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August 5 , 2015

U. S. D e p a rtm e nt of T r a n sport a t i on
Do c k e t Man a g e ment S y s tem

1200 N e w J e rs e y Av e

. S E

W a shin g ton, DC 20590

R e : P e ti t ion for Exemption under the FAA Modernization and Reform Act of 2012,

Public Law 112

- 95

, February 14, 2012, Section 333 for the use of Un m a nn e d A e r ial

S yst e m s ( U A S ) f or aerial imaging, mapping, inspections, and sensing.

D ea r Sir or M a d a m,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 and per Title 14 of the Code of Federal Regulations (CFR), Maul Foster & Alongi, Inc. (MFA)

, an environmental consulting and engineering company, hereby applies f or an exemption from the listed F ederal A viation R egulations (FAR) to allow commercial operation of its unmanned aerial systems (UAS) to provide aerial imaging, mapping, inspections

, and sensing for its clients.

S ec tion I. P e ti t io n e r C o n ta c t In f o r m ation

Steven P. Taylor, PE Maul Foster & Alongi, Inc. 400 East Mill Plain Boulevard, Suite 400 Vancouver, Washington 98660

B usiness: (360) 694

- 2691

Em a i l : staylor@maulfoster.comPage 2 of 

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S ec tion II. T h e sp ec i f ic S ec tions of Title 14 C F R from which MFA w is h e s to s ee k ex e m p tion:

1. Ch a pter 1, S ub c h a pter C, P a rt 21, Subp a rt H (§21.171

- §21.199)

2. Ch a pter 1, S ub c h a pter C, P a rt 45, § 45.23 (a )

3. Ch a pter 1, S ub c h a pter D, P a rt 61, § 61.113 (a )

4. Ch a pter 1, S ub c h a pter D, P a rt 91, §91. 7 ( a )

5. Ch a pter 1, S ub c h a pter D, P a rt 91, § 91.119 ( d)

6. Ch a pter 1, S ub c h a pter D, P a rt 91, § 91.121

7. Ch a pter 1, S ub c h a pter D, P a rt 91, § 91.151(a)

8. Ch a pter 1, S ub c h a pter s D & H

, P a rt s 45, 61, and 91, § 45.23(b); §61.113(a)(b); §91.7(a); §91.9(b)(2); § 91.103(b); § 91.109; § 91.119; § 91.121; § 91.151(a);
§ 91.203(a)(b); § 91.405(a); § 91.407(a)(1); § 91.409(a)(2); § 91.409(a)(2) ; and § 91.417(a)(b)

.

S ec tion III. MFA is re qu e sti n g re l i e f f r om e xisti n g re g u latio n s for these UAS applications:

MFA is r e qu e st i n g exemption from these Tit l e 14 C F R re g ulations so that it may use UAS platforms for aerial mapping . We believe this technology can benefit our company

, our clients

, and can directly benefit the public as a whole

. The extents of our applications are listed below:

• P h otog r a mm e t r y Ap p l i c ation s : B y usi n g fi x e d, down wa r d

- fa c ing ca m e r a s, photo g r a m m e t r y e n a b l e s us to create high

- resolution aerial mosaics of

o v e rl a p p e d a e ri a l i mag e s for use in g e o sp a t i a l softw a re ( e.g., G I S )

. MFA is an expert in providing GIS services and solutions to a broad client base

, a nd would like the ability to provide r a p i d d e l i v e r y of h i g h

- r e solu t ion orth o

- r e c t i fi e d photos to

c l i e n ts r e qu e st i ng the s e prod u c ts. There are many advantages of using UAS for

aerial mapping , including : safe and controlled mission planning; ease of deployment; a significant reduction of cost ; and use in GIS for spatial analysis throughout the project lifecycle. I n addition, flying below current restricted

altitudes allows much more detailed images than traditional aerial photographs. ( A pp e ndix F i g u r e 1 .)

• Digital surface modeling (3D): Photogrammetric science allows us to utilize the same overlapping photos that produce our high

- resolution ortho

- mosaics to generate digital elevation models for 3D analysis. These models can be used for volume estimates, surface flo w diagrams, biomass cal culations, inundation mapping, and feature extraction to assist with asset management.

• Site surveying (photos/video) : In an effort to provide our clients with aerial perspectives of their sites, we wish to add aerial photography and videography to

our pro fessional services. UAS has the ability to capture unique perspectives that are not available with the use of traditional aerial photography. Aerial photos and videos can help with inspections, site assessment, asset management, engineering design , and in general, improved communications to our clients and regulatory agencies

.Page 3 of 

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S ec tion IV. How MFA ’s Exe m ption w i l l b e n e f it t h e P ub l i c as a w h ole.

