Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

Brandon	M.	Cary

Founder	&	President

Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Avenue

Suite	1100

Denver,	Co	80237

(720)	557-5237

brandon@ridgelinemapping.com

To	whom	it	may	concern,

Ridgeline	Mapping	&	Surveying	Inc. is	petitioning	the	Federal	Aviation	

Administration	(FAA)	for an	exemption	to	Section	333	of	the	FAA	Modernization	

and	Reform	Act	of	2012 (FMRA)	and	14	CFR	Part	11. The	exemption	would	allow	

operation	of	the	3D	Robotics	X8-M	and	3D	ROBOTICS	SOLO	small-unmanned

aircraft	systems	(sUAS)	for	the	purpose	of	Low	Altitude	Aerial	Mapping (Below	400’	

AGL),	Land	Surveying,	Construction	Progress	Monitoring,	Environmental, Ecological	

&	Construction	Monitoring,	Aerial	Videography, Photography for Real	Estate	&	

Precision	Agriculture	Applications.	This	document	outlines the	proposed	operations	

regarding relief	from	regulations	pertaining	to	this	exemption.

Ridgeline	Mapping	&	Surveying	Inc. agrees	to	operate	within	the	boundaries	set	

forth	by	the	Section	333	exemption, if	granted.	Along	with	the	rules	and	regulations	

that	the	FAA	has	in	place,	Ridgeline	Mapping	&	Surveying	Inc.	plans	to	use	additional	

safety	precautions	such	as	pre	flight	checks,	thorough review	of	site	specific	terrain	

&	weather	condition	in	addition	to	company	wide	mandatory	UAV	specific	Ground	

School	+	Flight	Training	to ensure	safe sUAS	operations.	Implementation	of	

lightweight	sUas,	otherwise	known	as	“Small-Unmanned	Aerial	Systems”	is	a tool	

that can	greatly	improve	the	safety	of	Land	Surveyors	and	Mapping	Personnel while	

accessing	difficult and	dangerous	areas	of	operation.	The	intention	is	to	drastically	

improve	the	safety	and	efficiency	of	aerial	data	capture in	all	steps	of	mission	

planning	&	operation	in	the	field.	sUAS	can	fly faster,	cheaper	&	safer	operations	

that	traditionally	would	require	manned	aircraft	which carry	pilots, flammable	fuel

and	could	potentially	pose	a	great	risk	to	personnel	and	property	on	the	ground	

should	an	accident	occur.	Please	Allow	Ridgeline	Mapping	&	Surveying	Inc.	to	offer	

sUAS	operations	to our local	market	to	promote	the	safe, efficient	and	responsible	

use	of	sUAS.

Thank	you	for	your	time &	consideration.

Table	of	Contents

Glossary ....................................................................................................2

List	of	Attachments	..............................................................................2
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

Section	1: Introduction	and	Interest	of	

Petitioner..............................................................................................2

Section	2: Unmanned	Aerial	Systems.....................................2

Equipment	List....................................................................4

Section	3: Unmanned	Aircraft	Pilot	in	Command	(PIC)..5

Section	4: Proposed	Operation	of	sUas .................................7

Section	5: Requested	Exemptions	from	Regulations	.......9

Section	6: Public	Interest	............................................................11

Conclusion	..........................................................................................12

Glossary

AGL: Above	Ground	Level

ATC: Air	Traffic	Control

COA: Certificate	of	Authorization

FAA: Federal	Aviation Administration

FAR: Federal	Aviation	Regulation

MAAP: Mid	Atlantic	Aviation Partnership

NAS: National	Airspace	System

PIC: Pilot	in	Command

sUAS: Small	Unmanned	Aircraft Systems

VFR: Visual	Flight	Rules

VMC: Visual	Meteorological Conditions

VO: Visual	Observer

VLS: Visual	Line	of	Sight

DOT:	Department	of	Transportation

LIST	OF	ATTACHMENTS

3D	ROBOTICS	SOLO operational	Manual

Solo	Specs:	Just	the	Facts	document

3D	Robotics	X8-M	operational	manual

Pixhawk	Flight	Controller	User Manual

UAV	Flight Training	Certificate	– Brandon	M.	Cary

Section	1:	Introduction	and	Interest	of	Petitioner

Ridgeline	Mapping	&	Surveying	Inc. is	a	business	based	in	Denver,	Colorado

specializing	in	mapping	&	Land	Surveying.	We	intend to	use	two	current	3D	

Robotics	(3DR)	model	sUAS	platforms	to	gather	Aerial	Data,	Images &	Video for	the	

use of	Mapping,	Land	Surveying,	Construction	Monitoring,	Environmental	Mapping,	

Ecological	Monitoring,	and	Precision Agriculture	Applications.	Ridgeline	Mapping	&	
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

Surveying	Inc.	is	committed	to	providing safe	and	responsible	sUAS	flight	operations

by qualified	professionals. It	shall	be	the	intent	of	every	sUAS	operator	to	make	

a	responsible	effort	to not	invade	a	person's	reasonable	expectation	of	

privacy	when	operating	a sUAS.	Safety	and	the	best	interest	of	the	general	

public	are	the	top	priority.	When	operating	a sUAS,	Ridgeline	Mapping	&	

Surveying	Inc. operators	will	at	all	times	adhere	to all	FAA	Regulations	and	

obtain the proper	authorization	for	flight.

Section	2:	sUAS	(Small	Unmanned	Aerial	Systems)

General	Information	Regarding Proposed Operation	of	

sUAS

Ridgeline	Mapping	&	Surveying	Inc. will	operate	less	than	fifty-five	pound	sUAS,	to	

conduct aerial	mapping	services	as	well	as	photo	and	video	documentation,	with	

payloads	specifically	designed	for supporting	these	missions.

Prior	to	each	flight	the	Pilot	in	Command	(PIC) shall	inspect	the	sUAS	to	ensure	it	is	

in	a	condition	for	safe flight by	following	the	manufacturers	operating	manual	

recommendations	for safe	flight	operations	in	addition	to	company	specific	pre	

flight	checklists.	If	the	inspection	reveals	a	condition	that	impedes the	safe	operation	

of	the	sUAS,	the aircraft	will	be	prohibited	from	operating	until	the	necessary	

maintenance	has	been performed and	the	sUAS	is	found	to	be	in	a	condition	for	safe	

flight.	Ground	Control Stations will	be	included	in	preflight	inspections	as	well.	

Maintenance	and	Alterations will be	properly	documented	in	aircraft	records.	All	

discrepancies	noted	will be documented	as	described	in	the Ridgeline	Mapping	&	

Surveying	Inc. Pre	Flight Inspection	Logbook.	Any	maintenance	or	alterations	made	

to	the	sUAS	shall	be	documented	in	a	logbook	as well	as	undergo	test	flight	before	it	

can	return	to	service.	Any	repairs	or	alterations	must meet	the	manufacturer's	

specifications with	particular	attention	to	flight	critical	components that	may	not	be	

addressed	in	the	manufacturer’s	manuals.	Only	personnel	who	are authorized	shall	

perform	such	operations.

Ridgeline	Mapping	&	Surveying	Inc. will	follow	all	manufacturers’ sUAS	

aircraft/component, maintenance,	overhaul,	replacement,	inspection	and	life	limit	

requirements,	Ridgeline	Mapping	&	Surveying	Inc shall	carry	out	their	maintenance,	

inspections	and	record	keeping requirements,	in	accordance	with	the	operator’s	

manual.	Maintenance,	inspection, and alterations	must	be	noted	in	the	aircraft	

logbook,	including	total	flight	hours	and	a	thorough	description of	work to	be	

completed.	Each	sUAS	operated	under	the	proposed	exemption	shall	comply	with	all	

manufacturer System	Updates	and	Recommended	Safety	Procedures. Ridgeline	

Mapping	&	Surveying	Inc. technicians	will	receive	and	documented training	as	
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

referenced	in	the manufacturer’s operations	manual. Before	conducting	operations,	

the	radio	frequency	spectrum	used	for	operation	and control	of	the	sUAS	shall	

comply	with	the	Federal	Communications	Commission	(FCC) or	any	other	applicable

government	oversight	agency	requirements.

Equipment	List

3D	ROBOTICS X8-M

Ridgeline	Mapping	&	Surveying	Inc. seeks	an	exemption	to	operate	3D	Robotics	X8-

M	sUAS,	for compensation	or	hire.	The	3D	Robotics	X8-M	is	comprised	of	an	8	rotor	

powered	unmanned	aircraft and	a	handheld	ground	control	station.	The	X8-M

Specifications	are	as	follows:

Max	gross	weight	- approximately	7.7	lbs.	(3.5	kg) with	battery	included

Aircraft	Dimensions	- 13.7” diameter	(rotor	span),	width	of	20.1”,	height	of	11.8”

Recommended	Operating	Speed	-11	mph (5	m/s)

Payload	capacity		.4	lbs. (200	grams)

Radio	range	- .6	miles	(1	km)

Maximum	flight Time -14	minutes

Landing	Accuracy	– 8.2’	(2.5 m)

Max	Operational	Wind	Speed	- 25	mph	(11	m/s)

Autopilot:	3DR	Pixhawk	V2.4.5

Firmware	- ArduCopter	3.2

GPS	– 3DR	u-blox	GPS	with	compass	(LEA-6H	Module	/	5hz	Update)

