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1 Pub. L. No. 112-95, § 333, 126 Stat. 76. 

2 In support of this petition, Ray Carlson and Associates, Inc. is prepared to submit UAS-specific user manuals if 

necessary. All UAS listed have received previous approval from the FAA: Trimble UX5/UX5 HP; Trimble ZX5; DJI Inspire I; 

DJI Phantom 3; Sensefly eBee/EBee RTK 

3 See FAA, Authorizations Granted Via Section 333 Exemptions (rev. May 12, 2015), 

https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/; see also, e.g., Exemption No. 11109 in 

Docket No. FAA-2014-0507 (Clayco, Inc.); Exemption No. 11286 in Docket No. FAA-2014-0960 (Balfour Beatty 

Construction Services US); and Exemption No. 11227 in Docket FAA-2014-0678 (EnviroMINE, Inc.). 

4 See id.

5 See, e.g., Exemption No. 11227 at 6. 

January 26, 2016

U.S. Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Ray Carlson and Associates, Inc., Petition for Exemption under Section 333 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”)1 and 14 C.F.R. Part 11, 

Ray Carlson and Associates, Inc. seeks an exemption from the Federal Aviation Regulations (“FARs”) listed 

below to permit commercial operation of small Unmanned Aircraft Systems (“UAS”) to perform various tasks 

including: 

 Aerial surveying and mapping; photogrammetry;

 Filmmaking, cinematography and videography; 

 Construction and utility inspection and monitoring. 

The five (5) UAS proposed for use by Ray Carlson and Associates, Inc. are the Trimble UX5; Trimble UX5 HP; 

Trimble ZX5; DJI Inspire I; DJI Phantom 3; and the Sensefly eBee RTK. Ray Carlson and Associates, Inc.’s UAS 

operations will be conducted under the safeguards described in this petition and as may be further 

established by FAA.2

The agency has already issued over 320 Section 333 exemptions to various commercial enterprises for UAS 

applications ranging from aerial photography and precision agriculture to construction and surface mining 

(the “Section 333 Grants”).3 Indeed, FAA has granted at least 34 exemptions to companies specifically for 

construction, mining and/or utility inspections, and many others for aerial surveying, filmmaking, 

cinematography and videography more generally.4 In issuing the Section 333 Grants, FAA found that “the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner 

. . . gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public 

interest.”5 The same public interest and safety justifications apply to Ray Carlson and Associates, Inc.’s

petition, and should enable FAA to grant Ray Carlson and Associates, Inc.’s petition on an expedited basis. 
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6 FMRA § 333(a). 

7 See 49 U.S.C. § 106(f) and 49 U.S.C. § 44701(f). 

As described more fully below, the requested exemption would permit Ray Carlson and Associates, Inc. to 

operate the specified UAS under controlled conditions in low-altitude airspace that is: (1) access limited; (2) 

predetermined; and (3) located a sufficient distance from congested areas and airports, and would provide 

safety enhancements to operations using conventional aircraft. Ray Carlson and Associates, Inc.’s UAS are 

small, weighing 55 lbs. or less fully loaded, and under normal conditions, they will operate at speeds of 50 

knots or less, and under no circumstances will they be operated at speeds exceeding 87 knots. 

I. Petitioner 

Ray Carlson and Associates, Inc. is a land surveying firm in Northern California that has been serving both the 

public and private sectors since 1976. Traditionally, where large parcels of land are commissioned for survey

and mapping, Ray Carlson and Associates, Inc. utilizes aerial photogrammetric methods which involve fixed 

wing or rotary manned aircraft, conducted at significant expense, to accomplish its goals. 

Ray Carlson and Associates, Inc. now seeks to expand on this success by utilizing UAS in our operations. This 

new capability will, among other things, allow Ray Carlson and Associates, Inc. to supplement or supplant 

human workers in performing these aerial surveys and also substitute UAS for aerial survey and photography 

services. The UAS we propose to fly in these applications weigh under 55 lbs., and carry no combustible 

material or people on board. This presents a significant increase in safety to flight crew, the national airspace 

system (“NAS”), and people on the ground over manned fixed and rotary winged aircraft. Performing these 

hazardous tasks with UAS will limit human involvement only to those situations where physical work is 

required. Ray Carlson and Associates, Inc. is committed to any measure that will put fewer lives in danger, 

and integrating UAS into Ray Carlson and Associates, Inc.’s operations will do just that.

