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

G REGORY S. W INTON , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorney for Petitioner2

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 Ref orm 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. FAA

201 5

- 0 928 ), 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 al low the
petitioner to operate an Altavian Nova R84 00 to perform aerial data collection

. Specifically, Cardno seeks an amendment to Exemption No. 11776 to the extent
necessary to allow Cardno to operate a n 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, t he 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 F65 00 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 G round C ontrol S tation (GCS) . The Nova F6500 UA has a maximum3

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 Pos itioning 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 p ursuant 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

a rea 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 d esigned to a utomatic ally r eturn t o a preset poi nt of intended landing and

a uto

- l and i n t he e vent o f l oss o f t he c ontrol l ink o r GPS n avigation

. 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 972214

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 N o. 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 Limitati on No. 1 be amended as follows:
Operations authorized by this grant of exemption are limited to the Altavian Nova R 8 400 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

- 201 5

- 0 040 ) did not request that op eration 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 Adminis trator in Exemption No. 11776

. As the Administrator held on page 2 of Exemption5

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, rat her
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 pu b lic interes t 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 , i t 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 G ranting An Amendment T o Condition And Limitation No. 1 Wou ld 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 Grant s 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 Regi ster

.
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 woul d be detrimental to the
petitioner.6

G. Any Additional Information, Views, Or Arguments Available To Support Cardno ’s Request.
This Petition is made pursuant to the FAA Modern ization 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