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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. 

1 
As 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, 

P >0~.~- 

P. Scott Beathard 

President & CEO, GeoShack North America, Inc. 

2 
Section 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 

3 
vehicle 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. 

5 
Section 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. 

7 
45.23(b) Display of Marks GeoShack North Arnerica, 

Inc. sUAS shall be identified 

by 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 45 
and 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. 

10 
Traditional 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 these 

missions 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 complete 

these 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. 

11 
Appendix 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. 

12