
44

261. Sensurion Magpie MP-1

262. Service-Drone Recon One

263. Service-Drone Blackbird

264. SH 900

265. ShadowHawk 

266. Shrike 

267. Sirius Basic

268. Sirius Pro

269. Skycatch

270. SkyPhilly MI

271. Skywalker Aero

272. Skywalker Flying Wing X8

273. SkyWard 1

274. SnapRoll Media SUAS

275. Solutions Phoenix 30

276. Stark Aerospace ArrowLite

277. SteadiDrone

278. Steadidrone Quad 

279. Steadydrone QU4D 

280. Steadidrone Mavik
45

281. SuperX/P2 Multirotor

282. Swift Radioplanes Lynx

283. Tali 500

284. Talon 120LE

285. Tarot FY690S Hexacopter

286. Tarot quadcopter

287. Tarot 680pro

288. Tarot 690 

289. Tarot 900

290. Tarot 960

291. Tarot T-15

292. Tarot T15 C/F Folding Octocopter

293. Tarot T18 UAV 

294. Tarot T690

295. Tarot T810 

296. Tarot T960

297. Tarsier Systems MoAC

298. Tayzu Robotics Titan X8

299. TBS Discovery Pro

300. Team Black Sheep Discovery Pro Tarot T15
46

301. Thrust UAV Freeflight X4

302. T-Rex 700E F3C 

303. TREX 800E DFC PRO

304. Trimble UX5

305. Trimble UX5 hp

306. Trimble ZX5

307. Turningy Talon 500

308. TUP X8-800

309. Turbo Ace CINEWING 6

310. TurboAce Matrix-G quadcopter

311. Turbo Ace matrix-E

312. Turbo Ace MATRIX-1

313. UAV Factory Penguin B

314. UAV Solutions Phoenix 60

315. Universeye Penguin 

316. Universeye Penguin V2

317. Unmanned Flying Rolling Orb “UFRO”

318. US2 GreenHawk 

319. UtiliCopter ITX8

320. VA03-v1 
47

321. VA04-v1 

322. VA07-v1

323. Vanguard Defense Industries ShadowHawk

324. Viking UAS Multicopter (VTOL)

325. Viking UAS FF-X4/X8

326. VK-Patriot X4/X8

327. Viking UAS Patriot X4/X8 Multirotor

328. Viking UAS X6 Model 800

329. Viking UAS Viking ONE

330. VK-450

331. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX 

332. Viking VK-FF-X4

333. VK-Ranger EX-SAR Fixed Wing UAS

334. Volantex Raptor Tarot T-18

335. Volt Aerial Robotics Octane

336. Vulcan X8 controlled by a DJI A2 flight controller

337. Vulcan Mantis

338. Vulcan Octocopter

339. Vulcan Raven

340. Vulcan UAV 
48

341. Walkera TALI H500

342. Walkera Scout X4

343. Wookong DJI 5800 

344. xCel Drones XD550CDR

345. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 

Copter

346. X8-M

347. Yuneec Electric Aviation Model Q500 Typhoon