June 4, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as Reform Act)

and 14 CFR Part 11, Robbins Land Surveying, Inc. (D/B/A Robbins3D), a small Land Surveying and 3D Laser

Scanning firm, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow

commercial operation of UAS for precision aerial surveying and aerial imagery capture so long as such

operations are conducted within and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

As detailed in this document and the attached 3D Robotics X8+/M and DJI Inspire 1 User Guides (herein

referred to as User Guides), the requested exemption would permit the operation of UAS under controlled

conditions in airspace that is

1) limited, 2) predetermined, 3) controlled as to access and 4) would provide safety enhancements to the

already best practices safety protocols followed by Robbins Land Surveying, Inc. (D/B/A Robbins3D).

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's

responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national

airspace system." Section 333(c) Reform Act.

The name and address of the applicant is:

Robbins Land Surveying, Inc.

D/B/A Robbins3D

P. O. Box 1992

Loganville, GA 30052

Kenneth S. Robbins

Phone: 770-554-5810

Email: ken@robbinslandsurveying.com

Web Site: http://www.Robbins3D.com

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
Exemptions/Rule Making

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 45.29

14 CFR 61.23

14 CFR 61.113(a) & (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) & (b)

14 CFR 91.405(a)

14 CFR 407(a)(1)

14 CFR 409(a)(2)

14 CFR 417(a) & (b)

14 CFR Subpart E (91.401-91.417)

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes

exempting civil aircraft, as the term is defined under §40101 of the Act, including UASs, from the requirement that

all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or

(b) of this section or any sections §44702-44716 of this title if the Administrator finds the exemption in the public

interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UASs may operate in the national

airspace system without creating a hazard to the user, the public, or a threat to national security. In making this

determination, the Secretary must consider:

§ The UAS' size, weight, speed and operational capability;

§ Whether the UAS operates within the visual line of sight of the operator;

§ Whether the UAS operates outside of highly populated areas and away from close proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS "may operate safely in the national airspace system,

the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system."

Id. 333(c).

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
The 3D Robotics X8+/M is a multi-rotor aircraft weighing 8.1 pounds, including payload. It has the ability to

operate under normal conditions at a speed of no more than 10 knots and has the capability to hover and move in

the vertical and horizontal plane simultaneously. The UAS will operate only in the pilot's or visual observer's

visual line of sight at all times. Such operations will insure that the UAS will "not create a hazard to users of the

national airspace system or the public." Reform Act Section 333(b).

The DJI Inspire 1 is a multi-rotor aircraft weighing 6.5 pounds, including payload. It has the ability to

operate under normal conditions at a speed of no more than 42 knots and has the capability to hover and move in

the vertical and horizontal plane simultaneously. The UAS will operate only in the pilot's or visual observer's

visual line of sight at all times. Such operations will insure that the UAS will "not create a hazard to users of the

national airspace system or the public." Reform Act Section 333(b).

Given the small size of the UAS involved and the restricted environment within which they will operate, our

application falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned

that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to

the small size of the UAS and the low altitudes in which our UAS will operate, approval of the application presents

no national security issue.

VEHICLE DESCRIPTION

The UAS Robbins Land Surveying, Inc. (D/B/A Robbins3D) proposes to use is constructed by 3DRobotics and

referred to as the X8+/M . The X8+/M is commonly referred to as an octo-copter (8 rotors and 8 motors) which

weighs a total of 7.7 pounds without payload and is powered by lithium polymer batteries. It can

carry payloads up to 0.4 pounds resulting in a total weight of no more than 8.1 pounds and has an

operational range of up to 0.6 nautical miles. The X8+/M can be operated with a maximum wind threshold of

25 miles per hour (MPH) for sustained winds and wind gusts up to 30 (MPH)

The X8+/M can be operated entirely by a touch-screen, map-based interface. This means the operator

only needs to command the system where to go, and the system does all the flying for the operator.

The X8+/M can be operated in both semi and fully autonomous flight modes, with the operator simply

clicking on a map to create a preplanned flight path for a flight. In addition, the operator can create

no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe

or unnecessary to fly over.

The UAS has built-in intelligent fault handling which allows the X8+/M to detect a system fault while

in the air and automatically fly back to its take-off location and land. Faults that can be detected

include: loss of communication; exceeding preset wind thresholds; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. Also a flight termination link - to prevent a "fly

away" or other potentially dangerous situation - is available to the operator.

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
The UAS Robbins Land Surveying, Inc. (D/B/A Robbins3d) proposes to use is constructed by DJI and referred to

as the Inspire 1. The Inspire 1 is commonly referred to as a quad copter (4 rotors and 4 motors) which weighs a

total of 6.5 pounds (lbs.) with payload and is powered by lithium polymer batteries, resulting in a total weight of no

more than 6.5 lbs. and has an operational range of up to 1.2 nautical miles. The Inspire 1 can be operated with a

maximum wind threshold of 22 miles per hours (MPH) for sustained winds and wind gusts up to 30 MPH.

The Inspire 1 can be operated entirely by a touch-screen, map-based interface. This means the operator

only needs to command the system where to go, and the system does all the flying for the operator.

The Inspire 1 can be operated in both semi and fully autonomous flight modes, with the operator simply

clicking on a map to create a preplanned flight path for a flight. In addition, the operator can create

no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe

or unnecessary to fly over.

The UAS has built-in intelligent fault handling which allows the Inspire 1 to detect a system fault while

in the air and automatically fly back to its take-off location and land. Faults that can be detected

include: loss of communication; loss of GPS lock; and low battery levels.

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. Also a flight termination link - to prevent a "fly

away" or other potentially dangerous situation - is available to the operator.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by

FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by

Robbins Land Surveying Inc. (D/B/A Robbins3D), an exemption from Part 21 Subpart H meets the requirements of

 an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC

§44701(f) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certificate, upon consideration of the size, weight, speed, operational capability and proximity to

airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that

the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions

proposed, will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate

without the restrictions and conditions proposed.

14 CFR 45.23(b) & 14 CFR 45.29: Marking of the aircraft; Display of Marks; Size of Marks

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport category aircraft to

be marked with letters between 2 inches and 6 inches high "limited", "restricted" "light-sport," "experimental," or

"provisional," near each entrance to a cabin, cockpit or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have

no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size

of the UAS, 2 inch lettering will be impossible. Robbins Land Surveying, Inc. (D/B/A Robbins3D) will mark the

UAS with the organization's name and address. A QR Code attached to the aircraft will also be linked to

Robbins Land Surveying, Inc. (D/B/A Robbins3D).

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
14 CFR 61.23: Medical certificates; Requirement and duration

Regulations provide that a person:

(1) Must hold a first-class medical certificate:

 - When exercising the pilot-in-command privileges of an airline transport pilot certificate;

 - When exercising the second-in-command privileges of an airline transport pilot certificate in a flag or

 supplemental operation in part 121 of this chapter that requires three or more pilots; or

 - When serving as a required pilot flight crew member in an operation conducted under part 121 of this

 chapter if the pilot has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:

 - Second-in-command privileges of an airline transport pilot certificate in part 121 of this chapter (other

 than operations specified in paragraph (a)(1)(ii) of this section); or

 - Privileges of a commercial pilot certificate.

Given the size of the UAS, their structure, the limited flight area and the safety features integrated into the

autopilot (among others the flight termination system), Robbins Land Surveying, Inc. (D/B/A Robbins3D) believes

that an Equivalent Level of Safety can be reached if the pilot-in-command has a valid driver's license.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS will not carry a

pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by

requiring the pilot operating the aircraft to have completed UAS manufacturers flight training before flying

a UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with

no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned

and coordinated in advance as set forth in the User Guide. The risks associated with the operation of the small

UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61

when drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by

14 CFR 61.113(a) and (b).

14 CFR 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will

be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory

standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in

the User Guide for maintenance and use of safety checklists prior to each flight an equivalent level of safety will

be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not

only because there is no pilot on board, but because there is no room or capacity to carry such an item on the

aircraft.

The equivalent level of safety will be maintained by keeping the User Manual at the ground control point where

the pilot flying the UAS will have immediate access to it.

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
14 CFR 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An

exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for

weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other

actions in the User Guide and safety checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functioning dual controls. By design, UASs and remotely

piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a

control box that communicates with the aircraft via radio communications. The equivalent level of safety is

provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the

UAS via radio signals from the controller and by the size and speed of the aircraft.

14 CFR 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to

be operated at less than the minimums prescribed, provided the person operating the helicopter complies with

any route or altitudes prescribed for helicopters by the FAA. This exemption is for a multi-rotor craft that flies

similarly to a helicopter, with vertical takeoff and vertical landing, which will typically operate at altitudes of 200

feet above ground level (AGL), so an exemption may be needed to allow such operations. The UAS will never

operate at altitude higher than 400 feet AGL and all operations will occur during daylight hours under Visual

Meteorological Conditions (VMC) only.

The equivalent level of safety will be achieved given the size, weight and speed of the UAS as well as the

location where it is operated. No flight will be taken without the permission of the property owner or local

officials. Because advance notice to the property owner and any on-site personnel, as well as the precautions

outlined below, all affected individuals will be aware of the planned flight operations.

Flight operations will be conducted at least 200 feet from all non-participating persons (persons other than the

pilot in command (PIC) or visual observer (VO), vessels, vehicles and structures, unless:

1. Barriers or structures are present that sufficiently protect non-participating persons from debris in the

event of an accident. The PIC will ensure that non-participating persons remain under such protection.

 If a situation arises where non-participating persons leave such protection and are within 200 feet of

 the UAS, flight operations will cease immediately and/or;

2. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has

 granted permission and the PIC has made a safety assessment of the risk of operating closer to those

 objects and;

3. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 14 CFR 91.119(a).

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be conducted at lease 5

miles from an airport and at least 3 miles from any city or densely populated area. The PIC or VO will provide

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an

airport. The FAA will have advance notice of all operations through the filing of notices-to-airmen.

Compared to flight operations with aircraft or rotor craft weighing far more than the UAS proposed herein and

carrying flammable fuel, any risk associated with our operations if far less than those presently presented with

helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude

operations of the UAS will ensure separation between these UAS operations and the operations of conventional

aircraft that must comply with Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising altitude by reference to an

altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available

before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an

exemption may be needed. An equivalent level of safety will be achieved by the PIC confirming the altitude of

the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to

operations in controlled environments and has a limited flight time which require an exemption from 14 CFR

91.151(a).

The battery powering the UAS provides approximately 20 minutes of powered flight. This would render the

UAS unable to meet the 30 minute reserve requirement in 14 CFR 91.151. Given the limitations on the

UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer

time frame for flight in daylight VFR conditions is reasonable.

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery reserve to

ensure that the UAS lands at the ground station with at least 20% of battery power (as determined by the

on-board monitoring system and the PIC), whichever happens first. This restriction would be more than

adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an on-board pilot. Therefore, there is

no ability or place to carry certification and registration documents or to display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where

the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed

in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter...," and others shall inspect or

maintain the aircraft in compliance with Part 43.

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
Given that these sections and part 43 apply only to aircraft with an airworthiness certificate, these sections

will not apply to Robbins Land Surveying, Inc. (D/B/A Robbins3D). Maintenance will be accomplished by the

operator pursuant to the User Guide. An equivalent level of safety will be achieved because these UASs are very

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If

mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 feet AGL.

As provided in the User Guide, the operator will ensure that the UAS is in working order prior to initiating flight,

perform required maintenance and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalent level of safety.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for precision aerial surveys enhances safety

while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much

larger, have combustible fuel, and carry an on-board human pilot. In contrast, a UAS weighing 8 pounds and

powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel

carried on board. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks

associated with manned aircraft flights.

Conducting aerial surveys with the 3D Robotics X8+/M and DJI Inspire 1, instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial

survey flight operations. By using battery power and electric motors, the 3D Robotics X8+/M and DJI Inspire 1

produces no air pollution and is a viable, environmentally conscious alternative to the cabin class, six cylinder

internal combustion twin engine aircraft that are typically utilized for aerial surveys, while burning approximately

20-30 gallons per hour of leaded aviation fuel. The X8+/M and Inspire 1, while reducing the carbon footprint of

aerial surveys, also reduce noise pollution as the UAS is propelled by battery powered electric motors rather than

an internal combustion engine.

EQUIVALENT LEVEL OF SAFETY

Robbins Land Surveying, Inc. (D/B/A Robbins3D) proposes that the exemption requested herein apply to civil

aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide

for at least an equivalent or even higher level of safety to operations under the current regulatory structure

because the proposed operations represent a safety enhancement to the already safe protocols followed by aerial

survey operations conducted with helicopters and other conventional aircraft.

Robbins Land Surveying, Inc. (D/B/A Robbins3D) will be bound by the following limitations when conducting its

UASs operations under an FAA issued exemption:

1. The UAS will weigh less than 9 pounds.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operations flight will be 20 minutes. Flights will be terminated at 20%

battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flight operations will be conduced 5 miles from an airport and at least 3 miles from any city or densely

populated area, which are depicted in yellow on VFR sectional charts.

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com
6. Flight operations within 5 miles of an airport require notification and approval from the local Flight

Standards District Office and airport controller.

7. Flight operations will occur during daylight hours and under visual meteorological conditions only.

8. The FAA will have advance notice of all operations through the filing of notices-to-airmen.

9. Minimum crew for each operation will consist of the UAS pilot and visual observer/camera operator.

10. The pilot and visual observer will have been trained in the operation of the UAS.

11. The pilot and visual observer will at all times be able to communicate by voice and/or text.

12. Written and/or oral permission from the relevant property holders will be obtained.

13. Flight operations will be conducted at least 200 feet from all non-participating persons, vessels, vehicles

and structures unless:

a. Barriers or structures are present that sufficiently protect non-participating persons from debris in

 the event of an accident. The pilot will ensure that non-participating persons remain under such

 protection. If a situation arises where non-participating persons leave such protection and are

 within 200 feet of the UAS, flight operations will cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has

granted permission and the PIC has made a safety assessment of the risk of operating closer to

those objects and;

c. Operations near the pilot or visual observer do not present an undue hazard to the pilot or visual

observer.

14. If the UAS loses communication or loses its GPS signal, the UAS will have the capability to return to a

safe, pre-determined location and land.

15. The UAS will have the capability to abort flight in case of unpredicted obstacles or emergencies.

PRIVACY

All flights will occur over private or controlled access property with the property owner's prior consent and

knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed

to be in the area where aerial photography will take place.

FEDERAL REGISTER SUMMARY

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, operating

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

security - provide more than adequate justification for the grant of the requested exemptions allowing commercial

operation of Robbins Land Surveying, Inc. (D/B/A Robbins3D) UAS for precision aerial surveys and aerial imagery

capture.

Sincerely,

Kenneth S. Robbins

Robbins Land Surveying, Inc.

Robbins Land Surveying, Inc.

www.Robbins3d.com

P.O. Box 1992 ~ Loganville, Georgia 30052-5258

Tel. 770.554.5810 Email. ken@robbinslandsurveying.com