Original 08 / 1 4 /2015 Page 1

August 14 , 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113,

14 CFR 91. 7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E ( 91.40 5, 91.407, 91.409, 91.417)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

, and

14 C.F.R. Part 11, Galaxy Aviation Inc. files this petition on behalf of its client,

Lake Survey LLC/ DBA The Mapping Network ( The Mapping Network ) to operate

Unmanned Aircraft System s (UAS) for commercial purposes.

The Mapping Network is a company based in the state of Missouri, which provides

Geographic Information Systems consulting, data conversion, and GPS data collection

specializing in bathymetry studies for land

, water , sediment and vegetation since 1995

.

By appro ving the exemption request, The Mapping Network’s proposed UAS

operations will create benefits to both the economy and the environment which are

ultimately in the public interest.

The requested exemption wo uld support an application for a commercial Certifica te of

Authorization (COA) to u tilize the Unmanned Aircrafts ( UA ) to offer Aerial Data

Collection and Surveying services for app licable commercial industries

. A few examples of such industr ies include, but not limited to are la nd, water, sediment,

and vegetation aerial imaging, mapping, 3D modeling, Oil & Gas industry, str ucture

inspections, agriculture, real estate properties, construction site surveys, and other

potential industries that ne ed aerial data collection.

The Unmanned Aircraft consist s lightweight

, battery operated 3D Robotics

Solo q uadcopter ( Solo )

, onboard sensors

, and assoc iated communications

equipment.

The Solo unmanned aircraft s carry onboard camera systems that allow them to

perform aerial data collection, and surveying.

The afore mentioned U A have previously demonstrated to me e t the safety standards

and operational requirements resulting in recent grants of s ection 333 exemption

requests by other commercial UAS operators.Original 08 / 1 4 /2015 Page 2

If required, t he UA will be operated by an FAA licensed Pilot in Command

, and a

Visual Observer in accordance with the limitations set forth in the grant and the

following conditions :

- All operations will occur a t no more than 400' above ground level ( AGL )

- When necessary, permits will be acquired from land owners and local authorities

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC a t all time

- While the aircraft is airborne, the VO will be able to communicate verbally with the PIC

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time

- F or certain complex operations, The Mapping Network may assign sensor or

software operators to assist the operations

We submit that the combination of ;

- The Solo’s size, lig ht weight and historically demonstrated safe operation s and

receiving recent approval s of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operation s under the guidelines established within the grant

, The FAA can have confidence that The Mapping Network’s UAS operation s will

have an equivalent or greater level of safe ty as manned aircraft performing the same

mission.

We are prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. If necessary, a dditional documents supporting this petition will

be submitted following this request.

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Bryan Archer

Agen t for Lake Survey LLC/ DBA The Mapping Network

Galaxy Aviation Inc. ( Part 145 Repair Station # 5GXR127C )

6215 Kirby Lane

Frisco, TX 75035

Tel : (469) 766

- 0420

Fax : (866) 694

- 1989

Email: bryan.a rcher@g alaxy mro .com

c c: Steve Bartosh

Lake Survey LLC/ DBA The Mapping Network

steve @ them apping n etwork .comOriginal 08 / 1 4 /2015 Page 3 

## TABLE OF CONTENTS

NAME, ADDRESS , AND CONTACT INFORMATION OF PETITIONER .

........... ..............Page 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE MAPPING NETWORK

SEEKS EXEMPTION.

.............................................................................. ........ .............. ............Page 4

THE EXTENT OF RELIEF THE MAPPING NETWORK SEEKS AND THE REASON S

THE MAPPING NETWORK SEEKS THE RELIEF

............ ................ ........... ...... ....... Pages 4 to 6

THE REASONS WHY GRANTING THE MAPPING NETWORK’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ..................................................

............. ............ .............. . Page 7

THE REASONS WHY GRANTING THE MAPPING NETWORK THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY .......................................

........... .......... ................... ... Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...

......... .... ... . .... Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT THE MAPPING NETWORK’S R EQUEST...

.... ........ ...... Page 10

ACR ONYMS...............................................................

......... ....... Page s 11 & 12Original 08 / 1 4 /2015 Page 4

NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

Steve Bartosh

President

Lake Survey LLC/ DBA The Mapping Network

15072 NW 66th street,

Kansas City, Missouri 64152

Tel: (402)616

- 4919

Email: steve@TheMappingNetwork.com

cc: bryan.archer@g alaxy mro .com

THE SPECIFIC SECTIONS OF 1 4 CFR TO BE RELIEVED FROM

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF THE MAPPING NETWORK SEEKS AND THE REASONS

THE MAPPING NETWORK SEEKS THE RELIEF

14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act

as pilot in command of an aircraft in connection with any business or employment if;

(1) flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire

.

Since the UA cannot carry passengers or property, we request to be relieved from this

regulation if our pilots at minimum,

(1) hold at least a pilot qualification or certificate imposed within the grant

(2) hold a driver license or a third class medical certificate.

By meeting conditions (1) and (2), we believe that equivalent level of safety can be

achieved by complying with 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airwor thiness.

14CFR 9 1.7 (a) provide s

,

“ No person may operate a civil aircraft unless it is in an airworthy condition

. ”

T his rule prohibits the operation of an aircraft without an airworthiness certificate.

Since there is no such existing certificate that is applicable for the Unmanned Aircrafts

to properly comply with the FARs, we request that The Mapping Network to be

relieved from this regulation.

To provide equivalent level of safety, we will ensure that the Unmanned Aircraft

is in airworthy condition prior to every flight by following necessary safety

procedures.Original 08 / 1 4 /2015 Page 5

14 CFR 91.119 Minimum safe altitudes: Genera l

This regulation provides that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

To provide an equivalent level of safety we will only fly over propert ies with the

permission of the land owner. The land owner will be briefed of the expected route of

flight and the associated risks to persons and property on the ground. We maintain that

due to the small size of the Unmanned Aircrafts , the hazard to persons, vessels,

vehicles, and structures is not comparable to manned aircraft and should be

considered in granting the exemption.

14 CFR 9 1. 121 Altimeter Settings

Th is regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft.

The Unmanned Aircrafts will fly below 400 feet AGL and will not need to maintain

hemispherical c ruising altitudes in order to de

- conflict with other aircraft.

To provide an equivalent level of safety, the PIC will check and confirm the Unmanned

Aircrafts’ GPS altitude read out before each flight.

14 CFR 91.1 51 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

VFR conditions unless there is enough fuel to fly to the first point of intended landing

and to fly after that for at least 30 minutes. We believe the intention of this rule is to

provide a reserve of energy as a safety buffer for go

- arounds and other delays to

landing.

The Solo UA is battery operated and the maximum duration of flight with full payload,

from a single battery charge is a pproximatel y 26 minutes

. We believe that equivalent level of safety can be achieved by limiting our flight time to

appropriate percentage of battery charge with 10 % reserve energy on the battery.Original 08 / 1 4 /2015 Page 6

14 CFR 91 Subpart E ( 91. 405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance w ith part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be " approved for return to service by a

person authorized under 43.7 " after maintenance and inspection. It is our intention

that the PIC, VO or authorized personnel to perform maintenance and inspection of the

aircraft and "be authorized to approve the aircraft for return to service."

The Mapping Network requests that exemption to the regulations under conditions

below;

(1) The Mapping Network will follow Solo Unmanned Aircraft ’s manufacturer

maintenance instructions

, techniques and procedures

(2) The Mapping Network will designate, train, and document the personnel who will be

authorized to perform Inspection, Maintenance and Alterations

Such designated personnel may include PIC, VO or other equivalent trained persons

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight

looking for any structural or mechanical malfunctions

Due to the small size, light weight and simplicity of the Solo UAS, we believe that the

equivalent safety will be achieved by permitting any of the PIC , VO or equivalent

trained personnel, to perform maintenance

, inspection and alterations of the aircraft

and " be authorized to ap prove the aircraft for return to service. "Original 08 / 1 4 /2015 Page 7

THE REASONS WHY GRANTING THE MAPPING NETWORK’S REQUEST WOULD

BE IN THE PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR 61.113 , 61.133

14 CFR 91.9, 91.119

, 91.121

, 91.151

14 CFR 91 Subpart E ( 91 .405, 91.407, 91.409, 91.417) , is in the public’s interest and

will benefit the public as a whole for the following reasons.

1

- The S olo UA is battery operated and free from the harmful emissions

associated with the manned aircraft that are currently used for aerial data

collection.

As recently proven by several grants of section 333 petitions, UASs offer

equivalent level of safety while reducing environmental i mpacts, which is in the

public interest.

