U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

- S traub Surveying, LLC

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Straub Surveying, LLC (“Straub Surveying”), an Ohio based Professional Land Surveying and High Definiti on 3D Laser Scanning company equipped to operate an Unmanned Aircraft System (UAS), hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of a UAS commercially in airspace regulated by the Federal Avia tion Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Granting this exemption would allow Straub Surveying to enhance its existing Professional Land Surveying, Mapping, and 3D Laser Scanning services, through the use of a small, lightweight UAS

- the DJI Inspire 1

- and cloud

- based software, enabling the company to collect, process, and analyze high

- quality 3D imaging and videos for s urveying, mapping, and spatial analysis for a variety of construction, commercial, residential, and public uses, specifically targeting:

● Aerial land surveying and mapping

● Construction monitoring, planning & inspection

● Volumetric analysis of mining stockpil es

● Digital elevation models (DEMs)

● Existing conditions documentation

● Aerial photogrammetry and videography

● Building Information Modeling (BIM)

● Precision agriculture services

● Marketing services

● Increasing public knowledge of UAS and promoting safe UAS ope rations

Straub Surveying submits that because the UAS will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve at least an equiv alent level or greater ofPage 2 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com safety and benefit the public as a whole. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to " establish requirements for the safe operation of such aircraft systems in the national airspace system."

Straub Surveying is prepared to modify or amend any part of this request to satisfy your requirements. Please contact us at any time if you require ad ditional information or

clarification.

Sincerely,

___________________________ Michael A. Straub, PS

Straub Surveying, LLC

3580 Eldorado Drive Rocky River, OH 44116

Tel: (440) 333

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- 1700 • Info@StraubSurveying.com TABLE OF CONTENTS

GLOSSARY O F ABBREVIATIONS

................................ ................................ ............................. 4

SUMMARY

................................ ................................ ................................ ................................ .. 5

COMPANY INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ... 5

VEHICLE DESCRIPTION & BACKGROUND: DJI Inspire 1 UAS

................................ ............... 6

BASIS FOR PETITION

................................ ................................ ................................ ................ 6

INFORMATION TO SUPPORT PETITION, IN ACCORDANCE WITH 14 C.F.R. § 11.81:

......... 8

A. NAME AND ADDRESS OF THE PETITIONER.

................................ ................................ ............ 8

B. THE SPECIFIC SECTION(S) OF 14 CFR FROM WHICH STRAUB SURVEYING SEEKS

AN EXEMPTION.

................................ ................................ ................................ ........................... 8

C. THE EXTENT OF RELIEF STRAUB SURVEYING SEEKS, AND THE REASON STRAUB

SURVEYING SEEKS THE RELIEF.

................................ ................................ ............................. 11

D. THE REASONS WHY GRANTING STRAUB SUR VEYING’S REQUEST WOULD BE IN

THE PUBLIC INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A

WHOLE

................................ ................................ ................................ ................................ ........ 14

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETY, OR HOW THE EXEMPTION WOULD PROVIDE A LEVEL O F SAFETY AT

LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH STRAUB

SURVEYING SEEKS EXEMPTION.

................................ ................................ ............................ 16

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

................................ ... 26

G. ANY ADDITIONAL INFORMATION, VIEW S, OR ARGUMENTS AVAILABLE TO SUPPORT

STRAUB SURVEYING’S REQUEST.

................................ ................................ .......................... 27

CONCLUSION

................................ ................................ ................................ ........................... 27Page 4 of 28

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- 1700 • Info@StraubSurveying.com GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of In terest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingPage 5 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com SUMMARY

Straub Surveying, LLC seeks exemption from the requirements of 14 C.F.R § 61.113(a) & (b),
61.23, 91.7(a), 91.121, 91.151(b), 91. 405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and
91.417(a) & (b), to operate an Unmanned Aircraft System (UAS) pursuant to Section 333 of
the FAA Modernization and Reform Act of 2012 (FMRA). This exemption wi ll permit Straub
Surveying to pursue its commerc ial interests in providing services to clients interested aerial
data capture using a UAS.

COMPANY INTRODUCTION AND INTERESTS OF THE PETITIONER

As previously mentioned, the objective of Straub Surveying, LLC’s aerial photogrammetry and
surveying operati ons is to provide high

- quality 3D imaging and videos for surveying, mapping,
and spatial analysis for a variety of construction, commercial, residential, and public uses,
specifically targeting:

● Aerial land surveying and mapping

● Construction monitoring, pl anning & inspection

● Volumetric analysis of mining stockpiles

● Digital elevation models (DEMs)

● Existing conditions documentation

● Aerial photogrammetry and videography

● Building Information Modeling (BIM)

● Precision agriculture services

● Marketing services

● Inc reasing public knowledge of UAS and promoting safe UAS operations

Straub Surveying is a small, Ohio based Land Surveying and 3D Laser Scanning limited
liability company with over 30 years of professional land surveying and mapping experience.
The company is one of the few in Ohio to perform High Definition 3D Laser Scanning on
construction projects. It currently operates four surveying crews, mainly servicing General
Contractors on construction projects, most of which are repeat customers.

Furthermore, St raub Surveying’s use of the UAS will be performed under the supervision of a
Professional Land Surveyor whom, by virtue of his or her experience and licensing, technical
knowledge of GPS, plane geometry, trigonometry and spherical geometry inherently and

u niquely make s Straub Surveying a particularly well suited entity for the safe and efficient

commercial use of a UAS.Page 6 of 28

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- 1700 • Info@StraubSurveying.com VEHICLE DESCRIPTION & BACKGROUND: DJI Inspire 1 UAS

The UAS Straub Surveying seeks an exemption to operate for compensation or hire wit hin the
NAS is constructed by DJI and referred to as the Inspire 1. The DJI Inspire 1 is a vertical
takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS)

utilizing electronic tablet or smart phone systems. The DJI Inspire 1 has a maximum gross
weight of approximately 6 pounds 7.5 ounces, while having a length of 17.24 inches, width of
17.75 inches, height of 11.85 inches, and a maximum speed of approximately 42 knots. The
DJI Inspire 1 is equipped with four main rotors; driv en by Lithium Polymer battery powered

electric motors.

The Inspire 1 can be operated entirely by a touch

- screen, map

- based interface. The UAS can
be operated in both semi and fully autonomous flight modes, with the operator simply clicking

on a map to cre ate a preplanned flight path for a flight. In addition, the operator can create
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 positi oning 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 ot her potentially dangerous situation

- is available to the operator.

The DJI Inspire 1 UAS that will be operated by Straub Surveying will be registered in
accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,
Aircraft Regi stration, and marked in accordance with 14 C.F.R. Part 45, Identification and
Registration Marking.

BASIS FOR PETITION

Petitioner, Straub Surveying, pursuant to the provisions of the Federal Aviation Regulations
(14 C.F.R. § 11.61) and the FAA Moderniz ation and Reform Act of 2012 (FMRA), Section
333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator
to commercially operate the DJI Inspire 1 UAS in the National Airspace System (NAS), and for
an exemption from the req uirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,
91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and it s operation, Straub Surveying’s operation of the DJI Inspire 1 UASPage 7 of 28

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- 1700 • Info@StraubSurveying.com meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness
certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Straub Surveying reques ts relief from Sections 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for
maintenance that only apply to aircraft with an airworthiness certificate.

Straub Surveying submits that the request ed relief is proper since an equivalent level of safety
will be ensured. Straub Surveying will use experienced personnel or technicians to perform
maintenance, alterations, or preventive maintenance on the UAS using the methods,
techniques, and practices p rescribed in the UAS operating documents (i.e., the DJI Inspire 1

User Manual , Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B , D,
and E, respectively ). Furthermore, Straub Surveying will document and maintain all

maintenance re cor ds for the DJI Inspire 1 UAS using the Straub Surveyi ng UAS Monthly
Maintenance Log, attached hereto as Exhibit C.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command , is requ ested by Straub Surveying to the extent necessary to
allow a Pilot in Command (PIC) holding either an airline transport, commercial, private,
recreational, or sport pilot certificate, as well as a valid US driver’s license, and who has
demonstrated, by mee ting minimum flight

- hour and currency requirements, that the PIC is
able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption,
including evasive and emergency maneuvers and maintaining appropriate distances from
people, vesse ls, vehicles and structures.

Straub Surveying seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,
because the DJI Inspire 1 UA do es not require an airworthiness certificate in accordance with
14 C.F.R. Part 21, Subpart H. As such , S traub Surveying submits that the company will
ensure that the DJI Inspire 1 UAS are in an airworthy condition, prior to every flight, by
determining that the UAS are in compliance with the operating documents (i.e., the DJI Inspire

1 User Manual , Maintenan ce Manual, and Safety Guidelines, attached hereto as Exhibits B,
D, and E, respectively, as well as Straub Surveying’s UAS Monthly Maintenance Log,
attached hereto as Exhibit C), and that the aircraft are in a condition for safe flight.

Straub Surveying also seeks an exemption from the requirements of Section 91.121, entitled
Altimeter Settings , as the DJI Inspire 1 UAS will not have a typical barometric altimeter
onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via
Global Positioning System (GPS) equipment and radio communications telemetry data link,
which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude
information, combined with Straub Surveying’s operation of the DJI In spire 1 UAS withinPage 8 of 28

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- 1700 • Info@StraubSurveying.com vis ual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section

91.121.

Additionally, Straub Surveying seeks an exemption from the requirements of Section
91.151(b), entitled Fuel requirements for fl ight in VFR conditions . Straub Surveying submits
that safety will not be affected by operation of the DJI Inspire 1 UAs during daylight hours in
visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery
power to fly for a total duration of approximately 13.5 minutes to the first point of intended
landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

INFORMATION TO SUPPORT PETITION, IN ACCORDANCE WITH 14 C.F.R. § 11.81:

A. NAME AND ADDRESS O F THE PETITIONER.

The name and address of the Petitioner and point of contact is:

Straub Surveying, LLC

Attn: Michael A. Straub

, PS

3580 Eldorado Dr. Rocky River, OH 44116

Tel: (440) 333

- 1700

Email: Info @StraubSurveying.com

B. THE SPECIFIC SECTION(S) OF 14 CFR FROM WHICH STRAUB SURVEYING SEEKS

AN EXEMPTION.

1. Straub Surveying Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) presc ribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as P IC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or pr operty for compensation or hire.

2. Straub Surveying Seeks Exemption From The Requirements Of Section 61.23.

Section 61.23, entitled Medical certificates; Requirement and duration , prescribes the following, in relevant part:Page 9 of 28

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- 1700 • Info@StraubSurveying.com (a) Operations requiring a me dical certificate. Except as provided in paragraphs (b) and (c) of this section, a person

—

(1) Must hold a first

- class medical certificate:

(i) When exercising the pilot

- in

- command privileges of an airline transport pilot certificate; (ii) 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 (iii) When serving as a required pilot flight crew member in an operation

conduct ed 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:

(i) Second

- in

- command privileges of an airline transport pilot certificate in part 121 of this chapt er (other than operations specified in paragraph (a)(1)(ii) of this section); or (ii) Privileges of a commercial pilot certificate;

3. Straub Surveying Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworth iness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. Straub Surveying Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subse ction (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—

(1) Below 18,000 feet MSL, to

—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

5. Straub Surveying Seeks Exemption From The Requirement s Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:Page 10 of 28

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- 1700 • Info@StraubSurveying.com (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

6. Straub Surveying Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, en titled Maintenance required , subsection (a), states the following:

Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragrap h (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

7. Straub Surveying Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter[.]

8. Straub Surveying Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 4 3.7 of this chapter;

or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

9. Straub Surveying Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Main tenance records

, subsections (a) and (b), states the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this se ction:Page 11 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com (1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, r otor, and appliance of an aircraft. The records must incl ude

- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate nu mber of the person approving the aircraft for

return to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the t ime since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of complia nce, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

alteratio n to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained unti l the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. THE EXTENT OF RELIEF STRAUB SURVEYING SEEKS, AND THE REASON STRAUB

SURVEYING SEEKS THE RELIEF.

1. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding either an airline transport, commercial, private, recreational, or sport pilot certificate, as well as aPage 12 of 28

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- 1700 • Info@StraubSurveying.com valid US driver’s license, and who has met certain flight

- hour and currency requirements, to conduct th e proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any bu siness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Straub Surveying submits that an equivalent le vel of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a

m anner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Straub Surveying

submits tha t all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Straub Surveying’s business; and (2) will not carry passengers or property for compensation or hire

.

2. Extent Of Relief Straub Su rveying Seeks And The Reason Straub Surveying

Seeks Relief From Section 61.23.

Relief from portions of Section 61.23, entitled Medical certificates; Requirement and
duration, is requested to the extent necessary to allow a designated PIC to have a valid

U S driver’s license issued by the state in lieu of an airman medical certificate.

Given the size, weight, structure, limited flight area and the safety features integrated into the DJI Inspire 1 UAS, Straub Surveying believes that an Equivalent Level of

Sa fety can be reached if the PIC has a valid US driver's license, as it shows the ability to follow safe operating instructions for a man

- controlled vehicle.

3. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying

Seeks Relief From Section 9 1.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Straub Surveying to determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in complian ce with the DJI Inspire 1 operating documents.

Straub Surveying seeks the requested relief because the DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Straub Surveying will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., the DJI Inspire

1 User Manual , Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B, D, and E, respectively, as well as Straub Surveying’s UAS MonthlyPage 13 of 28

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- 1700 • Info@StraubSurveying.com Maintenance Log, attached hereto as Exhibit C), prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

4. Extent Of Reli ef Straub Surveying Seeks And The Reason Straub Surveying

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure s ensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Straub Surveying seeks the requested relief because the DJI Inspire 1 UAS’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent lev el of safety will be maintained since the DJI Inspire 1 UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC wit h altitude

information of the UA on the heads

- up display of the GCS.

5. Extent Of Relief Straub Surveying Seeks And The Reason Straub Surveying Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR c onditions , is requested to the extent required to allow flights of the battery powered DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first poi nt of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Straub Surveying seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Ins pire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Straub Surveying proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Inspi re 1 UAS, the DJI Inspire 1 operating documents, and Straub Surveying’s proposed operating limitations, ensure that Straub Surveying will safely operate the battery powered DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.Page 14 of 28

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- 1700 • Info@StraubSurveying.com 6. Extent Of Relief Straub Surveyi ng Seeks And The Reason Straub Surveying Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an air worthiness certificate, Straub Surveying requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Straub Surveying will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documen ts (i.e., the DJI Inspire 1 User Manual

, Maintenance Manual, and Safety Guidelines, attached hereto as Exhibits B, D, and E, respectively). Furthermore, Straub Surveying will document and maintain all

maintenance re cords for the DJI Inspire 1 UAS using the company’s UAS Monthly Maintenance Log, attached hereto as Exhibit C.

D. THE REASONS WHY GRANTING STRAUB SURVEYING’S REQUEST WOULD BE IN THE PUBLIC INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A

WHOLE

By granting this request for exemption and al lowing Straub Surveying’s use of the DJI Inspire 1 UAS, the public will experience decreased congestion of the NAS as well as significant environmental, public safety, and economic benefits, all of which are in the public interest. In addition, the benefit s of Straub Surveying’s proposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Inspire 1 UA S is battery powered and serves as a safe, eff icient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce th e amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airpor ts caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UA S does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would

result in fewer aircraft tha t must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS.Page 15 of 28

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- 1700 • Info@StraubSurveying.com Conducting aerial acquisitions with the DJ I Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electri c motors, the DJI Inspire 1 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS is propelled by battery powered electric motors, rather tha n an internal combustion engine.

In addition to environmental benefits, using the DJI Inspire 1 UAS will significantly reduce or completely eliminate the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately 6 pounds 7.5 ounces while having a length of 17.24 inches, width of 17.75 inches, height of 11.85 inches), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of appro ximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

As far as efficiency, using the DJI Inspire 1 UAS, as opposed to manned aircrafts, will provide significant efficiency enhancements that will benefit the public as a whole. For

ex ample, a mission does not need a long preparation time, long deployment constraints, or long waiting time for perfect weather conditions. Initial results are accessible directly on

- site, which is impossible with images provided by satellites or

manned airc rafts. This will ultimately increase the speed of projects, as land surveying is only one of the first steps of many involved with completing a construction project. When the land surveying process can be completed quicker, the rest of the project can

proc eed as planned, companies can reach deadlines with no delays, and the public

benefits.

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Straub Surveying, to remain competitive and contribute to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational flexibility compared to mannedPage 16 of 28

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- 1700 • Info@StraubSurveying.com aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the DJI Inspire 1 UAS, compan ies such as Straub Surveying can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growt h of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending, improves local, state, and federal tax revenues, and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Straub Surveying’s pro posed operation of the DJI Inspire 1 UAS will not
implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in
compliance with operating documents (i.e., the DJI Inspire 1 User Manual

, Maintenance Manual, and Safety Guidelines ), which require property owner

involvement as well as local law enforcement notification , and in accordance with the
Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R.
§ 91.119.

In addition, Straub Surveying submits t hat all f lights 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.

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

STRAUB SURVEYING SEEKS EXEMPTION.

1. Reason s Why The DJI Inspire 1 UAS Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Straub Su rveying’s operation of the DJI Inspire 1 UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthi ness certification and sets forth requirements for considering whether a UAS will create a hazard toPage 17 of 28

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- 1700 • Info@StraubSurveying.com users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In Gen eral

. -- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airs pace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section

334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a haz ard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Straub Surveying submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to F MRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe

Characteristics.

Th e DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 UAS.

The techni cal specifications of the DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Inspire 1 UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided in th e DJI Insp ire

1 User Manual , attached hereto as Exhibit B.Page 18 of 28

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- 1700 • Info@StraubSurveying.com iii. The DJI Inspire 1 UAS Is Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

If the Control Link is lost, the DJI Inspire 1 the UAS will remain stationary, in flight, for 3 seconds or more. If, afte r 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

s hutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 can be found at pages 13 through 15 of the DJI Inspire 1 User
Manual, attached hereto as Exhibit B, as well as the DJI Inspire 1 Safety Guidelines, attached hereto as Exhibit E.

iv. The DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software can be located in the DJI Inspire

1 User Manual. The DJI Inspire 1 User Manual is attached hereto as

Exhibit B.

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Straub Surveying will utilize a PIC holding either an airline transport, commercial, private, recreational, or sp ort pilot certificate, as well as a valid US driver’s license, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations. Additionally, a visual observer (VO) will assist the PIC during flight time. The UA S will be operated within the visual line of sight (VLOS) of the PIC and VO at all times, though the VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuan t To Specific Operating Limitations. In seeking this exemption, Straub Surveying proposes to commercially operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the foll owing specific operating limitations:

1. Operations authoriz ed by this grant of exemption are limited to the DJI Inspire 1 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

ca librated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater thanPage 19 of 28

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- 1700 • Info@StraubSurveying.com 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 tha n 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 m ust 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 Administ rator 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 w hich 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 UA S 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. Fu nctional 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 res ponsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.Page 20 of 28

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- 1700 • Info@StraubSurveying.com 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 mu st 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 be en performed and the UAS is found to be 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 Columbia, 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 air craft 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 purpo ses 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 t erms 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, an d 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

cond itions (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.Page 21 of 28

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- 1700 • Info@StraubSurveying.com 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 les s than 3 statute miles

from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstac les 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

h ave identification (N

− Number) 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 giv e 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, a nd 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 sit uation 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;

b. The owner/controller of any vessels, vehicles or str uctures 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.Page 22 of 28

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- 1700 • Info@StraubSurveying.com The PIC, VO, operator trainees or essent ial 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 prop erty 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 m ust 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

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Straub Surveying submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC wi ll be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including eva sive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Straub Surveying’s proposed area of operations and the operating limitations set forth, as well as the airmanship skills necessar y to safely operate the DJI Inspire 1 UAS, Straub Surveying submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Straub Surveying’s specific proposed flight operations. In addition, 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 fligh t 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 DJI Inspire 1 User Manual, Maintenance Manual, and Safety Guidelines

. The risks associated with the operation of the small UAS are so diminished from the level of risk associated with commercial operations contem plated 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).

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstan ces similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).Page 23 of 28

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- 1700 • Info@StraubSurveying.com As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Straub Surveying’s proposed operations. The Administrator has held that prior documented flight exper ience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operatio ns), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No.

1 1062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclu sive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 t akeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the peti tioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights

can also be conducte d under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14

C.F.R 91.119.

Exemption No. 11138 a t page 15.

Accordingly, Straub Surveying will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely opera te the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 9 1.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Straub Surveying will ensure that the DJI Inspire 1 UAS is in an airworthy condition compliant with its operating documents and as stated in the

conditions and limitations herein.Page 24 of 28

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- 1700 • Info@StraubSurveying.com Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safet y.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks fro m the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Straub Surveying’s operation of the DJI Inspire 1 UAS within visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety

e quivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,
11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a re sult of (1) the technical specifications of the DJI Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Straub Surveying will ensure that it will safely operate the batt ery powered DJI Inspire 1 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minu tes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

powe r, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft toPage 25 of 28

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- 1700 • Info@StraubSurveying.com operate at less than the minimums prescribed in Section 91.151, including Exemption
Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Straub Surveying submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.41 7(a) & (b) will be met because Straub Surveying will use trained technicians to perform maintenance,

al terations, and preventive upkeep using the methods, techniques, and practices prescribed in the operating documents, specifically the DJI Inspire 1 User Manual

, Maintenance Manual, and Safety Guidelines (attached hereto as Exhibits B, D, and E, respectively)

.

Furthermore, Straub Surveying will document and maintain all maintenance records for the DJI Inspire 1 UAS using Straub Surveying’s UAS Monthly Main tenance Log

, attached hereto as Exhibit C.

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 ari se, the UAS can land immediately and will be operating from no higher than 400 feet AGL . As provided in the DJI Inspire 1 User

Manual

, Maintenance Manual, and Safety Guidelines (attached hereto as Exhibits B, D, and E, respectively), the operator will ensu re that the UAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. The FAA has previously granted relief specific to UAS in
circumstances similar, in all materia l respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

In consideration of Straub Surveying’s proposed operati ng limitations, the operating documents, and the technical aspects of the DJI Inspire 1 UAS, Straub Surveying submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).Page 26 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Straub Surveying requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Su bpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national

securit y; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft . Section 21.16, entitled Special

Conditions , states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety sta ndards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.1 6, the FAA may prescribe special conditions for Straub Surveying intended operation of the DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F .R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTERPage 27 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com The Rules From Which Straub Surveying Seeks Exemption:

Straub Surveying, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 61.23 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Straub Surveying Seeks:

This exemption will permit Straub Surveying , LLC to commercially operate the DJI Inspire 1 UAS Unmanned Aircraft System (UAS) for the purpose of conducting precision aerial surveying services for a variety of construc tion, commercial, residential, and public uses

.

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO
SUPPORT STRAUB SURVEYING’S REQUEST.



### This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which d irects the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Straub Surveying’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthines s certification.

As discussed in detail above, Straub Surveying will operate the DJI Inspire 1 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Straub Surveying seeks an exemption pursuant to 14 C.F.R. §11.61 and

Section 333 of the FAA Modernizati on and Reform Act of 2012 , which will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting precision aerial surveying services over small, defined operatio nal areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while

also advanc ing the interests of the public.

WHEREFORE, in accordance w ith the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Straub Surveying respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b ), 61.23, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Straub Surveying to operate the DJIPage 28 of 28

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3580 Eldorado Drive • Rocky River, Ohio 44116 Phone (440) 333

- 1700 • Info@StraubSurveying.com Inspire 1 UAS commercially for the purpose of conducting precision aerial surveys, for a variety of co nstruction, commercial, residential, and public uses

.

Dated: November 23, 2015

Respectfully submitted,

___________________________ Michael A. Straub, PS

Straub Surveying, LLC

3580 Eldorado Drive Rocky River, OH 44116

Tel: (440) 333

- 1700 Info@Straub Surveying.com

Appendices:

EXHIBIT A

– DJI Inspire 1 Specifications Data Sheet

EXHIBIT B

– DJI Inspire 1 User Manual

EXHIBIT C

– Straub Surv eying UAS Monthly Maintenance Log

EXHIBIT D

– DJI Inspire 1 Maintenance Manual,

EXHIBIT E

– DJI Inspire 1 S afety Guidelines