UNITED STATES OF AMERICA
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Document No._______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

MORAN SURVEYING INCORPORATED

FOR AN EXEMPTION SEEKING RELIEF FR OM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113 (a) & (b), 91.7 (a), 91.121, 91.151 (b), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) & (a) (2), and 91.417 (a) & (b)
CONCERNING COMMERCIAL OPERATION OF THE 3DR X8

- M UNMANNED AIRCRAFT SYSTEM
PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

– 95)

Submitted on 5 October 2015 Stephen F. Moran, PLS , MBA Moran Surveying Incorporated

14 William Ave Pembroke, MA 02359 Tel: 781

– 293

– 5601
Fax : 781

– 293

– 1952 Professional Land Surveyors www.moransurveying.com sfmoran@moransurveying.com sfmoran62@gmail.com23 

### Table of Contents

Glossary of Abbreviati ons

................................ ................................ ................................ .......................... 3

Summary

................................ ................................ ................................ ................................ .................... 4

Introduction and Interests of Petitioner

................................ ................................ ................................ .... 4

Background

................................ ................................ ................................ ................................ ................ 4

Basis for Petition

................................ ................................ ................................ ................................ ........ 4

A. Name and Address of Petitioner

................................ ................................ ............................... 6

B. Specific Sections of 14 CFR from Which MSI Seeks Exemption

................................ ................ 6

C. Extent of Relief MSI Seeks and the Reason MSI Seeks Relie f

................................ .................... 9

D Reasons Why Granting MSI’s Request Would Be in the Public Interest

................................ .... 11

E. Reasons Why Granting the Exemption Would Not Adversely Affect Safety

............................. 13

Conclusion

................................ ................................ ................................ ................................ .................. 22

Appendices

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .... see separate attachment /filing4 

### Glossary of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Stat ion

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airman

OEM Original Equipment Manufacturer

PIC Pilot in Command

RTH Return to Home

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SVFR Special Vi sual Flight Rules

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing5 

## SUMMARY

Moran Surveying Incorporated (MSI) seeks exemption f rom the requirements of 14 CFR section 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an unmanned aircraft system pursuant to section 333 of the FAA modernization and Reform Act of 2012 (FM RA). Obtaining this exemption will permit Moran Surveying Incorporated to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial acquisitions within the National Airspace System (NAS).



## INTRODUCTION AND INTERESTS OF THE P ETITIONER

Moran Surveying Incorporated (hereafter referred to as “MSI”) is a registered professional land surveying business located in Pembroke, Massachusetts. MSI is an MBE veteran owned and operated small business that serves the communities surrounding Pembroke, including Boston, southeastern Massachusetts, Cape Cod and the Islands. It is owned and operated by Stephen F. Moran, a registered Professional Land Surveyor and veteran rotary and fixed wing pilot. Moran has been engaged in the practice of land surveying since the 1980s and has held a license (MA registration #41611) in this practice since 2000 . In addition, Mr. Moran is a veteran rotary wing pilot with over 4100 hours of time in the national airspace and five other countries. In addition to Mor an's surveying license, he also holds a commercial rotary wing license with a fixed wing rating. Moran is also a military qualified instructor pilot and instrument flight examiner. This makes Mr. Moran uniquely qualified for a UAS exemption for
commercial applications in conjunction with professional land surveying.



## BACKGROUND

Unmanned Aircraft System: 3DR X8

- M (UAS)

MSI seeks exemption to operate the 3DR X8

- M for compensation or hire within the NAS. The 3DR X8

- M and is comprised of a Vertical Takeoff and L anding (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The 3DR X8

- M has a maximum gross weight of approximately 7.3 pounds; measures approximately 20 inches in length, 13 inches in width, and 11.8 inches in height and has a
recommended speed of approximately 11 mph. The 3DR X8

- M is equipped with eight rotors arranged in 4 quadrants each quadrant having two motors and two rotor blades. E ach motor is being driven by a lithium polymer battery powered electric motor.



## BASIS FOR PETITION

Petitioner Moran Surveying Inc., by and through the undersigned point of contact Stephen F. Moran, pursuant to the provisions of the Federal Aviation Regulation (14 CFR § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Specia l Rules for Certain Unmanned Aircraft Systems , hereby petitions the administration to operate the 3DR X8

- M UAS within the National Airspace6

System (NAS), and for exemption from the requirements of 14 CFR § 61. 113(a) & (b), 91.7 (a), 91.121, 91.151 (b), 91 .405 (a), 91.407 (a) (1), 91.409 (a) (1) & (a) (2), and 91.417 (a) & (b).

In consideration of the size, weight, speed and limited operating area associated with the unmanned aircraft in its operation, MSI's operation of the 3DR X8

- M UAS meets the consider ations of FMRA Section 333 and therefore will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H.

