Monday, August 10, 2015



### U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 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);91.417 (a) & (b).

To whom it may concern,

In pursuant with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Staeppen Metrology an operator of a small Unmanned Aircraft System (sUAS) for Environmental/Civil/Structural engineering industry, seeks an exemption from the Federal Aviation Regulations (FARs) to allow commercial operations of its sUAS.
Staeppen Metrology’s requested exemption would permit the operation of a sUAS under control led conditions in project airspace that is: (i) limited, (ii) predetermined, (iii) subject to controlled access through our customers, and (iv) provides greater safety in connection with aircraft operations. Staeppen Metrology believes that an exemption in the engineering industry would enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to est ablish safe operations of sUAS.
A current WorkZoneSafety.org published document analyzes work zone fatalities by d iscipline and roles from 2003 to 2013. According to this report, 10

-- ‐year itemization records fatalities for Civil Engineers, Construction Supervisors and Construction inspectors at over 240 deaths. This is remarkable because these numbers consist of only first

-- ‐line supervisory/overseeing roles with limited time on site.
Currently, there are many applications in the Environmental/Civil/Structural engineering field that requires access through inefficient, tedious and dangerous methods. These tasks requir e an engineer to traverse, climb, or get in dangerous proximity of a subject to determine the correct action to take. Site visits and explorations for areas such as deteriorating bridge structures, eroded and unstable river channel banks or sinkholes and h eavily trafficked road construction zones present an extremely hazardous environment for engineering data collection. Even su rface parking studies require a long schedule of engineers on foot walking through active parking lots and streetscapes to manually record parking behaviors. In addition, areas of environmental contamination pose enormous respiratory risk for engineering inspections and site survey. Staeppen Metrology intends to utilize sUAS to greatly reduce the dangers of human exposure in these sit es.
Staeppen Metrology is a remote sensing survey company serving the Civil/Structural /Architectural and Construction industry specializing in remote sensing services across the continental United States. Staeppen Metrology’s Application Engineers have bee n involved in engineering designs and inspections industry over the last 20 years. Staeppen Metrology’s sUAS flights will be flown to achieve an aerial view, video recording, signal analysis, laser measurement and concentration measurements.Data captured from the flights will provide valuable date to assist in engineering proposals, design and

necessary actions

. The sUAS missions will be planned and executed with the highest level of safety in mind. The primary objective is safely collect data within a rel atively small flight window (typically 15 mins) and return to landing. Even in areas of heavy traffic, flights will be conducted as to minimize direct overhead exposure to people and moving traffic, eg. Over road centerline, grass swales, etc. For every fl ight that Staeppen Metrology performs, inspection task performed will be preplanned and coordinated with the crew to ensure full safety and success. Flight elevations will typically be below 200ft MSL and in rare cases be between 200

– 400ft MSL.

Informat ion Supporting this Petition as Specified in 14 C.F.R. §11.81

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, telephone number, or e

-- ‐mail address;


### Staeppen Metrology Gene E. Gladden GISP AM ASCE 2523 5 SE Klahanie Blvd # A104 Issaquah, WA 98029 425

- 281

- 7288 E mail: gene@staeppen.com

(b) The specific section or sections of 14 C.F.R. from which Staeppen Metrology seeks an exemp tion

 21

– Subpart H Certification procedures for products and pa rts, Airworthiness Certificates

 45 .23

– Display of marks; general

 61.113

-- ‐ Private pilot privileges an d limitations: Pilot in command

 91.103

– Preflight Actions

 91.105

– Flight crewmembers at stations

 91.109

– Flight instruction; Simulated instrument flight a nd certain flight test

 91.119

– Minimum safe altitudes: General

 91.121

– Altimeter settings

 91.151

– Fuel requirements for flights in Visua l Flight Rules (VFR) conditions

 91.203

– Civil a ircraft: certification required

 91.405

– Maintenance required

 91.407

– Operation after maintenance, preventative maintena nce, rebuilding, and alteration

 91.409

– Inspections

 91.417

– Maintenance records
We believe an exemption from the above regulations will allow Staeppen Metrology to conduct the needed work as described abo ve.
(c) The extent of relief Staeppen Metrology seeks, and the reason Staeppen Metrology seeks the relief
Staeppen Metrology seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent to operate small UASs around f or engineering data collection.

