September 15, 2015 

Federal Aviation Administration 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from certain parts of the FARs. 

Dear Sir or Madam: 

Pursuantto Section 333 oftheFAAModernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 

11, Ecology and Environment, Inc. (hereinafter "E & E") hereby applies for an exemption from the listed Federal 

Aviation Regulations ("F ARs") to allow it to operate small Unmanned Aircraft Systems ("sUAS") under the 

conditions and limitations set forth in this Petition. 

Founded in 1970, E & E is an environmental services firm whose underlying philosophy is to provide 

professional services that promote economic and human development in an enviromnentally sustainable 

manner. Incorporated in New York State, E & E is headquartered in Lancaster, New York, and is publicly 

traded on the NASDAQ. E & E maintains professional offices in approximately 30 major cities 

throughout the Unites States. 

E & E employs specialists in more than 85 disciplines in the sustainable, physical, biological, social, and 

health sciences. E & E offers a broad range of environmental consulting services for both private and 

public sector clients, including environmental planning and site assessment; management and regulatory 

compliance support; environmental and pollution control engineering; Environmental Impact Statement and Environmental Assessment report drafting, and, increasingly, emergency response and management. 

E & E has identilied sUAS as a technology that can improve public safety and alleviate heath and safety 

concerns associated with personnel field efforts while providing enhanced services and more accurate data 

collection. The proposed exemption, if granted, would allow E & E to conduct commercial operations with 

sUAS's, meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 

333 . 

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II. 14 CFR 11.81 (b)-Exemptions Requested: 

The Federal Aviation Administration (FAA) considers unmanned aircraft as "aircraft" flown by a "pilof' 

regardless of the location of the pilot. All aircraft and pilots must comply with applicable sections of Title 14 of 

the Code of Federal Regulations (14 CFR) and other rules/regulations to operate within the National Airspace. 

Unmanned aircraft are unable to comply with certain sections of 14 CFR as the regulations were written prior to 

the consideration of sUAS integration within the National Airspace. Therefore E & E is requesting an exemption 

from the sections of 14 CFR cited below, in addition to further exemptions and relief as the FAA may determine 

is necessary to permit the operations described here. 

14 CFR Part 21 Subpart H -Airworthiness certification 14 C.F R § 6123 (a) and (c)-Medical certificate: requirement and duration 14 C.F R § 61.101 (e) 4 and 5 -Recreational pilot privileges and limitations 14 C.F R § 61.113 (a)-Private pilot privileges and limitations: Pilot in command 

14 C.F R § 61.315 (a)- Sports pilot certificate privileges and limits 

14 C.F R § 91.7 (a)-Civil Aircraft Airworthiness 

14 C.F R § 91.119( c)-Minimum safe altitudes 14 C.F R § 91.121 -Altimeter settings 14 C.F R § 91.151 -Fuel requirement's for flight in VFR conditions 

14C.FR § 91215 -ATC Transponder and Altitude Reporting 

14 C.F R § 91.405-Maintenance required 14 C.F R § 91.407 (a) (1)-Operation after maintenance, preventive maintenance, rebuilding alteration 14 C.FR § 409 (a)(1)and(2)- Inspections 

14 C.F R § 417 (a) & (b)-Maintenance Records 

ill. 14 CFR Part 11.81 (c)- The extent ofreliefE & E seeks, and the reason E & E seeks the 

relief: 

E & E seeks relief from applicable parts of the F ARs and other rules/regulations to the extent necessary 

to permit civil flight operations within the national airspace. E & E seeks authorization to conduct 

sUAS flight operations to perform aerial data collection within the perimeters of this exemption request. 

Appendix 1 describes the F ARs from which an exemption is requested and summarizes the justification 

for each requested exemption. 

IV. 14 CFR Part 11.81 (d) The reasons why granting E & E's request would be in the public 

interest; that is, how it would benefit the. public as a whole: 

E & E requests thatthe FAA grant its exemption request in the public's interest. E & E' s proposed uses 

include photogrammetry, assessing environmental damage, responding to environmental emergencies, project 

siting and analysis, land and resource management, and reclamation and environmental remediation services. 

"[T]he enhanced safety achieved using an unmanned aircraft with the specifications described herein and 

carrying no passengers or crew, rather a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives ... good cause to fmd that the UAS operation ... is in the public interest" 

(see Docket No. FAA-2015-0094.) sUAS platforms provide an additional tool for professional environmental 

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sUAS platform puts the power of aerial intelligence and increased situational awareness directly into 

the hands of the first responders. Real-time video streaming can show not only the extent of the 

damage but may also warn responders of additional hazards. Geo-tagged digital photographs provide 

an aerial record of the on-ground situation both before and during response activities. It is in the 

public interest to provide first responders with the most accurate data so that containment and 

remediation efforts can be as safe, efficient and effective as possible. 

Assessing Environmental Damage from Long-Term Release of Hazardous Materials: 

In addition to supporting rapid response following disasters, sUAS technology can also be useful in 

assessing environmental damage that occurred either many years ago, or has occurred over long 

periods of time. Examples include impacts related to abandoned mines (or long-term operation of 

active mines) or industrial facilities. The public will benefit when sUAS platforms can efficiently 

determine where widespread impacts may have resulted from (for example) water discharge or air 

emissions that harm local populations, vegetation and wildlife habitat. 

Project Siting: 

sUASs can be utilized for assessing environmental conditions associated with future and current 

infrastructure and energy projects. E & E will be able to rapidly evaluate topography and environmental 

conditions, including habitat for sensitive species, areas prone to erosion, cultural resource sites, 

waters/wetlands, etc., over large tracts of land, leading to better-informed decisions on siting and routing 

of infrastructure. Large (and often linear) projects such as pipelines and transmission lines will-in 

particular-benefit from the use of sUAS platforms. The public will benefit from the more efficient use 

of resources and minimized impacts to sensitive species and natural resources when new projects are sited 

and permitted. 

Land and Resource Management: 

sUAS technology will streamline the assessment of environmental conditions for ongoing land and 

resource management. Resources that can be efficiently evaluated with sUAS technology may include water (use and retention), timber, range health, invasive species, waters/wetlands, wildlife, habitat quality, 

and many others. Numerous government entities are tasked with management of land and resources 

(open space, parks, federal lands, etc.) The ability to efficiently and accurately obtain data will lead to 

improved and more cost-effective management of lands and resources, thereby benefiting the 

public. Increased efficiency and effectiveness in managing land and resources will also reduce costs and 

administrative burdens to taxpayers. 

Reclamation and Environmental Remediation: 

sUASs can be utilized for the monitoring of environmental conditions during reclamation activities. For 

example, sUAS technology can be used to monitor the construction of pipelines, roadways, electric 

transmission lines, and other critical infrastructure development efforts, as well as to monitor the progress 

of post-construction reclamation efforts. The technology can also be used to monitor environmental 

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exemptions: 

>- Aerial inspection, environmental monitoring, construction monitoring, and preliminary 

engineering report related imagery- Regulatory Docket No. FAA-2015-0234; 

>- Aerial surveying, remote sensing, precision agriculture, aerial photography, wildlife and natural 

resource monitoring and educational multidisciplinary research- Regulatory Docket No. FAA2014-1056; 

> Aerial survey to produce imagery and terrain modeling products useful in applications ranging 

from civil engineering, land and water resources management, environmental research, disaster 

response, agriculture, and many other useful applications - Regulatory Docket No. FAA-2015-

0094; 

> Wildlife and forestry monitoring- Regulatory Docket No. FAA-2014-0826; 

>- Data collection for natural resources and conservation, construction and infrastructure, precision 

agriculture, and inspection and monitoring - Regulatory Docket No. FAA -20 14-0972; 

> Pipeline survey, and for monitoring damage in the event of a natural disaster- Regulatory Docket 

No. FAA-2014-0857; 

> Aerial inspection, environmental monitoring- Regulatory Docket No. F AA-20 15-0234; > Vegetation, and rights of way- Regulatory Docket No. F AA-2015-0005; 

> Aerial photo services to quickly assess potentially hazardous conditions (including but not limited 

to landslide and flooding) that may pose as a detriment to the public safety - Regulatory Docket 

No. FAA-2015-0181; 

>- Survey and monitoring of Surface mining- Regulatory Docket No. F AA-2014-0678; 

> Aerial surveying, remote sensing, precision agriculture, aerial photography, wildlife and natural 

resource monitoring, and educationaVmultidisciplinary research- Regulatory Docket No. FAA2014-1056; 

> Thermal and photographic inspection of power infrastructure -Regulatory Docket No. FAA2014-0845. 

V. 14 CFR Part 11.81 (e)- The reasons why granting the exemption would not adversely affect 

safety, or how the exemption would provide a level of safety at least equal to that provided by the rule 

from which E & E seeks the exemption: 

E & E is committed to utilizing sUAS technology in a safe and effective manner. E & E commits to 

the following guiding principles when operating sUAS technology pursuant to this requested 

exemption. 

1. Pilot in Control (Pig 

All E & E Pilot in Control (PIC) personnel will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. PIC personnel will also hold a current FAA airman medical 

certificate or a valid U.S. driver's license. The PIC will 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. This ensures that all 

PICs have the knowledge regarding the Federal Aviation Regulations, Airspace, and other pertinent 

knowledge to conduct safe operations of small unmanned aircraft systems. E & E's PICs will be trained 

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By way of example, E & E's Jim Welch will serve as one PIC. Mr. Welch received his airman's private 

certificate in 1996 and commercial and instrument licenses (fixed and rotary wing) in 1998. He has 

logged over 2,150 hours in a multitude of fixed and rotary wing aircraft. As a former Naval Aviator, his 

experience includes being a flight and instrument instructor as well as being type rated in the Sikorsky S61 aircraft. 

E & E's Eric Lindeman will serve as another PIC. Mr. Lindeman received his airman's private certificate 

in 1968. He has logged approximately 285 hours in a variety of single-engine, land-based aircraft. Mr. 

Lindeman carries an airman's 3rd class medical certification; his bi-annual Flight Review is current and he 

participates in the FAA Wing program. Mr. Lindeman is a member of the Aircraft Owners and Pilots 

Association and regularly attends their Safety Seminars. Mr. Lindeman will continue to maintain an 

airman's 3rd class medical certificate to operate any sUAS. 

2. Vehicle 

DJI Phantom 2 Vision+ 

E & E will fly one or more DJI Phantom 2 Vision+ systems equipped with a three-axis gimbal and 

camera. The DJI Phantom 2 Vision has been approved for Section 333 exemption in numerous prior 

FAA exemption approvals, including but not limited to Regulatory Docket Nos. F AA-20 15-0106, 

FAA-2014-0836, and FAA-2015-0174. FAA's prior approval of this sUAS platform, for other 

operators, demonstrates the confidence the FAA has for this manufacturer's operational and safety 

protocol. 

These vehicles have the built-in capability to limit the height they fly above the ground, limit the 

distance (radius) they fly from the launching point, and automatically land when entering airspace 

surrounding Class A and B airports. The aircraft also have the built-in capability to return to the 

launching point if the wireless control link is interrupted or if the operator attempts to exceed any of 

the height, radius, or airspace limitations previously programmed. In addition, the aircraft will 

automatically return to the launching point when the on-board battery charge falls below 20%. 

The vehicle weighs about 2 pounds and has a maximum gross weight of approximately 2.5 pounds. It has 

a top speed of about 26 knots. It has four fixed-pitch rotors, thrust from which is varied by changing 

Rotations per Minute (RPM). It is powered by an 11.1 v 5200 mAh Lithium-Polymer battery. 

DJI Spreading Wings SlOOO 

E & E will fly one or more DJI Spreading Wings S 1000 systems. The DJI Spreading Wings S 1000 

has been approved for Section 333 exemption in numerous prior FAA exemption approvals, including 

but not limited to Regulatory Docket Nos. FAA-2015-0653, F AA-2014-1017, and FAA-2015-0261. 

FAA's prior approval of this s U AS platform, for other operators, demonstrates the confidence the 

FAA has for this manufacturer's operational and safety protocol. 

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they fly above the ground, and limit the distance (radius) they fly from the launching point. Equipped 

with the A2 controller, the aircraft will have the capability to return to the launching point if the 

wireless control link is interrupted or if the operator attempts to exceed any of the height, radius, or 

airspace limitations previously programmed. 

senseFly eBee 

E & E will fly one or more senseFly eBee sUAS, equipped with an onboard camera. The senseFly eBee 

has been approved for Section 333 exemption in numerous prior FAA exemption approvals, including but 

not limited to Regulatory Docket Nos. F AA-2015-0091, F AA-2014-0733, and FAA-2014-0727. FAA's 

prior approval of this sUAS platform, for other operators, demonstrates the confidence the has for 

this manufacturer's operational and safety protocol 

The vehicle is ultra-light, with a maximum takeoff weight of 1.7 pounds. Propelled by an electric pusher 

propeller, it has a maximum cruising speed of up to 56 MPH, and a nominal cruising speed of 25 MPH. 

The eBee's 38 inch wingspan is made of detachable, flexible foam with no sharp or hard edges. It is 

powered by an 11.1v 2150 mAh Lithium-Polymer battery. 

The sUAS's eMotion software and onboard GPS allows the operator to plan a mission, in 3 dimensions, 

and then monitor the progress in real time. The eBee's incorporated autopilot system continuously 

analyzes data from the Inertial Measurement Unit and the onboard GPS and automatically operates the 

unit, under the supervision of the PIC. However, the unit provides a manual override capability allowing 

the PIC to suspend automated operations and take direct control of the aircraft in exigent circumstances. 

3. Flight profiles 

E & E will program each sUAS so that it will not fly more than 400 feet above ground level, or more 

than 2000 feet away from its operator. All flights will only begin if there is 50% or more available 

battery power. If the aircraft battery is reduced to 20% available power, it will automatically 

attempt to land. The PIC will carefully perform a preflight inspection of the vehicle before each 

mission to assure that its compass and GPS system are properly calibrated and that the return-tohome feature, exclusion area feature, and altitude and radius limitations are functioning. 

E & E will not operate sUASs in controlled airspace without approval from the FAA or above 

property which is access controlled without prior consent. All flight operations will be at least 500 

feet from all nonparticipating persons, vessels, vehicles, and structures, unless prior permission has 

been obtained by such person or owner of the vessels, vehicles, and structures. In the unlikely event 

that a manned aircraft flies below 400 feet where the E & E is operating its DJ Phantom 2 Vision+, 

the operator will keep both the vehicle and manned aircraft in sight and will give way to the manned 

aircraft at all times. 

E & E will never operate sUASs within 5 nautical miles from an airport, unless prior consent has 

been obtained. Flights will be remote from noise sensitive areas such as parks, schools, hospitals, 

and churches. Flights will be only conducted in daylight and permissible weather- rain, snow, or 

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(Standard Operating Procedures). Safety will be the paramount concern in defining flight profiles. 

The PIC and VO will conduct flight operations and safety briefings prior to all planned sUAS flights. 

Briefings will include weather reviews and reviews of takeoff, landing and aircraft performance data for 

real time conditions. Full pre- and post-flight inspections/checklists will be conducted for each specific 

sUAS. The radio frequency spectrum used for the operation and control of the sUAS will comply with 

the FCC or other appropriate government oversight agency requirements. 

4. Maintenance and Reporting 

The PIC will perform a functional test flight on any sUAS that has undergone maintenance or alterations 

that affects the sUAS operation or flight characteristics. The PIC will record the flight in the UAS aircraft 

records. All maintenance and alterations will be similarly documented in the aircraft records. E & E will 

follow the sUAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection and 

life limit requirements. All maintenance, preventive maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS will be recorded and 

documented. E & E will comply with all manufacturer safety bulletins. 

Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents will also be reported to the National Transportation Safety Board 

(NTSB). 

VI. 14 CFR Part 11.81 (f)- A summary the FAA can publish in the Federal Register: 

E & E' s s U AS program will be for aerial data collection purposes previously approved by the FAA. The 

program will utilize sUAS aircraft that have been similarly approved. E & E will operate its program 

responsibly and abide by the limitations of previous grants. As such, E & E believes the Summary Grant 

Process should be applied to this petition and no summary need be published in the Federal Register. 

However, in the event the FAA determines such a summary is needed, E & E respectfully submits the 

following: 

(1) The rule from which you seek the exemption: 

14 CPR Part 21 Subpart H -Airworthiness certification 

14 C.P.R.§ 4523 (b)-Display of marks: general 

14 C.P.R. § 61.23 (a) and (c)-Medical certificate: requirement and duration 

14 C.F .R. § 61.10 1 (e) 4 and 5 -Recreational pilot privileges and limitations 

14 C.P.R.§ 61.113 (a)-Private pilot privileges and limitations: Pilot in command 

14 C.F .R. § 61315 (a)- Sports pilot certificate privileges and limits 

14 C.P.R.§ 91.7 (a)-CivilAircraftAirworthiness 

14 C.F .R. § 91.119 (c)-Minimum safe altitudes 

14 C.F .R. § 91.121 -Altimeter settings 

14 C.F .R. § 91.151 (a) (1)-Fuel requirement's for flight in VFR conditions 

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its petition to allow E & E to safely and efficiently conduct aerial data collection for professional 

environmental consulting services. 

The exemption will enhance safety by reducing risk to the operator, the general public and property 

owners from the substantial hazards associated with performing equivalent work using traditional 

aircraft and rotorcraft. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 

11, E & E respectfully requests an exemption from the aforementioned F ARs, to allow it to operate sUASs under 

the conditions and limitations set forth in this Petition. 

Re ectfully submitt~ /- - ~ -~"· :..c.--~~ 

Courtney Hu k~, Esq. 

Staff Counsel 

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14 CFR § 61.101 (e) (4) and Recreational pilot posits that this certificate ensures the appropriate level (5) privileges and limitations of aeronautical knowledge to 

safely operate sUASs. 

Unmanned aircraft. E & E 

14 CFR § 61.113(a) Private pilot privileges posits that this certificate and limitations; Pilot in ensures the appropriate level 

command (PIC) of aeronautical knowledge to 

safely operate sUASs. 

Unmanned aircraft. E & E 

Sport Pilot Certificate posits that this certificate 14 CFR § 61.3 15 (a) ensures the appropriate level privileges and limits of aeronautical knowledge to 

safely operate sUASs. 

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUASs. However, E & E will 

maintain the sUAS and the 

14 CFR § 91.7 (a) Airworthiness requirement PIC will deem the sUAS safe 

for flight before all operations 

or discontinue any flight in 

the event of mechanical, 

electrical, or structural issues. 

Safety requires 

14 CFR § 91.119 (c) Minimum altitudes for safe flight operation below these 

altitudes 

E & E will operate 

below 400 feet and 

within visual lineof-sight. 

14 CFR § 91.121 Altimeter settings Additionally altitude, orientation, 

GPS position 

information will be 

relayed in real time 

to the operator. 

E & E will operate all sUAS 

under daytime VFR flight 

conditions using VLOS, and 

14 CFR § 91.151 (a)( 1) Fuel requirements terminate operations with at 

least 25% reserve battery 

power still available. 

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replacements. 

A sUAS technician or the 

sUAS manufacturer will 

approve a UAS to return to 

use after maintenance, 

14 CFR § 91.407 (a) (1) Operations after maintenance rebuilding or alteration. PIC 

will approve return to service 

after any preventative 

maintenance. Maintenance 

records will be maintained. 

E & E's PIC will perform 

preflight inspections that 

include all ofthe aircraft's 

14 CFR § 91.409 (a) (1) and Inspections components. Additionally, E (2) & E will follow the guidance 

included in the manufacturer 

maintenance schedule as 

attached. 

All inspections, maintenance, 

overhaul, and replacements 

14 CFR § 91.417 (a) and (b) Launch safety- maintenance records will be documented. E & E will comply with all 

manufacturers' safety 

bulletins. 

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