Accordingly, MSI requests relief from sections 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) & (a) (2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft
with an airworthiness certificate.

MSI submits that the requested relief is proper since an equivalent level of safety will be insured. All maintenance alterations or p reventative maintenance of the 3DR X8

- M UAS performed by MSI will be in accordance with the methods, techniques and practices prescribed in the operating documents (i. e.,
the 3DR X8

- M Operations Manual and associated checklist s ). Furthermore, only Origina l Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher

- level inspections and maintenance per the operations documents and OEM standards. MSI will document and maintain all flight and maintenance records for the 3DR X8

- M UAS.

Relie f from certain requirements of section 61. 113 (a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by MSI to the extent necessary to allow the proposed UAS flight operations to be conducted by a Pilot in Command ( PIC) holding a commercial pilot certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight hour and currency requirements, that they are able to safely operate they 3DR X8

- M UAS in a manner consistent with th is exemption including evasive and emergency maneuvers, and maintaining appropriate distances from people, vessels, vehicles, and structures.

MSI seeks relief from section 91.7 entitled Civil aircraft airworthiness , because the 3DR X8

- M UAS does not requir e an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. As such,
MSI submits that it will ensure that the 3DR X8

- M UAS is in airworthy condition prior to every flight by determining that the UAS is in compliance with the operating docu ments (i. e., 3DR X8

- M operations manual), and that the UAS is in a condition of safe flight.

MSI also seeks an exemption from the requirement of section 91.121, entitled Altimeter Settings , because the altitude reporting equipment of the 3DR X8

- M is set t o zero feet above ground level (AGL), rather than local barometric pressure or field altitude, before each flight. The altitude
information of the 3DR X8

- M is provided to the PIC via a barometric pressure sensor, global positioning system (GPS) equipment, and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. A level of safety equivalent to section 91.121 will be
insured as the altitude of the 3DR X8

- M UA will be reported to air

- traff ic control (ATC) in feet AGL, and MSI will operate the 3DR X8

- M UA within visual line of sight, at or below 200 feet AGL.

In accordance with 14 CFR § 11.81, Moran Surveying Incorporated provides the following information in support of its petition for exem ption:

A. Name And Address Of The Petitioner7

The name and address of the petitioner is:

Moran Surveying Incorporated
14 William Ave Pembroke, MA 02359

The point of contact for this petition and specific contact information is as follows:

Stephe n F. Moran, PLS Moran Surveying Incorporated
14 William Ave Pembroke, MA 02359 Tel: (781) 293

- 5601 | Fax: (781) 293

- 1952

Email: sfmoran@moransurveying.com

B. The Specific Sections of 14 CFR From Which MSI Seeks Exemption.

1. MSI seeks exemption from the requirements of section 61.113 (a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: pilot in command, subsections (a) and (b) prescribed the following, in relevant pa rt:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as a PIC of an aircraft.

(b) A p rivate pilot may, for compensation or hire, act as a PIC of an aircraft in connection with any business or employment if

-
(1) The flight is only incidental to the business or employment; and

(2) The aircraft does not carry passengers or property for co mpensation or hire.

2. MSI seeks exemption from the requirement of section 91.7 (a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition

.

3. MSI seeks exemption from the requirements of section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that
air craft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

—
(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;8 (ii) if there is no station within the area prescribed in paragraph (a) (1) (i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) in the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate al timeter setting available before departure;

4. MSI seeks exemption from the requirements of section 91.151 (b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under CFR 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, to fly after that for at least 20 min.

5. MSI seeks exemptio n from the requirements of section 91.405 (a).

Section 91.405, entitled Maintenance required , subsection (a), states the following:

Each owner or operator of an aircraft

--
(a) Shall have the aircraft inspected as prescribed in subpart E of this part and sh all between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter [.]

6. MSI seeks exemption from the requirements of section 91.407 (a) (1).

Section 91.407 entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a) (1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

7. MSI seeks exemption from the requirements of sections 91.409 (a) (1) and 91.409 (a) (2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. MSI seeks exemption from the requirements of sections 91.417 (a) a nd 91.417 (b).9

Section 91.417, entitled Maintenance records , subsections (a) and (b), states the following:

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the per iods specified in paragraph (b) of this
section:

(1) Records of the maintenance, preventive maintenance, and alteration, and records of
the 100

- hour, annual, progressive, and other required or approved inspections as appropriate, for each aircraft (includ ing the airframe) and each engine, propeller, rotor and appliance of an
aircraft. The records must include

--

(i) A description (or reference to data acceptable to the Administration) of the work performed; and

(ii) The date of completion of the work perf ormed; and

(iii) The signature and certificate number of the person approving the aircraft for
return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller and
each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The curr ent inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision state. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribe d by § 43.9 (d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records speci fied in paragraph (a) (1) of this section shall be retained until the work is repeated or superseded by work or for 1 year after the work is performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained and
transferred with the aircraft at the time the aircraft is sold.10 (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for
return to service.

