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 FROM 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.com
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Table of Contents

Glossary of Abbreviations..........................................................................................................................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 Relief....................................................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/filing
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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 Station

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 Visual 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 Landing
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SUMMARY

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 the FAA modernization and Reform Act 

of 2012 (FMRA). 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 PETITIONER

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 Moran'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 Landing (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. Each 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, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the administration to operate the 3DR X8-M UAS within the National Airspace 
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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 considerations 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 preventative 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 checklists). Furthermore, only Original 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. 

Relief 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 this 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 require 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 documents (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 to 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-traffic 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 exemption:

A. Name And Address Of The Petitioner
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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:

Stephen 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 part:

(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 private 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 compensation 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 

aircraft, 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;
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(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 altimeter 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 exemption 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 shall 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) and 91.417 (b).
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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 periods 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 (including 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 performed; 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 current 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 prescribed 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 specified 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.
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(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 extent 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 command, 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 operations 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) the 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 PIC 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 herein, 

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 petition: (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., the 

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 on 
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the 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 from 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 fully 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 constrain 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 fly 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 sections 

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 preventative 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 checklists, 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.
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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 will 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 studies, 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 operation 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 perform 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 utilities). 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 

baseline 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 qualifications, 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 administration 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 examples 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 FEMA (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 limits 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.
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2. The public will benefit from decreased congestion of the NAS.

The 3DR X8-M UA serves as a safe, efficient, 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 number 

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 arriving 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 control 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 updated 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 cabin 

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 acquisitions, 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 manned 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 weight; 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 alternative 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 local 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 operated 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.
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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 

performance 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 turn 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 no 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 pursuant 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 that 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 associated 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 states 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 aircraft 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 determination 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 within 
15

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 systems 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 safely 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 operating 

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.

The technical specifications of the 3DR X8-M as set forth at 3DR X8-M v3 

Specifications Page and the Operation Manual, attached hereto as exhibits 1 and 2. 

Exhibits 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 autonomous 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 flight 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 11 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 the 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 spectrum 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 certificate 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 exemption, 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 this 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), as 

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 vision 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 observer (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 operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the duration of the 
17

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

documents.

8. The VO must not perform any other 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 limitations 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 questions 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 must 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. The 

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 taken 

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 the 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, 

proficiency, 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 essential 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 

current 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 be 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 emergencies 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 with 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, altitude 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 government 

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 may 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 structures 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 arises 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, vehicles 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 essential 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 must 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 wesite: 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 and 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 the 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 attached 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 qualifications; 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 active 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 Guard 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), Academy 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 safety 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 use 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. 

Additionally, 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 not 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 with 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 hours 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 exemption). 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 compliance 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 safe 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 CFR § 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 UAS 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 10 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 that 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 experience 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 operate 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 and 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) will 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. Reasons 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 airworthy 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 the 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 petitioners belief that he his well-qualified and has the requisite 

experienced in aviation operations in the National Airspace to accomplish safe and efficient aerial

mapping with the use UAS. Further the petitioner believes that MSI should be given the opportunity to 

prove that it can play a key role in advancing the use of AUS in the small business environment

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 aerial 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 public. 
24

APPENDICES

See separate (PDF) attachment

Stephen F. Moran Resume

Stephen F. Moran military flight hours DD759

Stephen F. Moran Rotary Wing commercial pilot’s license

Stephen F. Moran Professional Land Surveyors license

Technical Specs

Operating Guides, 3DR X8-M Operation Manual

Examples of MSI traditional aerial survey work