### Sanborn Map Company ’s Petition for Exemption For Purposes of Operating Small Unmanned Aircraft System

FAA Rules D ocket :

____________

Name and Address of Petitioner
Sanborn Map Company, Inc. 1935 Jamboree Drive, Suite 100 Colorado Springs, CO 80920 Counsel for Petitioner

Thomas L. Gemmell HUSCH BLACKWELL LLP 120 South Riverside Plaza, 22 nd Floor Chicago, Illinois 60606 (312) 526

- 1523 tom.gemmell@huschblackwell.com

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- 1A. Summary
The Sanborn Map Company, Inc. seeks exemption from the requirements of 14 C.F.R. §§

45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii)
, 91.151(b)
, 91.405(a),

91.407(a)(1), 91.409(a)(1) and ( 2 ), and 91.417(a) and (b) . This exemption will permit The
Sanborn Map Company, Inc. to operate an u nmanned a ircraft s ystem while keeping the
documents required by the regulations at the ground control station and immediately accessible
to the pilot in command. Furthermore, the exemption will relieve The Sanborn Map Company,
Inc. from the airworthiness certificate standards and the requirement to have a certificate of

airworthiness iss ued for its UAS. This exemption will also permit any required markings
concerning the operational status of the UAS to be displayed on the fuselage of the unmanned

aircraft.

B. I ntroduction

The Sanborn Ma p Company, Inc. (hereinafter referred to as “Sanborn”) is a 148 year

- old
design, geospatial and infrastructure management firm with a long and well

- recognized history in
mapping and surveying. Sanborn excels in the collection of aerial imagery from manned, fixed

wing aircraft for the purpose of making highly accurate aerial maps for a range of clients and
various applications. In addition to operating a fleet of conventional fixed

- wing aircraft, Sanborn
has recently acquired a Leptron Avenger Unmanned Aircraft System (hereinafter referred to as

the “Leptron Avenger”). As set forth in this Petition, Sanborn seeks to operate its Leptron
Avenger for the special purpose of aerial surveying, continuing an established legacy that has
always sought the highest standards of operations and safety.

Pursuant to 14 C.F.R. § 11.81 ( Petition for Exemptions .)
, Sanborn provides the following

information in support of its petition:

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- 1C. B ackground

1. LEPTRON AVENGER

Sanborn seeks an exemption to operate a Leptron Avenger for compensation or hire

within the national airspace system (“NAS”) 1

. The Leptron Avenger is comprised of an airborne

unmanned aircraft and a transportable ground station. The Leptron Avenger has a maximum
gross weight of approximately 35 pounds, while having a wingspan of 72.5 inches and a length

of 58 inches. The Leptron Avenger unmanned aircraft is equipped with two rotor s driven by a

Lithium

- ion Polymer battery powered 10W electric motor.

Figure 1 depicts the Leptron Avenger with registration number displayed in accordance with 14 C.F.R. Part 45.

2. Proven Operational History of the Leptron Avenger in the NAS

.

1 Sanborn has reserved registration number N824LP, and will submit an Aircraft Registration Application upon the grant of the exemptions sought by this petition. 3
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- 1The Leptron Avenger is currently operating safely within the NAS pursuant to
approximately fourteen (14) Certificates of Authorization (“COA”) granted by the Federal

Aviation Administration (“FAA”) to the Middle Tennessee State University; Sinclair Community
College in Dayton, Ohio; the U.S. Army Corps of Engineers (Jacksonville District, for operations

in South Florida); Mississippi State University for the Pearl River Basin; and the University of

Florida.

D. Basis for Petition

Sanborn
, by and through undersigned counsel, pursuant to Federal Aviation Regulations

(FAR) ( 14 C.F.R. § 11.61 ) 2 and the FAA Modernization and Reform Act of 2012 ( “ FMRA ” )
,
Section 333, Special Rules for Certain Unmanned Aircraft Systems ( “ Section 333 ” ) , hereby
respectfully petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§
, 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii)
, 91.151 (b), 91.405(a),

91.407(a)(1), 91.409(a) (1) and (2), 91.417(a) and (b)

.
1. Section 333
Congress identifies Section 333 as a pathway for “ expedited operational authorization ” of

certain unmanned aircraft systems ( “ UAS ” ) in the national airspace system ( NAS )

. Section

332(b)(1) ( “ expedited operational authorization. ” )

. 3 Under Section 333 Congress mandates that

the FAA “ shall determine if certain unmanned aircraft systems may operate safely in the national
airspace system before completion of the plan and rulemaking required by section 332 of this
Act or the guidance required by section 334 of this Act ” ( Section 33 3(a) ) upon consider ation of

its “ size, weight, speed, operational capability, proximity to airports and populated areas, and

2 14 C.F.R. § 11.61 (b) (“ Using a petition for exemption, you may ask FAA to grant you relief from current regulations in 14 C.F.R.”) 3 See also www.faa.gov/uas/legislative_programs/section_333/ (noting that Section 333 grants the FAA “the statutory flexibility to expedite req uirements for the safe operation of certain aircraft systems in the NAS.”). 4
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- 1operation w ithin visual line of sig ht

. ” Section 333(b) (1 ). I f the FAA makes such a determination,

the FAA “ shall [also] establish requirements for the safe operation

. ” Section 33 3(c)

. T he FAA

further may find that the UAS does not require “ airworthiness certification under section 44704 of

title 49, United States Code

. ” Section 333(b) (2)

