December 15, 2015 

CON•AGG -- OFMISSOURI -

2604 N. Stadium Blvd. 

Columbia, Missouri 6S202-1271 

Telephone: 573-446·0905 

U. S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of 

the Federal Aviation Regulations. 

Petitioner: 

Con-Agg of MO LLC. 

2604 N. Stadium Blvd. 

Columbia, Missouri 65202-1271 

Telephone: 573-446-0905 

Con-Agg of MO is an aggregates producer in Central and northwest Missouri. Con-Agg of MO 

intends to incorporate the use of sUASs for a variety of projects which may include but not be 

limited to aerial surveying; aerial mapping; project and construction management, inspections 

and monitoring; environmental review projects; agricultural projects; educational and research 

projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, 

photography and real estate purposes; search and rescue, etc. 

Specific Section(s) seeking exemption: 

14 C.F.R Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 
CON•AGG -- OFMISSOURI -

2604 N. Stadium Blvd. 

Columbia, Missouri 65202-1271 

Telephone: 573-446-0905 

U. S. Department of Transportation 

Docket Management System 

December 15, 2015 

Page Two 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Extend of relief requested: 

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

Said exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, 

Norris Quarries would conduct commercial operations of sUASs meeting or exceeding all 

operational and safety requirements per Section 333. 

Public/Safety Benefits: 

1. Project and Quarry management, inspections and monitoring. The use of sUASs on 

quarry sites may improve the safety of workers, local residents and general public by 

assessing potential dangerous situations. Falls and injuries may be reduced or 

eliminated through a more thorough review of the mine sites. In some cases, sUASs 

may reduce the reliance of helicopters or small aircraft to monitor said sites. This may 

improve safety as well as reduce environmental impact by reducing energy usage; 

2. Environmental Review projects. The use of sUASs during the process of reviewing 

projects as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth 

Environmental Review of the project site as well as surrounding areas; 

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas 

may eliminate the use of helicopters or aircraft. This could provide a more cost 

effective, safer and more energy efficient product; 

4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with 

surveying agricultural projects as well as wildlife and forestry projects by providing 

information when problems occur, vermin infestation, fire hazards, etc.; 
CON•AGG -- OFMISSOURI --

2604 N. Stadium Blvd. 

Columbia, Missouri 65202-1271 

Telephone: 573·446-0905 

U.S. Department of Transportation 

Docket Management System 

December 15, 2015 

Page Three 

5. Remote Sensing projects. The use of sUASs could provide views and information for 

remote and inaccessible areas. This could promote worker safety as well as reduce the 

reliance on helicopters and aircraft; 

6. Educational and Research projects. The use of sUASs could provide information for said 

projects in a more cost effective and efficient manner than other available options; 

7. Aerial filmmaking, photography and real estate purposes. The use of sUASs may provide 

a point of view previously unavailable through other means. They would be more cost 

effective, efficient and more safely than helicopters and aircraft; and 

8. Search and rescue. The use of sUASs may provide assistance to local law organizations 

during search and rescue missions. SUASs may reach areas unattainable or viewable 

with helicopters and aircraft. SUASs may be implemented quicker as time is of the 

essence during search and rescue operations. 

Reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to the existing rule. 

Proposed operations using sUASs provide increased safety enhancement especially when 

compared with helicopters and aircraft for the following reasons: 

1. The sUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight 

times may be less than thirty (30) minutes as the UAS will continuously monitor battery 

reserve and return to the ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet 

AGL which will be predetermined in the flight planning software. As well, this current 

altitude is visible on the controller at all times; 

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said sUAS; 

7. Verbal/written consent will be required of all persons within 100 feet of flight operation; 

8. Flights shall occur on company owned or leased property only, if the need to operate 

sUAS outside of company property should occur written and/or oral permission from 

relative property owners will be obtained prior to operating the sUAS; 

9. All permits, permissions, etc. will be obtained from local government offices as required; 

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); and 
I' -.. 

-- OFMISSOURI -

2604 N. Stadium Blvd. 

Columbia, Missouri 65202-1271 

Telephone: 573-446-0905 

U.S. Department of Transportation 

Docket Management System 

December 15, 2015 

Page Four 

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move 

vertically and horizontally; 

12. The sUAS will be operated through the use of the Tower software which allows for flight 

planning by setting the security perimeters in which the sUAS will be required to fly. 

13. The sUAS will have the capability to return and land at the pre-determined location with 

the Security Perimeters should the sUAS lose communication or GPS signal during any 

operations; 

14. The sUAS PIC will have the capability to abort a manual flight as well as an automated 

flight in case of unpredicted obstacles or emergencies, as well a manual override is 

available in the instance of an automated flight; 

15. Operations will not be conducted over densely populated areas or heavily traffic 

highways; and 

16. Operations will not be conducted within five (5) NM of an airport or heliport unless 

given prior permission from said airport/heliports. 

Equipment and Specifications. 

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

Specifications: 

Up to 26 minutes of flight time (20 with camera and Solo Gimbal), 

HD video streaming to mobile 

Top speed: 55 mph 

Max Altitude: 400ft, per FAA rules 

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro 

Wi-Fi range: up to a half a mile, depending on environment 

Controller with color screen and live flight data 

Pixhawk 2 flight controller software 

Customizable color LEOs for orientation 

Solo Battery: 14.8 V LiPo (5200mAh) 

Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available) 

10x4.5 self-tightening props 

880 kV motors 

Plug and play with 3-axis Solo Gimbal from 3DR 
.. 

" CON•AGG - OFMISSOURI -

2604 N. Stadium Blvd. 

Columbia, Missouri 65202-1271 

Telephone: 573-446-0905 

U. S. Department of Transportation 

Docket Management System 

December 15, 2015 

Page Five 

Conclusion: 

Con-Agg of Missouri, LLC is a company owned by Summit Materials. We are engaged in the 

production of aggregates, redi-mix and concrete. The 3DR Solo is safer than having Con-Agg 

employees out in the field for specific projects, and also very safe for other aircrafts because of 

the mission specifications (below 400ft.) and 3DR Solo integrated safety features. We are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level 

I 

of safety. We look forward to working with your office. Please feel free to contact our office 

should you have any additional questions or comments. 

Thank you for your cooperation with this matter. 

Sincerely, 

~ ~------- Alan Vassmer 

Construction Engineering Tech. 

Company Representative 

dAAj~ larry Steeby 

Mine Development