Original 07 / 16 /2015 Page 1

July 16 , 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113,

14 CFR 91. 7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E ( 91.40 5, 91.407, 91.409, 91.417)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, Galaxy Aviation Inc. files this petition on behalf of its

client, PondMedics Incorporated (Pond M edics) to operate Unmanned Aircraft

System s (UAS) for commercial purposes.

The requested exemption would support an application for a commercial Certifica te of

Authorization (COA) to u tilize the Unmanned Aircrafts ( UA ) to offer Aerial Data

Collection and Surveying services for all appropriate commercial industries

. A few examples of such industries include, but not limited to, are lake and pond aerial

imaging, mapping, 3D modeling, Oil & Gas industry, str ucture inspections, agriculture,

real estate properties, construction site surveys, and other potential industries that need

aerial data collection.

PondM edics is a company based in the state of Texas, which provides engineering,

management and consulting services to private and public lake owners and managers.

By appro ving the exemption request, Pond Medics’ proposed UAS operations will

create benefits to both the economy and the environment which are ultimately in the

public interest.

The Unmanned Aircrafts consist lightweight battery operated 3D Robotics

Iris+ q uadcopter (Iris+)

, Event 38 E384 (E384) fixed wing u nmanned aircraft,

onboard sensors

, and assoc iated communications equipment.

The unmanned aircrafts carry onboard camera systems that allow them to perform

aerial data collection, and surveying.

The afore mentioned U A have previously demonstrated to me e t the safety standards

and operational requirements resulting in recent grants of s ection 333 exemption

requests by other commercial UAS operators.Original 07 / 16 /2015 Page 2

The aircraft will be operated by FAA licensed Pilot in Command

, and if required, a

Visual Observer in accordance with the limitations set forth in the grant and the

following applicable restrictions:

- All operations will occur a t no more than 400' above ground level ( AGL )

- The aircraft s will be operated with the permission of the property owner

- When necessary, applicable permits will be acquired from local authorities

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sigh t of the PIC at all time

- While the aircraft is airborne, the VO will be able to communicate verbally with the PIC

- When necessary and applicable, PondMedics will file a NOTAM providing radial/DME,

radius, and a date/time group for each operation

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time

- F or certain complex operations, Pond Medics may assign sensor or software

operators to assist the operations

We submit that the combinat ion of ;

- U ASs ’ size, lig ht weight and historically demonstrated safe operation s and receiving

recent approval s of multiple section 333 petitions

- Fully qualified flight crew

- Restricted operation s under the guidelines established within the grant

,

t he FAA can have confidence that PondMedics ’ UAS operation s will have an

equivalent or greater level of safety as manned aircraft performing the same mission s

.

We are prepared to modify or amend any part of this request to satisfy the need for an

equivalent level of safety. Additional documents supporting this petition will be

submitted following this request.

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Bryan Archer

Agent for Pond M edics Incorporated

Accountable Manager

Galaxy Aviation Inc. (Part 145 Repair Station # 5GXR127C )

6215 Kirby Lane

Frisco, TX 75035

Tel : (469) 766

- 0420

Fax : (866) 694

- 1989

Email: bryan.a rcher@GalaxyMRO.com

c c: Trent Lewis

PondMedics Incorporated

trent@pondmedics.comOriginal 07 / 16 /2015 Page 3 

## TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .......................Page 4

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PONDMEDICS

SEEKS EXEMPTION.

.............................................................................. ....................Page 4

THE EXTENT OF RELIEF PONDMEDICS SEEKS AND THE REASON S

POND MEDICS SEEKS THE RELIEF

.......................................... ................ ....... Pages 4 to 6

THE REASONS WHY GRANTING PONDMEDICS ’ REQUEST WOULD

BE IN THE PUBLIC INTEREST ........................................

.......... ........................... . Page 7

THE REASONS WHY GRANTING PONDMEDICS THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY .......................................

.............................. ... Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........

. .... Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT POND MEDICS ’ R EQUEST...

.............. .......... ...... Page 10

ACR ONYMS...............................................................

