April 24, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam:

REQUEST 

McKim & Creed, Inc. (McKim & Creed) seeks exemption to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA). from the requirements of 14 C.F.R. 

61.113(a) & (b), 

91.7(a), 

91.121, 

91.151(a)(1), 

91.405(a), 

91.407(a)(1), 

91.409(a)(1) & (a)(2), and 

91.417(a)& (b), 

This exemption will permit McKim & Creed to commercially operate three (3) 

Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial 

acquisitions within the National Airspace System (NAS) for compensation or 

hire. 

INTRODUCTION 

McKim & Creed’s three-plus decades in business have been marked by one 

constant, and that is change. As a consultancy offering a full range of 

engineering, surveying, landscape architectural and planning services, we have 

continuously reinvented ourselves to meet the ever-changing needs of our 
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customers and our marketplace. We have repositioned the business from a twoperson structural design firm to a 360 person infrastructure design company 

with offices from North Carolina to Florida. 

McKim & Creed offers a full range of engineering, surveying, and planning 

services. Core competencies of the firm include water and wastewater planning 

and design, site/civil engineering, landscape architecture, structural engineering, 

GIS, and surveying specialties ranging from electronic data collection to 

hydrographic surveying, aerial photogrammetry, laser scanning and subsurface 

utility engineering. Engineering News-Record has named McKim & Creed one of 

the top 500 design firms and top 200 environmental firms in the U.S. Public 

Works magazine ranked McKim & Creed as one of the top AEC firms in the U.S., 

and Southeast Construction names the firm as the top surveying and mapping 

firm in the region. 

McKim & Creed operates offices in Wilmington, Raleigh, Charlotte, and 

Asheville, NC; Clearwater, Daytona Beach, DeLand, Fort Myers, Palm Coast, 

North Tampa, and Sarasota, FL.; Austin, Fort Worth, Houston, and San Antonio, 

TX; Norfolk, VA, and Atlanta and Lawrenceville, GA. 

McKim & Creed will use the 3drobotics Aero-M (Aero-M) fixed wing , the Steadi 

Drone Mavrik (Mavrik), and the DJI S900 (S900) rotoray wing systems to 

commercially provide professional geospatial services to clients associated with 

land use planning, mining, utilities to conduct inventories, mapping and 

inspection services, environmental planning and other geomatics applications. 

Use of the Aero-M, Mavrik, and S900 will provide McKim & Creed a suite of safe 

and efficient platforms to perform its business operations. 

AIRCRAFT 

McKim & Creed seeks an exemption to operate the Aero-M, Mavrik, and S900 for 

compensation or hire within the NAS. The Aero-M is a fixed wing UAS, and the 

Mavrik and S900 are rotory wing UAS, all are electrically powered propeller 

driven systems. Unmanned Aircraft (UA) with transportable Ground Control 

Stations (GCS). 

The Aero-M has a maximum gross weight of approximately 6.8 pounds, the 

Mavrik has a maximum gross weight of approximately 4.8 pounds, and the S900 

has a maximum gross weight of approximately 7.2 pounds. All three systems are 

equipped with propeller systems driven by a Lithium Polymer battery powered 

electric motor. 
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The Aero-M, Mavrik, and S900 will be registered in accordance with 49 U.S.C. 

44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft Registration, 

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking. 

BASIS FOR PETITION

McKim & Creed, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 

333, Special Rules for Certain Unmanned Aircraft Systems, petitions the 

Administrator to commercially operate the Aero-M, Mavrik, and S900 UAS 

within the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R. 

61.113(a) & (b), 

91.7(a), 

91.121, 

91.151(a)(1), 

91.405(a), 

91.407(a)(1), 

91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

In accordance with 14 C.F.R. § 11.81, McKim & Creed provides the following 

information in support of its petition for exemption: 

Name and Address of the Petitioner.

The name and address of the 

Petitioner McKim & Creed, Inc. 

1730 Varsity Drive, Suite 500 

Raleigh, NC 27606 

Mr, Timothy Cawood, PLS 

Senior Vice President 

(910)-343-1048 ext 247 

tcawood@mckimcreed.com

 
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The following documents contain proprietary information and are to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b). 

1. Aero-M: Aero-M- Operations Manual V1 

2. Drone Saftey -3D Robotics 

3. Mavrik: Mavrik Manual Mavrik Quick Start Guide 

4. Mavrik LI-PO Saftey and Disposal 

5. Mavrik Peridoc Maintenance Check 

6. S900: S900 Relase Note, 

7. S900 User Manual V1.2 

8. McKim & Creed Field Preflight and Saftey Checklist 

9. McKim & Creed Flight Log 

10. McKim & Creed UAS Flight Saftey Procedure 

Description of Proposed Operations and Saftey Procedures 

1. In order to maintain the highest possible degree of safety and consistency 

the key safety and operational restrictions are incorporated to our daily 

Flight and safety checklist, thus ensuring full compliance by the PIC and 

VO. 

