December 15, 2015 

# CON•AGG

-- OFMISSOURI

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### 2604 N. Stadium Blvd. Columbia, Missouri 6S202-1271 Telephone: 573-446·0905

U. S. Department ofTransportation Docket Management System West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE Washington DC 20590



### RE: Exemption Request Section 333 ofthe FAA Reform Act

Dear Sir or Madam:

We respectfully request exemption underSection 333 ofthe FAA Reform ACT and Part 11 of the Federal Aviation Regulations.



### Petitioner:
Con-Agg of MO LLC. 2604 N. Stadium Blvd. Columbia, Missouri 65202-1271 Telephone: 573-446-0905
Con-Agg of MO is an aggregates producer in Central and northwest Missouri. Con-Agg of MO intends to incorporatethe use ofsUASs for avariety ofprojects which may include but not be limited to aerial surveying; aerial mapping; project and construction management, inspections and monitoring; environmental review projects; agricultural projects; educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and rescue, etc.


### Specific Section(s) seeking exemption:

14C.F.R Part 21 14C.F.R. 45.23(b) 14 C.F.R. 61.113(a) and (b) 14C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2) 14 C.F.R. 91.109

# CON•AGG

-- OFMISSOURI

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### 2604 N. Stadium Blvd. Columbia, Missouri 65202-1271 Telephone: 573-446-0905 U. S. Department ofTransportation Docket Management System December 15, 2015 Page Two

14 C.F.R. 91.119 14C.F.R. 91.121 14C.F.R. 91.151(a) 14 C.F.R. 91.203(a) and (b) 14 C.F.R. 91.215 14 C.F.R. 91.104 through 91.417



### Extend of relief requested:

To permitcommercial operation ofSmall Unmanned Aircraft Systems (sUASs) for operations conducted within and underthe conditions outlined herein or as may be established by the FAA
as required by Section 333.

Said exemption would permitthe operation ofsUASs under controlled conditions in limited, predetermined and controlled airspace. Upon granting ofthis proposed exemption request, Norris Quarries would conduct commercial operations ofsUASs meeting or exceeding all operational and safety requirements per Section 333. 

### Public/Safety Benefits:

1. Project and Quarry management, inspections and monitoring.The use ofsUASs on quarry sites may improvethe safety ofworkers, local residents and general public by assessing potential dangerous situations. Falls and injuries may be reduced or eliminated through a morethorough review ofthe mine sites. In some cases, sUASs may reduce the reliance ofhelicoptersor small aircraftto monitorsaid sites. This may improve safety as well as reduce environmental impact by reducing energy usage; 2. Environmental Review projects. The use ofsUASs duringthe process of reviewing projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review ofthe project site as well as surrounding areas; 3. Aerial surveying. The use ofsUASs in connection with aerial surveying ofsmaller areas may eliminate the use of helicopters or aircraft. This could provide a more cost effective, safer and more energy efficient product; 4. Agricultural projects. Wildlife and Forestry projects. The use ofsUASs could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information when problems occur, vermin infestation, fire hazards, etc.;

# CON•AGG

-- OFMISSOURI

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### 2604 N. Stadium Blvd. Columbia, Missouri 65202-1271 Telephone: 573·446-0905 U.S. Department ofTransportation Docket Management System December 15, 2015 Page Three

5. Remote Sensing projects. The use ofsUASs could provideviews and informationfor remote and inaccessible areas. This could promoteworker safety as well as reduce the reliance on helicopters and aircraft; 6. Educational and Research projects. The use ofsUASs could provide information for said projects in a more cost effective and efficient mannerthan other available options; 7. Aerial filmmaking, photography and real estate purposes. The use ofsUASs may provide
a point ofview previously unavailable through other means. They would be more cost effective, efficient and more safelythan helicopters and aircraft; and 8. Search and rescue. The use ofsUASs may provide assistance to local law organizations during search and rescue missions. SUASs may reach areas unattainable orviewable with helicopters and aircraft. SUASs may be implemented quicker as time is ofthe
essence during search and rescue operations. 

