Surveying And Mapping, LLC

4801 Southwest Parkway, Building Two, Suite L00, Austin, TX 78735

Ofc 512.447.0575 Fax 512.326.3029

info@sam.biz www.sam.biz TX Firm # 10064300

August 19,2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington,DC 20590

RE: Request for Exemption pursuant to Section 333 of the FAA Reform Act and Part 11

of the Federal Aviation Regulations in Regulatory Docket No. FAA-2014-0353-0001

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Actof 2012, Pub. L. No. ll2-95,

l26Stat.11(amending49U.S.C.)(hereinafter,the..@')and14C.F.R.Part1l,

Surveying And Mapping, LLC ("Sry" or "¡!pp!!q1!''), operator of small unmanned aircraft

systems (singularly a "!]UAS" or cumulatively "g!l¡!$9") equipped to conduct professional aerial

inspection, land surveying and geospatial services, hereby applies for an Exemption to allow

commercial operation of sUAS for inspecting telecommunication towers with a height greater

than 200 feet above ground level, so long as such inspections are conducted (i) on

telecommunication towers published on current FAA Visual Flight Rules (VFR) or Instrument

Flight Rules (lFR) charts, (ii) no further than 50 feet laterally from the telecommunication tower,

(iii) and no higher than 50 feet above the top of the telecommunication tower, and under the

conditions herein or as may be established by the FAA as required by Section 333 of the Reform

Act. The Applicant also requests that a "blanket" COA be issued in conjunction with this

exemption to allow for the operating conditions described herein.

As described more fully below, the requested exemption would permit the operation of sUAS

under controlled conditions in airspace that is limited, predetermined, is controlled as to access,

and would provide safety enhancements to the telecommunication tower inspection industry

presently using inspectors and climbing equipment to conduct inspections.

As inspections would be conducted only on telecommunication towers known to aircraft

operating within the national airspace, and within a distance from the tower where safe flight of a

manned aircraft is not possible, it is the Applicant's position this exemption would pose no

additional risk to manned aircraft than the telecommunication tower itself. Approval of this

exemption would thereby enhance safety and fulfill the Secretary of Transportation's

responsibilities to "... establish requirements for the safe operation of such aircraft systems in the

national airspace system."

Furthermore, the use of sUAS for telecommunication tower inspection will mitigate the risk to

personnel in the inspection industry by negating the need to physically climb a tower for the

purpose of visual inspection.
U. S. Department of Transportation

August 19,2015

The name and address of the Applicant is:

Surveying And Mapping, LLC

Attention: Patrick A. Smith, RPLS

4801 Southwest Parkway

Bldg. Two, Suite 100

Austin, T)(78735

Telephone: (512) 685-3 542

Email: psmith@sam.biz

The Applicant hereby requests the Exemption, and the issuance of an FAA Form 7711-l UAS

COA Attachment, to allow the use of the following sUAS:

l. senseFly Exom

(Aircraft number l, the "Amendment Unmanned Aircraft" or "AUA")

AUA technical data and checklists are attached to this petition, labeled "Annex 4". In

accordance with the conditions and limitations herein, the Applicant requests exemption from the

following while operating the Amendment Aircraft:

14 CFR $$ 61 .23(a) and (c),61.101(e)(a) and (5),61.113(a),61.315(a),91.7(a),91.119(c),

91.121,91.751(a)(1), 91.405(a), 91.a07@)(t), 91.409(a)(1) and (2), and 91.417(a) and (b), to

the extent necessary to allow the Applicant to operate the AUA to perform tower inspection

("Ergg@").

In accordance with the section of 11393 known as "Conditions and Limitations", SAM hereby

requests to operate the Amendment Aircraft while adhering to the conditions and limitations

listed below:

l. Operations authorized by this Exemption would be limited to the AUA, when weighing

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

require a new petition or a petition to amend this Exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not

permitted.

