**DAW SON SURVEYS**  **INC. 2502 CAMINO ENTRAD A, SANT**  **A FE, N M. 87507**  **PHONE 505 471 6660. E**  **- mail dsi.psi@gmail.com** 

January 12 , 201 6 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590. **RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT.** Dear Sir/Madam, This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and 14 C.F.R. Part 11, Dawson Surveys Inc. (The Petitioner), a licensed New Mexico Land Survey Company would hereby like to apply for a n exemption from the listed Federal Aviation Regulations (“FARs” ) and to allow commercial operation of our Unmanned Aircraft System (UAS) to conduct aerial photography and land surveys for various industries in airspace regulated by the Federal Aviation Administration (FAA). All operations of our UAS will be conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Dawson Surveys Inc. to pursue its commerc ial interest in providing land survey services (Photogrammetry, Point Cloud Generation) to consumers interested in the following commercial purposes.

 Boundary Surveys
 Te lecommunication and Utility infrastructure surv eys.
 To pogr aphic Surveys
 Aerial Photo graphy (excluding closed set filming).
 Engineering Surveys (Volume determinations and slope analys is )
 Construction and As

- built Surveys.
As described in more detail below, the requested exemption would permit the operation of unmanned UAS under controlled conditions in airspace that is limited, is predetermined, is controlled as to access and would provide safety enhancements to the already safe operations of the industry. Dawson Surveys states that all UAS surveys that will occur ove r private or c ontrolled access property will do so with the property owner’s prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photography will be captured.DA

WSON SURVEYS INC. Pa ge 2 **Name and contact information of this petitioner**  **:** Dawson Surveys Inc. Attn. Barry Phillips 2502 B Camino Entrada Santa Fe, New Mexico 87507 Phone (505) 471 6660 Email: dsi.psi@gmail.com Dawson Surveys Inc. hereby requests exempti on from the following FARs: FAR Section Subject Justification 14 CFR Part 21 Aircraft certification require

ments and procedures Designed for manned aircraft : n ot suitable for UAS 14 CFR 45.23 and 45.29 Requirement to display registration number of vehicle Insufficient space on UAS 14 CFR 61.113 (a) and (b) Private pilot privileges and limitations: pilot in command UAS will not carry a pilot or passengers 14 CFR 91.7 (a) Airworthiness requirement Designed for manned aircraft not UAS 14 CFR 91.9 Requirement to have manual available in cockpit Designed for manned aircraft not UAS 14 CFR 91.103 Preflight action Unmanned Vehicle. PIC will ensure flight safety based on UAS manufacturer instructions, weather conditions, and pre - flight UAS examination 14 CFR 91.105 Flight Crew Members Stations Unmanned Vehicle 14 CFR 91.109 Flight Instructions Unmanned vehicle 14 CFR 91.119 Minimum Safe Altitude Safety requires operation below these altitudes 14 CFR 91.121 Altimeter Settings Unmanned Vehicle. No person on board to read altimeter 14 CFR 91.151 Fuel requirements UAS use s batteries not fuel 14 CFR 91.203 (a) and (b) Requirement for registration and airworthiness certificates to be on board Unmanned Vehicle
14 CFR 91.205 (b) Cockpit Instruments Unmanned Vehicle 14 CFR 91.215 (a) and (b) Transponder requirements Vehicle has insufficient load capacity; operating below ATC radar coverage 14 CFR 91.401

- 91.417 Maintenance , p reventive m aintenance, i nspections Designed for manned aircraft : not suitable for UASDA

WSON SURVEYS INC. Pa ge 3 **Unmanned Aircraft System** Dawson Surveys Inc. is petitioning for exemption to operate three UAS’s.

 DJI Phantom 3 Professional will be used for small to medium surveys. The Phantom 3 Pr ofessional is multi

- ro tor (4) equipped U AS with a three axis gimbled camera platform. This U AS flies at 16m/s with a total weight with camera of less that 20lbs. The unit has a built

- in capability to limit the height it flies above ground, the radius of the dis tance it flies from the operator and a no fly z one feature. The remote has an operating frequency of 2.00 Ghz to 2.483Ghz. The Phantom 3 Professional also has the fai lsafe function of autopilot s ystem which means when the communication between the Main Flight Controller and the transmitter is lost, the system will automatically trigger a R eturn to Home mode and land safely

.

 3DR X8M will be used for medium projects. Th e 3DR X8M is a multi

- ro tor (8) equipped UA S with gimbaled camera platform and operates with the PIXHAWK flight control system operating in the 2.0 00 to 2.4 00 GHz frequencies. T otal weight with batteries and camera is less than 20lbs. Maximum airspeed is ap pr oximately 11m/s depending on camera siz e. The 3DR X8M has the failsafe function of the autopilot s ystem which means when the communication between the Main Flight Controller and the transmitter is lost, the s ystem will automatically trigger a Ret urn to H ome mode and land safely

.

