SURVEYING • ENGINEERING • CONSTRUCTION SERVICES 

August 7, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

1200 New Jersey Ave, SE., 

Washington, D.C. 20590-0001 

Geospatial Services • LiDAR Services• GIS 

RE: Exemption Request Section 333 ofthe FAA Reform Act of2012 and Part 11 ofthe Federal 

Aviation Regulations 

Dear Sir or Madam; 

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, Surveying 

Solutions, Inc. (SSI) requests exemption from the Federal Aviation Regulations to allow for commercial 

small Unmanned Aircraft Systems (sUAS) operations in performing aerial data acquisition within the 

National Airspace System (NAS) for various industries and for compensation or hire. This exemption would 

allow SSI to collect data safely and more cost effectively than a traditional manned aircraft. 

SSI plans to operate sUAS's that are rotorcraft and fixed wing aircraft, each weighing less than 55 pounds 

(including payload), at speeds less than or equal to 50 knots, and at or below 200 feet AGL. The sUAS's are 

constructed out of lightweight materials such as carbon fiber, foam and/or plastic, do not carry flammable 

materials, and will be operated by a highly qualified Pilot in Command (PIC). Given these operating 

limitations, SSI is confident that operations will not create a hazard to users of the (NAS) nor to the public 

and that the operation guidelines herein meet the safety that the Congress envisioned that the FAA must, by 

exemption, allow commercial operation of s U AS's. 

The specific sUAS's SSI is requesting an exemption for are: 

1.) Riegl RICOPTER (previous exception granted under Exemption No. 11581) 

2.) DJI Phantom 3 Advanced and Professional (Multiple exemptions previously granted) 

3.) Sensefly eBee (Multiple exemptions previously granted) 

All these aircraft are (Unmanned Aircraft) UA, electrically powered propeller systems, and controlled with 

transportable Ground Control stations. All weigh less than 55 lbs. with their maximum payload. Since there 

have been several exemptions granted for these models of aircraft, the Manuals and drawings for these 

sUAS' have not been provided, but can be provided upon request. 

SUrveying FOR TODAY... SOlutions FOR THE FUTURE ... TM 

4471 M-61, Standish, Michigan 48658 • tel 989-846-6601 • fax 989-846-6607 

1000 S. US-27, St. Johns, Michigan 48879 • tel989-227-9212 • fax 989-224-2729 

3734 Fortune Boulevard, Saginaw, Ml 48603• tel989-798-0527 • fax 877-581-6645 

www.ssi-mi.com 
\ 

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Introduction: 

SSI has been in business for 15 years. Since our firm's inception in 2001 as a 3 person organization, SSI has 

grown to a firm with over 65 employees with four office locations in Michigan. SSI offers surveying, 

mapping, geospatial and engineering services to our clients. SSI services a wide range of clientele in both 

the public and private sectors. We continue to evolve in order to meet the needs of those clients and to stay 

competitive in our sector. The addition of sUAS's to SSI's portfolio of offerings helps ensure that we remain 

competitive in the future. 

SSI offers its services nationwide and to date we have a portfolio of work encompassing most ofthe U.S. 

mainland including the State of Hawaii. For more information on SSI please visit our website www.ssimi.com. 

Petitioner: 

Surveying Solutions Inc. 

4471 M-61 Standish, MI 48658 

Andrew W. Semenchuk, P.S. 

President 

Phone: (989) 846-6601 

Email: semenchuk@ssi-mi.com 

Regulations from which the exemption is requested: 

14 CFR 21, Part 21; 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b)(2) 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

Part 91 Subpart E (91-401-91.417) 

14 CFR 21, Subpart H: Air worthiness Certificates 14 CFR 91.203(a)(1)- Part 21 Subpart H establishes 

the requirements for the issuance of an airworthiness certificate (FAR §91.203 (a) (1 )). SSI requests relief 

from 14 CFR part 21, Subpart H, pursuant to Section 333 given the size, operational capability, proximity to 

airports, VLOS operations with which SSI will operate the sUAS's. Operation of the sUAS's will be 

achieved with the operational limitations established in this document (see Appendix B) for all flights 

conducted by SSI. All SSI flights will be conducted in the VLOS of the PIC at an altitude of200 feet AFL or 

less and only over designated Limited Access Areas (LAA). This will ensure a safe operating environment 

without creating a hazard to other aircraft, people, or structures on the ground. 
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The UAS will not carry pilots, passengers, explosive materials or flammable liquids. 

14 CFR 45.23 (b)- Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with §45 .29 (f). The equivalent level of safety 

will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUAS will see the identification of the sUAS as "Experimental." 

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the sUAS will not carry a pilot or passengers, SSI 

requests a relief from these regulations. Any pilot in command or (PIC) operating the sUAS will hold a Sport 

Pilot (or greater) certificate. A visual observer or (VO) will be utilized and required to communicate verbally 

at all times. The sUAS will be limited to operations within visual distance of both the PIC and VO. All sUAS 

operations will take place in a controlled area. The risks associated with the use of a sUAS are far less than 

similar commercial aircraft operations. 

14 CFR 91.7 (a)- Since the UAS will not carry a pilot or passengers there will be no airworthiness certificate 

issued for the aircraft. Should this exemption be granted, no FAA regulatory standard exists for determining 

airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to each flight, an 

equivalent level of safety will be provided. All flights will be in accordance with the safety and maintenance 

recommendations by the sUAS manufacturers. 

14 CFR 91.9 (b) (2)- Given the size and configuration, the sUAS has no ability to carry a flight manual on 

the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent 

level of safety will be maintained by keeping the flight manual at the ground station where the sUAS's pilot 

will have immediate access to it. 

14 CFR 91.103 (b) (2) -As no FAA approved flight manuals will be provided for the aircraft an exemption is 

needed. Alternate procedures including but not limited to reviewing weather conditions, checking flight 

battery requirements, checking takeoff and landing distances along with those found in the attached 

Appendix "A" will be implemented. These actions will provide an equivalent or higher level of safety. 

14 CFR 91.109- sUAS's and remotely piloted aircrafts do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft via radio 

communications. An equivalent level of safety will be achieved using the real time ground station data and 

given the sUAS's will carry neither a pilot nor passengers. 

14 CFR 91.119 (c)- The sUAS's will never be operated at an altitude higher than 200 feet AGL. The UAS 

will operate in safe areas away from public and traffic and only with permission of the property and structure 

owners. The sUAS's will also be restricted by the flight controller to a maximum vertical height of200 feet 

AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, an equivalent 

or higher level of safety will be achieved. 

14 CFR 91.121- Since sUAS's may not have a barometric altimeter, but instead a GPS barometric sensor for 

altitude information an exemption may be required. An equivalent level of safety will be achieved using a 

ground station which links to a telemetry data link. This will provide the pilot with live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator prior to flight. 

14 CFR 91.151 (a)- The sUAS's have a limited range. The battery power the UAS provides approximately 

30 minutes of flight time. The sUAS's is unable to meet the 30-minute reserve requirement and therefore 
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ground station which links to a telemetry data link. This will provide the pilot with live flight data 

monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator prior to flight. 

14 CFR 91.151 (a)- The sUAS's have a limited range. The battery power the UAS provides approximately 

30 minutes of flight time. The sUAS's is unable to meet the 30-minute reserve requirement and therefore 

requires an exemption. An Equivalent level of safety will be achieved by monitoring the battery through the 

ground station and landing with a minimum of20 percent battery power remaining (as determined by the 

onboard monitoring system and the PIC). Such an operation guideline will ensure that the sUASs will have 

plenty of battery to return to the launch site safely; however, one major advantage of a sUAS is that unlike 

manned aircraft it can easily and safely land anywhere over a Limited Access Areas in which its operations 

are limited to. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

14 CFR 91.203 (a) & (b)- Given the size and configuration, the sUAS's have no ability to carry a flight 

manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An 

equivalent level of safety will be maintained by keeping the flight manual at the ground station where the 

sUAS pilot will have immediate access to it. Given the following sections only apply to aircraft with an 

airworthiness certificate these sections do not apply to this applicant. As a safety precaution, the operator will 

perform preflight inspections and ensure UAS is in working condition before initiating each flight: 

Part 91 Subpart E (91.401-91.417): Maintenance, Preventative Maintenance and Alterations 

These regulations outline the requirements for maintenance and inspections in reference to Part 39 and Part 

43. 91.405 (a), which states that "no person may perform maintenance, preventive maintenance, and 

alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including 

part 43 ofthis chapter." Since these sections apply to only aircraft with an airworthiness certificate, for which 

SSI has applied for exemption, SSI also seeks full exemption from these regulations. Prior to any flight, the 

PIC will be responsible for conducting pre-flight inspections and will following all inspection requirements 

specified by the manufacturer of the utilized sUAS. Further details can be found in Appendix A. 

Preventative maintenance and corrective maintenance will be conducted by the manufacture if so stated by 

the manufactures' guidelines. However, in instances that the manufacture does not require maintenance to be 

performed by the manufacturer, then the PIC will be responsible for conducting maintenance in accordance 

with the manufactures procedures and all maintenance performed by the PIC and/or manufacturer will be 

documented in accordance with 91.407 (a) (1). Specifically, records will include "a description of the work 

performed; and the date of completion of the work performed; and the signature of the person approving the 

aircraft for return to service." Further, SSI will ensure that no modifications or alterations are made to the 

airframe that affects the flight operating characteristics of the sUAS. These proposals are considered to be an 

equivalent level of safety since these sUAS 's are very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods of time. In the event that mechanical issues arise, the 

sUAS can land immediately and will be operating from no higher than 200 feet AGL. 

Equivalent Level of Safety 

In addition to the safety standards mentioned above the sUAS's will adhere to the following additional 

guidelines: 

1. The sUAS' s will not be operated within 5 miles of an airport unless prior contact to Air Traffic 

Control has been established. 

2. Flights will not exceed the an airspeed of 50 Knots 
. 

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3. Flights will be operated at or below an altitude never exceeding 200 feet AGL. 

4. The PIC and VO will communicate verbally at all times. 

5. UAS operations will not be conducted during night. 

6. All operations will be conducted under visual meteorological conditions. 

7. The UAS will land with a minimum 20 percent battery reserve remaining. 

8. The UAS will only be piloted within visual line of sight. 

9. The UAS will utilize an internal flight safety feature that will return to a preprograrnrned position and 

land if communication with the remote control is lost. 

10. Preflight inspections and protocol will be followed prior to all operations. 

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies. 

Benefits to the Public 

Approval ofthe above exemptions and commercial operation ofsUAS's by SSI will benefit the public in the 

following four ways. 

1) The commercial use of s U AS's to acquire aerial data will reduce the need for manned aircraft 

operating in the NAS. With the skies of America becoming busier and Air Traffic Control (ATC) 

workloads overburdened, the use of sUAS's will offer some relief to ATC since coordination during 

ground, takeoff, departure, transit, arrival, and landing phases of flights is not necessary. 

2) Reduced manned aircraft will reduce air and noise pollution. Since all sUAS's operated by SSI will 

be lightweight and battery powered, these sUAS's electric motors operate much quieter than manned 

aircraft and do not burn fossil fuels. Typically, aerial photography is captured by twin engine fixed 

wing aircrafts that burn between 20 to 30 gallons of fuel per hour and can require significant travel 

time before reaching the intended area of interest. However, acquiring aerial data with sUAS's can 

take off and land on site and would greatly reduce both air pollution and noise pollution which is of 

great benefit to the public. 

3) Operating sUAS's for the purpose of aerial data collection also reduces the risk to life and property on 

the ground. When compared to a twin engine airplanes, sUAS's size, weight, slow speed, and lack of 

flammable liquids are considerably less dangerous to people and/or structures on the ground. 

4) Operations ofsUAS's offer an effective, affordable, and safe method to acquire aerial data to many 

businesses. Data generated from sUAS flights can help construction sites monitor progress, plan and 

design future improvements/work, and aid in site surveys in both two-dimensional maps and threedimensional terrain models. Further, farmers and scientists can use this aerial data to estimate 

biomass, yield monitoring, leaf area indexing, and overall crop health. In all, this data will provide the 

information necessary for businesses of today to thrive in the future and thus in the publics' interest. 

Respectfully, 

Surveying Solution nc. 

Andrew W. Semenchu 

President 
Page 6 of9 

APPENDIX A: Pre-flight protocol 

This section is divided into two areas: 

1.) 24 hours prior to flight 

2.) Pre-flight inspection checklist. 

24 hours prior to flight: 

• Prior to a sUAS flight, an area of operation will be established. This area of operation will include 

a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be 

established for persons, property, and applicable airspace within the area of operation. 

• Flights will be operated within line of sight of the PIC. 

• The sUAS will weigh less than 55 lbs. total. 

• Flights will be operated in Class G airspace whenever possible. If operation in other airspace is 

required, the relevant controlling agency will be notified at least 24 hours prior to the operation 

and, if required, any necessary permission obtained. 

• Flight planning will include flight completion with at least 20% battery power remaining as 

measured by the s U AS or appropriate timing. 

• If equipped and appropriate for the operation, sUAS aircraft will utilize GPS navigation, failsafe, 

return-to-home (RTH) and/or flight abort safety features. 

• A briefing will be conducted in regard to the planned sUAS operations prior to operation at each 

new location. All personnel who will be performing duties within the boundaries of the area of 

operation will be present for this briefing. Therefore, images taken will be of individuals who 

have also consented to being photographed or otherwise have agreed to be in the area where aerial 

photography will take place. 

• All required permissions and permits will be obtained from appropriate state, county or city 

jurisdictions, including local law enforcement, fire, or others appropriate governmental agencies. 

• Written to include electronic and/or oral permission from the relevant property owners will be 

obtained prior to an operation. 

• All employees working onsite will be thoroughly briefed on sUAS operations prior to operations 

commencmg 

Pre-flight inspection checklist 

The pre-flight checklist/inspection will follow the specific pattern and sequence before each flight. 

1) Ground station setup: 

a) Place the "EXPERIMENTAL" flag near the area of PIC 

b) Visually scan the area of operation for any unforeseen hazards, persons, or infrastructure 

c) Check that all relevant documents are on site and within easy access. These include: 

i) PIC's pilot license 

ii) Proof of company's FAA exemptions 

iii) sUAS manufacturer's flight manual 

iv) All maintenance records 

2) Pre-start sUAS inspection checklist 

a) Check to ensure the sUAS power is "OFF" 

b) Battery 

i) Check sUAS batter is fully charged 

ii) Check the hand-held controller's battery is fully charged 
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c) Visually inspect the following 

i) All propeller blades are free of damages 

ii) All propeller blades are securely attached to the sUAS 

iii) All surfaces are free from damages 

iv) Antenna is undamaged 

3) Pre-flight inspection checklist 

a) Tum on the controller and sUAS battery 

i) Ensure that all available system read-outs are clearly displayed on the controller and 

within normal range 

ii) Test the functionality and free movement of: 

(1) Propulsion blade(s) 

(2) Ailerons (if applicable) 

(3) Check the GPS altitude reading of the sUAS is within range of a separate hand held 

barometer. 

b) Test flight 

i) Prior to flying the sUAS for commercial purposes, the aircraft must successfully 

demonstrate a successful flight of approximately one minute in duration, in a small area 

free from any hazards, persons, and property and at an elevation at or below 10 feet AGL. 

APPENDIX B: Flight protocol 

Safety is paramount for SSI. Therefore, the following outlines the limitations and conditions which will 

govern all commercial operations conducted by the SSI PIC in lieu ofthe approved FAA exemptions and all 

aircraft will be limited to the specifications of Appendix D. 

• The sUAS will be less than 55 pounds (including payload) 

• All sUAS flights will be piloted by an FAA licensed airman with at least a Private Pilot certificate 

and who will have completed the training outlined in Appendix C. 

• The sUAS FAA licensed airman will be considered Pilot in Command (PIC), whether flying or 

supervising, and will be responsible for safe operation of the flight. 

• The sUAS will operate at or below 200 feet AGL 

• No flight will be conducted ifwind speeds are in excess of20 mph. 

• The sUAS will operate within 1 NM and within visual line of sight (VLOS) of the PIC 

• The duration of each flight shall not exceed 20% of the sUAS battery's power or a maximum total 

flight time of 30 minutes, whichever occurs first. 

• All takeoff and landings will occur onsite in accordance with the specifications of the sUAS 

manufacture's User Manual 

• Flights will avoid direct overflight of any office or maintenance buildings located onsite 

• Flights will be cancelled in the event that any aircraft or ground control station equipment is 

inoperative or not fully functional 

• Flights will be operated under visibility and cloud clearance requirements equivalent to 

• Visual Flight Rules (VFR) and only in Visual Meteorological Conditions during daylight hours 

• If the PIC identify a potential hazard, such as a manned aircraft within close proximity to the 

designated flight area, the PIC will immediately land the sUAS and operations will only resume after 

the hazard is clear ofthe area 

• Only one sUAS will be airborne at any given time over a specific site, and at least 2NM away from 

any other sUAS operation. 

• Minimum crew for each operation will consist of the sUAS PIC. An observer is not specified since all 

operations will be limited to visual line of sight (VLOS) operations and that the recent proposals of 

the 'Operation and Certification of Small unmanned Aircraft Systems' (RIN: 2120-AJ60, Federal 
. 

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Register Number: 2015-03544) does not require such an observer. However, ifthe FAA decides in 

this exemption request, or in future regulations that a flight observer is necessary, than SSI will 

comply. 

• The sUAS PIC will establish a working relationship with a representative at the local FSDO with 

which to annually review safety procedures and other operations to further enhance safety. 

• All operations will be confined to a Limited Access Area (LAA), which are areas that are sparse in 

population and/or where access is limited to personnel with jobsite clearance. This will ensure that all 

persons near the sUAS operations will be given an operations and safety briefing of the planned 

sUAS operations and/or SSI can effectively prohibit persons from entering the flight perimeter 

boundaries during the flight operations. 

APPENDIX C: Pilot training protocol 

With safety the highest priority, proper sUAS flight training is imperative. While SSI seeks highly qualified 

pilots who have extensive knowledge within the NAS, operations of sUAS are unique to manned aircraft as 

well as to other types of sUAS. Therefore, the following pilot training is required in addition to at least a 

Sport Pilots Certificate. 

• The PIC must possess a Sport Pilot's Certificate 

• The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the make and 

model ofUAS to be utilized for operations under the exemption and three takeoffs and landings in the 

preceding 90 days. 

• The PIC will be trained in advance for the safe operation of the sUAS to be operated. This will 

include operation of the sUAS both in normal and emergency modes of operation, and will include 

familiarization with the operation manual (or similar) if published by the sUAS manufacturer. 

Training will also include types of maneuvers to be performed and the safe operation in relation to 

persons, property and applicable airspace. 

• Further, the PIC must have also satisfied any additional qualifications/training/experience that are 

required by the sUAS's manufacturer (i.e. flight operations and procedures manual). 

APPENDIX D: Utilized aircraft 

At this time, SSI does not own any sUAS's for commercial operation and has not specified the particular 

aircrafts in which will be operated. Instead, SSI has specified that both rotorcraft and fixed wing UAS 

systems will be within our fleet of operating aircraft. With the emerging technologies ofUAS growing 

rapidly and becoming more affordable, it would benefit SSI to have the liberty to utilize various aircraft and 

to have the ability to upgrade without regard to the particular exemption status. In order to provide as much 

aircraft detail as possible, SSI will be limited to the aircraft that meet the following specifications: 

All aircraft (rotor and fixed wing) will have the following traits: 

• Have a weight less than 55 lbs. 

• Operate at speeds slower than 50 knots 

• All equipment mounted to the aircraft( s) will be performed by the manufacturer 

• All aircraft will be: 

o Riegl RiCOPTER 

o DJI Phantom 3 

o Sensefly eBEE 

• All aircraft will use radio frequency that comply with the Federal 

• Communications Commission requirements. As a general rule, flight controls and data links will not 

interfere with manned aircraft communication and radio frequencies will range between 900 mhz and 
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5.8 Be able to safely operate in wind conditions greater than 20 mph have proven and built in safety 

features. These can include, but are not limited to: 

o Emergency landing 

o Return to 'Home' 

o Restart propeller 

o Ground proximity detection 

o Self-monitoring capabilities such as battery levels, wind speeds, etc.