# GeoCounsel •-- September 30 , 2015 US Department of Transportation Federa l Aviation Administration Airmen and Airspace Rules Division 800 I ndependence Ave. , S
.W
. Washington , DC 20591 31 Manzanita L•ttleton
. CO 80127 USA 303-979-7773



### Re: Public docket for GeoCounsel

. I nc.. No
. FAA-2015-0224, reply provided 4/8/2015 Sir/Madam : On March 20th, 2015 we received your letter asking for further clarification from us (attached)
. T hese cla rifications were provided by us on March 23rd (also attached) , and sent via regular mail to this same address (no alternative submission method appears mentioned). Since then (half a year ago) this additiona l mail is not mentioned in the docket , and I wish to indicate that we did in fact respond within the 30 days stipu lated. I wish to add that I understand the comp lexity of your efforts , and that the safety of the skies is important. As such , we await with patience the results of your work
. However, we do not want to be left out of the process. As a comment on our situation , we are a very small mapping firm that has engaged in photogrammetry for the last 30 years . As such , we have collected terrestrial im agery that long , and are teaching it. Our difficulty is that we are now seeing large organizations doing work that we safely did before , just because they can afford h i ring a pilot , in spite of the fact that they do not know anything about photogrammetry and mapping. We also see a lot of foreig n firms starting to position themselves in the US marketplace , since they have had the opportunity to gain expe ri ence outside of the US
. As a consequence , and as always , only a few small U S companies will survive, while the large ones have the credit to stay afloat, or the resources to do overseas work. Maybe you would like to know this. Best r egards ,



# ~ Harold Schuch , PE , CP , LSI President

Page 1 of 1

### u.s. Deportment of Transportation Federal Aviatton Administration 

### March 

### 23 ,20 15

Harold C
. Schuch, PE, C P, LSI GeoCounsel, Inc. 

### 31 Manzanita Littleton, CO 80127 Dea r Mr. Schuch: 800 I ndependence Ave
. S W
. Washington
. D
. C
. 20591



### This letter is to inform you that we are unable to process your request for an exemption. 

### It explains why we cannot process your request and what you should do in the next 

### 30 days. 

### Why We Cannot Process Yo ur Request We entered your January 

### 27 , 2015 exemption request on behalf ofGeoCounsel , Inc. into the public docket (No. 

### FAA-2015-0224, but we are unable to process your request any further. The information you sent does not comply w ith the requirements of§ 11.81 (copy enclosed). For us to consider the request any further, you must send us all of the fo ll owing:
• The reasons why granting the request would be in the public interest; that i s, how it would benefit the public as a whole . • Any additional information, views, or arguments available to support your request. 

### What You Should Do If you want us to process your request any further, you must send the information described earlier to reach us within 

### 30 days
. Please note that§ 11.63(d) requires yo u to send your petition for exemption at least 120 days before the proposed effective date ofthe exempt ion.

### If We 

### Do Not Hear From You If we do not hear from you within 30 days, we will close the docket without notifying you further. 

### Ifyou have any questions or require additional time, you may call (202) 267-9521. 

### Sincere,?7 

# /J
. .



# ~<7 **~** I



## ~routmai **/** / . Program Ana lyst, Airmen and Airspace Rules Division
Enclosure 

### 2

### eCFR

- Code ofFederal Regulations

ELECT RONIC CODE OF FEDERAL REGULATIONS e-CFR Data is current as of March 2, 2015 Title 14 __.Chapter I__. Subchapter B __. Part 11 __.S ubpart A __. §11.8 1 Ti tle 14: Aeronautics and Space PART 11-GENERAL RULEMAKlNG PROCEDURES Subpart A-Rulemaking Procedures §11.81 What information mu st I in clud e in my petiti o n for an exe mption ? 

### Page l of l

You must i nclude the following information i n your petition for an exemption and subm i t it to FAA as soon as you know yo u need a n exemption. (a) Your na me and mail in g address and, if you wi sh , oth er co ntact i nformation su ch as a fax numbe r, telephone numbe r, o r e-mail address; (b) T h e specific section o r sections of 1 4 C F R from which you seek an exemption; (c) The extent of relief you seek, and the reason you seek th e relief; {d) The reasons why granting your request would be in the public interest; that is, how it would ben efit the public as a whole; (e) The reasons why granting the exemption would not adversely affect safety, or how the exemption woul d provi de a level of safety at least equal to that provided by the rule from wh ich you seek the exemption; (f) A summary we can publish in the FEDERAL REGISTER, stating: (1) T h e rule fro m w h ich you seek the exemption; and (2) A b rief descript i on of the nature of the exemption you seek; (g) Any additional information , views or arguments available to support your request ; and (h) If you want to exercise the privileges of your exemption outside the United States, the reason why you need to do so . For questions or comments regarding e·CFR editorial content, features, or design, email ecfr@nara.gov. For questions concerning e-CFR programming and delivery issues, email webteam@gpo.gov.



### http: //www .ecfr.gov I 

### cgi-bin /text-idx?S ID=eee7bb3943bc0292a08fb8b9feb89c23&node=se... 3 /4

/20 15

# Geo Counsel 

# Jt•- April 8 , 2015 US Department of Transportation Federal Aviation Administration Ai rmen and Airspace Rules D ivisi on 800 Independence Ave. , S.W. Washington , DC 20591 31 Manzanita Littleton , CO 80127 USA 303-979-7773

Re: Pu bli c docket for GeoCo u nse l
. In c . . No. FAA-2015-0224. ente red January 27. 2015 Sir/Madam : Glad ly will we provide mo re inf o rmation toward the above application , specifica lly di recte d at your two requests for informat io n : • The reason s why granting the request would be in th e public inte rest ; that 

### is , how it would benefit t he public as a whol e . Answe r : The type of work we already perform wi th hand - held or pole - mounted cameras is directed toward collecting ha rd-to-measure quantities , such as distances , areas , volumes , and shapes
. Many private businesses and public agencies use this informatio n for frequent bus i ness auditing , expert witnessing , a n d for engineering design
. Th is is true for construction excavations , ope n pit m ining operations , flooding , avalanches. even wh i le they may be happening. This includes , for example , measuring steep walls in excavation sites , tall stock p i les of rocks , an d large sand pi les
. S in ce th ese forma t io n s a re un stable , th ere a re st ri ct OSHA ru les that cont ro l h ow close a wo rke r or f i rst responde r ca n come to them. Unfortun ate ly, these m easureme nts include t h e edges of these formations. This is also t rue fo r structures , (bu i ldings , bridges , etc.) that are facing collapse either due to structural failu re o r d isaster, and which therefo re cannot be approached by workers. Envision , fo r example , a serious situation on a roadway , where heavy traffic , fire , smoke or noxious fumes prevent a closeup v i ew of cond itions
. Therefore it becomes necessary to use remote measurement techniques , l i ke the photogrammetric methods we use . They allow us to take photog raphic images from a distance , and quickly build detailed and precise CAD information that can be used by workers , first responders , and the affected companies/agencies
. Presently we use hand - held or po le-mounted cameras for this , but additional angles are needed fo r greate r accuracy . Po les are not long enough to properly see the top of such Page1of7

# GeoCounsel**•- ~**  31 Manzanita Littleton. CO 80127 USA 303-979-7773 sites , and we still cannot take photography underneath bridges and overpasses and inside threatened buildings , which reduces the information available to responding personnel , and therefore their safety. That is why we have appl ied for the low-flying excemption. We plan to use inexpensive and sl ow-flyi ng UAVs for s u ch risky work , wh ich a ll ows u s to perform such a udi ts w h i le co u ntin g on better perspectives
. The intent is to provide much better and more frequent information to our customers and their personnel , making their operations much safer , while reducing or eliminating the need of regular aircraft traffic over such sites and the corresponding traffic at airports
. • Any additional information , views , or arguments avail a ble to support your request. Answer: We are licensed professionals who are performing serious technical work in support of engineering p lanning and design , mining operations , archeology , architecture , expert witnessing , and structure as- built preparation
. This is not for entertainment , it does not take place in crowded areas , and does not come close to people
. By addi ng ae ri a l i mag es to our data , we furth e r re d uce the n ee d to co m e c lose to ri sky locales
. For example , presently we sometimes have to move close enough (say , 20 feet) to the edge of an excavation wall to collect certain data. With a UAV we can collect these data from a distance of 100 feet or more , which significantly improves job safety for everyone. We have existin g customers who already u se o ur hand-held imagery services , who a llow us to perform unsupervised work on their sites because they know that they can do so . However , they already asked us if we provide UAV service , given the additional detail they provide. and how this reduces their own needs to clamber over stock piles and to come close to risky areas . On the following pages we show a few photographs of the type of work we have already done. With this , we hope to have addressed your request for additional information (copy attached) , and we hope for a positive outcome
. Thank you for your consideration , and for keeping the skies safe
. Sincerely , 

### Geo Counsel, Inc
. Harold Schuch , President Attachment Page 2 of 7

# GeoCounsel**Jt• ~**  31 Manzanita Littleton , CO 80127 USA 303-979-7773 

# ATTACHMENT Sample images of completed projects
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Photogrammetric survey of archeologic site (Dinosaur Ridge) that is too steep to walk on (pole mounted camera). UAV Benefits: • Much better results toward the design of safety measures to protect the visitor public. • Much better information for the planning and construction of structures (roof over site)
. • Much better slope assessment for rock fall abatement measures.

Page 3 of7 - 

### ,

# Geo Counsel 

# Jt•- 31 Manzanita Littleton. CO 80127 USA 303-979-7773

**~** Excavation volume calculation for large open pit excavation site (hand - held camera). Note fresh rock fall at bottom of 100 foot freshly excavated wall , making approach impossible. UAV benefits : • Increased distance from wall while collecting data
. • Better wall definition ( from the top). • Much less impact to mining operations , including avoidance of mining vehicle traffic
. • Saf er m i ning ope rat ions and lessened risk of i njury
.

Page 4 of 7

# .. 

# Geo Counsel •---- 31 Manzanita Littleton
. CO 80127 USA 303-979-7773

Volume audit of 150-foot-high sand pile (hand-held camera). Note gravity-fed slopes that cannot be walked on. UAV benefits: • Significantly reduced need to clamber over the top of unstable stock piles. • Reduced need to approach neighbors for permission to access their land for better photo angles. • Reduced exposure of ground personnel to flying materials (sand). • Improved and safer ability to map utilities near stock piles (note power pole).

Page 5 of7

## ,. 

# GeoCounsel**•- ~**  31 Manzanita littleton. CO 80127 USA 303-979-7773



### 30 Mapping of the roof of Samford Hall , Auburn University, using existing imagery (taken from regular Cessna aircraft with hand - held camera)
. Roof too old to walk on. Resulting engineering drawing is shown below
.



### r--------------------------------- ------ ,



## -- ------------------- ---------------- --J Page 6 of 7I I ' 

# GeoCounsel 

# Jt•- 31 Manzanita Littleton
. CO 80127 USA 303-979-7n3 In all the above cases, the availability of a UAV would have had the following impacts: • Increased certainty in results , and therefore the safety of operations for a significant group of people • Much faster realization of survey results , since UAV deployment and data delivery can be realized in one or two days , and even on-site ; • Reduced foot traffic on the ground within active sites (mi ning , sand , structures), because , after all , hand-held cameras have to be carried by someone ; • Reduced number of airplanes used for this type of imaging tasks ; • Reduced number of low flights over difficult terrain; • Reduced number of flight hours between airports and project sites; and • Reduced traffic of regular aircraft flying at normal flying heights, and reduced number of take-offs and landings that need to be managed by the FAA at regular airports
..

End of reply
.

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