July 30, 2015

Exemption No. 12226

Regulatory Docket No. FAA–2015–0582

Ms. Helleren Gregory

GrandView Services, LLC

208 Sequoia Avenue

Walnut Creek, CA 94595

Dear Ms. Gregory:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted March 9, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of GrandView Services, LLC (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct high 

resolution digital monitoring and surveying.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics Iris+.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 
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operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, GrandView Services, LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, GrandView Services, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.
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1. Operations authorized by this grant of exemption are limited to the 3D Robotics Iris+ 

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 
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the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 
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training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 
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These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 
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notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
GrandView Services, LLC

Helleren Gregory

208 Sequoia Ave.

Walnut Creek, CA 94595

925­932­6305

heller@grandview.biz

GrandView Services, LLC is filing a petition for exemption with the FAA regarding Title 14 of the Code of Federal

Regulations (CFR). We are seeking exemptions from the following items in the FAR/AIM rules and procedures:

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) &

(b) concerning commercial operation of the 3D Robotics Iris+ and additional UAS’s purchased for the business of

collecting data for civil and geotechnical engineering, environmental management, and infrastructure asset

management and maintenance. This is pursuant to section 333 of the FAA modernization and reform act of 2012

(Public law 122­95).

GrandView is seeking relief of the following in effort the use of UAS’s for commercial purposes. Operated initially by

private pilot and PIC Ms. Helleren Gregory for the purposes of high resolution digital modeling and surveying in the

applications of civil and geotechnical engineering, environmental management, and infrastructure asset management

and maintenance.

This request would benefit the practice of civil and geotechnical engineering, civil engineering construction, including

landslide identification and monitoring, real­time access to earthquake damaged areas, time lapse data collection for

management and maintenance of federal, state, and local infrastructure assets including levees, roads, and

waterways, and time lapse data collection for evaluation and management of environmental restoration. Geospatial

data collection for use in these applications enhances public safety and allows for better management of critical

infrastructure and environmental assets.

GrandView will currently use the services of PIC Helleren Gregory to ensure safety at job sites. Future UAV pilots will

go through the training and testing as deemed appropriate by the FAA, including both written and practical tests that

will apply. Ms. Gregory has taken the written knowledge test within the two year recent proposed time limit of the

FAA written test taken and passed in June, 2014.

GrandView is seeking exemption from the rules noted below. For clarity the specifics of our request are indicated in

italics.

61.113 Private pilot privileges and limitations: Pilot in command.

(a)​Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate

may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, for compensation or hire, act as pilot in command of an aircraft.

(b)​A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any

business or employment if:

(1)​The flight is only incidental to that business or employment; and

(2)​The aircraft does not carry passengers or property for compensation or hire.

(c)​A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers,

provided the expenses involve only fuel, oil, airport expenditures, or rental fees.
61.113(a) Requirement for certificates, ratings, and authorized

Pilot certificate. ​No person may serve as required pilot flight crew member of a civil aircraft of the United States,

unless that person ­

1. Has a pilot certificate or special purpose pilot authorization issued under this part in that person’s physical

possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or

authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that

country may be used; and

2. Has a photo identification that is in that person’s physical possession or readily accessible in the aircraft

when exercising the privileges of that pilot certificate or authorization. The photo identification must be a :

i. Driver’s license issued by a State, the District of Columbia, or territory or territory or possession of the United

States:

ii. Government identification card issued by the Federal government, a State, the District of Columbia, or a

territory or possession of the United States;

iii. US Armed Forces’ identification card;

iv. Official passport;

v. Credential that authorizes unescorted access to a security identification display area at an airport regulated

under 49 CFR part 1542; or

vi. Other form of identification that the Administrator finds acceptable.

The request of this exemption is to use a private pilot license for profit, only on UAV vehicles. The exemption will not

include single engine planes. Rule 61.113 will still apply to SEL planes in this request.

(b) Required pilot certificate for operating a foreign­registered aircraft. ​No person may serve as a required pilot

flight crew member of a civil aircraft of foreign registry within the United States, unless that person’s pilot certificate —

1. Is in that person’s physical possession, or readily accessible in the aircraft when exercising the privileges of

that pilot certificate; and

2. Has been issued under this part, or has been issued or validated by the country in which the aircraft is

registered.

91.7 Civil aircraft airworthiness:

a. No person may operate a civil aircraft unless it is in an airworthy condition

b. The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for

safe flight. The pilot in command shall discontinue the flight when un­airworthy mechanical, electrical, or

structural conditions occur.

Currently, there is no registration process for UAS vehicles. The PIC of UAS will perform the required checklist to

determine whether it is safe for flight. If registering a UAS in the future is a requirement, GrandView will comply.

If necessary, GrandView will apply for a special airworthiness certificate in the experimental category under Title 14

of the Code of Federal Regulations (14 CFR) § 21.191 for the purposes of research and development, crew training,

or market survey. We will also apply for type certification under § 21.17(b) (for a standard airworthiness certificate in

the special class category) or § 21.25 (for a special airworthiness certificate in the restricted category).

91.121 Altimeter settings.

a. Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the

case may be, by reference to an altimeter that is set, when operating —

1. Below 18,000 feet MSL, to —

i. The current reported altimeter setting of a station along the route and within 100 nautical miles of the

aircraft;
ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported

altimeter setting of an appropriate available station; or

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; or

(2) At or above 18,000 feet MSL, to 29.92” Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation.

(c) To convert minimum altitude prescribe under 91.119 and 91.177 to the minimum flight level, the pilot shall take the

flight level equivalent of the minimum altitude in feet and add the appropriate number of feet according to the current

reported altimeter setting:

GrandView will comply with the height and weight requirements proposed by the FAA on February 15, 2015 or as

modified in the future.

91.151 (b) Fuel requirements for flight in VFR conditions

Battery operated flight time of ten minutes for 3DR Iris+ UAS. UAS will be flown in accordance with line of sight and

weather minimums designated for UAS’s as proposed by the FAA on February 15, 2015 or as modified in the future..

91.405(a), Maintenance required

GrandView seeks exemption from maintenance required of a single engine plane. We will comply with manufacturer

recommended maintenance and maintenance as required of a UAS by the FAA when that is mandated.

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding or alteration

a. No person may operate aircraft that has undergone maintenance, preventive maintenance, rebuilding, or

alteration unless —

1. It has been approved for return to service by a person authorized under 43.7 of this chapter

91.409(a)(1) & (a)(2) Inspections

a. Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the

preceding 12 calendar months, it has had—

1. An annual inspection in accordance with part 43 of this chapter and has been approved for return to service

by a person authorized by 43.7 of this chapter.

2. An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No

inspection performed under paragraph (b) of this section may be substituted for any inspection required by

this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as

an “annual” inspection in the required maintenance records.

91.417(a) & (b) ­ Maintenance records

GrandView requests exemption from UAS annuals and inspections by an FAA authorized mechanic. Maintenance

and airworthiness will be performed either by the UAS manufacturer or by the dealer of the UAS. General

maintenance will be performed by the UAS PIC to ensure all precautions and checklists have been performed prior to

UAS flight.

GrandView Services, LLC will comply with all aspects of currently proposed and future FAA rulings. We feel that the

use of UAS’s in the engineering fields noted will enhance data collection for existing sites and for monitoring of site

conditions following natural disasters. We will operate specifically in this field, making the services available to
private engineering and consulting firms and public agencies who would like to focus on the engineering aspects and

not file for their own exemptions or create another data collection division of their current business or agency.

We understand that the currently proposed FAA rules are as follows:

• A small UAS operator must always see and avoid manned aircraft. If there is a risk of collision, the UAS

operator must be the first to maneuver away.

• The operator must discontinue the flight when continuing would pose a hazard to other aircraft, people or

property.

• A small UAS operator must assess weather conditions, airspace restrictions and the location of people to

lessen risks if he or she loses control of the UAS.

• A small UAS may not fly over people, except those directly involved with the flight.

• Flights should be limited to 500 feet altitude and no faster than 100 mph.

• Operators must stay out of airport flight paths and restricted airspace areas, and obey any FAA Temporary

Flight Restrictions (TFRs).

Helleren Gregory is current with these proposed regulations in operations regarding limitations in Class A,B,C, & D

airspace along with weather minimums for safe flight. GrandView will have current charts along with access to

DUATS, an AOPA membership, and TFR notifications before UAV flight.