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August 31, 20 15 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Federal Aviation Regulations 

Dear Sir or Madam: 

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 outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit the commercial operation of a Wood Rodgers' U AS 

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 of the 

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 of the 

cost of using conventional methods. 

The name and address of the 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.com 
US. Department of Transportation 

August 31, 2015 

Page2 

Regulations from which the exemption is requested: 

14 CFR Part 21, Subpart H 

14 CFR 45.23 

14 CFR 45.29 

14 CFR 61.113 (a) & (b) 

14 CFR 61.23 

14 CFR 61.3 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (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 5 pounds with the dimensions of 16 inches in length, 16 inches in width, and 8.5 inches 

in height; and it has a maximum speed of approximately 33 miles per hour with a cruising speed 

of 22 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 of approximately 

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 

can be avoided, is reduced. The cost of acquiring 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 aircraft is reduced as well by operating U AS. 
US. Department of Transportation 

August 31, 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 weigh less than 30 pounds. 

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. Flight operations 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 & A void other aircraft and 

obstacles at all times. 

8. Flight operations will be limited to Visual Flight Rules Meteorological Conditions 

(VMC) and daylight hours. 

9. Flight operations will comply with the manufacturer's user manuals. 

10. Maximum total flight time for each operational flight will be 20 minutes or not to exceed 

75 percent of the battery power capacity, whichever occurs first. 

11. Flight altitudes will remain below 400 feet above ground level. 

12. Flight ground 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, or take place within 5 miles of an 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 

tower is 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 crew for each flight operation will consist of the operator and the observer. 

18. The operator and the observer will be able to communicate with each other by voice 

and/or visuals at all times. 

19. The UAS will operate within a confined project area. 

20. Each UAS flight operation will be planned prior to any aerial activities. 

21. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight. 

22. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the project area and land. 
US. Department of Transportation 

August 31, 2015 

Page4 

23. The UAS will have the capability to abort a flight in case of unexpected obstacles, 

weather or emergencies. 

Specific Examples of Potential UAS Use by Wood Rodgers 

If Wood Rodgers' petition for exemption is granted, Wood Rodgers foresees the use of UAS 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 U AS 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 or prevent the impacts. 

• Develop Base Mapping 

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 Public Awareness 

o Aerial imagery and video acquired by the U AS 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 public to better understand the project. 

Wood Rodgers is prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us if you require additional information or clarification. 

Sincerely, 

Jonathan 

o~ Kors, P .E. 

Vice President 

Wood Rodgers, Inc.