4 December 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request

Re: Petition for Exemption (14 CFR 911.8U by the Federal Aviation Administration ("FAA") for the

usage of Small, Unmanned Aerial Systems ("sUAS") for geospatial applications.

Dear Sir or Madam,

l, Brock Boven, Founder and CEO of BatchMaps GIS Consulting, LLC, a GIS consulting company in

Phoenix, AZ, am petitioning to be granted exemption from the Federal Aviation Regulations ("FAR")

listed in Section 2 of this document. lt is my full intention to be compliant with the FAA Modernization

and Reform Act of 2012, Public Law 112-95, Sections 331-334 ("The Act"), and to operate sUAS

exclusively for the purposes defined in Section 3 of this document.

BatchMaps GIS Consulting, LLC is a consulting firm that provides geospatial, mapping, and surveying

services and products to several industries in the United States. The company finds innovative ways to

increase clientele safety, efficiency and profitability through the utilization of GlS-related technologies.

BatchMaps GIS Consulting, LLC believes that geographic understanding is instrumental in helping

develop solutions to issues on any organizational level. Along with mapping software and GPS systems,

sUAS technology is another critical tool in developing the highest quality data collection and geospatial

analysis platforms for our customers.

Section 1: Petitioner Contact lnformation

Brock Boven

BatchMaps GIS Consulting, LLC

3501 E Camelback Rd Unit 128

Phoenix, AZ 85018

Phone: 480.447.6140

Email : brock@ batchmapsgis.com

Website: http ://www. batch ma psgis.com

EIN:45-4194341

Section 2: Sections of Title 14 CFR that BatchMaps GIS Consulting, LLC wishes to be granted Exemption

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

2. Chapter 1, Subchapter C, Part 45, 545.23(a)

3. Chapter 1, Subchapter D, Part 61,561.113(a),(b)

4. Chapter 1, Subchapter F, Part 91, S91.119(d)

5. Chapter 1, Subchapter F, Part 91,591.121(a)

6. Chapter 1, Subchapter F, Part 91, 591.7(a)

Section 3: Extent of Relief and Reasons for Requesting Relief from Regulations

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BatchMaps GIS Consulting, LLC is requesting relief from the Title 14 CFR regulations in order to engage in

sUAS operations that will benefit the company, the company's clientele, and the geospatial community.

The extent by which BatchMaps GIS Consulting, LLC seeks relief is exclusive to the following applications:

o Aerial Photography and Videography: With the use of a rotating camera (0 - 90 degrees)

attached to the sUAS, BatchMaps GIS Consulting, LLC is capable of capturing oblique aerial

imagery and video for the presentation and marketing of real estate properties (housing,

commercial, industrial). Real estate brokers and developers requesting these products will

benefit by reaching a larger audience and giving their prospective buyers an in depth

understanding of property and community features from a remote environment. Capturing

aerial photography and videography by method of sUAS technology, as opposed to

rnanned/fixed wing aircraft, will allow for significant reduction in cost, heightened safety for the

pilot and community, less impact on the environment, and increased image resolution due to

lower flight path altitudes.

o OrthoAerial lmagery Collection and GtS Analysis: With the use of a fixed, downward facing

camera {90 degrees}, BatchMaps GIS Consulting, LLC is capable of capturing high-resolution

overlapping aerial images for the production of ortho-rectified basemap layers. Post-processing

this imagery within Geographic lnformation System software allows for multiple spatial

applications such as density analysis, volumetric analysis, vegetation analysis and 3D analysis.

These types of sUAS data collection and GIS analysis are intended solely for customers in the

fields of agriculture, archaeology, and natural resource management. Capturing ortho-aerial

imagery by method of sUAS technology will allow for much higher resolution, faster processing

time, more current datasets, and more cost-effective data collection than satellite or fixed wing

aircraft methods.

Section 4: Public Benefrts from BatchMaps GtS Consulting LLC's Exemption Request

The public benefits from BatchMaps GIS Consulting, LLC's intended operations of sUAS listed in Section 3

are as follows:

o The operation of sUAS fleets has many advantages over similar data collection techniques of

manned vehicles that subsequently benefit the public via economic, environmental, and public

safety avenues:

Economic: sUAS operations are significantly cheaper than those of manned vehicles

(helicopters) and directly impact the final cost of products and services. This will, in return, cut

consumer spending costs. Growth of the sUAS industry will account for increased job creation in

both the private and public sectors.

