Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

October 15, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

SE Washington, DC 20590

Dear Sir or Madam 

Attached please find Pacific Geomatic Services, Inc’s (PGS) request for an exemption from the 

listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned 

Aircraft Systems (“sUASs”) for aerial imaging, for safe and efficient surveying, and mapping of 

secured and controlled vacant and under-development sites. The exemption request is 

exclusively for the use of the sUASs and technology manufactured by DJI, and includes the 

Inspire 1 and the Matrice 100. 

Also attached to this letter is the DJI Inspire Flight Manual (“Manual”), which outlines the 

operating requirements, limitations, and technical specifications for the DJI system as well as its 

accessories. The flight characteristics and operation of the Matrice 100 are so similar to the 

Inspire 1 such that we feel it not necessary to include both manuals. PGS has reviewed the DJI 

Manual and its online resources and has found it to be acceptable for sUAS operations on secure 

project sites. Applicant submits this Manual as proprietary information pursuant to 14 CFR 

11.35(b). 

Thank you for your time and consideration, and please let me know if you have any questions. 

Sincerely, 

Ron Hilliard, PLS Principal

Pacific Geomatic Services, Inc

6608 216th St. SW, Suite 304

Mountlake Terrace, WA 98043

Ph: 425-778-5620 Fax: 425-775-2849

Cell: 206-255-7810

Email: ronh@pacgeoinc.com
Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

Exemptions/ Rule Making

Regulations from which the exemption is requested: 

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 45.29

14 CFR 61.23

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

14 CFR Subpart E (91.401-91.417)

AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including UASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections §44702-44716 of this title if the

Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR 91.203(a) (1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UASs may 

operate in the national airspace system without creating a hazard to the user, the public, or a 

threat to national security. In making this determination, the Secretary must consider: 

 The UAS' size, weight, speed and operational capability;

 Whether the UAS operates within the visual line of sight of the operator;

 Whether the UAS operates outside of highly populated areas and away from close 

proximity to airports. 
Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

Reform Act 333(a). If the Secretary determines that a UAS "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system." Id. 333(c).

The DJI Inspire 1 is a multi-rotor aircraft weighing 6.5 pounds, including payload. It has the 

ability to operate under normal conditions at a speed of no more than 42 knots and has the 

capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will 

operate only in the pilot's or visual observer's visual line of sight at all times. Such operations 

will insure that the UAS will "not create a hazard to users of the national airspace system or the 

public." Reform Act Section 333(b).

The DJI Matrice 100 is a multi-rotor aircraft weighing 7.5 pounds, including payload. It has the 

ability to operate under normal conditions at a speed of no more than 42 knots and has the 

capability to hover and move in the vertical and horizontal plane simultaneously. The UAS will 

operate only in the pilot's or visual observer's visual line of sight at all times. Such operations 

will insure that the UAS will "not create a hazard to users of the national airspace system or the 

public." Reform Act Section 333(b).

Given the small size of the UAS involved and the restricted environment within which they will 

operate, our application falls squarely within the zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the small size of the UAS and the low altitudes in 

which our UAS will operate, approval of the application presents no national security issue. 

VEHICLE DESCRIPTION 

The UAS’s that PGS proposes to use are both constructed by DJI and referred to as the Inspire 1

and Matrice 100. The Inspire 1 and Matrice 100 are commonly referred to as a quad copter (4 

rotors and 4 motors) which weigh a maximum of 7.5 pounds (lbs.) with payload and are powered 

by lithium polymer batteries, resulting in a total weight of no more than 7.5 lbs. and have an 

operational range of up to 1.2 nautical miles. The DJI UAS’s can be operated with a maximum 

wind threshold of 22 miles per hours (MPH) for sustained winds and wind gusts up to 30 MPH. 

The Inspire 1 and Matrice 100 can be operated entirely by a touch-screen, map-based interface. 

This means the operator only needs to command the system where to go, and the system does all 

the flying for the operator. The Inspire 1 and Matrice 100 both can be operated in semi and fully 

autonomous flight modes, with the operator simply clicking on a map to create a preplanned 

flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges 

and altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. 

The UAS has built-in intelligent fault handling which allows the Inspire 1 and Matrice 100 to 

detect a system fault while in the air and automatically fly back to its take-off location and land. 
Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

Faults that can be detected include: loss of communication; loss of GPS lock; and low battery 

levels. 

