Surveying And Mapping, LLC

4801 Southwest Parkway, Building Two, Suite 100, Austin, TX 78735

Ofc 512.447.0575 Fax 512.326.3029

info@sam.biz www.sam.biz TX Firm # 10064300

August 25, 2015

U. S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Request to Amend Exemption Number 11393 (Granted 20 April 2015) issued 

pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations in Regulatory Docket No. FAA-2014-0353-0001

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, 

126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, 

Surveying And Mapping, LLC (“SAM” or “Applicant”), developer and operator of small 

unmanned aircraft systems (singularly a “sUAS” or cumulatively “sUASs”) equipped to conduct 

professional aerial land surveying and geospatial services, hereby applies for a petition to amend 

Exemption Number 11393, granted April 20, 2015 (the “Exemption”), to allow commercial 

operation of two (2) additional sUAS, provided such operations are conducted within and under 

the conditions outlined by the grant of the Exemption.

As SAM is only requesting to add aircraft to the Exemption, it is our position this amendment does 

not qualify as precedent-setting, per guidance located at: http://aes.faa.gov/Petition/faq5a.html. 

Therefore, the Applicant respectfully submits that good cause exists such that notice does not need 

to be published in the Federal Register for the requested amendment.

Currently, per paragraph 1 of the section of the Exemption named “Conditions and Limitations,”

SAM’s exemption is limited to operations using the Allied Drones HornetCam, and proposed 

operations of any other aircraft require a petition to amend the Exemption.

The name and address of the Applicant is:

Surveying And Mapping, LLC

Attention: Pat Smith

4801 Southwest Parkway

Bldg. Two, Suite 100

Austin, TX 78735

Telephone: (512) 685-3542

Email: psmith@sam.biz
U. S. Department of Transportation

Docket Management System 

August 25, 2015

2 | Page

The Applicant hereby requests to amend the Exemption, and the issuance of an FAA Form 7711-

1 UAS COA Attachment, to allow the use of the following two (2) sUAS: 

1. SenseFly eXom; and

2. Aeryon Skyranger

(Aircraft numbered 1 and 2 above, collectively the “Amendment Aircraft”).

In parallel to the Exemption, the Amendment Aircraft will be used for commercial aerial data 

collection by Applicant. Aircraft technical data and checklists for the Amendment Aircraft are 

attached to this petition, labeled Annex A (SenseFly eXom Datasheet) and Annex B (Aeryon 

Skyranger Datasheet), respectively. Previously granted exemptions to other applicants, including 

Exemption No. 12106, allowed for the use of the Amendment Aircraft. For commercial 

purposes, and it is Applicant’s position, this petition to amend the Exemption is similar in 

material respects to the aforementioned granted exemption. In accordance with the conditions 

and limitations granted to SAM under the Exemption, the Applicant respectfully requests 

exemption from the following while operating the Amendment Aircraft:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c),

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

In accordance with the section of the Exemption known as “Conditions and Limitations,” SAM 

hereby requests to operate the Amendment Aircraft while adhering to the conditions and 

limitations listed below:

1. Operations authorized by this amendment to the Exemption are limited to the SenseFly 

eXom and the Aeryon Skyranger, when weighing less than 55 pounds including payload.

Proposed operations of any other aircraft will require a new petition or a petition to amend

this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not

permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft

manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than 
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corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The

VO and PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before the

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations

in accordance with the conditions and limitations stated in this grant of exemption, are

hereinafter referred to as the “operating documents.” The operating documents must be

accessible during UAS operations and made available to the Administrator upon request.

If a discrepancy exists between the conditions and limitations in this exemption and the

procedures outlined in the operating documents, the conditions and limitations herein take

precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating

documents. It is the operator’s responsibility to track such revisions and present updated

and revised documents to the Administrator or any law enforcement official upon request.

The operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a

manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a

condition that affects the safe operation of the UAS, the aircraft is prohibited from

operating until the necessary maintenance has been performed and the UAS is found to be
U. S. Department of Transportation

Docket Management System 

August 25, 2015

4 | Page

in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial,

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in

which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under

this exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from persons, vessels, vehicles and structures. PIC qualification flight hours 

and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for 

the purposes of training the operator’s PICs and VOs (training, proficiency, and

experience-building) and determining the PIC’s ability to safely operate the UAS in a

manner consistent with how the UAS will be operated under this exemption are permitted

under the terms of this exemption. However, training operations may only be conducted

during dedicated training sessions. During training, proficiency, and experience-building

flights, all persons not essential for flight operations are considered nonparticipants, and

the PIC must operate the UA with appropriate distance from nonparticipants in

accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 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 airport’s management is obtained

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement

with the airport management must be made available to the Administrator or any law

enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.
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18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption

holder may apply for a new or amended COA if it intends to conduct operations that

cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities

at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

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
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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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission

from property owner/controller or authorized representative will be obtained for each

flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA's UAS Integration Office (AFS-80) 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.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts

45, 47, 61, and 91.

