3050 S outh Delaware, Springfield, Missouri 65804, Telephone: 417.831.9700, Fax: 417.831.9777 www.geoengineers.com



### To: U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12

- 140

1200 New Jersey Ave. SE

Washington, DC 20590

From: Nicholas A. Arens

Date: June 22 , 2015

Subject: Ex e m ption Request S e ctio n 333 of the FAA Reform Act

Dear Sir/Madam,

Pursuant t o Section 3 3 3 of th e FAA Modern i z ati o n and Reform Ac t of 2012 (th e Reform A c t )

, and 14 C.F.R.

Part 11, GeoEngineers, Inc. (GeoEngineers)

, operating a s mall Unmann e d Aircraft Syst e m ( s UA S ) seeks an

ex e m ption from the Federal Aviation Regulati o n s (F A R s) listed below to allow operation of our sUAS

co m m ercia l ly in airspace regulat e d b y th e Federal Avia ti on Administration (FA A ) a n d u nde r t he condition s

outlined he r e i n or as may b e established b y th e FAA as required b y Section 33 3

.

Th e r e quest e d exemption would pe r mi t GeoEngineers to provide services t o consumers inter e sted in aerial

d a t a cap t ure us i n g a s U AS in the following areas:



### ■ Aerial Land Surveying and Mapping



### ■ Construction Monitoring and Inspection



### ■ Agricultural Surveying



### ■ Photography and Videography of jobsites

GeoEngineers states that all sUAS fl i ght s that will occu r over private or cont r olled access property and will d o

so with th e property owner's prior consent

. Operations under the exemption will be subject to strict operating

requirements and conditions to ensure at least an equivalent level of safety to currently authorized operations

using manned aircraf

t and under conditions as may be modified by the FAA as required by Section 333.

Regul a tion s f r o m which t he ex e m ption i s request e d :



### ■ 14 C.F.R. 61. 1 13(a) and ( b)



### ■ 14 C.F.R. 91.9 ( b) (2)



### ■ 14 C.F.R. 91. 1 09



### ■ 14 C.F.R. 91.119



### ■ 14 C.F.R. 91. 1 21



### ■ 14 C.F.R. 91. 1 51(a)



### ■ 14 C.F.R. 91. 2 03 (a ) & ( b)

### ■ 14 C.F.R. 91. 2 05 ( b)



### ■ 14 C.F.R. 91. 2 15



### ■ 14 C.F.R. (91.401

‐ 91.417)



### U AS

We are pe t i t i onin g for e x e mpti on t o ena bl e GeoEngineers t o o p era t e a DJI P h a nt om 2

, DJI Phantom 3

, and a

3DRobotics Aero fixed win g s U AS

. These s U AS a l l weigh less than 15 l b s, have a bui lt

‐ i n capabil i t y t o limi t th e

h e i g h t (400 feet AGL) i t flies above the ground, t o l i mi t th e radius of th e dist a nc e it f l ies from the operator

(Visual L i ne of Sight or 2000 horizontal feet) and t o exc l ud e i t from Class B, C and D airspace i n clud i n g a n o

f l y zon e featu r e

. E a c h system also has the failsafe function of th e a u topilot system, which me a n s when t he

communication b e t w ee n th e Ma i n Controller and t he transm i tte r is lost, th e system w ill autom a tic a ll y trigger

Ret u rn t o Home and will land in a safe manner

.

Th e above specific a t ions mee t standa r d s listed bel o w, some der i ved in accor d anc e with t he M o del Aircraft

Ope r ating Standa r d s:



### ■ Th e pet i tion er will only operate it s sUAS in lin e of sight of a pilot a nd/or observer and will operate at

sites that are a 'sufficient distance' from po pulate d areas withi n t he sterile area describ e d in the

operator’s manual. S u c h operations w ill insure th a t th e s U AS will "not creat e a hazard t o us e rs of th e

nat i onal airspace system or t he p u blic."



### ■ Whe n flying sUAV within 5 mile s of an airport, GeoEngineers shall subm it a P l an of Activit i es t o the

l o cal Fligh t St a nd a rd s District Office (FSD O) a t least 3 days before t he p l anned flight i n accordance

wit h FAA gu i d elines.



