Big Mountain Robotics, aka DroneMapper 18656 Eastridge Road Cedaredge, Colorado 81413
- 8319 February 25 , 2 01 6 Docket Operations, M
- 30 U.S. Department of Transportation 1200 New Jersey

Avenue, SE., Room W12
- 140 West Building Ground Floor Washington, DC 20590
- - - 0001 Subject: Section 333 Petition for Exemption 14 CFR **§** 11.81 Electronic Submittal

– Via FDMS Website Dear Staff: This letter serves as a petition for exemption from specific rules contained in Title 14 of the Code of Federal Regulations (14CFR), regarding the operatio n of a small, unmanned aircraft s ys tem (small UAS) in the National Airspace S ys tem (NAS). This petition has been prepared and filed in accordance with 1 4 CFR **§** 11.81. Operation of the Unmanned Aircraft The UAS will be used for precision mapping operations by Big Mountain Robotics, aka DroneMapper, that provides precision geo
- referenced orthomosaics, digital elevation models, digital terrain models and 3
- D point clouds to clientele worldwide. The U AS , a DJ I Phantom 3 Advanced , will be used primarily to obtain low elevation aerial photos of the terrain and structures to enable efficient and low cost generation of photogrammetrically produced products and 3
- D models
. T hese operations will benefit the public as a whole by enabling low cost image processing that is capable of producing accurate geo
- referenced mapping products used in a multitude of market applications
. We will implement all of the Operational Limitations , outlined in Proposed Part 107 of the Notice of Proposed Rulemaking (NPRM)
. These limitations will ensure the same level of safet y offered b y the rules for which the exemption is sought. The UAS will be operated in Class G airspace only , and flights will not exceed 200 feet in elevation above ground level (AG L)
. Operations will be limited to daylight
- only in Class G airspace, using visual line
- of
- sight (VLOS), in sparsel y populated areas. All o perations will also remain:

• 5 nautical miles from an airport having an ope rational control tower; or

• 3 nautical miles from an airport with a published instrument flight procedure, but not an operational tower; orBig Mountain Robotics, aka DroneMapper 18656 Eastridge Road Cedaredge, Colorado 81413
- 8319 • 2 nautical miles from an airport without a published instrument flight procedure or an operational tower; or

• 2 nautical miles from a heliport with a published instrument flight procedure. Prior to each flight, the Pilot In Command (PIC) will perform a preflight inspection of the UAS, and follow the manufacturer’s pre
- flight checklist and log that information . In addition, an Airplane Flight Manual/Phantom 3 Advanced User Manual (AFM) will also be available for each flight. An y anomalous indicators flagged during the pre
- flight inspection will be cause for flight termination. The aircraft weight including camera and battery is 1.28 Kg
. The Phantom 3 Advanced Safet y Guidelines also provide recommendations for the safe operation of the UAS, and potential hazards to be aware of
. Unmanned Aircraft Pilot in Command (PI C) and Operations The Pilot in Command (PI C) will be an aircraft licensed pilot experienced in the safe operation of the Phantom 3 Advanced . As pilot in command, he/ she will assume the final authorit y and responsibility

for the operation and safety of the flight. During an y flight operations at least one Visual Observer (VO) will assist the PI C in verifying safet y in the air and on the ground. Should the PI C and VO(s) be out of verbal communication distance , a set of radios will be utilized to assure real time communications. The Phantom 3 Advanced will be programmed prior to flight to fly autonomousl y over the area of interest. An area of interest geo
- referenced poly gon will be generated and will provide a contained geo
- fence for UAS operation. Should any potential hazard be identified during flight operation the PI C will activate the “return home” function using the flight controller. The UAS will be registered in a ccordance with Part 47 of the 49 UCS **§** 44711. Maintenance and repair will be performed as necessary , and a maintenance record will be recorded in a repair logbook. This will ensure that the UAS is in a safe condition for flight. The Maintenance M anual for the Phantom 3 Advanced will be used as a reference. Rules for Requested Exemption : **1. 14**  **CFR, Part 21, Subpart H**  - **Airworthiness Certificates** This section pertains to requirements for the issue of airworthiness certificates. Proposed Part 107 of the NPRM concluded that, requiring small UAS operators to conduct inspection and maintenance of the small UAS pursuant to the existing regulations of 14 CFR part 43, or to obtain a permit to operate (PTO), would not result in signif icant safety

benefits. **2. 14 CFR,**  **P**

**art 91 §**  **91.103** - **Preflight Action**  This section pertains to preflight actions for IFR flights, and reviewing information related to runway lengths, and takeoff and landing distances. The small UAS will never be flown under IFR conditions, and takeoff and landing distances are not a factor on a rotorcraft. The small UAS will undergo a preflight assessment, which will include: (1) l ocal weather conditions;Big Mountain Robotics, aka DroneMapper 18656 Eastridge Road Cedaredge, Colorado 81413
- 8319 (2) local airspace and flight restrictions; (3) the location of persons and propert y on the ground; (4) an y other ground hazards. **3. 14 CFR,**  **P**

**art 91 §**  **91.109** - **Flight Instruction**  This section pertains to aircraft being used for flight instruction. The small UAS will not be used for flight instruction. **4. 14**  **CFR, P** 

**art 91**  **§ 91.119**  - **Minimum Safe**  **Altitudes** This section pertains to minimum altitudes for flight, which are a minimum of 500 feet above the surface, and greater. The small UAS will be flown at a maximum altitude of 2 00 feet above the surface. This rule would not be applicable to Proposed Part 107 of the NPRM. **5. 14 CFR,**  **Part 91 §**  **91.121** - **Altimeter Settings**  This section pertains to cruising altitudes and flight levels as referenced b y altimeter settings. In addition, the rule pertains to flights that are above a minimum altitude of 500 feet. The small UAS does not contain an altimeter, and will be flown at a maximum altitude of 2 00 feet. This rule would not be applic able to Proposed Part 107 of the NPRM. **6. 14 CFR,**  **P**

**art 91**  **§ 91.151**  - **Fuel Requirements for**  **VFR Conditions**  This section pertains to fuel requirements in VFR conditions when flying an aircraf t to the first point of intended landing. The small UAS will be flown on battery power, and will remain within a visual line
- of
- sight (VLOS) at all times. This rule would not be applicable to Proposed Part 107 of the NPRM.
**7. 14 CFR,**  **P**

**art 91**  **§ 91.203(a)(1)**  - **Civil Aircraf**  **t Certifications**  This section pertains to airworthiness certificates originall y designed for manned aircraft. It is not practicall y feasible for small UAS manufacturers to complete the certification process required of manned aircraft. Proposed Par t 107 of the NPRM has accommodated non
recreational small UAS use through a certificate of waiver or authorization (COA). The UAS will be registered with the FAA, and a COA would be requested subsequent to the Section 333 exemption process. **8. 14 CFR,**  **P**

**art 91**  **§ 91.405**  - **Maintenance Required**  This section pertains to the maintenance of manned aircraft. Proposed Part 107of the NPRM concluded that, requiring small UAS operators to conduct inspection and maintenance of the small UAS pursuant to the existing regulations of 14 CFR P art 43, or to obtain a permit to operate (PTO), would not result in significant safet y benefits. **9. 14 CFR,**  **P**

**art 91**  **§ 91.407**  - **Operation After Maintenance,**  **Preventative Maintenance**  This section pertains to aircraf t maintenance, preventative maintenance, and alterations for manned aircraft. The small UAS will not carry persons, and will not be a ltered to change flight characteristics.Big Mountain Robotics, aka DroneMapper 18656 Eastridge Road Cedaredge, Colorado 81413
- 8319 **10. 14 CFR,**  **P**

**ar t**  **91 §**  **91.409** - **Inspe ctions**  This section pertains to manned aircraft inspections. Proposed Part 107 of the NPRM concluded that, requiring small UAS operators to conduct inspection and maintenance of the small UAS pursuant to the existing regulations of 14 CFR P art 43, or to obtain a permit to operate (PTO), would not result in significant safet y benefits. **11. 14**  **CFR, P** 

**art 91**  **§ 91.417**  - **Maintenance Records**  This section pertains to maintenance records for manned aircraft for the 100
- hour, annual, and progressive periods. These rules are impractical for a small UAS, and would not resul t in significant safet y benefits. Maintenance records for the small UAS will be kept as required. Summary of Rules for Exemption: Sections of 14 CFR: P arts 21 and 91. Specificall y including sections: P art 21, Subpart H, **§** 91.103, **§** 91.109, **§** 91.119, **§** 91.121, **§** 91.151, **§** 91.203(a)(1), **§** 91.405, **§** 91.407, **§** 91.409, **§** 91.417. Description of Relief Sought: DroneMapper is seeking an exemption to commercially operate a small unmanned aircraft sy stem, the DJ I Phantom 3 Advanced, at an AGL of 200 feet for the purpose of precision geo
referenced ortho mosaic and digital elevation model constructions to be used in a wide variet y of applications. Conclusion Due to their light weight, small
- unmanned aircraft generall y pose a significantl y lower risk to people and propert y on the ground, as compared to manned aircraft. The size, weight, speed, and capability of the Phantom 3 Advanced will no t create a hazard to the users of the NAS or the general public. Granting this reques t for exemption would not adversel y affect safet y, and would be in the general public interest. S incerel y, Pierre Stoermer, CEO Big Mountain Robotics, aka DroneMapper 18656 Eastridge Road Cedaredge, Colorado 81413 (970) 417
- 1102