### Petition for Exemption to Section 333 Welch Comer Engineers January 25, 2016

Introduction The purpose of this document is to provide the FAA information and justification as to why an exemption to Section 333 for use of an UAS by Welch Comer Engineers is appropriate. Below is specific information requested in the document “Public Guidance for Petitions for Exemptions Filed under Section 333”. Type of UAS

 DJI Phantom 2 Vision+ (Model No. PV331) with F2.8 140 Degree on-board camera with gimbal system.

 Radio frequency is 5.728 Ghz-5.85 GHz.

 FCC ID: SS3-201309581 – Complies with Part 15 of FCC rules. Uses of UAS Over 95% of Welch Comer’s work is for public agencies including cities, counties, State DOT’s, water/sewer districts, and road departments. We provide a wide range of general civil engineering services in which aerial imagery is very useful. When the UAS was purchased in the Fall of 2014 we intended to use it for the following:

 Reconnaissance photos to supplement our GPS surveys of large construction sites.

 Acquire photographs during construction project to document concerns and progress and provide very clear and easy-to-understand project updates to policy makers (Mayors, City Councils, board members, etc.).

 Use photographs for artistic renderings that help non-technical decision-makers understand how a project will look when complete.

 Provide free demonstrations at a university and GIS professionals who are curious about the technology.

 We do not sell our aerial photographs. Area of Intended Operations Because we work for several small cities and town, our intended area of operations varies, but is generally limited to Northern Idaho and Northeast Washington, aka the “Inland Northwest”. We do not operate within a 5 mile radius of any airport. The primary airport in our area is the Coeur d’Alene Airport in Hayden, Idaho. More specifically, our area of operation will be limited to small project sites we need pictures for. Project sites vary in area, but could range between 1 acre and 20 acres. That said, we only fly within the boundaries of the project, which we typically understand clearly because of our previous survey efforts.

UAS Pre-Flight Drone Protocol Welch Comer’s UAS is inspected for defects and damage prior to each use. Additional parts are repaired or replaced as-needed. Care is taken when transporting the UAS to protect from damage.Prior to any flight, Welch Comer’s protocol involves understanding the parcel(s) of property including boundaries, terrain, and neighbors. An open, flat, and solid area is selected for take-off and landing. This area will be far from any obstructions, including communications equipment that might cause interference. UAS In-Flight Protocol Welch Comer will only use the UAS at very slow speed and low altitude picture taking, which typically takes only a few minutes to capture. More specifically, the UAS will travel at a maximum of 15 mph and 200 feet in altitude. Although the maximum range claimed by the Phantom 2 Vision+ of 1000 meters, Welch Comer only allows about 350 meters. The primary reason is that beyond 350 meters (in clear weather), the UAS is difficult to see. It’s our internal policy to never the let the UAS out of sight. To maintain safety to the public and property, the UAS is only flown in open areas, away from trees, buildings, power lines, etc. The UAS is also flown in areas and at times, when no people are below it. In case of a mechanical failure, or a pilot error, the UAS can land/crash away from populated areas. Also, prior to any flight, Welch Comer policy is to get permission from the property owner (typically a local government), ask they be present for the flight, and notify local law enforcement. Notification to local law enforcement is done to understand if there may be any restrictions, and give a heads-up in case there are calls from the public. Pilot in Command (PIC) We understand that current rules require the PIC to be a permitted pilot. Since no one is a permitted pilot at Welch Comer, the UAS is not currently being used on our projects. That said, two of Welch Comers employees have flown the drone and understand its capabilities. More specifically, Matt Gillis and Adam Dorsey have an estimated 20 and 15 hours of flight experience, respectively. We also understand the current requirement to be a licensed pilot may be changing in the summer of 2016. The FAA may allow drone owners to take a “ground test” and secure an Airman Certificate. If that is the case, Matt and Adam will become certified. In the meantime, Welch Comer desires their UAS to be permitted.