Summary

Approval of this amendment to the granted Exemption and the issuance of an FAA Form 7711-1 

UAS COA Attachment, allowing the operation of the Amendment Aircraft listed in this petition

will provide an equivalent level of safety supporting the amendment requested herein. The

Amendment Aircraft possess even more enhanced safety features than the Allied Drones 

HornetCam which was previously approved for use in the Exemption, and when operated within 

the conditions and limitations outlined in the Exemption, are far safer than conventional 

operations conducted with manned aircraft used for aerial data acquisition.
U. S. Deparhnent of Transportation

Docket Management System

August 25,2015

Please let me know if you have any questions concerning this request for an amendment to the

Exemption

Very truly yours,

Patick A. Smith, RPLS

Associate

Surveying And Mapping, LLC (SAM)

4801 Southwest Parkway

Parkway Two, Suite 100

Austin, TX78735

Direct 512.685.3542

Email: osmithØsam.biz

Attachments:

Annex A (Sensefly eXom Datasheet)

Annex B (Aeryon Skyranger Datasheet)

TlPage
Annex A

Sensefly eXom Datasheet
The intelligent mapping 

& inspection drone

Technical specifications

Source

Number

Video

Horizontal field of view

Availability

Software application

Mission planning

Flying

After your flight

Software application

Processing

rayCloud Editor

Mosaic Editor 

Output results

Material

Function

Navigation lights

Anti-collision lights

 Avoidance procedure

Warning signals

Cruise control

Distance lock

Obstacle avoidance

Automated failsafe behaviours

Operator triggered

Type

Manual RC control

Sensor

Number

Range

Feedback

Situational awareness & assistance Ground station software

Image processing

Operational safety

Multidirectional video feed

Shrouding

Signalisation lights

Ground proximity detection

Flight assistance features (Interactive mode)

Safety procedures

Autopilot fallback

Object & range detection

Navcams (visual sensor)

5

VGA (640 x 480 pixels)

100 degrees

One navcam at a time

senseFly eMotion X (supplied)

Intuitive 3D user interface

Click and drag to set mission blocks

Automatic 3D flight planning

Edit mission plans during flight

Automated system checks

Automated take-off & landing

Real-time flight status

Main camera video feed integration

Thermal video feed integration

Navcam video feed integration

Fully automatic flight 

Interactive ScreenFly

Manual flight (with assistance 

functions)

In-flight switch between flight modes

Black-box recording of all flight & 

mission parameters

Project & data management 

Seamless interface to Postflight 

Terra 3D

DNG to JPEG conversion

Postflight Terra 3D (supplied)

Rapid Check processing

Quality Report

Automatic Aerial Triangulation (AAT) 

and Bundle Block Adjustment (BBA) 

Automatic point cloud classification 

and DTM extraction 

Point cloud filtering and smoothing 

Automatic brightness and colour 

correction 

Point cloud viewing & editing

Polyline, surface & stockpile 

measurement

Digitisation tools/vector object 

editing

Fly-through animation

Seamline editing

Planar/ortho projection selection

Mosaic colour/brightness editing

2D and 3D (orthoimage, point 

cloud, vector data, etc.)

Optimised camera position, 

external orientation and internal 

parameters, undistorted images

Carbon fibre

Defines propeller rotation area 

Protects from damage at low speed 

2 green on the right, 2 red on the left

1 top strobe, 1 bottom strobe

Automatic stop (can be deactivated)

Audio & visual

Maintains (low) constant speed in a 

given direction 

Keeps distance to frontal objects

3 - 5 m (9.8 – 16 ft)

Depending on flight phase

Geofencing, return home, 

emergency stop, emergency landing

Hold position, return home, go land, 

land now, emergency motor cut-off 

Independent low-level autopilot 

(backup for main autopilot)

Independent RC controller 

(take manual control at any time)

Ultrasonic 

5

Up to 6 m (20 ft)

Audio and visual object warning
Type

Dimensions (incl. shrouding)

Engines

Propellers

Take-off weight

Flight time (full system)

Max. climb rate

Max. airspeed

Wind resistance

Autopilot & control

Materials

Operating temperature

Type

Frequency

Data transmitted

Range

Technology

Type

Power level display

Charging time

Type

Frequency

Range

Flight system

Wireless communication

System power

Main communication link

RC (Remote control)

V-shaped quadcopter

56 x 80 x 17 cm (22 x 32 x 7 in)

4 electric brushless motors

4

1.7 kg (3.7 lb) incl. battery, payload & 

shrouding

Up to 22 min

7 m/s (15 mph)

Automatic flight: 8 m/s (18 mph)

Manual flight:12 m/s (27 mph)

Automatic: up to 8 m/s (18 mph) 

Manual: up to 10 m/s (22 mph)

IMU, magnetometer, barometer 

& GPS

Composite body, moulded carbon 

fibre arms and legs, precisionmolded magnesium frame, 

precision-molded injected plastic

-10 to 40o C (14o-104o F)

Digital, dual omnidirectional 

antennas, dual band, encrypted

2.4 GHz & 5 GHz ISM bands 

(country dependent)

Commands, main camera stream, 

navcam stream, sensor data, etc.

Up to 2 km (1.2 mi)

Smart battery

LiPo, 3 cell, 8500 mAh

LED display on battery, on-screen 

information

1 - 1.5 h

Digital

2.4 GHz

Up to 800 m (0.5 mi)

Control interface

Mission planning

Types of mission blocks

In-flight mission changes

Types

Availability

Type

Quad-core processor

Dual-core processor

Single-core processor

Single-core processor

Primary control interface

Flight assistance

(depending on the flight phase)

Primary control interface

Flight modes

On-board computing

Automatic 

Interactive ScreenFly

Manual (RC)

Mouse, keyboard or touchscreen 

Drag-and-drop mission blocks

Horizontal mapping

Around point of interest

User-defined route

Yes: manual waypoint changes and 

updates possible at any time

Automatic

Interactive ScreenFly

Manual (RC)

Switch between modes at any time

4 on-board CPUs

Principal autopilot & artificial 

intelligence

Video co-processing

Low-level autopilot (safety fallback) 

and motor control

Communication link management

The information contained in this brochure is for promotional purposes only and 

does not constitute an offer, warranty or contract.

Screen-based actions & USB joypad 

Cruise control 

Distance lock

Obstacle avoidance

RC (remote control)

Still images

Video

Horizontal field of view

Digital zoom

Number

Positions

Video

Horizontal field of view

Availability

Operational use

Still images/video

Horizontal field of view

Edge enhancement

Video

Video live streaming range

Horizontal field of view

Headlamp 

Flash

Integrated payloads

Main camera

Thermal camera

Head navcam (visual sensor)

Lights

38 MP, mechanical shutter

DNG (RAW image with correction 

metadata)

Ground sampling distance (GSD):

- 1 mm/pixel at 6 m

- 1 cm/pixel at 60 m

Recorded on board

Geo-referenced (position & 

orientation)

HD (1280 x 720 pixels) 

Recorded on board or streamed

63 degrees

6x

4 navcams

Left, right, rear, bottom

VGA (640 x 480 pixels)

100 degrees

One navcam at a time

Side views (w/o turning main 

camera) & parallel flight along 

objects

Back-up safely & control in 

tight environments

Landing & ground proximity

Thermal (80 x 60 pixels) overlaid on 

main camera stream 

50 degrees

Yes

VGA (640 x 480 pixels)

Up to 2 km (1.24 miles)

100 degrees 

Yes, used for video

Yes (not active upon release) 

TripleView head

Additional navcams (visual sensors)

For eXom updates

subscribe to our newsletter at

www.sensefly.com
Annex B

Aeryon Skyranger Datasheet
Field-tested and battle-proven, Aeryon small UAS set the 

standard for immediate aerial intelligence gathering by ANYONE,

ANYWHERE, at ANYTIME:

Intuitive touchscreen interface and advanced features, minimal user training

 Single operator transport and deployment, no launch or recovery equipment

	 Reliable flight performance even in the most demanding weather conditions,

	 	 when other systems cannot fly

The Aeryon SkyRangerTM introduces a new airframe and integrated system 

design to the Aeryon sUAS platform, based on thousands of hours of flight

time and successful customer exercises and missions around the world.

Designed to military and government specifications, SkyRangerTM extends 

industry-leading performance and system capabilities.

Intuitive interface and autonomous 

capabilities – no joysticks required

Advanced optics and networking – smart 

imagery and seamless integration

Pre-assembled deployment – 

airborne in seconds

Rugged, reliable and capable – 

dependable in extreme environments

Point-and-click touchscreen navigation 

and camera control 

Dynamic flight plans including Follow-MeTM

protection and AutoGridTM mapping modes

Stabilized, simultaneously-streaming 

dual EO/IR high resolution cameras 

-	 EO: 1080p24HDH.264 video, 		 	 	 	

	 15MPstill images

-	 IR: 640x480H.264 video and stillimages,

	 white-hot and black-hotmodes

Low-latency all-digital network – 256bit AES

encrypted streaming video to multiple devices, 

embedded geotags and metadata

Beyond line-of-sight range – 1.9 mi (3 km) integrated capability,

extensible beyond 3.1 mi (5 km)

Folding design protects payload & 

includes battery for powered standby

Payload, battery, arms and legs are 

easily replaced in the field without tools

Up to 50-minute endurance with payload,

continuous operation model

High wind tolerance

- 40 mph (65 kph) sustained

- 55 mph (90 kph) gusts

Ruggedized and weather-sealed

Environmental temperature range 

-22o

F to 122oF (-30oC to 50oC)
The Aeryon sUAS platform brings secure, real-time and simultaneous tactical situational 

awareness to ground forces and remote command. Advanced autonomous capabilities

and simple touchscreen controls require minimal training for soldier, squad, or 

platoon-level deployment.

Unlike fixed-wing systems, the Aeryon SkyRangerTM is a Vertical Take-Off and Landing (VTOL)

sUAS – ideal for providing continuous eyes-on-target for situational awareness, operations

in confined environments, and low-risk launch and retrieval without peripheral equipment.

SkyRangerTM is ideally suited for both land and maritime military use including covert ISR, 

convoy and compound security, and ship boarding operations.

Immediate deployment, small size, quiet operation and specialized imaging payloads 

make SkyRangerTM the ideal platform for a wide range of missions in any conditions, including:

	 Tactical situational awareness & targeting

Perimeter & convoy security

Covert Intelligence, Surveillance 

	 and Reconnaissance (ISR)

Copyright © 2015 Aeryon Labs Inc. - All rights reserved. Aeryon, Aeryon Labs and SkyRanger are trademarks of Aeryon Labs Inc.

Printed in Canada

TECHNICAL SPECIFICATIONS: 

ENDURANCE: 

	 • Up to 50-minute flight time (with payload)

WIND TOLERANCE: 

	 • 40 mph (65 kph) sustained

	 • 55 mph (90 kph) gusts

ENVIRONMENTAL TEMPERATURE RANGE:

• -22o

F to –122oF (-30oC to 50oC)

BEYOND LINE-OF-SIGHT RANGE: 

	 • 1.9 mi (3 km) integrated capability

	 • Extensible beyond 3.1 mi (5 km)

ALTITUDE:

	 • 1500 ft. (450 m) AGL, 15000 ft. (4500 m) MSL

LAUNCH & RECOVERY METHOD: 

• Vertical Take-Off and Landing (VTOL)

DIMENSIONS:

• Deployed: 40 in. (102 cm) diameter,

	 	 	 	 9.3 in. (24 cm) height

• Folded: 20 in. (50 cm) length,

10 in. (25 cm) width

WEIGHT (WITHOUT PAYLOAD): 

	 • 5.3 lbs (2.4 kg)

ADDITIONAL PAYLOADS:

	 • 3-axis stabilized high resolution EO camera

• Custom payload development

NAVIGATION LEDS:

• Red/Green and Red/NIR

RADIO FREQUENCIES: 

	 • 900 mhz, 2.4 GHz, custom

CONTROL AND DATA LINK: 

	 • Low-latency all-digital network

SECURITY: 

	 • Secure network pairing,

	 	 AES 256 bit encryption

MILITARY & GOVERNMENT APPLICATIONS

Anti-piracy, tactical ship boarding

De-mining

Emergency & disaster response

HAZMAT/CBRNE management

For information about Aeryon sUAS solutions, contact your Aeryon Sales Representative:

Call +1-519-489-6726 ext: 320 or email sales@aeryon.com

www.aeryon.com | @aeryonlabs