All communications regarding Ray Carlson and Associates, Inc.’s petition should be directed to: 

Ray Carlson and Associates, Inc.

411 Russell Ave.

Santa Rosa, Ca 95403

Attn.: John Pawson, PLS

Direct Ph: 707-571-5525

Email: jpawson@rcmaps.com

II. Section 333 

Ray Carlson and Associates, Inc.’s petition is consistent with Congress’s goal set forth in Section 333 of the 

FMRA, which directs the Secretary of Transportation to consider whether certain UAS may operate safely in 

the NAS before completion of the rulemakings required under Section 332 of that legislation. In making this 

determination, the Secretary is required to determine which types of UAS do not create a hazard to users of 

the NAS or the public or pose a threat to national security in light of the following: (1) the UAS’s size, weight, 

speed, and operational capability; (2) operation of the UAS in close proximity to airports and populated areas; 

and (3) operation of the UAS within visual line of sight of the operator.6 To implement Section 333, FAA has 

the authority to issue exemptions from its safety regulations and minimum standards when the Administrator 

decides a requested exemption is in the public interest.7
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8 See, e.g., Exemption No. 11062 in Docket No. FAA-2014-0352 (Astraeus Aerial), at 8 (citing FMRA § 333(b)). 

9 See, e.g., Exemption No. 11227 in Docket No. FAA-2014-0678 (EnviroMINE, Inc.), at 4, 8; see also FAA, FAA Summary 

Grants Speed UAS Exemptions (Apr. 9, 2015), https://www.faa.gov/news/updates/?newsId=82485. 

10 See supra note 3. 

Ray Carlson and Associates, Inc.’s proposed UAS operations meet the requirements of, and qualify for 

expedited approval under, Section 333. Ray Carlson and Associates, Inc.’s UAS weigh 55 lbs. or less, will 

operate at less than 400 feet above ground level (AGL) within visual line of sight (VLOS) at speeds of no more 

than 50 knots. Operations conducted under these safeguards will provide at least an equivalent level of safety 

compared to the current regulatory structure. They will also provide an environmental impact benefit over 

manned aircraft because Ray Carlson and Associates, Inc.’s UAS will draw their power from rechargeable 

batteries, as opposed to the hundreds of pounds of fossil fuels burned in the operation of manned aircraft 

that are thousands of times heavier. 

Moreover, Ray Carlson and Associates, Inc.’s operations will not “create a hazard to users of the national 

airspace system or the public or pose a threat to national security” due to the small size of the UAS and the 

restricted areas in which they will operate.8 

III. Regulations from which an Exemption is Requested 

Ray Carlson and Associates, Inc. requests an exemption from the following regulations to the extent 

necessary to conduct the operations described in this petition: 

14 C.F.R. §§ 61.23(a) and (c) 

14 C.F.R. §§ 61.101(e)(4) and (5) 

14 C.F.R. § 61.113(a) 

14 C.F.R. § 61.315(a) 

14 C.F.R. § 91.7(a) 

14 C.F.R. § 91.119(c) 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151(a) 

14 C.F.R. § 91.405(a) 

14 C.F.R. § 91.407(a)(1) 

14 C.F.R. §§ 91.409(a)(1) and (2) 

14 C.F.R. § 91.417(a) and (b) 

The following subsections describe Ray Carlson and Associates, Inc.’s request for an exemption from each of 

these regulations and demonstrate how Ray Carlson and Associates, Inc.’s operations will provide for at least 

an equivalent level of safety compared to the current regulatory structure that applies to manned aircraft. 

A. 14 C.F.R. §§ 61.23(a) and (c) – Medical certificates: Requirement and duration 

Sections 61.23(a) and (c) generally require pilots of manned aircraft to hold a FAA medical certificate in order

to exercise pilot privileges. As of March 24, 2015, however, FAA determined as matter of policy that 

operators holding a valid driver’s license in lieu of a third class medical certificate may conduct commercial 

UAS operations under a Section 333 grant.9 Accordingly, Ray Carlson and Associates, Inc. requests an 

exemption from these provisions to the extent necessary to give Ray Carlson and Associates, Inc. the same 

relief from medical certificate requirements that FAA has afforded to over 320 other Section 333 operators 

via the Section 333 Grants.10 
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11 See supra note 3. 