.
2. 49 U.S.C. § 44701

T he FAA is further authorized to grant exemptions from its safety regulations and

minimum standards under 49 U.S.C. § 44701 ( “ Section 44701 ” ) “ if the Administrator finds
the exemption is in the public interest. ” Section 44701(f) (authorizing the grant of
exemptions from safety regulations and minimum standards under section 44701(a) and (b) and

sections 44702

- 44716). 4

For the reasons addressed herein
, this Petition q ualifies for expedited approval of

Sanborn ’s request for exemption under both Sections 333 and 44701

.
E. The Leptron Avenger UAS Meets the Statutory Criteria for Exemption under Section 333

G iven its small size, light weight, slow speed, limited load capacity, superior
operational capabilities
, and that the operations will be conducted only during the day, under
visual meteorological conditions ( “ VMC ” ), within visual line of sig ht ( “ VLOS ” ) of the P ilot In

C ommand ( “ PIC ” ) with the assistance of a visual safety observer ( “ VO ” ) and not in the proximity
of airports or populated areas, the Leptron Avenger UAS is the very sort of UAS that qualifies
for expedited approval under Section 333

.
1. Section 333(b)(1) Criteria

a. Size

4 See e.g. 49 US C §44711 ( a ) ((1) prohibiting operations without airworthiness certificate; (2) prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in violation of regulations) ; 49 US C §44 7 04 (issuance of airworthiness certificate); 14 C.F.R. §91

. 203 ( a ) ( 1 ) (carry airworthiness certificate)). 5
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- 1T he Leptron Avenger measures approximately 19.75 inches in height and 58 inches
wide, with a wingspan of 72.5 inches.

b

. Weight
The Leptron Avenger has a maximum gross weight of 35 lbs.

c

. Speed

The Leptron Avenger has a maximum autopilot limited speed of approximately 12
Meters per second (m/s ) . However, Sanborn typically operates the aircraft at below 10 m/s

d

. Operational Capability

T he Leptron Avenger was specially designed for high or low altitude surveillance,
photography, and sensor management. Supported by electric batteries that are rechargeable , the
Leptron Avenger can fly for up to 2 hours and carry a variety of cameras or sensors

. Other
Operational metrics of the Leptron Avenger are as follows:

Unmanned A ircra f t Sys tem The Leptron Avenger is an UAS that is comprised of an unmanned aircraft and a transportable ground station.

Serial No. LEP822

Unmanned A ircra f t D ime ns i ons Rotor Diameter: 72.25 in. Length: 83.93 in.

Engine (Propulsive U nit ) Engine (Propulsive Unit) The aircraft uses a 10,000 Watts electric main motor and a 2,200 watt tail motor

Electric

- powered propulsion systems.

a. Type of Motor

- 395 KV Electric Main, 900 KV Electric tail b. Current draw range

– Total System current draw cruise = 30 Amps and Max total system current draw = 360 Amps

c. All electrical demands are derived from the unmanned aircraft’s battery system.

Make: LEPTRON

- AVGR

Model: 1000

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- 1Propeller a nd Propeller Limit s FAA Propeller Type Certificate: None
Propeller Type: 2

- blade, hinged (folding), carbon fiber reinforced plastic, fixed pitch, tractor

Diameter (Nominal): 17.25 in.

Battery Command & Control Thunder Power Air Vehicle Battery P/N Leptron 6S powers the motor, and battery command and control.

Airspeed Limits Vne (Never Exceed Speed) 12 m/s)

Vno (Maximum Structural Cruising Speed) 48 knots (25 m/s)

Va (Maneuvering Speed) 12 m/s knots (25 m/s)
Landing Speed: VTOL

– Vertical 1.5 M/s

Empty Weight C.G. Range 3

- 3.5 inches for or aft of datum

Datum Center of main rotor shaft

Maximum Weights 14.52 KG / 32 lbs.

Empty Weight 4.99 KG/ 11 lbs.

NOTE: Empty Weight Excludes weight of battery and payload modules.

Frequencies 902

- 928 MHz (ISM Band) 2.4 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above frequencies; uplink and downlink are on the 900Mhz band. If video is utilized, uplink, downlink, and video are all on 2.4 Ghz.

Computer Software Avionics embedded processor

– UTC Aerospace Cloud Cap Technologies

Max. Operating Altitude 20 ,000 ft. +

Control Surface Movements MAIN ROTOR

– VARIABLE PITCH +/

- 5

TAIL ROTOR

– VARIABLE PITCH +12/

- 12 °

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- 1Nominal Endurance 30 minutes above 32 °F (0 °C)

15 minutes below 32 °F (0 °C)

Ambient Outside Air Temperature (OAT) Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: 0 °F

Wind Limitation 40 MPH

Maintenance This Leptron Avenger must be maintained in accordance with the Leptron Maintenance Operation Manual, or later FAA accepted revision.

e

. Proximity of Airports/Populated Areas

F light o pe r a t i ons pursuant to t h i s Petition w i l l be t i g h t l y con t r o ll ed and restricted to
Class G airspace , which is defined as earth surface up to 1,200 feet above ground level and earth
surface to the base of controlled airspace (Class B, C, D, and E)
, and not in the proximity of
airports or populated areas

. The Leptron Avenger will not be operated within 5 nautical miles of
the geographic center of a non

- towered airport unless a letter of agreement with that airport’s
management is obtained, such letter to be made available to the Administrator upon request, and
the operation is conducted in accordance with a NOTAM a s required by the operator’s COA.
Operations will avoid congested or densely populated areas and comply with 14 C

. F

. R

. 91.119

.
f

. Visual Line

- of

- Sight

T he Leptron Avenger will at all times be flown by Sanborn only in the daytime (not at
night) under VMC within VLOS of the PIC (typically wit hin a range less than 500 feet) with the

further assistance of a VO with whom the PIC will have the ability for direct and continuous

verbal communication s 5 so as to ensure that the flight operations remain w i t h i n the PIC’s VLOS

