DAWSON SURVEYS INC. 2502 CAMINO ENTRADA, SANTA FE, NM. 87507 

PHONE 505 471 6660. E-mail dsi.psi@gmail.com 

January 12, 2016

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 an 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 commercial interest 

in providing land survey services (Photogrammetry, Point Cloud Generation) to consumers 

interested in the following commercial purposes.

 Boundary Surveys

 Telecommunication and Utility infrastructure surveys.

 Topographic Surveys

 Aerial Photography (excluding closed set filming).

 Engineering Surveys (Volume determinations and slope analysis)

 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 over private or 

controlled 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.
DAWSON SURVEYS INC. Page 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 exemption from the following FARs:

FAR Section Subject Justification

14 CFR Part 21 Aircraft certification requirements and proceduresDesigned for manned aircraft:

not 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 uses 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, preventive 

maintenance, inspections

Designed for manned aircraft:

not suitable for UAS
DAWSON SURVEYS INC. Page 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 

Professional is multi-rotor (4) equipped UAS with a three axis gimbled camera platform. 

This UAS 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 distance it 

flies from the operator and a no fly zone feature. The remote has an operating frequency 

of 2.00Ghz to 2.483Ghz. The Phantom 3 Professional also has the failsafe function of 

autopilot system which means when the communication between the Main Flight 

Controller and the transmitter is lost, the system will automatically trigger a Return to 

Home mode and land safely.

 3DR X8M will be used for medium projects. The 3DR X8M is a multi-rotor (8) equipped 

UAS with gimbaled camera platform and operates with the PIXHAWK flight control 

system operating in the 2.000 to 2.400 GHz frequencies. Total weight with batteries and 

camera is less than 20lbs. Maximum airspeed is approximately 11m/s depending on 

camera size. The 3DR X8M 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 Return to Home mode and land safely.

 Trimble ZX5 UAS will be used for Medium to larger projects that require longer flight 

times. The Trimble ZX5 is rotary wing UAS with 6 rotors and a maximum payload capacity 

(camera) of 5 lbs. Total weight of the UAS with batteries is around 12 lbs. Maximum 

flight speed is 12 m/s and operating frequency is 2.400Ghz. 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 Return to Home mode and land safely.

Ground Station System

 A Pilot in Command (PIC) is in operational control of a flight from beginning to end and 

controls the UAS while in the air. The UAS must be operated within visual line of sight 

(VLOS) of the PIC at all times. Dawson Surveys PIC operators will hold at least an FAA 

issued private, recreational, or sport pilot certification and a valid U.S. drivers license

issued by a state, the District 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 UAS is in a condition for safe flight. All PIC flight hours will be logged in a 

manner consistent with CFR 61.51(b).
DAWSON SURVEYS INC. Page 4

 A Visual Observer (VO) is a person who provides an additional set of eyes to visually 

track the UAS while in flight.

 A Camera Operator controls the camera and camera gimbal while in flight. Data 

collection is the responsibility of the Camera Operator.

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 UAS will operate at an altitude of no greater than 400 feet AGL. Visual line of site 

(VLOS) will be maintained at all times by the PIC and VO. The minimum crew for each 

operation will consist of the UAS’s PIC and VO.

 Permission will be obtained from the property owner/controller of any vessel, vehicle 

and structure 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 

operating closer to those objects and determine that it does not present an undue 

hazard.

 The UAS will not be operated by the PIC from any moving object or vehicle.

 The UAS will operate only during daylight hours 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 UAS will land safely back at the base prior to the manufacturer’s recommended 

minimum battery level of 25% remaining. The UAS will not begin a flight with less than 

75% of the battery level.

 The UAS will remain clear and give way to all manned aviation operations 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 UAS Integration office within 24 hours.

 Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.

 All operations shall be conducted in accordance with an ATO (Air Traffic Organization)

issued COA.
DAWSON SURVEYS INC. Page 5

 The UAS may not operate within 5 NM (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 airports 

management is obtained or otherwise permitted by a COA issued to Dawson Surveys 

Inc. 

 Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. All maintenance and alterations must be properly documented in the aircraft 

records.

 The UAS will not operate at a speed exceeding 30 knots (34 miles per hour). In no case 

will the UAS operate at a speed exceeding the manufacturer’s recommended operating 

speed.

SAFETY AND PUBLIC INTEREST CONSIDERATIONS

Land survey services as outlined above historically have been conducted with trained personnel, 

cumbersome and expensive equipment and in some instances with the use of costly manned 

aircraft. More often than not projects are in remote and inaccessible locations and/or difficult 

terrain; all that present their own set of safety and logistical concerns. Using UAS under the 

provisions set out in the exemption will certainly reduce the amount of resources and time 

required to complete the survey, but will significantly limit the survey personnel’s exposure to 

field time and potential hazards associated with working in remote and difficult terrain. 

Additionally, by using a UAS instead of the typical survey equipment and techniques, the impact 

to the environment will be reduced. 

Photogrammetry and topographic surveys are two excellent examples of the safety and public 

benefits of using UAS.

TOPOGRAPHIC SURVEYS INCLUDING VOLUME AND SLOPE ANALYSIS:

Typically topographic 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 construction. 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, moving around the project area 

to gather the data tends to have an environmental impact despite the careful nature of the 

crew. Using a UAS will eliminate the ground crews exposure to many 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 UAS reduce the need for the crew to physically move around the 

project area which will eliminate any environmental impact associated with traditional survey 

methods. 
DAWSON SURVEYS INC. Page 6

PHOTOGRAMMETRY:

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 aircraft at low altitudes, presents the risk 

associated with vehicles that exceed 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 UAS will not carry 

passengers or crew 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