Environmental: The operation of BatchMaps GIS Consulting, LLC's sUAS fleet is entirely battery

powered. This will account for a significant decrease in fossil fuel emissions compared to

manned vehicles. The light weight structure of our sUAS fleet allows for minimal energy

consumption and a significant decrease in the range and intensity of noise pollution.

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Public Safety: Public dangers are nearly nonexistent with the use of sUAS. As opposed to

manned vehicles, rare instances of catastrophic failure and crashes of sUAS will pose little to no

threat to public health and property infrastructure.

o BatchMaps GIS Consulting, LLC is dedicated to implementing sUAS technologies in projects that

benefit both organizations and the public. We are passionate about finding innovative ways to

better lives and rnaking a positive impact on the environment we live in.

Section 5: sUAS Specifications and Safety Requirements

It is BatchMaps GIS Consulting, LLC's intention to add sUAS capabilities to its suite of GIS services for

current and prospective clients. The two applications listed in Section 3 are specific to industries where

risk of human intervention and damage to property are extremely low. Our prospective service areas in

agriculture, archaeology, housing real estate, and natural resource management are in rural regions

with low population densities and pose no threat to current commercial airspace. Commercial/industrial

real estate project areas encompass less than 1/8 of a square mile, which maximizes safety and limits

exposure to civil infrastructure, hospitals, schools and residential communities. BatchMaps GIS

Consulting, LLC has dedicated over 80 cumulative hours studying sUAS safety methods and testing our

fleet's technical systems. We fully understand deployment processes and how to utilize the entire

Failsafe System (low battery and remote disconnect auto-return home functions) in order to return the

sUAS safely to the take off position in the event of a system failure.

BatchMaps GIS Consulting, LLC's sUAS Specificotions

BatchMaps GIS Consulting, LLC's fleet consists of two sUAS with specifications that ensure little to no

impact to the environment and existing infrastructure, and pose no threat to the public and manned

aircraft:

1. DJI Phantom 2 Vision+ (4 propeller quodcopter, plastic/metal):

o TotalWeight: 2.7lbs

o Dimensions: Width - 13.8in, Height - L2.5in

o Maximum Speed: 33.5 miles per hour

o Battery System: Three (3S, 11.1V, 57WH 5200mAh) intelligent flight batteries, each with

25 minutes of flight time and an automated "return home" low battery function

o Camera: Aptina 1/2.3"

o DJI Remote Control Ground Station & Wifi Video Downlink (includes GPS and Compass):

Operating Frequency - 5.728GH2-5.85GH2, CE Compliance Communication Distance -

1,3L2ft, FCC Compliance Communication Distance - 2,624f1, Battery - 3.7V,2000mAh

o Range Extender: Operating Frequency - 2412-2462MH2, Communication Distance -

'J.,640-2,296ft

o DJI Vision Android App: First-Person-View with real-time video monitor for advanced

safety, distance/altitude/speed rnonitoring and control, advanced flight path control

with "return home" function

2. DJI Phantam 3 Professianal {4 prapeller quadcopter, plastic/metal):

o Total Weight: 2.8lbs

o Dimensions: Width - 13.Bin, Height - 12.5in

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Maximum Speed: 35.8 miles per hour

Battery System:Two (4S, 75.2V,68WH 4480mAh) intelligent flight batteries, each with

25 minutes of flight time and an automated "return home" low battery function

Camera: Sony EXMOR 112.3"

DJI Remote Control Ground Station & WifiVideo Downlink (includes GPS and Compass):

Operating Frequency - 2.400GH2-2.483GH2, CE Compliance Communication Distance -

11,088ft, FCC Compliance Communication Distance - 15,368ft, Battery - 5000mAh LiPo

2S

DJI GO Android App: First-Person-View with real-time video monitor for advanced

safety, distance/altitude/speed monitoring and control, advanced flight path control,

GPS-assisted hover, automatic flight logs with "return home" and "follow me" functions

Risks of Operoting o sUAS

BatchMaps GIS Consulting, LLC acknowledges and fully understands the risks involved with operating a

sUAS. ln operating any manned or unmanned aircraft, unforeseen circumstances beyond the pilot's

control may exist. Following proper safety protocols, regularly scheduling sUAS maintenance checks, and

performing monthly pilot training are fundamental in minimizing these risks. The identified risks

involved in flying a sUAS fleet include possible wildlife strikes and physical/electrical faults. BatchMaps