14 C.F.R. 21

– Subpart H Certification procedures for products and pa rts, Airworthiness CertificatesStaeppen Metrology seeks exemption from 14 C.F.R. 21, Subpart H which states the certification

procedures for products and par ts as well as airworthiness certificates. Due to the limited airspace that Staeppen Metrology will be using at project locations across the country, we are seeking exemption to the airworthiness certification process. Staeppen Metrology has developed our o wn training procedures and regulations to promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) of this petition. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor
passe nger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the opera tor, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation.
14 C.F.R. § 45. 23 (b). Marking of the Aircraft
Staeppen Metrology seeks exemption from 14 C.F.R. 45.23 , which discusses the display of marks. Specifically, section 45.23 states, “(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 ligh t

-- ‐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, t he words “limited,” “restricted,” “light

-- ‐ sport,” “experimental,” or “provisional,” as applicable”.
Staeppen Metrology will need exemption from this regulation due to the small size of the aircraft and that there is no cabin, cockpit, or pilot station fo r the aircraft. The words “Experimental” can be placed on the fuselage in compliance with §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the following exemp tions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Staeppen Metrology seeks exemption from 14 C.F.R. 61.113, which discusses private pilot pri vileges and limitations for the Pilot in command (PIC). Staeppen Metrology is seeking exemption from this regulation, because Staeppen Metrology believes that there is inconclusive evidence that a person with a private pilot certificate can successfully ma neuver a sUAS without first hand flight experience with the particular sUAS. In fact, having a private pilot license does not automatically ensure competence at flying an sUAS in 3 rd person view as required to properly operate an sUAS within the required l ine of sight. However, we believe that the PIC and our FOVO (Field Operation Visual Observer) must be able to understand and correctly interact with the general aviation community. Therefore, we believe our own flight training with the sUAS will be more th an satisfactory. Our PIC and FOVO will be both certified in Ground School training to be able to properly interact with General Aviation protocols. They will also actively pursue a private pilot’s license as well have the ne cessary medical qualifications.

14 C. F.R. 91.103

– Preflight Actions
Staeppen Metrology seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, andany known traffic delays of which the pilot in c ommand has been advised by ATC; actions, including

reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before starting a flight. Staeppen Metrology’s will be operating our sUAS in VFR. Our operations manual already includes preflight procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning details regarding weather conditions, review of any possible flight path of general aviation, our mission flight path and weather conditions amongst other parameters required to complete the mission.

14 C.F.R. 91.105

– Flight crewmembers at stations
Staeppen Metrology seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. Specifically, 91.105 states “(a) During takeoff and landing, and while en route, each required flight crewmember shall (1) Be at the crewmember statio n unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.

-- ‐ registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if (1) The seat at the crewmember's station is not equipped with a should er harness; or (2) The crewmember would be unable to perform required duties with the shoulder harness fastened. Staeppen Metrology will need exemption from this regulation due to the fact that the sUAS will not have a flight crew or crew stations other th an the PIC and a Spotter. The PIC will also not have to be restrained into a seat via shoulder harness or safety belt at the time of the flight.

14 C.F.R. 91.109

-- ‐ Flight instruction; Simulated instrument flight and certain flight tests

Staeppen Metrolog y seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated instrument flight, and certain flight tests. Specifically, 91.109 states “(a) No person may operate a civil aircraft (except a manned free balloon) that is being used fo r flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when (1) The instructor has determined that the flight can be conducted safely; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (b) An airp lane equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recen t flight experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command dur ing the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot

-- ‐in

-- ‐command flight time in the make and model of airplane; a nd (4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless (1) The other control seat is occupied by a safety pilot who possesses at le ast a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the

v ision of the safety pilot; and (3) Except in the case of lighter

-- ‐ than

-- ‐air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

-- ‐ engine airplane, equipped with a si ngle, functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when (i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a priva te pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 pr oficiency flight test,unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in

command of the aircraft”. Again, Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or spars ely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

