GeoCounsel •--

September 30, 2015 

US Department of Transportation 

Federal Aviation Administration 

Airmen and Airspace Rules Division 

800 Independence Ave. , S.W. 

Washington, DC 20591 

31 Manzanita 

L•ttleton. CO 80127 USA 

303-979-7773 

Re: Public docket for GeoCounsel. Inc .. No. FAA-2015-0224, reply provided 4/8/2015 

Sir/Madam: 

T

On March 20th, 2015 we received your letter asking for further clarification from us (attached). 

mail 

hese clarifications were provided by us on March 23rd (also attached), and sent via regular 

to this same address (no alternative submission method appears mentioned). 

Since then (half a year ago) this additional mail is not mentioned in the docket, and I wish to 

indicate that we did in fact respond within the 30 days stipulated. 

I wish to add that I understand the complexity 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 

and 

for the last 30 years. As such, we have collected terrestrial imagery that long, 

we 

are teaching it. Our difficulty is that we are now seeing large organizations doing work that 

safely did before, just because they can afford hiring a pilot, in spite of the fact that they do 

not know anything about photogrammetry and mapping. We also see a lot of foreign firms 

gain 

starting to position themselves in the US marketplace, since they have had the opportunity to 

experience outside of the US. As a consequence, and as always, only a few small US 

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 regards, 

Harold 

~ Schuch, PE, CP, LSI 

President 

Page 1 of 1 
u.s. Deportment 

of Transportation 

Federal Aviatton 

Administration 

March 23,2015 

Harold C. Schuch, PE, CP, LSI 

GeoCounsel, Inc. 

31 Manzanita 

Littleton, CO 80127 

Dear Mr. Schuch: 

800 Independence 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 Your 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 with the requirements of§ 11.81 (copy enclosed). 

For us to consider the request any further, you must send us all of the following: 

• The reasons why granting the request would be in the public interest; that is, 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 you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption. 
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. If you have any questions or require additional time, you may call (202) 267-9521. 

Sincere,?7 /J . . 

~routmai

~<7/ 

I ~ 

/ . 

Program Analyst, Airmen and 

Airspace Rules Division 

Enclosure 

2 
eCFR - Code of Federal Regulations 

ELECTRONIC CODE OF FEDERAL REGULATIONS 

e-CFR Data is current as of March 2, 2015 

Title 14 __.Chapter I__. Subchapter B __. Part 11 __.Subpart A __. §11.81 

Title 14: Aeronautics and Space 

PART 11-GENERAL RULEMAKlNG PROCEDURES 

Subpart A-Rulemaking Procedures 

§11.81 What information must I include in my petition for an exemption? 

Page l of l 

You must include the following information in your petition for an exemption and submit it to FAA 

as soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information such as a fax 

number, telephone number, or e-mail address; 

(b) The specific section or sections of 14 CFR from which you seek an exemption; 

(c) The extent of relief you seek, and the reason you seek the relief; 

{d) The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole; 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which you 

seek the exemption; 

(f) A summary we can publish in the FEDERAL REGISTER, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description 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=eee 7bb3 943 bc0292a08fb8b9feb89c23&node=se... 3/4/20 15 
GeoCounsel Jt•-

April 8, 2015 

US Department of Transportation 

Federal Aviation Administration 

Airmen and Airspace Rules Division 

800 Independence Ave. , S.W. 

Washington , DC 20591 

31 Manzanita 

Littleton, CO 80127 USA 

303-979-7773 

Re: Public docket for GeoCounsel. Inc .. No. FAA-2015-0224. entered January 27. 2015 

Sir/Madam: 

Gladly will we provide more information toward the above application, specifically directed at 

your two requests for information: 

• The reasons why granting the request would be in the public interest; that is, how it 

would benefit the public as a whole. 

Answer: The type of work we already perform with hand-held or pole-mounted cameras is 

directed toward collecting hard-to-measure quantities, such as distances, areas, volumes, 

and shapes. Many private businesses and public agencies use this information for frequent 

business auditing, expert witnessing, and for engineering design. This is true for 

construction excavations, open pit mining operations, flooding, avalanches. even while they 

may be happening. 

This includes, for example, measuring steep walls in excavation sites, tall stock piles of 

rocks, and large sand piles. Since these formations are unstable, there are strict OSHA 

rules that control how close a worker or first responder can come to them. Unfortunately, 

these measurements include the edges of these formations. This is also true for structures, 

(buildings, bridges, etc.) that are facing collapse either due to structural failure or disaster, 

and which therefore cannot be approached by workers. Envision, for example, a serious 

situation on a roadway, where heavy traffic, fire, smoke or noxious fumes prevent a closeup view of conditions. 

Therefore it becomes necessary to use remote measurement techniques, like the 

photogrammetric methods we use. They allow us to take photographic 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 pole-mounted cameras for this, but additional angles are 

needed for greater accuracy. Poles 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 applied for the low-flying excemption. We plan to use inexpensive and 

slow-flying UAVs for such risky work, which allows us to perform such audits while counting 

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 available to support your request. 

Answer: We are licensed professionals who are performing serious technical work in 

support of engineering planning 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 adding aerial images to our data, we further reduce the need to come close to risky 

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 existing customers who already use our hand-held imagery services, who allow 

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, 

GeoCounsel, 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 

-

, 
GeoCounsel 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. 

• Safer mining operations and lessened risk of injury. 

Page 4 of 7 
.. 

GeoCounsel •---- 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 7 
I 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 (mining, 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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