MERIDIAN GROUP ofSouth Florida Inc. Surveying • Mapping •Planning • Construction Expediting

August 25, 2015 U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave. SE Washington, DC20590 Re: Request for Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations.

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. I**~** Pursuantto Section' 333 ot'the

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### A~t), and.14 C.P.R. Part 11, llyieridian Group ofSouth Florida, Inc. (MGSF), a Florida based company operating Small Unmanned

### Airc~aft Systerri (sUAS) equipped to conduct aerial photography and survey for various industries, hereby.applies for an exemption from the Federal Aviation Regulations (PARs) listed belowto allow operation ofour sUAS commercially in airspace regulated by the Federal Aviation Administration

. : ·' : (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by theFAA asrequired by Section 333. The requested exemption is similar to previous FAA issued grants of**exemp~i<iltUndudirtg** but not l·imited to Exemption Nos:; 11062·, 11109; '11112, 11213 and 11295. 

### Ourcommercialactivities wouldinclude: The requested exemption would permit Meridian Group ofSouthFlorida, Inc. to pursue its commercial interests in providing services to consumers interested in training, research, and aerial data capture using a small advanced sUAS in the following areas:

• Aerial Photography;and,Y,:ideography-for thereal estate, construction, and :utilitiesindustries ; • Agricultural Surveying and Applicatioh'

.. · • sUAS OperatorTraining .;'. • Product Demonstrations ' Research arid

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### ~cc~ss**prop~rty will** **d~** so withthe propertY,**ownpr'~** prior consent and knowledge. Only people who have consented or otherwisehave agreed to be in the area where photography and**~ideography** will take place will be captured in any photos or videos. Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954 . ''lAdditionally, all UAS Innovators pilots will hold an airline transport, commercial, private, recreational,or sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, a territory, a possession, or the Federal government. Ifan observer is not a qualified pilot, they will be trained by MGSF pilots to understandthe proper roles ofan observeF, communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections ofthe Aeronautical InformationManual. 

### ThePetitionerRequestsReliefFromthefollowingregulations: Regulations from which the exemption is requested: 14 CPR§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.215, 91.405(a), 91.407(a)(1), 91.409(a)(l) and (2), and 91.417(a) and (b), to the extent necessary to allow MGSF to operate a UAS to perform training, research, and aerial data collection. We are petitioning for exemption to enable MGSF to operate a series ofUAS platforms that have been previously approved by exemption. Namely: DJI Phantom 2 DJIPhantom 2 Vision DJI Phantom 2 Vision+ DJI Inspire DJI SlOOO DJI S900 Flamewheel 550 eBeeAG 3DRobotics IRIS+ RF-70 DJIPhantom 3Professional DJIPhantom 3 Advanced Trimble UX5 SenseFly-eBee RTK Exemption 11398 Exemption 11310 Exemption 11398 Exemption 11398 Exemption 11416 Exemption 11401 Exemption 11397 Exemption 11339 Exemption 11419 Exemption 11295 Exemption 12410 Exemption 12410 Exemption 12372 Exemption 12571

These sUAS all weigh less than 55 lbs, have a built- in capabilityto limit the height flown above the ground, to limit the radius ofthe distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function ofthe autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return to Home and will land safely. This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions. Copies ofall Operating Manuals for the individual models listed will be submitted on request.

Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954The above specifications meet standards listedbelow:



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### • • MGSF will only operate its sUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operator's manual. Such operations will insure that the sUAS will "not create a hazard to users ofthe national airspace system orthe public." MGSF will not operate sUAV within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless a letter ofagreement with that airport's management is obtained or otherwise permittedby a COA issued to MGSF. Maximum flight time for each operational flight will be 60 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 60 minutelimit. The sUAV will be programmed so that it will not be operated at an altitude ofno more than 400 feet AGL. Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer. The sUAS PIC's (Pilot in Command) will be an airline transport, commercial, private, recreational, or sport pilot ce1iificate and also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, a territory, a possession, or the Federal government. The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). The sUAS will operate at speeds ofno more than 55 knots. • Given the small size ofthe sUAS and the restricted sterile environment within which theywill operate, our sUAS operations adhere to the Reform Act's safetyrequirements. Additionally, the fact that the MGSF pilots hold FAA Pilot certificates demonstrates that they have a high regard to safe operations with an understanding ofPARs, pre-flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards

. Under the requested exemption, MGSF will ensure that all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background ii1formation such as charts, NOTAMS andAircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and SafeOperating Procedures. We respectfully request exemption under Section 333 to enable MGSF to operate safe, low-risk commercial sUAV operations for the activities stated. MGSF at all times will respect the space and privacy ofcitizens and property whilst keeping our skies safe. 

