October 30, 2015

U.S. Department ofTransportation Docket Operations WestBuilding Ground Floor 1200NewJerseyAve, SE., Washington, D.C. 20590-0001 SURVEYING • ENGINEERING • CONSTRUCTION SERVICES Geospatial Services • LiDAR Services• GIS

RE: Exemption Request Section 333 ofthe FAAReform Act o£2012 and Part 11 ofthe Federal Aviation Regulations Dear SirorMadam; In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, Surveying Solutions, Inc. (SSI) requests exemption from the Federal Aviation Regulations to allow for commercial small Unmanned Aircraft Systems (sUAS) operations inperforming aerial data acquisition within the National Airspace System (NAS) for various industries and for compensation orhire. This exemption would allow SSI to collect data safely and more cost effectively than a traditional manned aircraft. SSI plans to operate sUAS's that are rotorcraft and fixed wing aircraft, each weighing less than 55 pounds (includingpayload), at speeds less than orequal to 50 knots, and at orbelow 200 feet AGL. The sUAS's are constructed out oflightweightmaterials such as carbon fiber, foam and/orplastic, do not carry flammable materials, and will be operatedby a highly qualified Pilot In Command (PIC). Given these operating limitations, SSI is confidentthat operations will not create a hazard to users ofthe (NAS) norto the public and that the operation guidelines herein meet the safetythat the Congress envisioned that the FAAmust, by exemption, allow commercial operation ofsUAS's. Wehave previously applied for an exceptionbut since the application has been filed we have purchased anotherUAS and are requesting an exception for this new UAS 1) DJI Inspire 1Pro This (Unmanned Aircraft) UA, is electricallypoweredpropeller systems, and controlled with transportable Ground Control stations. Itweighs less than 55 lbs with its maximum payload. The manuals for this UAS can be found at the following: http://www.dji.com/product/inspire-11 download 

# SUrveyingFOR TODAY... 

# SOlUtiOnS FOR THE FUTURE

...TM 4471 M-61, Standish, Michigan 48658 • tel 989-846-6601 • fax 989-846-6607 1000 S. US-27, St. Johns, Michigan 48879 • tel989-227-9212 • fax 989-224-2729 3734 Fortune Boulevard, Saginaw, Ml 48603• tel 989-798-0527 • fax 877-581-6645 www.ssi-mi.comPage 2 of8 This linkprovided above includes the following: Inspire 1Release Note Inspire 1Disclaimer & Warning Inspire 1 Quick Start Guide (EN) v1.4 Inspire 1User Manual (EN) v1.8 Inspire 1 Safety Guidelines vl.O Intelligent Flight Battery Safety Guidelines v1.4 Charging Hub for Inspire 1Intelligent Flight Batteries v1.0 Inspire 1 1345s Quick-Release Propellers Quick Start Guide 1345 Propeller Locks Quick Start Guide Inspire 1Maintenance Manual v1.0 Introduction: SSI has been in business for 15 years. Since the firm's inception in 2001 as a 3 person organization, SSI has grown to a firm with over 65 employees and four office locations in Michigan. SSI offers surveying, mapping, geospatial and engineering services to its clients. SSI services a wide range ofclientele in the public and private sectors. SSI continues to evolve to meet the needs ofits clientele and to stay competitive in its sector. The addition ofsUAS's to SSI's portfolio offerings helps ensure that SSI remains competitive in the future. SSI offers its services nationwide and to date has a portfolio ofwork encompassing most ofthe U.S. mainland including the State ofHawaii. For more information on SSI please visit our website www.ssimi.com for information about SSI.

Petitioner: Surveying Solutions Inc. 4471 M-61 Standish, MI 48658 Andrew W. Semenchuk, P.S. President Phone: (989) 846-6601 Email: semenchuk@ssi-mi.com Regulations from which the exemption is requested: 14 CFR 21, Part 21; 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 (b)(2) 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) Part 91 Subpart E (91-401-91.417)Page3 of8

14 CFR21, Subpart H: Air worthiness Certificates 14 CFR 91.203(a)(1)- Part 21 Subpart H establishes the requirements for the issuance ofan airworthiness certificate (FAR §91.203 (a) (1 ))., SSI requests relief from 14 CFRpart 21, Subpart H, pursuant to Section 333 given the size, operational capability, ,proximityto airports, VLOS operations with which SSI will operate the sUAS's will be achieved with the operational limitations established in this document (see Appendix B) for all flights conducted by SSI. All SSI flights will be conducted inthe VLOS ofthe PIC at an altitude of200 feet AFL or less and only over designated Limited Access Areas (LAA). This will ensure a safe operating environment without creating a hazard to other aircraft, people, or structures on the ground. TheUAS will carry neither pilot, passenger, explosive materials nor flammable liquids. 14 CFR 45.23 (b)- Even though the UAS will have no airworthiness certificate, an exemptionmaybe needed as the UAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" can beplaced. Given the size oftheUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafety will beprovided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot orpassengers. SSI requests a relieffrom theseregulations. Anypilot in command or (PIC) operating the UAS will hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will beutilized and required to communicate verbally at all times. The UAS will be limited to operations within visual distance ofboththe PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use ofa UAS are far less than similar commercial aircraft operations. 14 CFR91.7 (a)- Since the UAS will not carry a pilot orpassengers there will beno airworthiness certificate issued for the aircraft, should this exemptionbe granted, no FAAregulatory standard exists for determining airworthiness. Given the size ofthe aircraft, maintenance, and use ofsafety checklistpriorto each flight, an equivalent level ofsafety will be provided. All flights will be in accordance with the safety and maintenance recommendations bythe sUAS manufacturers. 14 CFR91.9 (b)(2)- Given the size and configuration, the UAS has no ability to carry a flight manual onthe aircraft. There is no room, capacity, orpilot onboard to adequately carry a flight manual. An equivalent level ofsafety will bemaintainedbykeeping the flight manual at the ground station where the sUAS'spilot will have immediate access to it. 14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will beprovided for the aircraft an exemption is needed. Alternateprocedures including butnot limited to reviewing weather conditions, checking flight batteryrequirements, checkingtakeoffand landing distances along with those found in the attached Appendix "A" will be implemented. These actions will provide an equivalent orhigher level ofsafety. 14 CFR91.109- sUAS's and remotelypiloted aircraft do not have fully functional dual controls. Flight control is achieved through the use ofa control box that communicates with the aircraft viaradio communications. An equivalent level ofsafety will be achieved using the real time ground station data and given the sUAS's will carryneither a pilot orpassengers. 14 CFR91.119 (c)- The sUAS's will neverbe operated at an altitude higherthan 400 feet AGL. The UAS will operate in safe areas away from public and traffic and only withpermission ofthe property and structure owners. The sUAS's will also berestrictedbythe flight controllerto a maximum vertical height of400 feetPage 4 of8 AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed ofthe UAS, an equivalent orhigherlevel ofsafety will be achieved. 14 CFR 91.121- As the sUAS's maynot have a barometric altimeter, but instead a GPS barometric sensor for altitude information an exemption mayberequired. An equivalent level ofsafetywill be achievedusing a ground station which links to a telemetry data link. This will provide thepilot with live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicatorprior to flight. 14 CFR91.151 (a)- The sUAS's have a limited range. Thebatterypowerthe UAS provides approximately 30 minutes offlight time. The sUAS's is unable to meet the 30-minute reserve requirement and therefore requires an exemption. An Equivalent level ofsafetywill be achievedbymonitoring the batterythrough the ground station and landing with a minimum of20 percentbatterypowerremaining (as determined bythe onboard monitoring system and the PIC). Such an operation guideline will ensure that the sUASs will have plentyofbatteryto returnto the launch site safely; however, one major advantage ofa sUAS is that unlike manned aircraft it can easily and safely land anywhere over a Limited Access Areas in which its operations are limited to. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745,10673, and 10808. 14 CFR91.203 (a) & (b)- Given the size and configuration, the sUAS's have no ability to carry a flight manual onthe aircraft. There is no room, capacity, orpilot onboard to adequately carry a flight manual. An equivalent level ofsafety will be maintained bykeepingthe flight manual at the ground station where the sUAS pilot will have immediate access to it. Given the following sections only apply to aircraft with an airworthiness certificate these sections do not apply to this applicant. As a safetyprecaution, the operator will performpreflight inspections and ensure UAS is in working conditionbefore initiating each flight: Part 91 Subpart E (91.401-91.417): Maintenance, Preventative Maintenance and Alterations Theseregulations outline the requirements for maintenance and inspections in reference to Part 39 and Part 43. 91.405 (a), which states that "no person mayperform maintenance, preventivemaintenance, and alterations on an aircraft otherthan as prescribed inthis subpart and other applicable regulations, including part43 ofthis chapter." Since these sections apply to only aircraft with an airworthiness certificate, for which SSI has applied for exemption, SSI also seeks full exemption from these regulations. Priorto any flight, the PIC will beresponsible for conductingpre-flight inspections and will following all inspection requirements specified bythe manufacturer ofthe utilized sUAS. Further details can be found in Appendix A. Preventative maintenance and corrective maintenance will be conductedbythe manufacture ifso stated by the manufactures' guidelines. However, in instances that the manufacture does notrequire maintenance to be performedbythe manufacturer, then the PIC will beresponsible for conducting maintenance in accordance with the manufactures procedures and all maintenanceperformedbythe PIC and/ormanufacturerwill be documented in accordance with 91.407 (a) (1). Specifically, records will include "adescription ofthe work performed; and the date ofcompletion ofthe workperformed; and the signature oftheperson approving the aircraft for returnto service." Further, SSI will ensure that no modifications or alterations are made to the airframe that affects the flight operating characteristics ofthe sUAS. These proposals are considered to be an equivalent level ofsafety since these sUAS's are very limited in size and will carry a small payload and operate onlyinrestricted areas for limitedperiods oftime. In the event that mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 200 feet AGL.Page 5 of8 