Telemetry	Radio	– 3DR	Radio	v2	(915	MHz)

Motors	– 8	Sunny	Sky	V2216-12	800	kv	II

Frame	– X	8	type	

Propellers	– APC	11x4.7	SFP	(4),	APC	11x4.7	SF	(4)

Battery	– 4S	10,000	mAh	10C	Lithium	Polymer	(LiPo)

Camera	– Canon	SX260	12.1	Megapixel

The	design	and	operational	characteristics	of	the	3DR	X8-M	are	additionally	

provided	in	the Manufacturers	Operation Manual and	the	included	X8-M	spec	Sheet	

V3.	Figures	reflect	estimated	values	at	ideal	operating	conditions.	Environmental	

conditions	can	affect	flight	times,	range	and	area	coverage.	Flight	crews	will	be	

required	to conduct	pre-flight	inspections	as	documented	in	3DR	X8-M	Operation

Manual.	Special	attention	will	be	given	to	the	environmental	conditions	on	site	on	

the	day	of	the	operation	taking	into	account	weather	and	any	adverse	conditions	

that	may	cause	delays	or	otherwise	unsafe	flight	conditions.	

3D	ROBOTICS	SOLO

Ridgeline	Mapping	&	Surveying	Inc. seeks	an	exemption	to	operate	a	3D	Robotics	

Solo	sUAS	for	compensation or	hire.	The	3D Robotics Solo	is	comprised	of	a	quad-
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

rotor	unmanned	aircraft	and	a	handheld	ground	control	station.	The	3D Robotics

Solo	Specifications	are	as	follows:

Max	gross	weight	- approximately	3.3	lbs.	(1.5	kg)	/	3.9	lbs.	(1.8	kg)	w/	GoPro	+	Gimbal

Aircraft	Dimensions	– 10”	tall	(25	cm),	18”	(46	cm)	motor	to	motor

Maximum	Operating	Speed	-33	mph	(15	m/s)

Radio	range	- .5	miles	(.8	km)

Maximum	flight	Time	-25	minutes;	20	minutes	with	payload

Operating	Temperature	– 32	deg.	F	– 113	deg.	F	(0	deg.	C	to	45	deg.	C)

Max	Payload	– 420g

Max	Ascent	Speed	– 10	m/s	in	stabilize	mode;	5	m/s	in	“fly”	mode. Ditto	for	descent	

speed

Max	Operational	Wind	Speed	- 25	mph	(11	m/s)

Max	Altitude	– 400’	per	FAA	regulation	(122	m)	

Autopilot:	Pixhawk	2

Firmware	– APM:Copter

Telemetry	Radio	– 3DR	Radio	2.4	GHz	frequency

Motors	– 880	kV

Propellers	– 10”	Diameter	4.5”Pitch	Self	Tightening (24	cm	dia.	144	cm.	pitch)	Glass	

Reinforced	Nylon

Flight	Battery	– 5200	mAh	14.8	Vdc Lithium	Polymer	(LiPo)

Controller	Battery	– 2600	mAh 7.2	Vdc	rechargeable Lithium	Ion

Camera	– GoPro	Hero	4	Black	16	MP

Section	3:	Unmanned Aircraft	(PIC)	Pilot	in	Command

Ridgeline	Mapping	&	Surveying	Inc. Flight	Crew,	including	Pilots	in	Command	(PIC)

and	Visual	Observers	(VO),	will	be qualified	as	directed	by Ridgeline	Mapping	&	

Surveying	Inc.	Background	check	and	criminal	history	verifications	will	be	

completed	pre-employment	and	all	personnel	will	be	drug	screened	as	required	by	

DOT	standards under	the	Aviation	(FAA),	Pipeline	(PHMSA)	& Transit	(FTA)	modes.

These	modes	are	best	suited	to	our	areas	of	operation.	Pilot’s	in	Command	will	hold	

a	Private	Pilots	Certificate	or	at	a	minimum	a	Sport	Pilots	Certificate	as	defined	in	14	

C.F.R.	Part	61.113(a)	.

