110 Southeast Sixth Street • Fifteenth Floor • Fort Lauderdale, Florida 33301

Tel 954.525.7500 • Fax 954.761.8475 • www.trippscott.com

Fort Lauderdale • Boca Raton • Tallahassee

Ian J. Lis, Esq.

Direct Dial: 954.765.2902

Email: ijl@trippscott.com

July 1, 2015

Electronically Submitted

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Raptor Maps, Inc. - Petition for Exemption to Operate Unmanned

Aircraft Systems Pursuant to Section 333 of the FAA Reform Act

and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95

(2012) (“Section 333”) and the general exemption authority of the Federal Aviation

Administration (“FAA”) under 49 U.S.C. § 44701(f), and through the undersigned counsel,

Raptor Maps, Inc. (“Petitioner”) hereby petitions for exemptions from Federal Aviation

Regulations (“FARs”) 14 C.F.R., Part 21, 14 C.F.R. §§ 61.23(a) and (c), 61.101(e), 61.113(a)

and (b), 61.133(a), 61.315, 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91.121, 91.151,

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b).

The contact information of Petitioner is

Raptor Maps, Inc.

Attn: Nikhil Vadhavkar

241 “A” Street, Ste. 300, c/o Chu, Ring & Hazel LLP

Boston, MA 02210

Phone: 617-286-6466

Email: info@raptormaps.com

Petition Summary

Pursuant to 14 C.F.R Part 11, the following summary is provided for publication in the Federal

Register, should it be determined publication is needed:

Petitioner requests an exemption that would allow the commercial operation of small, unmanned

aircraft systems (“UAS”) weighing 55 pounds or less including payload for the purpose of
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conducting survey-grade terrain mapping. Petitioner’s proposed UAS activities include

agriculture mapping and monitoring, land and infrastructure surveying and monitoring, and

forestry and wildlife management. UAS-enabled mapping allows Petitioner to provide valuable

information to landowners and operators. Petitioner’s UAS pilot in command (“PIC”) will hold

at least a recreational or sport pilot certificate. The PIC will be proficient at manually flying

radio-controlled aircraft and will possess either a third-class medical certificate or a valid U.S.

driver’s license. The requested exemption should be granted because operation of the proposed

small UAS pursuant to the strict conditions outlined below will provide an equivalent level of

safety as Congress intended. Petitioner will operate the following UAS: AgEagle 2, 3DRobotics

Aero-M, Skywalker X-8, SenseFly eBee Ag, 3DRobotics IRIS+, DJI Phantom 3. Petitioner’s

lightweight UAS are far safer than conventional flight operations containing flight crew and

passengers. Petitioner’s UAS are small and will operate at slow speeds, close to the ground, far

from airports, in low-risk, low-population environments. They will operate only in line of sight

within a restricted environment. Petitioner’s UAS will carry no passengers, have enhanced safety

measures, and operate under the specific guidelines and specifications outlined herein.

Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption without

delay.

The Petitioner requests exemption from the following rules: 14 C.F.R., Part 21, 14 C.F.R. §§

61.23(a) and(c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(a), 61.315, 91.7(a), 91.9(b)(2),

91.103(b)(1), 91.119(c), 91.121, 91.151, 91.203(a) and (b), 91.405(a), 91.407(a)(1),

91.409(a)(2), 91.417(a) and (b), and any and all additional rules the FAA deems applicable to

Petitioner’s UAS activities.

Petitioner’s UAS

The requested exemption will permit the operation of four small fixed-wing aircraft: AgEagle 2,

3DRobotics Aero-M, Skywalker X8, SenseFly eBee Ag. The exemption will also permit the

operation of two small rotorcraft: DJI Phantom 3, 3D Robotics Iris+. All UAS provide the

following functions: three (3) redundant modes of autopilot, enhanced fail safe (return-to-home)

technology, and low voltage protection. Petitioner’s UAS use a radio frequency spectrum for

operation and control that complies with the Federal Communications Commission (“FCC”)

requirements. For additional information, please refer to the manuals and specifications for each

of the aforementioned UAS and Flight Controller systems attached hereto as exhibits.

