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P. Scott Beathard President & CEO GeoShack Nortli America, Inc. 2307 Springlake Rd. Suite 514 Dallas, TX 75234 January 29, 2016

U.S. Department of Transportation Docket Management Systeni 1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam:

Attached, please find GeoShack Noilh Asnerica, Inc.'s request for an exemption from cellain stated Federal Aviation Regulations to allow conunercial operation of its small unmanned aircraft systems (hereafter referred to as "sUAS") for the purposes of sales, training, mapping inspections, survey, and agricultural applications, so long as such operations are conducted withui and under the conditions outlined herein or as may be established by the FAA as required by Section 333 of the FAA Modernization and Reform Act of 2012.

The FAA has previously issued grants of exemption in circumstances similar in all material aspects to those requested in this petition, notably in Exemption No. 13313 to Sentera, LLC, and in Exemption No. 11446 to Tilimbull Unmanned LLC which includes the specific VTOL sUAS proposed herein. Therefore, GeoShack North Ainerica, Inc. respectfully requests this exemption be considered under the "suinmary grant" process.

As detailed in this document, a granted exemption would permit the commercial operation of sUAS under controlled conditions in airspace that is limited and controlled via subsequent COA applications. Predominantly, GeoShack North America, Inc. seeks to operate under the "Blanket 200ft COA" guidance that was issued by the FAA in March 2015 and respectfully requests the "Blanket 200ft COA" be granted in concert with these exemptions.

The requested exemptions and proposed limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory strueture, specifically for demonstration purposes for potential end-users.

1As outlined in this reduest for exemption, the two sUAS GeoShack North America, Inc. proposes

to use are the Lockheed Martin Procerus Technologies (LMPT) Indago and the Phoenix from Sentera.

If I can provide a.ny additional infornlation in support of your review of this petition, please do not hesitate to call me at 972-241-6001 or send an email to sbeathard@geoshack.com

.

Sincerely, 

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P. Scott Beathard President & CEO, GeoShack North America, Inc.

2Section l: Introduction & Interest of GeoShack North America, Inc.

GeoShack is a teanl of sales and service professionals operating fi•om our 20 retail locations in 9 states. Our job as a technology leader is to stay at the forefront of emerging technologies. Small Unmanned Aerial Vellicle (sUAS) tecluiology has beconie a desirable commodity witlhin the capital equipment market. GeoShack Noilh America, Inc. has the background and team to safely integrate within the NAS and provide low-risk, cost- effective airborne technology to its
customers.

GeoShack North America, Inc. proposes to conimercially operate its sUAS platforms for the purposes of sales, training, mapping inspections, survey, and agricultural applications and other flight operatioils conforming to the proposed limitations and restrictions. GeoShack North America, Inc. asserts that comtnercially operating an sUAS within the NAS under these saine limitations and restrictions will not pose a hazard to manned aircraft, and that operation of its sUAS is in the public best interest by providing an inexpensive, low-risk alternative to manned operations.

Section 2: Regarding the Unmanned Aircraft System The FAA's public guidance on filing an exemption under Section 333 readily available and not reprinted below. This section intetids to fiilfill eacll requirement of the published guidance.

GeoShack North America, Inc. intends to commercially operate sUAS weighing less than 551bs, during dayligllt hours, within visual line of sight of the Pilot in Command (PIC), at altitudes less than 400ft AGL and at speeds less than 52nlph (depending on system, see Section 2.1 below). GeoShack PICs shall be fully qualified airmen, holding at least a sport pilot certificate and meeting medical requirements of the certificate held. The proposed sUAS are equipped with GPS-enabled autopilots, capable of safe, steady autonomous fliglit and guided by the PIC. The proposed sUAS is commercially available, "off the she1P' products that have acctunulated innumerable flight hours and they have proven themselves low-risk, safe aircraft. Given the small size and weiglit, low altitudes, slow speeds, a qualified PIC, a GPS-equipped autopilot, data-link and countless flight hours, GeoShack North America, Inc. holds that commercially operating this sUAS under the limitations and restrictions set forth is a safe alternative to the current regulatory structure and minimizes risk to the NAS or to persons and property on the ground.

2.1 Pi•oposed sUAS GeoShack North America, Inc. intends to operate the Lockheed Martin Procei

-us Technologies (LMPT) Indago fatnily of sUAS along with the Sentera Phoenix family of sUAS. This system been proven to be a reliable and effective sUAS with the ability to carry payloads such as cameras, sernsors and other equipment necessary to complete GeoShack Noilh America's applications. Each sUAS is described below.