C. The e xtent of relief MSI seeks and reasons MSI seeks the relief.

1. Extent of relief MSI seeks and the reason MSI seeks relief from section 61.113 (a) and (b).

Relief from section 61.113 (a) and (b) entitled Private pilot privileges and limitations: pilot in c ommand , is requested to the extent necessary to allow a PIC holding a private or commercial pilot certificate, as well as an airman medical certificate and who has met certain flight our and currency requirements, to conduct the proposed UAS flight operati ons for compensation or hire.

This relief is requested since the limitations set forth in section 61.113 (a) and (b) state that a private pilot may for compensation or hire act as PIC of an aircraft in connection with any business or employment if: (1) th e flight is only incidental to that business or employment; and (2) the aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, MSI submits that an equivalent level of safety will be
maintained because no PI C will be allowed to operate the 3DR X8

- M unless that PIC has met certain flight our and currency requirements, demonstrating that the PIC is able to safely operate
the 3DR X8

- M UAS in a manner consistent with the operations specifications as set forth her ein, including evasive and emergency maneuvers as well as maintaining appropriate distances from people, vessels, vehicles, and structures.

Furthermore, MSI submits that all flights of the 3DR X8

- M conducted by the PIC pursuant to the grant of this petiti on: (1) will be incidental to Moran Surveying Incorporated's business; and (2) will not carry passengers or property for compensation or hire.

2. Extent of relief MSI seeks and the reason MSI seeks relief from section 91.7 (a).

Relief from section 91.7 (a ) entitled civil aircraft airworthiness, is requested to the extent required to allow MSI to determine that the 3DR X8

- M UAS is in an airworthy condition prior to every flight by insuring that the UAS is in compliance with the operating documents (e.g., th e 3DR X8

- M operation manual).

Moran Surveying Incorporated seeks the requested relief because the 3DR X8

- M UAS does not require an airworthiness certificate in accordance with 14 CFR 21, subpart H. Therefore, Moran Surveying Incorporated will ensure that the 3DR X8

- M UAS is in an airworthy condition based upon its compliance with the operating documents prior to every flight, and further, determine the aircraft is in a condition for safe flight as stated in the conditions and limitations
below.

3. Extent of relief MSI seeks and the reason MSI seeks relief from section 91.121.

Relief from section 91.121, entitled altimeter settings, may be required to allow flight operations of the 3DR X8

- M because the 3DR X8

- M altitude reporting equipment may be set on11

th e ground zero feet AGL, rather than by local barometric pressure or field altitude, before each flight. The 3DR X8

- M UAS utilizes a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information f rom the UA to the PIC at the ground station (GCS).

Considering the limited altitude of the proposed operations, relief from 14 CFR § 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated
below. As more fu lly set forth herein, a level of safety equivalent to section 91.121 will be
ensured as the altitude of the 3DR X8

- M will be reported to air traffic control (ATC) in feet above ground level (AGL), and Moran Surveying Incorporated will operate the 3DR X8

- M UA within visual line of sight, at or below 200 feet AGL.

4. Extent of relief MSI seeks and the reason MSI seeks relief from section 91.151 (b).

Relief from section 91.151 (b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery

- powered 3DR X8

- M UA during daylight hours in Visual Meteorological Conditions (VMC), under Visual Flight Rules (VFR) for a total duration of 14 min. to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 min. (i.e., 20% battery power remaining). MSI seeks the requested relief because without an exemption from section 91.151 (a), the flight time duration of the battery

- powered 3DR X8

- M UA will severely const rain the practicality of any aerial acquisition and research flight operations that Moran Surveying Incorporated proposes to conduct pursuant to this petition.

Significantly, as set forth below, the technical specifications of the 3DR X8

- M UAS the
3DR X8

- M operating documents and MSI's proposed operating limitations ensure that MSI will safely operate the battery

- powered 3DR X8

- M during daylight hours in Visual Meteorological Conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for duration of 20 min. to the point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 min. (i.e., 20% battery power remaining).

5. Extent of relief MSI seeks and the reason MSI seeks relief from sections 91.405 (a ), 91.407 (a) (1), 91.409 (a) (1) and (a) (2), and 91.417 (a) & (b).

Since section 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) and (a) (2), and 91.417 (a) and (b) only apply to aircraft with an airworthiness certificate, MSI requests relief from these sec tions because the 3DR X8

- M UAS does not require an airworthiness certificate. As set forth more fully below, the 3DR X8

- M UAS meets the conditions of section 333 of the FMRA without an
airworthiness certificate.

