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), 91.1 21, 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 w ould allow the commercial operation of small, unmanned aircraft systems (“UAS”) weighing 55 pounds or less including payload for the purpose ofJuly 1, 2015 Page 2

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com conducting survey

- grade terrain mapping. Petitioner’s proposed UAS activities include agriculture mapping and mo nitoring, 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 leas t 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 becau se 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 A g, 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 U AS 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. , Grant s of Exemption 11504 and 11567 . The AgEagle is a battery

- powered electri c 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 Interne tJuly 1, 2015 Page 3

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com (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 protoco ls including return

- to

- launch and unpowered glide. 3DRobotics Aero

- M The 3DRobotics Aero

- M h as been the subject of several recent Section 333 exemptions. See , e.g. , Grant s 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 ope ration 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 exemption s. 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. , Grant s 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 fli ght 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. , Grant s 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.July 1, 2015 Page 4

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com DJI Phantom 3 The DJI Phantom products have been the subject of several recent Section 333 exemptions. See , e.g. , Grant s 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 thatJuly 1, 2015 Page 5

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 o ne - third of all crops planted in the world are destroyed b y diseases, pests, and insects. Petitioner’s activiti es 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 a ss essment 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 fo r 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 limitati ons 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 obt ained 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.July 1, 2015 Page 6

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 expe dited 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 airs pace 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 gra nts 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 airw orthiness 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 UA S. 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 ex clusively 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, speedJuly 1, 2015 Page 7

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 co mpensation 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 re stricted 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 s tation, 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.July 1, 2015 Page 8

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 sh ould 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 mappin g, 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 proximit y 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.”July 1, 2015 Page 9

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com Petitioner will not have a typical barometric altimeter on board the UAS. Instead, altitude information is provided to the UAS PIC throu gh 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 perti nent 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 theJuly 1, 2015 Page 10

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 inclu de

— (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 ser vice. (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. (ii i) 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 sh all 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 Petiti on 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.July 1, 2015 Page 11

764405v1 999836.0001 Tripp Scott Fort Lauderdale • Boca Raton • Tallahassee www.trippscott.com 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 Page 12

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.