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 requirement s 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 commerc ially operate three (3) Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial acquisitions within the National Airspace System (N AS) 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 offer ing a full range of engineering, surveying, landscape architectural and p lanning services, we have continuously reinvented ourselves to meet the ever- changing needs of ourU.S. Department of Transportation April 24, 2015 Page 2

customers and our marketplace. We have repositioned the business from a twoperson structural design firm to a 360 person infra structure design company

with offices from North Carolina to Florida.

McKim & Creed offers a full range of engineering, su rveying, and planning services. Core competencies of the firm include wat er and wastewater planning and design, site/civil engineering, landscape archite cture, structural engineering, GIS, and surveying specialties ranging from electron ic data collection to hydrographic surveying, aerial photogrammetry, laser scanning and subsurface utility engineering. Engineering News-Record has na med 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 t op AEC firms in the U.S.,

and Southeast Construction names the firm as the to p surveying and mapping firm in the region.

McKim & Creed operates offices in Wilmington, Raleig h, Charlotte, and Asheville, NC; Clearwater, Daytona Beach, DeLand, Fort Myers, Palm Coast, North Tampa, and Sarasota, FL.; Austin, Fort Worth, Ho uston, 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) roto ray wing systems to commercially provide professional geospatial servic es to clients associated with land use planning, mining, utilities to conduct inve ntories, mapping and inspection services, environmental planning and othe r geomatics applications. Use of the Aero-M, Mavrik, and S900 will provide McK im & Creed a suite of safe and efficient platforms to perform its business ope rations.

AIRCRAFT

McKim & Creed seeks an exemption to operate the Aer o-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 electri cally powered propeller driven systems. Unmanned Aircraft (UA) with transpo rtable Ground Control Stations (GCS).

The Aero-M has a maximum gross weight of approximat ely 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 pou nds. All three systems are equipped with propeller systems driven by a Lithium Polymer battery powered

electric motor.U.S. Department of Transportation April 24, 2015 Page 3

The Aero-M, Mavrik, and S900 will be registered in a ccordance 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, Id entification and Registration Marking.

BASIS FOR PETITION

McKim & Creed, pursuant to the provisions of the Fe deral Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and R eform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Sys tems, petitions the Administrator to commercially operate the Aero-M, Ma vrik, and S900 UAS within the National Airspace System (NAS), and for a n 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 exemptio n:

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.comU.S. Department of Transportation April 24, 2015 Page 4

The following documents contain proprietary informa tion 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 Proce dures

1. In order to maintain the highest possible degree of safety and consistency the key safety and operational restrictions are inc orporated to our daily Flight and safety checklist, thus ensuring full comp liance by the PIC and

VO.

2. McKim & Creed proposes to commercially operate the UAS for the special purpose of conducting aerial acquisitions w ithin the NAS, pursuant to the following specific operating limita tions.

3. Proposed Operations will be limited to the followin g 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 approximat ely 6.8 pounds;

b. The Mavrik has a maximum gross weight of approximat ely 4.8 pounds and

c. The S900 has a maximum gross weight of approximatel y 7.2 pounds.

d. All three systems are equipped with propeller syste ms driven by a Lithium Polymer battery powered electric motor.

4. UAS operations under this proposed exemption will b e limited to conducting operations for the purpose of aerial acq uisitions.U.S. Department of Transportation April 24, 2015 Page 5

5. The UA will not be flown at an indicated airspeed e xceeding 80 knots or not exceeding the manufaturers reccomendations.

6. The UA will be operated at an altitude of no more t han 400 feet above ground level (AGL), as indicated by the procedures s pecified 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 alw ays maintains VLOS capability. The VO and PIC will be able to communic ate verbally at all times. Electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the f light 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 prescr ibed in the operating

documents.

10. The VO will not perform any other duties beyond ass isting the PIC with seeing and avoiding other air traffic and other gro und 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 Adm inistrator upon
request.

a. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedu res outlined in the operating documents, the conditions and limit ations 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 doc uments.U.S. Department of Transportation April 24, 2015 Page 6

d. It is the operator’s responsibility to track such r evisions and

present updated and revised documents to the Admini strator upon request.

e. The operator will present updated and revised docum ents if it petitions for extension or amendment to the grant o f exemption.

f. If the operator determines that any update or revis ion would affect the basis upon which the FAA granted the exe mption, then the operator will petition for amendment to the gra nt of exemption.

g. The FAA’s UAS Integration Office (AFS-80) will be c ontacted if questions arise regarding updates or revisions to t he operating

documents.

12. Prior to each flight the PIC will inspect the UAS t o 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 operatin g until the necessary maintenance has been performed and the UA S 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 do cumented in

the aircraft records.

13. Any UAS that has undergone maintenance or alteratio ns that affect the UAS operation or flight characteristics, e.g. repla cement of a flight critical component, will undergo a functional test flight. Th e PIC who conducts the functional test flight will make an entry in th e aircraft records.

14. The pre-flight inspection will account for all pote ntial discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents.

a. The operator will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replaceme nt, inspection, and life limit requirements.

b. The operator must carry out its maintenance, inspect ions, 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 theU.S. Department of Transportation April 24, 2015 Page 7

aircraft records, including total time in service, de scription of

work accomplished, and the signature of the authoriz ed 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 air craft record of the corrective action taken against discrepancies d iscovered between inspections.

15. The PIC will hold either an airline transport,comme rcial, private, recreational, or sport pilot certificate. The PIC wi ll also hold a current

FAA airman medical certificate or a valid U.S. driv er’s license issued by a
state, the District of Colombia, Puerto Rico, a territ ory, a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an airc raft 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 unl ess 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 fro m persons, vessels,
vehicles, and structures.

a. The PIC qualification flight hours will be logged i n a manner consistent with 14 C.F.R. § 61.51(b).

b. The VO will complete the operator’s training requir ements.

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 d edicated training sessions.

i. During training, proficiency, and experience-building flights, all persons not essential for flight operat ions are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants i n accordance with14 C.F.R. § 91.119.U.S. Department of Transportation April 24, 2015 Page 8

17. UAS operations will not be conducted during night, a s defined in 14 C.F.R. § 1.1. All operations will be conducted unde r visual meteorological conditions (VMC). Flights under special visual flig ht 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 aeronau tical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM a s required by the operator’s COA. The letter of agreement with the ai rport management will be made available to the Administrator upon re quest.

19. The UA will not be operated less than 400 feet belo w or less than 2,000 feet horizontally from a cloud or when visibility i s less than 3 statute

miles from the PIC.

20. If the UAS loses communications or loses its GPS si gnal, it will return to a pre-determined location within the planned operatin g area and land or be recovered in accordance with the operating document s.

21. The PIC will abort the flight in the event of unpre dicted obstacles or emergencies in accordance with the operating docume nts.

22. The PIC is prohibited from beginning a flight unles s (considering wind and forecast weather conditions) there is enough po wer to fly at normal cruising speed to the intended landing point and la nd the UA with 20% battery power remaining.

23. The operator will obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA w ill 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 air space requirements in the ATO issued COA including class of airspace, alti tude 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 wi th a Section 333 exemption. McKim & Creed will operate aircraft that weighs less than 55 lbs, will conduct operations under VFR rules andU.S. Department of Transportation April 24, 2015 Page 9

conditions within VLOS of the PIC and restrict flig ht from airports

and heliports as per applicable FAA rules.

24. All aircraft operated in accordance with the exempt ion will be identified by serial number, registered in accordance with 14 C .F.R. part 47, and have identification (N- Number) markings in accorda nce with 14 C.F.R. part 45, Subpart C. Markings will be as large as pr acticable.

25. Before conducting operations, the radio frequency sp ectrum used for operation and control of the UA will comply with th e Federal Communications Commission (FCC) or other appropriat e 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 mo ving device or

vehicle.

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

29. Flight operations will be conducted at least 500 fe et from all nonparticipating persons (persons other than the PI C, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficientl y protect nonparticipating persons from the UA and/or debris in the event

of an accident.

b. The operator will ensure that nonparticipating pers ons remain under such protection.

c. If a situation arises where nonparticipating person s 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 s tructures where the owner/controller of such vessels, vehicles or st ructures has granted permission and the PIC has made a safety as sessment of the risk of operating closer to those objects and d etermined that it does not present an undue hazard, and

e. Operations nearer to the PIC, VO, operator trainees o r essential persons do not present an undue hazard to those per sons per § 91.119(a).U.S. Department of Transportation April 24, 2015 Page 10

30. All operations shall be conducted over private or c ontrolled-access property with permission from the land owner/contro ller or authorized representative.

a. Permission from the land owner/controller or author ized 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 tran sgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA will be reported to the FAA's UAS Integration O ffice (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 an d limitations: Pilot in command, subsections (a) and (b) prescribe the follo wing, 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 pa ssengers or property for compensation or hire; nor may that per son, for compensation or hire, act as PIC of an aircraft.

b. A private pilot may, for compensation or hire, act a s PIC of an aircraft in connection with any business or employm ent 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 s afety will be maintained because no PIC will be allowed to operat e the Aero-M,
Mavrik, and S900 UAS’s unless that PIC has met certa in flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the Aero-M, Mavrik, and S900 UAS’s in a mann er consistent with the operations specifications as set forth herein, i ncluding evasive and emergency maneuvers, as well as maintaining appropri ate distances from people, vessels, vehicles and structures.U.S. Department of Transportation April 24, 2015 Page 11

3. Further, McKim & Creed submits that all flights of t he Aero-M, Mavrik, and S900 UAS, conducted by the PIC pursuant to the g rant of this Petition: (1) will be incidental to McKim & Creed b usiness; and (2) will not carry passengers or property for compensation o r hire.

4. Specifically, the PIC will have accumulated and logg ed, in a manner consistent with 14 CFR C.F.R. § 61.51(b), 25 hours o f 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 opera tions under the exemption). In addition to the hour requirements, t he 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 aircra ft 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 & C reed to determine that the Aero-M, Mavrik, and S900 UAS are i n an airworthy condition prior to every flight by ensuri ng that each UAS is in compliance with the operating documents ( UAS DOCUMENTS ) and that the aircraft are in a conditio n for safe flight.

b. McKim & Creed seeks the requested relief because th e Aero-M, Mavrik, and S900 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. The refore, prior to every flight, McKim & Creed will ensure that the Aero-M, Mavrik, and S900 UAS are in an airworthy condition b ased upon mnufacturers operating documents.

2. The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, McKim & Cr eed will ensure that the UAS are in an airworthy condition based upon th e aircraft’s operating documents (i.e., the User Manual, Maintenance Proced ures).

3. McKim & Creed seeks relief from Section 91.7(a), ent itled Civil aircraft
airworthiness, because the Aero-M, Mavrik, and S900 UA S’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,U.S. Department of Transportation April 24, 2015 Page 12

Subpart H. As such, McKim & Creed submits that it w ill ensure that the Aero-M, Mavrik, and S900 UAS’s are in an airworthy co ndition, 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 RotoryU.S. Department of Transportation April 24, 2015 Page 13

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, subsecti on (a), states the following, in part:

a. Each person operating an aircraft shall maintain th e cruising altitude or flight level of that aircraft, as the ca se may be, by reference to an altimeter that is set, when operatin g:
i. Below 18,000 feet MSL, the current reported altimete r 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 i n paragraph (a)(1)(i) of this section, the current rep orted altimeter setting of an appropriate available stati on; or
iii. In the case of an aircraft not equipped with a radi o, the elevation of the departure airport or an appropriat e altimeter setting available before departure.

2. McKim & Creed seeks relief from Section 91.121, enti tled Altimeter settings, which is required to allow flight operatio ns of the Aero-M, Mavrik, and S900 UAS because before each flight, th e altitude reporting equipment will be set on the ground to zero feet AG L, rather than the local barometric pressure or field altitude. The A ero-M, Mavrik, and S900 UAS utilize a barometric pressure sensor, GPS equipm ent, and a radio communications telemetry data link to downlink alti tude information from the UA to the PIC at the ground control statio n (GCS).

3. In order to maintain a level of safety equivalent t o Section 91.121 reporting will be ensured as the altitude of the Ae ro-M, Mavrik, and S900 will be reported to air traffic control (ATC) in fe et above ground level (AGL), and McKim & Creed will operate the Aero-M, Mav rik, and S900 within visual line of sight (VLOS), at or below 400 feet AGL.U.S. Department of Transportation April 24, 2015 Page 14

4. The altitude information of the UA will be provided to the PIC via a barometric pressure sensor, GPS equipment and a radi o communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. Prior t o each flight, a zero altitude initiation point will be automatically est ablished by the UAS at ground level.

14CFR Section 91.151(a)(1).

1. Section 91.151, entitled Fuel requirements for fligh t in visual flight rules (VFR) conditions, subsection (a)(1), states the follo wing, in relevant part:

a. No person may begin a flight in an airplane under V FR conditions unless (considering wind and forecast weather condi tions) there is enough fuel to fly to the first point of intended l anding and, assuming normal cruising speed.

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

2. McKim & Creed seeks relief from Section 91.151(a)(1 ) entitled Fuel requirements for flight in VFR conditions, to the ex tent required to allow flights of the battery powered Aero-M, Mavrik, and S9 00 during daylight hours in visual meteorological conditions (VMC), un der 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 m inutes or 20 percent battery power remaining. McKim & Creed seeks the r equested 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 acquisitio n and research flight operations that McKim & Creed proposes to conduct p ursuant to this

Petition.

3. The technical specifications of the Aero-M, Mavrik, a nd S900 UAS, as well as McKim & Creed proposed operating limitations, wil l 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 no rmal cruising speed, to fly after that for at least ten minutes or 20 pe rcent battery power remaining.

4. A grant of this exemption would ensure an equivalen t level of safety established by 14C.F.R. Section 91.151(a)(1) as a r esult of (1) the technicalU.S. Department of Transportation April 24, 2015 Page 15

specifications of the UAS; (2) the limitations on t he proposed flight operations; and (3) the location of the proposed fl ight operations.

5. McKim & Creed will ensure that it will safely opera te the battery powered UA only during daylight hours in visual met rological conditions (VMC) under visual flight rules (VFR), wi th 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 m inutes 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 ce rtificate, McKim & Creed requests relief from these Sections because t he Aero-M, Mavrik, and S900 UAS do not require an airworthiness certif icate. As set forth more fully below, the Aero-M, Mavrik, and S900 UAS mee t the conditions of Section 333 of the FMRA for operation without an airworthiness

certificate.

2. All maintenance, alterations, or preventive maintenan ce of the Aero-M, Mavrik, and S900 UAS will be performed by McKim & Cr eed in accordance with the methods, techniques, and practice s 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 q ualified OEM maintainers will perform higher-level inspections a nd maintenance per the operating documents and OEM standards. McKim & Creed willU.S. Department of Transportation April 24, 2015 Page 16

document and maintain all maintenance records for t he Aero-M, Mavrik,

and S900 UAS.

4. McKim & Creed submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requireme nts 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 w ill be in accordance with the methods, and practices required in the operating

documents.

5. Since the UAS will be inspected as prescribed by th e 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 publ ic interest by allowing McKim & Creed to safely, efficiently, and economicall y perform aerial acquisitions and mapping within the NAS, commerciall y, in support of government entities, engineering , agriculture, railro ad industry, utilities, oil and gas industries, environmental, and shoreline mapping. The use of the Aero-M, Mavrik, and S900 UAS will decrease conges tion of the NAS, reduce pollution, and provide significant benefits t o the economy. Notably, the benefits of McKim & Creed proposed oper ation of the AeroM, Mavrik, and S900 UAS will be realized without impl icating any privacy issues.U.S. Department of Transportation April 24, 2015 Page 17

2. The Aero-M, Mavrik, and S900 will provide safe, effic ient, and economical aerial acquisition and mapping operation s 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 per form with the AeroM, Mavrik, and S900 UAS demonstrate how the requested exemption will directly benefit the above-referenced industries an d the public, as a whole. In land use planning, engineering and mappin g and industrial operations, the UAS will be used to aid in inspectio ns, survey and plan new worksites, conduct volumetric analysis, and perfo rm right of way analysis. The UAS may also be used to aid in enviro nmental management of coastal and tidal areas, to map and monitor prote cted habitat and species.

The Public Will Benefit From Decreased Congestion O f The NAS

1. The Aero-M, Mavrik, and S900 UAS are battery powered and serve as a
safe, efficient, and economical alternative to the ma nned aircraft traditionally utilized to obtain aerial imagery. B y reducing the amount of manned aircraft needed to perform aerial acquisitio ns, 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 ai rport to takeoff
or land. Likewise, a reduction of manned aircraft c onducting aerial survey missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, depar ture, arrival, and landing phases of flight operations.

3. The UAS to perform aerial acquisitions, the substan tial risk to life and property in the air and on the ground, which is usua lly associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated.

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

limitations and in accordance with the Federal Avia tion 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 Regi ster, 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 commerc ially operate Unmanned Aircraft Systems (UAS) for the purpose of conducting aerial acquisitions within the National Airspace System (N AS).

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, Mavr ik, and S900 commercially, without an airworthiness certificate, f or the limited purpose of conducting aerial acquisitions within th e National Airspace System (NAS). By granting this Petition, the FAA Ad ministrator will be fulfilling the Congressional mandate of the FAA Mod ernization and Reform Act of 2012, while also advancing the public interests, by allowing McKim & Creed to safely, efficiently, and ec onomically 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, Mc Kim & Creed respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Section s 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 Aer o-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