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August 5, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Petition for Exemption under the FAA Modernization and Reform Act of 2012, 

Public Law 112-95, February 14, 2012, Section 333 for the use of Unmanned Aerial

Systems (UAS) for aerial imaging, mapping, inspections, and sensing.

Dear Sir or Madam,

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 for an exemption from the listed Federal Aviation Regulations (FAR) to allow 

commercial operation of its unmanned aerial systems (UAS) to provide aerial imaging, 

mapping, inspections, and sensing for its clients.

Section I. Petitioner Contact Information

Steven P. Taylor, PE

Maul Foster & Alongi, Inc.

400 East Mill Plain Boulevard, Suite 400

Vancouver, Washington 98660

Business: (360) 694-2691

Email: staylor@maulfoster.com
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Section II. The specific Sections of Title 14 CFR from which MFA wishes to seek exemption:

1. Chapter 1, Subchapter C, Part 21, Subpart H (§21.171 - §21.199)

2. Chapter 1, Subchapter C, Part 45, §45.23 (a)

3. Chapter 1, Subchapter D, Part 61, §61.113(a)

4. Chapter 1, Subchapter D, Part 91, §91.7(a)

5. Chapter 1, Subchapter D, Part 91, §91.119(d)

6. Chapter 1, Subchapter D, Part 91, §91.121

7. Chapter 1, Subchapter D, Part 91, §91.151(a)

8. Chapter 1, Subchapters D & H, Parts 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).

Section III. MFA is requesting relief from existing regulations for these UAS applications:

MFA is requesting exemption from these Title 14 CFR regulations 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:

• Photogrammetry Applications: By using fixed, downward-facing cameras, 

photogrammetry enables us to create high-resolution aerial mosaics of

overlapped aerial images for use in geospatial software (e.g., GIS). MFA is an 

expert in providing GIS services and solutions to a broad client base, and would 

like the ability to provide rapid delivery of high-resolution ortho-rectified photos to

clients requesting these products. 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. In addition, flying below current restricted 

altitudes allows much more detailed images than traditional aerial photographs.

(Appendix Figure 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 flow diagrams, biomass calculations, 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 professional 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.
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Section IV. How MFA’s Exemption will benefit the Public as a whole.

UAS technology allows MFA to provide the services listed in Section III and 

consequently benefit the public as a whole. MFA is actively working on projects that 

promote environmental conservation, environmental cleanup, economic 

development, and asset management. UAS technology allows 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 practices 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 practices 

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 soils that support food production. As 

population centers expand, it is imperative to 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 cleanup 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 forces, and site conditions. MFA has worked on hundreds of 

cleanup projects throughout 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 professionals are active in projects 

involving redevelopment, 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 and 
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communities. Community planning, strategic planning and policy analysis and 

master plan development are examples of MFA’s contribution to this sector. UAS 

can 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 

inventory 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 the 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 operations 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 costs 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, FAR altitude restrictions (14 CFR §91.119) may

affect the value of the end product.

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

aircraft services.

o Electric-powered UAS have fewer environmental impacts than fossilfueled, full-sized aircraft.

o Noise pollution is reduced.

o Catastrophic failures of aircraft happen every day around the world,

resulting in loss of life, property damage, and legal disputes. UASs

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 

million and more than 100,000 jobs created (Source: Association for 

Unmanned Aerial Systems).

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

altitude thresholds provides 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 applications. Air quality 

monitoring sensors allow us to address growing concerns about air pollution in 

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

increased in agricultural applications where crop health and moisture stress are 
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valuable indicators allowing farmers to more efficiently monitor their 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.

Section V. Reasons why MFA’s exemption will not adversely affect safety, or how

the exemption would provide a level of safety at least equal to the existing rule.

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 industry 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 Fleet Specifications

MFA’s unmanned-aircraft fleet consists of two quadcopters 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 human beings, manned aircraft, and infrastructure. The X8-M and the ATI 

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

datasets that are optimized 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-propeller quad frame, plastic/polymers):

• Total weight with maximum allowable payload: 3.6 lb.

• Dimensions: greatest width: 21.65", height (with leg extensions): 7.5".

• Maximum speed: 40 mph.

• Battery system (4-cell, 11.1 volt, 5,100 mAh lithium-polymer) provides 16 to 22

minutes of flight time (depending on payload).

• 3DR Pixhawk 32-bit flight controller with Cortex M4 CPU (with global 

positioning system [GPS] and compass) is installed on this UAS, and is the 

most advanced system currently available, with latest firmware release.
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• 3DR “LiveView” First-Person View (FPV) kit increases flight safety; provides 

a real-time video feed from the IRIS+ to a video monitor mounted on 

radio controller.

• 3DR IRIS+ Operation Manual can be found here: http://3drobotics.com/wpcontent/uploads/2015/02/IRIS-Plus-Operation-Manual-vH-web.pdf

2) 3D Robotics X8-M Multi-rotor (eight-propeller quad frame, aluminum):

• Total weight with maximum allowable payload: 7.3 lb.

• Dimensions: greatest width: 20.1", height (with landing gear): 11.8".

• Maximum speed: 38 mph.

• Battery system (4-cell, 14.8 volt, 10,000 mAh lithium-polymer) provides 14

minutes of flight time at ideal operating conditions.

• 3DR Pixhawk 32-bit flight controller is also installed 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-Manualv1.pdf

http://3drobotics.com/wp-content/uploads/2014/11/X8+-Operation-ManualvA.pdf

3) Aerial Technology International (ATI) AgBot (four-propeller quad frame, carbonfiber/aluminum):

• Total weight with maximum allowable payload: 10.4 lb.

• Dimensions: greatest width: 40.5", height (with landing gear): 13.2".

• Maximum speed: 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 installed 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-DataSheet-150-1.pdf

4) Sensefly eBee (fixed-wing, foam/carbon structure and composite parts):

• Total weight with maximum allowable payload: 1.56 lb.

• Dimensions: wingspan: 38".

• Maximum speed: 50 mph.

• Battery system (11.1 volt, 2,150 mAh lithium-polymer) provides up to 45

minutes of flight time.

• Sensefly autopilot/ flight controller.
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• Sensefly radio tracker and eMotion ground station software allow accurate 

in-flight monitoring of the aircraft’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

Flight Controller and Fail-Safe Systems

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 ensure safe flying and 

landing of the aircraft:

• GPS Attitude Control: The origin of flight 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.

• Attitude Control: 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 

harming persons or damaging property.

• Return-to-Land (RTL): 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 aircraft will land 

immediately in a circling pattern 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 

landing. The aircraft will continue to return to land at the point of origin if GPS 

signal is restored. 
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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 preflight 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. These 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, but can be avoided if proper preflight 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.

• Wildlife. 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+

uses the 3DR Radio v2 (915 MHz) 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 operations 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 

separate 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 multispectral camera for data gathering, and can be equipped with an FPV camera for inflight monitoring.
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MFA Is Committed 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 the FAA. MFA also understands that additional Certificates 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 almost all 

operations will be at or below 200 feet, during daytime Visual Flight Rules (VFR), always

maintaining visual line of sight (VLOS), and staying required distances away from airports 

and heliports. We are committed 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 preflight 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 DroidPlanner/Mission Planner/eMotion software, 

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

the mission and reloading 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 an 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 an 
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airport without a published 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 interactive 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 never exceed VLOS during flight operations, 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 stopwatch 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.

• Postflight 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 access points if operating on private property.

• Postflight completion will also include communications with clients and others 

directly involved with the operation.

• MFA will possess on-site documentation pertaining to the FAR exemption, 

including licenses and medical cards, if applicable.

• Comply with any additional and future regulations enforced by the FAA FAR.

Section VI. Federal Register Rulemaking, The extent of relief MFA seeks and the reason we 

seek the relief.

1) Certification Procedures for Products and Parts Subpart H, Airworthiness Certificates

Title 14, CFR 21: (§21.171 - §21.199):
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Section 333 of The Act states:

(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 hazard 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).

Reason for Exemption:

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 by 

Section 333. Paragraph (2) states that if UASs meet this requirement, exemption 

from 14 CFR 21, Subpart H may be granted.