2. McKim & Creed proposes to commercially operate the UAS for the 

special purpose of conducting aerial acquisitions within the NAS, 

pursuant to the following specific operating limitations. 

3. Proposed Operations will be limited to the following aircraft described in 

the operating documents, which are fixed and rotory wing, propeller 

driven aircraft with the following characteristics:

a. The Aero-M has a maximum gross weight of approximately 6.8 

pounds; 

b. The Mavrik has a maximum gross weight of approximately 4.8 

pounds and 

c. The S900 has a maximum gross weight of approximately 7.2 

pounds. 

d. All three systems are equipped with propeller systems driven by a 

Lithium Polymer battery powered electric motor. 

4. UAS operations under this proposed exemption will be limited to 

conducting operations for the purpose of aerial acquisitions. 
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5. The UA will not be flown at an indicated airspeed exceeding 80 knots or 

not exceeding the manufaturers reccomendations. 

6. The UA will be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operating documents. All altitudes reported to ATC will be in feet AGL. 

7. The UA will 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. 

8. The use of first person view (FPV) by the pilot in command PIC or visual 

observer (VO) will not be permitted. 

9. All operations will utilize a visual observer (VO). The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC will be able to communicate verbally at all 

times. Electronic messaging or texting will not be permitted during flight 

operations. The PIC will be designated before the flight and will not 

transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the functions prescribed in the operating 

documents. 

10. The VO will not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and will not be permitted to operate the camera or 

other instruments. 

11. The operating documents and the grant of exemption will be accessible 

during UAS operations and made available to the Administrator upon 

request. 

a. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined 

in the operating documents, the conditions and limitations 

contained in the grant of exemption take precedence and must be 

followed. 

b. The operator will follow the procedures as outlined in the 

operating documents. 

c. The operator may update or revise the operating documents. 
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d. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator 

upon request. 

e. The operator will present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. 

f. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted the exemption, then 

the operator will petition for amendment to the grant of 

exemption. 

g. The FAA’s UAS Integration Office (AFS-80) will be contacted if 

questions arise regarding updates or revisions to the operating 

documents. 

12. Prior to each flight the PIC will inspect the UAS to ensure it is in a 

condition for safe flight. 

a. 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 and the UAS is found 

to be in a condition for safe flight. 

b. The Ground Control Station will be included in the preflight 

inspection. 

c. All maintenance and alterations will be properly documented in 

the aircraft records. 

13. Any UAS that has undergone maintenance or alterations that affect the 

UAS operation or flight characteristics, e.g. replacement of a flight critical 

component, will undergo a functional test flight. The PIC who conducts 

the functional test flight will make an entry in the aircraft records. 

14. The pre-flight inspection will account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

a. The operator will follow the UAS manufacturer’s 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. 

b. The operator must carry out its maintenance, inspections, and 

record keeping requirements, in accordance with the operating 

documents. 

c. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts will be noted in the 
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aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person 

returning the UAS to service. 

d. Each UAS operated under this exemption will comply with all 

manufacturer Safety Bulletins. 

e. The authorized person will make an entry in the aircraft record of 

the corrective action taken against discrepancies discovered 

between inspections. 

15. The PIC will hold either an airline transport,commercial, private, 

recreational, or sport pilot certificate. The PIC will also hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or 

the Federal government. The PIC will also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate. This is per exemption as granted in 

Docket 11238 Dated March 26, 2015. 

16. The operator will not permit any PIC to operate unless the PIC meets the 

operator’s 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. 

a. The PIC qualification flight hours will be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). 

b. The VO will complete the operator’s training requirements. 

c. The record of training will be documented and made available 

upon request by the Administrator. 

d. Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building), will be permitted 

under the terms of the exemption. 

e. Training operations will only be conducted during dedicated 

training sessions. 

i. During training, proficiency, and experience-building

flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC will operate the 

UA with appropriate distance from nonparticipants in 

accordance with14 C.F.R. § 91.119. 
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17. UAS operations will not be conducted during night, as defined in 14 

C.F.R. § 1.1. All operations will be conducted under visual meteorological 

conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized. 

18. The UA will not operate within 5 nautical miles of an airport reference 

point as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management 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 

will be made available to the Administrator upon request. 

