U.S Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20S90 

Great Lakes Geomatics, LLC 

Martin Dunn, P.S., Managing Member 

12504 Stephens Rd. 

Warren, Ml 48089 

586.755.5770 

PROFESSIONAL SURVEYORS • 3D LASER SCANNING 

Re: Petition for Exemption under Section 333 of the FAA Modernization and Reform Act and 

Part 11 of the Federal Aviation Regulations. Great Lakes Geomatics (GLG) petitions for Grant of 

Exemption for the following Sections per the above referenced Act. 

• 14 C.F.R Part 21 

• 14 C.F.R 45.23 

0 14 C.F.R 45.29 

0 14 c.F.R 61.23 

• 14 C.F.R 61.3 

• 14 c.F.R 61.113 (a) & (b) 

0 14 C.F.R 61.133 (a) 

• 14 c.F.R 91.7(a) 

• 14 C.F.R 91.9 

• 14 C.F.R 91.109(a) 

• 14 C.F.R 91.119 

• 14 CFR 91.121 

• 14 c.F.R 91.151(a) 

• 14 C.F.R 91.203 (a) & (b) 

• 14 c.F.R Subpart E (91.405-91.417) 

Great Lakes Geomatics is a company with over 28 years of experience in land surveying and 13 

years specializing in 3D laser scanning. Due to our background in mapping and 3D modeling we 

would use our UAS for aerial videography and cinematography to complement our construction 

staking and as-builts, aid in mapping, access areas that are unsafe for field personnel, real 

estate, and site documentation. We will be using a DJI Phantom II with a Go Pro camera 

mounted to the bottom of the UAS. The DJI Phantom II is a quad-copter weighing 

approximately three pounds (3 lbs.). It is equipped with four rotors and is battery operated. THE 

DJI Phantom II is equipped with internal GPS that allows the UAS to hover and return home if 

radio contact is lost or power is low. We have flown multiple practice flights as hobbyists in 

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remote areas to get a general understanding of the operation of UAS and its abilities in 

different weather conditions. 

Safety is the main reason why we have opted to use this particular UAS as it is a safer 

alternative than operating a larger fuel powered aircraft that would require on-board 

operators. We believe that having a state issued driver's license would be sufficient to operate 

our UAS along with a training course from a certified UAS operator. All of our pilots in charge 

(PIC} will have taken these courses along with a valid license. The course covers weather 

requirements, ground training, emergency procedures, flight operations and limitations. The 

training will also cover flight logs and flight documentation. In addition to the training, all of our 

PICs will have a minimum of 30 hours flight time operating our particular multi-rotor UAS. If 

UAS usage low, we will make sure our PICs have at least three 'take-offs' and 'landings' per 

month. Our UAS will undergo safety inspection prior to any flight and will regularly go in for 

maintenance to a certified supplier. All flights will require an additional person on the ground 

observing the UAS and operator to ensure safety requirements and flight limitations are not 

exceeded. We will not fly our UAS over 400 feet, within a 1000 feet of the PIC, or within 5 miles 

of an airport unless we are in direct radio contact with the control tower. We will land the UAS 

prior to battery level reaching its mandatory self-landing time. We will post all flights on 

Notams and will contact all local residence about our flight path. When flying, we will post 

sign age (AERIAL PHOTOGRAPHY IN PROGRESS) to let the general public know there is a UAS in 

the area. Prior to flight operation, we will run through a systems check and safety protocol to 

ensure that all components are working correctly. Our flights typically last a maximum of 

twenty minutes and include short flight paths. 

The interest in small UAS that capture photogrammetry and cinematography has increased 

recently due to lower cost than that of a typical photogrammetric fixed wing aircraft or 

helicopter. We feel that by using our UAS for business purposes we can add great benefit to our 

clients and the general public at a much lower cost. Another benefit is the safety and lesser 

ecological impact than that of your typical petroleum powered aircraft. We believe that with 

these exemptions granted, we can provide an added value to our customers. Please see the 

attached annex with the specific exemptions we are applying for and the reasons we feel they 

should be granted. 

Sincerely, 

~~ Martin C. Dunn PS 

Principal 

Great Lakes Geomatics, LLC 

12504 Stephens 

Warren, Ml48089 

586.755.5770 

mcdu nn @greatla kesgeomatics.com 

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PROFESSIONAL SURVEYORS • 3D LASER SCANNING 

Annex 

EXEMPTION REQUEST AND EQUIVAlENT lEVEl OF SAFETY SHOWINGS UNDER APPliCABlE 

RUlES SUBJECT TO EXEMPTION 

GlG requests an exemption from the following regulations as well as any additional regulations 

That may technically apply to the operation of the DJI Phantom II UAS: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 91.203 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart 

H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR§ 91.203(a). 