2) Display of Marks, General

Title 14, CFR §45.23(a)(b): 

(a) Each operator of an aircraft must display on that aircraft marks consisting of 

the Roman capital letter “N” (denoting United States registration) followed by

the registration number of the aircraft. Each suffix letter used in the marks 

displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration 

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

Reason for Exemption: (a): MFA’s UAS surface areas prevent attachment of a

distinguishable registration number greater than 2" in height (applicable only to

§45.23b) from a distance equal to or greater than 40', unless optical 

magnification is used. Attaching a flag or equivalent surface to display a 

registration number may inhibit the use of the UAS because of the additional 

payload weight and potential surface area, which may also result in flight 

instability and/or failure. (b): The classification of UAS under the current regulatory

restriction period is unclear; therefore, this exemption shall remain active.
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3) Private Pilot Privileges and Limitations

Title 14 CFR §61.113(a):

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as 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 pilot in command of an aircraft.

Reason for Exemption: UASs are unmanned aircraft and it is not possible to carry 

passengers. However, property assets for the purposes of scientific research and 

photogrammetry will consist of the UAS payload, and the company’s PIC (UAS

operator) will be compensated for expertise, services, and deliverables.

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 relief 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) Civil Aircraft Airworthiness

Title 14 CFR §91.7(a): 

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

Reason for Exemption: The aforementioned 14 CFR 21 Subpart H exemption 

from requiring airworthiness certificates for a UAS is the reason for this 

exemption.

5. Minimum Safe Altitudes

Title 14 CFR §91.119(d):

(d) Helicopters, powered parachutes, and weight-shift-control aircraft: If the

operation is conducted without hazard to persons or property on the surface, a 

helicopter may be operated at less than the minimums prescribed in paragraph 

(b – 1000’) or (c – 500’) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA.

Reason for Exemption: This exemption applies to the routes and altitudes of 

helicopters specifically. UAS operators must obey a maximum of 300' above 

ground level, and below the 500' restriction for manned aircraft in uncongested

areas. Research areas and areas of interest may exist in these corridors. Additional 

research on the location of these helicopter-specific flight corridors will be

conducted before any flight operations begin.
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6. Altimeter Settings

Title 14 CFR §91.121:

(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... [remainder of regulation].

Reason for Exemption: UAS altimeter settings are controlled by the onboard 

altimeter (GPS-based, or backup/validation barometric altimeter). “Cruising 

altitude” does not apply to UASs within MFA’s operational capacities.

7. Fuel requirements for flights in VFR conditions

Title 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

Reason for Exemption: 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 batteries powering the UAS provide approximately 15

to 30 (45 for the eBee) minutes of powered flight. To meet the 30-minute 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 UASs in the MFA fleet are programmed with fail-safes that will return the 

aircraft to the ground before the batteries reach critical levels. When 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

Title14 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 UASs for 

surveying/mapping enhances safety while reducing risk. Manned-aircraft 

monitoring and surveying create a greater risk because the craft are much 

larger, have combustible fuel, and carry an onboard human pilot. In contrast, a 

UAS weighing close to 10 lb and powered by batteries eliminates virtually all of 
Page 14 of 15

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

carried on board. The UASs will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, 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 conducted with full-sized helicopters and airplanes.

In regard to maintenance and inspections, MFA will adhere to any future FAA 

requirements specific to UASs for inspections/maintenance, but until then we 

will thoroughly comply with manufacturer-recommended maintenance and 

preflight inspections for ensuring that all flights are conducted with a 

competent aircraft.

Section VII. Additional Information, Views, or Arguments.

Personal Statement

MFA is committed to safe flying practices through a regimen of preflight 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 UASs 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 continues 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 sites, 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 risks posed by environmental hazards, assist with community 

planning, and identifying/protecting valuable resources.

We appreciate the consideration of the FAA in allowing us to petition to fly UASs 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.

Section VIII. Exemption outside the United States.

MFA has no intention of operating a UAS outside the United States.
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To the Director and Administration of the Federal Aviation Administration, I hereby submit

this Petition for Exemption, dated August 5, 2015. Respectfully,

Steven P. Taylor, PE

Maul Foster & Alongi, Inc.

400 East Mill Plain Boulevard, Suite 400

Vancouver, Washington 98660
Appendix

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/airphotos/about-aerial-photography/9687
Figure 2. UAS-generated, high-resolution aerial map and contours generated from a 

classified digital-surface-model. Graphic courtesy of MFA.
Figure 3. AirMap.io flight planning map, including all airports with five (5)-mile 

radius buffers applied, consistent with Commercial Blanket COA restrictions.

Checking missions with this map will be a standard procedure before each 

MFA flight operation.

Graphic courtesy of AirMap.io

http://www.airmap.io

– END OF PETITION –