2

- The Mapping Network’s UAS operation s will contribute to a po sitive aggregate

e conomic i mpact resulting in creation of jobs both direct and indirectly.

Economic Research estimates that the UAS market will grow from $ 6 billion to

$ 94 billion over the next decade resulting in a new workforce development

. Because The Mapping Network’s operations will create new jobs such as p ilots,

flight operation staff, and administrative supporting staff, it will directly cause

positive economic impact , hence granting The Mapping Network ’ s petition will

benefit the public as a whole.

3

- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS (s) into the national airspace system, hence the passing

of the FAA Modernization and Reform Act of 2012.

Granting The Mapping Network’s petition furthers the public ’s interest as a

demonstrated progression of integrating Unmanned Aircraft Systems into

National Air Space , thus it will benefit public as a whole

.Original 08 / 1 4 /2015 Page 8

THE REASONS WHY GRANTING THE MAPPING NETWORK THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY

The Mapping Network believes that the grant of exemption from,

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of the reasons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF THE

MAPPING NETWORK SEEKS AND THE REASONS THE MAPPING

NETWORK SEEKS THE RELIEF ” by describing how we intend to mitigate risk

and accomplish FAA equivalent and acceptable level of safety for each 14 CFR

sub part s

.

(b) As a result of Solo unmanned aircraft s ’ size, weight, speed, operational

capability, proximity to airports and populate d areas, operation within visual line

of sight combined with the implement ing FAA required safety procedures , we

believe that granting The Mapping Network’s exemption request will not

adversely affect safety.

(c) The Mapping Network’s Solo u nmanned a ircrafts has demonstrated to satisfy

necessary safety risk mitigation by FAA thus resulting in multiple grants of

section 333 petitions.

Because of t he combination of Unmanned Aircrafts’ proven success and the

conditions and limitations of our operations, we believe granting The Mapping

Network’s request will not adversely safety.Original 08 / 1 4 /2015 Page 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Lake Survey LLC/ DBA The Mapping Network

Petition of exemption from section s of ;

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief s ought;

The Mapping Network se eks an exemption from parts of 14 CFR, Federal Aviation

Regulations for commercial operati on s of the Unmanned Aircraft described above

. The unmanned aircraft systems have an onboard camera system capable of acquiring

high resolution data.

Proposed operations will offer aerial data collection and surveying services for

appropriate commercial industries.Original 08 / 1 4 /2015 Page 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT THE MAPPING NETWORK ’ REQUEST



### (A) 3D Robotic s Solo UAS a nd Specifications.

3DR SOLO UAS consists;

3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller

Set

– Blac k, 3DR Solo Battery Charger

Specifications :

Up to 26 minutes of flight time

Max Airspeed : 5 0 Knots

Max Altitude : 490 ft.

Weight : 1760 g Max Takeoff Wight

Controller R ange : up to a mile

Flight Controller : 3DR Pixhawk 2

Battery : 14.8 V LiPo 5200mAh

Propulsion : 880 kV motors

Camera System : 3

- axis Solo Gimbal from 3DR and a high resolution camera



### (B) Positive Economic & Environmental Impacts

The Mapping Network’s UAS operation s will contribute to a po sitive aggregate

e conomic i mpact resulting in creation of jobs both direct and indirectly. Economic

Research estimates that the UAS market will grow from $6 billion to $ 94 billion over the

next decade resulting in a new workforce development

. Because The Mapping Network’s UASs utilize electrical propulsion and batteries

, it

has less environmental footprint compared similar tasks done by manned aircrafts.



### (C) N o Privacy Issues

The Mapping Network’s proposed operations will create no privacy issues because the

Unmanned Aircrafts UAS will be operating in the areas within the boundaries of the

propert ies with the land owner’s permission.

When necessary, The Mappi ng Network will also obtain any permits or authorizations

from local author ities.Original 08 / 1 4 /2015 Page 11 A CRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FA Rs F ederal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management

System

FTP Flight Termination Point

FTS Flight Termination System

G Hz Gigahertz

GCS G round Control Station

MHz Megahertz

MTOW M aximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

N O TA M N otice To A irman

OPA Optionally Piloted Aircraft

PIC Pilot in Command

The Mapping Network Lake Survey LLC / DBA The Mapping Network

U AS Unmanned Aircraft System

U A Unmanned Aircraft ( s )

R&D Research and Development

RF Radio Frequency

RM Risk ManagementOriginal 08 / 1 4 /2015 Page 12

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System (s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer