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Gowdy Brothers Aerospace, LLC			8170 Old Carriage Court N., Suite #200, Shakopee, MN 55379		

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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

North Star Aerial

FOR AN EXEMPTION SEEKING RELIEF FROM

THE REQUIREMENTS OF THE FAA REFORM ACT AND

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on October 13, 2015

North Star Aerial

5605 Highwood Dr.

Edina, MN 55436

adam@northstaraerial.com

NSA’s Consultant

Gowdy Brothers Aerospace, LLC

8170 Old Carriage Court N. Suite #200

Shakopee, MN 55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com
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Table of Contents

GLOSSARY OF ABBREVIATIONS...........................................................................................3

INTRODUCTION AND INTERESTS OF THE PETITIONER..............................................5

Executive Summary .................................................................................................................5

Expeditious Summary Grant Approval Request......................................................................5

Description of Type, Make and Models of sUAV/UAS Requested:.............................................6

Commercial (Mission, Operation) Purpose:........................................................................................6

Regulations from which the Exemption Relief is requested:.......................................................7

The name and address of the Petitioner: .............................................................................................8

Background...........................................................................................................................................8

Commitment to Safety..................................................................................................................................9

Expertise & Experience................................................................................................................................9

The Exemption Request ...................................................................................................... 10

Operator Requirements ................................................................................................................ 12

Aircraft and Equivalent Level of Safety.................................................................................... 15

Specific Uses Public Benefits ....................................................................................................... 19

Equivalent Level of Safety............................................................................................................. 20

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................21

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................21

14 C.F.R. §91.121 Altimeter Settings...................................................................................................22

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................22

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections.....................................................................................................................................................23

Federal Register Publication............................................................................................. 24

Privacy and National Security........................................................................................... 24

Summary................................................................................................................................... 24

APPENDIX A - EXEMPTION PATTERN....................................................................................... 27

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS............................................ 28

APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA PREVIOUS

APPROVED EXEMPTION NUMBERS........................................................................................... 29

APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION NUMBERS.... 30

APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED EXEMPTION

NUMBERS............................................................................................................................................ 31

APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG............................................. 32

APPENDIX G – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS MANUAL

VERSION 1.0....................................................................................................................................... 33
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System
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sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear Sir or Madam:

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

“Reform Act”) and 14 C.F.R. Part 11, North Star Aerial, (“NSA”) Operator of Small

Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand commercial

UAS operations for a host of industries and applications and to perform the

purposes listed below, hereby applies for an exemption from the listed Federal

Aviation Regulations (“FARs”) to allow commercial operation of its sUAV’s/UAS, so

long as such operations are conducted within and under the conditions outlined

herein or as may be established by the FAA in an exemption granted under either

Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the

operation of a UAS under controlled conditions in airspace that is 1) limited; 2)

predetermined; and 3) would provide safety enhancements in the fields in which it

will operate, which now depend upon conventional aircraft or humans climbing

high on dangerous structures, walking in insect laden swamps, and working

adjacent to treacherous infrastructure. Approval of this exemption would thereby

enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibilities to “... establish requirements for the safe operation

of such aircraft systems in the national airspace system.” Section 333(c) of the

Reform Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this

application. Petitioner has provided in a confidential document attachment labeled

as petitioner proprietary information, specific exemption numbers whereby the FAA

has already granted a previous exemption similar or identical to each and every

request, herein.

For the FAA’s benefit, Petitioner’s Consultant, Gowdy Brothers Aerospace, LLC, has

researched, categorized and arranged all 631 exemptions granted as of June 23,

 

1		North Star Aerial relies upon the following exemptions where specific reference to

an exemption is not provided: Exemptions 11062 thru 11067, 11080, 11109

through 11112, 11114, 11213, 11062 and as recent as 11857.
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2015 into a usable searchable database, based upon the following criteria: date

submitted, date grant issued, time to petition grant, petitioner, petitioner’s state,

exemption number, sUAV equipment type, grant purpose (mission/operation),

along with other supporting data.		