Each of the proposed UAS has been the subject of recent FAA exemptions:

AgEagle 2

The AgEagle 2 is the updated version of the AgEagle, which has been the subject of several

recent Section 333 exemptions. See, e.g., Grants of Exemption 11504 and 11567. The AgEagle is

a battery-powered electric fixed wing aircraft with a wingspan of 56 inches and weighs 7.5

pounds (including battery). It can operate at a maximum speed of 32 knots, with a cruising speed

of 23 knots. The AgEagle system carries a geo-referenced still camera to conduct

photogrammetry and crop scouting in order to perform precision agriculture. The AgEagle is

programmed and operated primarily using cellular data network services, with the PIC

overseeing operations using a laptop, tablet computer or smartphone connected to the Internet
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(usually over the same cellular data network). The AgEagle can also be piloted manually over a

900 MHz radio using a laptop, tablet, or smartphone and via a standard 2.4 GHz radio-control

(RC) transmitter. It is programmed with standard loss-link protocols including return-to-launch

and unpowered glide.

3DRobotics Aero-M

The 3DRobotics Aero-M has been the subject of several recent Section 333 exemptions. See, e.g., Grants of Exemption 11617, 11626, and 11379. It is a fixed-wing, electrically-powered

UAS designed for farming, construction, conservation, and search and rescue and emergency

response. It has a 74 inch wingspan and weighs 6.8 pounds (including battery). The 6,000 mAh

battery supports a flight time of up to 40 minutes. The maximum speed of operation is 39 knots

with a cruising speed of 29 knots. The aircraft is constructed of durable foam. It utilizes the 3DR

Pixhawk flight controller, a 2.4 GHz Spektrum DX7s transmitter, and a 900 MHz radio for

communication with the ground station. The short failsafe (1 second) action is a return-to-launch,

and the long failsafe (20 second) action is an unpowered glide.

Skywalker X-8

The Skywalker X-8 flying wing has been the subject of recent Section 333 exemptions. See, e.g., Grant of Exemption 11446. The X-8 is a fixed-wing, electrically-powered flying wing UAS

designed for aerial mapping and surveying. It has an 84 inch wingspan and weighs 8 pounds

(including battery). The two 5,000 mAh batteries support a flight time of up to 45 minutes. The

maximum speed of operation is 46 knots, with a cruising speed of 31 knots. The aircraft is made

of durable foam. The X-8 was originally designed as a hobby grade model aircraft. However,

Petitioner chose to install the 3DR Pixhawk flight control system, which makes it a

commercially viable UAS. The Pixhawk also allows for computer guided waypoint navigation

for precise ground tracks necessary for aerial mapping applications.

SenseFly eBee Ag

The SenseFly eBee Ag has been the subject of several recent Section 333 exemptions. See, e.g., Grants of Exemption 11628 and 11635. It is a fixed-wing, electrically-powered UAS designed

specifically for precision farming. It has a 38 inch wingspan and weighs 1.6 pounds (including

battery). The 2,150 mAh battery supports a flight time of up to 45 minutes. The maximum speed

of operations is 49 knots with a cruising speed of 29 knots. The aircraft is constructed of durable

foam. SenseFly is a subsidiary of Parrot, one of the largest consumer UAS manufacturers.

3DRobotics IRIS+

The 3DRobotics IRIS+ and its predecessors have been the subject of several recent Section 333

exemptions. See, e.g., Grants of Exemption 11521 and 11318. The 3DRobotics IRIS+ is an

electrically-powered multirotor UAS designed for aerial photography. It has a motor-to-motor

dimension of 21.7 inches, and weighs 2.9 pounds (including battery). The 5,100 mAh battery

supports a flight time of 16-22 minutes. The maximum speed is 44 knots; however, Petitioner

will operate the IRIS+ only within 5-15 knots range. The aircraft also uses the aforementioned

Pixhawk flight controller and accompanying mission planning software. The IRIS+ can land

itself automatically, or return to a home point if it travels out of range or runs low on battery.
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DJI Phantom 3

The DJI Phantom products have been the subject of several recent Section 333 exemptions. See, e.g., Grants of Exemption 11696 and 11515. The DJI Phantom 3 is an electrically powered

multirotor UAS designed for aerial photography and video. It has a motor-to-motor dimension of

23.2 inches, and weighs 3.3 pounds (including battery), which is within the sUAS class and

within the micro UAS weight limit (4.4 pounds) under the proposed NPRM §107. The system

consists of a ground control station, camera gimbal, GoPro camera, and iPhone video monitor.

Petitioner’s proposed uses of the Phantom will be similar in all material respects to those

outlined in Grants of Exemption 11138, 11062, 11109, 11112, and 11213.

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 CFR Part

47, and have identification (N-Number) markings in accordance with 14 CFR Part 45, Subpart C.

Markings will be as large as practicable in accordance with § 45.29(f).

Flight Conditions and Operations

The UAS will be flown in airspace under 400 feet above ground level and under controlled

conditions. The operational limitations and aircraft requirements will be in accordance with the

provision proposed by the FAA in Proposed Part 107 for small UAS. Petitioner will utilize the

best practices of the Academy of Model Aircraft (“AMA”) Safety Code as set forth in the

exhibits attached hereto. If Petitioner intends to operate within five (5) miles of any active

landing strip or airport, Petitioner will follow proper FAA procedure, notifying the FAA in

advance of operation and when operation is complete.

Petitioner’s pilot in command (“PIC”) will hold at least a recreational or sport pilot certificate.

PIC will be proficient at manually flying radio-controlled aircraft. The PIC will possess either a

third-class medical certificate or a valid driver’s license. The PIC will always make a safety

assessment of the risk of every operation and will only operate the UAS when the PIC

determines no undue hazards exist. A minimum of one (1) visual observer will be required to be

in line of sight of the UAS at all times to further watch for intrusions into the area from

individuals and other aircraft. All visual observers have experience flying radio-controlled

aircraft. The PIC and visual observer will be in constant communication through at least one (1)

of the following methods: cellular phone communication (constant open call during flight); two- way radio communication; or verbal communication. No UAS flight will exceed line-of-sight

distance of the PIC and visual observer at any time.

All UAS will be flown on private property only with the consent of the landowner. Petitioner

will obtain consent and permission from any party filmed or photographed. Petitioner will

protect the privacy of all involved and non-involved parties present during the use of the UAS.

The visual observer will be on the lookout for any trespassers so all operations can be quickly

stopped if an unauthorized person comes within range of the UAS.

For each UAS use, flights will be logged in a traditional pilot log-book and further documented

through an electronic invoice/billing system that records the date of each UAS flight. Petitioner

will follow the procedures for start-up set forth in the manual for each UAS. Additionally,

Petitioner will perform a site inspection before each flight to determine additional measures that
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may be necessary to safely operate the UAS. Petitioner will further perform a pre-flight

communications check to make sure the PIC, visual observer, and UAS can remain in contact.

Public Interest

Studies estimate that one-third of all crops planted in the world are destroyed by diseases, pests,

and insects. Petitioner’s activities related agricultural monitoring and analytics provide a method

to prevent these economic damages. Agricultural monitoring will additionally reduce the

environmental impacts of pesticide, herbicide, and fungicide used in the food system.

Petitioner’s assessment of hydration status will conserve water through selective irrigation of

crops. Petitioner has found that UAS-based crop monitoring fills a dire need in the agricultural

industry. Petitioner is looking to use recent advancements in UAS technology for the good of

agricultural producers, the environment, and the general public.

Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption requested herein apply to UAS that have the

characteristics and that operate within the limitations outlined herein. These limitations provide

for at least an equivalent or greater level of safety to operate under the current regulations.