12 See, e.g., Exemption No. 11422 in Docket No. FAA-2015-0154 (Soar Environmental Consulting, Inc.), at 4. 

13 See supra note 3. 

14 FAA has concluded that no exemption from Part 21, Subpart H (Airworthiness Certificates) is needed if the agency 

makes a finding under the FMRA that the UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met here, and therefore no exemption is needed. See, e.g.,

Exemption No. 11062, Docket No. FAA-2014-0352 at 13-14, 22. But to the extent FAA determines that there are some 

characteristics of Ray Carlson and Associates’ UAS that fail to meet the “equivalent level of safety” requirement of the 

FMRA, an exemption is requested. 

15 See, e.g., id. 

B. 14 C.F.R. §§ 61.101(e)(4) and (5) – Recreational pilot privileges and limitations 

Sections 61.101(e)(4) and (5) prohibit a recreational pilot from acting as pilot in command of an aircraft for 

compensation or hire or in furtherance of a business. Since Ray Carlson and Associates, Inc. will be conducting 

its UAS operations in furtherance of its aerial survey, topography and other services, it requests an exemption 

from these provisions to the extent necessary. Ray Carlson and Associates, Inc. notes that FAA has provided 

such relief to over 320 other Section 333 operators.11 

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

Section 61.113(a) limits private pilots to conducting non-commercial operations. FAA has already determined, 

however, that a private pilot certificate is sufficient to conduct commercial UAS flights; in fact, the agency has 

revised its Section 333 approval framework to allow UAS operations to be conducted by a pilot with only a 

recreational or sport pilot certificate.12 

Consistent with the operating conditions and limitations specified in the Section 333 Grants, Ray Carlson and 

Associates, Inc. will utilize only pilots holding a FAA airline transport, commercial, private, recreational, or 

sport pilot certificate and at least a valid U.S. driver’s license. The UAS will be operated within VLOS of the PIC 

at all times, and because the area of operation will be controlled and restricted in accordance with the 

safeguards contained in the Manual and the FAA-approved conditions and limitations described in Section VI, 

infra, permitting the UAS operations as requested would provide for the level of safety otherwise achieved 

through Section 61.113(a). Accordingly, grant of the requested exemption, subject to the conditions and 

limitations specified herein, would not adversely affect the safety of the NAS. 

D. 14 C.F.R. § 61.315(a) – Sport pilot certificate privileges and limits 

Section 61.315(a) authorizes a sport pilot certificate holder to act as pilot in command of a light-sport aircraft, 

subject to certain restrictions specified in Section 61.315(c), including a prohibition on doing so for 

compensation or hire or in furtherance of a business, among other restrictions. Since Ray Carlson and 

Associates, Inc. will be conducting its UAS operations in furtherance of its business purposes, it requests an 

exemption from this provision to the extent necessary. Ray Carlson and Associates, Inc. notes that FAA has 

provide the same relief to over 320 other Section 333 operators. 13

E. 14 C.F.R. § 91.7(a) – Civil aircraft airworthiness 

Section 91.7(a) prohibits any person from operating a civil aircraft unless it is in an airworthy condition. FAA 

has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the airworthiness certificate 

requirements of Part 2114 are waived or inapplicable. Such airworthiness certificate requirements are 

inapplicable here, insofar as Ray Carlson and Associates, Inc.’s UAS provides an equivalent level of safety 

when compared to manned aircraft, consistent with the relevant language of the FMRA and the precedent 

established by the Section 333 Grants.15 
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16 FAA determined in the Section 333 Grants that relief from other provisions of Section 91.119 are either unwarranted 

or inapplicable. See Exemption No. 11062 at 20. 

17 See, e.g., supra note 3. 

18 See id. 

19 See supra note 3.

20 See id. 

F. 14 C.F.R. § 91.119 – Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft.16 Specifically, Section 91.119(c) 

provides that except when necessary for takeoff or landing, no person may operate an aircraft below an 

altitude of 500 feet above the surface except over open water or sparsely populated areas and that in such 

cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. As 

detailed in the Section 333 Grants, however, FAA has determined that adherence to certain safety measures 

is sufficient to warrant an exemption for UAS operations.17 Consistent with the relief provided to other UAS 

operators via the Section 333 Grants, Ray Carlson and Associates, Inc. requests an exemption to the extent 

necessary to operate below an altitude of 500 feet AGL and closer than 500 feet to any person, vessel or 

structure. An equivalent level of safety will be achieved given the size, weight and speed of Ray Carlson and 

Associates, Inc.’s UAS, as well as the locations where it will be operated. 