As	Founder	&	President	of	Ridgeline	Mapping	&	Surveying	Inc.,	I	have	over	16	years	

of	mapping	and	land-surveying	experience	including	remote	sensing	LIDAR	mission	

Ground	Control	Point	(GCP)	Surveys	using	manned	aircraft and	ground	based	GPS	

surveying	methods. I	have	completed	an intensive UAV	Flight	Training Course	

including	16	Hours	of	ground	school, 10 hours	of	Simulated	Flight	Training and	24

Hours	of	real	world	flight	testing	for	certification	by	Unmanned	Vehicle	University	

http://www.uxvuniversity.com/.	I will	encourage	any	applicants	for	Pilots	in	

Command	positions or	Visual	Observers	to	hold	at	a	minimum	a	comparable	level	of	

training	certification as	well	as	the	minimum	Private	pilot	or	Sport	Pilot’s	Certificate	

as	required	by	FAA	regulations.	I	have	taken	steps towards obtaining a	Sport	Pilot’s	
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

Certificate	at	the	earliest	possible	opportunity	as	well,	upon	approval	of	the	

exemption	by	the	FAA.	In	addition,	Ridgeline	Mapping	&	Surveying	Inc. will	conduct	

all	flight	operations	under	a	comprehensive	commercial	insurance	policy	with	

minimum	liability	coverage	of	1 Million	Dollars.	

Pilots	in	Command	will	hold	a	minimum	of	a	Sport	Pilot	or	Private	Pilot’s	Certificate	

as	defined	in	14	C.F.R.	Part	61.113(a).	The VO	will	be	trained	in	safe	operations	and	

given	a	safety	brief	at	each	site on	a pre	flight basis.	Should the	company	expand	

enough	to	justify	additional	PIC’s &	VO’s,	all	personnel	hired	will	be	expected	to	

exhibit	a	thorough	and	complete	understanding	of	all	flight	rules	pertaining	to	the	

333	exemption,	FAA	regulations	pertaining	to	the	safe	operation	of	UAS	and	be	able	

to	exhibit	a	safe	and	competent	level	of	flight	experience	through	training	and	

certification.	A	comprehensive	flight	test	will	be	given	to	each	applicant at	an	

approved	AMA model	aircraft	flight	facility	or	an	FAA	approved	Drone	Test	Site	at a	

minimum	of	500’	away	from	bystanders	and	non-essential	personnel.

All	flight	crewmembers,	including future PIC’s and	VO’s,	will	have	an	understanding	

of,	and	comply	with,	Title	14	Code	of	Federal	Regulations,	and/or	Agency	directives	

and regulations,	applicable	to	the	airspace	where	the	sUAS	will	operate.	Specifically	

all	flight crewmembers will	receive	training	on	the	rules	and	responsibilities	

described	in	14	CFR Part	91	Sections	91.111,	91.113	and	91.115	regarding	cloud	

clearance,	flight	visibility and	the	pilot	controller	glossary,	including	standard	ATC	

phraseology	and communication. Prior	documented	flight	experience	that	was	

obtained	in	compliance	with	applicable regulations	may	satisfy	this	requirement.	

Training,	proficiency,	and	experience	building flights	shall	be	conducted in	a	closed	

course	environment	such	as an	approved	AMA	(Academy	of	Model	Aeronautics)	

flight	facility. The	AMA	is	a	self	supporting,	non-profit	agency	committed	to	the	

promotion	and	development	of	model	aeronautics.

During	training,	proficiency,	and	experience building	flights,	all	persons	not	

essential	for	flight	operations	will	be	considered	nonparticipants and	the	PIC	will	

operate	the	sUAS	with	appropriate	distance	from	nonparticipants in	accordance	

with	14	CFR	Section	91.119.	Operations),	the	PIC	must	have accumulated	and	logged	

in	a	manner	consistent	with	14	CFR	Section	61.51(b),	a minimum	of	five	hours	as	a	

sUAS	PIC	operating	the	make	and	model	of	the	sUAS	to	be utilized	for	operations	

under	this	requested	exemption,	and	three	takeoffs and	landings	in the	preceding	90	

days.	Ridgeline	Mapping	&	Surveying	Inc.	is	requesting	that all	training,	proficiency,	

experience	building, takeoff and landing	currency	flights	be	conducted	under	this	

grant	of	exemption	to accomplish	the	required	flight	time	and	90	day	currency.	

All	operations	must	utilize	a	Visual	Observer	(VO).	The	VO	may	be	used	to	satisfy	the	

Visual	Line	of	Sight (VLOS)	requirement	as	long	as	the	PIC	always	maintains	VLOS	

capability.	The	VO	and PIC	must	be	able	to	communicate	verbally	at	all	times.	This	

condition	and	limitation	is consistent	with	all	FAA	approved	Exemptions.
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

Section	4:	Operations	of	sUAS

		The	following	general	rules	and	guidelines	will	be	strictly	adhered	to	at	all	times:

- At	all	times	the	sUAS	must	remain	within	visual	line	of	site	from	to	PIC	and	the	operator	

must	be	able	to	see	the	sUAS unaided	by	any	device	other	than	corrective lenses.