19. The UA will not be operated less than 400 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute 

miles from the PIC. 

20. If the UAS loses communications or loses its GPS signal, it will return to a 

pre-determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

21. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

22. The PIC is prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 20% 

battery power remaining. 

23. The operator will obtain an 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 will be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

a. Note as of March 22 2015 the FAA granted a “blanket” COA for 

flights at or below 200 feet to any UAS operator with a Section 333 

exemption. McKim & Creed will operate aircraft that weighs less 

than 55 lbs, will conduct operations under VFR rules and 
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conditions within VLOS of the PIC and restrict flight from airports 

and heliports as per applicable FAA rules. 

 

24. All aircraft operated in accordance with the exemption will be identified 

by serial number, registered in accordance with 14 C.F.R. part 47, and 

have identification (N- Number) markings in accordance with 14 C.F.R. 

part 45, Subpart C. Markings will be as large as practicable. 

25. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA will comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

26. The UA will remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

27. The UAS will not be operated by the PIC from any moving device or 

vehicle. 

28. The UA will not be operated over congested or densely populated areas. 

29. Flight operations will 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 the UA and/or debris in the event 

of an accident. 

b. The operator will ensure that nonparticipating persons remain 

under such protection. 

c. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations will 

cease immediately and/or; 

d. 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 

e. Operations nearer to the PIC, VO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 

91.119(a). 
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30. All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized 

representative. 

a. Permission from the land owner/controller or authorized 

representative will be obtained for each flight to be conducted and 

will be documented as part of the project execution plan. 

31. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable 

COA will 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 Web site: www.ntsb.gov. 

Requested Regulations for Exemptions and Equivalent Level of Saftey

14CFR Section61.113(a) And (b). 

1. Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

command, subsections (a) and (b) prescribe 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 PIC of an aircraft. 

b. A private pilot may, for compensation or hire, act as PIC of an 

aircraft in connection with any business or employment if: 

i. The flight is only incidental to that business or 

employment; and 

ii. The aircraft does not carry passengers or property for 

compensation or hire. 

2. McKim & Creed submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Aero-M, 

Mavrik, and S900 UAS’s unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely 

operate the Aero-M, Mavrik, and S900 UAS’s 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. 
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3. Further, McKim & Creed submits that all flights of the Aero-M, Mavrik, 

and S900 UAS, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to McKim & Creed business; and (2) will 

not carry passengers or property for compensation or hire. 

4. Specifically, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR C.F.R. § 61.51(b), 25 hours of total time as a UAS 

pilot (with a minimum of 5 hours of those hours as a UAS pilot operating 

the same make and model of UAS to be used for operations under the 

exemption). In addition to the hour requirements, the PIC will 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

14CFR Section 91.7(a).

1. 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. 

a. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow McKim & Creed to 

determine that the Aero-M, Mavrik, and S900 UAS are in an 

airworthy condition prior to every flight by ensuring that each 

UAS is in compliance with the operating documents (UAS 

DOCUMENTS ) and that the aircraft are in a condition for safe 

flight. 

b. McKim & Creed seeks the requested relief because the Aero-M, 

Mavrik, and S900 UAS do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, prior 

to every flight, McKim & Creed will ensure that the Aero-M, 

Mavrik, and S900 UAS are in an airworthy condition based upon 

mnufacturers operating documents. 

 

2. The equivalent level of safety established by Section 91.7(a) will be 

maintained because prior to every flight, McKim & Creed will ensure that 

the UAS are in an airworthy condition based upon the aircraft’s operating 

documents (i.e., the User Manual, Maintenance Procedures). 

3. McKim & Creed seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the Aero-M, Mavrik, and S900 UAS’s do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 
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Subpart H. As such, McKim & Creed submits that it will ensure that the 

Aero-M, Mavrik, and S900 UAS’s are in an airworthy condition, prior to 

every flight, by determining that the UAS being used is in compliance 

with the operating documents and that the aircraft is in a condition for 

safe flight as below in the supporting documents: 

a. Aero-M : Aero-M- Operations Manual V1 

b. Drone Saftey -3D Robotics 

c. Mavrik : Mavrik Manual Mavrik Quick Start Guide 

d. Mavrik LI-PO Saftey and Disposal 

e. Mavrik Peridoc Maintenance Check 

f. S900: S900 Relase Notes 

g. S900 User Manual V1.2 

h. McKim & Creed – Field Preflight Saftey Checklist 

i. McKim & Creed Flight Log 

j. McKim & Creed UAS Flight Saftey Procedure 

UAS Specifications: 

Aero M 

Type Fixed Wing 

Weight 6.8 Lbs 

Flight Time 40 Min 

Power 4S 600 mAh 35C LP 

Motor Tiger AT 2828-7 830kv 

Flight speed 33 MPH 

Wing Span 74 Inches 

AC Length 51 Inches 

 

MAVRIK 

Type Rotory 

Weight 4.8 Lbs 

Flight Time 18 Min 

Power 8000mah 4S LP 

Motor 4 x 600kv 4008 

Flight speed 10 MPH 

Wing Span 14 Inches 

AC Length NA Inches 

 

S900 

Type Rotory 
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Weight 7.2 Lbs 

Flight Time 18 Min 

Power 6S 15000mAh LP 

Motor 400rpm/V 

Flight speed 10 MPH 

Wing Span 15.5 Inches 

AC Length NA Inches 

14CFR Section 91.121. 

1. 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: 

i. Below 18,000 feet MSL, the current reported altimeter 

setting of a station along the route and within 100 nautical 

miles of the aircraft; 

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. 

2. McKim & Creed seeks relief from Section 91.121, entitled Altimeter 

settings, which is required to allow flight operations of the Aero-M, 

Mavrik, and S900 UAS because before each flight, the altitude reporting 

equipment will be set on the ground to zero feet AGL, rather than the 

local barometric pressure or field altitude. The Aero-M, Mavrik, and S900 

UAS utilize 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 control station (GCS). 

3. In order to maintain a level of safety equivalent to Section 91.121 

reporting will be ensured as the altitude of the Aero-M, Mavrik, and S900 

will be reported to air traffic control (ATC) in feet above ground level 

(AGL), and McKim & Creed will operate the Aero-M, Mavrik, and S900 

within visual line of sight (VLOS), at or below 400 feet AGL. 
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4. The altitude information of the UA will be provided to the PIC via a 

barometric pressure sensor, GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. Prior to each flight, a zero 

altitude initiation point will be automatically established by the UAS at 

ground level. 

14CFR Section 91.151(a)(1).

1. Section 91.151, entitled Fuel requirements for flight in visual flight rules 

(VFR) conditions, subsection (a)(1), states the following, in relevant part: 

a. No person may begin a flight in an airplane under VFR 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. 

b. During the day, to fly after that for at least 30 minutes. 

2. McKim & Creed seeks relief from Section 91.151(a)(1) entitled Fuel 

requirements for flight in VFR conditions, to the extent required to allow 

flights of the battery powered Aero-M, Mavrik, and S900 during daylight 

hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR) to fly for a total duration of 18- 40 (Rotory ,fixed wing) 

minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least ten minutes or 20 percent 

battery power remaining. McKim & Creed seeks the requested relief 

because without an exemption from Section 91.151(a)(1), the flight time 

duration of the battery powered Aero-M, Mavrik, and S900 will severely 

constrain the practicality of any aerial acquisition and research flight 

operations that McKim & Creed proposes to conduct pursuant to this 

Petition. 

3. The technical specifications of the Aero-M, Mavrik, and S900 UAS, as well 

as McKim & Creed proposed operating limitations, will ensure safe 

operation of the battery powered Aero-M, Mavrik, and S900 UAS during 

daylight hours in VMC, under VFR, with enough battery power to fly to 

the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least ten minutes or 20 percent battery power 

remaining. 

4. A grant of this exemption would ensure an equivalent level of safety 

established by 14C.F.R. Section 91.151(a)(1) as a result of (1) the technical 
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specifications of the UAS; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. 

5. McKim & Creed will ensure that it will safely operate the battery 

powered UA only during daylight hours in visual metrological 

conditions (VMC) under visual flight rules (VFR), with enough battery 

power for the Aero-M, Mavrik, and S900 to fly for the specific system 

duration to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least ten minutes or 20 percent 

battery power remaining. 

14CFR Section 91.405(a). 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only 

1. Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) only apply to aircraft with an airworthiness certificate, McKim & 

Creed requests relief from these Sections because the Aero-M, Mavrik, 

and S900 UAS do not require an airworthiness certificate. As set forth 

more fully below, the Aero-M, Mavrik, and S900 UAS meet the conditions 

of Section 333 of the FMRA for operation without an airworthiness 

certificate. 

2. All maintenance, alterations, or preventive maintenance of the Aero-M, 

Mavrik, and S900 UAS will be performed by McKim & Creed in 

accordance with the methods, techniques, and practices prescribed in the 

operating documents: 

a. Aero-M : Aero-M- Operations Manual V1 

b. Drone Saftey -3D Robotics 

c. Mavrik : MavrikManual Mavrik Quick Start Guide 

d. Mavrik LI-PO Saftey and Disposal 

e. Mavrik Peridoc Maintenance Check 

f. S900: S900 Relase Notes 

g. S900 User Manual V1.2 

h. McKim & Creed – Field Preflight Saftey Checklist 

i. McKim & Creed Flight Log 

j. McKim & Creed UAS Flight Saftey Procedure 

3. Only the Original Equipment Manufacturer (OEM) or qualified OEM 

maintainers will perform higher-level inspections and maintenance per 

the operating documents and OEM standards. McKim & Creed will 
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document and maintain all maintenance records for the Aero-M, Mavrik, 

and S900 UAS. 

4. McKim & Creed submits that the equivalent level of safety with regard to 

the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

will be met because all maintenance, alterations, or preventive 

maintenance of the UAS performed by McKim & Creed will be in 

accordance with the methods, and practices required in the operating 

documents. 

5. Since the UAS will be inspected as prescribed by the operating 

documents, McKm & Creed will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The 

following operating documents are attached. 

a. Aero-M : Aero-M- Operations Manual V1 

b. Drone Saftey -3D Robotics 

c. Mavrik : MavrikManual Mavrik Quick Start Guide 

d. Mavrik LI-PO Saftey and Disposal 

e. Mavrik Peridoc Maintenance Check 

f. S900: S900 Relase Notes 

g. S900 User Manual V1.2 

h. McKim & Creed – Field Preflight Saftey Checklist 

i. McKim & Creed Flight Log 

j. McKim & Creed UAS Flight Saftey Procedure 

The Public Interest 

1. Granting the present Petition will further the public interest by allowing 

McKim & Creed to safely, efficiently, and economically perform aerial 

acquisitions and mapping within the NAS, commercially, in support of 

government entities, engineering , agriculture, railroad industry, utilities, 

oil and gas industries, environmental, and shoreline mapping. The use of 

the Aero-M, Mavrik, and S900 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of McKim & Creed proposed operation of the AeroM, Mavrik, and S900 UAS will be realized without implicating any 

privacy issues. 
U.S. Department of Transportation 

April 24, 2015 

Page 17 

 

2. The Aero-M, Mavrik, and S900 will provide safe, efficient, and 

economical aerial acquisition and mapping operations to further each of 

these fields, all of which are critical to the well being of the general public. 

3. The specific operations that McKim & Creed will perform with the AeroM, Mavrik, and S900 UAS demonstrate how the requested exemption will 

directly benefit the above-referenced industries and the public, as a 

whole. In land use planning, engineering and mapping and industrial 

operations, the UAS will be used to aid in inspections, survey and plan 

new worksites, conduct volumetric analysis, and perform right of way 

analysis. The UAS may also be used to aid in environmental management 

of coastal and tidal areas, to map and monitor protected habitat and 

species. 

The Public Will Benefit From Decreased Congestion Of The NAS

1. The Aero-M, Mavrik, and S900 UAS are battery powered and serve as a 

safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of UAS would reduce the amount 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. 

2. The Aero-M, Mavrik, and S900 UAS do not require an airport to takeoff 

or land. Likewise, a reduction of manned aircraft conducting aerial 

survey missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and 

landing phases of flight operations. 

3. The UAS to perform aerial acquisitions, the substantial risk to life and 

property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. 

4. The UAS will only be operated pursuant to the specific conditions and 

limitations and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. The 

UA will not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure, which is not directly involved in the operation so that 

privacy will not be of a concern. 
U.S. Department of Transportation 

April 24, 2015 

Page 18 

 

5. A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which McKim & Creed Seeks Exemption: 

a. McKim & Creed seeks exemption from the requirements of 14 

C.F.R. Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(a)(1), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

CONCLUSION 

1. This exemption will permit McKim & Creed to commercially operate 

Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial 

acquisitions within the National Airspace System (NAS). 

2. McKim & Creed seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the Aero-M, Mavrik, and S900 

commercially, without an airworthiness certificate, for the limited 

purpose of conducting aerial acquisitions within the National Airspace 

System (NAS). By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the public interests, by 

allowing McKim & Creed to safely, efficiently, and economically operate 

UAS commercially within the NAS. 

3. In accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, McKim & Creed 

respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), and permit operation of the Aero-M, Mavrik, and 

S900 UAS commercially for the purpose of conducting aerial acquisitions 

within the NAS. 

Respectfully Submitted, 

McKim & Creed, Inc. 

Mr. Timothy Cawood, PLS 

Senior Vice President