G. 14 C.F.R. § 91.121 – Altimeter Settings 

Although Section 91.121 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” and Ray Carlson and Associates, Inc.’s UAS will not be equipped with a typical 

barometric altimeter, FAA has already granted relief from this provision to other UAS operators flying at 

similarly low altitudes.18 Ray Carlson and Associates, Inc. will operate the UAS within VLOS at or below 400 

feet AGL and provide altitude information to the PIC via a digitally encoded telemetric data feed that 

downlinks from the aircraft to a ground-based on-screen display. The altitude information will be generated 

by equipment installed on the UAS, and prior to each flight a zero altitude initiation point will be established 

and confirmed for accuracy by the PIC. 

H. 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 point of intended 

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.” But provided certain operational parameters are 

established, FAA has found that good cause exists for granting exemptions from this provision for operations 

in a multitude of contexts.19 

Ray Carlson and Associates, Inc. will be operating a less than 55 pound UAS in tightly controlled environments 

at speeds below 50 knots and within VLOS. Combined with the fact that Ray Carlson and Associates, Inc. will 

not conduct operations unless the UAS has enough available power to complete the intended mission and 

return, relief from Section 91.151(a) is warranted, in accordance with the conditions and limitations specified 

in Section VI, infra.

I. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and (b): Maintenance Inspections 

These FAR provisions require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph 

(c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . .,” and that other 

persons shall inspect or maintain the aircraft in compliance with Part 43. Through the Section 333 Grants, 

however, FAA has established safety measures for certain UAS operations sufficient to warrant an exemption 

from these provisions.20 .
Page 6

Ray Carlson and Associates, Inc. will strictly adhere to the maintenance and inspection requirements 

developed under its UAS program, which is consistent with applicable conditions and limitations described in 

Section VI, infra. These requirements include the development and documentation of maintenance, 

overhaul, replacement and inspection requirements; procedures to document and maintain maintenance 

records with regard to Ray Carlson and Associates, Inc.’s UAS; and UAS technician qualification criteria. 

IV. Characteristics of Ray Carlson and Associates, Inc.’s UAS 

All of the UAS which Ray Carlson and Associates, Inc. will operate under this proposed exemption are small, 

weighing less than 55 lbs. maximum gross weight, and they will operate at 50 knots or less. They all feature 

automatic return to home or flight termination procedures in the event of a loss of controller signal or 

diminished battery output or capacity. 

V. Unmanned Aircraft PIC 

As described above, the PIC will be a FAA licensed airman with either an airline transport, commercial, 

private, recreational, or sport pilot certificate that holds a current FAA airman medical certificate or a valid 

U.S. driver’s license. The PIC will also meet the flight review requirements specified in Section 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

VI. Operation of the Unmanned Aircraft 

Ray Carlson and Associates, Inc. will conduct all flights under the requested exemption subject to the 

following conditions and limitations, and as further detailed in Users Manuals for the specified UAS: 

A. The UAS will weigh less than 55 pounds, including payload. 

B. The UAS will not be flown at a ground speed exceeding 50 knots. 

C. Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by the procedures 

specified in the Manual. All altitudes reported to ATC will be in feet AGL. 

D. The UAS will be operated within VLOS of the PIC and/or VO at all times. 

E. When operations utilize a VO, the PIC will always maintain VLOS capability and the VO and PIC will be able 

to communicate verbally at all times. 

F. Prior to each operation, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, it will not be operated until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The GCS 

will also be included in the preflight inspection. All maintenance and alterations will be documented in the 

UAS records.

G. Ray Carlson and Associates, Inc. will follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

H. The PIC will possess a current FAA airman medical certificate or a valid U.S. driver’s license. The PIC will be 

trained in accordance with the Manual, and will undergo training to ensure that he or she can follow these 

procedures.

I. Prior to conducting commercial operations under this exemption the PIC will assess the intended operating 

area, including weather and any potential obstacles, and determine procedures in case of emergency. 
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21 Pursuant to its new “blanket” COA, FAA will automatically grant a COA for flights at or below 200 feet to any UAS 

operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during daytime VFR 

conditions, operate within VLOS, and stay certain prescribed distances away from airports or heliports. See FAA, FAA 

Streamlines UAS COAs for Section 333 (rev. Mar. 24, 2015), https://www.faa.gov/news/updates/?newsId=82245. This 

blanket COA allows flights anywhere in the country except restricted airspace and certain other prohibited areas, and

FAA automatically issues it at the time the exemption is approved. Id. To the extent Ray Carlson and Associates will be 

operating above 200 ft. AGL at any of its UAS sites, it will apply for a COA authorizing it to do so. 