All maintenance, alterations, or preventat ive maintenance on the UAS of the 3DR X8

- M UAS performed by MSI will be in accordance with the methods, techniques, and practices prescribed in the operating documents (e.g., the 3DR X8

- M Operation Manual, the 3DR X8

- M Quick Start guide, the 3 DR X8

- M chec klists, the smart flight battery safety guidelines and the
3DR X8

- M training guide). Furthermore, only the original equipment manufacturer (OEM) or qualified OEM maintainers will perform higher

- level inspections and maintenance for the operating documents in OEM standards. MSI will document and maintain all maintenance
records of the 3DR X8

- M UAS.12

D. The reasons why granting MSI's request would be in the public interest; that is, how would it benefit the public as a whole.

Granting the present petition wi ll further the public interest by allowing MSI to safely, efficiently, and economically perform aerial acquisitions in research within the NAS, commercially in support of private and government entities, local municipalities, agriculture, scientific studie s, railroad industry, and the oil and gas industries. Additionally, the use of the 3DR X8

- M UAS will decrease congestion of the national airspace system, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of MSI's oper ation of the 3DR 8X

- M UAS will be realized without implicating any privacy issues.

1. The public will benefit from the aerial acquisition in research performed.

Moran Surveying Incorporated submits this petition to commercially operate the 3DR 8X

- M UAS and pe rform aerial acquisitions within the NAS, in support of its current business model which includes but is not limited to, private and government entities, local municipalities, agricultural, private and public industry (e.g., local gas and electric utilitie s). The 3DR X8

- M UAS will provide safe, efficient, and economical aerial acquisition and research operations to further each of these fields, all of which are
critical to the well

- being of the general public. They are also critical in planning the orderly development and expansion of local communities.

The public will also benefit in that it will realize that a local business can operate an UAS in a safe and efficient manner in the conduct of its everyday business. This operational data will serve as a
base line example to the administration and local municipalities of how UAS can be safely and efficiently integrated by a local business entity. It will also demonstrate to the administration and local municipalities that given the requisite experience and qual ifications, an UAS can be utilized in commercial applications by a local business that presently performs this type of data acquisition on a recurrent basis. The methods and safety techniques (e.g., fail safe software altitude restrictions,
manufacturer's checklists, and other restrictions described herein) combined with the experience of the UAS pilot (Stephen F. Moran, see resume in attached appendix) employed by Moran Surveying Incorporated in its commercial utilization of an UAS will serve the administr ation and local municipalities as a baseline for later commercial exceptions.

Additionally, the specific operations that Moran Surveying Incorporated will perform with the
3DR X8

- M UAS demonstrate how the requested exemption will directly benefit the above

- referenced industries and the public. In the oil and gas industry, the 3DR X8

- M will be used to: aid surveys for the planning of gas pipelines along established roadways or wetlands (see an example of such a survey in the attached appendix). Other example s include but are not limited to large detailed surveys used to repurpose unused or antiquated large commercial and or municipal facilities such as schools and hospitals (examples of such work by MSI are provided in the attached appendix). With respect to environmental surveys UAS can be utilized to trace the path of rivers and streams and their impact on the local community (an example of this type of survey is also provided in the attached appendix).

Moran Surveying Incorporated has also done numerous FEM A (Federal Emergency Management Agency) flood certifications for private clients. An UAS would play an integral part in the collection of data for the surveys. Three

- dimensional aerial data will provide the client with a better overall picture
of how the l imits of the FEMA flood lines impact private dwellings. All of the above

- mentioned data will aid local, state and federal entities should they require it.13

2. The public will benefit from decreased congestion of the NAS.

The 3DR X8

- M UA serves as a safe, effic ient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 3DR X8

- M UAS would reduce the numbe r of manned aircraft in the NAS, reduce noise and air pollution, and increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by ar riving and departing aircraft will be reduced. The 3DR X8

- M UA does not require an airport to take off or land. Likewise, a reduction of manned aircraft conducting aerial survey missions would result in fewer aircraft that must be handled by a traffic cont rol during the ground, takeoff, departure, arrival and landing phases of flight operations. That being the case, more data can be collected and stored in a safer, more efficient manner. This would give local, state, and federal agencies greater access to u pdated and actionable aerial imagery.

3 The public will benefit from the safety and efficiency of the 3DR X8

- M UAS

Conducting aerial acquisitions with the 3DR X8

- M UAS instead of a manned aircraft will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial survey flight operations. By using battery power and electric motors, the 3DR X8

- M UAS produces no air pollution, and is the most viable environmentally conscious alternative to the cab in class, six

- cylinder internal combustion twin

- engine aircraft that are typically utilized for aerial acquisitions, which burn approximately 20

- 30 gallons per hour of leaded aviation fuel. The 3DR X8

- M UA reduces the carbon footprint of aerial acquisition s, and also reduces noise pollution, as the UA is propelled by battery

- powered electric motors, rather than an internal combustion engine.

