SURVEYING • ENGINEERING • CONSTRUCTION SERVICES

August 7, 2015

U.S. Department ofTransportation Docket Operations West Building Ground Floor 1200 NewJersey Ave, SE., Washington, D.C. 20590-0001 Geospatial Services • LiDAR Services• GIS

RE: Exemption Request Section 333 ofthe FAAReform Act of2012 and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam; In accordance with the Public Guidance for Petitions for Exemptionfiled under Section 333, Surveying Solutions, Inc. (SSI) requests exemption from the Federal Aviation Regulations to allow for commercial small Unmanned Aircraft Systems (sUAS) operations inperforming aerial data acquisition withinthe National Airspace System (NAS) for various industries and for compensation orhire. 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 orequal to 50 knots, and at orbelow 200 feet AGL. The sUAS's are constructed out oflightweight materials such as carbon fiber, foam and/orplastic, do not carry flammable materials, and will be operatedby a highly qualified Pilotin Command (PIC). Given these operating limitations, SSI is confidentthat operations will not create a hazard to users ofthe (NAS) norto the public and thatthe operation guidelines herein meetthe safety thatthe Congress envisionedthatthe FAA must, by exemption, allow commercial operation ofsUAS's. The specific sUAS's SSI is requesting an exemption for are: 1.) Riegl RICOPTER (previous exception granted under ExemptionNo. 11581) 2.) DJI Phantom 3 Advanced and Professional (Multiple exemptionspreviously granted) 3.) Sensefly eBee (Multiple exemptionspreviously granted) All these aircraft are (UnmannedAircraft) UA, electrically poweredpropeller systems, and controlled with transportable Ground Control stations. All weigh less than 55 lbs. withtheir maximumpayload. Since there have been several exemptions granted for these models ofaircraft, theManuals and drawings for these sUAS' have not beenprovided, but canbe provided uponrequest. 

# SUrveyingFOR 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\ Page2 of9

Introduction: SSI has been in business for 15 years. Since ourfirm'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 ofclientele in both the public andprivate sectors. We continue to evolve inorderto meetthe needs ofthose clients and to stay competitive in our sector. The addition ofsUAS's to SSI'sportfolio ofofferings helps ensurethatwe remain competitive inthe future. SSI offers its services nationwide and to date we have a portfolio ofwork encompassing most ofthe U.S. mainland including the State ofHawaii. Formore 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 whichthe 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 SubpartE (91-401-91.417) 14 CFR21, SubpartH: Airworthiness Certificates 14 CFR91.203(a)(1)- Part 21 Subpart H establishes the requirements for the issuance ofan airworthiness certificate (FAR §91.203 (a) (1)). SSI requests relief from 14 CFRpart 21, SubpartH, pursuant to Section 333 given the size, operational capability, proximity to airports, VLOS operations with which SSI will operate the sUAS's. Operation ofthe sUAS's will be achieved withthe operational limitations established inthis document (see Appendix B) for all flights conducted by SSI. All SSI flights will be conducted in the VLOS ofthe 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.Page 3 of9 The UAS will not carrypilots, passengers, explosive materials or flammable liquids. 14 CFR45.23 (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, cockpitorpilot station on whichthe word "Experimental" can be placed. Given the size ofthe sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed onthe fuselage in compliance with §45.29 (f). The equivalent level ofsafety will beprovided by having the sUAS marked on its fuselage as requiredby §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification ofthe sUAS as "Experimental." 14 CFR 61.113 (a) & (b) & 14 CFR61.133 (a)- Since the sUAS will not carry a pilot or passengers, SSI requests a relieffrom 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 requiredto communicate verbally at all times. The sUAS will be limitedto operations within visual distance ofboth the PIC and VO. All sUAS operations will take place in a controlled area. The risks associated with the use ofa sUAS are far less than similar commercial aircraft operations. 14 CFR 91.7 (a)- Since the UAS will not carry a pilot orpassengers there will be no airworthiness certificate issued for the aircraft. Should this exemption be granted, no FAAregulatory standard exists for determining airworthiness. Giventhe size ofthe aircraft, maintenance, and use ofsafety checklistpriorto eachflight, an equivalent level ofsafety will be provided. All flights will be in accordance with the safety and maintenance recommendations by the sUAS manufacturers. 14 CFR91.9 (b) (2)- Giventhe size and configuration, the sUAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, orpilot onboard to adequately carry a flight manual. An equivalent level ofsafety 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 butnot limited to reviewing weather conditions, checking flight battery requirements, checking takeoffand landing distances along with those found in the attached Appendix "A" will be implemented. These actions will provide an equivalent or higher level ofsafety. 14 CFR 91.109- sUAS's and remotelypiloted aircrafts do nothave fully functional dual controls. Flight control is achievedthrough the use ofa control box that communicates with the aircraft viaradio communications. An equivalent level ofsafety will be achieved using the real time ground station data and given the sUAS's will carry neither a pilotnorpassengers. 14 CFR 91.119 

### (c)- The sUAS's will never be operated at an altitude higherthan 200 feet AGL. The UAS will operate in safe areas away from public and traffic and only withpermission ofthe 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 ofthe UAS, an equivalent orhigher level ofsafety 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 ofsafety will be achieved using a ground station which links to a telemetry datalink. This will provide the pilot with live flight data monitoring, confirming the altitude ofthe launch site shown onthe GPS altitude indicatorpriorto flight. 14 CFR 91.151 (a)- The sUAS's have a limited range. Thebattery power the UAS provides approximately 30 minutes offlight time. The sUAS's is unable to meetthe 30-minute reserve requirement and therefore' Page4 of9 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 onthe GPS altitude indicatorpriorto flight. 14 CFR91.151 (a)- The sUAS's have a limited range. The battery power the UAS provides approximately 30 minutes offlight time. The sUAS's is unable to meetthe 30-minute reserve requirement and therefore requires an exemption. An Equivalent level ofsafety will be achievedbymonitoring the battery throughthe ground station and landing with a minimum of20percent battery powerremaining (as determined by the onboard monitoring system and the PIC). Such an operation guideline will ensure thatthe sUASs will have plenty ofbatteryto returnto the launch site safely; however, one major advantage ofa 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)- Giventhe size and configuration, the sUAS'shave no ability to carry a flight manual onthe aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level ofsafety will be maintained by keeping the flight manual at the ground station where the sUAS pilotwill 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 performpreflight inspections and ensure UAS is in working conditionbefore 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 performmaintenance, preventive maintenance, and alterations on an aircraft otherthan as prescribed in this subpart and other applicable regulations, including part43 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. Priorto any flight, the PIC will be responsible for conducting pre-flight inspections and will following all inspection requirements specified bythe manufacturer ofthe utilized sUAS. Further details can be found in Appendix A. Preventative maintenance and corrective maintenance will be conducted by the manufacture ifso stated by the manufactures' guidelines. However, in instances thatthe manufacture does not require maintenance to be performed bythe manufacturer, thenthe PIC will be responsible for conducting maintenance in accordance withthe manufactures procedures and all maintenance performedbythe PIC and/or manufacturer will be documented in accordance with 91.407 (a) (1). Specifically, records will include "adescription ofthe work performed; and the date ofcompletion ofthe work performed; and the signature ofthe person approving the aircraft for return to service." Further, SSI will ensure thatno modifications or alterations are made to the airframe that affects the flight operating characteristics ofthe sUAS. These proposals are considered to be an equivalent level ofsafety since these sUAS's are very limited in size and will carry a small payload and operate only inrestricted areas for limited periods oftime. In the eventthatmechanical issues arise, the sUAS can land immediately and will be operating from no higher than 200 feet AGL.
Equivalent Level ofSafety In addition to the safety standards mentioned above the sUAS's will adhere to the following additional guidelines: 1. The sUAS's will notbe operated within 5 miles ofan airportunless prior contactto Air Traffic Control has been established. 2. Flights will not exceedthe an airspeed of 50 Knots