-- ‐shift

-- ‐control aircraft. If the operation is conducted without hazar d to persons or property on the surface

— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescri bed for helicopters by the FAA; and (2) A powered parachute or weight

-- ‐shift

-- ‐control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section (a) Each person operating an aircraft shall maintain the cruising altitud e or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the airc raft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92′′ Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table: Staeppen Metrology believes that there is inconclusive evidence that a person with a private pilot certificate or license can successfully maneuver or train someone to use an sUAS without first hand flight experience with the particular sU AS. Flying in 3 rd person orientation requires built

-- ‐up experience in that form of flying for many years. Therefore, we believe our own flight training, pilot protocols and first hand experiences with the sUAS as laid out in our Flight Operations Manual m eets and exceeds the requirements necessary to safely operate our sUAS for the tasks we purpose . Also, the sUAS will be operated by a remote control, which will only require a single person operator and dual controls will not be necessary.

14 C.F.R. 91.119

– Minimum safe altitudes: General
Staeppen Metrology seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Since project needs are low

-- ‐level data collection and the majority of flight will be less than 200ft MSL and no more than 400ft MSL, this would not pertain to our sUAS operations

14 C. F.R. 91.121

– Altimeter settings
Staeppen Metrology seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest usable flight level.

C.F.R. 91.121 states
, Current altimeter setting Lowest usable flight level 29.92 (or higher) 180 29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot

shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the curr ent reported altimeter setting:”

Current altimeter setting Adjustment factor 29.92 (or higher) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000

Staeppen Metrology’s sUAS uses both GPS altitude and barometric sensors and relays that information to our ground station. However, this data is used help the sUAS to automatically maintain position hold at the required elevation and therefore this code is not pertinent the functionality of this sUAS.

14 C.F.R. 91.151

– Fuel requirements for flights in Visual Flight Rules (VFR) conditions Staeppen Metrology seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in VFR

con ditions. Specifically, 91.151 states “(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 cru ising 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. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather cond itions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes ”. Staeppen Metrology’s sUAS has a typical mission time of less than 15 minutes with maximum flight ti me of 25 minutes. Since this amount less than the 30 minute reserve minimum, this reserve minimum would not even make sense in allowing the sUAS a chance to fly. According to Staeppen Metrology’s aircraft flight manual, the PIC is instructed to maintain fl ight until battery power reaches 25%, or 1 st level warning. At this level, landing procedures will be initiated . Once the sUAS reads 20%, 2 nd level warning, the flight control system automatically take over and initiates safe landing sequence at the logged in takeoff point. Staeppen Metrology policy outlined in our operating flight manual achieves satisfactory safety standards.

14 C.F.R. 91.203

-- ‐ Civil aircraft: certification required

Staeppen Metrology seeks exemption from 14 C.F.R. 91.203, which discusses states:
(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subpar agraph (except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned spe cial identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon applic ation to an FAA Flight Standards district office. (2) An effective U.S. registrationcertificate issued to its owner or, for operation within the United States, the second copy of the Aircraft

registration Application as provided for in §47.31(c), or a reg istration certification issued under the laws of a foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displaye d at the cabin or cockpit entrance so that it is legible to passengers or crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger compartment or a baggage compartment unless the installation was accomplished pursuant to part 43 of this chapter, and a copy of FAA Form 337 authorizing that installation is on board the aircraft. (d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United States unless it complies with the fuel ven ting and exhaust emissions requirements of part 34 of this chapter”.
Staeppen Metrology believes that an appropriate and current airworthiness certificate would not be necessary to fly a sUAS given the size of the aircraft and the necessary level of skill needed to operate the aircraft. Before putting in to service, each of our sUAS goes through our own airworthiness procedures of minimum test flight and reliability checks. Also, our sUAS are recalibrated each at the site location before each flight to ens ure that all systems functions as designed. Staeppen Metrology seeks exemption from this regulation because we believe this rule was not meant for a sUAS and operators.