3. The AUA may not be operated at a speed exceeding 43 knots (50 miles per hour). The

Exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 43 knot speed restriction. In no case will the AUA be operated at

airspeeds greater than the maximum AUA operating airspeed recommended by the aircraft

manufacturer.

4. The AUA must be operated at an altitude of 200 feet AGL or less when inspecting

telecommunication towers that are not published on FAA navigational charts.

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U. S. Department of Transportation

August 19,2015

5. When inspecting a telecommunication tower published on FAA navigational charts, the

AUA must be operated at an altitude of no more than 50 feet above the published tower

height, and no more than 50 feet laterally from the published tower location.

6. An electronic means of restricting the horizontal and vertical location of the AUA during

flight, commonly referred to as a 

o'geofence," must be used at all times.

7. The AUA must 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, as specified on the PIC's FAA-issued airman medical certificate or U.S.

driver's license.

8. All operations must utilize a visual observer (VO). The AUA must be operated within the

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The

VO and PIC must be able to communicate verbally at all times; electronic messaging or

texting is not permitted during flight operations. The PIC must be designated before the

flight and cannot transfer his or her designation for the duration of the flight. The PIC

must ensure that the VO can perform the duties required of the VO.

9. This Exemption and all documents needed to operate the AUA and conduct its operations

in accordance with the conditions and limitations stated in this grant of exemption, are

hereinafterreferredtoasthe..@.''TheoperatingDocumentsmust

be accessible during AUA operations and made available to the Administrator upon

request. If a discrepancy exists between the conditions and limitations in this Exemption

and the procedures outlined in the Operating Documents, the conditions and limitations

herein take precedence and must be followed. Otherwise, the operator must follow the

procedures as outlined in its Operating Documents. The operator may update or revise its

Operating Documents. It is the operator's responsibility to track such revisions and

present updated and revised documents to the Administrator or any law enforcement

official upon request. The operator must also present updated and revised Operating

Documents if it petitions for extension or amendment to this grant of exemption. If the

operator determines that any update or revision would affect the basis upon which the

FAA granted this Exemption, then the operatormust petition for an amendment to its grant

of Exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the Operating Documents.

10. Any AUA that has undergone maintenance or alterations that affect the AUA operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight prior to conducting further operations under this Exemption.

Functional test flights may only be conducted by a PIC with a VO and must remain at least

500 feet from other people. The functional test flight must be conducted in such a manner

so as to not pose an undue hazard to persons and property.

3lPage
U. S. Department of Transportation

August 19,2015

1 l. The operator is responsible for maintaining and inspecting the AUA to ensure that it is in a

condition for safe operation.

12. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the AUA is

in a condition for safe flight. The pre-flight inspection must account for all potential

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a

condition that affects the safe operation of the AUA, the aircraft is prohibited from

operating until the necessary maintenance has been performed and the AUA is found to be

in a condition for safe flight.

13. The operator must follow the AUA manufacturer's maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.

14. Each AUA operated under this Exemption must comply with all manufacturer safety

bulletins.

15. Under this grant of Exemption, a PIC must hold either an airline transport, commercial,

private, recreational, or sport pilot certificate. The PIC must 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

must also meet the flight review requirements specified in l4 CFR $ 61.56 in an aircraft in

which the PIC is rated on his or her pilot certificate.

16. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under

this Exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and

cuffency must be logged in a manner consistent with 14 CFR $ 61.51(b). Flights for the

purposes of training the operator's PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC's ability to safely operate the AUA in a manner

consistent with how the AUA will be operated under this Exemption are permitted under

the terms of this Exemption. However, training operations may only be conducted during

dedicated training sessions. During training, proficiency, and experience-building flights,

all persons not essential for flight operations are considered nonparticipants, and the PIC

must operate the AUA with appropriate distance from nonparticipants in accordance with

14 cFR $ 91.119.

17. AUA operations may not be conducted during night, as defined in 14 CFR $ 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

18. The AUA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted

with an ARP, the center of the airport symbol as denoted on the current FAA-published

4lPage
U. S. Department of Transportation

August 19,2015

aeronautical chart, unless a letter of agreement with that airport's management is obtained

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement

with the airport management must be made available to the Administrator or any law

enforcement official upon request.

19. The AUA may not be operated less than 500 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 AUA loses communications or loses its GPS signal, the AUA must return to a predetermined location within the private or controlled-access property.

2l.The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

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

weather conditions) there is enough available power for the AUA to conduct the intended

operation and to operate after that for at least frve minutes or with the reserve power

recommended by the manufacturer if greater.

23. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be conducted in accordance with an ATO-issued COA. The exemption

holder may apply for a new or amended COA if it intends to conduct operations that

cannot be conducted under the terms of the attached COA.24. All aircraft operated in

accordance with this Exemption must be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N-Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the AUA and

any documents required under l4 CFR $$ 91.9 and 91.203 must be available to the PIC at

the Ground Control Station of the AUA any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

25.The AUA must remain clear and give way to all manned aviation operations and activities

at all times.

26.The AUA may not be operated by the PIC from any moving device or vehicle.

27. All Flight operations must be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the AUA and/or debris in the event of an accident. The operator must ensure

that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of the

5lPage
U. S. Department of Transportation

August 19,2015

AUA, flight operations must cease immediately in a manner ensuring the safety of

nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has gtanted permission for

operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this Exemption.

28. All operations shall be conducted over private or controlled-access property with

permission from the property owner/controller or authorized representative. Permission

from property owner/controller or authorized representative will be obtained for each flight

to be conducted.

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

boundaries of the operational area as defined by the applicable COA must 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.sov.

Unless otherwise specified in this grant of Exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47,67, and 91.

Summarv

Approval of this Exemption and the issuance of an FAA Form 7711-l UAS COA Attachment,

allowing the operations listed in this petition, will provide an equivalent level of safety to the

aviation community and greatly improved safety to the telecommunication tower inspection

community. The AUA possesses enhanced safety features designed for telecommunication

tower inspection, and when operated within the conditions and limitations outlined in the

Exemption, are far safer than conventional operations conducted with manned aircraft or

personnel climbing a tower for visual inspections.

6lPage
U. S. Department of Transportation

August 19,2015

Please let me know if you have any questions concerning this request for an amendment to the

Exemption.

Very truly yours,

Patrick A. Smith, RPLS

Associate

Surveying And Mapping LLC (SAM)

4801 Southwest Parkway

ParkwayTwo, Suite 100

Austin, T){78735

Direct 512.685.3542

Attachments:

Annex A (senseFly Exom Technical Data)

TlPage
Situational awareness & assistance

Mult¡directional video feed

Ground stat¡on software

Source

Number

Video

Hor¡zont¿l fìeld of view

Avôilab¡lity

Serrso¡

Nurnber

Rånge

Feedback

Navigat¡on l¡ghts

Anti-collis¡on lights

,tomåled fa¡lsafe behav¡ours

Operâtor triggered

N¿vcôms (v¡sual sensor)

5

VGA (fio x 480 pixels)

100 degrees

One n¿vcam ¿t ¿ time

Object & range detection

Ultrasonic

5

up (o 6 m (20 fr)

Audio ¿nd v¡sual object w¿rning

tenseFly eMot¡on X (suppl¡ed)

lntui¡¡ve 3D user ¡nterf¿ce

Cl¡ck ðnd drag to set m¡ss¡orì blocks

Autom¿tic lD flight Þlann¡ng

Edit nì¡ssion plans d('r¡ng fl¡ght

Automôted system checks

Autom.lted take-off & larrding

Reôl-tinìe flight gtatus

M¡in camer¿ video feed ¡n(egrat¡on

Íhernl¿l video feed integration

N¿vcam video feed integl¿t¡on

tully automatic flight

lnteractive Screently

Manu¿l flighr (with assistance

funct¡ons)

ln-fl¡ght sw¡tch between fl¡9ht ¡nodes

Blôck-box record¡ng of all fl¡ght &

nì¡ss¡on p¿rameters

Projecr & data managernent

Seamless interface to Postflight

fer¿ 3D

DNG to JPEG convers¡on

lmage process¡ng

ùorn

Softw¿re aÞplication

M¡ssion pl¿nn¡ng

l-lyirì9

Alter your flight

senseFly

Operational safety

Shrouding

Mater¡al

F-unct¡on

C¿rbon fibre

Defirres propeller rot¿t¡orì are¿

Protects from danrage at low speed

Slgnallsatlon lights

2 green on the right.2 red orì the left

I top strobe, I bot(orn strobe

Geofencing, return home,

emergency stop, emergency landing

Hold posit¡on, return home, go land,

land now enrergerrcy motor cut-off

J)

Ground prox¡m¡ty detection

Avoidance procedure I Autom¿tic s(op (can be deactiv¿tcd)

W¿rning signàls I nudio & visual

Flight assistancefeatures (lnteractive mode)

Cru¡secontrol I Ma¡ntarns(low)consrantspeed rì¿

I q¡ven dircction

I

D¡stancclock I Keepsdrsrancorofrontalobiecrs

| 3-5m(eB- 16ír)

Obstacleavoidance I Depend¡ngonfìighrph¿se

Safety procedures

Softw¿re ¿ppl¡cat¡on

Processing

raycloud Ediror

Mosåic Ed¡tor

output results

Postflight Tera 3D (suppl¡ed)

Rap¡d Check processing

Quality Repon

Automatic Aer¡al Ïr¡anqul¿l¡on (AAT)

and Eundle Elock Adjustrrerìt (88^)

Automat¡c po¡nt cloud classification

¿nd DIM extr¿ction

Po¡nt cloud fiher¡rìg and sûìootlìing

^utomðt¡c 

brightness and coloul

coíection

Point cloud viewiñg & ed¡tirìg

Polyling surface & stockpile

measuremerìt

D¡g¡t¡sation tools/vecror obiecr

edir¡ôg

tly.through animation

Seôml¡ne editing

Planar/ortho project¡orì selection

Mosa¡( colour/briglìtness editing

2D ônd 3D (ortho¡'nage, point

cloud, vector d¿ta, etc.)

Opt¡m¡sed c¿mera pos¡tion,

exrern¿l orient¿tion ¿rìd ¡nternðl

par¿meters, urìd¡storted ¡mages

Type

Manual RC corrtrol

Autopilot fallback

I ndependent low-level .ìutop¡lot

(backup for mairì autop¡loù

lndependerìt fìC controller

(take m¡nu¿l control at any t¡me)
Flight system lntegrated payloads Flight modes

Types Automatic

lnterâct¡ve ScreenFly

Manu¿l (RC)

Avâilability Switch between modes ¿t any tim

Automatic

ïype

Dimensions (¡ôcl. shroud¡ng)

Engines

Propellers

Take-off we¡ght

tlight t¡nìe (full system)

Max. cl¡mb rate

Max. a¡rspeed

Wind resist¿nce

^utop¡lol 

& control

Materials

Operating temperature

V-shôped qu¿dcopter

56x80x l7 cm (22 x 32 x / in)

4 electric brushless ntotors

4

l./ k9 (3.7 lb) ¡ncl. bauery, payload &

shrouding

Up to 22 nì¡n

/ m/s (l 5 nìph)

Automat¡c flight: 8 m/5 (18 mph)

Manu¿l ll¡9ht:12 nì/s (2i¡ mph)

Autonr¿tic: up to 8 nlls (18 mph)

Manual: up to l0 m/s (22 nìph)

lMU, m¿gnetometer, baromc'ter

& GPs

Composite body, moulded carbon

fibre anns and leqs, precision'

molded magnesium frame,

prec¡s¡on-molded ¡njected plastic

.l0to40 C(14 .104 F)

Strll imagcs

Vid€o

Horizont¿l field of view

D¡9irôl/_oom

5t¡ll iordges/video

l-lor¡zontôl field of vieu/

Idqe enhancement

Video l¡ve s(re.lnlirìg rarìge

l lorizontal field of view

Headlamp

Ëlash

J8 MR nìcchanic¿l shu(tcr

DNG (RAW ìrn.lge with cotect¡on

mer¿dat¿)

6round sampl¡ng distance (6SD):

- I nìnì/pixel ¿t 6 m

ì cnì,/p¡xel ¿t 60 m

Recorded ôn boârd

Geo-referenced (position &

orierìtation)

HD (l 280 x 720 p¡xe¡s)

Rccorded on board or stre.ìrned

63 degrees

6x

Thermalcamera

Thernal (80 x ó0 pixels) overl¿id on

m¿irì caÙìera stre.ìnì

50 degrees

Yes

Head navcam (visual sensor)

V¡deo VGA (ó40 x 480 pixels)

UÞ ro 2 km (ì.24 Íìiles)

100 deqrees

TripleMewhead

Ma¡n camera

Lights

Yes, used for video

Yes (rìot òctive upon rele¿sc)

Control ¡rìterfðce

M¡ss¡on pl¿nnrnq

ïypes of m¡ss¡on blocks

ln-flight miss¡on clìanges

Mouse. keyboard or touchscleen

Dr¿g-ând-drop mission blocks

l-ior¡zontal mapping

Around po¡nt of ¡nterest

Userdefìned route

Yes: manual waypoirìt changes ¿n

updates possible at ¿ny t¡me

Prinìàry control interface

Fl¡ght ¿ss¡stance

(de0endrng on the fìighr ph¿se)

lnteract¡ve ScreenFly

Screerì-b¿sed âctions & USB joypð

Cru¡se control

Distance lock

Obstâc¡e àvoid¡nce

Wi reless commun¡cat¡on

Manual (RC)

Primâry corìtrol ¡nterface I RC (remote control)

On-board comput¡ng

TYPe

Frequency

Datð traDsm¡ttcd

RâÍìge

Main communi<ation l¡nk

Digitô1, dual omniclirecrional

¿ntenn¿s, duðl band, erìcrypted

2.4 GHz & 5 6Hz ISM bands

(country dependent)

Comm¿nds, m¿¡rì camera stre¿m,

navc¿m stre¿nì, sensor d¡l(1, etc.

Up to 2 km (1.2 mi)

System power

IYPe

Quôd:corc proccssor

Dualcore Þrocessor

Single core processor

4 on-board CPUs

Prirìcip¡l ¿utopilot & ôrt¡ficiôl

intelligence

V¡deo co-processing

Low'level autoÞilo( (safety f¿llbacl

and motor conrol

RC (Remote controll Communicôtion link marìagemen

.lipe I Dig¡ral

Frequency I z..o c,r,

Range I up to eOO m (0.5 mi)

l\ddltlonal' navcams (vlsual'sensors) Single-core processor

lhe'nfoiln¡t'on (onr¿iìed rì th¡J brtrhure ß for tror¡otrorrrl purfþtetoDlyô¡d

doet not (on9ti¡ile¿n offer, r\tr¿nty or (onÍ¿(1.

Number

Posit¡orìs

Video

l"lorzontal fìeld of v¡ew

Av¿ilab¡l¡(y

Oper¿t¡onal use

4 rì¿vc¿ms

Left, riqht, re.lr, bo(orì'ì

VGA (640 x 480 pixels)

100 degrees

Onc navcan'ì àt ¿ time

Side views (w,/o turninO rn¿in

canrera) & p¿r.ìllel ll¡9ht along

objects

Back-up safely & control in

t¡ght envirorìments

1,.ìncling & ground proxim¡ty

Technology

Type

Power level display

Charging t¡me

Sm¿rt battcry

LiPo. 3 cell,8500 m^lì

LED display on battery, orì-screerì

informat¡on

r t.5h