~ Graniterock. 

The Honorable Michael P. Huerta 

Office of the Administrator 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

December 11, 2015 

Kevin Jeffery 

Vice President 

Granite Rock Company 

350 Technology Drive 

Watsonville , CA 95076-2488 

Tel ( 408) 644-0307 

The Honorable Anthony R. Foxx 

Office of the Secretary 

US Department of Transportation 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Granite Rock Company sUAS Petition for Exemption Pursuant to FMRA Sec 

333 and 14 CFR Part 11 

Dear Administrator Huerta: 

Granite Rock Company hereby petitions the FAA for regulatory relief pursuant to Section 333 of 

P.L. 112- 95 and 14 C.F.R. Sec. 11.81 to conduct commercial flights using the 3DR X8+ , DJI 

Phantom 3 Professional, and Graniterock Hexarotor Model 1 sUAS for the following applications: 

• Aerial Survey 

• Aerial Inspection 

• Aerial Videography and Photography 

• Aerial Mapping 

Gra.niterock, therefore, seeks a request for exemption from airworthiness and the following specific 

Title 14 C.F.R. provisions: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 61.113(a) (b) 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.7(a) 

• 14 C.F.R. 91.9 

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• 14 C.F.R. 91.109(a) 

• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 

• 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) (b) 

The FAA has issued grants of exemption in circumstances similar in all material respects to those 

presented in this petition, specifically Exemptions No. 12910 to KOA Corporation Inc, 12817 to 

ArizonaFPV LLC, and 12786 Satstellar LLC; and we therefore request that our petition be granted 

without delay. Additional similar exemptions include (survey and mapping) No. 12803, 12792, 

12790, and 12696, (inspection) No. 11846, 11808, 11835, 11799, 11676, 11648, 11508, 11469, 11451, 

11286, 11258, 11275, and 11109, and (videography) No. 11843, 11845, 11848, 11850, 11820, 11822, 

11825, 11826, 11829, and 11833. 

Graniterock has also provided supporting documentation to include; a General Operations Manual 

(Graniterock Manual') which is composed of (1) an operations manual, (2) flight manuals for each 

of the Graniterock models; (3) an Operator Training Manual, and ( 4) a Maintenance and Inspection 

ManuaL Please note that all the Graniterock Manual (including all of the above listed components) 

are clearly marked "Confidential" on each page and contain confidential commercial and proprietary 

information that Graniterock has not and will not share with others who are not subject to a 

"Nondisclosure Agreement" (NDA). Therefore, the Graniterock Manual (including all components) 

are not available to the public and contain operating conditions, procedures and other information 

that are protected from public release or disclosure under the Freedom of Information Act 5 USC 

Sec. 552 et seq. 

1 Company Description 

This section responds to the specific requirements of 14 CFR Sec 11.81. 

Granite Rock Company (Graniterock) is an industry-leading provider of materials and products to 

the construction industry and offers engineering and building services for large-scale civil projects. 

Graniterock believes there is ample opportunity to benefit from the use of UAS technology throughout its portfolio, from surveying quarry stockpiles to tracking the progress of construction projects. 

1.1 Contact information and Mailing address. 

Consultant Contact Information for Petition 

Petition POC: Andrew McCollough, Ph.D. 

Email: exemption@skyward.io 

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Petitioner (Graniterock) Contact Information 

ATTN: Bruce Wallace 

Granite Rock Company 

350 Technology Drive 

Watsonville, CA 95076-2488 

Email: bwallace@graniterock.com 

2 Relevant Statutory Authority 

3 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the P.L. 112- 95, the FAA Modernization and Reform Act ('Reform Act'). This law 

directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the U AS within visual line of sight of the operator. 

1 

Lastly, if the Secretary determines that such vehicles "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."2 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined tmder §40101 

of the Act, that includes sUASs, from the requirement that all civil aircraft must have a CtuTent 

airworthiness certificate. 

3 Qualification for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are 

satisfied. The requested exemption would permit Graniterock to perform commercial operations 

under controlled conditions in airspace that is 1) limited 2) predetermined 3) restricted, limited, or 

controlled as to access and 4) would provide safety enhancements to the already safe operations in 

these industries presently using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "establish requirements for the safe operation of such aircraft systems in the national airspace 

system." Section 333(c) of the Reform Act. 

1 Public Law 112- 95, 'FAA Modernization a.nd Reform Act' Section 333 (a) 

2 Id. §333(c). 

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Each Graniterock sUAS weighs 55 lb. or less including payload. Each Graniterock sUAS operates 

under normal conditions at a speed of no more than 87 knots. 

Generally Graniterock sUAS operations will be below an altitude of 400 ft. AGL, within specific 

access-restricted areas, either within Class G airspace or with the permission of the ATC, using 

sUAS operated by Graniterock-qualified sUAS pilots, and within the visual line of sight of the 

operator and observer. Such operations will insure that the sUAS will "not create a hazard to users 

of the National Airspace System or the public" as per the FMRA 2012 Section 333. Given the 

size of the sUAS and the operating environment, this petition for exemption meets an equivalent 

level of safety, in which Congress envisioned that the FAA must, by exemption allow commercial 

operations of UASs to commence immediately. Also due to the size and environment, approval of 

the application presents no national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit described herein, the grant of the requested exemptions is 

also in the public interest. 

4 Graniterock D escription of Proposed Operations 

Graniterock operations will provide a level of safety that is equivalent to current aviation standards. 

Graniterock safety procedures, risk assessments, and flight operations standards are described in 

detail in the accompanying Graniterock Manual. In brief, the following procedures that apply 

during operations conducted under this exemption request, establish an equivalent level of safety 

(ELOS) as follows: 

1. The sUAS will weigh less than 55 lb. 

2. Flights will be operated within line of sight of a pilot and/ or observer. 

3. Flights will occur during daylight hours. 

4. Flights will occur during Visual Flight Rules Meteorological Conditions (VMC). 

5. Flights will generally be operated at an altitude of no more than 400 feet AGL and within Class 

G airspace. Operations in controlled B,C, or D airspace will be conducted in coordination with 

the proper FSDO and ATC with prior permission. 

6. Flights will be terminated at 25% battery power reserve should that occur during the operation. 

7. All Graniterock sUAS will be U.S. registered and display marks either in accordance with 14 

C.F.R. Part 45, Subpart C or approved alternative markings. 

8. Operations will be conducted in defined regions and over property authorized for this use by the 

landowner. All operations will remain within the geographic boundaries of the operating a1·ea. 

Most operations may be conducted within the limitations of the blanket COA authorization 

provided with 333 grants as of 3/ 23/ 2015. 

9. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

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10. The operator will obtain the consent of all persons involved and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation, and this radius may be reduced 

to 30 feet based upon an equivalent level of safety determination. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

12. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/ or 

the Camera Operator. 

13. Operations without a Visual Observer (sUAS Pilot only) may occasionally be conducted subject to additional and specific aircraft equipment, operator competency, and flight restrictions 

(maximum distance from the sUAS Pilot, maximum altitude, and maximum speed) as defined 

in the Graniterock Operations Manual. 

14. sUAS operations under this exemption will be conducted under the supervision of a designated 

pilot in command (PIC) who has final responsibility for the operation and in accordance with 

14 C.F.R. 91.3. All sUAS operators must have completed training on the normal, abnormal, 

and emergency procedmes in the Graniterock Manual and demonstrated proficiency with the 

sUAS being operated. The PIC will meet at least the minimum FAA sUAS regulations for 

licensure. Graniterock requests that the alternative minimum PIC qualification proposed in 

Graniterock manual is approved by the FAA. Otherwise, Graniterock PICs must possess at 

least a sport pilot certificate and hold a valid U.S. driver's license. 

15. sUAS Pilot \vill be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS 

Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), 

that person can also be designated as the PIC. 

16. Observer and pilot will at all times be able to maintain verbal communication, either directly 

or through electronic means. 

17. Operators and engineers will maintain the sUAS system in a condition for safe operation 

according to the Graniterock Manual and associated manufacturer's maintenance manuals, 

including pre-flight and post-flight inspections. 

18. The PIC and observers will maintain situational awareness and perceive, process, and perform 

risk management prior to and during each operation as described in the Graniterock Manual. 

The PIC will terminate the operation in accordance with the Graniterock Manual if hazards 

that cannot be acceptably mitigated are observed. 

19. sUAS will safely stop operating and either return home or auto-land at a safe location along 

the flight path if the control link is lost. 

20. For each sUAS, the PIC will have the ability to force a controlled landing at any time. 

In addition to the above, Graniterock has implemented a Safety Management System. The Graniterock Safety Manager is responsible for conducting safety audits, investigations, and inspections 

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and is authorized to stop or prohibit any activity or operations which is considered unsafe. Full 

details are available in the Graniterock Manual. 

5 Regulations From Which Exemption is Requested 

6 Public Interest 

Graniterock believes that the enhanced safety achieved using a sUAS with the specifications described in this petition and supporting documents and by carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions carrying crew in addition to flammable 

fuel, gives the FAA good cause to find that the UAS operations enabled by this exemption are in 

the public interest. 

7 Privacy 

All flights will occur over private, limited, or restricted-access areas with the property owner's prior 

consent and knowledge. Operations will be conducted by trained crew and all other individuals will 

either be a part of the operation or consent to be present at the time of operations. 

8 Federal R egister Summary 

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

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 

45.23(b);14 C.F.R. §§61.113( a) & (b), 61.133(a); 91.7 (a); 91.9 (b) (2); 91.109; 91.119; 91.121; 

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

& (b) to operate s U AS for commercial use. 

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9 Conclusion 

Graniterock seeks this exemption to conduct commercial operations using sUAS within restrictedaccess areas in the NAS. Without this exemption, sUAS innovation will be suppressed, the public 

economic benefits derived from increased sUAS development will be denied, and the Congressional 

directive to accelerate the integration of UAS into the NAS will be impeded. The sUAS physical and 

operational characteristics are compliant with those described in the FMRA and FAA's guidance for 

Sec 333 exemptions. Graniterock respectfully requests that the FAA grant its petition for exemption 

from airworthiness. 

Please do not hesitate to contact Andrew McCollough, the Regulatory Services POC, via email at 

exemption@skyward.io if you have any questions or concerns. 

Very Respectfully Yours, 

K..~in Teffer1 

Kevin Jeffery 

Vice President 

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