U.S. Department of Transportation

Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition for Summary Grant of Exemption Under Section 333 of the FAA Modernization

and Reform Act of 2012

To whom it may concern,

I, Douglas Stern, DBA Airborne Geomatics (hereinafter “the petitioner” or “Airborne Geomatics”), hereby apply for Section 333 summary grant of exemption pursuant to the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-95), and 14 C.F.R. Part 11 to allow the commercial use of Small Unmanned Aircraft Systems (sUASs) for aerial data collection in support of scientific research, remote sensing, and photogrammetric and geospatial applications.

The petitioner holds an Airline Transport Pilot certificate, a 2 nd Class Medical Certificate, and has over 20,000 hours of flight time in manned aircraft and more than 30 years in commercial aviation. The petitioner has two years experience building, operating and maintaining sensor-equipped model aircraft under the provisions of Section 336 FMRA. The petitioner has the experience and training to ensure that all sUAS operations are conducted in the safest possible manner and in compliance with aircraft operating limitations and the Federal Aviation Regulations.

Summary:

Petitioner: Douglas Stern, DBA Airborne Geomatics

Petitioner’s sUAS Models: DJI F550

DJI S1000

Petitioner’s sUAS(s) Operations : Aerial data collection for remote sensing, aerial mapping and surveying, structural inspections, and environmental monitoring.

Regulations Requiring Exemption : 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c) 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1) 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1) 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b)Contact Information

Douglas Stern

Airborne Geomatics

PO Box 55

310 St. Moritz Drive Girdwood, AK 99587-0055 Telephone: 907-317-1462 Email: airbornegeomatics@alaska.net

Description of Proposed Operation

Airborne Geospatial is requesting regulatory relief in order to conduct aerial data collection with small Unmanned Aerial Systems in support of remote sensing, aerial mapping and surveying, structural inspections, and environmental monitoring.

The proposed operations would use DJI F550 and S1000 UAs carrying cameras, LiDAR, thermal imagers and other sensors to conduct flights below 400 ft. AGL within visual line of sight of the Pilot in Command (PIC) and Visual Observer (VO).

The DJI F550 and S1000 UASs are proven, readily available systems that meet the requirements of Section 333 of the FMRA due to their weight, speed, and operational capabilities.

The F550 is a 6-rotor, VTOL, battery-powered UA with the following basic specifications:

 Total weight with maximum allowable payload: 6.5 lb

 Dimensions: Diameter: 21.65 in, Height (with landing gear): 10.5 in.

 Maximum speed: 30kts

 Battery system (4-cell, 14.8 volt, 4000maH lithium-polymer) provides 12 to 15 minutes of flight time, and 3 minutes of reserve for RTH function if

necessary,

 NAZA-M V2 Flight Controller (with GPS and compass), incorporating Intelligent Orientation Control, loss-of-telemetry Return-to-Home failsafe modes, and advance attitude stabilization algorithms.

The S1000 is an 8-rotor, VTOL, battery-powered UA with the following basic specifications:

 Takeoff Weight, Maximum: 24.2 lb

 Basic Weight: 9.3 lb

 Diameter: 41.1 in

 Battery: 6-cell 22.2V, 20000mAh lithium-polymer provides 12 to 15 minutes of flight time, and 3 minutes of reserve for RTH function if

necessary DJI A2 Flight Controller (with GPS and compass), incorporating Intelligent

Orientation Control, loss-of-telemetry Return-to-Home failsafe modes, and advance attitude stabilization algorithms.

Flight control will use FASST-modulated spread-spectrum 2.4 GHz band telemetry with FCC-approved industry-standard equipment. Additional telemetry, when required for servos or sensors, may use the 900-915, 1.3 GHz, and 5.8 GHz bands and will be configured to comply with all FCC rules and to protect the integrity of the 2.4 GHz flight control datalink.

The FAA has issued grants of exemption for commercial operations of the F550 and S1000 in circumstances similar in all material respects to Airborne Geomatics’ proposed operations. Examples include:

F550: Exemption No. 11397 to Colorado Cartographics; Exemption No. 11312 to Southgate Films Inc.; Exemption No. 11430 to Aerial Optics; Exemption No. 11378 to Shanon Kern; and Exemption No. 11318 to Micro Drone Vision, Inc.

S1000: Exemption No. 11731 to D&C Inspection Services, Inc.; Exemption No. 11732 to Terraplance, LLC; Exemption No. 11733 to The Visual Arts Group, LLC; Exemption No. 11694 to Accupoint, Inc.; Exemption No. 11633 to Principia Inc.; Exemption No. 11318 to MicroDrone Vision Inc.

The Airborne Geomatics UAs will be operated and maintained in accordance with their respective Operations and Maintenance Manuals within the requirements of Section 303 of the FMRA and 14 CFR, and according to best-practice industry guidelines, to

include:

 Minimum crew shall consist of the Pilot in Command (PIC) and the Visual Observer (VO). The PIC may deem other crew essential to the safe operation of the aircraft to include: a sensor operator, instructor, trainee, or other persons necessary for the safe operation of the flight.

 The UA will be operated within visual line of sight (VLOS) of the PIC and VO at

all times.

 The PIC and Observer will be able to communicate verbally at all times.

 Prior to each flight the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for safe flight.

 Maintenance, alterations and repairs will be in accordance with the manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements, and will be recorded in the Aircraft Maintenance Log.

 All flights will be conducted under daylight visual meteorological conditions (VMC).

 Flights will operate at no more than 400 ft. AGL, and at speeds less than 87 knots or maximum UA operating speed, V NE , whichever is less.

 Maximum takeoff weight the F550 will not exceed 6.5 lbs. Maximum takeoff weight of the S1000 will not exceed 22 lbs. No operations will be conducted within 5 nautical miles of an airport reference

point (ARP) or the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA.

 Airborne Geomatics UASs will be operated in accordance with standardized procedures as specified in the respective UAS Operations Manual, and the

Normal and Non-normal checklists.

 The PIC will conduct a briefing before each flight with the VO and any other essential crew as to the plan for the flight including: flight area, weather, potential obstacles and hazards, flight time, battery time and any other information affecting the safety of flight.

Public Interest

Small unmanned Aircraft Systems promise significant advantages over manned aircraft in some remote sensing applications.

The capability to operate at lower altitudes and lower speed than manned platforms permits image acquisition at higher resolutions, and the low altitude perspective is particularly effective for generating 3D models of terrain and structures.

Small UASs often have significantly lower acquisition and operating costs compared to manned platforms. This advantage makes imagery and remote sensing data more accessible to businesses, government agencies, research organizations, universities, and the public than would be the case without this developing technology.

Small UASs, particularly electrically powered ones such as the F550 and S1000, have a smaller environmental impact than manned platforms. They do not consume fossil fuels or emit air pollution, and have a smaller noise footprint. They do not require extensive infrastructure such as runways, taxiways, and hangar facilities.

Small UAS operations reduce the safety risk to personnel by eliminating the requirement to place flight crews at risk in aircraft operating at low altitude and in 'dangerous, dirty, and dull' scenarios.

Equivalent Level of Safety

The F550 and S1000 UAs are widely used and proven platforms that exploit microprocessors, GNSS, and miniaturized inertial units to provide a high level of mission reliability and safety in the hands of trained operators.

In normal operations flight path and orientation are precisely controlled by the GPS/compass system. System logic provides multiple fail-safe modes. In normal operations the UA will autonomously execute a pre-planned course and altitude, such as a survey grid pattern.A Return-to-Home (RTH) mode may be activated manually, or automatically in the case

of loss-of-telemetry or low voltage. RTH will autonomously return the UA to its origin point and execute a landing.

Enhanced stability and orientation is provided by an on-board IMU and associated barometric altimeter. If the GNSS signal is lost, the system will maintain a level attitude and constant altitude, allowing the PIC to recall the UA manually.

Intelligent Orientation Control aligns flight control inputs with respect to the PIC position rather than aircraft heading, greatly facilitating flight path control in manual flight.

The multi-rotor design of the F550 and S1000 is capable of controlled flight in case of motor or propeller failure, providing and additional layer of safety.

Airborne Geomatics is committed to maintaining a culture of operational reliability and flight safety. Standardized procedures and crew resource management will be conscientiously applied in all flight operations, and equipment will be rigorously inspected and maintained in accordance with the User Manuals and manufacturers

bulletins.

The technical capabilities of the F550 and S1000 UAs, and the use of best-practice maintenance and operating procedures will ensure an equivalent level of safety to manned aircraft operations.

Conclusion:

The proposed operations in this Petition for Exemption satisfy the criteria of Section 333 of the FMRA, and the FAA has issued grants of exemption in circumstances similar in all respects to those presented by Airborne Geomatics in this Petition for Exemption.

I, Douglas Stern, DBA Airborne Geomatics, respectfully submits that this Petition for Exemption qualifies for expedited approval via the FAA’s summary grant process.

Thank you for your consideration of the requested exemptions.

Sincerely,

Douglas Stern,

DBA Airborne Geomatics