Petitioner agrees to the following limitations and conditions with conducting its commercial

UAS operations under an FAA exemption:

1. All UAS will weigh no more than 55 pounds, including payload. 2. All UAS will be operated within line of sight of the PIC and visual observer.

3. The maximum total flight time for each UAS flight will conclude upon the earlier of

forty-five (45) minutes or until 25% of UAS battery remains.

4. The UAS will be operated at an altitude of no more than 400 feet above ground level.

5. The PIC will hold at least a recreational or sport pilot certificate and a third-class medical

certificate or a valid U.S. Driver’s License.

6. The minimum crew for each UAS flight will be the PIC and one visual observer.

7. The crew for each operation will at all times be able to communicate by voice or through

radio or cellular devices.

8. Written or oral permission will be obtained from the landowners or their authorized

agents of the land over which all flights will occur.

9. All necessary permissions and permits will be obtained from all appropriate local

governmental agencies.

10. All UAS will have the capability to abort a flight in case of unexpected obstacles or

emergencies.

11. All UAS will be equipped with enhanced failsafe (return-to-home) technology.

12. No UAS operations will present any national security issue.

13. Petitioner will obtain an Air Traffic Organization issued Certificate of Waiver or

Authorization (“COA”) prior to conducting any operations under its grant of exemption

that exceed the requirements of the “blanket” COA to be granted in connection with any

grant of exemption received. In fulfilling the requirements of the COA, Petitioner may be

required to request a Notice to Airmen (“NOTAM”) not more than 72 hours in advance,

but not less than 48 hours prior to operation.
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Satisfaction of Section 333’s criteria (size, weight, speed, operating capabilities, proximity to

airports and populated areas, operation within line of sight and national security) provide an

adequate justification for the grant of the exemptions requested herein allowing Petitioner’s

commercial operation of UAS for the purpose of conducting survey-grade terrain mapping, agriculture mapping and monitoring, land and infrastructure surveying and monitoring, and

forestry and wildlife management.

Statutory Authority for Exemption

Section 333, in reference to 49 U.S.C. § 44704, provides a mechanism for expedited operational

authorization for the use of safe civil UAS operations in the National Airspace System (“NAS”).

Specifically, Section 333(a) states that the FAA “shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion” of final

rulemaking. If the Secretary of Transportation determines that certain UAS “may operate safely

in the national airspace system, the Secretary shall establish requirements for the safe operation

of such aircraft in the national airspace system. § 333(c). The FAA Administrator also has the

general authority to grant an exemption if the Administrator finds the exemption to be in the

public interest. 49 U.S.C. § 44701(f). The Federal Aviation Act (the “Act”) expressly grants the

FAA the authority to issue exemptions for exempt civil aircraft, as defined by § 40101 of the

Act, which includes an exemption for small UAS from the requirement that all civil aircraft have

a current airworthiness certificate.

Requested Exemptions

Petitioner respectfully requests relief from the following regulations:

14 C.F.R. Part 21 prescribes, in pertinent part, the procedural requirements for issuing and

changing design approvals, production approvals, airworthiness certificates, and airworthiness

approvals.

The Act and Section 333 both authorize the FAA to exempt aircraft from the requirement

of an airworthiness certificate upon consideration of the size, weight, speed, operational

capability, and proximity to airports and populated areas of the particular UAS. It is clear

that Petitioner’s UAS may be operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed in a manner as safe or safer

than a conventional aircraft operating with an airworthiness certificate without the

restrictions and conditions proposed.

The small UAS to be operated hereunder (i) are less than 55 pounds fully loaded, (ii)

carry neither pilot nor passengers; (iii) carry no explosive materials or flammable liquid

fuels; and (iv) operate exclusively within a secured area. Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by both the

operator and in compliance with local public safety requirements. The FAA will have

advance notice of all operations when required. Application of these criteria demonstrate

there is no credible threat to national security posed by the UAS based on its size, speed
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and location of operation, lack of explosive materials, and inability to carry a substantial

external load.