5 VO will at all times be in proximity of PIC so as to allow direct verbal communication s. In addition, the PIC and VO will maintain direct communications through cell or push

- to

- talk communications capability throughout the duration of flight. 8
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- 1and prescribed flight boundaries and deconflict with objects in the air and on the ground. Thus
, pursuant to the FAA’s Interim Operational Approval Guidelines for UAS the proposed
operations provide an approved method of control and collision avoidance to satisfy the “ see and

avoid ” requirement of 14 C

. F

. R

. § 91.113 :
While considerable work is ongoing to develop a certifiable “ detect, sense, and avoid ” system, no current solution exists. C ompliance with the “ see and avoid ” aspect of 14 C.F.R. 91.113, Right

- of

- Way Rules: Except Water Operations , becomes one of the primary issues in UAS operational approvals. As a result, alternate methods of compliance are required to accomplish the “ see and avoid ” function. See an d avoid risk mitigation strategies are normally based on the use of visual observers or other methods of segregation.
Interim Operational Approval Guidance 08

- 01, Unmanned Aircraft Systems Operations in the
U.S. National Airspace System (March 13, 2008) a t 8

. Only qualified and current PIC’s and

VOs , as provided in the FOD (as defined below)
, will be used

.
2. Other Factors

a. Leptron Avenger S afety Systems

T he Leptron Avenger UAS is replete with mechanisms to ensure safe operations and
protect persons and property on the ground. In addition to having experienced operator/ PIC and

VO
, the Leptron Avenger UAS has a variety of inherent safety systems, including :

• Redundant Communications: The Avenger has (2) simultaneous communications

link s that allow for backup and safe operations. This includes a 2.4 GHz wireless
hand held radio and a 900 MGhz laptop ground station link. Both links must be
terminated to execute a ‘Lost Communication’ return home logic

.

• Flight Plan Altitude Settings: The Avenger has the ability for the operators to set
Maximum and Minimum flight altitudes for a specific flight ‘corridor’ for safe
operations.

• Flight Logic: The Avenger has the ability for the operators to set safety return

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- 1logic including: Exceeding a pre

- set flight timer, Loss of GPS, Loss of

Communications, Max and Min Altitude, and Low Voltage

.

• Ground Station Warnings: The Avenger Ground station has many visual operator
cues for error conditions such as low RSSI strength, low battery, low RPM, low

s ystem parameters, and many other real time conditions. The system also offers
color coded ‘Dashboard’ lights for the operator.

• Double Entry : The Avenger Ground Station has double entry response window

for all in

- flight parameter changes. This allows the user to not send incorrect

information without a two verification mouse clicks.

b

. Flight Operations Documents
To ensure consistent safety operations, Sanborn has developed a comprehensive and

detailed set of flight operations documents (FO D ) for the Leptron Avenger UAS based on

Sanborn ’s extensive use and experience
, procedures and notices provided by the UAS

manufacturer , and guidance the FAA has provided to obtain exemption under Section 333

. The
FOD is comprised of the Sanborn Standard Operating Procedures, the Sanborn Maintenance and
Safety Manual, the Leptron Remotely Piloted Vehicle Operators Manual, and the Leptron
Inspection and Maintenance Manual. S ee Exhibit A (submitted on a confident ial basis).
In seeking this exemption, Sanborn proposes to operate the Leptron Avenger pursuant to

the following specific operating limitations, as also addressed in the FOD :

1. Flight operations are permitted only in Class G Airspace.

2. The Leptron Avenger shall only be operated below 1,200 f ee t above ground level (AGL)

3. The Leptron Avenger shall be operated within line of sight of the pilot in command and
safety observer.

4. The Leptron Avenger shall be operated pursuant to Day Visual Flight Rules (VFR) in

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- 1visual meteorological conditions (VMC). The Leptron Avenger shall be operated only
during daylight hours ( i.e. between the end of morning civil twilight and the beginning of
evening civil twilight, as published in the American Air Almanac, converted to local

time).

5. The duration of each flight shall not exceed 1.5 hours , or with 20% battery power
remaining, whichever occurs first

.

6. The Leptron Avenger shall operate from on

- site takeoff/landing locations directly next to

the pilot in command and co

- located VO . The pilot in command and the VO shall be able
to verbally communicate during all operations. If the operation is from a watercraft, the
pilot in command and VO shall remain co

- located on the same watercraft.

7. Operation of the Leptron Avenger with any inoperative instruments or equipment is
prohibited.

8. The Leptron Avenger shall be operated pursuant to 14 C.F.R. Part 91, operating
requirements.

9. For the proposed flight operation, only one Leptron Avenger shall be airborne at any
given time.

10. The PIC shall give the local Air Traffic Control (ATC) a single pre

- flight call with the
location, approximate start time, and approximate finish time of the operation. The PIC
shall notify the local ATC upon completion of the operation.

11. For any flight operations over U.S. Government or state managed lands, Sanborn shall

coordinate with the appropriate authority and ensure that the property owners have at least

twelve (12) hours of advance notice prior to the proposed flight operations. Coordination

shall include anticipated periods of operation, purpose of the flights, and contact

information for the operator should questions or issues arise.

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- 112. The UA shall be marked with an identification (N

- Number) in accordance with 14 C.F.R.

§ 45.23 , such markings to be as large as practicable pursuant to 14 C.F.R. § 45.29(f) , and
identified by a serial number registered in accordance with 14 C.F.R. P art 47.

13. The UA shall only be operated at or below an airspeed of 12 Meters Per Second

.
14. Prior to performing any flight operations, the PIC and VO shall have successfully
completed a qualifying process, as provided in the F OD

.
15. Prior to performing any flight operations, a flight demonstration administered by an

operator

- qualified PIC and provid ed in the FOD , shall be performed and successfully
completed

. Documentation of such demonstration shall be made in the aircraft records
and such records shall be made available to the Administrator upon request.

16. The UA shall not be operated less than 500 feet below or less than 2,000 feet horizontally
from a cloud or when visibility is less than 3 statute miles from the PIC.

17. The UA shall at all times remain clear and yield the right of way to all other manned
operations and activities ( e.g. gliders, ultral ights, parachutes).

18. The radio frequency spectrum used for operation and control of the UA shall comply
with the requirements of the Federal Communications Commission (FCC) or other
appropriate government oversight agency.

19. Any time the UA is operating, all documents required under 14 C.F.R. § 91.9 and §

91.203 shall be available to the PIC at the GCS. Such documents shall be made available
to the Administrator or any law enforcement official upon request.

20. The UAS shall not be operated by the PIC from any m oving vehicle or device ; however
the UAS may be operated by the PIC from a stationary watercraft

.
21. The UA shall not be operated directly over any person, except authorized and consenting
personnel involved in the flight/filming operations, below an altitude that is hazardous to

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- 1persons or property on the ground in the event of a UAS failure or emergency.

22. T he UA shall at all time s be operated to ensure a safe distance away from all
participating and non

- participating personnel.

23. Other than for takeoff and landing, the UA shall be operated at least 100 feet away from
persons involved in the flight/filming operations (participating persons) , such
participating persons shall at all times be essential to the flight/filming operations and
have provided prior written consent to their participation in such operations. This
distance may be reduced to no less than 30 feet if it would not adversely affect safety and
such person provides his/her prior consent.

24. The UA shall at all times be op erated 500 feet away from persons not involved in the
flight/ filming operations (non

- participating persons) . This distance may be r educed to no

less than 2 00 feet if it would not adversely affect safety and such person provides his/her
prior consent

.
25. Prior to each flight the PIC shall inspect the UAS , including for any inoperable
components, items or equipment, to ensure the UA S is in a condition for safe flight. If
the inspection reveals a condition that affects safe operations, the UA S shall not be
operated until the necessary maintenance has been performed and the UAS is found to be
in a condition for safe flight. Any discrepancies and all maintenance or alterations shall

be doc umented in the aircraft records, such records to be made available to the
Administrator upon request.

26. Any UAS that has undergone maintenance or alternations that affect the UAS operation
or flight characteristics, e.g. replacement of a flight critical component, shall undergo a
functional test flight in accordan ce with the FOD . The operator shall make an entry in
the UA record of such test flight.

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- 127. Record of the UAS maintenance, preventive maintenance, alternations, status of
replacement/overhaul component parts, and the total time in service of the UAS shall be

documented and maintained in accordance with the FOD

.
28. Except as may be designated otherwise for FailSafe operations, t he UA shall take off and

land at a location within the boundaries of the subject property next to the PIC.

29. Upon loss of communication or GPS signal, the UA shall return to a predetermined
location within the boundaries of the landowner’s property and land or be recovered in

accordance with the FOD

.
30. In the event of an emer gency or unanticipated obstacle to plann ed operations, the UAS
operation shall be aborted and the UA, if airborne, shall return to a predetermined

location.

31. The PIC shall possess at least a private pilot certificate and at least a current third

- class

medical certificate , and p rior to opera tions shall have met the FAA’s currency and

recency of experience requirements

.
32. Prior to operations, the PIC shall have accumulated and logged (in a manner consistent

with 14 C.F.R. § 61.51(b)) a minimum of 200 flight cycles and 25 hours of total time as a
UAS rotorcraft pilot and at least ten (10) hours as a UAS pilot with a similar UAS type

( dual

- rotor), such log of which shall be made available to the Administrator upon request.

33. Prior to operations, the PIC shall have accumulated and logged (in a manner consistent

with 14 C.F.R. § 61.51(b)) a minimum of five (5) flight hours as a UAS pilot operating
the make and model of UAS to be used for operations under the exemption ( e.g. Leptron
Avenger ) and three (3) take

- offs and three (3) landings in the preceding 90 days, such log
of which shall be made available to the Administrator upon request.

34. The UAS shall be maintained in accordance with the Leptron Inspection & Maintenance

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- 1Manual , including any amendments or updates thereto. All amendments or updates shall

be tracked and a record of such amendments or updates shall be maintained and made
available to the Administrator upon request.

35. All maintenance to be performed on the UAS shall be performed by a technician
qualifi ed pursuant to the criteria provided in the FOD

.
36. The UAS shall comply with all manufacturer safety bulletins.

37. Prior to conducting any operations , the operator shall obtain a Certificate of Waiver or

Authorization (C OA). Pursuant to such COA, operator shall request of a Notice to
Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to
the operation.

38. At least three (3) days before scheduled operations, operator shall submit a written P lan

of Activities to the local Flight Standards District Office ( FSDO ) with jurisdiction over
the area of proposed operations, such submission of which may be waived with the

concurrence of the FSDO. If required by the FSDO to be submitted, t he Plan of

Activities shall include : dates and times for all flights; operator’s and on

- scene flight
operator’s name and phone number ; UAS make, model and serial or N

- number ; PIC’s

name and certificate number ; statement that the operator has obtained permission from

proper t y ow ner s and/or local officials to conduct the operations (such list of those who
gave permission to be made available upon request) ; description of the planned flight
activity, including, as applicable, maps or diagrams of the area, city, town, cou nty and/or

state over which the operation will be conducted, and the altitudes essential to
accomplish the operation; signature of the exemption holder or representative.