		- Small	Unmanned	Aircraft	may	not	operate	over	any	persons	not	directly	involved	in	the

operation. Daylight	only	operations	(official	sunrise	to	official	sunset,local time).

- sUAS	Must	yield	right-of-way	to	other	aircraft,	manned	or	unmanned.

- First-person	view (FPV) camera	cannot	satisfy	“see-and-avoid”	requirement	but	can	be	

used as	long	as	requirement	is	satisfied	in	other	ways.

- Maximum	airspeed	of	30	mph

- Maximum	altitude	of	400	feet	AGL	(above	ground	level).

- Minimum	weather	visibility	of	3	miles	from	control	station.

- No	operations	are	allowed	in	Class	A	(18,000	feet	&	above)	airspace.

- Operations	in	Class	B,	C,	D	and	E	airspace	are	allowed	with	the	required	ATC permission

but	for	all	intents	and	practical	purposes	will	not	be	necessary	due	to	the	nature	of	our	

opperations.

- Operations	in	Class	G	airspace	are	allowed	without	ATC	permission

- No	person	may	act	as	an	operator	or	VO	for	more	than	one	unmanned	aircraft operation	at	

any	one	given	time.

- No	careless	or	reckless	operations will	be	allowed.

- Preflight	inspection	is	mandatory	by	the	operator or	PIC.

- The	sUAS shall	remain	clear	and	yield	the	right	of	way	to	all	other	manned	aviation

operations	and	activities	at	all	times.

- The	sUAS	shall	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level

(AGL).	All	altitudes	reported	to	ATC	will	be	in	feet.

- The	multi-rotor	sUAS	shall	not	be	flown	at	a	ground	speed	not	to	exceed 30	mph.

- sUAS	Operations	will	be	conducted	under	visual	meteorological	conditions	(VMC).

-sUAS	will	not	be	operated	less	than	500	feet	below	or	less	than	2000	feet	horizontally from	

a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.

- If	the	sUAS	loses	communications	or	loses	its	GPS	signal,	it	must	return	to	a predetermined	

location	within	the	planned	operating	area	and	land	or	be	recovered.

- The	sUAS	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles	or emergencies	in	

accordance	with	operating	documents.

- The	sUAS	PIC	is	prohibited	from	beginning	a	flight	unless	there	is	enough	power	to	fly	at	

normal	cruising	speed	to	the intended	landing	point	and	land	the	sUAS	with	25%	battery	

power	remaining	while	taking	into	consideration	current	weather	conditions.

-The	sUAS	operated	in	accordance	with	this	proposed	exemption	shall	be	identified	by

Serial numbers,	registered	in	accordance	with	14	CFR	part	47,	and	have	identification

(Number)	markings	in	accordance	with	14	CFR	part	45,	Subpart	C.	Markings	will	be	as

large as	practicable.

- The	sUAS	documents	required	under	14	CFR	91.9	and	91.203	shall	be	available	to	the

PIC	at	the	Ground	Control	Station	of	the	sUAS	anytime	the	aircraft	is	operating.	Those

documents	shall	be	available	to	the	Administrator	or	any	law	enforcement	official	upon

request.

- Any	sUAS	incidents,	accidents	or	flight	operations	that	transgress	the	lateral	or	vertical

boundaries of	the	operational	area	as	defined	by	the	applicable	COA	shall	be	reported	to

the	FAA’s	UAS	Integration	Office	(AFS-80)	within	24	hours.	Accidents	shall	be	reported
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

to	the	National	Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	the

NTSB	Web	site:	www.ntsb.gov.

- Unless	otherwise	specified	in	this	petition,	the	sUAS	PIC,	and	the	sUAS	operations	shall

comply	with	all	applicable	parts	of	14	CFR	including,	but	not	limited	to,	parts	45,	47,	61

and	91.

Proposed	Area	of	Operations

The	sUAS shall	not	be	operated	over	congested	or	densely	populated	areas.	These areas	

include	but	are	not	limited	to	the	yellow	areas	depicted	on	World	Aeronautical Charts	

(WAC),	Sectional	Aeronautical	Charts	(Sectionals),	or	Terminal	Area	Charts (TAC).	Each	

work	site	will	also	be	evaluated	based	on	local	conditions. Operations	of	sUAS	may	be	

conducted	at	distances	less	than	500	feet	from	participating persons,	vessels,	vehicles	or	

structures	that	perform	an	essential	function	in	connection with	these	special	purpose	

operations.	Operations	closer	than	500	feet	from	the	PIC, VO,	operator	trainees	and	

essential	persons	are	permitted	when	operationally necessary;	but	never	so	close	to	present	

an	undue	hazard.	This	is	consistent	with Exemption	No.	11138.