61.23(a) and(c) set forth requirements relating to pilots and medical certificates for certain

operations.

61.101(e)(4) and (5) prescribe in relevant part that a pilot holding recreational pilot privileges

may not act as pilot in command of an aircraft for compensation or hire.

61.113(a) and (b) prescribes that “no person who holds a private pilot certificate may act as a

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,” and that

“a private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business 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.”

61.133(a) sets forth privileges for persons holding commercial pilot certificates, including a

provision that limits the ability to act as PIC of an aircraft for compensation or hire to persons

holding a commercial pilot certificate.

61.315(a) provides that the holder of a sport pilot certificate may act as a pilot in command of a

light-sport aircraft.

Petitioner’s UAS operations will be limited to restricted conditions and a controlled

environment. The PIC will hold at least his sport pilot certificate or recreational pilot

privileges, giving him adequate knowledge based on his experience and the exams and

courses required to obtain these privileges. The PIC will hold either a valid driver’s

license or a third class medical certificate, which provides adequate knowledge for the

operations of small UAS. Additionally, while the UAS will be operated in connection

with Petitioner’s business, no passengers or cargo will be transported. Petitioner believes

these factors warrant relief from 61.23(a) and (c), 61.101(e), 61.113 (a) and (b), 61.133(a)

and 61.315(a). 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy

condition.

As there will be no airworthiness certificate issued for the UAS should this exemption be

granted, no standard will exist for determining airworthiness. Petitioner will keep all

UAS maintenance and safety information at the pre-determined ground station, where it

will be readily accessible to the PIC and visual observer. Based on the documents

available at the ground station, the PIC will be able to make a determination as to the

airworthiness of the UAS.
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91.9(b)(2) prohibits the operation of U.S.-registered civil aircraft unless there is available in the

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material,

markings, and placards, or any combination thereof.

Based on the FAA’s Memorandum dated August 8, 2014, Petitioner does not believe

exemption from 91.9(b) or 91.203(a) and (b) is necessary. However, to the extent the

FAA deems an exemption from these sections necessary for Petitioner’s proposed

operations, such exemptions should be granted. Petitioner’s UAS are too small to safely

carry the required manuals and placards. Additionally, as the UAS are unmanned, the

manuals and other required information is more useful to the PIC at ground control.

91.103(b)(1) prescribes, in pertinent part, that each PIC shall, before beginning a flight, become

familiar with all available information concerning that flight. This information must include—

(a) For a flight under instrument flight rules (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, and any known traffic delays of which the PIC has been advised by air

traffic control (ATC); (b) For any flight, runway lengths at airports of intended use, and the

following takeoff and landing distance information: (1) For civil aircraft for which an approved

Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required,

the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those

specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft,

relating to aircraft performance under expected values of airport elevation and runway slope,

aircraft gross weight, and wind and temperature.

Petitioner will comply with all applicable requirements of 91.103(a) and (b) and requests

relief from 91.103(b)(1). The PIC will review weather, flight and battery requirements,

UAS performance data, and appropriate landing and takeoff distances before each flight.

Any risks presented will be mitigated by the PIC’s ability to see all nearby air traffic and

activate the UAS return-to-home procedures if necessary.

91.119(c) prescribes that, “[e]xcept 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.”

Due the nature of Petitioner’s UAS activities survey-grade mapping, Petitioner requests

relief from 91.119(c) with respect to participating persons, vehicles, and structures

directly involved in Petitioner’s operations. Each UAS manual sets forth safety factors

that will be used to ensure safe operation when in proximity to consenting participants.

Petitioner will ensure that no UAS are operating within 500 feet of non-participating

persons.

91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude

by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate

altimeter setting available before departure.”
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Petitioner will not have a typical barometric altimeter on board the UAS. Instead, altitude

information is provided to the UAS PIC through a digitally encoded telemetric data feed,

which downlinks from the aircraft to an on-screen display on the ground. Prior to each

flight, a zero altitude initiation point will be established and confirmed for accuracy by

the PIC.

