UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

PETITION FOR AMENDMENT TO GRANT OF EXEMPTION NO. 11776

BY CARDNO LIMITED

Submitted on August 25, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
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Petitioner, Cardno Limited (“Cardno”), by and through undersigned counsel, pursuant to 

the provisions of the Federal Aviation Regulations and the Federal Aviation Administration 

(“FAA”) Modernization and Reform Act of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator for an amendment to the 

conditions and limitations of Grant Of Exemption No. 11776 (Regulatory Docket No. FAA2015-0928), which granted to Cardno an exemption from 14 CFR §§ 61.23(a) and (c), 

61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow the 

petitioner to operate an Altavian Nova R8400 to perform aerial data collection. 

Specifically, Cardno seeks an amendment to Exemption No. 11776 to the extent 

necessary to allow Cardno to operate an Altavian Nova F6500 UAS (hereinafter “Nova 

F6500”) under Exemption No. 11776. Cardno submits that operation of a Nova F6500 UAS 

under the conditions and limitations set forth in Exemption No. 11776 will ensure the safety of 

the National Airspace System (“NAS”), as well as the safety of persons or property on the 

ground. Additionally, the Nova F6500 has previously been the subject of multiple Grants of 

Exemption under Section 333, including most recently in Exemption No. 11172A on July 20, 

2015.

In support of its Petition, Cardno states the following:

Nova F6500 Unmanned Aircraft System

Cardno Limited seeks an amendment to operate the Nova F6500 UAS for compensation 

or hire within the NAS pursuant to Paragraph 1 of the Conditions and Limitations section of 

Exemption No. 11776. The Nova F6500 UAS is comprised of an amphibious unmanned aircraft 

(UA) and a transportable Ground Control Station (GCS). The Nova F6500 UA has a maximum 
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gross weight of approximately fifteen (15) pounds, and has a wingspan of 108 inches and a 

length of 65 inches. The Nova F6500 UA is equipped with a single, front-mounted propeller 

driven by a Lithium Polymer battery powered electric motor. The altitude information of the 

Nova F6500 UA is provided to the PIC via Global Positioning System (GPS) equipment, a 

barometric pressure sensor, and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. A description of the Nova 

F6500 UAS, including its specifications and software, can be found at pages 2-1 through 2-15 of 

the Nova F6500 Flight Manual, which contains proprietary information and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b), attached hereto as Exhibit A.

As an additional precaution, prior to any operation the Nova F6500 UAS is given a fixed 

area of operation and its flight can be completely automated. A description of the Nova F6500’s 

flight operations can be found at pages 5-1 through 5-9 of the Nova F6500 Flight Manual. The 

Nova F6500 UAS is designed to automatically return to a preset point of intended landing and

auto-land in the event of loss of the control link or GPS navigation. Further description of Nova 

F6500’s Emergency Procedures can be found on pages 9-1 through 9-5 of the Nova F6500 Flight 

Manual. The Nova F6500 UAS is compliant with all Federal Communication Commission 

requirements and the radio frequency spectrum used for operation and control of the UA is set 

forth at page 2-3 of the Nova F6500 Flight Manual. 

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Cardno Limited

5415 SW Westgate Drive

Suite 100

Portland, Oregon 97221
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The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. Cardno Seeks To Amend Condition and Limitation No. 1 Of Grant Of 

Exemption No. 11776.

Condition and Limitation No. 1 of Exemption No. 11776 states the following:

Operations authorized by this grant of exemption are limited to the Altavian Nova 

R8400 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.

Exemption No. 11776 at page 3, ¶1.

C. Extent Of The Amendment That Cardno Seeks And The Reason Cardno Seeks 

To Amend Condition And Limitation No. 1.

Cardno submits that Condition and Limitation No. 1 be amended as follows:

Operations authorized by this grant of exemption are limited to the Altavian Nova 

R8400 and Altavian Nova F6500 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. 

This relief is requested because Cardno’s original Petition For Exemption (Regulatory 

Docket No. FAA-2015-0040) did not request that operation of the Nova F6500 UAS be allowed 

under the Exemption. However, Cardno proposes that it may safely operate the Nova F6500

UAS under the same Conditions and Limitations set forth in Exemption No. 11776 for the Nova 

R8400 UAS.

D. The Reasons Why Granting Cardno’s Request For Amendment Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present petition for amendment will further the public interest as set forth by 

the Administrator in Exemption No. 11776. As the Administrator held on page 2 of Exemption
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No. 11776, the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) 

with the specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this 

exemption is in the public interest. Further, there has been no change in the conditions and 

reasons relative to the public interest and safety that were the basis for granting the original 

exemption.

Cardno’s proposed amendment not only furthers the public’s interest as set forth by the 

Administrator in Exemption No. 11776, it also is another step forward in fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, by allowing Cardno

to safely, efficiently, and economically operate the Nova F6500 UAS commercially within the 

NAS.

E. The Reasons Why Granting An Amendment To Condition And Limitation No. 1

Would Not Adversely Affect Safety.

Cardno proposes that it may safely operate the Nova F6500 UAS within the NAS because

the Nova F6500 has previously been the subject of multiple Grants of Exemption under Section 

333, including most recently in Exemption No. 11172A on July 20, 2015, and will be operated 

pursuant to the same Conditions and Limitations set forth in Exemption No. 11776.

F. A Summary That Can Be Published In The Federal Register.

Cardno submits that good cause exists for not publishing a summary of this petition for 

amendment in the Federal Register because the requested amendment to Exemption No. 11776

would not set a precedent, and any delay in acting on this petition would be detrimental to the 

petitioner. 
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G. Any Additional Information, Views, Or Arguments Available To Support 

Cardno’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Cardno’s request for amendment may be granted pursuant 

to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

CONCLUSION

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Cardno respectfully requests that the 

Administrator grant this Petition for an amendment to Exemption No. 11776 to the extent 

necessary to allow Cardno to operate the Altavian Nova F6500 UAS in addition to the Nova 

R8400 UAS under the Conditions and Limitations originally set forth in Exemption No. 

11776.

Dated: August 25, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton 

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner