1523 Kinnaird Ter NE, Leesburg, VA 20176

(T) 571-309-7995 * WWW.NAVIGATORCS.COM

NAVIGATOR CS, LLC 

Chart a Course to Project Success

November 11, 2015 

U. S. Department of Transportation 

Docket Management System 

Washington, DC 20590 

Re: Request to Amend Exemption No. 11658, FAA Docket No. FAA-2015-0546, to Add UAS and 

Expand Intended Uses

Dear Sir or Madam: 

Pursuant to 14 Code of Federal Regulations (14 CFR) part 11 and Section 333 of the Federal Aviation 

Administration (FAA) Modernization and Reform Act of 2012 (Public Law 112-95), Navigator CS, LLC 

(“Navigator”) hereby requests that our Exemption No. 11658 (FAA Docket No. FAA-2015-0546) granted 

on May 22, 2015, be amended as follows:

A. Expand Intended Uses to include precision agriculture, mapping, and GIS applications, including 

but not limited to 3D modeling of natural and man-made structures and development of point 

clouds.

B. Revise Condition and Limitation No. 1 to add the following Unmanned Aircraft Systems (UAS):

1) DJI Innovation’s Phantom 3 Series and Matrice 100

2) Ascending Technology’s Falcon 8

3) senseFly SA’s eBee Ag and RTK

4) senseFly SA’s eXom

Navigator seeks relief from the same regulations for which relief was granted under Exemption No. 11658

and is committed to carrying the expanded operations and to operate the additional UAS with the same 

level of safety that it has exercised under its current Exemption. 

Navigator will continue to ensure that its UAS operations do not create a hazard to the users of the national 

airspace or the public, or pose a threat to national security. Navigator’s operations will ensure privacy, as 

they will continue to take place over private or controlled access property with the prior consent and 

knowledge of the property owner and/or the authority having jurisdiction. Images taken will be of 

individuals who have consented to being filmed or otherwise have agreed to be in the area where

aerial imagery will take place. Navigator UAS operations will continue to be of benefit to the public. 

A. Petitioner

The name of the petitioner is:

Navigator CS, LLC

1523 Kinnaird Ter NE 

Leesburg, VA 20176
Navigator CS, LLC - Petition to Amend Exemption No. 11658 to Add UAS and Expand Intended Uses 2

Point of Contact: Gladys M. Miller, M.S., M.B.A., P.M.P

Sr. Project Engineer

Phone No.: 703-568-7780

Email: gmiller@navigatorcs.com

B. Request to Amend Intended Uses

Navigator’s current Exemption allows it to operate the Inspire 1 to “conduct aerial imaging in support of 

engineering surveys of construction sites, existing buildings and facilities, and other sites, for the 

purpose of monitoring and ensuring site safety, proper material usage, quality of workmanship, and/or 

to inspect the integrity of buildings and/or structures, including bridges and dams.”

Navigator requests that the intended uses listed on Exemption No. 11658 be amended to add precision 

agriculture, mapping, and GIS applications, including but not limited to 3D modeling of natural and manmade structures and development of point clouds. The FAA has found these intended uses to be in the 

public interest, as demonstrated in Exemptions Nos. 11136, 11166 and 13402 (precision agriculture); and 

Exemption Nos. 12064, 12609, and 13140 (mapping and GIS applications).

As this request is an amendment to an existing exemption asking for the addition of intended uses that have 

already been approved by the FAA and found by same to be in the public interest, Navigator respectfully 

submits that good cause exists so that notice does not need to be published in the Federal Register for this 

requested amendment.

C. Request to amend Condition and Limitation No.1 to add other UAS

Condition and Limitation No. 1 of Navigator’s Exemption No. 11658 states the following: 

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this exemption.

Navigator requests that the above referenced Condition and Limitation be revised to include, in addition to 

the Inspire 1, the UAS listed on Table 1. The Column titled “Associated Exemptions” contains exemptions 

that the FAA has granted, which allow the use of the respective UAS for civil operations.

Table 1: UAS to be added to Navigator’s Exemption No. 11658

Model Manufacturer Type Max. 

Airspeed

Max. Takeoff 

Weight Associated Exemptions

Phantom 3

Series DJI Innovations Quadcopter 31.1 knots (35.8 mph) 2.83 lb 11172A, 12711, 12646, 12744, 12700, 12706

Matrice 100 DJI Innovations Quadcopter 33 knots

(38 mph) 7.5 lb 12378A, 12697

Falcon 8 Ascending 

Technology Octocopter 31.1 knots (35.8 mph) 5.1 lb 11208, 12646

eBee Ag senseFly SA Fixed Wing 48.6 knots

(55.9 mph) 1.56 lb 11136, 11167

eBee RTK senseFly SA Fixed Wing 48.6 knots

(55.9 mph) 1.61 lb 11263, 12646, 12710

eXom senseFly SA Quadcopter 23.3 knots

(26.8 mph) 3.96 lb 11263A, 12646
Navigator CS, LLC - Petition to Amend Exemption No. 11658 to Add UAS and Expand Intended Uses 3

As shown on Table 1, all the UAS that Navigator wishes to add to its Exemption weigh less than 55 lbs and 

have a maximum airspeed well below the maximum allowable speed of 87 knots (100 miles per hour) 

prescribed by the FAA in Condition and Limitation No. 3 of Navigator’s Exemption. All the unmanned 

aircraft listed on Table 1 are battery-operated and have a PC-based ground control station and associated 

telecommunications equipment. Each aircraft carries an onboard geo-referenced camera that allows

Navigator to obtain aerial images and, in the case of the eBee Ag, precision photogrammetry and crop 

scouting at the resolutions necessary for precision agriculture. The data gathered by Navigator via these 

UAS will benefit the end users and will be in the public interest.

Because this request is an amendment to an existing exemption asking for only the addition of other types

of UAS, Navigator respectfully submits that good cause exists so that notice does not need to be published 

in the Federal Register for this requested amendment.

We trust that this petition is self-explanatory; however, should you have any questions or comments, 

or need further clarification, please do not hesitate to contact me by phone at (703)568-7780 or by email to gmiller@navigatorcs.com.

Very truly yours,

Gladys M. Miller

Gladys M. Miller, M.S., M.B.A., P.M.P.

Senior Project Engineer

703-568-7780

We are a Service Disabled Veteran Owned Small Business