27 April 2015 

David D. Harwood, P.E. 

18001 W 1 061

h St., Ste. 300 

Olathe, KS 66061 

david.harwood@terracon.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Section 333 Exemption Request 

Terracon Consultants, Inc. 

Dear Sir or Madam, 

lli!rracan 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 

14 C.F.R. Part 11, Terracon Consultants, Incorporated and wholly owned subsidiaries (Terracon) 

hereby applies for an exemption from certain federal aviation regulations (FARs). 

Summary 

Terracon is an engineering and science consulting firm. We wish to use small, unmanned aircraft 

systems (SUAS) for data collection, photography and videography in performance of 

environmental, geotechnical, geologic, and facility assessment, as well as construction monitoring 

activities. 

We request exemption from the following sections of 14 CFR: 

• 61.23(a) and (c) 

• 61.101(e)(4) and (5) 

• 61. V3(a) 

• 6·; .3'f·5(a) 

• 91.7(a) 

• 91.119(c) 

• 91.121 

• 91 . 151 (a)( 1 ) 

• 91.405(a) 

• 91.407(a)(1) 

• 91.409(a)(1)and(2) 

• 91.417(a)and(b) 

Terracon Consultants, Inc. 18001 W 1 061

h Street, Ste 300 Olathe, KS 66061 

P [913]599 6886 F [913]599 0574 terracon.com 

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Section 333 Exemption Request 

27 April 2015 lrerracon 

We request relief to the extent necessary for typical SUAS operations, in line with what the FAA 

has granted recently for similar requests. Other petitioners, as well as the FAA's responses, have 

explained the reasons why granting an exemption to the sections listed above would not adversely 

affect safety. 

Operations 

Terracon requests to perform the following types of operations: 

Environmental Assessment: Terracon will use SUAS for data collection, photography and 

videography on parcels of land and improvements as part of our environmental services for 

transactional screenings (Phase 1111 site investigations), regulatory compliance, permitting, 

monitoring, and remediation projects. 

Geotechnical and Geologic Assessment: Terracon will use SUAS for data collection, photography 

and videography on parcels of land and improvements as part of our evaluation of geologic 

hazards (landslides, subsidence, rock fall, debris flow), mapping of geologic features, and site 

reconnaissance. 

Facility Assessment: Terracon will use SUAS for data collection, photography and videography 

on existing structures and infrastructure (towers, bridges, pipelines, pavement) as part of our 

assessment of building systems including exterior components such as roofing, windows, and 

exterior finish, as well as to supplement engineering assessment of operations and maintenance 

activities or needs. 

Construction Monitoring: Terracon will use SUAS for data collection, photography and 

videography as part of our construction observation and site assessment services for construction 

projects. 

In addition, Terracon will conduct flights for training, evaluating systems and pilots, and 

maintaining pilot proficiency. 

Safety 

Use of SUAS devices in the course of our services as described will improve workers' safety, 

reducing the need for workers to visit difficult, elevated, or contaminated locations. Additionally 

our proposed SUAS use will benefit the public by helping our clients operate safe construction 

sites, build and maintain safe structures, and protect the environment. 

The operations described above will typically occur in locations with restricted, controlled and/or 

managed access, such as undeveloped parcels, construction sites, and privately owned property. 

Terracon will manage exposure by establishing a 500-foot protection zone where nonparticipating 

persons will be protected by barrier or structure. 

Responsive • Resourceful • Reliable 
Section 333 Exemption Request 

27 April2015 lrerracon 

Terracon has worked in the environmental and construction industries for decades and has a 

strong safety culture. Planning and executing safe work, using and inspecting appropriate safety 

equipment, maintaining situational awareness, and stopping work when safety is in question are 

all part of our everyday activities. 

Terracon will inspect, maintain, and operate all aircraft in accordance with manufacturers' 

manuals and checklists. This will include a preflight inspection to ensure that the aircraft is in a 

condition for safe flight. 

Unmanned aircraft systems 

We request to use the following unmanned aircraft and their associated control systems: 

• DJ I Phantom 2+ 

o Quadcopter 

o Weight 2.9 lbs. 

• 3D Robotics DIY Quad 

o Quadcopter 

o Weight 5.5 lbs. 

• 3D Robotics X8/X8M 

o Octocopter 

o Weight 7.71bs. 

• 3D Robotics Aero/Aero-M 

o Fixed-wing, single-engine 

o Weight 6.8 lbs. 

Telemetery, control, and video systems will use ordinary equipment operating in the 915 MHz, 

2.4 GHz, and 5.8 GHz bands. 

Pilots 

Each pilot will hold an airman certificate and either a medical certificate or a valid driver's license. 

Pilots will train with the aircraft and demonstrate proficiency before flying on job sites. 

Sincerely, 

Terracon Consultants, Inc. 

Senior Vice President GIS Technical Lead 

Responsive • Resourceful • Reliable