14 C.F.R. 91.405 , 91.407, 91.409, and 91.417
Staeppen Metrology seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or alteration, inspections, and maintenance records. In Staeppen Metrology’s aircraft flight manual, maintenance and inspection procedures have been established for the aircraft. Staeppen Metrology believes these regulations are meant for manned operated aircrafts and not unmanned systems, therefore making them unnecessary. Nevertheless, we seek an exemp tion from any such specific provisions to the extent FAA finds it

n ecessary to grant this request.
(d) The reasons why granting Staeppen Metrology’s request would be in the public interest; that is, how it would benefit the public as a whole.
Staeppen Metrology is classified as an engineering company by the U.S. Department of Transportation and provides services to the engineering industry. Staeppen Metrology’s use of a sUAS can assist in collecting and verifying critical data for design projec t. With Staeppen Metrology’s sUAS usage in the engineering industry, we will be able to gather valuable information to help increase safety and productivity. In addition, the sUAS flights will be putting fewer lives in danger.
(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which Staeppen Metrology seeks exemption Our Engineering department will provide a level of safety that exceeds the level of safety required by the FAA for its use on sUAS. The following are Staeppen Metrology’s safety procedures, features, regulations, and operati ng specifications for our sUAS:

 The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will be required to wear (PPE) hard hats, safety vests, and safety glasses to protect the head and eyes from potential mishaps during given operational flights includi ng training or testing of sUAS.

 The flight area of the sUAS will be observed for best take

- off and landing locations. Desired conditions include: flat and level surfaces clear of debris, at least 15ft from power lines and structures, and a minimum distance of 1 2ft from the PIC and observers. The sUAS will also be in the Visual Line of Sight (VLOS) to both the P IC and FOVO during all flights.

 Flights must take place during good weather conditions with no rain, low laying clouds, or heavy winds. All flights will take place during daylight hours with no evening or late night flights. The P IC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being designated working flights around cellular communication towers.

 All batteries must be charged completely before each flight and each flight must end when the battery h as a 25% power level remaining.

 A visual safety inspection will occur before each flight, testing propeller tightness, security mount of camera/detection equipment, remote range test, and proper safety equipment is adorned to PIC and FOVO.

 The sUAS will be flow n under a height of 500 ft AGL.

 No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a configuration appropriate for the purpose of the intended flight.

 If there is more than just an operator at a site during a flight, the PIC operator and observer or FOVO will maintain two

-- ‐way communic ation with each other during all operations; if unable to maintain
two

-- ‐way communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the operator will imme diately conclude the operation.

 If the communication link is lost, the sUAS will go into fail

-- ‐safe mode and safely descend to its designated home

-- ‐point location. If the communication link is reconnected during fail

-- ‐safe mode, control of the sUAS can be regained before landing occur s at the home

-- ‐point locatio n.

 There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of explosion i f a crash occurs with the sUAS.

 The sUAS will feature a built in compass that will be recalibrated at every site to maintain accurate directio nal readings. The compass will also help in keeping the sUAS stable during flights.

 The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum of 6 satellites will ac tivate the Ready to Fly status.

 The weight of the sUAS i s less than 10 lbs. with a maximum ascent speed of 6 m/s and a descent speed of 2 m/s. The aircrafts maximum flight speed is 15 m/s.

 The aircrafts vertical and horizontal aspect concerning hovering accuracy is 0.8m and 2.5m respectfully.

 The typical airc raft dimensions will be 39.4 x 23.6 x 4.1 in or less.

 The aircraft runs off a 14.8 V, 6600 mAh battery
(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the exemption; and (2) A brief description of the nature of the exemption you se ek

Petitioner: Staeppen Metrology.
Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91. 405; 91.407; 91.409; and 91.417
Description of R elief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct data collection for Env ironmental/Civil/Structural /Architectural engineering services using operating procedures that
meet or exceed those that FAA requires.(g) Any additional information, views or arguments av ailable to support your request
Please see the introduction to this exemption request.
(h) If you want to exercise the privileges of your exemption outside of the United States, t he reason why you need to do so
The Operations described in this exemption request will be conducted wholly within the United States.

Please do not hesitat e to contact me via email at gene @s taeppen .com if you have any questions or concerns.

Respectfully submitted,



### Gene E Gladden , GISP AM ASCE President Staeppen Metrology