### EquivalentLevel ofSafety In addition to the safety standards mentioned above the sUAS's will adhere to the following additional guidelines: 1) The sUAS's will not be operated within 5 miles ofan airport unless prior contact to Air Traffic Control has been established. 2) Flights will not exceed the an airspeed of 50 Knots 3) Flights will be operated at orbelow an altitude never exceeding 200 feet AGL. 4) The PIC and VO will communicate verbally at all times. 5) UAS operations will not be conducted during night. 6) All operations will be conducted under visual meteorological conditions. 7) The UAS will land with a minimum 20 percent batteryreserve remaining. 8) The UAS will onlybepiloted within visual line ofsight. 9) The UAS will utilize an internal flight safety feature that will return to a preprogrammedposition and land ifcommunicationwith the remote control is lost. 1

0) Preflight inspections and protocol will be followed priorto all operations. 11)The UAS will abort flight in the event ofunpredictable obstacles or emergencies. 

### Benefits to the Public Approval ofthe above exemptions and commercial operation ofsUASsby SSI will benefit the public in the following four ways. 1) The commercial use ofsUASs to acquire aerial data will reduce the need for manned aircraft operating in the NAS. With the skies ofAmericabecomingbusier and Air Traffic Control (ATC) workloads overburdened, the use ofsUASs will offer some reliefto ATC since coordination during ground, takeoff, departure, transit, arrival, and landing phases offlights is not necessary. 2) Reduced manned aircraft will reduce air and noise pollution. Since all sUASs operatedby SSI will be lightweight and batterypowered, these sUASs electric motors operate much quieter than manned aircraft and do not bum fossil fuels. Typically, aerial photography is capturedbytwin engine fixed wing aircrafts that bumbetween 20 to 30 gallons offuel perhour and can require significant travel timebefore reaching the intended area ofinterest. However, acquiring aerial data with sUASs can takeoffand land on site and would greatlyreduce both air pollution and noise pollution which is of great benefit to the public. 3) Operating sUASs for the purpose ofaerial data collection also reduces the risk to life and property on the ground. When compared to a twin engine airplanes, sUASs' size, weight, slow speed, and lack of flammable liquids are considerably less dangerous to people and/or structures on the ground. 4) Operations ofsUASs offer an effective, affordable, and safe method to acquire aerial data to many business. Data generated from sUAS flights can help construction sites monitorprogress, plan and design future improvements/work, and aid in site surveys inboth two-dimensional maps and threedimensional terrain models. Further, farmers and scientists can use this aerial data to estimate biomass, yield monitoring, leafarea indexing, and overall crop health. In all, this data will provide the information necessary for businesses oftoday to thrive in the future and thus inthe publics' interest.Page 6of8
Respectfully,

President



### APPENDIX APPENDIX A: Pre-flight protocol This section is divided into two areas: 1) 24 hours priorto flight 2) Pre-flight inspection checklist. 24 hours prior to flight: • Prior to a sUAS flight, an area ofoperation will be established. This area ofoperation will include a defined lateral and vertical area, where the sUAS will operate. Safetyprocedures will be established for persons, property, and applicable airspace within the area ofoperation. • Flights will be operated within line ofsight ofthe PIC. • The sUAS will weigh less than 55 lbs total. • Flights will be operated in Class G airspace wheneverpossible. lfoperation in other airspace is required, the relevant controlling agency will be notified at least 24 hours prior to the .operation and, ifrequired, any necessarypermission obtained. • Flight planning will include flight completion with at least 20% batterypowerremaining as measuredbythe sUAS or appropriate timing. • Ifequipped, and appropriate for the operation, sUAS aircraft will utilize GPS navigation, failsafe, return-to-home (RTH) and/or flight abort safety features. • A briefing will be conducted in regard to the planned sUAS operations priorto operation at each new location. All personnel who will beperforming duties within the boundaries ofthe area ofoperation will bepresent for this briefing. Therefore, images taken will be of individuals who have also consented to beingphotographed or otherwise have agreed to be in the area where aerial photography will take place. • All required permissions and permits will be obtained from appropriate state, county or city jurisdictions, including local law enforcement, fire, or others appropriate governmental agencies. • Written, to include electronic, and/or oral permission from the relevant property owners will be obtained prior to an operation. • All employees working onsite will be thoroughly briefed on sUAS operations prior to operations commencing Pre-flight inspection checklist Thepre-flight checklist/inspection will follow the specific pattern and sequencebefore each flight. 1) Ground station setup: a) Place the "EXPERIMENTAL" flag near the area ofPICPage 7of8 b) Visually scan the area ofoperation for any unforeseen hazards, persons, orinfrastructure c) Check that all relevant documents are on site and within easy access. These include: i) PIC's pilot license ii) Proofofcompany's FAA exemptions iii) sUAS manufacturer's flight manual iv) All maintenance records 2) Pre-start sUAS inspection checklist a) Check to ensure the sUAS power is "OFF" b) Battery i) Check sUAS batter is fully charged ii) Check the hand-held controller's battery is fully charged c) Visually inspect the following i) All propellerblades are free ofdamages ii) All propellerblades are securely attached to the sUAS iii) All surfaces are free from damages iv) Antenna is undamaged 3) Pre-flight inspection checklist a) Tum on the controller and sUAS battery i) Ensure that all available system read-outs are clearly displayed onthe controller and within normal range ii) Test the functionality and free movement of: (1) Propulsionblade(s) (2) Ailerons (ifapplicable) (3) Check the GPS altitude reading ofthe sUAS is within range ofa separatehand held barometer. b) Test flight i) Prior to flying the sUAS for commercial purposes, the aircraftmust successfully demonstrate a successful flight ofapproximately one minute in duration, in a small area free from any hazards, persons, and property and at an elevation at orbelow 10 feet AGL. APPENDIX B: Flight protocol Safety is paramount for SSI. Therefore, the following outlines the limitations and conditions which will govern all commercial operations conductedbythe SSI PIC in lieu ofthe approved FAA exemptions and all aircraft will be limited to the specifications ofAppendix D.

• The sUAS will be less than 55 pounds (includingpayload) • All sUAS flights will be piloted by an FAA licensed airman with at least a Private Pilot certificate and who will have completed the training outlined in Appendix C. • The sUAS FAA licensed airman will be considered Pilot in Command (PIC), whether flying or supervising, and will beresponsible for safe operation ofthe flight. • The sUAS will operate at orbelow 200 feet AGL • No flight will be conducted ifwind speeds are in excess of20 mph. • The sUAS will operate within 1NM and within visual line ofsight (VLOS) ofthe PIC • The duration ofeach flight shall not exceed 20% ofthe sUAS battery's power or a maximum total flight time of30 minutes, whichever occurs first. • All takeoffand landings will occur onsite in accordance with the specifications ofthe sUAS manufacture's User Manual • Flights will avoid direct overflight ofany office ormaintenance buildings located onsitePage8of8

• Flights will be cancelled in the event that any aircraft orground control station equipment is inoperative ornot fully functional • Flights willbe operated under visibility and cloud clearance requirements equivalent to • Visual Flight Rules (VFR) and only in Visual Meteorological Conditions during daylight hours • Ifthe PIC identify a potential hazard, such as a manned aircraft within close proximity to the designated flight area, the PIC will immediately land the sUAS and operations will onlyresume after the hazard is clear ofthe area • Onlyone sUAS will be airborne at any giventime over a specific site, and at least 2NM away from anyother sUAS operation. • Minimum crew for each operation will consist ofthe sUAS PIC. An observeris not specified since all operations will belimited to visual line ofsight (VLOS) operations and that the recentproposals of the 'Operation and Certification ofSmall unmanned Aircraft Systems' (RIN: 2120-AJ60, Federal RegisterNumber: 2015-03544) does notrequire such an observer. However, ifthe FAA decides in this exemptionrequest, orin future regulations that a flight observeris necessary, than SSI will comply. • The sUAS PIC will establish a working relationship with a representative at the local FSDO with which to annuallyreview safetyprocedures and otheroperations to further enhance safety. • All operations will beconfined to a Limited Access Area (LAA), which are areas that are sparse in population and/orwhere access is limited to personnel withjobsite clearance. This will ensure that all persons nearthe sUAS operations will begiven an operations and safetybriefing oftheplanned sUAS operations and/or SSI can effectivelyprohibit persons from entering the flight perimeter boundaries during the flight operations. APPENDIX C: Pilot training protocol With safety the highest priority, proper sUAS flight training is imperative. While SSI seeks highly qualified pilots who have extensive knowledge within the NAS, operations ofsUAS are unique to manned aircraft as well as to other types ofsUAS. Therefore, the following pilot training is required in addition to at least a Sport Pilots Certificate. • The PIC must possess a Sport Pilot's Certificate • The PIC must have accumulated and logged a minimum offive hours as UAS pilot with the make and model ofUAS to beutilized for operations under the exemption and three takeoffs and landings in the preceding 90 days. • The PIC will be trained in advance for the safe operation ofthe sUAS to be operated. This will include operation ofthe sUAS both in normal and emergencymodes ofoperation, and will include familiarization with the operation manual (or similar) ifpublishedbythe sUAS manufacturer. Training will also include types ofmaneuvers to beperformed and the safe operation in relation to persons, property and applicable airspace. • Further, thePIC musthave also satisfied any additional qualifications/training/experiencethat are required bythe sUASs manufacturer (i.e. flight operations and procedures manual).

APPENDIX D: Utilized aircraft At this time, SSI owns the DJI Inspire 1 and is looking at purchasing the sUASs that we previously applied an exemption for. SSI is waiting to fly this sUAS for commercial operation one an exemption is granted.