JANUS Developing Tomorrow's Answers Today 

RESEARCH GROUP, INC www.janusresearch.com 

August 18, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 5 Section 333 and the Code of Federal Regulations (CFR), Title 14, Part 11 

Dear Sir or Madam: 

Pursuant to the FAA Modernization and Reform Act of 2012, Section 333 and 14 CFR Part 11, JANUS 

Research Group, Inc. requests exemption from the Federal Aviation Regulations (FARs) listed in the 

enclosure to permit commercial operations using the 3DR X8+ small Unmanned Aircraft System (UAS) 

for terrain survey and mapping, precision silviculture, agriculture, lake, river and swamp spectroscopy 

data collection, remote sensing and inspecting, photography, videography, filmmaking, training and 

research. The following information is provided as required by 14 CFR 11.81: 

A. Contact Information. 

JANUS Research Group, Inc. 

Attn: Scott Martin 

600 Ponder Place Drive 

Evans, GA 30809 

Telephone: (706) 364-9100 

Email: scott.martin@janusresearch.com 

B. Exemption Requests. 

JANUS Research Group, Inc. requests exemptions from the CFR sections listed below. These sections are 

reviewed in the enclosure. 

14 CFR. Part 21 

14 CFR. 61.113(a) and (b) 

14 CFR. 91.7(a) 

14 CFR. 91 .119(c) 

14 CFR. 91.121 

14 CFR. 91.151(a) 

14 CFR. 91.203(a) and (b) 

14 CFR. 91.405(a) 

14 CFR. 91.407(a)(1) 

14 CFR. 91.409(a)(1) and (2) 

14 CFR. 91.417(a) and (b) 

600 Ponder Place, Evans, GA 30809 ♦ PHONE (706) 394-9100 ♦ FAX (706) 922-0098 
JANUSI Developing Tomorrow's Answers Today 

RESEARCH GROUP, INC I www.janusresearch.com 

C. Public Interest Value. 

Manned aerial services are available to perform each of the operations listed in this request. In fact, for 

long-duration requirements or for payloads that have significant power requirements it is difficult to 

replace manned aircraft. This request, however, focuses on requirements that involve lower-duration 

flights (less than 1 hour) and lower-power payloads (less than 100 Watts). Approving this request benefits 

the public interest because using a small UAS to accomplish these tasks involves fewer safety risks and is 

less costly, more responsive and, in some cases, more precise than manned aircraft services. These factors 

make the specialized aerial services available and attractive to a broader customer base. The cost for these 

constrained services is reasonable for farmers, forest and waterway management agencies, university 

research groups, businesses and individuals. 

D. Safety. 

JANUS Research Group, Inc. acting as UAS Pilot-in-Command (PIC) and Visual Observer (VO) agree to 

abide by such Conditions and Limitations that the FAA places on this request. Additionally, JANUS 

Research Group, Inc. will establish internal rules and procedures for conducting a risk and safety analysis 

for each mission. The procedures will include requirements regarding the crew, mission, UAS and 

weather. 

Crew: The PIC will possess proper pilot and medical certification and will be fully trained to operate 

the UAS. The PIC will be responsible for conducting safe flight operations and for adhering 

to FAA regulations, conditions and limitations. The PIC will ensure that the VO is briefed on 

responsibilities for the specific mission. 

Mission: Define the mission purpose and the operational area. Consider proximity to airports, people 

and structures. Obtain proper releases and permission statements, as needed, prior to flight 

operations. Review Notices to Airmen (NOTAMs). Ensure that safety measures such as a cell 

phone with emergency numbers, first aid kit and fire extinguisher on hand during the mission. 

UAS: Conduct pre-flight checks to establish that the UAS is structurally sound and that the radios, 

instrumentation, motors and payload are fully functional. Ensure that programmable safety 

settings for return-to-home, auto-land, loiter and flight-abort are properly entered in the flight 

controller. 

Weather: Establish that weather conditions (wind speed, visibility and precipitation) are suitable for the 

mission. 

The safety attributes of battery powered UASs coupled with safety conscious JANUS Research Group, 

Inc. flight operations provides a level of safety that is at least as safe as the rules for which exemptions are 

requested. 

600 Ponder Place, Evans, GA 30809 ♦ PHONE (706) 394-9100 ♦ FAX (706) 922-0098 
JANUS Developing Tomorrow's Answers Today 

RESEARCH GROUP, INC www.janusresearch.com 

E. Federal Register Summary. 

The following summary is provided for publication in the Federal Register: 

Docket No.: No. FAA-2015- Petitioner: JANUS Research Group, Inc. Section of 14 CFR: Part 21, 61.113(a) and 

(b), 91.7(a), 91. l 19(c), 91.121, 91.15 l(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

91.417(a) and (b). JANUS Research Group, Inc. is seeking an exemption to conduct commercial operations using a 

small Unmanned Aircraft System, 55 pounds or less gross weight, for terrain survey and mapping, precision 

silviculture, agriculture, lake, river and swamp spectroscopy data collection, remote sensing and inspecting, 

photography, videography, filmmaking, training and research in the United States. 

Sincerely, 

T Scott Martin 

Chief Technology Officer 

JANUS Research Group, Inc. 

Enclosure 

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JANU Developing Tomorrow's Answers Today 

RESEARCH GROUP, INC www.janusresearch.com 

ENCLOSURE: EXEMPTION REQUESTS 

JANUS Research Group, Inc. requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to commercial UAS operations: 

14 CFR Part 21, Subpart H- Airworthiness Certificates. 

14 CFR 91.203(a) &(b) - Civil aircraft: Certifications required. 

Section 91.203(a)(1) requires all civil aircraft to have "an appropriate and current airworthiness certificate." 

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the applicability and the procedural requirements 

for the issuance of airworthiness certificates as required by Section 91.203(a)(1). The spirit of the airworthiness 

certificate is to protect the safety of aircraft passengers, people on the ground and property. The small UAS 

limitations in weight and altitude combined with rules that govern UAS flights achieve or exceed the level of safety 

intended by the Airworthiness Certificate requirement. The Federal Aviation Act and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate of the UAS involved 

upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas. 

These outlined conditions all apply to the UAS considered in this exemption request. 

14 CFR 61.113(a) &(b) - Private pilot privileges and limitations: Pilot in 

command. 

Sections 61.1 l 3(a) &(b) provide regulations for the limitation of private pilot privileges to non-commercial 

operations. Section 61.133(a) requires an individual to hold a commercial pilot's license when acting as pilot in 

command of an aircraft used for compensation or hire. The commercial license is an indication that the pilot 

possesses the higher skill level expected for transporting people or property commercially. The UAS flight 

controller with automatic safety features accomplish for a small UAS much of what additional commercial pilot 

training does for larger, manned aircraft. The small UAS is lightweight, very stable and can react automatically to 

emergency conditions. The PIC and VO will follow established flight procedures and will achieve at least the same 

safety level as expected of commercial pilots in manned aircraft. 

14 CFR 91.7(a) - Civil aircraft airworthiness. 

This regulation requires that "no person may operate a civil aircraft unless it is in airworthy condition." No FAA 

standard exists for determining an aircraft's airworthiness when an airworthiness certificate is not issued. If the 

requested exemption from 14 CFR PART 21, SUBPART H: AIRWORTHINESS CERTIFICATES is granted, an 

equivalent safety level will be achieved by complying with operating rules, conditions and limitations. 

14 CFR 91.119(c) - Minimum safe altitudes: General. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying 

over areas other than congested areas to 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. This UAS exemption request is based on conducting precision work that may require low altitude flight 

or flights closer than 500 feet to structures. Internal flight operations require written waivers or permission 

statements for every flight over private property. Therefore, no flight operations will occur without the permission of 

the property owner or land management entities. In addition, small size, weight, and low speeds of UAS, contribute 

to very minimal hazards to persons, property, vessels, vehicles or structures. The associated risks are marginal and 

will be reviewed during the safety and risk analysis for each mission. 

600 Ponder Place, Evans, GA 30809 ♦ PHONE (706) 394-9100 ♦ FAX (706) 922-0098 
ANUSI Developing Tomorrow's Answers Today 

RESEARCH GROUP, INC www.janusresearch.com 

14 CFR 91.121 - Altimeter settings. 

Section 91.121 (a)( l)(iii) requires a person operating an aircraft to maintain cruising altitude or flight level by 

reference to an altimeter that is set, when operating below 18,000 MSL, to: In the case of an aircraft not equipped 

with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. An 

exemption to this regulation is not sought, rather a verification that Global Positioning System (GPS) elevation data 

at the takeoff site is appropriate for setting the small UAS altimeter. 

14 CFR 91.151(a) - Fuel requirements for flight in VFR conditions. 

This regulation prohibits an individual from beginning "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." This regulation provides a safety margin for manned airplanes. An exemption 

to this regulation is sought because the small UAS is not manned, does not have liquid fuel and because the PIC and 

VO have continuous visual contact with it. Additionally, the 30 minute reserve requirement exceeds the total flight 

time that some of the UAS battery packs provide. A safety feature of the flight controller will automatically land the 

UAS, typically at the takeoff point, when the battery level is low. These conditions achieve an equivalent safety 

level to having reserve fuel for manned airplane flights. 

14 CFR 91.405 (a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) — 

Maintenance. 

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter ..." Section 91.407 makes reference to 

requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air worthiness 

certificate. Section 91.417(a) requires the owner or operator to keep records of maintenance work that has been 

accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval for aircraft return 

to service. An exemption to these sections is requested because there is not a maintenance infrastructure or certified 

personnel for officially inspecting and repairing small UAS. JANUS Research Group, Inc. will maintain the UAS 

and keep detailed records. The equivalent level of safety will be achieved through periodic maintenance checks and 

preflight checks for each mission. 

600 Ponder Place, Evans, GA 30809 ♦ PHONE (706) 394-9100 ♦ FAX (706) 922-0098