Lockheed Martin Procerus Technologies (LMPT) Indago The Indago system is comprised of a four-rotor Vertical Takeoff and Landing (VTOL) unnlanned aircraft and ground cotitrol station — either a handheld controller or a laptop/tablet based control station — which is responsible for both

3vehicle operation and camet

- a functions, along with a coniinunications data-link providing bi-directional conununications between the air vehicle and the ground control station. The Indago sUAS lias the ability to conduct vertical takeoffs and landings, hover and execute standard liorizontal flight maneuvers. The maximum gross weight of the Indago is 4.85 lb (2200g), and it measures 32 x 32 x 9 in (813 x 813 x 229min). The Indago's maximuni llorizontal speed is 30mph (13.4 m/s), inaximutn ascent speed is 800 ft/min (4.1 n

- ds), and maximum descent speed is 400 ft/min (2.0 m/s). The Indago is powered by a Litlliunl Ion battery and flies for approxiinately 45 minutes. More detailed specifications are available in the Indago User Guide attaclled as Appendix 1.

The Indago system has been proven to be a reliable and effective system for operations such as those proposed herein and has previously been approved for siniilar uses by FAA.

Sentera Phoenix The Sentera Phoenix system is coinprised of a fixed wing, hand-launched, propeller driven uiunanned aircraft and a laptop or tablet based ground control, responsible for both vehicle operation and camera fiinctiolls, along with a communications data-liilk providing bi-directional communications between the air vehicle and the groulld colltrol station. The Phoenix sUAS has the ability to conduct hand-launched takeoffs, precision landings in varied terrain and execute standard horizontal flight maneuvers. The maximum gross weight of the Phoenix is 3.51b (1588g), and it measures 8in (203mm) talk, 22-26in (559-660mm) long (depending on the model) and has either a 38in (96511un) or 48in (12191nm) wingspaii (again, depending on the model). Its standard cruise speed is 29-35 mpll (25-30 ktas, 13-15n1/s), nlaximutn horizontal speed is 52 mph (45 ktas, 23m1s) and maximum ascent and descent speeds are 800 ft/min (4.1m/s) is 400 ft/min (2.0m/s) respectively. The Phoenix is powered with a Litllium lon battery and flies for approximately 60 mirnrtes. Detailed specifications are available in the Sentera Plioenix UAS Pilot Operational Handbook attaclled as Appendix 3.

The Sentera Phoenix system has been proven to be a reliable and effective system for operations such as those proposed herein and has previously been approved for similar uses by FAA. The Sentera Phoenix is an evolution of the Vireo UAS, originally produced by UTC Aerospace Systeins by the team that now fornis the core engineering team of Sentera. The Sentera Phoenix's immediate predecessor, the Vireo is currently operating in numerous FAA-approved Public COAs as identified below: • 2013-ESA-46 COA Hyde (Proponent: NC State University) • 2013-ESA-65 COA Butner (Proponent: NC State University) • 2013-ESA-69 COA Caratoke (Proponent: NC State University) • 2014-ESA-93 COA Lake Wheeler (Proponent: NC State University) • 2104-ESA-114 COA Springfield Airpark (Proponent: NC State University)

4• 2015-CSA-25 COA Springfield Airpa.rk (Proponent: Sinclair Comnlunity College) • 2013-CSA-56 Wilmington Airpark (Proponent: Sinclair Conlnlunity College)

2.2 Maintenance & Inspection GeoShack Noi

- th America, Inc. shall follow the manufacturer's maintenance, overhaul, inspection and record-keeping guidelines as specified in the relevant manufacturer user manivals, attached as Appendix 1 and 3. GeoShack North America, Inc. will conduct inspections and maintenance, which shall be noted in the aireraft's logbook including total flight hours and the nature of maintenance perfornled. Comprehensive maintenance will be performed in conformance with the manufacturer's guidelines.

In advance of every flight operation, the PIC will thoroughly inspect the sUAS to ensure it is safe to fly as described in the relevant manufacturer user manuals and checklists, attached as Appendices 2(LMPT Indago). Fuilhermore, the PIC will conduct a pre-flight cllecklist as described in the Operations Manual.

All sUAS proposed under this request for exeinption will be in compliance with all manufacturer maintenance, system and safety bulletins.

2.3 Radio Commuiiications All radio systems used in the proposed sUAS coinply with FCC regulations. Certificates of compliance may be found in Operations manuals in Appendix 1 and 3.

Section 3: Regarding the Unmanned Aircraft PIC The FAA's public guidance on filing an exernption under Section 333 is reprinted below. This section intends to fulfill each requirenlent of this guidance.

GeoShack Noilh America, Ulc. PICs shall possess a current airline transport, conlmercial, private, recreational or sport pilot certificate. The PIC shall also hold the appropriate current FAA airman medical for the pilot certificate or a valid U.S. Driver's Liceilse in the case of a sport pilot. The PIC sllall also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or Iler pilot certificate.

Prior to commercial operations, GeoShack North America, Inc. PICs sllall have accumulated and logged a ininimum of 25 hours total time as a sUAS pilot. Flights for the purposes of training GeoShack North America, Inc.'s PICs and Visual Observers (VOs) (training, proficiency, and experience-building) and determining the PIC's ability to safely operate the UAS in a manner consistent with how the sUAS will be operated linder this exemption, are requested under the terms of this exemption. Training operations shall only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations shall be considered nonpai

- ticipants, and the PIC shall operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

5Section 4: Iaegax•ding tiie Operation oI' the Unmanned Aircraft



### The sUAS will be operated during daylight hours, in compliance with visual flight rules, and flown within direct visual line of sight of the PIC at all times and never over congested or densely populated areas unless specifically authorized by an Air Traffic Organiza.tion- issued COA. The PIC shall 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.

The sUAS shall be operated at an altitude of no more than 400ft AGL, unless specifically authorized and operating under the terms of the COA, at speeds less than 23m/s (52mph). The sUAS will not be operated less than 500ft below or less than 2000ft horizontally from 

### a cloud, or when visibility is less than 3 statute miles.

Prior to beginning a flight, the PIC shall clearly establish the limits in latitude, longitude and altitude AGL to ensure compliance with the COA under which the sUAS is flown and establish the "sterile area" for operations. If at any time, this area is breached by unpredicted obstacles (manned aircraft or otherwise), the PIC shall abort the flight. Manned aircrafl shall have right of way at all times.

In case of a reduced or diminished control link, the sUAS will automatically return to a predetermined point within the private or controlled-access property.

The PIC shall not begin a flight unless there is sufficient available power for the sUAS to complete the intended mission and to operate for at least five minutes after that.

By operating within the li_mitations and guidelines set forth herein, GeoShack North America, Inc. shall provide an equivalent level of safety to operations under the existing regulatory
structure.
All flight operations will be conducted at least 500ft from all nonparticipating persons, vessels, vehicles and structures on private or controlled access property with permission from the property owner/controller or authorized representative. In some cases due to mission requirements, the sUAS will be operated closer than 500ft to commercial a.nd industrial infrastructure and facilities. In these instances, GeoShack North America, Inc. shall have the authorization of the property owner/controller or from an authorized representative, and the PIC shall have conducted a safety assessment and determined that it does not present an undue hazard. Permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted.

In accordance with the "Blanket 200ft COA" guidance that was issued by the FAA in March 2015, flight operations will not take place within

0 

### 5 nm feom an airport having an operational control tower; oi• • 3 nm from an airport with a published instrument flight procedure, but not an operational tower; or • 2 nm from an airport without a published instrument flight procedure or an operational tower; or

N

.• 2 nm fiom a heliport with a published instrument flight procedure unless a letter of

agreement witll that airport's management is obtained and/or othei

- wise permitted by an Air Traffic Organization-issued COA.

Foreseen hazards include encroachment of manned aviation operations and non- participants on the ground. Both of these hazards are mitigated by choice of location (non- congested areas) and strict limits on range (visual line of sight) and altitude established herein. Operation under these limits effectively mitigates these risks.

As described above, the sUAS will be operated during daylight hours, in compliance with visual flight rules, and flown within direct visual line of sight of the PIC at all tinles.

In advance of every flight operation, the (PIC) will thoroughly inspect the sUAS to ensure it is safe to fly as described in Appendices 1 and 2. Furthermore, the PIC will conduct a pre-flight checklist as described in Appendix 2 and 4(LMPT Indago), and ensure the planned operation can be completed safely with suff' icient battery reserves (including wind and terrain limitations). With both inspections completed and passed, the sUAS sha11 be deemed safe to fly.

GeoShack North America, Inc.'s aerial operations will notify FSDO's if the proposed aerial operation has any requirement to do so.

As stated previously, GeoShack North America, Inc. shall obtain an Air Traffic Organizationissued COA prior to conducting any operations under this requested grant of exemption. GeoShack North America, Inc. seeks primarily to operate under the "Blanket 200ft COA" guidance offered by the FAA in March, 2015 and respectfully requests that COA be issued concurrently with these exemptions. For operations not conforming to the "Blanket 200ft COA" guidance, GeoShack NoY•th America, Inc. will seek separate and additional COAs to operate its sUAS.

Section 5: Requested Exemptions

14 C.F.R. PaY•t Summary of Re ulation Proposed Action 21, Subpart H Airworthiness hl consideration of the size, Certification weight, speed, and linlited operating area associated with the aircraft and its operation, the FAA has previously held that this aircraft meets the conditions of Section 333, therefore, requested relief from 14 CFR part 21, and any associated noise certification aild testing requirements of part 36, is not necessary.

745.23(b) Display of Marks GeoShack North Arnerica, Inc. sUAS shall be identifiedby serial number and Nntunber, in markings as large as practical given the small size of the aircraft. I Iowever, the 2 inch minimum set forth in this rule is impractical, therefore relief is requested. 61.23(a) Certification: Pilots, Flight In previous petitions for 61.101(e) (4&5) Instructors and Ground exemption, the FAA has held 61.113(a) &(b) Instructors tliat a PIC of a sUAS liolding 61.133(b) at least a Spoi•t Pilot 61.315(a) certificate and a U.S. Driver's License, or greater medical certification, would not adversely affect safe operations within the NAS or present a hazard to people or structures on the ground. Relief, subject to the limitations provided in this docutnent, is requested. 91.7(a) Civil Aircraft PICs operating on behalf of Airwortliiness GeoShack North America, hlc. shall perform preflight inspections and ensure airworthiness prior to flight as described in this document, manuals and appropriate appendices. Relief froln this requirement is not necessary. 91.9(b)(2) &(c) Civil aircraft flight manual, GeoShack North. America, marking, and placard Inc. shall provide a current requirements sUAS Flight Manual, and operational instruction material at the location of the PIC and /or Ground Station. The FAA has previously determined that, given this relief from this requirenient is not necessary. 91.103 Preflight Action GeoShack North America, Inc. will perform. Relief is not necessary.91.105 Flight Crewmembers at No huinan will be aboard the Stations sUAS operated by GeoShack North America, Inc., however, the FAA has held in previous petitions that relief is not necessaiy. 91.109(a) Flight Instruction GeoShack North America, Inc. will conduct flight training in accordance with the guidance and limitations offered in this document, as well as the Operations & Flight Manuals attached as appendices to this document. The FAA has held in previous petitions that relief is tlot
necessary. 91.119 Minimum Safe Altitudes Request relief witlhin limitations and restrictions proposed herein, specifically in Section 4. 91.121 Altimeter Settings The sUAS GeoShack Nortli America, Inc. proposes to operate measures altitude with both barometric pressure sensors and GPS. Prior to each flight, the barometric altimeter will be set to Oft AGL instead of the setting of the tlearest reporting station. GeoShack North America, Irnc. holds that by counting altitude 

### u1 AGL, zeroed at the point of deparhire, will ensure conformance to the COA restrictions under which the sUAS is operating. Given the low operating altitudes of system atld operating within the proposed restrictions, relief is requested. 91.151 Fuel Requirements in VFR As described in this COndltlons docutnent, the sUAS GeoShack North America, Inc. proposes to operate has total endurance of between 45and 60 minutes. GeoShack North America, Inc. will ensure missions are conducted with sufficient reserve to operate for at least five minutes after the intended mission is complete. The short flight time makes the reserves specified in 91.151 impractical and therefore relief is requested. 91.203 Certifications Required GeoShack North America, Itic. will place these documents at the location of the ground station and/or with the PIC. The FAA has previously held that this is sufficieilt to provide an equivalent level of safety, and therefore, relief is requested. 91.405 Maintenance Required Relief is requested within the limitations and conditions set forth in Section 2.2 of this document. 91.407 Operations After Relief is requested within the Maintenance liinitations and conditions set forth in Section 2.2 of this docunlent. 91.409 Inspections Relief is requested within the lirnitations aiid conditions set forth in Section 2.2 of this document. 91.417 Maintenance Records Relief is requested within the limitations atld conditions set forth in Section 2.2 of this document.

Section 6: Public Interest & Equivalent Level of Safety

GeoShack North America, Inc. proposes certain 14 CFR exemptions to allow commercial operation of its small unnlanned aircraft systems for the purposes of training, survey, and agricultural applications and other flight operations, so long as such operations are conducted within and under the conditions outlined herein.

10Traditional agricultural operations such as crop inspections and data collections under the current

regulatory structure include the use of manned aireraft, wliich are expensive, inefficient and cannot be safely operated in close proximity to the ground. By using sUAS to complete thesemissions the public intei•est is served by increasing safety to pilots, passengers atld iionparticipants on the ground.

Traditional industrial infrastruchire inspection operations tinder the current regulatory structure are often performed 1) from the ground, where higlh detail is impossible 2) by a climber at great risk to his or her persoilal safety, or 3) by a manned aircraft where flying close to elevated infrastructure is extremely dangerous, and not permitted by 14 CFR 91.119.

Traditional public safety, security (such as facility perimeter monitoring), first responder, natural resource management and emergency response/emergency management flight operations under the current regulatory structure include the use of manned aireraft, which are expensive, inefficient and can pose significant risks to the aircrew, property and structures and persons on the ground when being operated in close proximity to the ground. By using sUAS to completethese missions the public interest is served by increasing safety to pilots, passengers and nonparticlpallts on the ground wlhile increasing availability and responsiveness due to the lower cost of equipnlent and operations.

Grant of exemption, with the conditions and limitations set forth herein, to GeoShack Nortll America, Inc. will provide for at least an equivalent or better level of safety, reduce risk to life and property, thereby serving the public interest.

Section 7: Sunimary of Exemption Request foi• the Fedei•al Register In accordance with 14 CFR 11.81 and Section 333 of the FAA Modernization and Refoirn Act of 2012, P.L. 112-95, GeoShack North Anlerica, Inc. seeks exemption from the requirements of 14 C.F.R §§Part 21, Subpart H, 45.23(b), 61.23(a), 61.101(e)(4&5), 61 113(a) &(b), 61.133(b), 61.315(a), 91.7(a), 91.9(b)(2) &(c ), 91.103, 91.105, 91.109(a), 91.119, 91.121, 91.151, 91.203, 91.405, 91.407, 91.409 and 91.417 to operate small unmanned vehicles weighing 551bs or less for comtnercial purposes.

Approval of these exemptions will allow GeoSllack North America, Inc. to conduct safe, commercial operation of sinall unmanned aircraft for the purposes of aerial photography, mapping, crop surveying, inspections, data collection, security monitoring, public safety, first responder and emergency response support and other flight operations.

Section 8: Compliance with 14 CFR 11.81 14 CFR 11.81 a— Published on Cover Page. 14 CFR 11.81 b— Please see Section 5. 14 CFR 11.81 c— Please see Sections 2, 3, 4 and 5. 14 CFR 11.81 d— Please see Section 6. 14 CFR 11.81 e— Please see Sectioil6. 14 CFR 11.81 f— Please see Section 7. 14 CFR 11.81 g— Please see Appendices 1-4. 14 CFR 11.8111— Not applicable.

11Appendix 1: Lockheed Martin Procerus Technologies Indago User Guide v2.0

Lockheed Martin considers these documents to be proprietary infortnation and prefers to keep this confidential. To make it available for review, it has been sent to 333exemptions@faa.gov with the cominent tracking nuinber included in the email. Please contact sbeathard@geoshack.com with questions or concerns.

Appendix 2: Lockheed Martin Procerus Technologies Indago Flight Checklist Lockheed Mai

- tin considers these documents to be proprietary information and prefers to keep this confidential. To make it available for review, it lhas been sent to 333exemptions@faa.gov with the comment ti•acking nuinber included in the email. Please contact sbeathard@geoshack.com with questions or concerns

Appendix 3: Sentera Phoenix UAS Pilot Operating Handbook Sentera considers these docutrneilts to be proprietaty information and prefers to keep this confidential. To make it available for review, it has been sent to 333exemptioiis@faa.gov with the comment tracking nunlber included in the email. Please contact sbeatllard@geoshack.com with questions or concerns.

Appendix 4: Sentera Phoenix Flight Checklist Sentera considers these documents to be proprietary information and prefers to keep this confidential. To make it available fo1• review, it llas been sent to 333exemptions@faa.gov with the comment tracking number included in the email. Please contact sbeathard@geoshack.com with questions or concei•ns.

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