Petitioner has identified four previous approved exemptions for each of the

Petitioners FAA submission requests:

 Commercial (mission/operation) purposes;

 Type of sUAV’s (UAS);

 Title 14 Exemptions (exemption pattern referenced in appendix A)2

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAV’s makes and

modes as follows:

DJI - Phantom 2, DJI - Phantom 3, DJI - Inspire 1, DJI – Spreading Wings S800, DJI –

Spreading Wings S900, DJI – Spreading Wings S1000, DJI – Matrics 100, Cinestar 8

Octo, Altavian Nova F6500, FreeFly Alta, Blade 350 QX3, AgEagle, 3DRobotics X8,

3DRobotics Iris, 3DRobotics Solo, SenseFly eBee, Yuneec Q500 Typhon, DraganFlyer

X4-ES, Trimble UX5, Microdrones MD4

Each separately weighs 55 lbs. or less, with imaging payload and applicable

equipment.

Equipment operation manuals for each sUAV are included for your reference and

are considered confidential information for each respective company’s UAS and are

affixed separately in these documents labeled Appendix.

Commercial (Mission, Operation) Purpose:

This exemption request, once granted would allow the petitioner to operate a small

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge

Inspections, flare stack inspection, utility-power generation system inspections and

patrolling, aerial inspection, photography and videography of residential and

commercial real estate, weddings, aerial inspection, photography and videography

 

2 Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).
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of utility infrastructure including but not limited to electrical power lines, wind

turbines and cell towers, pipeline inspection and patrolling, filmmaking,

cinematography, and videography, precision agriculture with on board sensors,

wildlife and forestry monitoring and mosquito and insect control, aerial surveying,

construction site inspection and monitoring, public entity support operations, Aerial

imaging for safety, monitoring and comparing work efforts and completion

percentages, and security of controlled environment of various sites, aerial video

and live video feed to assist with search and rescue operations under the authority

and support of local authority officials, aerial video and photography for public and

private use including television, public events, and cinematography live feed and

live news-gathering, training to persons individually or belonging to both private

and public organizations to increase awareness and improve safety for current and

future UAS operations within the NAS, special events: including high schools,

colleges, professional sports, open air events and fairs, research, risk management

and assessment, motion picture production3, surface mining, closed set filming4,

disaster and catastrophe events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

See Appendix E

 

3 Motion Picture and Television Flight Operations Manual is herein attached as

Appendix G.

4 Motion Picture and Television Flight Operations Manual for closed set filming is

herein attached as Appendix G.
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The name and address of the Petitioner:

North Star Aerial

Attn: Adam Geiss

5605 Highwood Dr.

Edina, MN 55436

Please direct any question or comment regarding this petition to Petitioners

Consultant: Gowdy Brothers Aerospace, LLC.

8170 Old Carriage Court N., Suite #200

Shakopee, MN 55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com

Background

The Petitioner, NSA is under Adam Geiss’ direction. Adam Geiss is a highly

accomplished, capable, experienced and trusted professional.

Adam has spent more than 20 years in the world of commercial photography and

video production. Shooting for ad agencies like Campbell Mithun and Fallon and

studios like Paramount Pictures, Geiss has always enjoyed creative visual problem

solving. Adam as logged over 1000 flights. He is FlySafe trained and certified RC

pilot, and he founded North Star Aerial. Adam is on the board of the local chapter of

the American Society of Media Photographers, and is a passionate advocate for

professionals working in the Radio Controlled Aerial Photography (RCAP) industry.

"Safety is Paramount and Weather is King” says Geiss, “training and proper

education is key in this new evolving industry."
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Commitment to Safety

As part of its commitment to safety and innovation, NSA is asking for this

exemption, in part, to further advocate safe UAV operations, to promote

professionalism within the industry, and to reduce the risk of injury to its

employees and contractors, who participate in the proposed activities the petitioner

requests. These activities include, but are not limited to, damage to agriculture,

natural habitat, buildings, and other structures within the United States of America.