 Tr imble ZX5 U AS will be used for Medium to larger project s tha t r equire longer flight times. The Trimble ZX5 is rotary wing U AS with 6 rotors and a maximum pa yload capacity (camera) of 5 lbs. T

otal weight of the U AS with batterie s is around 12 lbs. Maximum flight speed is 12 m/s and operating frequency is 2.4 00 Ghz. The Trimble ZX5 has the failsafe function of the autopilot system which means when the communication between the Main Flight Controller and the transmitter is lost, the system will automatically trigger a Ret urn to Home mode and land safely

. **Ground Station System**

 A Pilot in Command (PIC) is in operational control of a flight from begin ning to end and controls the UAS while in the air . The U A S mus t be operated within visual line of sight (VL OS) of the PIC at all times. Dawson Surveys PIC operators will hold at least an FAA issued private, recreational, or sport pilot certific ation and a valid U .S. drivers license issued by a s tate, the Dis tric t of Columbia, Puerto Rico, a territory a possession or Federal government. The individual acting as PIC will be identified prior to any flight and will not change once a flight has begun. The PIC must conduct a pre

- flight inspection and determine the U AS is in a condition for sa fe flight. All PIC flight hours will be logged in a manner consis tent with CFR 61.51(b).DA

WSON SURVEYS INC. Pa ge 4  A V isual Observer (VO) is a person who provides an additional set of eyes to visually tr ack the U AS while in flight.
 A Camera Operator controls the camera and camera gimbal while in flight. Data collection is the responsibility of the Camera Oper ator
. **UAS OPERATING PARAMETERS** Dawson Surveys Inc. will abide by the following additional operating conditions under the exemption, which will ensure a level of safety at least equal or greater to the existing rules:

 The U A S will operate at an altitude of no greater than 400 feet AGL. Visual line of site (VL OS) will be maintained at all times by the PIC and VO. The minimum crew for each oper at io n will consis t of the U AS’ s PIC and VO.

 Permission will be obtained from the property owner/controller of any vessel, vehicle and s tructure when operations are conducted closer than 500 feet to any such vessel, vehicle or structure. The PIC will conduct a thorough safety assessment of the risk of oper at ing closer to those objects and determine that it does not present an undue hazard.

 The U A S will not be oper ated by the PIC from any moving object or vehicle.

 The U A S will operate only during daylight hour s and for a maximum of 30 minutes each flight. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not permitted.

 The U AS will land safely back at the base prior to the manufacturer ’s recommended minimum ba ttery lev el of 25% remaining. The U AS will not begin a flight with less than 75% of the battery level.

 The U A S will remain clear and give way to all manned aviation opera tions and activities at all times.

 Any incident, accident or flight operations that transgress the vertical or lateral boundaries of the operational area as defined by the applicable COA must be reported to the FAA

’s U AS Integration office within 24 hours .

 Accidents mus t be r eported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov

.

 All operations shall be conducted in accordance with an A TO (Air Traffic Organization) issued COA.DA

WSON SURVEYS INC. Pa ge 5  The U A S ma y not operate within 5 NM (Nautical Miles) of an airport refer ence point (ARP) as denoted in the current FAA Airport/F acility Directory (AFD) or for airports not denoted with an ARP

, the center of the ai rport s ymbol a s denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airports management is obtained or otherwise permitted by a COA issued to Dawson Surveys Inc.

 Prior to each flight the PIC must inspect the U A S to ensure that it is in a condition for safe flight. All maintenance and alterations must be properly documented in the aircraft records.

 The U A S will not operate at a speed ex ceeding 30 knots (34 miles per hour). In no case will the U A S oper ate at a speed exceeding the manufacture r’ s recommended operating speed.

**SAFETY AND PUBLIC INTEREST CONSIDERA TIONS**  Land survey services as outline d above historically have been conducted w ith trained personnel, cumber some and expensive equipment an d in some ins tances with the use of costly manned aircraft. More often than not pr ojects are in remote and inaccessible locations and /or difficult terrain; all that present their own set of safety and logistical concerns. Using U AS under the pr ovisions set out in the exemption will certainly reduce the amount of resources and time required to complete the survey , but will significantly limit the sur vey personnel’ s exposure to field time and potential hazards associated with working in remote and difficul t t err ain. Additionally

, by using a U AS ins tead of the typical survey equipment and techniques, the impact to the environment will be reduced. Photogrammetry and topographic surveys are two ex cellent ex amples of the safety and public bene fits of using U AS. TO POGRAPHIC SURVEYS INCLUDING VOLUME AND SLOPE ANAL YSIS : Ty pically topogr aphic surveys involve field personnel employing expensive equipment to capture terrestrial elevation data and features, often in remote and inaccessible location or in the case of volume surveys, around heavy machinery or cons truction. Ground based surveys of this type rely on the personnel physically moving around the project area gathering the data which exposes the ground crew to certain hazards. In addition, mov ing around the project area to g ather the data tends to have an environmental impact despite the careful nature of the crew. Using a U AS will eliminate the ground crews exposure to m any of the hazards associated with this survey because it will reduce the amount of field work required, especially in remote and rugged terrain. In addition U AS reduce the need for the crew to physically move around the pr oject area which will eliminate any environmental impact associated with traditional survey methods.DA

WSON SURVEYS INC. Pa ge 6 P HOTO GRAMMETRY : Current methods for gathering photo data for land surveying involve the use of costly manned platforms that are often prohibitively expensive for small to medium sized survey companies. Conventional photogrammetry , using jet or piston aircr aft at low altitudes, presents the risk associated with v ehicles that ex ceed 3000 lbs. and carry large amounts of jet A or other fuels. In sharp contrast a UAS weighing less that 55 lbs. and powered by batteries eliminates virtually all the risk given the mass and lack of combustible fuel. Additionally the U AS will not carry passengers or c re w and therefore will not expose them to risks associated with manned aircraft. Thank you for your consideration of our exemption request Sincerely, Scott Meredith Barry Phillips Dawson Surveys Inc. 2502 B Camino Entrada Santa Fe, New Mexico 87507 Phone (505) 471 6660 Email: dsi.psi@gmail.com www.dawsonsurveys.com