All flight operations are global positioning system (GPS) controlled, making the systems easy to 

navigate. At any point if the operator is not explicitly commanding the system to move, the 

system automatically holds its GPS position. Also a flight termination link - to prevent a "fly 

away" or other potentially dangerous situation - is available to the operator. 

DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203(a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by PGS, an exemption from Part 21 Subpart H meets the requirements of 

an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 USC §44701(f) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed, will be at least as safe, or safer, than a conventional aircraft operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

14 CFR 45.23(b) & 14 CFR 45.29: Marking of the Aircraft; Display of Marks; Size of Marks 

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport 

category aircraft to be marked with letters between 2 inches and 6 inches high "limited,"

"restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit 

or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the UAS, 2 inch lettering will be impossible. 

PGS will mark the UAS with the organization's name and address.

14 CFR 61.23: Medical Certificates; Requirement and Duration 

Regulations provide that a person:

1. Must hold a first-class medical certificate: 

- When exercising the pilot-in-command privileges of an airline transport pilot certificate;

- When exercising the second-in-command privileges of an airline transport pilot 

certificate in a flag or supplemental operation in part 121 of this chapter that requires 

three or more pilots; or
Pacific Geomatic Services, Inc.

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Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

- When serving as a required pilot flight crew member in an operation conducted under 

part 121 of this chapter if the pilot has reached his or her 60th birthday.

2. Must hold at least a second class medical certificate when exercising: 

- Second-in-command privileges of an airline transport pilot certificate in part 121 of this 

chapter (other than operations specified in paragraph (a) (1) (ii) of this section); or 

- Privileges of a commercial pilot certificate.

Given the size of the UAS, their structure, the limited flight area and the safety features 

integrated into the autopilot (among others the flight termination system), PGS believes that an 

Equivalent Level of Safety can be reached if the pilot-in-command has a valid driver's license. 

14 CFR 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the aircraft to have completed UAS 

manufacturer’s flight training before flying a UAS. Unlike a conventional aircraft that carries the 

pilot and passengers, the UAS is remotely controlled with no living thing or cargo on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the User Guide. The risks associated with the operation of the small UAS 

are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present level 

of safety achieved by 14 CFR 61.113 (a) and (b). 

14 CFR 91.7(a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the User Guide for maintenance 

and use of safety checklists prior to each flight an equivalent level of safety will be provided. 

14 CFR 91.9(b) (2): Civil Aircraft Flight Manual, Marking and Placard Requirements 

The UAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or capacity 

to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the User Manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. 

14 CFR 91.103: Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery 
Pacific Geomatic Services, Inc.

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Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

requirements, checking takeoff and landing distances, and all other actions in the User Guide and 

safety checklists. These actions will provide an equivalent level of safety. 

14 CFR 91.109: Flight Instruction 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. By design, UASs and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The equivalent level of safety is provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via 

radio signals from the controller and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This 

exemption is for a multi-rotor craft that flies similarly to a helicopter, with vertical takeoff and 

vertical landing, which will typically operate at altitudes of 150 feet above ground level (AGL), 

so an exemption may be needed to allow such operations. The UAS will never operate at altitude 

higher than 400 feet AGL and all operations will occur during daylight hours under Visual 

Meteorological Conditions (VMC) only. 

The equivalent level of safety will be achieved given the size, weight and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because advance notice to the property owner and any on-site 

personnel, as well as the precautions outlined below, all affected individuals will be aware of the 

planned flight operations. 

Flight operations will be conducted at least 200 feet from all non-participating persons (persons 

other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, 

unless: 

1. Barriers or structures are present that sufficiently protect non-participating persons from 

debris in the event of an accident. The PIC will ensure that non-participating persons 

remain under such protection. If a situation arises where non-participating persons leave 

such protection and are within 200 feet of the UAS, flight operations will cease 

immediately and/or;

2. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety assessment of the 

risk of operating closer to those objects and;

3. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 14 

CFR 91.119(a).

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be 

conducted at least 5 miles from an airport. The PIC or VO will provide notification to the local 

Flight Standards District Office and airport controller of all operations within 5 miles of an 
Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

airport. The FAA will have advance notice of all operations through the filing of notices-toairmen. 

Compared to flight operations with aircraft or rotor craft weighing far more than the UAS 

proposed herein and carrying flammable fuel, any risk associated with our operations is far less 

than those presently presented with helicopters and other conventional aircraft operating at or 

below 500 feet AGL. In addition, the low-altitude operations of the UAS will ensure separation 

between these UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the UAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the PIC confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS 

is limited to operations in controlled environments and has a limited flight time which require an 

exemption from 14 CFR 91.151(a). 

The battery powering the UAS provides approximately 20 minutes of powered flight. This would 

render the UAS unable to meet the 30 minute reserve requirement in 14 CFR 91.151(a). Given 

the limitations on the UAS's proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight VFR conditions is 

reasonable. 

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery 

reserve to ensure that the UAS lands at the ground station with at least 20% of battery power (as 

determined by the on-board monitoring system and the PIC), whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its limited operating area. 

14 CFR 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration 

The UAS has no cabin, cockpit or pilot station and is operated without an on-board pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. 
Pacific Geomatic Services, Inc.

 PGS, Inc. Quality Service ✷ Creative Solutions

Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

14 CFR 91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to PGS. Maintenance will be accomplished by the operator pursuant 

to the User Guide. An equivalent level of safety will be achieved because these UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise, the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the User Guide, the operator will ensure that 

the UAS is in working order prior to initiating flight, perform required maintenance and keep a 

log of any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

PUBLIC INTEREST 

Approval of exemptions allowing commercial operations of UASs for precision aerial surveys 

enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater 

risk because the craft are much larger, have combustible fuel, and carry an on-board human pilot. 

In contrast, a UAS weighing under 8 pounds and powered by batteries eliminates virtually all of 

that risk given the reduced mass and lack of combustible fuel carried on board. The UAS will 

carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. 

Conducting aerial surveys with the DJI Inspire 1 and Matrice 100, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial survey flight operations. By using battery power and electric 

motors, the DJI Inspire 1 and Matrice 100 produces no air pollution and is a viable, 

environmentally conscious alternative to the cabin class, six cylinder internal combustion twin 

engine aircraft that are typically utilized for aerial surveys, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The Inspire 1 and Matrice 100, while reducing the 

carbon footprint of aerial surveys, also reduce noise pollution as the UAS is propelled by battery 

powered electric motors rather than an internal combustion engine. 

EQUIVALENT LEVEL OF SAFETY 

PGS proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 
Pacific Geomatic Services, Inc.

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Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

protocols followed by aerial survey operations conducted with helicopters and other 

conventional aircraft. 

PGS will be bound by the following limitations when conducting its UASs operations under an 

FAA issued exemption: 

1. The UAS will weigh less than 10 pounds.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operations flight will be 20 minutes. Flights will be 

terminated at 20% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flight operations will be conducted no less than 5 miles from an airport, which are 

depicted on VFR sectional charts. 

6. Flight operations within 5 miles of an airport require notification and approval from the 

local Flight Standards District Office and airport controller.

7. Flight operations will occur during daylight hours and under visual meteorological 

conditions only.

8. The FAA will have advance notice of all operations through the filing of notices-toairmen.

9. Minimum crew for each operation will consist of the UAS pilot and visual 

observer/camera operator.

10. The pilot and visual observer will have been trained in the operation of the UAS.

11. The pilot and visual observer will at all times be able to communicate by voice and/or 

text.

12. Written and/or oral permission from the relevant property holders will be obtained.

13. Flight operations will be conducted at least 200 feet from all non-participating persons, 

vessels, vehicles and structures unless: 

a) Barriers or structures are present that sufficiently protect non-participating persons 

from debris in the event of an accident. The pilot will ensure that non-participating 

persons remain under such protection. If a situation arises where non-participating 

persons leave such protection and are within 200 feet of the UAS, flight operations 

will cease immediately and/or;

b) The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and;

c) Operations near the pilot or visual observer do not present an undue hazard to the 

pilot or visual observer.
Pacific Geomatic Services, Inc.

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Pacific Geomatic Services, Inc. 6608 216th St. SW, Suite 304, Mountlake Terrace, WA 98043 (425) 778-5620

14. If the UAS loses communication or loses its GPS signal, the UAS will have the capability 

to return to a safe, pre-determined location and land. 

15. The UAS will have the capability to abort flight in case of unpredicted obstacles or 

emergencies.

PRIVACY 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place. 

FEDERAL REGISTER SUMMARY 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security - provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of Pacific Geomatic Services, Inc. 

(PGS) UAS for precision aerial surveys and aerial imagery capture. 

Sincerely, 

Ron Hilliard, PLS Principal – Pacific Geomatic Services, Inc.