By using the 3DR X8

- M to perform aerial acquisitions, the risk to life and property in the air and on the ground will be substantially reduced or completely eliminated. Aside from the lack of flight crewmembers located on board the aircraft, the 3DR X8

- M has less physical potential for collateral damage to life and property on the ground and in the air. Compared to manne d aircraft that typically conduct aerial acquisitions (weighing approximately 6500 pounds with a wing span of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons), the UA weighs approximately 8.1 pounds at its maximum gross wei ght; measures approximately 14 inches diagonally; and carries no fuel on board.

4 Performing aerial acquisition operations with the 3DR X8

- M UAS will benefit the

economy.

In addition to being safe and efficient, the 3DR X8

- M UAS is a more economical altern ative to using manned aircraft to conduct aerial acquisitions. As such, operation of the 3DR X8

- M UAS will allow traditionally classified small business entities like Moran Surveying Incorporated to remain competitive and contribute to the growth of the lo cal economy and thereby contributing to the overall US economy. Specifically with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, classical small businesses owned and oper ated in local communities must adopt new and affordable alternative technologies in order to remain competitive. Operating the battery

- powered 3DR X8

- M UAS is one such technology that not only allows small business greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.14

By operating the 3DR X8

- M UAS, companies such as Moran Surveying Incorporated (a registered Minority Business Entity (MBE), veteran owned and operated), can remain competitive and profitable, and therefore provide greater job stability to employees and contractors, which will ultimately contribute to the growth of other local businesses and the US economy as a whole. Improved financial perfo rmance of small business entities such as MSI, through commercial use of the 3DR X8

- M UAS, provides a stable workforce that increases consumer spending; improves the outlook of small business owners, and improves state, and federal tax revenues; which in t urn allows small business to invest in research and development in order to remain competitive both locally and throughout the United States. This will ultimately allow small businesses to expand abroad should the opportunity present itself.

5. There are n o privacy issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, MSI's proposed operation of the 3DR X8

- M UAS will not implicate any privacy issues. Specifically, the 3DR
X8

- M UAS will only be operated purs uant to the specific conditions and limitations set forth herein, and it accordance with the federal aviation regulations, including minimum safe altitude requirements of 14 CFR § 91.119. Most significantly, the 3DR X8

- M UA will not be operated closer than 500 feet to any person, vessel, vehicle, or structure which is not directly involved in the operation.

E. The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to tha t provided by the rule from which MSI seeks exemption.

1. Reasons why the 3DR X8

- M UAS meets the conditions of the FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed and limited operating area associate d with the unmanned aircraft and its operation, MSI's operation of the 3DR X8

- M UAS meets the conditions of the FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H.

Section 333 provides authority for the UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA
Section 333 st ates the following, in part:

(a) in General.

-- Notwithstanding any other requirement of this subtitle, and not later than hundred and 80 days after the date of an act meant of this act, the Sec. of Transportation shall determine if certain unmanned aircra ft systems may operate safely in the national airspace system before completion of a plan in rulemaking required by section 332 of this act or the guidance required by section 334 of this act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the det ermination under subsection (a), the Secretary shall determine, at a minimum

--
(1) which type of unmanned aircraft systems, if any, as a result of the size, weight, speed, operational capability, proximity to airports in populated areas, and operation with in15 visual line of sight to not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified in the paragraph (1).

(c) Requirements for safe operation.

-- If the Secretary determines under this section that certain unmanned aircraft system s may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, MSI submits that the 3DR X8

- M UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 3DR X8

- M UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The specifications of the 3DR X8

- M UAS demonstrate safe operati ng characteristics.

The 3DR X8

- M UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed and operational capability.

i. Technical specifications of the 3DR X8

- M UAS.

T he technical specifications of the 3DR X8

- M as set forth at 3DR X8

- M v3 Specifications Page and the Operation Manual, attached hereto as exhibit s 1 and 2

. Exhibit s 1 and 2 contains proprietary information and is to be held in separate file pursuant to 14 CFR § 11.35 (b) 1

ii. The 3DR X8

- M UAS autonomous flight and navigation modes enable the UAS to remain within a defined operational area.

The 3DR X8

- M UAS may be operated in both semi

- autonomous and fully autonomous flight modes. The 3DR X8

- M UAS autonomou s features include the following: a GPS Position and Altitude Hold when the GCS controls are released to the neutral position; a Return To Home (RTH) function; and Flight Limits (i.e., preset limitations that restrict the distance and height of the UAS fli ght operations).

A complete description of the autonomous modes of the 3DR X8

- M UAS is provided at pages 7 through 8 of the 3DR X8

- M Operation Manual, attached hereto as exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 CFR § 11.35 (b).

iii. The 3DR X8

- M UAS is designed for automatic return to home point or auto land in the event of loss of navigation control.

A complete description of the failsafe functions of the 3DR X8

- M UAS is set forth in pages 1 1 through 13 of the 3DR X8

- M Operation Manual, attached hereto as exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 CFR § 11.35 (b).16 iv. The 3DR X8

- M GCS in its operation.

A complete description of th e operation and specifications of the 3DR X8

- M GCS and its software is provided on pages 7 through 19 of the 3DR X8

- M Operation manual. The 3DR X8

- M UAS is compliant with all Federal Communications Commission (FCC) requirements in the radiofrequency spect rum used for operation and control of
the UA as set forth on 3DR X8

- M v3 specifications page . A copy of the 3DR X8

- M v3 specifications page , which contains proprietary information, is attached hereto as exhibit A, and is held in a separate file pursuant to 14 CFR § 11.35 (b).

b. Flight operations of the 3DR X8

- M UAS are limited to the line of sight of the certified pilot in command with the safety observer.

MSI will utilize certified commercial pilots who possess a current and valid FAA
issued airman medical c ertificate to act as a Pilot In Command of the 3DR X8

- M UAS. Additionally, a safety observer will assist the pilots during flight operations.

c. Flights of the 3DR X8

- M UAS will be conducted pursuant to specific operating limitations.

In seeking this exemptio n, MSI proposes to commercially operate the 3DR X8

- M UAS for the special purpose of conducting aerial acquisitions within the NAS, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents, which is a four position rotorcraft with dual rotors and motors per position (eight total motors and rotors, a pictorial description is located on page 21 of the operation manual contained
herein exhibit A). With the total operating weight, battery included of 8.1 pounds, the aircraft is commercially named 3DR X8

- M . Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under thi s exemption will be limited to conducting operations for the purpose of aerial acquisitions.

3. The UA may not be flown at an indicated airspeed exceeding 30 KN

. 4. The UA must be operated at an altitude of no more than 200 feet above ground level (AGL), a s indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be
in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC
to be able to use human visi on unaided by any device other than corrective lenses, as specified on the
PIC's FAA issued airman medical certificate.

6. The use of first person view (FPV) by the PIC of visual observer (VO) is not permitted.

7. All operations must utilize a visual obser ver (VO). The VO may be used to satisfy the CLOS requirement as long as the PIC always maintains CLOS capability. The VO and the PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during the flight opera tions. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the17

flight. The PIC must ensure that the VO can perform the functions prescribed in the operating
documents.

8. The VO must not perform any o ther duties beyond assisting the PIC with seeing and avoiding other air traffic or ground

- based obstacles/obstructions and is not permitted to operate the camera or other
instruments.

9. The operating documents in the grant of exemption must be accessible during the UAS operations and made available to the administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption in the procedures outlined in the operating documents,
the conditions and lim itations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in their operating documents. The operator may update or revise their operating documents. It is the operator' s responsibility to track such revisions and present updated and revised documents to the administrator upon request. The operator must also present updated and revised documents if it petitions for extensions or amendment to the grant of exception. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to the grant of exemption. The FAA's UAS integration office (AFS

– 80) may be contacted if questio ns arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed until the UAS is found to be in a condition for safe flight. The ground control station must be included in the preflight inspection. All
maintenance and alterations m ust be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g. replacement of flight critical components), must undergo a functional test flight. T he PIC conducts the functional test flight must make an entry in the aircraft records.

12. The preflight inspection must account for all potential discrepancies, e. g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections and recordkeeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, in the signature of authorized person returning the UAS to
service.

15. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

16. The authorized person must make an entry in the aircraft records of the corrective action t aken against discrepancies discovered the twin inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third class medical certificate. The PIC must also meet the flight requirements specified in 14 CFR § 61.56 in an aircraft which the PIC is rated on his or her pilot certificate.18

18. The operator may not permit any PIC to operate unless the PIC meets the qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how th e UAS will be operated under the exemption, including evasive and emergency maneuvers, and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 CFR § 61.51 (b). The VO is also required to complete the operator's training requirements. A record of training must be documented and made available upon request of the administrator. Flights for the purpose of training the operators, PICs and VO's (training,

p roficiency, and experience building), are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience building flights, all persons not esse ntial for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1 . All operations must be conducted under visual meteorological conditions (VMC). Flights under Special Visual Flight Rules (SVFR) are not authorized.

20. The UA may not operate within five nautical miles of an airport reference point as denoted on a

curren t FAA

- published aeronautical chart unless a letter of agreement with the airports managers is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must b e made available to the administrator
upon request.

21. The UA may not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than three statute miles from the PIC.

22. If the UA loses communication or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating
documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergenci es in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly a normal cruising speed to the intended landing point and land
the UA wi th 20% battery power remaining.

25. The operator must obtain the Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a notice to airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with the airspace requirements in the ATO issued CAO including class of airspace, altit ude level and potential transponder requirements.

26. All aircraft operate in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47 and have identification number (N

– number) markings in accordance with 14 CFR part 45, subpart C. Markings must be large as practical.19

27. Before conducting operations, the radio frequency spectrum use for operation and control of the UAS must comply with Federal Communications Commission (FCC) or the appropriate governm ent oversight agency requirements.

28. The documents required under 14 CFR § 91.9 and 91.203 must be available to the PIC at the ground control station of the UAS any time the UAS is operating. These documents must be made available to
the administrator or any law enforcement official upon request.

29. The UA must remain clear of and yield the right

- of

- way to all manned aviation operations and
activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. The UA m ay not be operated over congested and densely populated areas.

32. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, VO, operator trainees or essential persons, vessels, vehicles, and struc tures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation ar ises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or:

1. b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehic les or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations near to the PIC, VO, operator trainees are essent ial persons do not present in undue hazard to those persons per § 91.119 (a).

33. All operations shall be conducted over private or controlled

– access property with permission from the land owner/controller or authorized representative. Permission from the landowner/controller or authorized representative will be obtained for each flight to be conducted.

34. Any incident, accident or flight operation that transgresses the lateral or vertical barriers of the operation area as defined by the applicable COA mus t be reported to the FAA's UAS integration office (AFS

– 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB we site: www.ntsb.gov

.

2

. Reasons why in exemption from requirements of section 61.113 (a) and (b) would not adversely affect safety.

Moran Surveying Incorporated submits that the equivalent level of safety established by section 61.113 (a) and (b) will be maintained because no PIC will be allowed to operate the 3DR X8

- M UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that they are able to safely operate the 3DR X8

- M UAS in a manner consistent with the exemption, including
evasive a nd emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles
and structures.20

All operations of the 3DR X8

- M UAS will be overseen and coordinated by Stephen F. Moran, PLS; owner and operator of MSI. Stephen F. Moran; If not t he PIC of the 3DR X8

- M UAS operations that MSI performs will be on

- site and will coordinate and oversee the planning phase of any 3DR X8

- M UAS operations. Additionally, if Stephen F. Moran is not the operator/PIC of the 3DR X8

- M , a licensed FAA
airman with at least a current class 3 medical certificate and with the requisite experience listed herein
will act as the PIC of the 3DR X8

- M UAS operations. Moran's extensive experience in the NAS and overseas as a military rotary wing and fixed wing aviator (see a ttached military qualifications and resume in appendix B ) greatly enhances and insures the safe operation of the 3DR X8

- M UAS for the commercial application of collecting aerial imagery.

In addition, with respect to Stephen F. Moran’s aerial qualification s; Stephen F. Moran will remain current in military and by extension civil air operations in the NAS with his participation in the National Guard as an Army aviator, instructor pilot and instrument flight examiner. Moran expects and is expected to be an ac tive National Guard aviator until the year 2021. If in the case Moran decides prior to 2021 to give up his status as a military National Guard aviator, instructor pilot and instrument flight examiner by retiring from active participation in Army National G uard aviation, he will keep current and abreast of all of the changes to the FAR’s with regard to UAS and other air operations by subscribing and attending the aviation industry's continuing education programs. Moran will also maintain his commercial pilot ’s licenses and keep current his FAA medical qualifications. Examples of industry specific information sites include the following: Know Before You Fly, which was formed in association with the Association For Unmanned Vehicles International (AUVSI), Acade my Of Model Aeronautics (AMA), and the Small UAV Coalition in partnership with the Federal Aviation Administration (FAA) (as stated on ww.knowbeforeyoufly.org ). These associations in addition to the FAA saf ety team and their Safer Skies Through Education website: www.faasafety.gov are but a few of the safety references and guidelines that will be incorporated into the commercial acquisition of aerial data with the us e of the 3DR X8

- M UAS by Moran Surveying Incorporated.

The operation of UAS in commercial applications has been the subject of multiple grants of exemption from section 61.113 (a) and (b) Private pilot privileges and limitations: Pilot in command

. Additio nally, the FAA has previously granted relief from section 61.113 (a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161, 11170, 11171, 11172).

If in the case where Stephen F. Moran, PLS is not the PIC of the 3DR X8 + UAS operations, the following restriction will apply: Moran Surveying Incorporated will no t allow any PIC to operate the 3DR
X8

- M unless that PIC has demonstrated, by meeting minimum flight hour requirements and the 3DR X8

- M UAS training and currency requirements, that the PIC is able to safely operate the 3DR X8

- M UAS in a
manner consistent wi th this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 25 hou rs of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot
with multi

- rotor UAS (with a minimum of five hours of those hours as a UAS Pilot operating the same make and model of UAS to be used for operations under this exem ption). In addition to the hour requirements, the PIC must accomplish three takeoffs and landings in the preceding 90 days (for currency purposes).21

As in exemption numbers 11062, 11138, and 11153, prior documented flight experience that
was obtained in co mpliance with applicable regulations will ensure an equivalent level of safety during MSI's proposed operations. The administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure saf e operations, stating as follows:

In exemption number 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CF R § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS Pilot with multirotor UAS. Prior to operations under exemption number 11062, the PIC must have accumulated and logged a minimum of five
hours as a U AS Pilot operating the same make and model of UAS to be useful operations under the exemption. For clarification the FAA considers these minimum requirements to be inclusive rather than additive; i.e. five hours make and model time may be included in the 1 0 hours of multirotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the requirements the PIC must accomplish three takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds th at a minimum, the flight hour requirements in exemption number 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experienc e that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119. Exemption number 11138 at page
15.

Accordingly, MSI will ensure safe operations by not allowing any PIC to ope rate the 3DR X8

- M UAS unless that PIC has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to safely operate the 3DR X8

- M UAS in a manner consistent with the exemption, including evasive and emergency maneuvers a nd maintaining appropriate distances from people, vessels, vehicles
and structures.

3. Reasons why an exemption from the requirements of section 91.7 (a) would not adversely affect safety.

The equivalent level of safety established by section 91.7 (a) wi ll be maintained because prior to every flight, MSI will ensure that the 3DR X8

- M UAS is in an airworthy condition based upon the 3DR X8

- M UA’s compliance with operating documents (e.g. the 3DR X8

- M user manual, the 3DR X8

- M Pre

- flight
Checks , the 3DR X8

- M Takeoff Checklist , and the flight battery & powering sections of said manual ), and
as stated in the conditions and limitations herein.

UAS’s similar in construction, operation, and their proposed operating circumstances which are similar, in all material respects to the 3DR X8

- M UAS have been subject to multiple grants of exemption from section 91.7 (a) (exemption numbers 11153, 11157). Additionally, the FAA has previously granted relief from sections 91.7 (a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. exemption numbers 11062, 11063, 11064, 11065, 11066, 11067, 11080, 1109, 11110, 1112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).22

4. Reas ons why an exemption for the requirements of section 91.121 would not adversely affect safety.

Equivalent level of safety established in section 91.7 (a) will be maintained because prior to every flight, MSI will ensure that the 3DR X8

- M UAS is in an airw orthy condition based upon the 3DR X8

- M UAS's compliance with its operating documents (e.g. 3DR X8

- M user manual, the 3DR X8

- M Pre

- flight Checks, the 3DR X8

- M Takeoff Checklist, and the flight battery & powering sections of said manual ).23 

## CONCLUSION

Moran Surveying Incorporated (MSI) seeks exemption from the requirements of 14 CFR section 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an unmanned aircraft system pursuant to section 333 of th e FAA modernization and Reform Act of 2012 (FMRA).

The petitioner believes that in granting the exemption, the Administrator would be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also benefiting the public in several ways. It is also the petitioner s belief that he his well

- qualified and has the requisite experienced i n aviation operation s in the National Airspace to accomplish safe and effici ent aerial mapping with the use UAS. Further the p etitioner believes that MSI s hould be given the opportunity t o prove that it can play a key role in advancing the use of AUS in the small business envi ronment

The efficient acquisition of accurate geodetic information from Moran’s aerial drone surveys would enable communities to make more informed decisions with regard to land planning and community development.

Moran’s work will differ from other aerial information in that it will be tied to local mapping systems. These ties will be made utilizing sub

- centimeter Global Positioning equipment as well other tradition land surveying equipment . This equipment will be used in the first stage of any aeri al survey to create base lines which Moran will use to adjust survey work so that the final product will be accurate to within 3 cm horizontally.

The general public would glean knowledge on the safe and efficient operation of an UAS in the performance of a small commercial business enterprise.

Furthering the economic development of small businesses, helping them compete in a rapidly changing business and regulatory climate.

This last fact is the overriding benefit to the FAA and subsequently the general pub lic.24 

## APPENDICES See separate (PDF) attachment

Stephen F. Moran Resume

Stephen F. Moran military flight hours DD759

Stephen F. Moran Rotary W i ng com mercial pilot’s license

Stephen F. Moran Professional Land Survey ors license

Technical Specs

Operating Guides, 3DR X8

- M Operation Manual

Examples of MSI traditional aerial survey work