1 U.S. Department of Transportation

19th 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 Aviation

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 Systems (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 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 following 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 processed to create an orthophotography 

and also a 3-D surface of the ground.

2. Inspection of 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 playback. The video operator is a 

separate individual from the Pilot in Command (PIC) and the Visual Observer (VO) if required.
2 U.S. Department of Transportation

19th March, 2015

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

document under controlled conditions 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@geoResourceTechnologies.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: 
3 U.S. Department of Transportation

19th March, 2015

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 frame with 8 motors, a DJI A2 flight controller, a DJI iOSD (onscreen telemetry display), a DJI 

Datalink and associated DJI Ground Control software, a Zenmuse 3-axis gimbal (with controller), and a Sony NEX7 camera. The sUAS is flown by the PIC using a 2.4 GHz Futaba T14SG radio, 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 flight 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 batteryvoltage 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 the 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 mannedaircraft (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 applicant 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 on 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 operate the system
4 U.S. Department of Transportation

19th March, 2015

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 Pilot in Command (PIC) and at least one Visual 

Observer (VO), and 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 Medical 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 flights consisting of all the days’ production 

activities.

10. The 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 flights will occur in Class G airspace no closer than a 5-mile radius of the geographic center/Airport 

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

14. If 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 advising 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, operations at closer 

range may be approved.
5 U.S. Department of Transportation

19th March, 2015

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 be 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 communications 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 obstacles (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 authorize 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 without 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 operates 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 requirements. 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 load.
6 U.S. Department of Transportation

19th March, 2015

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 provisionally 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," "experimental," 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. Given 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 property 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 

be, 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 checklists prior to each flight, an equivalent level of safety will be provided.
7 U.S. Department of Transportation

19th March, 2015

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 aircraft, 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 aircraft 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 communications. 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. 
8 U.S. Department of Transportation

19th March, 2015

As this exemption is for a UAS that is a helicopter and the exemption requests authority 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 

exception 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 conventional 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 departure.” 

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 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to 

fly after that for at least 45 minutes.”

The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the UAS in a tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to 
9 U.S. Department of Transportation

19th March, 2015

alleviate given the size and speed of the small UAS. The applicant 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): Carrying 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 sections and Part 43 apply only to aircraft with an airworthiness 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 condition to provide the equivalent level of safety.
10 U.S. Department of Transportation

19th March, 2015

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 applicant’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 applicant 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,

Stephen Keen, dba ‘geoResource Technologies, Inc.’