UAS technology allows MFA to provide the services listed in Section III and consequently benefit the public as a whole. MFA is actively working o n projects that promote environmental conservation, environmental cleanup, economic development, and asset management. UAS technology allow s MFA to obtain data with the use of much smaller aerial platforms ; the data

- gathering process using

traditional methods can be expensive, dangerous, and time

- consuming . The points

below illustrate the benefits MFA can provide by using UAS :

• MFA is a local industry leader in the Pacific Northwest, is an active participant in regional conferences, and has many business partners and clients across a variety of sectors. MFA’s exemption would provide our firm with the unique opportunity to be an ambassador of safe UAS flying pract ices and to provide data that can be beneficial to the general public. One of MFA’s employees is a current master’s student in the Portland State University Geography Department, and has been very active in promoting safe UAS flying/data

- collection practic es in the Geography and Urban Planning departments.

• MFA’s mission is to provide environmental solutions for brownfield redevelopment, environmental cleanup, and community planning issues. MFA has partnered with the National Oceanic Atmospheric Association , the U.S. Environmental Protection Agency, and the U.S. Army Corps of Engineers, to name a few. MFA is actively involved in making our world a better place.

• Conservation: MFA works with land trusts throughout the Northwest to develop conservation planning strategies and identify land acquisition opportunities that benefit native wildlife species and soil s that support food production. As population centers expand, it is imperative t o steward and monitor these habitats and working land easements as many allow public access for recreation activities or economically support local farming communities. Flying UAS will lead to increased efficiency and safety for annual easement compliance monitoring of large, inaccessible or difficult to reach lands. Monitoring of restoration activities and soil health will be enhanced from acquisition of high

- spatial resolution imagery.

• Environmental Cleanup: MFA has been involved in environmental cleanu p and engineering strategies for 19 years. Transitioning sites from a substantial environmental liability into a productive asset requires applying science and technology with a deep understanding of regulatory requirements, available funding, market force s, and site conditions. MFA has worked on hundreds of cleanup projects t hroughout the greater Northwest and we are experts in providing our clients with the knowledge and strategies to fit their project’s needs.

• Economic Development: Our urban planning pr ofessionals are active in projects involving r edevelopment, job growth and leveraging existing assets. Our team possesses the problem

- solving skills and creative insights to create opportunities,

facilitate partnerships, and gain community support. Results

- oriented planning is focused on achieving desired outcomes and adding value to projects andPage 4 of 

### 15

communities . Community planning, strategic planning and policy analysis and master plan development are examples of MFA’s contribution to this sector. UAS

c an benefit these projects by providing the technology to gather aerial perspectives and imagery to help planners visualize potential developments and impacts on the landscape.

• Asset Management: Utilities are the backbone of our everyday lives. From

invent ory development and streamlined field data collection, to systems integration with operation and maintenance software, we help engineers, dispatchers, accountants, and crews better manage critical assets. We provide enterprise asset management solutions to help municipalities and businesses maintain spatial inventories of their resources. UAS can generate these data; from high

- resolution aerial imagery for resource analysis, to 3D

- object extraction, these tools can be utilized to provide our clients with th e asset management solutions they require.

UAS Advantages and Efficiencies versus Traditional Methods:

• UAS offers a more affordable option for aerial surveying. Traditional techniques

are often intensive operation s involving full

- size aircraft. UAS

- acquired data come at price, but this technology is much more affordable for consumers

because of low overhead costs versus the combined cost s of operating a

manned aircraft or helicopter for aerial mapping. These details and other

benefits of UAS mapping are listed below :

o Costs of the aircraft, the pilot, and the air traffic control can be a prohibiting factor; also, F AR a l t i t ude r e strictions (14 C F R §91.119) m a y

a f f e c t the v a lue of the end prod uc t

.

o The cost of fuel is often passed along to the organizations hiring the

aircraft services

.

o E l e c tri c

- pow e r e d UAS have fewer environmental impacts than fossil

fueled

, full

- sized aircraft

.

o N oise p ol l ut i on is reduced.

o Catastrophic failures of aircraft happen every day around the world

, resulting in loss of life, property damage, and legal disputes. UAS s operate at lower altitudes, and safe flying practices can dramatically lower or eliminate the risk of potential disasters

.

o The economic benefit from UAS in 2025 is projected to be $80

mi llion and more than 100,000 jobs created (Source: A ssociation for Unmanned Aerial Systems )

.

• A UAS ’s unique ability to operate below forbidden manned

- aircraft operations altitude thresholds provide s us with the tools to observe our earth in ways never

before seen. UAS offers an inexpensive aerial platform that can be equipped

with a variety of different sensor types for particular application s . Air quality monitoring sensors allow us to address growing c oncerns about air pollution in

urban areas. The use of i nfrared and thermal imaging sensors has dramatically

increased in agricultural applications where crop health and moisture stress arePage 5 of 

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valuable indicators allowing far mers to more efficiently monitor t heir crop yields.

Low costs of UAS allow the temporal resolution needed for farmers to aggregate these useful data to precisely apply irrigation and herbicides and to determine

harvest times.

S ec tion V. Re ason s why MFA ’s e xe m ption will n ot adve r s

e ly affect safety , or h ow the e x e m p tion w o u ld p r ov i d e a lev e l o f sa f e ty at l e ast e qu al to t h e e xisti n g r u le.

MFA is filing this exemption request so that it can include UAS as a service sector for our existing clients and potential future clients. The techniques and technologies listed in
Section III are practices that are conducted at a low risk to human life and to property.
MFA ’s intended area of operations will not be focused in urban areas; our operations will be safely conducted and our flight areas will never exceed an area larger than 0.5 square mile. We are committed to preflight check procedures, which includes always flying with a two

- person team : a visual observer and a pilot

- in

- command (PIC).

After logging nearly 100 hours of flying, testing, and processing data, the MFA flight team is committed to fully understanding UAS technology and its capabilities and limitations. We are consistently monitoring ind ustry trends in technology and are pursuing object

- detect

- and

- avoid systems and add

- on fail

- safes such as parachute deployment systems

— which can effectively and safely deliver a failed unmanned aircraft to the ground should a malfunction occur mid

- flight.

MFA ’s UAS Fle e t S p ec i fi c at i o n s

MFA ’s unmanned

- aircraft fleet consists of two quad copters made by American company 3D Robotics (3DR) . The IRIS+ was our first UAS : a great prototype aircraft that

allowed MFA to research and develop data acquisition schemes that minimized the impact on h uman beings, manned aircraft, and infrastructure. The X8

- M and the ATI AgBot are more advanced craft designed for mapping and creating the high

- resolution

dataset s that are opt imized for GIS mapping and spatial analysis. The eBee fixed

- wing craft is a large

- area survey tool that MFA would operate in rural areas only.

These aircrafts’ specifications are listed below:

1) 3D Robotics IRIS+ quad

- rotor ( four

- prop e l l e r quad fr a m e, plast i c / polymers ) :

• Tot a l w e i g ht wi t h ma x i m um allow a ble p a y load: 3.6 lb

.

• Dimensions: g rea test w i dth: 21. 6 5 "

, h e i g ht ( w i t h leg extensions ) : 7 .5 ".

• M a x i m um sp ee d: 40 mph

.

• B a t t e r y s y stem ( 4

- c e l l

, 11.1 vol t

, 5

, 100 m Ah l i th i u m

- po l y me r ) p r ovides 16 to 2 2

m i nutes of fli g ht t i m e (depending on payload)

.

• 3DR Pixhawk 32

- bit flight controller with Cortex M4 CPU ( w i t h global positioning system [ GPS ] a nd c o mpass) is i nstalled on th i s UAS

, a nd is the

most a dv a n ce d s y st e m cu r r e nt l y a v a i l a ble, w i th l a test fi r mw a re r e l e a s e

.Page 6 of 

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• 3DR “LiveView” F i rst

- P e rson V iew ( F P V ) kit increases flight safety ; p rovid e s

a r e a l

- t i me vid e o feed f r om the IRIS+ to a v i d e o mon i tor mounted on radio controller

.

• 3DR IRIS+ Operation Manual can be found here: http://3drobotics.com/wp

content/uploads/2015/02/IRIS

- Plus

- Operation

- Manual

- vH

- web.pdf

2) 3D Robotics X8

- M M u l t i

- rotor ( eight

- prop e l l e r quad fr a m e

, aluminum ):

• Tot a l w e i g ht wi t h ma x i m um allow a ble p a y l o a d: 7

. 3 lb

.

• Dimensions: g rea test w i dth: 20.1 "

, h e i g ht ( w i t h landi n g g e a r ) : 11.8 ".

• Maximum sp ee d: 38 mph

.

• B a t t e r y s y stem ( 4

- c e l l

, 14.8 vol t

, 10,000 m Ah l i t h iu m

- po l y m e r) p rovid e s 14

m i nutes of fli g ht t i m e at ideal operating conditions

.

• 3DR Pixhawk 32

- bit flight controller is also i nstalled on this unit

.

• 3DR “LiveView” FPV kit is also installed on this unit.

• 3DR X8

- M and X8+ Operation Manuals can be found here: http://3drobotics.com/wp

- content/uploads/2014/10/X8M

- Operation

- Manual

v1.pdf http://3drobotics.com/wp

- content/uploads/2014/11/X8+

- Operation

- Manual

vA.pdf

3) Aerial Technology International (ATI ) AgBot ( four

- prop e l l e r quad fr a m e

, carbon

fiber /aluminum ):

• Tot a l w e i g ht wi t h ma x i m um allow a ble p a y l o a d: 10.4 lb

.

• Dimensions: g reatest width: 40.5 "

, h eight (with landing gear): 13.2 "

.

• Maximum sp ee d: 38 mph

.

• Battery system (dual 6

- cell, 6,500 mAh lithium

- polymer) provides 26+ minutes of flight time ( depending on payload)

.

• 3DR Pixhawk 32

- bit flight controller is also i nstalled on this unit

.

