June 13th, 2015 Landmark Surveys LLC 51 Bridge Street Metuchen, N.J. 08840

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

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

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Refo rm Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Landmark Surveys LLC, seeks an exemptio n from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial System called in this application the ME System, which includes an Unmanne d Aircraft (UA) and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

! A lightweight (20 lb gross weight with all on-board e quipment), manufactured by DJI, Inspire 1- t-600, Phantom 3 that includes the following equipmen t in flight; ! An on-board flight computer with GPS navigation and locati on ability that receives signals for flight controls from a ground-based transmitter/controller; ! An on-board camera capable of capturing imagery in the fo rm of full color, high definition still photos and video; ! An on-board telemetry system that delivers flight data from th e on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site; ! A 2.4GHz on-board radio transmitter that transmits live vi deo from the on-board camera plus all the flight data from the telemetry system described above;

THE GROUD STATION –BASED PART OF THE SYSTEM:

! A Pilot in Command (PIC) in operational control of a flightoperation from beginning to end and who controls the UA while in the air; ! A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight; ! A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together onto a screen for the PIC to vie w during flight; ! A Visual Observer (VO) is a person who provides a second pairof eyes to visually track the UA while in flight.The requested exemption would support an application for acommercial Certificate of

Authorization to use the above described ME System to support aerial photography and video primarily of Real Property, Aerial topography, Constructio n observation & Documentation, Tax Maps and Utility mapping operating over persons not directly i nvolved with the ME system.

The UA, powered by batteries, is smaller, lighter and mor e maneuverable than larger aircraft running on combustible fuel, it operates at lower altitu des with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than groundbased imagery for displaying the characteristics of large, comple x properties with several buildings and large trees. The alternative could be to ch arter a full-sized helicopter for this purpose, which has proven more costly than many potential clien ts are able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property and mari ne property.

Additionally, we request that we be allowed to use oursystem to benefit first responders nearby who might require assistance, including fire fighters, the poli ce, the sheriff, et al., while remaining subject to all limitations cited in this applicati on as we do so.

The ME System will be operated in the field with both a P IC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following
Restrictions:

a) No flight will be made with a UA Gross weight exceeding 5 5 pounds; b) All operations must occur in FAA Class G airspace at no more t han 400 ft AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; d) Operations will be restricted to flights over property wi th the permission of the property owner; e) The PIC must have accumulated and logged, in a manner con sistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not be operated over densely populate d areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assemb ly of people; j) The ME System will not be operated over heavily trafficked roa ds; k) The ME System will not be operated within 5 NM of an ai rport or heliport; l) Operations will be restricted to day only and weather con ditions equivalent to VFR; m) The PIC will brief the VO and property owner about th e operation and risk before the first flight at each new location; n) No flight may be made without a Pre-Flight Inspection by t he PIC before each operation to ascertain that the UA is in a condition safe for flight (se e Appendix A).The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16

personnel Qualifications. Additionally, the PIC and VO wi ll perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guideli nes established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the F AA can have full confidence that the operation will have an equivalent or greater level of saf ety than manned aircraft performing the
same mission.

The name and contact information of the applicant are:

dba Landmark Surveys LLC : Otto Craig Rossmeyer
Ph: 732-735-5697 Email:Ottojr@lmspls.com

The regulations from which the exemption is requested are l isted below. Beside each regulation number is the page of the attached Addendum upon which e ach may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21.................................Ad dendum Page 1
- 14 CFR 91.203.................................Add endum Page 1 - 14 CFR 45.23, 45.29..........................Adden dum Page 2
- 14 CFR 91.9....................................Add endum Page 2 - 14 CFR 61.113, 61.133.......................Adden dum Page 2 - 14 CFR 91.109, 91.119, 91.121..............Addend um Page 3
- 14 CFR 91.151.................................Add endum Page 3 - 14 CFR Subpart E (91.401 - 91.417) ......Addendum Page 3 - FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 1 6(e)(1) ...Addendum 1

We are prepared to modify or amend any part of this requestto satisfy the need for an equivalent level of safety. Please contact us at any time i f you require additional information or clarification. We look forward to working with your office.

Sincerely,

Otto Criag Rossmeyer, Landmark Surveys LLC Addendum containing Exemption Requests and Equivalent Level o f Safety Appendix A – Flight
Manual’s Appendix B – Owner’s Manual for UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Landmark Surveys LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the o peration of the ME System:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System u nder either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purpose s: (a) Research and development. Testing new aircraft design con cepts, new aircraft equipment, new aircraft installations, new aircraft operating techniq ues, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight t ests and other operations to show compliance with the airworthiness regulations including flight s to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial p urposes such as market surveys, sales demonstrations, and customer crew training, we woul d expect that an experimental certificate would permit our commercial purpose as we ll.

The aircraft will not carry persons or property, will notcarry fuel, and will only fly under strict operational requirements. Combined with the UA’s light w eight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be atleast as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and t he requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications requ ired. The regulation provides that an airworthiness certificate, wit h the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft.Additionally,subparagraph (b) provides that the airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew."At a maximum gross we ight of 6.5 pounds, the UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard co ntaining the following information plus the word “EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description below:Appendix A

EXPERIMENTAL Manufacturer: DJI Innovations, Inc. 950 E Baseline Ave. Ste. 2 10 Apache Junction AZ 85119 Models: Inspire 1- t-600, Phantom 3

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" a nd the aircraft's registration number in letters at least 3 inches high. Additionally, th e aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.

We propose to achieve an equivalent level of safety by inclu ding the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above , where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch w ill be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the grou nd station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to a nyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and pl acard requirements. This regulation provides that no person may operate an ai rcraft unless a current, approved flight
manual is in the aircraft. We assume that the intent of t his requirement is to ensure that flight manual information is available to the aircrew while ope rating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the int ent of 91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available t o the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any bu siness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must either

1. Hold a Commercial Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Oper ations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA
Private Pilot written examination." Since there are curre ntly no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license, we propose to generate an equiva lent level of safety by requiring our Appendix Apilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the FAA

Commercial Pilot written examination in addition

Appendix A to completing the private pilot requirements. Since the a ircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subpara graph (b) even though the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flig ht and certain flight tests The regulation states that "No person may operate a civil ai rcraft that is being used for flight instruction unless that aircraft has fully functioning dual controls.”

The ME System ground-based control station consists of a small ha nd-held radio transmitter and while it does not offer a second set of "controls", b oth the student and instructor can, and will, operate the single set of controls simultaneously. W ith both student and instructor having "hands-on" the controls during flight, we feel that this tech nique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requireme nt.

In order to provide an equivalent level of safety we will only fly over private property with a size of at least two acres with the permission of the owner ofthe property flown over. The aircraft will not be operated over congested areas or over any open air a ssembly of persons. The property owner will be briefed on the expected route of flight an d the associated risks to persons and property on the ground. The aircraft will be operated ata low altitude allowing, if a power unit fails, an emergency landing without undue hazard to person s or property on the surface.
Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should b e considered in granting the exemption.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruisi ng altitudes by reference to an altimeter setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not n eed to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from th e UA on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditi ons. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first poin t of intended landing and to fly after
that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than 3⁄4 NM from the point of int ended landing, a full battery charge atlaunch will ensure that we meet the reserve energy requireme nt of this paragraph. We request

an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Prevent ive Maintenance, Alterations The regulation provides that the operator is primarily responsi ble for maintaining the aircraft in an airworthy condition, including compliance with part 39 a nd 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance an d inspection of the aircraft and "be authorized to approve the aircraft for return to service." As p rovided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in a n airworthy condition prior to every flight
and in addition conduct

Appendix A detailed inspections after every two hours of flight. Maintenan ce performed by the PIC is limited to repairing small cracks, replacing a propeller, checking elect rical connections and updating software and firmware for the on-board computer. All other ma intenance will be performed by the manufacturer or their designated repair facility. Th e PIC will document work performed in accordance with 91.417. We feel that due to the size, con struction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)( 1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in order to perform as a pilo t or observer. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber an d plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the ai rcraft is in flight, the UA will return autonomously to the site of launching and land without cr ew intervention.

Therefore, requiring the PIC and VO to meet the same me dical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary b urden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vi sion requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is me dically qualified to operate a much larger vehicle. Appendix A

APPENDIX A – FLIGHT MANUAL

FLIGHT RESTRICTIONS a) No flight will be made with a UA Gross weight exceeding 5 5 pounds; b) All operations must occur in FAA Class G airspace at no more t han 400' AGL, at an airspeed
of no more than 50 knots and no further than 3/4 NM fro m the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to
communicate verbally at all times during a flight operation; d) Operations will be restricted to flights over property wi th the permission of the property owner;e) The PIC must have accumulated and logged, in a manner con sistent with 14 CFR § 61.51

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local government prior to operation; g) The ME System will not be operated over densely populate d areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assemb ly of people; j) The ME System will not be operated over heavily trafficked roa ds; k) The ME System will not be operated within 5 NM of an ai rport or heliport; l) Operations will be restricted to day only and weather con ditions equivalent to VFR; m) The PIC will brief the VO and property owner about th e operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre-Flight Inspectio n by the PIC before each operation to ascertain that the UA is in a condition safe for flight.

PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device a re fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SD card has been inserted if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft.
TO REGAIN CONTROL AFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, a n automatic Return to Home feature is activated and will bring the UAV back to the PIC.