December 6, 2015 FILED ELECTRONICALLY

U.S. Department of Transportation Docket Management System We st Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Wa shington 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 , N o. 12646 (hereinafter referred to as t he exemption ) for operation in the national airspace. Measure , hereby request s an amendment to the exemption to allow fo r a revision to Conditi on 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 pr otect 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 wi thin 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 fromnonparticipating persons and structures can be safely obtained. Measure will send all research

docu mentation (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 pa rabolic route to ground impact (note

- multi

rotor 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 fo r nonp articipants 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 a nd 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 nonp articipating 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