### ■ Maxi m u m flight tim e for e a c h oper a t ional fligh t will b e 50 m i nutes.



### ■ Flight s will b e term i nat e d a t 20% b a tter y power rese r ve should th a t occur prior to th e 50 m i n ute limit.



### ■ Th e s U AS will b e progra m m ed so that i t will not b e o p erated at an altitude gre a te r than 400 f eet AGL.



### ■ Min i mu m c re w for eac h operation will consist of th e sUAS Pilot an d t he Visual Observer.



### ■ The sUAS will operate during daylight hours only.



### ■ Th e s U AS Pilot will be the Pilot in Command ( PIC ) and will be trained in flight operations , Visual Flight

Rules (VFR), and safety procedures.



### ■ Th e s U AS operated b y the pet i tione r w e igh s less th a n 15 pounds, including t he payload (i .e. camera,

l e ns, and gimba l ) utilizing FCC compliant devices and frequencies ( 5 GHz, 2.5 GHz

, and 915 MHz )

.



### ■ Th e s U AS w ill operate a t s peed s of n o more th a n 45 knots.



### ■ Give n th e small siz e of th e sUAS and the restricted environment within whic h t h e y w ill operate, our

sUAS operations adhere to th e Reform Act's safety require m ents.



### FLIGHT OPERATIONS

Flight Limits

Operators should abide by all state , federal and regulatory agencies requirements for flight. In general, a s UAS

should not be operated in wind speeds greater than 10 m/s, or in snow, rain, low cloud cover, and fog. It isalso recommended to avoid all metal structures, power lines, and transmission towers that m ay interfere with

the s UAS compass and GPS.

No

- Fly Zones

It is the operator’s responsibility to fly safely and abide by all state, federal and regulatory agencies

requirements. A flight log is required to maintain safe flight ope rations. An important part of documenting the

flight log is verifying the area is not within a no

- fly zone. Several resources exist online detailing th e locations

of no

- fly zones. The following example provides no

- fly zones for the area surrounding Seattle , Washington,

provided by http://flysafe.dji.com/no

- fly

. It should be noted the use of s UAS inside National Parks is

prohibited and may not be reflected on the above listed no

- fly zone maps, as well as other sta te, and federal

facilities.

Several manufacturers utilize onboard GPS restricting flight in no

- fly zones. The flight controller has the ability

to disable take

- off, reduce altitude, and automatically land in some situations . With the use of a ground

stat ion, warnings and restrictions w ill be displayed on the screen.

When researching no

- fly zones, refer to the following websites:



### ■ http://f lysafe.dji.com/no

- fly



### ■ https://www.mapbox.com/drone/no

- fly/



### ■ http://tfr.faa.gov/tfr2/list.html (FAA temporary flight restriction areas)



### ■ http://flightaware.com/live/ (Live air traffic, weather, and temporary flight restriction areas)

s UAS Checklist

The following safety instructions and checklists are intended to not only protect the s UAS but also people and

property. Improper operation can cause serious injury and property damage. Proper training, guidance,

maintenance, and following pre

- flight checklist procedures can reduce these risks , and provide equivalent

level of safety to manned aircraft oper ations

. The pre

- flight checklist and flight log must be performed and is

required prior to each mission.Pre

- Flight Checklist



### ■ Equipment

 Visually inspect the airframe

 Loose or damaged screws

 Loose or damaged wiring and connections

 Batteries charged, properly installe d and secure

 Propellers are tight and in good condition

 Remote control batteries charged

 Camera battery, SD card, secure



### ■ Pre

- Flight

 Notify personnel of flight operations

 Position s UAS in a safe, level location for takeoff

 Verify remote controls move freely

 Set remote control modes

 Turn on remote control

 Turn on s UAS

 Calibrate compass

 Turn on Ground Station app and connect to s UAS

 Verify GPS status and correct LED indicators

 Arm s UAS motors

 Takeoff and hover between 3 to 5 feet

 Start timer for flight time

 Test r emote control movements (forward, backward, up, down, left, right )