• 3DR “LiveView” FPV kit is also installed on this unit.

• ATI is a local company here in Portland, OR and they provide maintenance and expertise on the equipment they manufacture.

• ATI AgBot Data

- sheet can be found here:
http://www.aerialtechnology.com/wp

- content/uploads/2015/03/AgBOT

- Data

Sheet

- 150

- 1.pdf

4) Sensefly eB ee ( fixed

- wing

, foam/carbon structure and composite parts ):

• Tot a l w e i g ht wi t h ma x i m um allow a ble p a y l o a d: 1.5 6 lb

.

• Dimensions: wing span : 38 ".

• Maximum sp ee d: 50 mph

.

• Battery system ( 11.1 volt

, 2,150 mAh lithium

- polymer) provides up to 45 minutes of flight time

.

• Sense f ly autopilot/ flight controller

.Page 7 of 

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• Sensefly radio tracker and eMotion ground station software allow accurate

in

- flight monitoring of the a ircraft ’ s position at all times and allows reprogramming and landing point modification mid

- flight in case of

emergency.

• Sensefly eBee operating brochure can be found here:

https://www.sensefly.com/fileadmin/user_upload/documents/brochures/eBee_en. pdf

Fl i g h t Co n troller a n d F ai l

- S afe S y ste m s

The MFA UAS research and development team has been very impressed with the 3DR Pixhawk flight controller (autopilot) found in the IRIS+, X8

- M and ATI AgBot . The flight

controller allows customizable fail

- safes and added features to ens ure safe flying and landing of the aircraft:

• G P S A t ti t

ud e Con tr ol: The orig i n of f l i ght latitude and longitude are recorded

when the UAS first takes off

. The aircraft’s onboard GPS allows the UAS to hold its position, and does not stray from it, unless the flight mode is changed by the PIC. This provides a level of safety that prevents the UAS to stray or drift and which poses a risk to personal injury or property damage.

• A t ti t

ud e Cont r ol: The PIC has the option of disabling the GPS

- assisted flight mode by switching to “standard” mode. This allows the operator to control

the UAS in a manual flying mode. This method maintains altitude and uses the onboard stability system to prevent irregular flight performance. This can also be used as a “mission abort” mechanism during an autonomous mission if the PIC wishes to abandon a mapping mission because he or she deems

the aircraft ’s performance to be suspicious or if there appears to be risk of

harm ing persons or damaging property.

• R e tu r n

- t o

- Land ( R T L

): The RTL function can be deployed at any time during flight if the PIC deems the flight to be in danger of becoming a risk to persons or property or to the UAS itself. The RTL fail

- safe, when enabled, will program the UAS to return to its point of origin and land autonomously. This

fail

- safe is a switch on the flight radio controller. The RTL is also auto

- enabled

when the UAS experiences a loss of remote

- control signal, loss of GPS signal, or low battery. This is a unique ability of an unmanned aircraft equipped with a flight controller to bring the aircraft back to the ground in the event of an

emergency.

• Sensefly eBee Flight Controller and Fail

- safes: The eBee fixed

- wing craft has similar RTL capabilities. The aircraft will return to its launching point if it detects low battery, strong wind, or if the aircraft is traveling too far from its take

- off location. In the unlikely case of a loss of GPS signal, the air craft will land immediately in a circling patter n and at a slow speed so as to minimize the risk

to third

- parties and property. The low weight and rear

- mounted single prop design also minimizes the risk to people and property in the event of a sudden

landi ng. The aircraft will continue to return to land at the point of origin if GPS signal is restored.Page 8 of 

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UAS Operating Risks

MFA is very knowledgeable of the risks associated with flying unmanned aircraft. As with any aircraft, there are circumstances beyond the control of the flight team. MFA is committed to practicing proper pre flight checks, continuous pilot training, and regular

aircraft maintenance to ensure that the technology will perform in a safe and controlled manner. It is important to acknowledge the risks associated with flying UAS . T hese are

outlined below:

• Hardware Failure

. Examples of a physical failure of this type include a failed propeller motor or a break in the frame of the aircraft that could adversely affect flight performance and cause a malfunction. These failures are beyond the flight controller’s ability to stabilize the UAS and could result in a crash landing. As with any machine, mechanical failure is an innate risk, b ut can be avoided if proper pre flight safety checks and

routine maintenance of the aircraft are conducted

.

• Electrical Failure

. As discussed previously, mechanical failures can adversely affect flight performance and can cause the UAS to crash. Similarly, electrical shortages or failures can impact the battery, telemetry receiver /radio, flight controller, motors, GPS, or inertial measurement units. These also have the potential to cause impact with the ground.

• Wi ld l i f e

. Although highly unlikely, wildlife can pose a threat to flight performance. Whether it is a chance encounter or aggressive behavior,

wildlife strikes could severely compromise the UAS and could result in ground impact, property damage, and/ or injury to persons. It is important to observe your surrounds and the survey area prior to take

- off. MFA has researched the potential fail

- safe method as mentioned above : a UAS parachute system can deploy in the event of a mid

- air collision to safely return the aircraft to the ground.

Telemetry Equipment and Radio Controllers

MFA uses 3D Robotics telemetry hardware and FPV systems in UAS operations. The IRIS+

use s the 3DR Radio v2 (915 MH z ) controller. The X8

- M uses the Spektrum DX7 radio controller (915 MHz). The AgBot uses the Spektrum DX8 radio controller (915 MHz). The eBee is controlled by Sensefly eMotion mission planning software and the aircraft ’ s autopilot . Manual options can be used, but they are not advised by the manufacturer. MFA will fly this aircraft strictly as an autonomous aircraft in rural areas only.

3DR’s LiveView FPV system allows the PIC to maintain a real

- time data feed of the UAS during ope rations on the multi

- rotor aircraft . The IRIS+ is equipped with a GoPro HERO4

action

- sports camera used on the Tarot T

- 2D brushless gimbal stabilizer to provide video feed during flight operations. The X8

- M uses a Canon digital camera for mapping, and a

se parate FPV camera is equipped to monitor the aircraft during flight. The LiveView kit on

the X8

- M uses a Sony HAD 520 line camera. The AgBot uses a MicaSense RedEdge multi

spectral camera for data gathering, and can be equipped with an FPV camera for in

fl ight monitoring.Page 9 of 

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MFA I s C ommitted to Safety and Regulatory Compliance

If an exemption is granted, MFA is committed to operating in full compliance with the regulatory statutes set forth by t he FAA

. MFA also understands that additional Certificate s of Authorization (COAs) will be needed to operate UAS in certain airspace(s)

.

MFA plans to adhere to the “Blanket COA” granted with 333 exemptions where al most all operations will be at or below 200 feet, during daytime Visual Flight Rules (VFR), always maintaining visual line of sight (VLOS), and stay ing required distances away from airports

and heliports. We are commit t ed to meeting the requirements listed in the article found

here: https:/ /www.faa.gov/news/updates/?newsId=82245

.

After all regulatory requirements are met and licensing is completed, MFA will be committed to practicing a strict regimen of operating procedures :

• A pre flight checklist

, as well as a visual inspection of the aircraft , will always be conducted . An example checklist can be found here: http://3drobotics.com/kb/preflight

- checklist

- 2/

• MFA will use only flightworthy components during operations and will ensure that all required spare parts and accessories are available on site, as well as the proper tools, batteries, chargers, and other necessary equipment

.

• Flight performance is of the utmost importance for safety and efficient mission planning. MFA will stay up to date on manufacturer notifications regarding

hardware and software and make sure that all potential issues are resolved prior to any operation

.

• Radio transmitter/ FPV systems will be fully tested to ensure effective communication links before any flight operation begins

.

• GPS systems will be tested to be sure that they are working properly and receiving required satellite coverage before any flight operation

.

• For autonomous flights using Dr oidPlanner/Mission Planner /

eM otion software,

MFA will ensure that waypoints are properly sent to the aircraft by clearing

the mission and re loading the waypoints from the UAS to the ground station.

This double

- check ensures that the only waypoints assigned to the UAS are the waypoints associated with the currently programmed mission

.

• A “geo

- fence” will be calibrated for each aircraft to maintain horizontal and vertical regulatory limits; the aircraft will enable a n RTL fail

- safe if the UAS travels outside the “geo

- fence”

.

• To comply with the “Blanket COA” requirements, MFA will ensure that all flights occur outside 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from anPage 10 of 

### 15

airport without a pub lished instrument flight procedure or an operational

tower; or 2 NM from a heliport with a published instrument flight procedure.

• To assist with safe mission planning and to comply with the airport buffer
zones listed above, MFA will use the AirMap.io int eractive map, the most comprehensive Airport Buffer/UAS mission planning map available (see Appendix Figure 3 ).

• MFA does not plan to operate in Class B, C, D, or portions of E Airspace.

• MFA will n e v e r e x cee d V L O S during fl i g ht ope r a t i ons, and a visual observer

will always be on site to assist the PIC. This two

- person flight team will also employ the use of a stop watch to track flight time and battery life in addition to ground

- station live telemetry data to monitor flight performance

.

• If any operation occurs within close proximity to a public right

- of

- way

, the flight team will display the necessary signage or “WARNING” markers

.

• Being aware of your surroundings is essential, as is knowledge of commercial airspace. MFA will be aware of air traffic conditions in the immediate area and observe existing aircraft flight patterns and wind conditions, and will also employ the use of aviation tracking applications such as FlightRadar24, if

necessary

.

• Knowledge of terrestrial surroundings and flight conditions allows the PIC and visual observer to maintain safe flying practices. Being aware of changing weather conditions that may affect aircraft performance and VLOS is essential so that the PIC can ground the UAS if conditions worsen

.

• Post flight procedures will be essential in the demobilizing the unmanned aircraft: disconnecting batteries, storing components in their proper cases/containers, checking the surrounding area for stray equipment, and securing any ac cess points if operating on private property

.

• Post flight completion will also include communications with clients and others directly involved with the operation

.

• MFA will possess on

- site documentation pertaining to the FAR e xemption, including licenses and medical cards, if applicable

.

• Comp l y with a n y a ddi t ional a nd futu r e re g ulatio n s e nfo r c e d b y the F AA F AR.

S ec tion VI. F e d er al R e g ist e r Ru le m a k i n g

, The extent of relief MFA seek s and the reason we

seek the relief.

1) C e rt i f

ic at i on Pro ce dur e s for P r odu c ts and Parts Subpart H, Airworth i n e ss C e rt i f

icat e s
T

i t

le 14, CFR 21: ( §21.171

- §21.19 9 ) :Page 11 of 

### 15

S ec t i on 333 of The A c t s t ates:

(1) whi c h t y p e s of un m a nn e d a ir c r a ft s y s t e ms, i f a n y

, a s a r e sult of th e ir s i z e

,
w e i g ht, sp ee d, op e r a t i on a l c a p a b i l i t y

, p ro x i m i t y to ai r ports a nd popul a ted

a r ea s, a nd op e r a t i on with i n visual line of si g ht do not c r e a te a h a z a rd to us e rs o f

the n a t i on a l a ir s

p ac e s y stem or the public or pose a t h r e a t t o n a t i on a l s e c uri t y ;

a n d

,

(2) wh e th e r a c e rtifi c a te of wa iver, ce rtif i ca te of a uthori z a t i on, or

a ir w orthin e ss ce rtifi c a t i on und e r s ec t i o n 44704 of T itle 49, United S t a tes Code,

is r e quir e d for the op e r a t i on of unman n e d a ir c r a ft s y stems identifi e d und e r
p a ra g r a ph (1 )

.

R e ason f or Ex e m p tion:

MFA ’s UAS fleet consists of small

- size and low

- weight unmanned aircraft, which

are flown at low speeds and over a limited geographical extent ; combined with

MFA ’s compliance and knowledge of airspace /airport proximity rules and regulations, our UAS operations meet the level of safety compliance proposed b y S

ec t i on 333. P a ra g r a ph ( 2) st a tes th a t i f UAS s m e e t t his r e quir e ment, e x e mp t ion

f r om 14 CFR 21, Subpart H m a y b e g r a nted.

2) D isp l ay of Mar k s, G e n e ral

T

i t

le 14, CFR §45.2 3 ( a ) ( b ) :
( a ) E a c h op e r a tor of a n a i r c raft must disp la y on th a t ai rc raft m a rks c onsist i ng of

the Roman ca pi t a l l e t t e r “ N ” (d e not i ng United S t a tes r e g is tr

a t i on) f ol l ow e d b y
t he re g is t r

a t i on number of t h e a ir c r a ft. E ac h suf f ix letter us e d in t he ma r ks

dis p l a y e d must a lso be a Roman c a pi t a l l e t t e r.

(b) W h e n ma r ks in c lude on l y the Rom a n c a pi t a l l e t t e r “ N ” a nd the re g is t rat i on number is disp la y e d on l i m i ted, re s t ri c ted or l i g h t

- sport ca t e go r y a ir c r a ft or

e x p e rim e ntal or provisional l y c e rtific a ted a ir c r a ft, the op e r a tor m u st also d i spl a y on that a i r c r a ft n ea r eac h e ntr a n c e to t he ca bin, c o c kpi t , or p i l ot s t a t i on, in l e t t e rs not less than 2 in c h e s nor mo r e than 6 in c h e s hi g h, t h e w ords “ l i m i ted,”

“ r

e str i c t e d,” “ l i g h t

- sp o rt,” “ e x p e rim e ntal,” or “ provisional,” a s a ppl ica ble.

R e ason f or Ex e m p tio n : ( a ): MFA ’ s UAS sur f a c e a r e a s p r e v e nt a t t ac hment of a

dis t in g uishable re g is t r

a t i on number g r ea t e r th a n 2 " in he i g ht ( a pp l ic a ble on l y to §45.23b) f r om a dist a n c e e q u a l to or g rea t e r th a n 40 '

, u nless o p t ic a l

m a g nifi c a t i on is used

. Attaching a flag or e quiva l e nt sur f a c e to display a registration number m a y inh i bit the use of the UAS because of t he a ddi t ional

p a y l o a d w e i g ht a nd p o tential sur fa c e a r ea , whi c h m a y also r e sult in fli g ht

ins t a bi l i t y a nd/ o r fa i l ur e

. (b ) : The c lassif i ca t i on of UAS und e r the c u r re nt r e g u l a to r y

r e str i c t i on p e riod is uncl ea r ; t h e ref o r e , th i s e x e mp t ion sh a ll r e main ac t i ve.Page 12 of 

### 15

3) Private Pilot Privileg e s and Li mitat i ons

T

i t

le 14 CFR §61.11 3 ( a ) :
( a ) E x ce pt as p r ovided in p a ra g r a phs (b) thro u g h ( h) of th i s se c t i on, no p e r s

on who holds a priv a te pilot ce rtif i ca te m a y ac t as pilot i n c om m a nd of a n a i r c r a ft

th a t i s c a r r y i n g p a sse n g e rs o r p r op e r t y f o r c ompens a t i on or h i r e ; nor m a y t h a t

pe r son, f o r compens a t i on or hi re

, a c t as pi l ot i n c om m a nd of a n a i r c raft.

R e ason f or Ex e m p tio n : UAS s are unmanned aircraft and it is not possible to carry

passengers. H o w e v e r, p r op e r t y a ssets for t h e pur p os e s of s c ientific r e s e a rch a nd photogr a m m e t r y will c onsist of the UAS p a y l o a d, a nd the c ompa n y ’ s PIC ( UAS

ope ra tor) will be c ompens a ted f o r e x p e rtise, s e rvi c e s, a nd d e l i v e r a b les.
Furthermore, N

– 8900.227 “Unmanned Aircraft Systems (UAS) Operational Approval” paragraph 16(c)(2)(c) “Operations without a pilot certificate” states that operations that conform to said paragraph may be performed by a PIC who does not possess a private pilot’s license but who has completed FAA private pilot ground instruction and passed the FAA Private Pilot written test. In addition, currently there is no means of obtaining a commercial rating for a UAS. Thus, we require relie f from flight training in order to conduct UAS operations . Our operations fulfill all the requirements in the aforementioned N

– 8900.227 16(c)(2)(c) for operations without a private pilot’s license. The level of safety provided by the requirements included in the notice exceeds that provided by a single individual holding a commercial pilot's certificate and operating a conventional aircraft.

4) C ivil Air c raft Air w

ort h iness

T

i t

le 14 CFR § 91.7 ( a ) :
( a ) N o p e rson m a y op e r a t e a c iv i l ai r c r a ft unless it is i n a n a ir w ort h y c ondi t ion.

R e ason f or Ex e m p tio n : The a fo r e mentioned 14 CFR 21 Subpart H e x e m pt i on
f r om r e quiri n g a ir w orthin e ss c e rtifi ca t e s for a UAS is t he re a son f or this

e x e mp t ion.

5

. M in i mum Safe A l t i t

ud e s
T

i t

le 14 CFR §91.119 ( d ) :
(d) H e l i c opt e rs, po w e r e d p a r a c hu t e s, a n d w e i g h t

- s hift

- c ontrol ai r c r a ft: I f t h e
op e r a t i on is c ondu c ted w i t hout ha z a r d to persons or p r op e r t y on the su r f a c e , a h e l i c opter m a y be op e r a ted a t l e ss t h a n the m i ni m ums pr e s c rib e d in pa r a g r a ph (b

– 1000 ’ ) or (c

– 500 ’ ) o f th i s se c t i on, p r ovided ea c h p e rson op e r a t i ng the

h e l i c opter c omp l ies w i t h a n y rout e s o r a l t i t ud e s spe c ifi ca l l y pr e s c rib e d for

h e l i c opte r s b y the F A A

.

R e ason f or Ex e m p tio n : This exemption applies to the routes and altitudes of helicopters specifically. UAS op e r a t o rs must ob e y a ma x i m um of 300 ' above ground level

, a nd b e low the 500 ' r

e striction for mann e d a ir c r a ft in un c o n g e sted

a re a s . R e s e a r c h a re a s a nd a r e a s of int e r e st m a y e x ist in these c o r r idors. Addit i on a l

r e s e a r c h on the lo ca t i on of the s e h e l i c opte r

- sp ec ific fli g ht c o r rido r s will be

c o ndu c ted b e f o re a n y fli g ht op e r a t i ons begin

.Page 13 of 

### 15

6. A l t i m e ter S e t t ings

T

i t

le 14 CFR §91.121:

( a ) E a c h p e rson op e r a t i ng a n a ir c r a ft sh a ll mainta i n the c ruising a l t i t ude or fli g ht

l e v e l of that a ir c r a ft, a s the c a se m a y b e

, b y ref e r e n c e to a n a l t i m e ter that is s e t,

wh e n op e r a t i n g

... [ r e maind e r of r e g ulatio n ]

.

R e ason f or Ex e m p tio n : UAS a l t i m e ter s e t t in g s a re controll e d b y the onb o a rd

a l t i m e ter ( GP S

- b a s e d

, o r backup/validation barometric altimeter). “ C ruising

a l t i t ud e ” do e s not a pp l y to UAS s with i n MFA ’s o p e r a t i on a l c a p a c i t ies

.

