Spectrum Geomatix, LLC 

939 NW 176th Ave.

Beaverton, OR 97006

Tel: (541) 250-9526 

Oct 9, 2015

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam: 

 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and 

CFR Part 11, Spectrum Geomatix, LLC, owner and operator of Small Unmanned Aircraft Systems 

(UASs), requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that 

Spectrum Geomatix, LLC may operate UASs commercially in airspace regulated by the FAA., as long as 

such operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. 

 Spectrum Geomatix, LLC (a geomatics company) is owned by Ryan Benz, Jonathan Burnett, and 

Richard Gabriel. They are all Oregon residents with Oregon driver’s licenses. Someone with a sport 

pilots certificate or higher will be PIC at all times. All operations will be performed with the public’s safety 

and right to privacy safeguarded at all times. 

 As described below, the requested exception would permit the operation of light weight (less than 

55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private 

pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) 

responsibility to” establish requirements for safe operation of such aircraft systems in national airspace 

systems.” Section 333(c), of the Reform Act. 

 Spectrum Geomatix UASs (The 3dr solo quadcopter) are rotorcraft weighing less than 55 pounds 

including payload. They operate at a speed less than 50 knots and have the capability to hover and move 

in the vertical and horizontal plane simultaneously. It has an auto return to launch point when battery 

power is under 15%. The UAS will operate within the line of sight within a protected flight area as 

described below and at 400 feet AGL or less with an observer located close at hand as to make voice 

communication possible. These operations will not create a hazard to users of the nation airspace, public 

nor the environment. 

 Spectrum Geomatix, LLC respectfully requests the grant of an exception to the following specific 

sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial 

use, 

 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 

91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b). 

 Spectrum Geomatix, LLC submits this application in accordance with the Reform Act ,112 P.L. 95 

331-334, seeking relief from any currently applicable FAR’S operating to prevent Spectrum Geomatix, 

LLC future commercial use of small UASs to operate in the national airspace system as described below. 
The reform Act section 332 provides for such integration of civil unmanned aircraft into our national 

airspace system as it is in the public’s interest to do so. Spectrum Geomatix, LLCs UASs meet the 

definition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these 

UASs are expressly contemplated by the Reform Act. Spectrum Geomatix, LLC would like to operate its 

lightweight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such aircraft. 

 The Reform Act directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in national airspace before completion of the rule making required under 

Section 332 of the reform Act. In making this determination, the Secretary of Transportation is required to 

determine which UASs do create a hazard to users of the national airspace system or the public or pose 

a threat to national security in light of the following: 

 The UASs size, speed, weight and operational capability 

 Operation of the UASs in close proximity to airports and populated areas 

 Operation of the UASs within visual line of sight of the operator 

 

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in National 

Airspace System, the secretary shall establish requirements for the safe operation in national airspace. 

Spectrum Geomatix, LLC use rotorcraft weighing less than 55 lbs. and they operate at speeds less than 

50 knots and have the capability to operate in the vertical and horizontal plane simultaneously. The UASs 

will operate only within the line of sight of the operator within a protected flight area and at 400 feet AGL 

or less. These will not present a hazard to the national airspace nor the public. 

 

The very small nature of these UASs combined with the safe guards presented below, will allow for the 

safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow 

commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas 

and altitudes they will operate approval of this exception presents no national security issues and 

absolutely minimal safety concerns which have been mitigated through our rigorous risk management 

process. Given the clear direction given in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions 

utilizing UASs verses traditional aircraft as well as the economic impact of greatly reducing the cost of 

aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests 

that the FAA grant the requested exemption without delay. 

 

The following will be considered as the binding limitation on operations of Spectrum Geomatix, LLC, 

 Flights will only occur in the daylight hours, 

 Flights will be operated in the line of sight of the operator(PIC) and Observer,(VSO) 

 Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by 

manufacturers recommendations, 

 The UASs will weigh less than 55 lbs., 

 Flights will be operated at 400 feet AGL or less. 

 Crew will be at a minimum of operator(PIC) and an observer and/or camera operator(VSO), 

 Operator and crew will remain in contact during the flight operation, 

 The UASs operator will perform a check of the flight area and make certain of the safety of all 

persons in the area, 

 All required FAA clearances, will be obtained and distances from airports strictly observed. 
 All UASs will have the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working. 

 Flights will only operate in VFR conditions. 

 UASs have a function on the control to tell operator the distance away from the operator and its 

battery power remaining. 

 Flight team will communicate by voice and the use of two-way radio if the area is too big to hear 

voice from all team members. 

 UASs will be used for videography and stereographic scene reconstruction

 In the event of an unscheduled landing all UASs will be recovered to prevent environmental 

contamination from lithium batteries

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) 

 Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for 

Spectrum Geomatix, LLC UASs flights permits exception from Part 21 because they meet an equivalent 

level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from 

the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in 

consideration of weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Spectrum Geomatix, LLC meets or exceeds each of these elements 

As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA for flights at or 

under 200 AGL to any UASs operator with a section 333 exemption. 

 14 CFR 91.203(a&b)

provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the 

same reasons stated above. The equivalent level of safety will be achieved by maintaining such 

certifications and registrations at Spectrum Geomatix, LLC operations center. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by FAR’s this regulation is inapplicable. 

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

 14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining such certifications and registrations at Spectrum Geomatix, LLC 

operations center. 

The FAA has previously issued exemptions to this regulation in Exemptions No’s 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Spectrum Geomatix, LLC will only 

operate its UASs at or below 400AGL. They will be operated on a will defined AOR that has been 

carefully reviewed for hazards and minimizes the presence of any persons not essential for these 

operations. Electric UASs under 55 lbs operate with a much smaller environmental footprint and with a 

lower risk of human injury or property damage than manned counter parts that are powered by highly 

volatile liquid fuel.

 Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of 

aerial photography will greatly enhance safety by reducing the overall risk associated with traditional 
aircraft. Small autopilot equipped UASs weighing 55 lbs or less and flying below 400 ft AGL have fewer 

mechanical parts, lower mass and redundant electronic sensors that all combine to improve the 

operational risk management conditions relative to conventional manned aircraft when operating in similar 

roles.

Spectrum Geomatix, LLC respectfully requests the FAA grant its exception without delay. The FAA has 

the authority to issue the exemption sought by Spectrum Geomatix, LLC pursuant to the Federal Aviation 

Act, 85 P.L. 726 (1958) as amended (the ACT). 

Sincerely 

Spectrum Geomatix, LLC

Jonathan Burnett

939 NW 176th Ave.

Beaverton, OR 97006

Tel: (541) 250-9526

jonathan.burnett@spectrumgeomatix.com