December 6, 2015 FILED ELECTRONICALLY

U.S. Department of Transportation

Docket Management System

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington D.C., 20590

Reference: Amendment to Measure’s Exemption No. 12646 Regulatory Docket No. FAA–2015–

1602 Re: Conditions and Limitations #26 All Flight operations must be conducted at least 500 

feet from all nonparticipating persons, vessels, vehicles, and structures

Dear Sir or Madam,

Measure was issued exemption, No. 12646 (hereinafter referred to as the exemption) for 

operation in the national airspace. Measure, hereby requests an amendment to the exemption

to allow for a revision to Condition and Limitation #26 within the exemption which states,

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and 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.

Measure agrees with the FAA that safety is the most important consideration in regards to UAS 

(unmanned aircraft systems) operations and agrees that nonparticipating persons or property 

should be protected from any and all UAS activities. However, Measure is requesting the FAA 

consider our equivalent level of safety parameters for our exemption approved multi-rotor 

platforms in regard to the 500 feet radius from nonparticipating persons and/or property.

Measure pilots and analysts have conducted research and determined that based on 

calculations utilizing the multirotor UAS final velocity and altitude that a lower radius from 
nonparticipating persons and structures can be safely obtained. Measure will send all research 

documentation (graphs, charts, data, etc.) in a separate confidential document.

An example of our research utilized the flight characteristics of the Aerialtronics Altura Zenith

ATX8:

The ATX8 maximum speed is 6 m/s (18ft/s) groundspeed and and when a speed limitation is 

incorporated, it drastically reduces the maximum parabolic route to ground impact (note-multirotor UAS do not have a glide ratio like the fixed wing UAS). Considering the COA blanket 200 

feet AGL altitude, the safe radius distance for nonparticipants for the ATX8 would be 120 feet 

radius. If we operate at 50 feet AGL, the safe radius for nonparticipants is 64 feet.

Measure requests that the FAA allow for the utilization of the calculations (of all exemption 

approved multi-rotor UAS) to determine the safe operational radius for nonparticipants and to 

remove the 500 feet AGL condition and limitation within the exemption. Measure pilots will 

utilize the calculations to make their proper flight planning based on the UAS speed, flight 

altitude and calculated safe operational radius and provide the information in their NOTAM 

filings and monthly FAA reports. Measure has proven an equivalent level of safety utilizing this 

process and requests the FAA review and approve the documentation provided. 

Measure continues to provide safe, legal and insured UAS services to our clients and will 

continue to properly protect the areas we conduct flight operations to the highest standard for 

those involved and those nonparticipating persons and property.

Attached and submitted as confidential documents in a separate correspondence, are the 

graphs, calculations, and flight data to support the amendment.

Sincerely,

Kathleen Swain

VP

Measure

Mobile: + 1 713 893 8907

kswain@measure.aero

Twitter: @kat_swain

measure.aero