# . Page 5 of9 3. Flights will be operated at orbelow an altitude never exceeding 200 feet AGL. 4. The PIC and VO will communicate verbally at all times. 5. UAS operations will notbe conducted during night. 6. All operations will be conducted under visual meteorological conditions. 7. The UAS will landwith a minimum 20 percent battery reserve remaining. 8. The UAS will only be piloted within visual line ofsight. 9. The UAS will utilize an internal flight safety feature that will return to apreprograrnrned position and land ifcommunication with the remote control is lost. 10. Preflight inspections and protocol will be followed priorto all operations. 11. The UAS will abort flight inthe event ofunpredictable obstacles or emergencies. Benefits to the Public Approval ofthe above exemptions and commercial operation ofsUAS'sby SSI will benefitthe public in the following four ways. 1) The commercial use ofsUAS'sto acquire aerial data will reduce the need for manned aircraft operating inthe NAS. Withthe skies ofAmericabecoming busier and Air Traffic Control (ATC) workloads overburdened, the use ofsUAS's will offer some reliefto ATC since coordination during ground, takeoff, departure, transit, arrival, and landing phases offlights is notnecessary. 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 notburn fossil fuels. Typically, aerial photography is capturedbytwin engine fixed wing aircrafts thatburn between 20 to 30 gallons offuel perhour and canrequire significanttravel time before reaching the intended area ofinterest. However, acquiring aerial data with sUAS's can take offand land on site and would greatly reduce both air pollution and noise pollutionwhich is of greatbenefitto the public. 3) Operating sUAS's for the purpose ofaerial data collection also reduces the risk to life and property on the ground. When comparedto a twin engine airplanes, sUAS's size, weight, slow speed, and lack of flammable liquids are considerably less dangerous to people and/or structures onthe ground. 4) Operations ofsUAS's offer an effective, affordable, and safe method to acquire aerial datato 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 bothtwo-dimensional maps andthreedimensional terrain models. Further, farmers and scientists can use this aerial datato estimate biomass, yield monitoring, leafarea indexing, and overall crop health. In all, this data will provide the informationnecessary for businesses oftoday to thrive inthe future and thus inthe publics' interest. Respectfully,

Surveying Solution nc. Andrew W. Semenchu PresidentPage 6of9

APPENDIX A: Pre-flight protocol This section is divided into two areas: 1.) 24 hours priorto flight 2.) Pre-flight inspection checklist. 24 hours prior to flight: • Prior to a sUAS flight, an area ofoperation will be established. This area ofoperation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property, and applicable airspace withinthe area ofoperation. • Flights will be operated within line ofsight ofthe PIC. • The sUAS will weigh less than 55 lbs. total. • Flights will be operated in Class G airspace wheneverpossible. Ifoperation in other airspace is required, the relevant controlling agency will be notified at least 24 hours priorto the operation and, ifrequired, any necessary permission obtained. • Flightplanning will include flight completion with at least 20% batterypowerremaining as measured by the sUAS or appropriate timing. • Ifequipped 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 beperforming duties withinthe boundaries ofthe area of operation will be present for this briefing. Therefore, images taken will be ofindividuals who have also consentedto being photographed or otherwise have agreed to be inthe area where aerial photography will take place. • All requiredpermissions andpermits will be obtained from appropriate state, county or city jurisdictions, including local lawenforcement, fire, or others appropriate governmental agencies. • Writtento include electronic and/or oral permission from the relevantproperty owners will be obtainedpriorto an operation. • All employees working onsite will bethoroughly briefed on sUAS operations priorto 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 nearthe area ofPIC b) Visually scanthe area ofoperation for any unforeseen hazards, persons, or infrastructure c) Checkthat all relevant documents are on site and within easy access. These include: i) PIC'spilot license ii) Proofofcompany's FAA exemptions iii) sUAS manufacturer's flight manual iv) All maintenance records 2) Pre-start sUAS inspection checklist a) Checkto ensure the sUAS poweris "OFF" b) Battery i) Check sUAS batter is fully charged ii) Checkthe hand-held controller'sbattery is fully charged' Page 7of9 c) Visually inspectthe following i) All propellerblades are free ofdamages ii) All propellerblades are securely attached to the sUAS iii) All surfaces are free from damages iv) Antennais undamaged 3) Pre-flight inspection checklist a) Tum onthe controller and sUAS battery i) Ensure that all available systemread-outs are clearly displayed onthe controller and within normal range ii) Testthe functionality and free movement of: (1) Propulsionblade(s) (2) Ailerons (ifapplicable) (3) Checkthe GPS altitude reading ofthe sUAS is withinrange ofa separate hand held barometer. b) Test flight i) Prior to flying the sUAS for commercial purposes, the aircraft must successfully demonstrate a successful flight ofapproximately one minute in duration, in a small area free from any hazards, persons, and property and at an elevation at orbelow 10 feet AGL. APPENDIX B: Flight protocol Safety is paramount for SSI. Therefore, the following outlines the limitations and conditions whichwill govern all commercial operations conducted by the SSI PIC in lieu ofthe approved FAA exemptions and all aircraft will be limited to the specifications ofAppendix D.