7. Fuel requirements for flights in VFR conditions

T

i t

le 14 CFR §91.151(a):

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (2) At night , to fly after that for at least 45 minutes

R e ason f or Ex e m p tio n : MFA’s UAS fleet is limited to operations in controlled environments and has a limited range and flight time that require an exemption from 14 CFR 91.151(a). The batter ies powering the UAS provide approximately 1 5

to 30 (45 for the eBee) minutes of powered flight. To meet the 30

- m inute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately five

minutes. Given the limitations on the UAS ’ s proposed flight area and the location of its proposed operations in a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

All of the UAS s in the MFA fleet are programmed with fail

- safes that will return the aircraft to the ground before the batteries reach critical levels. W hen performing surveying/mapping operations, the UAS will be programmed autonomously and flight times will be specifically limited to allow for a safe take

- off and landing.

8. Commercial Use

Title 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) &(b);91.7 (a); 91.9 (b) (2); 91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) and (b) :
The following summary addresses the commercial operation of a UAS (55 lb or less) for aerial imaging, mapping, inspections, and sensing :

Approval of these exemptions allowing commercial operations of UAS s for surveying/mapping enhances saf ety while reducing risk. Manned

- aircraft monitoring and surveying create a greater risk because the craft are much larger, have combustible fuel, and carry an onboa rd human pilot. In contrast, a UAS weighing close to 10 lb and powered by batteries eliminates virtually all ofPage 14 of 

### 15

that risk

, given the reduced mass and the fact that no combustible fuel is

carried on board. The UAS s will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UAS s

, weighing close to 10 lb, conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and 113(a) and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a closed environment and therefore are far safer than conventional operations condu cted with full

- sized helicopters and airplanes

.

In regard to maintenance and inspections, MFA will adhere to any future FAA requirements specific to UAS s for inspections/maintenance, but until then we will thoroughly comply with manufacturer

- recommended m aintenance and

pre flight inspections for ensuring that all flights are conducted with a competent aircraft.

S ec tion VII. Ad d itio n al I nf o r m ation, Vi e w s, or A r g u m e n ts.

P e rso n al S ta t e m e n t

MFA is committed to safe flying practices th rough a regimen of pre flight procedures and maintaining compliance within legal operation locales. These regulations will help ensure

minimal risk of harm to persons and damage to property. MFA understands that the FAA has placed regulations on UAS s to ensure that their use throughout the United States is conducted in a safe and controlled manner. Our company is committed to operating with safety as the number one priority ; we will be ambassadors to other UAS users and our data products will be used for good.

As technology c ontinues to push its limits, we are poised in a unique position to utilize these new scientific advancements in our field and provide our clients with data that can help them learn more about their site s , properties, and assets. Conventional survey

methods have proven to be costly and time

- consuming . We want to be able to utilize UAS technologies to the best of our ability to provide the public with data that can be

used to eliminate health risk s posed by environmental hazards, assist with community plannin g

, and identifying /protecting valuable resources.

We appreciate the consideration of the FAA in allowing us to petition to fly UAS s for commercial purposes. We at MFA

, and other members of the UAS community who are committed to responsible operation

, are the leaders in our industries and it is inspiring to

see others like us using science and technology to better understand our changing earth and human impacts. We would like to thank the FAA and everyone involved with governing UAS regulations.

S ec tion VIII. E x e m p ti o n outside the U n it e d S t at e s.

MFA h a s no intention of op e r a ting a UAS outs i de the U ni t e d S tat e s.Page 15 of 

### 15

To the Dir e c tor a nd Ad m in i str a t i on of the F e d e r a l Avi a t i on Admin i str a t i on, I h e r e b y submit

th i s P e t i t i on f o r E x e mp t ion, d a ted August 5 , 2015 . R e sp ec tful l y

,

Steven P. Taylor, PE Maul Foster & Alongi, Inc. 400 East Mill Plain Boulevard, Suite 400 Vancouver, Washington 98660Appendix

Figures 1

- 3

Figure 1. Principles of Photogrammetry: Downward

- facing camera captures images to
provide an optimal 60% image overlap. This forward and lateral overlap provides the

information necessary to photogrammetry software to create high

- resolution aerial maps

and 3D models.

Graphic courtesy of Natural Resources, Canada

https://www.nrcan.gc.ca/earth

- sciences/geomatics/satellite

- imagery

- air

- photos/air

photos/about

- aerial

- photography/9687Fi g u r e 2. UAS

- generated

, high

- resolution aerial ma p and contours generated from a classified digital

- surface

- m odel. Graphic courtesy of MFA

.Fi g u r e 3. AirMap.io flight planning map

, i n c l u d i ng a l l a ir p o r t s w it h fi v e ( 5 )

- m il e

r a d i us b u ff e r s a pp l i ed

, consistent with Commercial Blanket COA restrictions

. Checking missions with this map w i l l b e a s t and a r d p r o c edu r e before each

MFA f l i g ht op e r a t i o n

.

Graphic courtesy of AirMap.io

http://www.airmap.io

– END OF P ETI T ION

–