......... Page s 11 & 12Original 07 / 16 /2015 Page 4

NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

Trent Le wis, FPC

Senior Consultant

PondMedics Incorporated

1251 Legacy Drive

Prosper, Texas 75078

Tel : 972.905.4761

trent @pondmedics.com

cc: bryan.archer@g alaxy mro .com

THE SPECIFIC SECTIONS OF 1 4 CFR TO BE RELIEVED FROM

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF PONDMEDICS SEEKS AND THE REASONS POND

MEDICS SEEKS THE RELIEF

14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private

pilot to act as pilot in command of an aircraft in connection with any business or

employment if;

(1) flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire

.

Since the aircraft cannot carry passengers or property, we request to be relieved from

this regulation if our pilots

, at minimum,

(1) Hold at least a current sport pilot certificate and,

(2) Hold a driver license or a third class medical certificate.

By mee ting conditions (1) and (2), we believe that equivalent level of safety can be

achieved by complying with 61.113 Subparagraph (b) even though the intent of this

application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 9 1.7 (a) states

,

“ No person may operate a civil aircraft unless it is in an airworthy condition

. ”

T his rule prohibits the operation of an aircraft without an airworthiness certificate.

Since there is no such existing certificate that is applicable for the Unmanned Aircrafts

UAS to properly comply with the FARs, we request that Pond Medics to be relievedOriginal 07 / 16 /2015 Page 5

from this regulation.

To provide equivalent level of safety, we will ensure that the Unmanned Aircrafts

UAS is in airworthy condition prior to every flight by following necessary safety

procedures.

14 CFR 91.119 Minimum safe altitudes: Genera l

This regulation provides that over sparsely populated areas the aircraft cannot be

oper ated closer than 500 feet to any person, vessel, vehicle, or structure. Since the

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this

requirement.

To provide an equivalent level of safety we will only fly over private property with the

permission of the land owner. The land owner will be briefed of the expected route of

flight and the associated risks to persons and property on the ground. We maintai n that

due to the small size of the Unmanned Aircrafts , the hazard to persons, vessels,

vehicles, and structures is not comparable to manned aircraft and should be

considered in granting the exemption.

14 CFR 9 1. 121 Altimeter Settings

Th is regulation provides that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 nautical miles of the aircraft.

The Unmanned Aircrafts aircraft will fly below 400 feet AGL and will not need to

maintain hemisp herical cruising altitudes in order to de

- conflict with other aircraft.

To provide an equivalent level of safety, the PIC will check and confirm the Unmanned

Aircrafts’ GPS altitude read out before each flight.

14 CFR 91.1 51 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

VFR conditions unless there is enough fuel to fly to the first point of intended landing

and to fly after that for at least 30 minutes. We belie ve the intention of this rule is to

provide a reserve of energy as a safety buffer for go

- arounds and other delays to

landing.

The Unmanned Aircrafts UAS is battery operated and the maximum duration of flight

with full payload, from a single battery charge is a pproximately 9 0 minutes for E384,

and 25 minutes for Iris+.

We believe that equivalent level of safety can be achieved by limiting our flight time to

appropriate percentage of battery charge with 10 % reserve energy on the battery.Original 07 / 16 /2015 Page 6

14 CFR 91 Subpart E ( 91. 405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be " approved for return to service by a

person authorized under 43.7 " after maintenance and inspection. It is our intention

that the PIC, VO or authorized personnel to perform maintenance and inspection of the

aircraft and "be authorized to approve the aircraft for return to service."

Pond Medics requests that exemptions to the regulations under conditions below;

(1) PondMedics will follow Unmanned Aircrafts’ manufacturer maintenance instructions

, techniques and procedures.

(2) PondMedics will design ate, train, and document the personnel who will be

authorized to perform Inspecti on, Maintenance and Alterations.

Such de signated personnel may include PIC, VO or other equivalent trained persons

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight

looking for any structural or mechanical malfunctions

.

Due to the small size, light weight and simplicity of the Unmanned Aircrafts UAS, we

believe that the equivalent safety will be achieved by permitting any of the PI C , VO or equivalent trained personnel, to perform maintenance

, inspection and alterations of the

aircraft and " be authorized to approve the aircraft for return to service. "Original 07 / 16 /2015 Page 7

THE REASONS WHY GRANTING PONDMEDICS ’ REQUEST WOULD BE IN THE

PUBLIC INTEREST

We believe that granting our exemption request from,

14 CFR 61.113 , 61.133

14 CFR 91.9, 91.119

, 91.121

, 91.151

14 CFR 91 Subpart E ( 91 .405, 91.407, 91.409, 91.417) , is in the public’s interest and

will benefit the public as a whole for the following reasons.