### Reasons whythe exemption would not adversely affect safetyor howthe exemption would provide alevel of safetyat least equal to the existing rule.
Proposed operations using sUASs provide increased safety enhancement especially when compared with helicopters and aircraftforthefollowing reasons:
1. The sUASs will weigh less than ten (10) pounds; 2. Flights will be operated within the visual line ofsight ofthe pilot; 3. Maximumtotal flighttime for each operational flight will be thirty (30) minutes. Flight times may be less than thirty (30) minutes as the UAS will continuously monitor battery
reserve and return tothe ground station with at least 20% battery power reserved; 4. Flights will be operated at an altitude of200 feetAGL. Flights will never exceed 400feet AGL which will be predetermined in theflight planning software. As well, this current altitude is visible on the controller at all times; 5. Minimum crewfor each operation will consist ofthe sUAS pilot and aVisual Observer; 6. A briefingwill be conducted daily by all personnel workingwith said sUAS; 7. Verbal/written consent will be required ofall persons within 100feet offlight operation; 8. Flights shall occur on company owned or leased property only, ifthe need to operate sUAS outside ofcompany property should occurwritten and/or oral permission from relative property ownerswill be obtained priorto operatingthe sUAS; 9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); andI' -..

-- OFMISSOURI

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### 2604 N. Stadium Blvd. Columbia, Missouri 65202-1271 Telephone: 573-446-0905 U.S. Department ofTransportation Docket Management System December 15, 2015 Page Four

11.The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and horizontally; 12.The sUAS will be operated through the use oftheTower software which allows forflight planning by setting the security perimeters in which the sUAS will be required tofly. 13. The sUAS will have the capabilityto return and land atthe pre-determined location with the Security Perimeters should the sUAS lose communication orGPS signal during any operations; 14.The sUAS PIC will have the capabilityto abort a manual flight as well as an automated flight in case of unpredicted obstacles or emergencies, as well a manual override is available in the instance ofan automated flight; 15. Operationswill not be conducted over densely populated areas or heavilytraffic highways; and 16. Operations will not be conducted within five (5) NM of an airport or heliport unless given prior permission from said airport/heliports. 

### Equipment and Specifications.

3DR SOLO KIT"' 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller SetBlack, 3DR Solo Battery Charger, 3DR Solo Controller Charger 

### Specifications: Up to 26 minutes offlight time (20 with camera and Solo Gimbal), HD video streamingto mobile Top speed: 55 mph MaxAltitude: 400ft, per FAA rules Weight: 1600g; 1760 gwith Solo Gimbal and GoPro Wi-Fi range: up to a halfa mile, depending on environment Controllerwith color screen and live flight data Pixhawk 2flight controller software Customizable color LEOs for orientation Solo Battery: 14.8V LiPo (5200mAh) Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available) 10x4.5 self-tightening props 880 kV motors Plug and play with 3-axis Solo Gimbal from 3DR

# .. " 

# CON•AGG

- OFMISSOURI

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### 2604 N. Stadium Blvd. Columbia, Missouri 65202-1271 Telephone: 573-446-0905 U. S. Department ofTransportation Docket Management System December 15, 2015 Page Five



### Conclusion:
Con-Agg of Missouri, LLC is a company owned bySummit Materials. We are engaged in the production ofaggregates, redi-mix and concrete. The 3DR Solo is safer than having Con-Agg employees out in thefield for specific projects, and also very safe for other aircrafts because of the mission specifications (below400ft.) and 3DR Solo integrated safetyfeatures. We are prepared to modifyor amend any part ofthis request to satisfythe need for an equivalent level

I ofsafety. We lookforward to working with your office. Please feel free to contact our office should you have any additional questions or comments. Thankyou for your cooperation with this matter.
Sincerely,

# ~**~-------** Alan Vassmer Construction Engineering Tech.

Company Representative

# dAAj~ larrySteeby Mine Development



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