### Exemption Requests and Equivalent Level ofSafety MGSF requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAV System:

Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954

### 14 CFR 61.23 Medical Certificates The regulation provides that a person requires a first or second class medical to act as pilot inCommand ofan aircraft for compensation orhire. Our proposed operations require thatthe PIC must hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColombia; Puerto Rico, a territory, a possession, or the Federal government. Since the aircraft cannotcarry passengers or property, we feel we meetthe intent of61.23 even though the intent ofthis application is to conduct abusiness. 

### 14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations Theregulation provides that no person that holds a Recreational Pilot, SportPilot, orPrivate Pilot certificate may act as pilot in Command ofan aircraft for compensation orhire. Ourproposed operations require that the PIC must hold at least airline transpmi, commercial, private, recreational, or sportpilot certificate. Sincethe aircraft cannot carry passengers orproperty, we feel we meetthe intent of61.113 Subparagraph (b) even thoughthe intent ofthis application is to conduct a business. 

### 14 CFR 91.7 Civil Aircraft Airworthiness This Section prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplatedbythe PARs, this Regulation is inapplicable. 

### 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flighttests The regulation states that "No person may operate a civil aircraft that is being used for flightInstruction unless that aircraft has fully functioning dual controls." Training will be conductedby Aerial Opticswe have the ability to provide dual controls utilizing two Spektrumtransmitters with a wireless linkbetween the transmitters. One transmitter is designated the master transmitter and the other transmitteris designated as a slave. ThePIC instructor, utilizing the master transmitter, will be at all times beable assume control ofthe sUAS. 

### 14 CFR91.119Minimumsafe altitudes: General Theregulation states that over sparsely populated areas the aircraft cannotbe operated closer than 500feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would bephotography or survey ofpersons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown overproperty orpersons where permissionhas been obtained and careful pre-planned has beenperformed. The aircraft will be operated at a low altitude allowing, ifa powerunit fails, an emergency landing withoutundue hazard to persons orproperty onthe surface. Therefore we maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954

### 14 CFR 91.121 Altimeter settings Theregulationrequires that aircraft shall maintain cruising altitudes byreference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below400 feet AGL and will notneed to maintain cruising altitudes in orderto prevent conflict with other aircraft. AnAbove GroundLevel altimeter measurement above the takeoffpoint is transmitted via radio from the sUAS on-board computer to the display screen heldby the PIC, providing a constantly updated AGLreadout. 

### 14 CFR 91.151 Fuel requirements for flight in VFR conditions Theregulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for at least 30 minutes. We feel the intention ofthis paragraph is to provide an energyreserve as a safety bufferfor delays to landing. The sUAS are battery operated and the maximumduration offlight from a single battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Sincethe aircraft will never fly more than 112 NM from the point ofintended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request anexemptionto the word "fuel" and ask for an equivalent interpretation with the word "energy". We also requestexemptionfrom the 30 minreserve and ask that ourreserve will be to fly the mission to the point ofintended landing and have at least a 20% battery reserve afterthat. 

### 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment anduse: This regulation states all aircraft operating within 30 nautical miles ofclass A, B and C airspace mustbe equipped with automatic pressure altitude reporting equipment having a Mode C capabilitythat automaticallyreplies to Mode C interrogations. Dueto the small size and lifting capabilities ofourUASs we cannot carry a traditional transponder. All ofour operations will be under 250' ifwe areoperating within the 30mi reach ofa mode c vail. 

### 14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarilyresponsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" aftermaintenance and inspection. It is our intention that thePIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." ThePIC will ensure that the aircraft is in an airworthy conditionprior to every flight and in addition, conduct detailed inspections after everytwo hours offlight. Maintenance performedbythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections andupdating software and firmware for the on-board computer. All other maintenance will be performedby the manufactureror their designated repair facility. ThePIC will document workperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety.

Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954How this Request is to the Betterment ofourCommunity We believe that the use ofUAS to perform agricultural land imaging creates a benefit to the public.The ability to use an onboard geo-referenced still camera to collect high-resolution data that can be usedto increase crop production and reduce unnecessary chemical use will provide a less expensive andhealthier food supply to the public. The unmanned aircraft does not carry any persons or flammable liquids, reducing public exposure in the event ofan incident. Finally, the unmanned aircraft canbe launchedand recovered from the property which we have been contracted to image. The ability to avoidoverflying private and public properties provides the public with the benefit ofprivacy from aircraft flyingoverhead. Unmanned Aircraft Systems (sUAS) are also a feasible method to obtain information ofagricultural cropland to determine optimum inputs that result in cost savings to farmers, yield security, andreduce environmental impact ofexcess fertilizers and chemicals in the soil. 

### Request for Blanket COAApproval On March 24, 2015, the FAA announced that it has implemented a new policy ofgranting "blanket" CO As to applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of the FAAModernization and Reform Act of2012. The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in https://www.faa.gov/news/updates/?newsid=82245 upon approval ofUASI's exemption request. Sincerely,

Joseph E. Trott President Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954 (941) 766-0011

Meridian Group ofSouth Florida, Inc. 493 Barger Drive Unit A Port Charlotte, FL 33954 

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