1

- Unmanned Aircrafts is battery operated and free from the harmful emissions

associated with the manned aircraft that are currently used for aerial data

collection.

As recently proven by several grants of s ection 333 petitions, UASs offer

equivalent level of safety while reducing environmental impacts, which is in the

public interest.

2

- PondMedics ’ UAS operation s will contribute to a po sitive aggregate e conomic

i mpact resulting in creation of jobs both direct and indirectly. Economic

Research estimates that the UAS market will grow from $ 6 billion to $ 94 billion

over the next decade resulting in a new workforce development

. Because PondMedics ’ operations will create new jobs such as pilots, fli ght

operation staff, and administrative supporting staff, it will directly cause positive

economic impact , hence granting Pond Medics ’ petition will benefit the public as

a whole.

3

- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS (s) into the national airspace system, hence the passing

of the FAA Modernization and Reform Act of 2012.

Granting PondMedics ’ petition furthers the public ’s interest as a demonstr ated

progression of integrating Unmanned Aircraft Systems into National Air Space

, thus it will benefit public as a whole

.Original 07 / 16 /2015 Page 8

THE REASONS WHY GRANTING PONDMEDICS THE EXEMPTION WOULD

NOT ADVERSELY AFFECT SAFETY

Pond Medics believes that the grant of exemption from,

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of the reasons listed below.

(a) We have stated in the a bove section “ THE EXTENT OF RELIEF

POND MEDICS SEEKS AND THE REASONS POND MEDICS SEEKS THE

RELIEF ” by describing how we intend to mitigate risk and accomplish FAA

equivalent and acceptable level of safety for each 14 CFR sub part s

.

(b) As a result of unmanned aircraft s ’ size, weight, speed, operational capability,

proximity to airports and populated areas, operation within visual line of sight

combined with the implement ing FAA required safety procedures , we believe

that granting PondMedics ’ exemption request will not adversely affect safety.

(c) PondMedics’ u nmanned a ircrafts have demonstrated to satisfy necessary safe ty

risk mitigation by FAA thus resulting in multiple grants of section 333 petitions.

Because of t he combination of Unmanned Aircrafts’ proven success and the

conditions and limitations of our operations, we believe granting PondMedics ’

request will not adversely safety.

.Original 07 / 16 /2015 Page 9

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration

Petitioner: Pond m edics Incorporated

Petition of exemption from section s of ;

14 CFR 61.113,

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

PondMedics se eks an exemption from afore mentioned parts of 14 CFR, for commercial

operati on s of the Unmanned Aircrafts described above

.

The unmanned aircraft systems have an onboard camera system capable of acquiring

high resolution data.

Proposed operations will offer aeria l data collection and surveying services for

appropriate commercial industries.Original 07 / 16 /2015 Page 10

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT POND MEDICS ’ REQUEST



### Positive Economic & Environmental Impacts

PondMedics’ UAS operation s will contribute to a po sitive aggregate e conomic

i mpact resulting in creation of jobs both direct and indirectly. Economic Research

estimates that the UAS market will grow from $6 billion to $ 94 billion over the next

decade resulting in a new workforce development

. Because PondMedics’ UASs utilize electrical propulsion and batteries

, it has less

environmental impact compared to manned aircrafts performing similar missions

.



### N o Privacy Issues

PondMedics ’ proposed operations will create no privacy issues because the Unmanned

Aircrafts UAS will be operating in the areas within the boundaries of the propert ies with

the land owner’s permission.

When necessary, Pond Medics will also obtain any permits or authorizations from local

author ities.Original 07 / 16 /2015 Page 11 ACRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FA Rs F ederal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management

System

FTP Flight Termination Point

FTS Flight Termination System

G Hz Gigahertz

GCS G round Control Station

MHz Megahertz

MTOW M aximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile

N O TA M N otice To A irman

OPA Optionally Piloted Aircraft

PIC Pilot in Command

Pond M edics PondMedics Incorporated

U AS Unmanned Aircraft System

U A Unmanned Aircraft ( s )

R&D Research and Development

RF Radio Frequency

RM Risk ManagementOriginal 07 / 16 /2015 Page 12

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System (s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer