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19 th March, 2015

Stephen Keen geoResource Technologies, Inc.

41 Cameron Avenue Cambridge, MA 02140

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal A viation Regulations from:

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR
91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a ) and (b); 14 CFR
91.405 (a); 14 CFR 91.407 (a) (1) ; 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part
11, Stephen Keen

, DBA ‘ geoResource Technologies, Inc. ’ operator of Unmanned Aircraft System s (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operat ion of designated UAS, provided such operations are conducted within and under the conditions outlined herein or as may

be established by the FAA as required by Section 333. Thank you in advance for your consideration.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the follo wing areas :

1. Aerial Mapping and Survey. This service involves flying a project area in a series of parallel flight

- paths, utilizing a downward

- facing camera taking photographs at a pre

- designated interval to create a mosaic of photographs that cover the project area. The platform includes both a navigational GPS and a locational GPS to geo

- reference the photographs. These photographs are proce ssed to create an orthophotography

and also a 3

- D surface of the ground.

2. Inspection o f buildings . This service involves using a camera to create video of a building structure which is both relayed to a video

- operator on the ground and stored for later pl ayback. The video operator is a separate individual from the Pilot in Command (PIC) and the Visual Observer (VO) if required.

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As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this

document under controlled cond itions in the NAS that would be operated with safety as the primary concern

. Approval of this exemption would provide services by a safety

- focused operation that would reduce the risk

associated with manned solutions , in both flight and other methods of inspection.

The name and address of the applicant is:

Stephen Keen geoResource Technologies, Inc.

41 Cameron Avenue Cambridge, MA 02140 Stephen.Keen@geoResourceTechnolog ies.com
(617) 583

- 3735

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121
14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1)
14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

Stephen Keen dba ‘geoResouce Technologies, Inc’ will operate a DJI S1000 sUAS in connection with this exemption application :

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DJI S1000 , with a total weight of less than 20 lbs. This system is manufactured by DJI and professionally assembled by Troy Built Models. This platform has been extensively tested and has a proven safe flight history. The system comprises a fr ame with 8 motors , a DJI A2 flight controller, a DJI iOSD (onscreen telemetry display), a DJI

Datali nk and associated DJI Ground Control software, a Zenmuse 3

- axis gim b al (with controller), and a Sony NEX

7 camera. The sUAS is flown by the PIC using a 2.4 GHz Futaba T14SG ra dio, with the camera operated by a Camera Operator (CO) with an additional Futaba T14SG radio as to keep the two operations completely separate. Flights are carried out at less than 10 knots and at approximately 150 feet above the ground surface. The platform has a sophisticated fligh t control system that enables the operator to locate the sUAV on a ground control system in addition to being continually being in visual line

- of

- sight and has safety systems to warn and manage low battery

voltage situations. The S1000 will be flown under a comprehensive set of operational standard procedures focused on the safe operation of the platform to minimize risk. The S1000 has a LED lighting system to communicate key elements of operational status at all times, in addition to the on

- screen display showing flight parameters relevant to
the safe operation of the sUAS.

PUBLIC GOOD

Given the small size of the UAS in scope and the controlled environment provided

, the proposed operations will

adhere to t he Reform Act’s safety requirements. The approval of this application presents no national security

issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Once of the primary benefits of sUAS operation is the removal of the requirement to having a human put in a potentially hazardous situation

– this could be individuals on manned

aircraft (although the risk is minimal) or individuals on apparatus to gain an elevated view of a structure. Accordingly

, the applicant graciously requests that the FAA grant the requested exemption

.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will

further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applica nt agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. All operation will be carried out with strict adherence to the standard operating procedures outlined o n the operating manual (and generally achieved with the use of checklists) and associated documents pertaining

to: a) Review of the system to ensure all hardware and software is operating within defined parameters b) List of all required components to safely ope rate the system

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c) Set

- up parameters d) Pre

- flight checklist e) Takeoff checklist f) Landing checklist g) Emergency procedures h) System maintenance and service schedules

2. The UAS will weigh less than 20 lbs.

3. The UAS, will operate at 20 knots or less and generally be flying at 10 knots

. 4. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

5. Maximum flight time for each operational flight will be approximately 18 minutes, depending on conditions, and will operate under a strict battery management regime that alerts the operator to end flight at a determined battery voltage (first alert) and will autonomously ‘return home’ if a second determined battery voltage is reached (or radio control is lost)

. 6. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and missions will generally be at approximately 150 feet above ground level

. 7. Minimum crew for each operation will consist of the UAS Pil ot in Command (PIC) and at least one Visual Observer (VO)

, a nd may include a third, but separate , Camera Operator (CO)

. 8. The UAS pilot will be a designated Pilot in Command (PIC) and will hold a Private Pilot Certificate with a

Third Class Med ical Certificate and at least 20 hours of logged UAS flight time

. The PIC and the VO, as well as the CO if assigned, will have completed a one day safety training pertaining to the flight and safe operation of the DJI S1000.

9. A safety briefing will be performed prior to each day’s flight s consisting of all the days’ pro duction

activities.

10. T h e applicant will also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to conducting operation(s) in the NAS.

11. All flight activities will be logged.

12. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

13. The flight s will occur in Class G a irspace no closer than a 5

- mile radius of the geographic center/Airport

Refe rence Point (ARP) of a tower controlled or uncontrolled airport.

14. I f operations will be within a 5

- mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted ad vising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

15. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission of the FSDO, oper ations at closer

range may be approved.

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16. The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

17. The PIC and VO will b e able to communicate by voice and/or radio at all times.

18. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations

. 19. If the UAS loses communicat ions with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomously.

20. The UAS will have the capability to abort a flight in case of unpredicted obsta cles (aircraft in vicinity, persons entering perimeter, etc.) , weather, or emergencies such as low battery

.

In pursuit of this petition the following exemptions are requested:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1).

Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both au thorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated witho ut an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and op erates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requir ements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external l oad.

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14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisio nally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not

less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "exper imental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Give n the size of the
UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b) , no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or pro perty for compensation or hire.

The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because

the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant to the operation of UAS

is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will

b e , or be under the direct supervision of

, a FAA Certificated Private Pilot with current Third Class or higher medical

certificate. It is believed that the operation and limitations set forth in the FOM will equate to the safe operation of

the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight

, an equivalent level of safety will be provided.

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14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the ai rcraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that ai rcraft has fully functioning dual controls.

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio commu nications. The

FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and

for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA.

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As this exemption is for a UAS that is a helicopter and the exemption requests authori ty to operate at altitudes up to
400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be

needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the

ex ception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds
400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will

however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location

where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conv entional aircraft operating at or below 500 AGL. In addition, the

low

- altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before depart ure.”

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions u nless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At nigh t, to fly after that for at least 45 minutes.”

The a pplicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior e xemptions. Operating the UAS in a tightly controlled area where only people and property owners or official re presentatives who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to

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alleviate given the size and speed of the small UAS. The a pplicant believes that an equivalent level of safety can be

achieved by limiting flights to 30 minutes or 25% of battery power

— whichever happens first. This restriction

would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating

area.

14 C.F.R. §91.203 (a) and (b): Ca rrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs well under the proposed 55

- lb limit and is operated without an onboard pilot. As such,

there is no ability or place to carry certification and registration documents or to display them on the UAS

. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section s and Part 43 apply only to aircraft with an air worthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of time.

If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condit ion to provide the equivalent level of safety.

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An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance

with the UAS Manufacturer's User Manual and Operators Pilot OPeratingHandbook . As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required maintenance

needed.

Additional Information :

The applicant believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012 , providing sufficient justification for the granting of commercial operations of the appl icant’ s UAS. The application has 20+ years’ experience in geospatial technologies and the implementation of similar projects without sUAS technology and is familiar with following procedures outlined in operations manuals and health and safety plans. The appli cant has spent the last 12 months familiarizing himself with the potential of safely implementing sUAS technology in a commercial environment to provide services that provide benefit to society by increasing efficiency while reducing risk.

Sincerely,

Ste phen Keen, dba ‘geoResource Technologies, Inc.’