GIS Consulting, LLC's fleet of sUAS include top of the line GPS-navigation and object sensor systems that

aid in the prevention of air and ground impacts. There may be rare instances where potential wildlife

strikes could compromise these systems. Wildlife strikes can cause damage to sUAS quadcopter

propellers that may lead to ground impact. BatchMaps GIS Consulting, LLC's fleet of sUAS also include

advanced notification systems between the sUAS, batteries, and remote ground station

controller/application. Complete system status of sUAS distance, altitude, speed, and battery levels are

streamlined to the First-Person-View real-time video monitor. ln the event of a sUAS or remote ground

station low battery warning, the sUAS is programmed to safely return and land at its take-off position. ln

the rare instance of a complete electrical system failure, this "return-home" function could be

compromised and lead to ground impact.

BatchMaps GIS Consulting, LLC's Commitment to Salety ond Regulotory Compliance

lf an exemption is granted, BatchMaps GIS Consulting, LLC will be committed to full compliance with the

statutes set forth by The Act. When the additional Certificate of Authorization {"COA') process is

completed thereafter, BatchMaps GIS Consulting, LLC will be able to operate sUAS in a commercial

manner. BatchMaps GIS Consulting, LLC will implement the follow procedures and guidelines:

o Ensure pre-flight checklist is complete before each flight

o Notify clientele and/or property owners of flight time and location prior to operation, as well as

when the flieht(s) is completed

o Ensure the project area is at least five miles from any airport and does not fall within National

Park boundaries or other restricted airspaces

o Check commercial flight patterns using a consumer-grade tracking application to ensure no

conflict of airspace is present

o Ensure the sUAS maintains a distance of at least 500' from people, vehicles, and infrastructure

o Check weather conditions prior to flight to ensure flight performance and line-of-sight visibility

is acceptable

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Equip sUAS with allflightworthy components

Bring necessary spare parts (propellers, landing gear, batteries), tools, and battery charging

equipment to each flight location

Test communication between the sUAS and the remote ground station, camera, and FirstPerson-View real-time monitor before each flight

Activate sUAS GPS system and ensure the minimum number of seven satellites are

communicating with the sUAS before each flight

Calibrate altimeters to a maximum altitude of 300' AGL to ensure sUAS does not fly beyond an

acceptable range

Ensure that sUAS maintains visual line-of-sight distance during flight operations and a trained

spotter is on-site with the pilot

Adhere to post-flight guidelines by powering off sUAS and remote ground, stowing away all

sUAS components in protective case, and securing any entry/exit ways on property

Carry copies of all FAR Exemption documentation, including licenses, if applicable

Comply with any future regulations enforced by the FAA FAR

Section 6: Federal Register Rulemaking and Reasoning for Exemption

7. Title 74, CFR 27: Certificotion Procedures for Products and Ports Subpart H, Airworthiness

Ce rtificotes (5 21. 17 1 - 521. 199 )

Section 333 of The Act states:

(1-) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed,

operational capability, proximity to airports and populated areas, and operation within visual

line of sight do not create a hazard to users of the national airspace system or the public or pose

threat to national security; and,

(2) weather a certificate of waiver, certificate of authorization, or airworthiness certification

under section 44704 of Title 49, United States Code, is required for the operation of unmanned

aircraft systems identified under paragraph (1)

Reasons for Exemption: The combined operational specifications of BatchMaps GIS Consulting,

LLC's sUAS fleet consisting of small size and weight, low speed, and limited range in distance and

altitude and cornpliance with proximity to airport and populated area regulations both meet the

level of safety compliance proposed by Section 333. Paragraph (1) states that if sUAS meet this

requirement, exemption from 14 CFR 21, Subport H may be granted.

2. Title 74, CFR 545.23(o),(b): Display of Marks: Generol

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman

capital letter "N" (denoting United States registration) followed by the registration number of

the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the

words "limited," "restricted," "light-sport," experimental," or "provisional," as applicable.

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4.

Reasons for Exemption: (a): BatchMaps GIS Consulting, LLC's sUAS surface areas are not large

enough to attach a discernible registration number greater than 2" in height (applicable only to

545.23b). The addition of attachment objects by which registration number must be visible may

obstruct usage of sUAS due to the additional payload weight, which may result in flight

instability and/or failure. (b): The classification of sUAS under the current regulatory restriction

period is unclear, therefore, this exemption shall remain active.

Title 14 CFR 961.11i(o): Privote Pilot Privileges ond Limitations

(a) Except as provided in paragraphs (b)through (h)of this section, 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.

Reasons for Exemption: Since BatchMaps GIS Ccnsulting, LLC's fleet of sUAS are unrnanned, it is

not possible to carry passengers. However, company assets (gimbal and camera) for the

purposes of aerial photography, data collection and GIS analysis will be a part of the sUAS

payload, and the company's pilot will be compensated for services and deliverables associated

with operating the sUAS.

Title L4 CFR 99L.11"9(d): Minimum Sofe Altitudes: General

(d) Helicopters, powered parachutes, and weight-shift-contro! aircraft.lf the operation is

conducted without hazard to persons or property on the surface -- (1i A helicopter may be

operated at less than the minimums prescribed in paragraph (lr - 1000') or (c - 500') of this

section, provicled each person operating the helicopter complies with any routes or altitudes

specifically prescribed for helicopters by the FAA.

Reasons for Exemption: Since the sUAS pilr:t rnust comply u,riiir a maximum of 300' AGL, and

stay below the 500' restriction for nianned aircraft in non-corigested areas, this exemption

applies specificallyto the routes anclaltitudes for helieonters. Additional research on tn€

location of tire se helicopter flight cori'idors wiil be conducted hefore any sUAS flight ooeration

Titie 14 CFR 59L.121{a}: Altimeter Settings

/al Farh pprsnn nperatino an airrraff 5hall m;1int2in the crrrising altitr.rcf e 11r flight lerrel of that

arrcraft, as the case may be, by reference to an aitimeter that is set, when operating --

{1) Below 18,000 feet MSL, to --

(i) The current reported altimeter setting of a station along the route and within L00 nautical

miies of the aircrart; (ii) if rhere is no sration wirhin the area prescriireci in paragrapir (a)(1)(i)of

this secticln, the current reported altimeter setting of an appropriate available station; or (iii) ln

the case of an aircraft not equlipped with radio, the elevation of the departure airport or an

appropriaie aitimeter setting available before departure; or

(2) At or above i.8,000 feet MSL, to 29.92" fr1.

Reasons for Exemption: BatchMaps GIS Consulting, LLC's sUAS altinreter seittings are controlled

by a built-in GPS-based altimeter. The pilot automatically receives sUAS attitude, distance, and

speed measurements throughout each flight via the remote ground station system. Cruising

altitude does not apply to sUAS within BatchMaps GIS Consuiting, LLC's operations, unless this

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term is used to describe the altitude, in which a specific altitude can be set using an automated

flight path.

5. Title 74 CFR 591.7(o): Civil Aircrafi Airworthiness

(a) No person may operate a civil aircraft unless it is in an airworthy condition,

Reasons for Exemption: The 14 CFR 21 Subpart H exemption from requiring airworthiness

certificates for sUAS stated in Section 6(1) is the reason for this exemption.

Section 7: Additional lnformation, Views or Arguments

Personol Stotement

BatchMaps GIS Consulting, LLC embraces the highest of standards in safety and quality when providing

products and services to its customers. Agreement and awareness of the FAA's rules and regulations for

operating a fleet of sUAS is of our utmost concern. BatchMaps GIS Consulting LLC is fully committed to

abiding by all laws associated with usage of sUAS. Our goal is to bring the next level of G|S-related

products and services to our clientele through sUAS technology. Usage of sUAS technology in the fields

of agriculture, archaeology, natural resource management, and real estate will allow for increased

safety, efficiency, and profitability not only for customers, but for the public and geospatial community

alike. We appreciate the opportunity to petition for this exemption and would be honored to be a part

of the sUAS community.

Section 8: Exemption Outside the United States

BatchMaps GIS Consulting, LLC has no intention to operate a sUAS outside of the United States at this

time.

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Brock Boven, Founder & CEO

BatchMaps GIS Consulting, LLC

To the Director and Administration of the Federal Aviation Administration, I hereby submit this Petition

for Exemption, dated December 4,20t5.

Regards,

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