# ~ WClClO -RClOGE:RS August 31, 2015

U.S. Department ofTransportation DocketManagement System 1200NewJerseyAve., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the FederalAviation Regulations

Dear Sir orMadam:

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (Reform Act) and 14 C.F.R. Part 11, Wood Rodgers, Inc. (Wood Rodgers), a multi-discipline, full service engineering firm, seeks an exemption from the Federal Aviation Regulations (FARs) listed below to allow commercial operation of its unmanned aircraft system (UAS), so long as such operations are conducted within and under the conditions outlinedherein or as may be established bythe FAA as required by Section 333. The requested exemption would permit the commercial operation of a Wood Rodgers' UAS under controlled conditions in the National Airspace System (NAS) to conduct aerial and video acquisition for reconnaissance and monitoring purposes and geospatial services. The use ofthe UAS for aerial reconnaissance and monitoring reduces the need to operate conventional aircraft or other equipment for the same purpose and provides high quality imagery for a fraction ofthe cost ofusing conventional methods.
The name and address ofthe applicant is: Wood Rodgers Attn: Jonathan Kors 3301 C Street Building 100-B Sacramento, CA 95816 Phone: 916-341-7760 Email: jkors@woodrodgers.com

Corporate Office: 3301 C Street, Bldg. 100-B
· Sacramento, CA 95816 · Tel: 916.341.7760
· Fax: 916.341.7767 Off1ces located 1n California and Nevada www.woodrodgers .comUS. Department of Transportation August31, 2015 Page2
Regulations from whichthe exemptionis requested:
14 CFRPart 21, Subpart H 14 CFR45.23 14 CFR45.29 14 CFR 61.113 (a) & (b) 14 CFR61.23 14 CFR61.3 14 CFR91.7 (a) 14 CFR91.9 (b) (2) 14 CFR91.103 14 CFR91.109 14 CFR91.119 14 CFR91.121 14 CFR91.151 (a) 14 CFR91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR91.407 (a) (1) 14 CFR91.409 (a) (2) 14 CFR 91.417 (a) & (b) 14 CFR 91.9


### U

AS Characteristics
Wood Rodgers seeks an exemption to operate the DJI Phantom 2 Vision+ UAS (Phantom 2 Vision+ UAS) for compensation or hire within the NAS. The Phantom 2 Vision+ UAS is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The Phantom 2 Vision+ UAS has a total weight of less than 5pounds withthe dimensions of 16 inches in length, 16 inches in width, and 8.5 inches inheight; and ithas a maximum speed ofapproximately 33 miles per hour with a cruising speed of22 miles per hour. The Phantom 2 Vision+ UAS has four rotary motors, each powered by a 6-cell 5200 mAh Lithium Polymer battery that is able to provide a flight time ofapproximately 20 minutes.
Public Benefit
There is a benefit for the public by using UAS to acquire aerial imagery and video, information and data instead of using conventional aircraft and manual methods. By using UAS, the statistical risk to human life due to manned aircraft accidents and other dangerous activities that canbe avoided, is reduced. The cost ofacquiring such information is also greatly reduced which benefits the consumer and the economy. The environmental impact is also reduced by eliminating sources of hydrocarbon emissions from manned aircraft. Noise pollution from manned aircraftis reduced as well by operating UAS.US. Department of Transportation August31, 2015 Page3
Safety Not Adversely Affected
Wood Rodgers will operate its UAS in the following manner when conducting commercial operations under an FAA-issued exemption.
1. The UAS will weighless than 30pounds. 2. The UAS will be controlled with a remote controller that has an operating frequency of 2.404GHz- 2.476 GHz. 3. The live video feed from the UAS will have an operating frequency of 5.728 GHz5.850GHz. 4. Flight operations will be conducted over private, controlled-access, or public property where approved. 5. Permission from the land owner/authority required shall be obtained before commencing any flight. 6. Flightoperations over congested areas shall be avoided. 7. Flight operations must not interfere with manned aircraft operations, must yield the right-of-way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times. 8. Flight operations will be limited to Visual Flight Rules Meteorological Conditions (VMC) anddaylighthours. 9. Flightoperations will comply withthe manufacturer's user manuals. 10. Maximum total flight time for each operational flight will be 20 minutes ornotto exceed 75 percent ofthe batterypowercapacity, whichever occurs first. 11. Flight altitudes will remain below400 feet above ground level. 12. Flightground speeds will not exceed 33 miles per hour. 13. Flight operations will not intrude into Class B, C or D airspace, or published approach, SID or STAR, ortakeplace within 5 miles ofan airport. 14. Flight operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority, or with air traffic control when a control toweris present at the airport. 15. Flight operations shall comply with required permissions and permits established by territorial, state, county or city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies. 16. Flight operations will be conducted within the line of sight of the operator and/or observer. 17. Minimum crewfor each flight operationwill consist ofthe operator and the observer. 18. The operator and the observer will be able to communicate with each other by voice and/orvisuals at all times. 19. The UAS will operate within a confinedproject area. 20. EachUAS flight operationwill be plannedpriorto any aerial activities. 21. Pre-flight inspections (including ground control station, if any) and safety risk assessments will be conductedpriorto eachflight. 22. If the UAS loses communications or loses its GPS signal, the UAS will have the capabilityto returnto apre-determined locationwithinthe project area and land.US. Departmentof Transportation August31, 2015 Page4 

### 23. The UAS will have the capability to abort a flight in case of unexpected obstacles, weather oremergencies. Specific Examples ofPotentialUAS Use by

### Wood Rodgers IfWood Rodgers' petition for exemption is granted, Wood Rodgers foresees the use ofUAS in the following examples:

• Evaluate Conditions of Levees 

### o Aerial imagery acquired by UAS can be used to evaluate conditions of levees from seepage and erosion, and to identify obstructions within the levee prism against the United States Army Corp of Engineers (USACE) regulations. This would save time and money compared to performing the same operations using conventional manned flights.

• Monitor Crops 

### o Aerial imagery acquired by UAS can be used to monitor crop conditions and the effects of drought impact on crop yield. This will help farmers address these situations and implement strategies to reduce orpreventthe impacts.

• DevelopBaseMapping 

### o Aerial imagery acquired by UAS can be used to quickly and inexpensively develop base maps for land development compared to conventional methods using manned flights.

• Enhance PublicAwareness 

### o Aerial imagery and video acquired by the UAS can be used to provide current project conditions and provide status updates of project progress in public meetings. This will help the client and the publicto betterunderstandthe project. Wood Rodgers is prepared to modify or amend any part ofthis requestto satisfy the need for an equivalent level ofsafety. Please contactus ifyou require additional information or clarification.
Sincerely,



# o~ Jonathan Kors, P.E. Vice President Wood Rodgers, Inc

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