Original 08/14/2015 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 (91.405, 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 Systems (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 approving 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 would support an application for a commercial Certificate of 

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

Collection and Surveying services for applicable commercial industries.

A few examples of such industries include, but not limited to are land, water, sediment, 

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

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

potential industries that need aerial data collection.

The Unmanned Aircraft consists lightweight, battery operated 3D Robotics

Solo quadcopter (Solo), onboard sensors, and associated communications

equipment.

The Solo unmanned aircrafts carry onboard camera systems that allow them to 

perform aerial data collection, and surveying. 

The afore mentioned UA have previously demonstrated to meet the safety standards 

and operational requirements resulting in recent grants of section 333 exemption 

requests by other commercial UAS operators.
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If required, the 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 at 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 at 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

- For 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, light weight and historically demonstrated safe operations and

receiving recent approvals of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operations under the guidelines established within the grant,

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

have an equivalent or greater level of safety 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, additional 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

Agent 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.archer@galaxymro.com

cc: Steve Bartosh 

 Lake Survey LLC/ DBA The Mapping Network

 steve@themappingnetwork.com

 
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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 REASONS

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 REQUEST..................... Page 10 

ACRONYMS............................................................................... Pages 11 & 12
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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@galaxymro.com

THE SPECIFIC SECTIONS OF 14 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 Airworthiness.

14CFR 91.7 (a) provides,

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

This 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. 
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14 CFR 91.119 Minimum safe altitudes: General 

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 properties 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 91.121 Altimeter Settings 

This 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 cruising 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 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under dayVFR 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 approximately 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.
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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 with 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 approve the aircraft for return to service. "
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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 Solo 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 impacts, which is in the 

public interest.

2- The Mapping Network’s UAS operations will contribute to a positive aggregate 

economic impact 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 pilots, 

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. 
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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 

subparts.

 

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

capability, proximity to airports and populated areas, operation within visual line 

of sight combined with the implementing 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 unmanned aircrafts has demonstrated to satisfy 

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

section 333 petitions.

Because of the 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 08/14/2015 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 sections 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 sought;

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

Regulations for commercial operations 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.
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ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE MAPPING NETWORK’ REQUEST

(A) 3D Robotics Solo UAS and Specifications.

3DR SOLO UAS consists;

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

Set – Black, 3DR Solo Battery Charger

Specifications:

Up to 26 minutes of flight time 

Max Airspeed : 50 Knots

Max Altitude : 490 ft.

Weight : 1760 g Max Takeoff Wight 

Controller Range : 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 operations will contribute to a positive aggregate 

economic impact 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) No 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

properties with the land owner’s permission. 

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

from local authorities.
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ACRONYMS

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

FARs Federal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management 

System

FTP Flight Termination Point

FTS Flight Termination System

GHz Gigahertz

GCS Ground Control Station

MHz Megahertz

MTOW Maximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

NOTAM Notice To Airman 

OPA Optionally Piloted Aircraft

PIC Pilot in Command

The Mapping Network Lake Survey LLC / DBA The Mapping Network 

UAS Unmanned Aircraft System

UA Unmanned Aircraft(s)

R&D Research and Development

RF Radio Frequency

RM Risk Management
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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