Expertise & Experience

NSA and Adam Geiss, due to his professional experience as a trusted sUAV pilot, is

not only extremely well-qualified, but also is considered an up and coming subject

matter expert in the Minneapolis area for UAS of all types, models, and

makes. Adam has logged over 1,000 UAV flights. He has world-wide drone

experience, flying in many types of environments. "Safety is Paramount and

Weather is King says Geiss. From saving lives in search and rescue operations, to

telling a story from remote places in the world, this newer technology will become,

and is now, a game changer in countless industries.

Geiss has been involved in many projects over the years, and three are of critical

importance: He was the first to provide aerials for the US Capital Christmas Tree

cutting project, he has been involved with Mission Trips to the Dominion Republic

to tell the story of education thru the building of schools that have been utilized to

literally change lives, and locally he has produced a training video for the

Minneapolis Police Department, which has been employed to aid in the safe training

of cadets involved in pursuit training.
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The Exemption Request

NSA proposes the use of the sUAV’s will be for capture of high resolution imagery

and video of residential or commercial applications and purposes to a level of

quality that allows the Petitioner to use the imagery to identify, record, memorialize

events and objects according to the purposes noted.

The imagery and video will be used to identify the condition of landscapes,

agriculture, events, disasters and infrastructure to conduct bridge inspections, flare

stack inspection, utility-power generation system inspections and patrolling, aerial

inspection, photography and videography of residential and commercial real estate,

weddings, aerial inspection, photography and videography of utility infrastructure

including but not limited to electrical power lines, wind turbines and cell towers,

pipeline inspection and patrolling, filmmaking, cinematography, and videography,

precision agriculture with on board sensors, wildlife and forestry monitoring and

mosquito and insect control, aerial surveying, construction site inspection and

monitoring, public entity support operations, aerial imaging for safety, monitoring

and comparing work efforts and completion percentages, and security of controlled

environment of various sites, aerial video and live video feed to assist with search

and rescue operations under the authority and support of local authority officials,

aerial video and photography for public and private use including television, public

events, and cinematography live feed and live news-gathering, training to persons

individually or belonging to both private and public organizations to increase

awareness and improve safety for current and future UAS operations within the

NAS, special events: including high schools, colleges, professional sports, open air

events and fairs research, risk management and assessment, motion picture

production, surface mining, closed set filming, disaster and catastrophe events.

The UAS will be operated by a NSA and or contracting operators on occasion to

capture high-resolution imagery/video of large structures (wide and tall) such as

warehouses, high rise buildings, bridges, and construction sites, as well as “bird’s

eye” views of fire and explosion sites. Given the small size of the sUAV’s involved, no

more than 55 lbs., majority of the speed of operation be between 5-15 mph and the

restricted environment within which they will operate, the Petitioner falls squarely

within that zone of safety (an equivalent level of safety) in which Congress

envisioned that the FAA must, by exemption, allow commercial operations of UASs

to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of

Transportation to consider whether certain unmanned aircraft systems may

operate safely in the national airspace system (NAS) before completion of the rule

making required under Section 332 of the Reform Act. In making this determination,

the Secretary is required to determine which types of UASs do not create a hazard to
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users of the NAS or the public or pose a threat to national security in light of the

following:

 The UAS’ size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may

operate safely in the national airspace system, the Secretary shall establish

requirements for the safe operation of such aircraft in the national airspace system.”

Id. §333(c) (emphasis added).5

The Federal Aviation Act expressly grants the FAA the authority to issue

exemptions. This statutory authority, by its terms, includes exempting civil aircraft,

as the term is defined under §40101 of the Act: The Administrator may grant an

exemption from a requirement of a regulation prescribed under subsection (a) or

(b) of this section or any of sections 44702-44716 of this title if the Administrator

finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC

§44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant

exemptions reaches such issues as authorization of commercial operation of aircraft

without an FAA issued pilot’s license.

NSA in filing this application is requesting that the FAA combine the grant of the

Section 333 exemption with a standard Certificate of Operation (COA) that will

allow commercial operations of its NSA’s sUAV without the necessity of filing for a

COA for each flight, unless such flight is to be conducted in an area not approved in

the exemption. Compliance with the conditions agreed to herein and that may be

imposed by the FAA, as set forth in prior Section 333 exemptions, provide the

separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no

closer than 5 nautical miles of the geographic center of an airport as denoted on a

current FAA published aeronautical chart, unless a letter of agreement with that

airport’s management is obtained, NSA requests that operations over congested or

densely populated areas be allowed. The new sUAV’s do have GPS geo-fencing, it will

operate at a very low altitude, within confined areas, at low speed and weighs no

more than 55 lbs. Such operations will only be under-taken with the approval of the

land or home owner, as set forth herein, and will comply with the requirements that

operations be no closer than 500 feet to the adjacent building unless the land owner

 

5 Applicant interprets this provision to place a duty on the Administrator to not only

process applications for exemptions under section 333, but for the Administrator to

craft conditions for the safe operation of the UAS, if it should be determined that the

conditions set forth herein do not fulfill the statutory requirements for approval.
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has provided permission, and the Operator has made a safety assessment of the risk

from such operations.

Operator Requirements

Given the sUAV proposed by NSA, Operators should not be required to hold a

private pilot license. NSA believes that 1) the operator, instead of understanding

how to operate a passenger carrying aircraft, should have knowledge and

experience that enables the safe operation of a small, remotely piloted sUAV should

understand airspace restrictions and know how to ensure separation from other

aircraft as well as non-participants and property; 2) the sUAV has built-in technical

capabilities that limit the potential for unsafe operation and 3) there are other

security screening mechanisms already in existence that NSA will utilize to ensure

the operators are acting consistently with national security interests.

Given the sUAV safety features outlined below, NSA proposes that its operations

under this Exemption request should not be required to hold a commercial or

private pilot certification. Instead, Operators should be required to: have

successfully completed, at a minimum, FAA private pilot ground instruction and

passed the FAA Private Pilot written examination or FAA-recognized equivalents;

have completed NSA’ training program for operation of the UAS.

NSA notes that 1) the FAA has found that safety factors permitted operation of

sUAV’s by Operators with these qualifications in the case of operations pursuant to

public COAs when the mandatory operating conditions specified above were

present; and 2) that the Notice of Proposed Rule making entitled Operation and

Certification of Small Unmanned Aircraft Systems, 80 F.R. 9544 (February 23, 2015)

(“NPRM”), does not require the operator to hold a private pilot license or a third

class medical.

Advanced sUAVs have a navigation and control system and auto-pilot that allows it

to execute very accurate pre-programed flights. Flights are pre-programmed with

GPS waypoint to establish perimeters beyond which the aircraft will not operate.

Flights under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the

control unit, and the autopilot executes those maneuvers. Pre-programmed

Operator interventions include: initiation of holding at present position; suspension

of mission; fly back to launch point; abort mission and land immediately; and

emergency power cut off and land (flight termination system). Additional

automated safety functions and safety enhancing features of the advanced sUAV’s

may include the following:
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1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an

immediate landing,

2)		Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels. Low power below 10% triggers an immediate landing,

3)		If the auto-pilot detects a lost-link to the ground controller, the UAS will hold

position at its current location for 5 seconds and if the signal is not restored,

execute a return to home and land,

4)		Redundant “kill switches” that enable completely shutting the aircraft down

in flight in the event of a loss of control or un-commanded deviation from the

flight path,

5)		The aircraft, weighs less than 55 lbs., fully loaded,

6)		The motors are driven by pulse width modulated signals, not analog signals,

7) The aircraft will operate for the Purposes at no more than 30 mph (while

imaging) nor above 200 feet above the structure (imaging altitude) or a

maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has

determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”),

in comparing the requirements for private pilot knowledge and the knowledge

required for a commercial pilot, that knowledge associated with a private pilot

license, and therefore private pilot ground school, was sufficient to allow private

pilots to operate sUAV’s under those exemptions.