91.151 prescribes, in pertinent part, that “(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 cruising 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 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 least 20 minutes.”

91.151 provides for a safety reserve of fuel so that aircraft may timely land when fuel is

running low. Petitioner will operate UAS until the earlier of a maximum of forty-five

(45) minutes or when 25% of battery remains. All UAS are additionally equipped with a

low battery failsafe that allow the UAS to safely land when little battery remains. The

UAS are not propelled by fuel and will operate only within the safety constraints of the

UAS battery life.

91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has

within it “(1) an appropriate and current airworthiness certificate [. . . and] (2) an effective U.S.

registration certificate 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).”

91.203(b) prescribes, in pertinent part, that “no person may operate a civil aircraft unless the

airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the

cabin or cockpit entrance so that it is legible to passengers or crew.”

91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft

inspected as prescribed in subpart E of the same part and shall, between required inspections,

except as provided in paragraph (c) of the same section, have discrepancies repaired as

prescribed in Part 43 of the chapter.

91.407(a)(1) prescribes that no person may operate any aircraft that has undergone maintenance,

preventive maintenance, rebuilding, or alteration unless it has been approved for return to service

by a person authorized under § 43.7 of the same chapter.

91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within

the preceding 12 months, it has had an inspection for the issuance of an airworthiness certificate

in accordance with Part 21 of the same chapter.

91.417(a) and (b) prescribes, in pertinent part, that each registered owner or operator “keep the

following records for the periods specified in paragraph (b) of this section: (1) Records of the
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maintenance, preventive maintenance, and alteration and records 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 (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 since last overhaul of all items

installed on the aircraft that 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 under 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) 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 paragraph

(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 shall be retained until the

defects are repaired and the aircraft is approved for return to service.”

Petitioner will comply with safety and maintenance procedures included in all UAS

manufacturer’s instructions and operating manuals. If necessary, Petitioner will develop

and document additional maintenance protocols to ensure the highest level of safety.

Therefore, Petitioner’s exemption from 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and

91.417(a) and (b) is warranted.

Conclusion

This Petition for Exemption demonstrates the appropriate safeguards and criteria that Congress

articulated in Section 333 including weight, speed, operating capabilities, proximity to airports

and populated areas, operation within VLOS and national security concerns. The proposed UAS

operations will benefit the public as a whole by reducing human exposure to the risks associated

with manned aircraft performing the activities. The public will also benefit from Petitioner’s

assistance to agricultural producers to prevent disease and destruction of crops, reduction of the

environmental impacts of pesticide, herbicide, and fungicide, and conservation of water through

selective irrigation. In consideration of the foregoing, this Petition for Exemption provides the

FAA with more than adequate justification to allow commercial operation of Petitioner’s small

UAS for the purpose of conducting survey-grade terrain mapping, including agriculture mapping

and monitoring, land and infrastructure surveying and monitoring, and forestry and wildlife

management.
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We appreciate your prompt consideration of our requested exemptions. In further support of this

Petition, Petitioner has submitted confidential information under separate cover. Should you

have any questions, or if you need any additional information to support the requested

exemptions, please do not hesitate to contact the undersigned.

Respectfully submitted,

Ian J. Lis, Esq.

Tripp Scott, P.A.

Counsel for Petitioner Raptor Maps, Inc.
July 1, 2015

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764405v1 999836.0001 Tripp Scott

Fort Lauderdale • Boca Raton • Tallahassee

www.trippscott.com

Exhibits

Confidential:

1. Letter of Support—Submitted Confidentially to the FAA

Manuals:

2. AgEagle 2

3. 3DRobotics Aero-M

4. Skywalker X8

5. SenseFly eBee Ag

6. DJI Phantom 3

7. 3D Robotics Iris+

8. AMA Safety Code

Exhibit 1 has been submitted confidentially and is not available to the public.