• The sUAS will be less than 55 pounds (including payload) • All sUAS flights will be piloted by an FAA licensed airman with atleast a Private Pilot certificate and who will have completedthe training outlined in Appendix C. • The sUAS FAA licensed airman will be considered Pilotin Command (PIC), whether flying or supervising, and will be responsible for safe operation ofthe 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 1NM and within visual line ofsight (VLOS) ofthe PIC • The duration ofeach flight shall not exceed 20% ofthe sUAS battery's power or a maximum total flight time of30 minutes, whichever occurs first. • All takeoffand landings will occur onsite in accordance with the specifications ofthe sUAS manufacture's UserManual • Flights will avoid direct overflight ofany office ormaintenance buildings located onsite • Flights will be cancelled in the eventthat any aircraft or ground control station equipmentis 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 • Ifthe 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 onlyresume after the hazard is clear ofthe area • Only one sUAS will be airborne at any giventime over a specific site, and at least 2NM away from any other sUAS operation. • Minimum crewfor each operationwill consist ofthe sUAS PIC. An observer is not specified since all operations will be limitedto visual line ofsight (VLOS) operations and that the recentproposals of the 'Operation and Certification ofSmall unmanned Aircraft Systems' (RIN: 2120-AJ60, Federal

# . Page8of9 RegisterNumber: 2015-03544) does not require such an observer. However, iftheFAA 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 safetyprocedures 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 withjobsite clearance. This will ensure that all persons nearthe sUAS operations will be given an operations and safety briefing ofthe planned sUAS operations and/or SSI can effectivelyprohibit persons from entering the flight perimeter boundaries during the flight operations. APPENDIX C: Pilot training protocol With safety the highestpriority, proper sUAS flight training is imperative. While SSI seeks highly qualified pilots who have extensive knowledge within the NAS, operations ofsUAS are unique to manned aircraft as well as to othertypes ofsUAS. Therefore, the following pilottraining is required in addition to atleast a SportPilots Certificate. • The PIC must possess a SportPilot's Certificate • The PIC must have accumulated and logged a minimum offive hours as UAS pilot withthe 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 ofthe sUAS to be operated. This will include operation ofthe sUAS both in normal and emergency modes ofoperation, and will include familiarization with the operationmanual (or similar) ifpublishedbythe sUAS manufacturer. Training will also include types ofmaneuvers to be performed and the safe operation inrelationto persons, property and applicable airspace. • Further, the PIC musthave also satisfied any additional qualifications/training/experience that are requiredby the sUAS's manufacturer (i.e. flight operations and procedures manual).

APPENDIX D: Utilized aircraft Atthis 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 bothrotorcraft and fixed wing UAS systems will be within our fleet ofoperating aircraft. Withthe emerging technologies ofUAS growing rapidly andbecoming more affordable, it would benefit SSI to havethe liberty to utilize various aircraft and to have the ability to upgrade withoutregard to the particular exemption status. In orderto provide as much aircraft detail as possible, SSI will belimited to the aircraft thatmeetthe following specifications: All aircraft (rotor and fixed wing) will have the following traits: • Have a weight less than 55 lbs. • Operate at speeds slowerthan 50 knots • All equipmentmounted to the aircraft(s) will be performed bythe manufacturer • All aircraft will be: o Riegl RiCOPTER o DJI Phantom 3 o Sensefly eBEE • All aircraft will useradio frequency that comply withthe Federal • Communications Commissionrequirements. 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' Page 9of9 

### 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.