Based upon that analysis, NSA believes successful completion of FAA private pilot

ground school is a suitable predicate to operating the sUAV under this exemption.

NSA proposes that the Operator accumulate required sUAV flight training hours

through the operation of sUAV’s rather than flight hours in conventional aircraft.

Those hours are more relevant to the operations proposed herein than hours gained

in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those

aircraft are orders of magnitude heavier than the sUAS and carry not only the pilot

himself, but also passengers and fuel, none of which is carried in the sUAS. These

conventional aircraft fly over all sorts of airspace without the permission or

knowledge of the landowner.

A handheld radio controller controls the sUAV and the vehicle is operated within the

line of sight. The requirements of Part 61.127 (commercial flight proficiency) and

§61.107 (private flight proficiency), to the extent they are relevant to UAS

operations, can be taught in the training proposed herein. As a review of the

requirements of part 61.127 and 107 demonstrate, the issues presented as they

relate to a 55 pound aircraft, operating at less than 30 mph during filming

operations are those taught in ground school and in flight training with the

particular UAS and not gained from accumulating flight hours in a fixed wing or

rotorcraft gas or jet A powered aircraft completing cross country flights and take

offs and landings at controlled and uncontrolled airports.
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As to national security review of pilots, each of NSA’s pilots/operators will obtain

internally provided certified training (Ground and Practical) from NSA to operate

the sUAV. This review and certification could reasonably vet the Operators against

any known terrorist or no fly listings that are relevant and publicly available.

NSA additionally asks that the exemption be issued without the requirement for a

visual observer. As set forth herein, an equivalent level of safety is provided by the

size, speed and control capabilities of the aircraft, as well as the operational

procedures that will be applicable to all flight hereunder. These obviate the need for

the visual observer.

The Operator will be operating the aircraft, always within line of sight. He or she will

walk and follow the aircraft around the inspection area so that while it is flying its

pre-programed and at times, manual flight path, the UAS will always be directly in

his or her line of sight. The Operator will not be distracted by viewing the pictures

taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty

will be to watch the flight of the UAS over the structure and intervene to address

flight path deviations or other issues that arise during the flight. The functions that

an observer performs where the aircraft is flown at long distances from the launch

area will not be necessary as the Operator will always have the aircraft in his or her

direct sight. The observer also will not be necessary because the Operator will

conduct a pre-flight inspection of the area, will and if needed, cordon off the area

and will perform frequent visual scans of the area while the vehicle is operating.

NSA again notes that the NPRM does not require the use of a visual observer. Given

the clear direction in Section 333 of the Reform Act; the authority contained in the

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding

the proposed operations, and the significant public benefit, including enhanced

safety, reduction in environmental impacts, including reduced emissions associated

with allowing battery powered sUAV’s for these functions instead of turbine or gas

power aircraft/rotorcraft and operations with pilots having at least a private pilot

license, the grant of the requested exemptions is in the public interest. 6

 

6 Should the FAA determine that it cannot grant such an exemption for operations

without a FAA licensed private pilot, despite the showing made herein, under the

statutory authority the FAA already has, North Star Aerial will operate its aircraft

with pilots holding at least a private pilot certificate issued by the FAA. In that event,

North Star Aerial requests that the exemption be granted with conditions similar to

those contained in numbered paragraphs 14-15 in Exemption 11136
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Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft

that have the characteristics and that operate with the limitations listed herein.

These limitations provide for at least an equivalent or even higher level of safety to

operations under the current regulatory structure because the proposed operations

represent a safety enhancement to the operations conducted with conventional

aircraft or with humans climbing up and around structures. These conditions are

drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109,

11112, and 11213 and as recent as 11857.

These limitations and conditions to which NSA (referred to as “Operator”) agrees to

be bound when conducting commercial operations under an FAA issued exemption

include:

1) Operations authorized by this grant of exemption are limited to

the aircraft described in the Operator’s manual, which is a multirotor weighing up to 55 pounds: Proposed operations of any

other aircraft will require a new petition or a petition to amend

this grant.

2) The UA may not be flown at an indicated airspeed exceeding 30

mph (10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet

above ground level (AGL), as indicated by the procedures

specified in the Operator’s manual. All altitudes reported to ATC

must be in feet AGL.

4) The UA must be operated within visual line of sight (VLOS) of the

Aircraft Operator at all times. This requires the Aircraft Operator

to be able to use human vision unaided by any device other than

corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all

conditions and limitations required by the FAA. The Manuals

must be maintained and made available to the Administrator

upon request. If a discrepancy exists between the conditions and

limitations in the exemption and the procedures outlined in the

Exemption Holder’s Operator’s manual, the conditions and

limitations in the exemption take precedence and must be

followed. Otherwise, the Aircraft Operator must follow the

procedures as outlined in its Aircraft’s manual. The Exemption

Holder may update or revise its Manuals. It is the Exemption

Holder’s responsibility to track such revisions and present

updated and revised documents to the Administrator upon
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request. The Exemption Holder must also present updated and

revised documents if it petitions for an extension or amendment

of this exemption. If the Exemption Holder determines that any

update or revision would affect the basis upon which the FAA

granted this exemption, then the Exemption Holder must

petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to

ensure it is in a condition for safe flight. 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. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be

properly documented in the aircraft records.

7) 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 in accordance with the Exemption holder’s

Manuals. The Aircraft Operator who conducts the functional test

flight must make an entry in the UAS aircraft records of the

flight. The requirements and procedures for a functional test

flight and aircraft record entry must be added to the Exemption

Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement,

inspection, and life limit requirements, with particular attention

to flight critical components that may not be addressed in the

manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance,

inspections, and record keeping requirements in accordance

with the Operator’s Manuals. Maintenance, inspection, and

alterations must be noted in the aircraft logbook, including total		

flight hours, description of work accomplished, and the signature

of the authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a

record entry in the UAS logbook or equivalent document of the
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corrective action taken against discrepancies discovered

between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have

logged at least 25 hours of total time as a UA rotorcraft pilot and

at least ten hours logged as a UA pilot with a similar UA type and

5 hours in the make and model.

14) 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 and land or be recovered in

accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of

unpredicted obstacles or emergencies, including unauthorized

people entering the flight area, in accordance with the

Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight

unless (considering wind and forecast weather conditions) there

is enough power to fly to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 10

minutes.

17) All aircraft operated in accordance with the 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.

18) Before conducting operations, the radio frequency spectrum

used for operation and control of the UA must comply with the

Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be

available to the Operator at the Ground Control Station of the

UAS any time the aircraft is operating. These documents must be

made available to the Administrator or any law enforcement

official upon request.

20) The UA must remain clear and yield the right of way to all other

manned operations and activities at all times (including, but not

limited to, ultra-light vehicles, parachute activities, parasailing

activities, hang gliders, etc.).
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21) The UA may not be operated by the Aircraft Operator from any

moving device or vehicle.

22) UAS operations may not be conducted during night, as defined in

14 CFR 1.1.

23) All operations must be conducted under visual meteorological

conditions (VMC). 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 Operator.

24) During operations the UA may not operate within 5 nautical

miles of the geographic center of an airport as denoted on a

current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM, if as

required by the Operator’s COA. The letter of agreement with the

airport management must be made available to the

Administrator upon request.

25) The UA may not be operated over congested or densely

populated areas unless the conditions set for in #26 are satisfied.

These populated areas include but are not limited to the yellow

areas depicted on World Aeronautical Charts (WAC), