UNITED STATES

OF AMERICA DEPARTMENT

OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON,

DC Regulatory Docket

**No. ~-----**  IN THE MATTER

OF THE PETITION FOR EXEMPTION

OF: GEOSTABILIZATION INTERNATIONAL,

LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS

OF TITLE

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a)

& (b), 91.7(a), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a)

& (b) CONCERNING COMMERCIAL OPERATION

OF THE DJI PHANTOM

3 UNMANNED AIRCRAFT SYSTEM PURSUANT

TO SECTION

333 OF THE FAA MODERNIZATION

AND REFORM ACT OF 2012 <PUBLIC LAWJ12-95l Submitted

on May 18,2015 GeoStabilization International,
LLC 543 31 Rd Grand Junction,
CO 81504 Tel: (970) 210-6170 Fax: (970) 245-7737TABLE
OF CONTENTS

Page GLOSSARY

OF ABBREVIATIONS ............................................................................................

3 SUMMARY ............................................................................................................................

4 INTRODUCTION

AND INTERESTS

OF PETITIONER ...............................................................

.4 BACKGROUND ......................................................................................................................

4 BASIS FOR PETITION .............................................................................................................

6 NAME AND ADDRESS

OF PETITIONER ...................................................................................

7 THE SPECIFIC SECTIONS

OF 14 C.F.R. FROM WHICH GEOSTABILIZATION INTERNATIONAL,LLC

SEEKS EXEMPTION ...............................................................................

8 THE EXTENT

OF RELIEF GEOSTABILIZATION INTERNATIONAL
SEEKS AND THE REASON GEOSTABILIZATION INTERNATIONAL
SEEKS THE RELIEF

11 THE REASONS WHY GRANTING GEOSTABILIZATION INTERNATIONAL'S REQUEST WOULD BE IN THE PUBLIC INTEREST .............................................................................................................................................

1 3 THE REASONS WHY GRANTING
THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY .............................................................................................................................................

1 7 SUMMARY THAT CAN BE PUBLISHED

IN THE FEDERAL REGISTER .......................................

33 ANY ADDITIONAL INFORMATION, VIEWS,
OR ARGUMENTS AVAILABLE

TO SUPPORT GEOSTABILIZATION INTERNATIONAL

LLC REQUEST .............................................................................................................................................

4 33 CONCLUSION .....................................................................................................................

34 2AGL AOI ATC ATO AV C.F.R. COA FAA FAR GCS NAS NOT AM PIC Section 333 SOP UA UAS VFR VLOS VMC vo
GLOSSARY

OF ABBREVIATIONS Above Ground Level Area of Interest Air Traffic Control Air Traffic Organization Aerial Vehicle Code
of Federal Regulation Certificate

of Authorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station National Airspace System Notice

to Airmen Pilot

In Command FAA Modernization

and Reform Act of 2012 (FMRA) Section 333 Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line of Sight Visual Meteorological Conditions Visual Observer

3SUMMARY GeoStabilization International,

LLC. seeks exemption from the requirements

of 14 C.F.R.
§§ 61.113(a)

& (bL 91.7(aL 91.121, 91.151(a)(1), 91.405(aL 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (bL to operate

an Unmanned Aircraft System pursuant

to Section 333 ofthe FAA Modernization

and Reform Act of 2012 (FMRA). This exemption

will permit GeoStabilization International,

LLC to operate

an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial acquisitions

and research within the National Airspace System (NAS). INTRODUCTION

AND INTERESTS

OF THE PETITIONER GeoStabilization International,

LLC (hereinafter referred

to as "GSI")

is focused

on providing solutions

for utilizing unmanned aircraft

to safely and efficiently collect data that

is precise, accurate,
and timely. GSI's mission

is to use unmanned aircraft

to simplify and increase
the effectiveness

of data collection

for the purpose

of more efficient and effective imaging and classification

of geohazards

in order
to better understand

and design better mitigation strategies for geotechnical hazards throughout

the United States that threaten infrastructure (roads, pipelines, homes, etc) As set forth

in this Petition,
GSI seeks
to commercially operate

its DJI PHANTOM

3 UAS within the NAS for the purpose

of conducting aerial acquisitions

and research
for geotechnical hazards.
BACKGROUND Unmanned Aircraft System:

DJI PHANTOM

3 GSI seeks
an exemption

to operate the DJI PHANTOM

3 UAS, for compensation

or hire within the National Airspace System ("NAS").
The DJI PHANTOM

3 UAS

is comprised

of an 4unmanned aircraft (UA) and

a remote controller.

The DJI PHANTOM

3 UA has

a maximum

net weight

of approximately 1,280g, while having

a diagonal
size (including propellers)
590 mm. The DJI PHANTOM

3 UA
is equipped with four propellers driven
by
a 6000 mAh LiPo 25 battery. The DJI PHANTOM

3 UA that will be operated

by GeoStabilization International,

LLC will be registered

in accordance
with 49 U.S.C. 44103, Registration

of Aircraft,

as well as 14 C.F.R. Part 47, Aircraft Registration.
Figure

1: The DJI PHANTOM

3 UA. BASIS FOR PETITION Petitioner, GeoStabilization International,

LLC pursuant

to the provisions

of the Federal Aviation Regulations

(14 C.F.R.

§ 11.61) and the FAA Modernization

and Reform Act of 2012, 5Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions
the Administrator

to operate the DJI PHANTOM

3 UAS within the National Airspace System (NAS), and for an exemption from the requirements

of 14 C.F.R.
§§ 61.113(a)

& (b), 91.7(a), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b). In consideration

of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, GSI's operation

of the DJI PHANTOM

3 UAS meets the conditions

of Section 333 and will not require

an airworthiness certificate

in accordance
with 14 C.F.R. Part 21, Subpart

H. Therefore,

GSI requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), 91.417(a)

& (b), as these sections
set forth requirements

for maintenance

that only apply
to aircraft with an airworthiness certificate. GSI submits that the requested relief

is proper since
an equivalent level of safety will be ensured
GSI will use its technicians

to perform maintenance, alterations,

or preventive maintenance

on the unmanned aircraft system using the methods, techniques,

and practices prescribed

in the manufacturer's maintenance manual. Furthermore,

GSI will document

and maintain

all maintenance records
for the DJI PHANTOM

3 UAS. Relief from certain requirements

of Section 61.113(a)
and (b), entitled Private pilot privileges
and limitations:
Pilot

in command,

is requested

by GSI to the extent necessary

to a

· qualified

GSI employee

or consultant who has completed

the DJI PHANTOM

3 UAS training,

to conduct the proposed
UAS operations.
GSI's UAS program
will be overseen
and supervised

by employee licensed private pilots, who will provide initial internal GSI-UAS Operations Certification training

as well as ongoing oversight
and continuing education
and training regarding flight and operations protocol consistent with their training.
GSI submits that the conditions

and limitations set forth herein will ensure the safety

of the NAS,
as well as the safety

of persons

or property

on 6the ground. GSI seeks relief from Section
91. 7(a), entitled Civil aircraft airworthiness, because
the DJI PHANTOM

3 UAS does not require

an airworthiness certificate

in accordance
with 14 C.F.R. Part 21, Subpart

H. As such, GSI submits that

it will ensure that the DJI PHANTOM

3 UAS

is in an airworthy condition, prior to every flight,
by determining
that the UAS

is in compliance
with the DJI PHANTOM

3 UAS Operator Manual and that the UAS

is in condition

for

s afe flight. GSI also seeks
an exemption from the requirements

of Section 91.121, entitled Altimeter Settings, because the altitude reporting equipment

of the DJI PHANTOM

3 UAS

is set to a pressure level of zero feet above ground level (AGL), rather than local barometric pressure or field altitude, before each flight.

A level of safety equivalent

to Section 91.121 will be ensured

as the altitude

of the DJI PHANTOM

3 UA will be reported

to air traffic control (ATC)

in feet AGL, and GSI will operate the DJI PHANTOM

3 UA within visual line of sight,

at or below 400 feet AGL. GSI also seeks
an exemption from the requirements

of Section 91.151(a)(1),

Fuel requirements

for flight

in VFR conditions.

GSI submits that safety will not be affected

by terminating flights
of the battery powered

DJI PHANTOM

3 UA after
13 minutes

of continuous operation, with 10 minutes remaining battery power. In accordance
with 14 C.F.R.

§ 11.81, GSI provides
the following information

in support

of its petition
for exemption: A. Name And Address

Of The Petitioner. The name and address

of the Petitioner

is: GeoStabilization International,

LLC 543 31 Rd Grand Junction,

CO 81504 The point
of contact
for this Petition and specific contact information

is as follows: Michelle Urlacher GeoStabilization International,

LLC 543 31 Rd Grand Junction,

CO 81504 Tel: (970) 210-6170

I Fax: (970) 245-7737 7Email:Michelle@gsi.usTHESPECIFICSECTIONSOF14C.F.RFROMWHICHGEOSTABILIZATIONINTERNATIONAL,LLCSEEKSEXEMPTION1.GSISeeksExemptionFromTheRequirementsOfSection61.113(a)And(b).Section61.113,entitledPrivatepilotprivilegesandlimitations:Pilotincommand,subsections(a)and(b)prescribethefollowing,inpart:(a)Nopersonwhoholdsaprivatepilotcertificatemayactasapilotincommand(PIC)ofanaircraftthatiscarryingpassengersorpropertyforcompensationorhire;normaythatperson,forcompensationorhire,actasPICofanaircraft.(b)Aprivatepilotmay,forcompensationorhire,actasPICofanaircraftinconnectionwithanybusinessoremploymentif-(1)Theflightisonlyincidentaltothatbusinessoremployment;and(2)Theaircraftdoesnotcarrypassengersorpropertyforcompensationorhire.2.GSISeeksExemptionFromTheRequirementsOfSection91.7(a).Section91.7,entitledCivilaircraftairworthiness,subsection(a),statesthefollowing:(a)Nopersonmayoperateacivilaircraftunlessitisinanairworthycondition.3.GSISeeksExemptionFromTheRequirementsOfSection91.121.Section91.121,entitledAltimetersettings,subsection(a),statesthefollowing,inrelevantpart:(a)Eachpersonoperatinganaircraftshallmaintainthecruisingaltitudeorflightlevelofthataircraft,asthecasemaybe,byreferencetoanaltimeterthatisset,whenoperating--(1)Below18,000feetMSL,to--(i)Thecurrentreportedaltimetersettingofastationalongtherouteandwithin100nauticalmilesoftheaircraft;(ii)Ifthereisnostationwithintheareaprescribedinparagraph(a)(1)(i)ofthissection,thecurrentreportedaltimetersettingofanappropriateavailablestation;or8(iii)

In the case of an aircraft not equipped with

a radio, the elevation of the departure airport

or an appropriate altimeter setting available before departure; 4. GSJ Seeks Exemption From The Requirements

Of Section 91.151(a)(1). Section 91.151, entitled Fuel requirements

for flight

in VFR conditions, subsection (a)(1), states the following: (a) No person may begin

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
15 minutes[.] 5. GSI Seeks Exemption From The Requirement

Of Section 91.40S(a). Section 91.405, entitled Maintenance required, subsection

(a), states the following:
Each owner

or operator

of an aircraft- (a) Shall have that aircraft inspected

as prescribed

in subpart

E of this part and shall between required inspections, except

as provided

in paragraph

(c) ofthis section, have discrepancies repaired

as prescribed

in part 43 of this chapter[.] 6. GSI Seeks Exemption From The Requirements

Of Section 91.407(a)(1). Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding,

or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding,

or alteration unle ss-- (1)
It has been approved

for return
to service

by a person authorized under

§ 43.7ofthis chapter[.] 7. GSI Seeks Exemption From The Requirements

Of Sections 91.409(a)(1}

And 91.409(a)(2}. Section 91.409, entitled Inspections, subsection

(a), states the following: Except

as provided

in paragraph

(c) of this section,

no person may operate

an aircraft 9unless, within the preceding

12 calendar months,

it has had; (1) An annual inspection

in accordance
with part 43 ofthis chapter and has been approved

for return
to service

by a person authorized
by§ 43.7 of this chapter;

or (2) An inspection

for the issuance

of an airworthiness certificate

in accordance with part 21 of this chapter. 8. GSI Seeks Exemption From The Requirements

Of Sections 91.417(a)
And 91.417(b). Section 91.417, entitled Maintenance records, subsections

(a) and (bL state the following:
(a) Except for work performed

in accordance
with §§ 91.411 and 91.413, each registered owner

or operator shall keep the following records
for the periods specified

in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance,

and alteration
and records

of the 100-hour, annual, progressive,

and other required

or approved inspections,

as appropriate,

for each aircraft (including
the airframe)
and each engine, propeller, rotor, and appliance

of an aircraft. The records must include-- (i) A description

(or reference

to data acceptable

to the Administrator)

of the work performed;

and (ii) The date of completion

of the work performed;

and (iii) The signature,
and certificate number

of the person approving

the aircraft for return

to service. (2) Records containing

the following information: (i) The total time

in service

of the airframe, each engine, each propeller, and each rotor. (ii) The current status
of life-limited parts
of each airframe, engine, propeller, rotor, and appliance

. (iii) The time since last overhaul

of all items installed

on the aircraft which are required

to be overhauled

on
a specified time basis. (iv) The current inspection status
of the aircraft, including
the time since 10the last inspection required

by the inspection program under which the aircraft and its appliances

are maintained. (v) The current status
of applicable airworthiness directives (AD) and safety directives including,

for each, the method

of compliance,

the AD or safety directive number and revision date.

If the AD or safety directive involves recurring action, the time and date when the next action

is required. (vi) Copies

of the forms prescribed
by§ 43.9(d)

of this chapter
for each major alteration

to the airframe
and currently installed engines, rotors, propellers,

and appliances. (b) The owner

or operator shall retain the following records
for the periods prescribed: (1) The records specified

in paragraph (a)(l) ofthis section shall be retained until the work

is repeated

or superseded

by other work
or for

1 year after the work

is performed. (2) The records specified

in paragraph (a)(2)
of this section shall be retained
and transferred
with the aircraft

at the time the aircraft

is sold. (3) A list of defects furnished

to a registered owner

or operator under§ 43.11
of this chapter shall be retained until the defects are repaired and the aircraft

is approved

for return

to service. B. The Extent
Of Relief GSI Seeks And The Reason
GSI Seeks The Relief. 1. Extent

of Relief GSI Seeks And The Reason GSI Seeks Relief From Section 61.113(a) And (b). Relieffrom Section 61.113(a)
and (b), entitled Private pilot privileges
and limitations:
Pilot in command,

is requested

to the extent necessary

to allow

a PIC who has completed

the Phantom 3 UAS training requirements,

to conduct the proposed
UAS flight operations

for compensation. This relief

is requested since the limitations

set forth

in Section 61.113(a)
and (b) state that

a private pilot may, for compensation

or hire, act as PIC of an aircraft

in connection
with any business

or employment

if: (1) The flight

is only incidental

to that business

or employment;

and The aircraft does not carry passengers

or property
for compensation

or hire. 11Assetforthmorefullybelow,GSIsubmitsthatanequivalentlevelofsafetywillbemaintainedbecausenoPICwillbeallowedtooperatetheDJIPHANTOM3UASunlessthatPIChasdemonstrated,throughtheDJIPHANTOM3UAStrainingrequirements,thatthePICisabletosafelyoperatetheDJIPHANTOM3UASinamannerconsistentwiththeoperationsspecificationsasdescribedinthisexemption,includingevasiveandemergencymaneuvers,aswellasmaintainingappropriatedistancesfrompeople,vessels,vehiclesandstructures.Further,GSIsubmitsthatallflightsoftheDJIPHANTOM3UAS,conductedbythePICpursuanttothegrantofthisPetitionwillbe:(1)incidentaltoGSI'sbusiness;and(2)notcarrypassengersorpropertyforcompensationorhire.2.ExtentofReliefGSISeeksAndTheReasonGSISeeksReliefFromSection91.7(a).RelieffromSection91.7(a),entitledCivilaircraftairworthiness,isrequestedtotheextentrequiredtoallowGSItodeterminethattheDJIPHANTOM3UASisinanairworthyconditionpriortoeveryflightbyensuringthattheUASisincompliancewiththeDJIPHANTOM3UASOperatorManualandthattheUASisinconditionforsafeflight.Copiesofthemanuals,whichcontainproprietaryinformation,areattachedheretoasExhibitsA.respectively,andaretobeheldinaseparatefilepursuantto14C.F.R.§11.35(b).GSIseekstherequestedreliefbecausetheDJIPHANTOM3UASdoesnotrequireanairworthinesscertificateinaccordancewith14C.F.R.Part21,SubpartH.Therefore,GSIwillensurethattheDJIPHANTOM3UASisinanairworthyconditionbaseduponitscompliancewiththeoperatingdocumentspriortoeveryflight,andasstatedintheconditionsandlimitationsbelow.3.ExtentOfReliefGSISeeksAndTheReasonGSISeeksReliefFromSections1291.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l)

& (a)(2), and 91.417(a)

& (b) only apply
to aircraft with an airworthiness certificate,

GSI requests relief from these Sections because the DJI PHANTOM

3 UAS does not require

an airworthiness certificate.

As set forth more fully below, the DJI PHANTOM

3 UAS meets the conditions

of Section 333 for operation without an airworthiness certificate. Accordingly,

GSI will use technicians

to perform maintenance, alterations,

or preventive maintenance

on the unmanned aircraft system using the methods, techniques,

and practices prescribed

in the manufacturer's maintenance manual. Furthermore, GSI will document
and maintain

all maintenance records
for the DJI PHANTOM

3 UAS. C. The Reasons Why Granting GSI's Request Would

Be In The Public Interest; That
Is, How

It Would Benefit The Public
As A Whole. Granting
the present Petition will further the public interest

by allowing
GSI to safely, efficiently,

and economically perform aerial acquisitions

and research within the NAS, commercially,

in support

of researching geotechnical hazards, which threaten public and private infrastructure. Additionally,

use ofthe
DJI PHANTOM

3 UAS will decrease congestion ofthe NAS, reduce pollution,
and provide significant benefits

to the economy. Notably, the benefits

of the proposed operation

of the DJI PHANTOM

3 UAS will be realized without implicating

any privacy issues.

1. The Public Will Benefit From The Aerial Acquisition
And Research Performed. GSI submits this Petition

to commercially operate the DJI PHANTOM

3 UAS and perform aerial acquisition

and research within the NAS,

in support

of government entities, transportation departments, agriculture, scientific studies, wildlife monitoring, forestry, mining, and the oil 13and gas industries.

The DJI PHANTOM

3 UAS will provide safe, efficient,
and economical aerial acquisition

and research operations

to further identify geotechnical hazards

of which are critical to the well-being

of the general public. The specific operations
that GSI will perform with the DJI PHANTOM

3 UAS demonstrate how the requested exemption

will directly benefit the above-referenced industries

and the public. The DJI Phantom

3 will be used to reach previously inaccessible areas
to image and map potential geotechnical

risks to the public. The DJI Phantom
will give our crew the safe approach

of being able to monitor potential landslides, rockfall areas and other potential geohazard situations that are

a potential
risk to the public. 2. The Public Will Benefit From Decreased Congestion

Of The NAS. The DJI PHANTOM

3 UA
is battery powered
and serves

as a safe, efficient,
and economical alternative

to the manned aircraft traditionally utilized

to obtain aerial imagery.

By reducing
the amount

of manned aircraft needed

to perform aerial acquisitions,

an exemption allowing the use of a DJI PHANTOM

3 UAS would reduce the amount

of manned aircraft

in the NAS, reduce noise and air pollution,

as well as increase the safety
of life and property

in the air and on the ground. Furthermore,

by reducing
the number

of manned aircraft operating

in the NAS, congestion around airports caused

by arriving and departing aircraft

will be reduced.
The DJI PHANTOM

3 UA does not require

an airport

to takeoff

or land. Likewise,

a reduction

of manned aircraft conducting aerial survey missions would result

in fewer aircraft that must be handled

by air traffic control during the ground, takeoff, departure, arrival, and landing phases

of flight operations.

3. The Public Will Benefit From The Safety And Efficiency

Of The DJI PHANTOM

3 UAS.

14ConductingaerialacquisitionswiththeDJIPHANTOM3UAS,insteadofmannedaircraft,willgreatlybenefitthepublicbydrasticallyreducingthelevelsofairandnoisepollutiongeneratedduringtraditionalaerialsurveyflightoperations.Byusingbatterypowerandanelectricmotor,theDJIPHANTOM3UASproducesnoairpollution,andisthemostviableenvironmentallyconsciousalternativetothecabinclass,sixcylinderinternalcombustiontwinengineaircraftthataretypicallyutilizedforaerialacquisitions,whileburningapproximately20-30gallonsperhourofleadedaviationfuel.TheDJIPHANTOM3UA,whilereducingthecarbonfootprintofaerialacquisitions,alsoeliminatesnoisepollution,asitsbatterypoweredelectricmotorisbarelyaudibleduringthetake-offphase,andcannotbeheardwhenoperatingmorethan100feetabovegroundlevel.ByusingtheDJIPHANTOM3UAStoperformaerialacquisitions,thesubstantialrisktolifeandpropertyintheairandontheground,whichisusuallyassociatedwithtraditionalmannedaircraftflightoperations,willbesubstantiallyreducedorcompletelyeliminated.Asidefromthelackofaircrewmemberslocatedonboardtheaircraft,theDJIPHANTOM3UA(weighingapproximately1,280gatitsmaximumgrossweightwithaDiagonalSize590mm,withnofuelonboard),haslessphysicalpotentialforcollateraldamagetolifeandpropertyontheground,andintheair,comparedtothemannedaircraftthattypicallyconductaerialacquisitions(weighingapproximately6,500poundswithawingspanofapproximately40feet,alengthof34feet,andafuelcapacityof180gallons).Furthermore,byusingtheDJIPHANTOM3UAStoperformaerialacquisitionsofpotentialgeotechnicalriskstothepublicweareabletoquickly,andefficientlyaccessemergencysituationsanddevelopadesign-buildapproachtoremedysuchgeohazardrisks.154. Performing Aerial Acquisition Operations With The DJI PHANTOM

3 UAS Will Benefit The Economy. In addition

to being safe and efficient,
the DJI PHANTOM

3 UAS

is also an economical alternative

to using manned aircraft

to conduct aerial acquisitions.

As such, operation

of the DJI PHANTOM

3 UAS will allow United States based companies,

like GSI, to remain competitive and contribute

to growth

of the U.S. economy. Specifically,
with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded fuels, U.S. owned and operated companies must adopt new and alternative technology

in order
to remain competitive. Operating

the battery powered

DJI PHANTOM

3 UAS

is one such technology
that not only allows companies greater operational flexibility compared

to manned aircraft, but provides such flexibility without the high operational
cost of a traditional manned aircraft.

By operating
the DJI PHANTOM

3 UAS, companies
such
as GSI can remain competitive and profitable,

and therefore provide greater job stability

to employees

and contractors, which will ultimately contribute

to growth

of the U.S. economy. Improved financial performance

of U.S. companies, through commercial

use ofthe
DJI PHANTOM

3 UAS, provides

a stable workforce
that increases consumer spending; improves local, state, and federal tax revenues; and allows companies

to invest

in research and development

in order
to remain competitive both

in the United States and abroad. 5. There Are No Privacy Issues. Like the manned aerial acquisition flight operations
that have been conducted

for decades,
the proposed operation

of the DJI PHANTOM

3 UAS will not implicate
any privacy issues.

16Specifically,

the DJI PHANTOM

3 UAS will be operated

in accordance
with operating limitations set forth herein and the Federal Aviation Regulations, including
the minimum altitude requirements

of 14 C.F.R.

§ 91.119. D. 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 GSI Seeks Exemption. 1. Reasons Why The OJI PHANTOM

3 UAS Meets The Conditions

Of The FAA Modernization

and Reform Act of 2012 (FMRA) Section 333. In consideration

of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, GSI's operation ofthe
DJI PHANTOM

3 UAS meets the conditions

of FMRA Section 333, and will not require

an airworthiness certificate

in accordance
with 14 C.F.R. Part 21, Subpart

H. Section 333 provides authority

for UAS to operate without airworthiness certification and sets forth requirements

for considering whether

a UAS will create

a hazard

to users ofthe NAS or the public,

or otherwise pose

a threat

to national security. Specifically, FMRA Section 333 states the following,

in part: (a) In Generai.--Notwithstanding

any other requirement

of this subtitle, and not later than 180 days after the date of enactment

of this Act, the Secretary

of Transportation shall determine

if certain unmanned aircraft systems may operate safely

in the national airspace system before completion

of the plan and rulemaking required

by section 332 of this Act or the guidance required

by section 334 of this Act. (b) Assessment

of Unmanned Aircraft Systems.--ln making the determination under subsection

(a}, the Secretary shall determine,

at a minimum-- (1)

) which types of unmanned aircraft systems,

if any, as a result of their size, weight, speed, operational capability, proximity

to airports and populated areas, and operation within visual line of sight do not create

a hazard

to users of the national airspace system

or the public
or pose

a threat

to national security; and

17(2))whetheracertificateofwaiver,certificateofauthorization,orairworthinesscertificationundersection44704oftitle49,UnitedStatesCode,isrequiredfortheoperationofunmannedaircraftsystemsidentifiedunderparagraph{1).(c)RequirementsforSafeOperation.--JftheSecretarydeterminesunderthissectionthatcertainunmannedaircraftsystemsmayoperatesafelyinthenationalairspacesystem,theSecretaryshallestablishrequirementsforthesafeoperationofsuchaircraftsystemsinthenationalairspacesystem.Inseekingthisexemption,GSIsubmitsthattheDJIPHANTOM3UAScanoperatesafelyintheNASpursuanttoFMRASection333,asdemonstratedby:(a)thesafeoperationalhistoryandcurrentuseoftheDJIPHANTOM3UASintheNAS;(b)thecharacteristicsoftheDJIPHANTOM3UAS;(c)theprivatepilotcertificationrequirement;and(d)thespecificoperatinglimitations.a.TheOJIPHANTOM3UASHasAProvenHistoryOfOperationInTheNAS.TheDJIPhantom3utilizesfour(4)counter-rotatingpropellerspairedoppositelytoeachotherforbalance,controlandstability.ThetotalspanoftheUAS6590mmincludingpropellers,allowingforstableflightorlandingevenwiththesuddenonsetofdetrimentalenvironmentalconditions.TheUASsmaximumweight(includingbattery,propellers)of13Kg.Theapplicant'sUASisdesignedtohoverinplacetocapturephotographicdataandthenoperateatlessthan50knotmaximumspeedtothenextpointofInterest.Theyarecapableofverticalandhorizontaloperationsbut,inpractice,isoperatedonlywithinunaidedVLOSofthePIC.InadditiontothePIC,theApplicantemploysaspotter(VOSrole)andatechnician(secondaryVOSandonsitepersonnelliaison)whicharewithinverbalcommunicationrange.IntheeventoflossofvisualoftheUASthePJCcanchangetheflightcontrolsfromCartesian(X,Y,Z.)basedcontrolstoradial(r,a,h)basedcontrolswhichallowsthePICtoutilizeonecontrolleraxistorecalltheUAStothePIC'spositionwithoutconcerntothecurrentheadingoftheUASs.TheUASsalsohaveaReturn-to-HomefeaturethatwillallowtheUAStoreturntothePIC'slocationinthecaseoftheUASbsingsignaltothePIC,orfthePICinitiatestheReturn-toHomeprocedure.IntheeventoflossofsightoftheUASsintoanareacontaininghazardsorpossiblehazards,thespotterhasaheads-up-displaycontainingalivevideofeedwhichcanbeusedtolocatetheUASwhileitmaintainsitspositionhovermode.TheUAShasdemonstrateditsabilitytomaintainitspositionbyGPS,SONAR,andOpticalflowcamerawithanaccuracyof+/-lOcmverticaland+1-1mhorizontal.Alloftheapplicant'sUAS'sutilizeLiPo(lithiumpolymer)batterybasedpowersources,decreasingsafetyrisksfrommoreeasilycombustible,fuelbased,powersources.Flighttimesgenerallylastbetween18eight (8) to ten {10} minutes allowingthe
staff to work with small areas per phase. The maximum flight time without payload

is approximately

25 minutes; however practical safe operation limits this to l5 minutes

to gve ample time to control the UASs to
a safe landing zone. The applicant further restricts flight time by to operating the UASs with less than twenty five percent (25%) battery capacity. b. The Specifications

Of The DJI PHANTOM

3 UAS Demonstrate

Its Safe Characteristics. The DJI PHANTOM

3 UAS does not create

a hazard

to users
of the NAS or the public,

or otherwise pose

a threat

to national security considering

its size, weight, speed, and operational capability. Technical Specifications

Of The DJI PHANTOM

3 UAS. Aircraft Weight (Including Battery And Propellers) 1280g Diagonal Size (Including Propellers) 590mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy Vertical:

+/- 10cm Horizontal:

+/- 1m Max Speed 16 m/s (ATTI mode,
no wind) Max Altitude Above Sea Level 6000m Operating Temperature ooc to 40°C GPS Mode GPS/GLONASS Camera Sensor Sony EXMOR 1/2.3" Effective pixels: 12.4
M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus

at oo 19ISORange100-3200(video)100-1600(photo)ShutterSpeed8s-1/8000sImageMaxSize4000X3000StillPhotographyModesSingleShotBurstShooting:3/5/7shotsAutoExposureBracketing(AEB):3/5BracketedFramesat0.7EVBiasTime-lapseVideoRecordingModesPhantom3ProfessionalUHD:4096x2160p24/25,3840x2160p24/25/30FHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60Phantom3AdvancedFHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60SupportedSDCardTypesMicroSDMaxcapacity:64GB.Class10orUHS-1ratingrequiredMaxBitrateOfVideoStoragePhantom3Professional60MbpsPhantom3Advanced40MbpsSupportedFileFormatsFAT32/exFATPhoto:JPEG,DNGVideo:MP4,MOV(MPEG-4AVC/H.264)OperatingTemperatureoocto40°CGimbalControllableRangePitch-90°to+30°Stabilization3-axis(pitch,roll,yaw)20VisionPositioningMaxVelocityLessthan8m/s(when2 maboveground)AltitudeRange30cm-300cmOperatingRange30cm-300emOperatingEnvironmentSurfacewithclearpatternandadequatelighting(Lux>15)RemoteControllerOperatingFrequency2.400GHz-2.483GHzMaxDistance2000m(outdoorsandunobstructed)VideoOutputPortUSBOperatingTemperature0°C-40°CBattery6000mAhLiPo2SMobileDeviceHolderFortabletorphoneReceiverSensitivity(1%PER)-101dBm±2dBmTransmitterPower(EIRP)FCC:20dBmCE:16dBmWorkingVoltage1.2A@7.4VBatteryChargerVoltage17.4vRatedPowerPhantom3Professional100WPhantom3Advanced57WIntelligentFlightBatteryCapacity4480mAh21Voltage 15.2


## v Battery Type LiPo 4S Energy 68Wh Net Weight 365

g Max Flight Time Approximately

23 minutes Operating Temperature -10oC
to 40oC Max Charging Power 100W App



## I Live View MobileApp DJI Pilot EIRP 100mW Live View Working Frequency 2.4GHz ISM Live View Quality 720P

@ 30fps (depending

on conditions

and mobile device) Latency 220ms (depending

on conditions
and mobile device) Required Operating Systems iOS 8.0 or later Android 4.1.2
or later Recommended Devices iOS: iPhone
Ss, iPhone

6, iPhone

6 Plus, iPad Air, iPad Air Wi-Fi +Cellular,
iPad mini
2, iPad mini

2 Wi-Fi + Cellular, iPad Air 2, iPad Air
2 Wi-Fi +Cellular,
iPad mini
3, and iPad mini

3 Wi-Fi +Cellular.
This app

is optimized

for iPhone
Ss, iPhone

6, and iPhone

6 Plus Android: Samsung

55, Note

3, Sony Xperia Z3, Google Nexus 711, Google Nexus

9, Mi 3, Nubia
Z7 mini *Support

for additional Android devices available

as testing and development continues 

## 22Phantom

3 Flight System: Maintaining complete control and stability

in the air
is crucial

to every successful flight. The Phantom

3 contains the best and newest
OJI flight technology, giving you an enjoyable experience through full, automatic intelligent support. These systems help you fly better and safer, and are designed

so that you never have to think about them at all. Main Controller: Processing
and analyzing flight data
in real time takes serious power. The Main Controller

is the control center

of your Phantom

3. It collects data from the entire system, including motor speed, GPS location, your command inputs, and data from automatic sensors, and analyzes

it all to tell your Phantom

3 exactly how to behave

at any given moment. GPS: Never lose track
of your Phantom

3. GPS and GLONASS combine

to make the Phantom 3 completely aware

of its location and relation

to you.

It hovers more precisely, moves more accurately,

and locks onto satellites faster. With the new availability

of GLONASS, a minimum

of 36 satellites
are available

to you around the world

at any time. Through
the DJI Pilot app, you can track its location

on
a live map, and record your takeoff point
so you can bring

it back to you with the tap of a finger. IMU: Keeping your Phantom

3 stable and flying the way you want

it to is the Inertial Measurement
Unit. Inside

is a 6-axis gyroscope
and an accelerometer

that records and relays even the smallest changes

in tilt and movement.

It is constantly

at work, detecting
the slightest changes and compensating

for them automatically. ESCs Motor speed

is critical

to flight, and each motor

is managed individually

by the Electronic Speed Controllers.
ESCs not only relay vital motor speed information

to the Main Controller, they also send commands
back to the motors based
on your input. This constant communication
keeps your Phantom stable

in flight, and also helps you achieve any flight movement, from gentle pans to rapid acceleration. 23c.FlightsWillBeConductedPursuantToSpecificOperatingLimitations.Inseekingthisexemption,GSIproposestocommerciallyoperatetheDJIPHANTOM3forthespecialpurposeofconductingaerialacquisitionswithintheNAS,pursuanttothefollowingspecificoperatinglimitations:Asmuchasispossible,theapplicantattemptstohavearedundancyinexpertiseandskillsetsrelatedtooperationsoftheUASs.PilotinCommand(PIC)•PilotingtheUAS.Thiswilllnclude:TakeoffNormalflightFlightduringemergencyproceduresLanding•AssemblingtheUAS•Performspre-flightchecksofthefirmware•Performspre-flightchecksofthehardware•PerformspreflightchecksofthesoftwareSpotter•Relaysnotableflightparameterssuchash:ileystrength,andmetricsiantheUAS.•Primarycommunicationbetweenpilotandon-sitesafetypersonnel•Willholdphysicaldocumentsrelatedtocurrentflight•Performspre-flightchecksofthedatacollectionequipment•Monitorsgroundandgreaterabove-groundenvironmentforsafetyconcernsTechnician•AssemblingtheUASPreformspre-flightchecksofthehardware•Preformspre-flightchecksofthesoftware24• Secondary Communication

link between pilot and on-site safety personnel • Relays
to the spotter and records notable flight parameters metrics from the UAS Monitors ground and greater above-ground environment

for safety concerns Ill. Pre-Flight Checklist A. Before power

is applied • Check for physical damage and any missing hardware • Check
all electronics present and connected/ check cord connections

are tight. • Confirm

all batteries
are charged • Check
all rotors and moving parts for debristhat would prevent proper operation • Check weather patterns the night beforehand. • Check
all data collection equipmentfor proper nstallation/operation • Checkalldatacollectionequipmentforissuesthat

would impact safe operations offlight package. B. After Power Source Applied - Confirm proper power reading

of battery • Run hardware based systems check Run software based systems check • Check flight LED array • Confirm proper radio link to flight controller • Confirm proper radio link to data collection device controller • Confirm secondary controller connection

to UAS on board flight controller • Confirm waypoints

and geofences

are accurate

to current flight • Confirm desired behavior

of emergency

fail safes • Check with on site safety personnel

for any changes

in goals/flight
path IV. Flight-time Checklist • Check with on-site personnel

for safe flight area for first flight • Record relevant metrics inflightlog • Check for ground hazards

at home-base

and rectify Confirm more than eight (8) satellite GPS lock • Confirm Initial state
of controllers Initialize rotors and check for proper operation Perform controlled flight
to hover mode approximately

five (5) 25metersabovetheground•Checklandinggearflightmode(up)operation•Performcontrolledmulti-axisrollproceduretocheckforproperorchestratedrotoroperation•Performcontrolledmulti-axis(ifapplicable)controlprocedureofdatacollectionpackage•Switchcontrollermodetoradialbased,checkforproperoperationtomaximumfive(5)meterdistancetoPICandreturntoInitialposition•ReturnUAStonormalorientationPerformcontrolledflighttohovermodeone(1)meterabovetheground•Checklandinggearlandingmode(down)operation•LandtheUASandcheckforproperde-initializationofrotorsPerformcontrolledflighttohovermodeapproximatelyfive(5)metersabovetheground•Checklandinggearflightmode(up)operation•OperateUA5toeachwaypoint/positionuntilmaximumflighttimeisachievedReturnUAStonormalorientation•Performcontrolledflighttohovermodeapproximatelyone(1)meterabovetheground•Checklandinggearlandingmode(down)operation•LandtheUASandcheckforproperde-initializationofrotors•Removepowertotheflightpackage•Removepowertothedatacollectionpackage•Removepowertocontrollers•CompleteflightlogV.StandingProcedures•ThePilot,Spotter,andTechnicianwillbetheonlymembersintheforwardfrghtarea.On-sitepersonnelwillbewithinverbalrangebehindthePIC,Spotter,andTechnician•Themaximumpowerusedtocontrolthedeviceissoftlimitedto75%inordertomaintainpoweririreserveforunforeseenconditions•Flighttimeislimitedtol5minutesandgoaIswillbeplannedinphasestobeaccomplishedduringthistime•Flighttimeislimitedtoreserving25%batterypower•Flightheightissoftlimitedtovisibleandunaidedlineofsight(VLOS)1andhardlimitedto400ft.AGL•Flighttimeislimitedtooperationinsafeenvironmentalconditions26• Flight staff will maintain proximity

so as to be in !Ear verbal range • The PICwill announce

all movements

to staff and on-site staff so that non-PIC staff members

can identify possible safety concerns before operation ofthe UAStothe nextwaypointor position • All regular and irregularoperationsare notedwithtimestamps, relevant UAS metrics and corrective action procedures {CAP) that are performed
o Note:AII irregular behavior have root cause analysis performed before UASoperation 6resumed VI. Emergency procedures Loss of Remote Signal o The flight package features

an optional enhanced fail-safe which returnsthe UAStothe home basewaypointviathesame

path taken
to point of lost signal o The UAS will then perform

a hover overthis waypoint
and then perform

a controlled landing • LossofGPSsignal
o The system will operate

in GPS mode with three
(3) satellites o At brofthree (3)GPSsatellites, manual mode can be activated ofthe flight package
can be programmed

to perform

a controlled landing to the home base waypoint. o Ground based height ranging

is performed

by separate system and so loss of GPS will not impact controlled landing

n a safe manner Loss of Ground Control Software o This will not affect operation

of the flight. The unit will be piloted

to a safe landing area then landed

so that examination

of the link can be made. 2. Reasons Why An Exemption From The Requirements

Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. GSI submits that an equivalent level of safety established

by Section 61.113(a)
and (b) will be maintained because

no PIC will be allowed

to operate the DJI PHANTOM

3 UAS unless that PIC has demonstrated, through
the DJI PHANTOM

3 UAS training, that the PIC
is able to safely operate the DJI PHANTOM

3 UAS

in a manner consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from 27people, vessels, vehicles and structures. Considering
GSI's proposed area of operations

and the operating limitations

set forthabove; the parallel nature

of private pilot aeronautical knowledge requirements

to those
of commercial
pilot requirements

(See Exemption

No. 11062); and the airmanship skills necessary to safely operate the DJI PHANTOM

3 UAS, GSI submits that the additional manned airmanship experience

of a commercially certificated
pilot would not correlate

to the airmanship skills necessary

for GSI's specific proposed flight operations. As in Exemption

No. 11109, GSI will not allow any PIC to operate the DJI PHANTOM

3 UAS unless that PIC has demonstrated through the DJI PHANTOM

3 UAS training requirements that the PIC

is able to safely operate the DJI PHANTOM

3 UAS

in a manner consistent
with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

283.ReasonsWhyAnExemptionFromTheRequirementsOfSection91.7{a)WouldNotAdverselyAffectSafety.ThelevelofsafetyestablishedbySection91.7(a)willbemaintainedbecausepriortoeveryflight,GSIwillensurethattheDJIPHANTOM3UASisinanairworthyconditionandsafeforflightbasedupontheDJIPHANTOM3UAS'scompliancewithitsoperatingdocumentsandasstatedintheconditionsandlimitationsherein.4.ReasonsWhyAnExemptionFromTheRequirementsOfSection91.121WouldNotAdverselyAffectSafety.TheequivalentlevelofsafetyestablishedbySection91.121willbemaintainedbecausethealtitudeoftheDJIPHANTOM3UAwillbereportedtoairtrafficcontrol(ATC)infeetabovegroundlevel(AGL),andGSIwilloperatetheDJIPHANTOM3UAwithinvisuallineofsight,atorbelow400feetAGL.Priortoeachflight,azeroaltitudeinitiationpointisestablishedatgroundlevel.29The FAA has previously granted relief from Section 91.121 specific

to UAS,

in circumstances similar,

in all material respects,

to those presented herein. 5. Reasons Why An Exemption From The Requirements

Of Sections 91.151(a)(l), 91.405(a), 91.407(a)(l), 91.409{a)(l)

& (a)(2), And 91.417(a)

& (b) Would Not Adversely Affect Safety. In seeking this exemption,

GSI submits that the level of safety with regard

to the regulatory maintenance

and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), 91.417(a)

& (b) will be met because GSI, will use its trained technicians

to perform maintenance, alterations,

or preventive maintenance

on the unmanned aircraft system using the methods, techniques,

and practices prescribed

in the manufacturer's maintenance manual. Furthermore,

GSI will document

and maintain

all maintenance records
for the DJI PHANTOM

3 UAS. The Applicant contends that operation

of its UASs will not ·"create

a hazard

to users
of the national airspace system

or the public."

As stated

in ll2 P.L 95

§ 333(b). Given the diminutive size and weight

of the UASs, combined with their operation

in rordoned
off and well-controlled areas. The applicant's UASs falls within congress's contemplated safety zone. The applicant's UASs have an established safety record bolstered

by multi-point preflight checklists, awareness

of their surroundings

and intimate knowledge

and behavior ofthe UASs platform

In many weather conditions.
This safety record and implemented operational practices demonstrates

an awareness

of public safety. The Applicant's operations routinely provide

a level of safety
at least equal
to existing rules and

in nearly every instance, exceeds existing rules. The applicant's UASs does not and cannot operate

on or near airports and generally

has only operated

its fleet on private grounds with cordoned

off area

s or areas under the control

of the property owner/ client with assistance

by safety officials employed

by the business. The applicant determines

the areas needed

to fulfill the clients goals and only operates

its UASs ilthese flight zones and only

in compliance
with well-regarded safety protocols

set forth initially

by the RC UAS trade and hobby groups and recently codified

by relevant FARs. The applicant

is standartiza:irnthefollowing
practices

to ensure safe operations

of its UASs safe; Work with on-site personnel

to plan the flight goals. Work with on-site personnel

to restrict access

to non-essential persons. 30OperationsbyunaidedVLOSoperationsonly.Operationphasesofl5minutesinlength.Operationtominimal25%batterypower.OperationofdevicetoGPSaidedreadoutofnomorethan400feetAGL.Numerouspre-programmedfail-safesthatensurespecificbehaviorperissue.Threemainrolessupplementedbyon-sitesafetypersonnel.Employcontrolledlifecyclemanagementofcomponentstoguardagainstfailures.Preformasitecheckday(s)beforeflighttoidentifypotentialissues.SubscribetorelevantlocalandsafetyalertsExpertlychoosedatacollectioninstrumentsandaccessoriestominimizeflightrequirementsorexpertise.SatisfactionofthecriteriaprovidedinSection333oftheReformActof2012-size,weight,speed,operatingcapabilities,proximitytoairportsandpopulatedareasandoperationwithinvisuallineofsiteandnationalsecurity-providemorethanadequatejustificationforthegrantoftherequestedexemptionsallowingcommercialoperationoftheapplicant'sUASsinconductingaerialacquisitionsandresearchforgeotechnicalhazards.6.TheFAAMayPrescribeAnyOtherConditionsForSafeOperation.InaccordancewithSection333oftheFAAModernizationandReformActof2012(FMRA)and14C.F.R.§21.16entitledSpecialConditions,GSIrequeststhattheFAAprescribespecialconditionsfortheintendedoperationoftheDJIPhantom3,whichcontainsuchsafetystandardsthattheAdministratorfindsnecessarytoestablishalevelofsafetyequivalenttothatestablishedby14C.F.R.Part21,SubpartH,and14C.F.R.§§91.151(a)(1),91.405(a),91.407(a)(1),91.409(a)(1)&(a)(2),and91.417(a)&(b).Suchspecialconditionswillpermit31safeoperationoftheunmannedaircraftforthelimitedpurposeofconductingaerialacquisitionswithintheNAS.FMRASection333setsforththerequirementsforconsideringwhetheraUASwillcreateahazardtousersoftheNASorthepublic,orotherwiseposeathreattonationalsecurity;andfurther,providestheauthorityforsuchUAStooperatewithoutairworthinesscertificationinaccordancewithanyrequirementsthatmustbeestablishedforthesafeoperationoftheaircraftsystemsintheNAS.Likewise,theAdministratormayprescribespecialconditionspursuantto14C.F.R.§21.16,foroperationoftheOJIPhantom3,sincetheairworthinessregulationsof14C.F.R.Part21donotcontainadequateorappropriatesafetystandards,duetothenovelorunusualdesignfeaturesoftheaircraft.Section21.16,entitledSpecialConditions,statesthefollowing:IftheFAAfindsthattheairworthinessregulationsofthissubchapterdonotcontainadequateorappropriatesafetystandardsforanaircraft,aircraftengine,orpropellerbecauseofanovelorunusualdesignfeatureoftheaircraft,aircraftengineorpropeller,heprescribesspecialconditionsandamendmentstheretofortheproduct.ThespecialconditionsareissuedinaccordancewithPart11ofthischapterandcontainsuchsafetystandardsfortheaircraft,aircraftengineorpropellerastheFAAfindsnecessarytoestablishalevelofsafetyequivalenttothatestablishedintheregulations.32See 14 C.F.R.

§ 21.16. Therefore,

in accordance
with FMRA Section 333 and 14 C.F.R.

§ 21.16, the FAA may prescribe special conditions

for GSI's intended operation ofthe
DJI PHANTOM

3 UAS, which contain such safety standards that the Administrator
finds necessary

to establish

a level of safety equivalent

to that established

by 14 C.F.R. Part 21, Subpart

H, and 14 C.F.R. Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1), 91.40S(a), 91.407(a)(1), 91.409(a)(l)

& (a)(2), and 91.417(a)

& (b). E.

A Summary That Can Be Published

In The Federal Register, stating: The Rules From Which GSI Seeks Exemption: GSI seeks exemption from the requirements

of 14 C.F.R. Sections 61.113{a)

& (b), 91.7(a), 91.121, 91.151{a}(1}, 91.405{a), 91.407(a}(1}, 91.409(a)(1}

& (a)(2}, and 91.417(a)

& (b). A Brief Description

Of The Nature
Of The Exemption

GSI Seeks: This exemption

will permit GSI to commercially operate

an Unmanned Aircraft System (UAS} for the purpose

of conducting aerial acquisitions

and research within the National Airspace System (NAS}. F. Any Additional Information, Views,

Or Arguments Available

To Support GSI's Request. This Petition

is made pursuant

to the FAA Modernization

and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary

of Transportation

to determine

if certain UAS may operate safely

in the NAS. As such, GSI's request
for exemption
may be granted pursuant to the authority

of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements

for considering whether

a UAS will create a hazard

to users
of the NAS or the public,

or otherwise pose

a threat

to national security;
and 33further, provides
the authority

for such UAS to operate without airworthiness certification. As discussed

in detail above, the DJI PHANTOM

3 UAS has
in the past, and will continue in the future,

to operate safely

in the NAS without creating

a hazard

to users
of the NAS, or the public,

or otherwise pose

a threat

to national security. CONCLUSION As set forth herein, GeoStabilization International,

LLC seeks
an exemption pursuant

to 14 C.F.R.

§ 11.61 and Section 333 ofthe FAA Modernization

and Reform Act of 2012 (FMRA), which will permit safe operation

of the DJI PHANTOM

3 UAS commercially, without

an airworthiness certificate,

for the limited purpose

of conducting aerial acquisitions within the National Airspace System (NAS). By granting this Petition, the FAA Administrator

will be fulfilling the Congressional mandate

of the FAA Modernization

and Reform Act of 2012, while also advancing

the interests

of the public,

by allowing
GSI to safely, efficiently,

and economically operate the DJI PHANTOM

3 UAS commercially within the NAS. WHEREFORE,

in accordance
with the Federal Aviation Regulations

and the FAA Modernization

and Reform Act of 2012, Section 333, GSI respectfully requests that the Administrator
grant this Petition
for an exemption from the requirements

of 14 C.F.R. Sections 61.113{a)

& (b), 91.7(a), 91.121, 91.151{a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2),and 91.417(a)

& (b), and permit GSI to operate the DJI PHANTOM

3 UAS for the purpose

of conducting aerial acquisitions

and research within the NAS. 34Dated: May 18, 2015

35 Respectfully submitted, GeoStabilization International,

LLC **~** Michelle Urlacher 543 31 Rd Grand Junction,

CO 81504 Tel: (970) 210-6170 Fax: (970) 245-7737