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 GISConsulting, LLC, a GISconsulting company in Phoenix, AZ,am petitioning 

### to be granted exemption 

### from the FederalAviation 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 

### forthe purposes defined in Section 3 of this document.
BatchMaps GISConsulting, 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 GISConsulting, 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 isanother critical 

### tool in developing 

### the highest quality data collection and geospatial analysis platforms 

### for our customers.
Section 1: 

### Petitioner Contact 

### lnformation

Brock Boven BatchMaps GISConsulting, LLC 3501 ECamelback 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 GISConsulting, LLCwishes 

### 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

Page 1BatchMaps GISConsulting, 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, andthe geospatial community. The extent bywhich BatchMaps GIS Consulting, LLCseeks relief isexclusive 

### to the 

### following applications: 

## o Aerial Photography and Videography: 

### Withthe use of a rotating camera (0 - 90 degrees) attached 

### tothe sUAS, BatchMaps GISConsulting, LLC is capable of capturing oblique aerial imagery andvideofor 

### the presentation and marketing 

### of real estate properties (housing, commercial, industrial). Realestate 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 andvideography by method of sUAStechnology, 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 GtSAnalysis: 

### Withthe useof afixed, downward facing camera {90 degrees}, BatchMaps GISConsulting, 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 sUAStechnology 

### will allow

### for much higher resolution, faster processing 

### time, more current datasets, and more cost-effective data collection than satellite orfixed 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 asfollows: 

## o The operation 

### of sUASfleets 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 GISConsulting, LLC's sUAS

### fleet is

### entirely battery powered. This

### will account 

### for asignificant decrease in fossil fuel emissions compared

### to manned vehicles. The lightweight structure of our sUAS

### fleet allows 

### for minimal energy consumption and asignificant decrease in

### the range and intensity 

### of noise pollution.

Page 2Public Safety: Public dangers are nearly nonexistent 

### with the useof 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 isdedicated 

### to implementing sUAStechnologies in projects 

### that benefit both organizations and

### the public. We are passionate about finding innovative ways

### to better lives and rnaking a positive impact onthe environment we live in.

Section 5: sUAS Specifications and Safety Requirements
It is BatchMaps GISConsulting, LLC's intention 

### to add sUAS capabilities

### to itssuite 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 asquare mile, which maximizes safety and limits exposure 

### to civil infrastructure, hospitals, schools and residential communities. BatchMaps GIS Consulting, LLC hasdedicated over 80 cumulative hours studying sUAS safety methods andtesting 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 inthe event 

### of a system failure. BatchMaps GISConsulting, LLC's sUAS Specificotions
BatchMaps GISConsulting, LLC's

### fleet consists of

### two sUAS 

### with specifications 

### that ensure 

### little

### to no impact

### tothe environment and existing infrastructure, and pose no 

### threattothe 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 DJIVision 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 TotalWeight: 2.8lbs 

## o Dimensions: 

### Width - 13.Bin, Height - 12.5in

Page 3Maximum 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 GISConsulting, LLCacknowledges and

### fully understands 

### the risks involved

### with operating a sUAS. lnoperating 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 inflying a sUAS 

### fleet include possible 

### wildlife strikes and physical/electrical faults. BatchMaps GISConsulting, 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 GISConsulting, 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 

### tothe 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 acomplete 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 isgranted, BatchMaps GIS Consulting, LLC

### will be committed 

### to full compliance 

### with the statutes set

### forth byThe Act. When 

### the additional Certificate of Authorization {"COA') process is completed 

### thereafter, BatchMaps GISConsulting, LLC

### will be able 

### to operate sUAS in acommercial manner. BatchMaps GISConsulting, 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

### flighttime and location prior 

### to operation, aswell as when the flieht(s) is completed 

## o Ensure 

### the project area isat leastfive 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 

### toflightto ensure 

### flight performance and line-of-sight 

### visibility is acceptable a
a

a
a

Page 4Equip 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 sevensatellites 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 atrained 

### spotter ison-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, CFR27: Certificotion Procedures 

### for Products and Ports Subpart H,Airworthiness
Certificotes (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 acertificate ofwaiver, 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 GISConsulting, 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 meetthis requirement, exemption 

### from 14 CFR21, 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. Eachsuffix 

### 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 eachentrance

### tothe 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. a
a

a
a

Page 54. Reasons 

### for Exemption: (a): BatchMaps GISConsulting, LLC's sUAS surface areas are 

### not large enough 

### to attach adiscernible registration number greater than 2" in height (applicable only 

### to 545.23b). The addition of attachment objects bywhich registration number must bevisible may 

### obstruct usage of sUAS due

### tothe 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 CFR961.11i(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 iscarrying passengersor 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 GISanalysis 

### 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 SofeAltitudes: 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 

### specificallytothe 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 CFR59L.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 

### aitimeterthat is set,when operating

-- {1) Below 18,000 

### feet MSL, 

### to

-- (i)The

### current reported 

### altimeter setting of astation 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 GISConsulting, 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 eachflight via 

### the remote ground station system. Cruising 

### altitude does not apply 

### to sUAS

### within BatchMaps GISConsuiting, LLC's operations, unless this

Page 6

### term is used 

### to describe 

### thealtitude, inwhich a specific 

### altitude can be set using an automated 

### flight path. 

# 5. Title 74 CFR591.7(o): Civil 

### Aircrafi Airworthiness (a) No person may operate a civil 

### aircraft unless 

### it is in an 

### airworthy condition,
Reasons 

### for Exemption: The 14 CFR21 Subpart Hexemption 

### 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 GISConsulting, LLCembraces 

### 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 isof 

### our utmost concern. BatchMaps GIS 

### Consulting LLC is

### fully committed 

### to abiding byall 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 sUAStechnology inthe 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

### theopportunity 

### to petitionfor this exemption and

### would be honored

### to be a part of

### the sUAS community.
Section 8: Exemption Outside

### the United States BatchMaps GISConsulting, LLC has no intention 

### to operate a sUAS outside of

### the United States atthis 

### time.

Page 7Brock Boven, Founder & CEO

BatchMaps GISConsulting, LLC To 

### the Director andAdministration of

### the FederalAviation Administration, Iherebysubmit this Petition 

### for Exemption, dated December 

### 4,20t5.
Regards,

Page 8