 Begin mission

Flight Log

Flight logs are important to record training, hours logged, s UAS maintenance schedules, and to provide an

added layer of safety to flight operations. It is the respo nsibility of the pilot to ensure the s UAS is airworthy

and capable to operate in a safe manner. An example flight log is detailed below , and is required prior to any

mission.Project Name :

File No: Date: Site Location :

Pilot/Co

- Pilot : Position/ Title : Reviewed by : Position/ Title :

UAS Checklist: ( check the box when complete )

Equipment Pre

- Flight Checklist

☐ Visually inspect airframe ☐ Tablet charged ☐ Weather conditions ☐ Clear area

☐ Loose/damaged screws ☐ Camera/SD card ☐ Notify personnel of flight ☐ Arm motors

☐ Loose/damaged wiring ☐ First Aid Kit ☐ Position UAS in safe area ☐ Hover between 3

- 5 feet

☐ Loose connections ☐ Glasses ☐ Remote control mode set ☐ Start flight timer

☐ Batteries charged ☐ High Visibility Vest ☐ Calibrate compass ☐ Test remote control movements

☐ Propellers in good condition ☐ Hardhat ☐ Connect ground station ☐ Begin mission

☐ Remote control charged ☐ Tools ☐ Verify GPS status ☐ Maintain visual contact

Job Steps Potential Hazards Critical Actions to Mitigate Hazards

Flight Operations Location 

### ■ Proximity to airports, structures, power lines, etc



### ■ Maintain visual observation of UAS



### ■ High altitude flying reduces battery life

Weather 

### ■ Monitor weather, and be aware of changing conditions



### ■ Avoid flying during periods of high wind



### ■ Temperature extremes reduce battery life drastically

Malfunctions 

### ■ Locate areas on flight plan for emergency landings



### ■ Utilize pre

- programmed flight modes and return to launch features

Pre

- Flight Safety

Meetings Injury due to not

understanding the hazards 

### ■ Hold a pre

- work safety meeting with the crew before any flight operations.



### ■ Carry additional tools, batteries, propellers, first aid kit

Take off/Landing Possible propeller strike 

### ■ Be alert and cautious at all times.



### ■ Approach UAS after motors disarmed and powered down

.



### ■ Maintain large radius for take/off and landing.



### ■ Never exceed payload capacity



### ■ Never attempt to catch UAS

Fatigue Exposure to the elements

during long flying hours 

### ■ Keep aware of hazards at all times.



### ■ Do not fly for extended times without rest

Communications Visibility/Inclement Weather 

### ■ Check remote controls, antennas, batteries and radar for weather

Faulty Radios 

### ■ Carry spare batteries.



### ■ Pre

- program ground station for return to launch on radio loss

Emergency 

### ■ Dial 911



### ■ Hospital Route

Air Traffic No

- Fly zones 

### ■ http://flysafe.dji.com/no

- fly



### ■ https://www.mapbox.com/drone/no

- fly/



### ■ http://tfr.faa.gov/tfr2/list.html (FAA temporary flight restriction areas)



### ■ http://flightaware.com/live/ (Live air traffic, weather, and temporary

flight restrictio n areas)Flight Plan

Aircraft: Battery #: Departure Time:

Weather: Departure (%): Return Time:

Wind Speed: Return (%): Time Flown:

Mission: ☐ Reconnaissance ☐ Agriculture Ground Station (yes/no) :

☐ Mapping/Surveying 

### ■ ☐ Construction Autonomous (yes/no) :

☐ Search and Rescue ☐ Research Elevation:

☐ Videography ☐ Other : Speed:

Flight Path : ( mission details, take off/landing locations, additional comments )

Required Control Measures: (check the box when complete)

☐ Conduct a pre

- flight safety meeting.

☐ Conduct equipment inspection.

☐ Perform pre

- flight checklist

☐ Create flight plan

☐

### CONCLUSION

Additionally, GeoEngineers has a hi gh regard t o safe operations wit h an u nd e rstandin g of FA R s, pr e

‐ flight

inspections, maintenance and r e pair, operations within airspace, as well as be i n g tra i ned t o hig h safety

standards

.

Unde r the r e quested e x e mpt i on GeoEngineers e n s u res th a t all operators have cond u c t e d a thorough review

of s UAS education ma t erial co n ce r nin g th e systems t o b e operated in addition t o all appli c able r egulations

and gu i dance do cum en t s; i n clud i n g aeronautical bac kg r ound information s uc h as cha r ts, N O TAMS and

Aircraft Circulars; Radi o C o mmun i cati o n s Procedur e s; Human Factors and Crew Resou r c e M a n agem e n t ;

Basic s UA S Aero d yna mic s; We a t her factors; Ai r m anship and Decisio n

‐ makin g and Safe Operating Procedures.

We resp e c tfully request e x emptio n u n der S e ctio n 3 3 3 t o en a bl e GeoEngineers t o operate safe, low

‐ risk

comme r c ial s U AV operations for th e activities stated.

S incerely

,

Nicholas A. Arens

Geotechnical Engineer

GeoEngineers, Inc.

3 050 S. Delaware

Springfield, Missouri 65804

(417) 576

- 1719

### EX E MPT I O N RE Q U ESTS

GeoEngineers, Inc. reque s ts an e x e m pt io n from the f ollowing regulations as well as any additional regulations

that may apply to th e operation of th e sUAS :

14 CFR 61.1 1 3 (a) & (b)

Section s 61. 1 13 (a ) & ( b) l i mi t private p i lot s t o no n

‐ commercial operations. GeoEngineers proposes that it s

sUAS PIC will have complet e a flight

- training p rogram and at l e ast 15

‐ Hours of fligh t ti me i n a safe and

controlled envi r o nmen t prior t o operating th e s U AS commercially

. Th e airmanship skills necessary t o operate

th e s U AS do not correlate significan t ly to th e airmanship skills necessary for pilotin g mann e d aircraft and,

thus

, e x e m pt io n from the nee d for th e PIC t o hold a comme r c ial pilot ce r tific a te is request e d

. Unlike a

conv e n tional aircr a ft that carries th e pilot and passengers, the sUAS is remotely controlled with n o living thing

on board. T he areas of operation will b e restricted to jobsites a t whic h third par t y access is controlled, a n d all

f lights are plann ed a n d coordinated in advance

. T h e r i s k s associated with the operation of the sUAS are

dim i nishe d f r o m th e level of risk associated with com m ercial operations cont e mp l ate d b y Part 61 whe n

dra f ted, that allowing operations of th e sUAS as reques t ed with a private pil o t as th e PIC exceeds the present

level of safety achieved b y 14 C.F.R. §6 1

. 113 (a ) & ( b). I n addition, th e PIC will u nderg o all necessary security

screenings b y th e Transportation Security Administration that ce r tificat e d airmen undergo. 

### The FAA has

granted exemptions for private pilots to conduct similar operations in Exemptions 11062, 11213,

11360 and 11447.

14 CFR 91.9

Thi s regulati o n provides that n o person may operate an aircraft unless a current, approved fl i gh t manual is in

the a i r c raf

t

. We assume that th e i nt e n t of thi s r e quire me n t i s t o ensure that flight ma n u al information i s

available t o th e aircrew w h ile operating t he aircra f t

. We r e quest an ex e m ption t o this require m e n t sinc e th e

aircraft is not only too small t o carry d o cu me ntation

, th e docum e ntat i on would not b e available t o t he c re w

duri ng flight operations. T o obtain an equivalent l e vel of safety and meet the i nt e n t of 91.9, we pr o p ose that a

current, approved sUAS Fl i g h t Manua l m u st b e available t o the crew at the g round station anytime th e aircraft

is in

, or preparing for, flight.

14 CFR 91.1 0 9

Th e r e gulati o n states, "N o person may operate a civi l aircraft that is being used for flight inst r u ction unless

th a t aircraft has f u l l y functioning dual con t rols." T h e s U AS S y ste m ground

‐ based con t rol station consists of a

small hand

‐ held radio tra n smitter and while i t does not offer a second set of "controls", bot h th e student a n d

i n s t r uct or can

, and will, operate t he single s et of controls simult a n eously. With bot h student and inst r u ctor

having "ha n d s

‐ on" the c o ntrol s duri ng flight

, w e feel that this t e chniq ue meet s th e intent 91.109 a n d provides

an equivalent l e vel of safety.

14 CFR 91.1 1 9

Th e r e gulati o n states that over sparsely populated areas th e aircr a ft can n ot b e operated closer than 500 feet

t o any perso n

, vessel, vehicle, or structure. Since t he t y pica l mission of t he sUAS would be photography or

survey of perso n s, vess e ls, vehicle s or structures i t would b e necessary t o operate closer than 500 f ee t t o the

i t e m s listed

. Oper a tions will only b e flown over property or persons whe r e permission has bee n obtained and

car e ful pr e

‐ planned has bee n performed. T h e aircraft will be operated a t a low altitude allowing, if a power

un it f a ils, an eme r genc y landing without u n d ue hazard to persons or p r opert y on th e surface. Therefore, we

maintain that d ue t o th e small siz e of th e UAS, the hazard t o pe r sons, vehicle s and structures is min i ma l

compared t o manne d aircraft, which should be considered in grant i n g th e exemption.14 CFR 91.1 2 1

Th e r e gulati o n requires that aircraft shall maintain cruising alt i t u de s b y r efer e nc e t o an alt i mete r sett i ng

available within 100 N M o f th e aircraft. Th e s U AS w ill always fly b e low 400 feet AG L and will not n e e d to

maintain cr ui sin g alt i tude s in order t o prevent conflict with other a i rcraft. A n Above Groun d L e vel altimeter

m e asurement a b o ve th e ta ke off point is t r ansmitt e d via radio from the sUAS o n

‐ board comp u te r t o th e

display screen held b y th e PIC, providing a const a ntl y updated AG L re a dout.

14 CFR 91.1 5 1

Th e r e gulati o n provides that n o person may b e gi n a f ligh t in a n airplane unde r day

‐ VFR conditions un l ess

ther e is enough fuel t o fly t o th e first point of i nt e nd e d land i n g a n d t o fly after that for at l e ast 30

- minutes. W e

feel the i n t e ntion of this para g ra p h is to provide an energ y r e s erve as a safety buffe r for delays t o landing. T he

sUAS are b a tter y operated and th e ma x im u m d u ra ti on of flight from a single battery char g e is 12

‐ 45

(d e pend i n g on w hic h sUAS) m i nute s w it h a 20% reserve. Sinc e the aircraft will never fly more th a n 1/2 N M

from t he point of in t ended landing, a full battery charge at launch will ensure that we m e e t th e reserve ene r g y

requirem e n t of thi s pa r agraph. W e r equest an e x emptio n to th e word " f ue l " and ask f o r an equivalent

i n terp r etat i on wit h the word "e n e rg y "

. W e also r e quest exemption from t he 30

- minute reserve and ask th a t

our reserve will b e t o fly t he mission t o th e point of intended landing a n d have at l e ast a 2 0% battery reserve

after tha t

.

14 CFR S ubp a r t E (91.401

‐ 91.417)

Th e r e gulati o n provides that t he operator is primari l y responsible for m a int a i n i n g the aircraft in an airworthy

c o ndition

, i nc l udin g comp l ianc e wit h part 39 and 43. P aragraphs 91.407 and 91. 4 09 require that th e aircraft

b e "ap p roved for retu r n t o service b y a person authorized u nder 43.7" after maint e nanc e and inspection. I t is

our intention that the PIC perform ma i nten a n c e and inspection of the aircraft and "be authorized t o approve

th e aircraft fo r return t o s ervice." T h e P I C will e n s u re that the aircraft is in a n airworthy condition prior t o every

flight and in addition, conduct detai l e d i n sp ecti o n s after every 1 0 hours of f light or manufacturer

recommendations

. Maint e nanc e perfo r med b y th e PIC is lim i te d to repairing s m a l l cr a c ks, replacing

propeller s

, checking electric a l con n ec t ion s and upd a ti ng software and firmware for th e on

‐ board c o m pu t er.

All other maint e nanc e will b e perfo r med b y th e manufactur e r or thei r des i gnated repair facil i t y

. T he PIC will

docum e n t wo rk perform e d in accordance with 9 1 .417. We f ee l that d ue to th e size, con s truction, and

simplic i t y of the aircraft, t he PIC ca n en s u re an equiv a lent level of s afe t y.