Given the size of the UA V, their very light weight and the limited operating area associated with 

its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 

21 Subpart H in order to achieve or exceed current safety levels. 

Such an exemption 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 both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

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

populated areas of the UAS involved. An analysis of these different criteria demonstrates that 

the UAS operated without an airworthiness certificate, under the conditions proposed in that 

exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness 

certificate. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAl" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. 

Given the size of the UAS, this requirement is impossible to match. 

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14. CFR §61.23: Medical certificates: Requirement and duration 

Regulations provide that a person: 

(1) Must hold a first-class medical certificate: 

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

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

flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or 

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

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

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

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

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

• Privileges of a commercial pilot certificate 

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

integrated in the autopilot (among others a flight termination system), GLG believes that an 

Equivalent Level of Safety can be reached if the operator has a valid driver's license. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 

61.113(a} & (b); 61.133(a}: Private Pilot Privileges and limitations; Pilot in Command; 

Commercial Pilot Privileges and limitations 

The regulation provides that no person may serve as a required pilot flight crew member of a 

civil aircraft ofthe United States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that 

person's physical possession or readily accessible in the aircraft when exercising the privileges 

of that pilot certificate or authorization. However, when the aircraft is operated within a foreign 

country, a pilot license issued by that country may be used. The regulation provides also 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) The flight is only incidental to that business or employment; 

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

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Given the safety features of the UAS and the fact that the missions are pre-programmed and 

monitored in real-time with a specific flight management software, GLG proposes that 

operators of the UAS should not be required to hold a commercial or private pilot certification. 

Instead, operators should be required to: 

• Have completed the UAS manufacturers training program for operation of the UAS. The 

manufacturer's training program for OJ/ Phantom II operators has been already satisfactorily 

reviewed through the Application for Airworthiness Qualification Level (AQL} 3 Airworthiness 

Release (AWR). The equivalent level of safety will be achieved by having an operator trained 

UAVs manufacturer, and using the integrated features of the aircraft to maintain a high level of 

safety during the different missions. 

14 C.F.R. §91. 7(a): Civil aircraft airworthiness 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1 ). 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FM to exempt aircraft 

from the requirement for an airworthiness certificate, upon consideration of the size, weight, 

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

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

14 C.F.R. §91.9: Civil aircraft flight manual, marking, and placard requirements 

The equivalent level of safety will be achieved by keeping a hard copy of the user manual in 

close proximity to the operator. The equivalent level of safety will be provided by having the UAS 

marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the UAV will see the identification of the UAS as "Experimental." The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 

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PROFESSIONAL SURVEYORS • 3D LASER SCANNING 

14 C.F.R. §91.109(a): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

The equivalent level of safety during the in-flight training will be achieved by the manufacturer 

or affiliate providing the training as described in the manufacturer's training program and 

through the use of experienced and qualified instructors familiar with the UAS. 

14 CFR §91.119: Minimum Safe Altitudes Section 

91.119 establishes safe altitudes for operation of civil aircraft. The exemption requests 

authority to operate at altitudes up to 400 AGL, It will however be operated in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations without 

their pre-obtained consent. 

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

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

owner or local officials. Compared to flight operations with aircraft weighing far more than 

those proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft. 

14 CFR 91.121: Altimeter settings 

This regulation 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." 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption is requested. An equivalent level of safety will be achieved by the operator 

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 

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. 

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As the UAS are electric-powered, this requirement is inapplicable. In any event, given the 

contemplated operations, GLG believes that an equivalent level of safety is already achieved 

with the specific procedure preventing the UAS accepting a take-off order is the battery level is 

below a given value. Moreover, the manufacturers have integrated low and critical battery level 

warnings and implemented a "return to home" action in these situations. 

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

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current airworthiness 

certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

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

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

applicable to such UAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 CFR Subpart E (91.401- 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 Parts 39 and 43. Paragraphs 91 A07 and 

91.409 require the aircraft to be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the 

issuance of an airworthiness certificate. Section 91 A17 requires the owner or operator to keep 

records showing certain maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to 

service. 

GLG proposes that the maintenance of the UAS will be accomplished by the owner or the 

operator according to the manufacturer's user manual. Given that these section and Part 43 

apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

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PROFESSIONAL SURVEYORS • 3D LASER SCANNING 

operating handbook as referenced herein. An equivalent level of safety will be achieved because 

these small UAS are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure 

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

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

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

equivalent level of safety. 

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