39. The UA shall not operate within 5 nautical miles of the geographic center of a non

t owered airport unless a letter of agreement with that airport’s management is obtained,

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- 1such letter to be made available to the Administrator upon request, and the operation is
conducted in accordance with a NOTAM as required by the operator’s COA.

40. Any inc ident, accident or flight operation that transgresses the lateral or vertical
boundaries of the operational area as defined by the applicable COA shall be reported to
the FAA’s UAS Integration Office within 24 hours. Accidents shall also be reported to

th e National Transportation Safety Board (NTSB). Further flight operations shall not be
conducted until the incident, accident or transgression is reviewed by UAS Integration
Office and authorization to resume operations is provided.

41. The UAS shall be operat ed pursuant to the FOD , such manual to be made available to the
Administrator upon request. If a discrepancy exists between the FOD and the conditions
and limitations directed by the Administrator in granting the exemption , the conditions

and limitation in the exemption shall take precedence and be followed.

c

. Privacy

Sanborn will comply with all federal, state, and/or local privacy regulations that may
apply in the areas in which Sanborn will operate the Leptron Avenger pursuant to this Petition.

Further, Sanborn ’s policy, as outlined in the FOD
, is to avoid any operations that might
invade personal privacy

.
d

. Physical Security

In order to ensure its safe and proper us e , Sanborn will be the only operator of the UAS

and the UAS will at all times remain in Sanborn ’s custody

.
3. Sanborn ’s History of Safe Operations Flying the Leptron Avenger UAS
Sanborn has amassed nearly 10,000 fixed

- wing flight hours in the past four years of
aerial surveying with only one accident and has conducted local test flights of the Leptron
Avenger UAS by FAA certified pilots checking operations, flight deconfliction and safety

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- 1procedures of over 50 hours.

4. Lack of Threat to the NAS, Public, or National Security

T hose reasons addressed, including meeting Section 333( b)(1) criteria, Sanborn ’s

established record of safety
, operations pursuant to the FOD
, and the other factors discussed
,
demonstrate that the Leptron Avenger UAS will be operated safely in the NAS without creating a

hazard to other aircraft or persons or property on the ground or pose a threat to national security

. For all of these reasons, Sanborn ’s proposed operations using the Leptron Avenger qualify for
expedited approval of the sought exemption pursuant to Section 333 for the specified uses and

under the proposed operating requirements and restrictions.

F. Sanborn ’s Operations Pursuant to This Petition Qualify for Exemption Under Section 44701

.

Granting Sanborn ’s request for exemption would benefit the public and have no
adverse effect on safety. Accordingly, Sanborn ’s operations pursuant to this Petition also
qualify for an exemption from the FAA’s related safety regulations under Section 44701

.
1. Public Interest Benefits
The public would greatly benefit from granting Sanborn ’s petition for exemption so it

can use the Leptron Avenger UAS. The Leptron Avenger is a battery powered UAS that serves

as a safe, efficient, and economical alternative to manned aircraft traditionally use for aerial
surveying

. No pilot or crew need be airborne, thereby providing for superior safety to persons
and property in the air and on the ground than that provided by manned aircraft performing the
same operations. Granting the exemp tion would also reduce the number of manned aircraft in

the NAS and
, as a result
, reduce the environmental impact of such operations
, as well as provide

for better aerial imaging and production and, as a result, a more robust economy

. Using the

Leptron Avenger also provides the benefit of greater operational flexibility and reduced cost when

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- 1compared to manned aircraft.

(a) Increased Aircrew Safety and Reduced Risk to P ersons/ Property On G round

Because the Leptron Avenger is unmanned, the proposed operations eliminates the risk to
pilot and crew associated with flying such aerial

- surveying missions at low altitude
, in confined
airspace

. Further, g iven its small size and weight and low air speed
, using the Leptron Avenger also
reduces the risk of damage or injury to persons or property on the ground , and in the air, were there

to be a mishap

. (b) Reduced Environmental Impact

U sing the Leptron Avenger UAS instead of manned aircraft also benefit s the public by
eliminating or greatly reducing air and noise pollution associated with traditional aerial surveying
operations

. Because it is battery power ed (using rechargeable batteries) and uses electric motors,

the Leptron Avenger UAS consumes no fuel and generates no air pollution
, and creates very little

noise . As a result, the public is benefited as a result of reduced enviro nmental impact, r educed

operator and other human exposure , and greater fuel conservation, which serves additionally

to su pport our g overnmen t’s specific effort s to reduce the U.S.’s carbon footprint. 6

(c) Fewer Manned Aircraft In NAS and Reduced Need for ATC Handling

The Leptron Avenger also does not require a runway or helipad to takeoff or land and
will not be operated within the proximity of any airports

. As such , fewer aircraft will need to be

handled by a ir t raffic c ontrol during ground, takeoff, departure, arrival, and landing phases.
Operations pursuant to this Peti tion (unmanned, VLOS, below 1,2 00 ’ AGL , and not within
proximity to airports) will further reduce the number of manned aircraft flying or transiting at or

above 500’ AGL to and from the areas of surveying operations as well as congestion around

6 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental Protection Agency’s regulatory efforts to phase out the use of fossil fuels

. 18
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- 1airports due to aircraft arrival and departure.

(d) Superior Aerial Imagery and Increased Benefit to U.S. E conomy

B etter aerial footage can also be obtained using the small and nimble Leptron Avenger than

can be obtained using manned aircraft or other ground

- based methods

. Due to its small size and
superior flight performance characteristics, the Leptron Avenger allows for images to be taken from

certain locations and angles and with better precision than using manned aircraft

. As a result, less

time is needed in the air to obtain the desired footage
, which in addition to providing the benefit of

fewer aircraft in the NAS and associated reduced risk to objects and persons and property in the air
and on the ground, reduced noise, etc., allows for the production of surveys , which benefit s

consumers

. This additionally ensures that companies such as Sanborn and its customers remain
competitive and profitable, thereby providing their employees greater job stability, which
ultimately contributes further to the U.S. econom y through increased consumer spending

. (e) Increased Operational Flexibility and Reduced Cost
Using the Leptron Avenger also provides the benefit of greater operational flexibility and

reduced cost when compared to manned aircraft. Instead of each time having to hire a manned

aircraft at thousands of dollars/hour, subject to the pilot’s schedule and availability, Sanborn can
operate the Leptron Avenger , which it has purchased and outfitted at lower combined cost
,
innumerable times and at the convenience of Sanborn ’s and its customers schedules

.
2. No Adverse Safety Effects
Granting Sanborn ’s Petition will also not adversely affect aviation safety or pose any

undue risks to the public. The operations pursuant to this Petition will be in accordance with

Sanborn ’s FOD and in c o m p li ance w i t h all applicable pub li c s a f e t y r e q u i r e m en t s

. Accordingly,

and as detailed herein, g ranting the requested exemption would not adversely affect safety.

Indeed
, as detailed below
, operations pursuant to the limitations and guidelines addressed herein

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- 1and in the FOD will provide a n equivalent or even higher level of to those regulations from

which Sanborn seeks exemption

.

T he FAA has previously granted e x e m p t i ons in circumstances similar, in all material

respects, to those presented herein

. See Exemption Nos. 11062, 11063, 11064, 11065, 11066

,
11066A, 11067 , 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161

.
For all of these reasons, Sanborn ’s operations pursuant to this Petition also qualify for an
exemption under Section 44701

.
G

. Exemption s Sought By Sanborn And Reasons For The Requested Relief

Pursuant to Section 333, Sanborn seeks an exemption from the requirements of 14 C.F.R.

§§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii)
, 91.151(b)
, 91.405(a),

91.407(a)(1) and (2) , 91.409(a) (1) and (2), 91.417(a) and (b)

.
1. Section 45.27(a). Location of marks; nonfixed

- wing aircraft

.

Section 45.27, entitled Location of marks; nonfixed

- wing aircraft
, subsection (a) states
(emphasis added):

(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.
To the extent subsection 45.27(a) may be deemed to apply to the Leptron Avenger UAS,

Sanborn seeks an exemption from the subsection ( i.e., that the marks be displayed on both surfaces

of the cabin, fuselage, boom, or tail) because the Leptron Avenger UA is of insufficient size to
accommodate any such marking. Thus marking the Leptron Avenger UA as required by this
subsection would not be possible.

An e q u i v a l ent l e v el of s a f e t y can be provided instead by marking the Leptron Avenger
UA, as may be applicable, with lettering as large as practicable ( 14 C.F.R. § 45.29(f)) on its

20
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- 1largest available surface so as to permit such marking to be displayed to pilot, crew, and

others both when the Leptron A venger UA is on the ground and airborne

.
2. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in command

.
Sanborn seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled
Private pilot privileges and limitations: Pilot in command
, subsections (a) and (b) state
(emphasis added):

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft

. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any busin ess 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.
In general, subs ec t i ons 61

. 113 ( a ) and ( b ) prohibit a p r i v a t e p il o t from conducting

co m m e r c i al ope r a t i on s . Sanborn seeks exemption from the subsections because t he UA S w i l l

not ca rr y a p il o t , passe n g e r s or property (other than a camera). As addressed, the Leptron
Avenger is a very light, remotely controlled UAS with no persons or property on board. The
area of operations is generally remote or sparsely populated. Each f li g h t is p l anned and fully

coo r d i na t ed i n a d v ance in accordance with those procedures provided in the FOD

. Thus t he r i s k

assoc i a t ed w i t h the proposed ope r a t i on s is so d i m i n i shed fr om that ass o c i a t ed w i t h co m m e r c i al

ope r a t i ons con t e m p l a t ed by P a r t 61, t hat a ll o w i ng a PIC having a private pilot certificate , rather

than a commercial certificate, met the minimum flight hour and qualification criteria, and
operating according to the limitations and guidelines provided herein
, provides a level of safety

that e x ceeds t hat p r o v i ded by a pilot having a co mm e r c i al ce r t i f i ca t e op e r a t i n g a con v en t i onal

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- 1a i r c r a f t as required under the regulations

.

T he FAA has previously granted e x e m p t i ons in circumstances similar, in all material

respects, to those presented herein

. See Exemption Nos. 11062, 11063, 11064, 11065, 11066

,
11066A, 11067 , 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161

.
3. Section 91.7(a). Civil Aircraft Airworthiness

. Either finding that Sanborn meets the Section 333 criteria or exemption from the
airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a)
inapplicable.

Section 91.7, entitled Civil aircraft airworthiness
, subsection (a ) states (emphasis added):

“ No person may operate a civil aircraft unless it is in an airworthy condition .” T here is no FAA
standard by which such a determination of airworthiness can be made. Nonetheless, given t he
limitations and procedures , as con t a i ned herein, and in t he FOD
, for maintaining the aircraft and
checking it before each flight to ensure that it is in peak operational condition, an e q u i v a l ent

l e v e l o f s a f e t y w il l be p r o v i ded.

4

. Section 91.105. Flight crewmembers at stations

. Sanborn seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight

crewmembers at stations
, states (emphasis added):

(a) During takeoff and landing, and while en route, each required flight crewmember shall

— (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircraft or in connection with physiolog ical 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

as signed duty station . This paragraph does not apply if

—
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- 1(1) The seat at the crewmember's station is not equipped with a shoulder harness; or

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.
In general, S ec t i on 91

. 105 requires pilot and crew to be at their duty stations and
harnessed during flight

. Sanborn seeks exemption from the Section 91.105 because the Leptron
Avenger UA is by definition an unmanned aircraft, having neither pilot nor crew so as to be
stationed or harnessed as required by the regulation. An e q u i v a l ent or even higher l e v el of s a f e t y

can be provided instead by using an unmanned aircraft controlled by a PIC who at all times is

located at and controls the UAS from the GCS.

5

. Section 91.119(c). Minimum safe altitudes

.
Sanborn seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum
safe altitudes: General
, subsection (d) states (emphasis added):
Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

***

(c) Over other than congested areas. An altitude of 500 feet above the surface
, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

S ec t i on 91

. 119(c) e s t ab li shes s a f e a l t i t ud e s f or ope r a t i on o f c i v i l a i r c r a f t over other than
congested areas

. Sanborn seeks exemption from subsection 91.119(c) because, pursuant to this

Petition, t he Leptron Avenger UA w il l at times be ope r a t ed below 5 00 ’ A G L

.
An e q u i v a l ent or even higher l e v el of s a f e t y can be provided instead by, as provided
herein, ope r a t ing so as to deconflict with manned vehicles operating above 500 ’ AGL , within the

VLOS of the PIC with the assistance of a VO so as to ensure the safety of and deconfliction with
any persons or property in the air and on the ground , including participating and non

participating personnel, 100 feet and 500 feet, respectively, away from who the UA would 23
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- 1generally be restricted . Further t he Leptron Avenger UAS flight operations will be m on i t o r ed

at all times by bo t h t he PIC and VO and will be i n c o m p li ance w i t h l ocal pub li c s a f e t y

r e q u i r e m en t s , so as to prevent access to t he restricted a r eas o f ope r a t i on.

The FAA has previously granted e x e m p t i ons in circumstances similar, in all material

respects, to those presented herein

. See Exemption Nos. 11062, 11063, 11064, 11065, 11066

,
11066A, 11067 , 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161

.

6

. Section 91.121(a)(1)(iii). Altimeter settings

.
Sanborn seeks an exemption from 14 C.F.R. 91.121(a)(1)(iii). Section 91.121, entitled
Altimeter settings
, states in relevant part (emphasis added):

(a) Each person operating an aircraft shall maintain the cruising altitude 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

—

***

(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

Subsection 91.121(a)(1)(iii) r e q u i r es persons ope r a t i n g a n a i r c r a f t t o m a i n t a i n a l t i t ude by

r e f e r ence t o an a l t i m e t er s e t “t o t he e l e v a t i on o f t he depa r t u r e a i r p o r t or an ap p r op r i a t e a l t i m e t er

s e tt i n g a v a il ab l e b e f o r e dep a rt u r e

. ” Sanborn seeks exemption from subsection 91.121(a)(1)(iii)
because the Leptron Avenger UA does not use or have on board a typical barometric altimeter as
contemplated by the regulation. Instead, the Leptron Avenger UAS has a laser altimeter to

maintain alt itude.

A n e q u i v a l ent l e v el of s a f e t y w i l l be p r o v i ded instead by operating the UA below

1
, 200 ’ A G L within the VLOS of the PIC (with the assistance of a VO) with laser altimeter
information downlinked from the UA to the PIC to maintain altitude and ensure safety. Prior to

24
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- 1each flight, a zero altitude/AGL will be established at the launch site
, as confirmed for accuracy
by the PIC.

7

. Section 91.151(b). Fuel requirements for f light in VFR conditions.

Sanborn seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel
requirements for flight in VFR conditions
, states (emphasis added):

(b) No person may begin a flight in a rotorcraft 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 cruising speed, to fly after that for at lea st 20 minutes

.

T he Leptron Avenger is an unmanned aircraft, and thus would not begin a flight with a
person in it as the regulation contemplates. T o the extent the regulation applies to the Leptron
Avenger, a n e q u i v a l ent l e v el of s a f e t y can be ach i e v ed instead by l im i t i ng the Leptron Avenger

f

l i g h t s t o 1.5 hours o r 2 0 % b a t t e r y po w er, w h i ch e v er occurs f i r s t, as provided in the FOD . Given
that the Leptron Avenger UA, has a maximum weight of approximately 32 pounds and will fly at
approximately 12m/s , will be operated within the VLOS of the PIC
, this restriction would provide
more than enough battery reserve to accommodate a safe return to the landing zone from
anywhere in the operating area with no adverse effect on the safety of persons and property in
the air or on the ground.

See also e.g. E xemption Nos. 2689, 5745, 10650 (granted exemption to manned aircraft to
operate at less than the minimums prescribed in Section 91.151) and Exemption Nos. 8811,
10808, 10673 (granted similar relief for UAS for day VFR conditions).

8

. Sections 91.405(a), 91.407(a)(1), 91.409(a) (1) and (2), 91.417(a) and (b). Maintenance inspections and recording

.
Section 91.405(a) , entitled Maintenance required
, states:
Each owner or operator of an aircraft

—

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- 1(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Section 91.407(a)(1) , entitled Operation after maintenance, preventive maintenance, rebuilding,

or alteration
, states:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter;

Section 91.409 (a) (1) and (2) , entitled Inspections
, states:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the require d maintenance records.

Section 91.417(a) and (b) , entitled Maintenance records
, state:
(a) Except for work performed in accordance with §§ 91.411 and 91.413 , each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and re cords of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

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- 1(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time si nce last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program und er which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragrap h (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
In general, t hese r e g u l a t i ons r e q u i r e t h a t an airworthy certificated a i r c r a f t be i nspec t ed as

p r e s c r i bed i n 14 C.F.R. Part 91, S ubpa r t E (Maintenance, Preventive Maintenance, and

Alterations), any d i sc r epanc i es be r e pa i r ed and the aircraft be approved for return to service a s

p r e s c r i bed i n P a r t 43 ( Maintenance, Preventive Maintenance, Rebuilding, and Alterations ) and
that any work on the aircraft be recorded and such records maintained.

27
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- 1Sanborn seeks an exemption because , as addressed, the Leptron Avenger UA will operate
pursuant to this Petition without airworthiness certification

. An e q u i v a l ent l e v el of s a f e t y can be
provided instead by requiring, as provided herein, that inspections and m a i n t enance be

acc o m p li shed according t o t he inspection, maintenance, and preflight sections of the FOD
including the Leptron Inspection & Maintenance Manual

. A s p r o v i ded i n t he FOD
, among

other things , the UAS will be inspected prior to each flight to confirm that it is in good

w o r k i n g o r der, any maintenance or repairs will be p e r f o r m ed and l o g ged , and , upon any work
being performed on the UA, the UA will be checked and approved for flight by qualified Sanborn
personnel before being returned to service

. No pilot or crew need be airborne flying a heavy,

fuel

- ladened aircraft, the reby providing for superior safety to persons and property in the air and

on the ground

. Further, all flights will be conducted during the day below 1
, 200 ’ AGL within the
VLOS of the PIC with the assistance of a VO so as to ensure deconfliction with objects in the air
and on the ground. Given the Leptron Avenger UA ’s light w eight, slow speed and l o w

- a l t i t ude

ope r a t i ons there is little risk of any damage to persons or property in the air or on the ground should
a maintenance issue present itself when airborne. Accordingly, any risk associated with using the
Leptron Avenger UAS as proposed i s significantly reduced when compared to that p r esen t ed by
using manned ai r c r a f t to condu ct the same operations

.

T he FAA has previously granted e x e m p t i ons in circumstances similar, in all material

respects, to those presented herein

. See Exemption Nos. 11062, 11063, 11064, 11065, 11066

,
11066A, 11067 , 11067A, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161

.

H

. A Summary That Can Be Published In The Federal Register, s tating:

The Rules From Which Sanborn Seeks Exemption:

The Sanborn Map Company, Inc. seeks exemption from the requirements of 14 C.F.R. §§

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- 145.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii)
, 91.151(b)
, 91.405(a), 91.407(a)(1), 91.409(a)(1) and ( 2 ),and 91.417(a) and (b)

.
A Brief Description Of The Nature Of The Exemption Sanborn Seeks:
Approval of the above mentioned exemptions will allow Sanborn LLC to operate the Leptron Avenger for compensation in the National Airspace system. In relation to Sanborn’s current aerial surveying and mapping operations, such exemptions will increase safety, reduce risk to person and property on the ground, decrease carbon emissions, reduce the need for Air Traffic Control handling, and provide better aerial sur veying footage. The Leptron Avenger runs on rechargeable batteries and does not carry any persons on

- board. Sanborn’s customer’s will also benefit from greater operational flexibility and lower costs since Sanborn can operate the Leptron Avenger at a low er cost than traditional manned aircraft doing the same job.
Specifically, Sanborn is seeking exemptions to allow:
(1) The Leptron Avenger to be marked with its registration number on its largest available services; (2) A private pilot with 3 rd class med ical to operate the Leptron Avenger as the Pilot in Command; (3) Operate the Leptron Avenger even though it has n ot been certified as airworthy; (4) Allow the Pilot in Command to control the Leptron Avenger from the controls that are located at the ground control station; (5) Operate the Leptron Avenger below 500 ’ AGL ; (6) Operate the Leptron Avenger with a laser altimeter instead of a barometric altimeter; (7) Conduct operations lasting 1.5 hours or until the battery life reaches 20%, whichever occurs fir st; and (8) Conduct inspections and maintenance in accordance with the Leptron Maintenance Operations Manual and Sanborn’s Flight Operations Documents.

I. C onclusion

A ccordingly, a s set forth above, Sanborn Map Company, Inc. seeks an exemption

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of

2012, to permit safe operation of the Leptron Avenger UAS commercially, without an

airworthiness certificate, for the special purpose of conducting aerial imaging operations

. By
granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of

Section 333 of the FAA Modernization and Reform Act of 2012 to expedite approval of
operations of certain UAS in the NAS , while also advancing the interests of the public

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

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- 1Modernization and Reform Act of 2012, Section 333, Sanborn Map Company, Inc. respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121(a)(1)(iii)
, 91.151(b)
,
91.40 5(a), 91.407(a)(1), 91.409(a)(1) and ( 2 )
, and 91.417(a) and (b)

.

Dated: February 6, 2015 Respectfully submitted,

Husch Blackwell LLP

/s/ Thomas L. Gemmell Thomas L. Gemmell

HUSCH BLACKWELL LLP 120 South Riverside Plaza, 22 nd Floor Chicago, Illinois 60606 Tel: (312) 526

- 1523 Fax: (312) 655

- 1501 tom.gemmell@huschblackwell.com

Attorneys for Petitioner

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- 1