719 2ND AVENUE, S UITE 200 | SEATTLE, WA 98104 | P 206.394.3700

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May 5 , 2015

United S tates Department of Transportation Docket Management System 1200 New Jersey Ave nue SE Washington, DC 20590

Re: Petition for Exemption Request of Parametrix, Inc. , under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C

. F

. R

. 61.113 (a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203 (a) & (b); 14 C.F.R. 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.417 (a) & (b).

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Parametrix, Inc. (Parametrix), an operator of smal l Unmanned Aircraft Systems (“UASs”) hereby applies for an exemption from the before mentioned Federal Aviation Regulations (“FARs”) to allow

co mmercial operation of its UASs. Parametrix will conduct its operations within and under the conditions of this p etition or as established by the FAA in granting a Section 333 exemption to Parametrix.

The name and address of the applicant is:

Parametrix, Inc. Attn: Steven K Aisaka 719 Second Avenue, Suite 200 Seattle, WA 98104 Ph. : 253

- 501

- 5206 Email: saisaka@parametrix.com

Specific Sections of 14 CFR from which Parametrix seeks an exemption: 14 C

. F

. R

. Part 21 14 C.F.R. 45.23(b) 14 C

. F

. R

. 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 C

. F

. R

. 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 C

. F

. R

. 91.151 (a)United States Department of Transportation May ____, 2015 Page 2

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14 C

. F

. R

. 91.203 (a) & (b) 14 C

. F

. R

. 91.405 (a) 14 C

. F

. R

. 407 (a) (1) 14 C

. F

. R

. 409 (a) (2) 14 C

. F

. R

. 417 (a) & (b)

From offices throughout the western United States, Parametrix provides multidisciplinary engineering

, pla nning and environmental science services in transportation, environmental planning and compliance,
water reso urces, and community building. As a 100

- percent employee

- owned firm, our staff have a vested interest in strong performance a nd exceptional client service. Individually

, and as a team, we are committed to providing high quality, cost

- effective solutions that enable our clients to make informed decisions.

Parametrix seeks an exemption to be able to provide the following services to our public and priv ate clients:

 Construction site observation and monitoring

.

 Aerial surveying and photogrammetry

.

 Photography and videography

.

 Inspection of structures

. The requested exemptions would permit Parametrix to operate small, unmanned UASs under conditions that are 1) limited

, 2) controlled

, 3) economical

, and 4) would provide safety enhancemen ts over conventional aircraft. Approval of this exemption would thereby enhance safety to the public and fulfill the FAA’S responsibilities to establish requirements for the safe operation of such aircraft systems in the national airspace system.

Parametrix proposes to operate the DJI Phanto m 2, and the s enceF ly eBee

. The relevant user manuals of the UASs are attached. Parametrix’s UASs weigh 55 or fewer pounds includin g payload. The UASs will be operate d , under normal conditions

, at a speed of no more than 100 mph and have the capability to move in the vertical and h orizontal plane simultaneously. The UASs will be operate d only in line of sight and only within a control led area. These operations will insure that the UAS will not create a hazard to users of the national airspace system or the public.

Given the small size of the UASs involved and the restricted controlled environment which the UASs will operate, Parametrix falls within that zone of safety (an equivalent level of safety) in which Con gress envisioned that the FAA, by exemption, allow commercial operations of UASs to operate. Also

, due to the size of the UASs and the controlled areas in which the UASs will ope rate, approval of the application presents no national security issue. Under Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the equivalent level of safety surrounding the proposed operations, and the public benefit, inc luding enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs, the grant of the requested exemptions is in the public ’s interest.

Parametrix proposes that the exemption requested apply to civil aircra ft that have the characteristics and that operate with the limitations listed. These limitations provide for at least an equivalent or even higherUnited States Department of Transportation May ____, 2015 Page 3

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level of safety to operations under the current regulatory structure because the proposed operations
represen t a safety enhancement to the existing safe operations conducted with conventional aircraft. These limitations and conditions to which Parametrix agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAS will w eigh less than 55 pounds (25 kg). 2. The UAS will be operated at a speed of no more than 100 mph. 3. Only visual line

- of

- sight (“VLOS”) operations will be allowed; the UAS must remain within VLOS of the operator or a visual observer (“VO”). 4. UAS operations will o ccur during daylight hours only. 5. No person may act as an operator or VO for more than one unmanned aircraft operation at one time. 6. Minimum crew for each operation will consist of the UAS Operator and a Visual Observer. 7. The UAS Operator will be Pilot in Com mand (PIC) who shall have completed the required FAA training

, along with training from the manufacturer or distributor of the UAS. 8. The PIC will be vetted by the TSA and have a TSA Known Traveler Number, and have a valid driver’s license from the State of the PIC’s domicile. 9. The UAS will only operate within a confined controlled area of the flight operations area. 10. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 20% battery power reserve, should that occur prior to the 30

- minute limit. 11. A briefing will be conducted in regard to the planned UAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 12. The operator will obtain the consent of all persons involved and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivalent leve l of safety determination. 13. UAS operations may not occur over any persons not directly involved in the operation. 14. PIC and VO will at all times be able to communicate by voice. 15. PIC will conduct preflight inspections to ensure the UAS is safe for operation. 16. T he UAS will be required to yield right

- of

- way to all other aircraft, manned or unmanned. 17. Flights will be operated at an altitude of no more than 200 feet AGL

. 18. The UAS will only operate in Class G airspace. 19. The UAS will stay certain distances away from airports or heliports:

a. Five ( 5 ) nautical miles (NM) from an airport having an operational control tower; or b. Three ( 3 ) NM from an airport with a published instrument flight procedure, but not an operational tower; or

c. Two ( 2 ) NM from an airport without a pub lished instrument flight procedure or an operational tower; or d. Two ( 2 ) NM from a heliport with a published instrument flight procedure

. 20. UAS operations will be permitted to occur only when conditions allow minimum weather visibility of 3 miles from the cont rol station. 21. Written permission from the relevant property own ers will be obtained.United States Department of Transportation May ____, 2015 Page 4

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22. All required permissions and permits will be obtained from territorial, state, county

, or city jurisdictions, including local law enforcement, fire, or other appropriate go vernmental agencies. 23. If the UAS loses communication or loses its GPS signal, the UAS will have capability to return to a
pre

- determined location within the Security Perimeter and land. 24. The UAS will have the capability to abort a flight in case of unpredict ed obstacles or emergencies.

Accordingly, Parametrix respectfully requests that the FAA grant the requested exemption.

The extent of relief you seek, and the reason you seek the relief :
14 C.F.R. Part 21, Subpart H: Airwor thiness Certificates 14 C.F.R. 91.203 (a) (1).

Part 21 Subpart H, entitled Airworthiness Certificates

, sets forth the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. 91.203 (a) (1). Given the limited size, weight

, and operating area associ ated with the UAS to be utilized by Parametrix, 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 and Section 333 of the Reform Act authori ze 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.

The UAS s operated by Parametri x is less than 55 pounds fully loaded, carries no pilot or passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Operations under this exemption will be controlled and monitored by the operator and in compliance with the conditions of this document and also in compliance with any local public safety requirements. The FAA will have advance notice of all operations through a COA or more likely be operated under the “blanket” 200

- foot COA

.
In this case , 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 (fixed wing or ro torcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

14 C.F.R. 45.23 (b). Marking of the Aircraft

.

14 C.F.R. 45.23 prescribes that when marks include only the Roman capital letter “ N ” and the registration number is displayed on limited, restricted

, or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,”

“ restricted, ” “ light

- sport, ” “ experimental, ” or “ provisional, ” as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have n o entrance to the cabin, cockpit

, or pilot station on which the word “Experimental” can be placed. Given the size of the UAV

, 2

- inch lettering will not be possible. An equivalent level of safety will be the word “Experimental

, ” at a size that is as large a s practicable

, will be placed on t he fuselage in compliance with Section 45.29 (f). Additionally

, Parametrix will mark its UAS s with its company name and contact information.United States Department of Transportation May ____, 2015 Page 5

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14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (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 PIC operating the aircraft to have successfully completed, at a minimum

, FAA sport pilot ground instruction and passed the FAA Sport Pilot written examination or other FAA r ecognized equivalent training. The PIC will have also completed a manufacturer’s training program for the mo del the PIC will be operating. Additionally, the PIC will have been vetted by the TSA by obtaining a Known Traveler Number which comes along with TSA Pre status, and possess a valid driver’s license from the state of the PIC’s domicile.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights a re planned and coordinated in advance. The level of safety provided by these requirements will be at least as safe, or safer, than that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks as sociated with the operation of the UASs are diminished from the level of risk associated with commercial operations contemplated by Part 61

, when drafted, that allowing operations of the UAS as requested with FAA ground instruction and manufacturer’s train ing exceeds the present level o f safety achieved by 14 C.F.R. 61.113 (a) & (b).

14 C.F.R. 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 a irworthiness certificate issued for the UAS, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness of the UASs operated by Parametrix. Given the size of the aircraft and the requirements contained in the manu facturer’s manual for maintenance and use of safety check lists prior to each flight

, an equivalent level of safety will be provided.

14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides that no person may ope rate a U.S.

- registered civil aircraft . . . . (2) For which an Airplane or Rotorcraft Fl ight Manual is not required by Section 21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The Parametrix 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 the re is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the UAS flight manual at the ground control point where the PIC operating the UAS will have immediate access to it.United States Department of Transportation May ____, 2015 Page 6

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14 C.F.R. 91. 103: Preflight action

. This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.

Because FAA

- approved UAS flight manuals will not be provided for the aircraft

, an exemption will be needed. An exemption is requested from this requirement as the PIC will take separate preflight actions, including checking the condition of the UAS, checking flight battery requirements, weather conditions, checking takeoff and landi ng distances, and all other actions in the Use r Guide and safety checklists. These actions will provide an equivalent level of safety.

14 C.F.R. 91.109: Flight instruction

.

Section 91.10 9 provides that no person may operate a civil aircraft (except a manne d free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

UASs

, by their design

, do not have fully functional dual controls. Flight control is accomplished through the use of a controls that commun icate with the aircraft via radio c ommunications. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimum safe altitudes

.

S ection 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) limits aircraft flying over areas other th an congested areas to 500 AGL. Over sparsely populated areas

, aircraft cannot be operated closer than 500 feet of any per son, vessel

, or structure.

T his exemption is requested for minimum safe altitudes as Parametrix proposes to o perate its UASs below 200 AGL. As set forth herein, t he UAS will never o perate at higher than 200 AGL. An equivalent level of safety will be achi eved given the size, weight, and speed of the UAS

, as well as the location where it is operated. Additionally, n o flight operations will be made without the permission of the property owner or local officials.

1 4 C.F.R. 91.121 Altimeter Settings

. This reg ulation requires each person operating an 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.

Because the UAS will not h ave a barometric altimeter, but instead a GPS altitude read

- out, an exemption is requested. An equivalent level of safety will be achieved by confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions

. Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first poin t of intendedUnited States Department of Transportation May ____, 2015 Page 7

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landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The intent of this requirement is to provide enough fuel or energy rese rve in the event of delays due to
conges tion or weather at an airport. The typical battery powering a UAS provides approximately 40 minutes of powered flight. To meet the 30

- minute reserve requirement i n 14 CFR 91.151, Parametrix’s UAS flights would be lim ited to approximately 10 minutes in length. Given that the limitations o f a n UAS proposed flight will be operated with visual line of sight and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight VFR conditions is reasonable. Parametrix believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 20% of battery
power , whichever happens first. This exemption would be more than adequate to return the UAS to the landing zone from anywhere in its limited operating area.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

. The regulation provides in pertinent part:

(a) Except as provided in Section 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special fli ght authorization issued under Section 91.715 is displayed at the cabin

or co ckpit entrance so that it is legible to passengers or crew.

The UAS has no cabin or cockpit, there is no ability or place to carry certification and registration documents or to display these documents on the UAS. As with 14 C.F.R. 91.9 (b) (2): Civil Airc raft Flight Manual in the Aircraft, an equivalent level of safety will be achieved by keeping these documents at the ground control point where the PIC operating the UAS will have immediate access to the documents , to the extent needed and applicable to th e UAS.

14 C.F.R. 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 requi red inspections, except as provided in paragraph (c) of this section, have discrepan cies repaired as prescribed in P art 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Parametrix. The operator following the manufacturer’s product and operating manual will accomplish maintenance. An equivalent level of safety will be achieved becau se Parametrix’s 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 immediately land and will be operating from no higher than 200 feet AGL. As provided in the manufacturer’s manual, 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.United States Department of Transportation May ____, 2015 Page 8

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Summary :
Pursuant to 14 C.F.R. Part 11, the followin g summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules:

14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. 61.113( a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.409 (a) (2) ; and 14 C.F.R. 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 pounds or less).

Approval of exemptions allowing commercial operations of UASs will enhance safety by reducing risk. Conventional operations, using jet or piston

- power aircraft, o perate at low altitudes just feet from the subjects being photographed and in close proximity to people and structures and present the risks associated with vehicles that weigh in the neighborhood of 4,000 pounds and carrying l arge amounts of aviation fuel

. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates almost all of that risk given the reduced weight and lack of combustible fuel carried on bo ard. The UAS will carry no passengers or crew and, therefore, will not expose anyone to the risks associated with manned aircraft flights.

The operation of UASs, weighting less than 55 pounds , conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requeste d herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than co nventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Additional Information:

Privacy

All flights will occur over private or public controlled access property with the property owner’s prior
consent and knowledge. Photography will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. The grant of this exemption request will provide improved safety in both day and night operation s. Satisfaction of t he 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 ade quate justification for grant ing the requested exemptions allowing commercial operations.

Regards,

Steven K. Aisaka, PE, SE, JD Director of Risk Management Parametrix, Inc.ATTACHMENT A

– OPERATIONS MANUALS