J. The UAS will not be operated within 500 feet of any nonparticipating persons, vessels, vehicles, or 

structures unless the PIC has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. 

K. If the UAS loses communications or loses its GPS signal, the PIC will institute procedures to safely land the 

UAS according to Users Manuals for the specified UAS. 

L. The UAS will not be operated unless it has enough available power to conduct the intended operation and 

return, or with the reserve power recommended by the manufacturer, whichever is greater. 

M. Ray Carlson and Associates, Inc. will obtain a Certificate of Waiver or Authorization (COA) prior to 

conducting any operations above 200 feet AGL under the exemption.21 

N. All UAS operated in accordance with this exemption will be identified by serial number, registered in 

accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. 

Part 45, Subpart C. Markings will be as large as practicable. 

O. Ray Carlson and Associates, Inc. will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and 

the total time in service of the UAS.

P. Each UAS operated under this exemption will comply with all manufacturer Safety Bulletins. 

Q. The PIC shall conduct a preflight inspection prior to each flight and will document discrepancies (i.e., 

inoperable components, items, or equipment). 

R. Ray Carlson and Associates, Inc.’s use of radio frequency spectrum for operation and control of the UAS 

will comply with the Federal Communications Commission (FCC) or other appropriate agency requirements. 

S. The documents required under Sections 91.9 and 91.203 will be available to the PIC at the GCS of the UAS 

any time the aircraft is operating. These documents will be made available to FAA or any law enforcement 

official upon request. 

T. The UAS will remain clear and yield the right of way to all manned operations and activities at all times.

U. UAS operations will not be conducted at night, as defined in Section 1.1. All operations will be conducted 

under visual meteorological conditions (VMC). 

V. The UAS will not be operated from any moving device or vehicle. 

W. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than three statute miles from the PIC. 
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22 See Exemption No. 11062 at 22. 

X. The UAS will not operate within five nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport 

symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that 

airport’s management is obtained or otherwise permitted by a COA issued to Ray Carlson and Associates, Inc..

The letter of agreement with the airport management will be made available to FAA and any law 

enforcement official upon request. 

Y. Any accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area 

defined by the applicable COA will be reported to FAA’s UAS Integration Office (AFS-80) within 24 hours and 

the National Transportation Safety Board (NTSB), as applicable. 

VII. Public Interest 

Authorizing Ray Carlson and Associates, Inc. to conduct commercial operations using UAS under the 

conditions specified herein would bring immediate and significant safety improvement to the aerial mapping, 

construction inspection, energy and other industries. Ray Carlson and Associates, Inc.’s UAS would be used to 

perform aerial mapping, construction inspections and conduct other key functions in a manner that provides 

at least an equivalent level of safety compared to the current regulatory structure that applies to manned 

aircraft.22 

Aerial mapping and construction inspections require human beings to visually observe and analyze the 

physical status of various equipment and surrounding conditions. By replacing these perilous tasks with UAS 

flights, Ray Carlson and Associates, Inc. can map areas and conduct inspections without subjecting a human 

to the attendant risks. 

VIII. Conclusion 

Given the small size of Ray Carlson and Associates, Inc.’s UAS and the restricted environments where they will 

operate, Ray Carlson and Associates, Inc. falls squarely within the type of operations that Congress intended 

be authorized pursuant to Section 333. Ray Carlson and Associates, Inc.’s proposed UAS operations are similar 

in all material respects to the operations authorized under the Section 333 Grants, including several covering 

nearly identical types of operations – and should be approved on an expedited basis. Based on the clear 

direction from Congress, the authority contained in the FMRA; the well-established equivalent level of safety 

present in Ray Carlson and Associates, Inc.’s proposed operations; the significant public benefits associated 

with using UAS to perform the proposed operations; and FAA’s recent determinations in the Section 333 

Grants, grant of Ray Carlson and Associates, Inc.’s petition is in the public interest. Accordingly, Ray Carlson 

and Associates, Inc. respectfully requests that FAA grant it an exemption without delay. 

Respectfully, 

John Pawson, PLS

Ray Carlson and Associates, Inc.

411 Russell Ave.

Santa Rosa, Ca 95403

Direct Ph: 707-571-5525 

Email: jpawson@rcmaps.com

Enclosures