Operations	of	sUAS	may	be	conducted	at	distances	less	than	500	feet	from	unoccupied

Vessels,	vehicles	or	structures	owned	by	the	land	owner/controller	when	the	land

owner/controller	grants	such	permission,	and	the	PIC	makes	a	safety	assessment	of	the risk	

from	operations	and	determines	that	it	does	not	present	an	undue	hazard	to	persons or	

property.	This	is	consistent	with	Exemption	No.	11138. Flight	operations	will	be	conducted	

at	least	500	feet	from	all	nonparticipating	persons unless	barriers	or	structures	are	present

that	sufficiently	protect	nonparticipating	persons from	the	sUAS	and/or	debris	in	the	event	

of	an	accident.	Ridgeline	Mapping	&	Surveying	Inc.	shall	ensure	that nonparticipating	

persons	remain	under	such	protection.	If	a	situation	arises	where nonparticipating	persons	

leave	such	protection	and	are	within	500	feet	of	the	sUAS, flight	operations	will	cease	

immediately.	This	is	consistent	with	Exemption	No.	11138. All	operations	of	sUAS	shall	be	

conducted	with	the	permission	from	the	land owner/controller	or	authorized	

representative.	Permission	from	the	land	owner/controller or	authorized	representative	

will	be	obtained	for	each	flight	to	be	conducted.

Airport	Proximity

The	sUAS	will	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as denoted	

on	a	current	FAA-published	aeronautical	chart	unless	a	letter	of	agreement	with that	

airport’s	management	is	obtained,	and	the	operation	is	conducted	in	accordance with	a	

NOTAM	as	required	by	the	operator’s	COA.	The	letter	of	agreement	with	the airport	

management	will	be	made	available	to	the	Administrator	upon	request.	This	is consistent	

with	Exemption	No	11159.

Visual	Line	of	Site

The	sUAS	must	be	operated	within	VLOS	of	the	PIC	and	VO	at	all	times.	This	requires the	PIC	

to	be	able	to	use	human	vision	to	see	the	sUAS	unaided	by	any	device	other than	corrective	

lenses,	as	specified	on	the	PIC’s	FAA	issued	medical	certificate. All	sUAS	operations	must	

utilize	a	VO.	The	VO	may	be	used	to	satisfy	the	VLOS requirement	as	long	as	the	PIC	always	

maintains	VLOS	capability.	The	VO	and	PIC must	be	able	to	communicate	verbally	at	all	

times.	The	PIC	and	VO	must	be	designated before	the	flight	and	cannot	transfer	his	or	her	

designation	for	the	duration	of	the flight.	The	PIC	must	ensure	that	the	VO	can	perform	the	
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

functions. The	sUAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or vehicle.	

Operations	will	not	be	conducted	during	night	as	defined	in	14	CFR	1.1.

PreFlight	Safety	(14	CFR	§	91.7(b))

Ridgeline	Mapping	&	Surveying	Inc. will	conduct	preflight	safety	risk	assessments	to	

determine	that	the sUAS	is	in	a	condition	for	safe	flight	(14	CFR	Section	91.7(b))	and	that	

the	planned operation	can	be	completed	safely.	Specific	procedures	will	be	consistent	with	

the	recommendations	in	the	3DRobotics	Manufacturers	Operating	manual.

Flight	Standards	District	Offices	(FSDOs)

Ridgeline	Mapping	&	Surveying	Inc. operations	do	not	require	a	notification	to	Flight	

Standards	District Offices	(FSDOs).	They	will	not	be	engaging	in	the	type	of	sUAS	that	would	

warrant contact.

Certificate	of	Waiver	or	Authorization

Ridgeline	Mapping	&	Surveying	Inc. shall	obtain	an	Air	Traffic	Organization	(ATO)	issued	

Certificate	of Waiver	or	Authorization	(COA)	prior	to	conducting	any	operations	under	this	

requested grant	of	exemption.	Additionally,	Ridgeline Mapping	&	Surveying	Inc.	will	request	

a	Notice	to	Airmen (NOTAM)	not	more	than	72	hours,	but	not	less	than	48	hours	prior	to	the	

operation.

Weather

sUAS	Operations	will	be	conducted	under	visual	meteorological	conditions	(VMC).	The

sUAS	will	not	be	operated	less	than	500	feet	below	or	less	than	2000	feet	horizontally

from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.	In	additions

fellow	sUAS manufacturer's	guidelines	for	weather	operation	limitations	and	standards.

Section	5:	Requested	Exemptions	from

Regulations

Considered Regulation Title & Requested Actions

• 14	C.F.R	Part 21.185 Airworthiness Certificate

Ridgeline	Mapping	&	Surveying	Inc. recommends	that	in	consideration of	the	size,	weight,	

speed	and	limited	operating	area associated	with	these	aircraft	and	their	operation,	the

Secretary	of	Transportation	determines	that	these aircraft meet	the	conditions	of	Section	

333.	

Relief	is not	necessary.

• 14	C.F.R.	Part 45.23(b) Display	of	marks

Ridgeline	Mapping	&	Surveying	Inc.	sUAV	shall	be	identified	by	serial number,	registered	in	

accordance	with	14	CFR	part 47,	and	have	identification	(N-Number)	markings	in

accordance	with	14	CFR	part	45,	SubpartC.	Markings	will	be	as	large	as	practicable.

Relief	is	not	necessary.

(In	Addition	to	14	C.F.R.	Part	45.23	(b),	Ridgeline	Mapping	&	Surveying	Inc.	will	register	

each	of	it’s	UAV	systems	with	the	Department	of	Transportation	(D.O.T.)	as	will	most	likely	

be	a	requirement	by	federal	law.)

• 14	C.F.R.	Part 61.113(a) Private	pilot privileges	and limitations
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

The	FAA	has	found	in	previous	grants	of	exemption that	a	PIC	with	a	private	pilot	certificate	

operating	a sUAS would	not	adversely	affect	operations	in	the NAS	or	present	a	hazard	to	

persons	or	property	on the	ground.	Request	relief	with	limitations	and conditions	

specified	in	this	petition.

• 14	C.F.R.	Part 61.133(b) Commercial	pilot privileges	and limitations

The FAA	has	found	in	previous	grants	of	exemption that	a	PIC	with	a	private	pilot	certificate	

operating	a sUAS	would	not	adversely	affect	operations	in	the NAS	or	present	a	hazard	to	

persons	or	property	on the	ground.	Request	relief	with	limitations	and conditions	

specified	in	this	petition.

• 14	C.F.R.	Part 91.7(a) Civil	Aircraft Airworthiness

Ridgeline	Mapping	&	Surveying	Inc. recommends	that	in	consideration of	the	size,	weight,	

speed	and	limited	operating	area associated	with	this	aircraft	and	its	operation,	the

Secretary	of Transportation	determines	that	these	aircraft	meet	the conditions	of	Section	

333.	Relief	is	not	necessary.

• 14	C.F.R.	Part 91.9(b)(2)	&(c) Civil	Aircraft	Flight Manual,	Marking, and	

Placard Requirements

The	FAA	has	previously	determined	that	relief	from these	sections	is	not	necessary.	

Relevant	materials may	be	kept	in	a	location	accessible	to	the	PIC	in compliance	with	the	

regulations.	Relief	is	not necessary.

• 14	C.F.R.	Part 91.103 Preflight	Action

Ridgeline	Mapping	&	Surveying	Inc.	will	perform.	Relief	is	not necessary.

• 14	C.F.R.	Part91.109(a) Flight Instruction

Ridgeline	Mapping	&	Surveying	Inc. will	conduct	all	flight	training	through Procedures

specified	in	Training	Instruction	during dedicated	training	sessions.	Based	on	previous

decisions	made	by	the	FAA	for	sUAS	petitions	regarding this	regulation,	relief	is	not	

necessary.

• 14	C.F.R.	Part 91.119(c) Minimum	Safe Altitude

Aircraft	will	be	operated	below	400	AGL,	but	not	over congested	areas.	Request	relief	with	

limitations	and conditions	specified	in	this	petition.

• 14	C.F.R.	Part 121 Altimeter Settings

The	proposed	aircraft	have	a	barometric	altimeter	and

High	Accuracy	Survey	Grade	GPS	 (GNSS)	derived	altitude	capabilities. Ridgeline	Mapping	&	

Surveying	Inc. recommends	that	the	altimeter	be	set	to	zero	feet	AGL rather	than	local	

barometric	pressure	or	field	altitude before	flight.	Considering	the	limited	altitude	of	the

proposed	operations.	 In	addition	to	the	safety	measures	in	place	using	the	high	accuracy	

GPS	we	will	also	install	a	small	optical	flow	sensor	that	tracks	the	distance	to	the	ground	

while	communicating	with	the	on	board	flight	controller.	This	provides	additional	stability	

and	accuracy	of	the	real	time	accuracy	of	the	altitude.	Accurate	altitude telemetry	is	

calculated	instantly	and	displayed	on	the	controller	display	screen. Request	relief	with	

limitations and	conditions	specified	in	this	petition.
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

• 14	C.F.R.	Part	91.151	(a)	Fuel Requirements	in	

Prior	relief	has	been	granted	for	manned	and	unmanned aircraft	to	operate	at	less	than	

prescribed minimums.	Request	relief	with	limitations	and conditions	specified	in	this	

petition.

• 14	C.F.R.	Part 91.203(a)	and (b) Certifications Required

Original	intent	of	these	regulations	was	to	display	an aircraft’s	airworthiness,	certification	

and	registration documents	so	they	would	be	easily	available	to inspectors	and	passengers.	

Based	on	the	FAA Memorandum	subject,	“Interpretation	regarding	whether certain	

required	documents	may	be	kept	at	an	unmanned aircraft’s	control	station,”	dated	August	8,	

2014,	relief	is not	necessary.

• 14	C.F.R.	Part 91.405(a) Maintenance Required

Request	relief	with	limitations	and	conditions specified	in	this	petition.

• 14	C.F.R.	Part 91.407(a)(1) Operation	after Maintenance

Request	relief	with	limitations	and	conditions specified	in	this	petition.

• 14	C.F.R.	Part 91.409(a)(1) and	(2) Inspections

Request	relief	with	limitations	and	conditions specified	in	this	petition.

• 14	C.F.R.	Part 91.417(a)	and (b) Maintenance Records

Request	relief	with	limitations	and	conditions Specified in	this	petition.

Protection	of	Rights	and	Privacy

UAS PIC (Pilot	in	Command),	Gimbal	Operators	and	Spotter	or	any	other	person	involved in	

flight	mission	is	to	observer	and	privacy	rights	or	expectations	of	the	public.	Any person	

involved	in	any	unlawful	flights	that	may	jeopardize	someone's	privacy	right	or

expectations	will	be	held	accountable	for	their	actions.

Section	6:	The	Public	Interest

Ridgeline	Mapping	&	Surveying	Inc. is	a	small	business with	50+	years	combined

experience	in	Land	Surveying,	Mapping,	GIS,	Aerial	Photogrammetry	and LIDAR	

Mapping	using	manned	aircraft,	ground	based	Data	Collection	Systems,	High	

Precision	Survey	Grade	GPS	and	Optical	Equipment.	Our	core	group consists	of a	

Certified	Professional	Mapping	Scientist	(LIS/GIS)	and	PLS	registered	to	offer	

professional	Land	Surveying	Services	in	the	state	of	Colorado,	Montana	&	Utah.	

Myself	as	Founder	and	President	hold	a	Certified	UAS	Pilot	Certificate	Issued	by	the	

Unmanned Vehicle	University and	am	currently	studying	the	ground	school	

materials	in	order	to	sit	for	the	FAA	knowledge	test.	I	intend	to	have	a	Sport	Pilots	

License	at	the	earliest	opportunity	in	order	to	conduct	flights	within	the	limits	set	

forth	in	the	approved	exemption,	should	it	be	granted.	

We	are	dedicated	to	supporting	and	promoting	the safe	and	responsible	

implementation	of	sUAS	into	our	national	airspace while	creating	jobs	and	investing	
Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Ave.	Suite	1100	Denver,	Co	80237

in	a	fast	paced and	exciting	new	market. Ridgeline	Mapping	&	Surveying	Inc.	will	

offer	the	local	market	an	accredited	sUAS	operation	to aid	in	aerial	data	acquisition,	

land	surveying,	construction	monitoring,		aerial	mapping,	aerial	videography	and	

photography.	Ridgeline	Mapping	&	Surveying	Inc.	use	small-unmanned	aerial	

vehicles	that	have	the	capacity	to	perform	work	in	a	safe	and	effective	manor	that	

would otherwise require	a	full-scale fixed wing aircraft or	helicopter	plus	a pilot and	

passengers	to	operate	the	digital	data	capture	sensors,	thus	reducing	risk	to	people	

and	property.

For	these	reasons	we	feel	Ridgeline	Mapping	&	Surveying	Inc.,	while	conducting	safe	

and	responsible	commercial	operations	of	sUas,	will	be	operating	in	the	best	

interest	of	the	general public. This	above	all,	is	our	first	priority.

Conclusion

In	conclusion,	if	granted	relief	for the	above	listed	FAA	Codes	of	Federal	Regulations,		

Ridgeline	Mapping	&	Surveying	Inc.	will	proceed	to perform	safe,	efficient	and	responsible	

flight	operations	while	promoting	legal	flight	operations to	ensure	greater	public	safety and	

discouraging	unlawful	use of	sUAS.	We	will	also	reduce risk	to	pilots,	property	and	civilians	

due	to	the	implementation	of	lightweight	sUas	(small	unmanned	systems).

Sincerely,

Brandon	M.	Cary

Founder	& President

Ridgeline	Mapping	&	Surveying	Inc.

7900	E.	Union	Avenue

Denver,	Co 80237

(720)	557-5237

brandon@ridgelinemapping.com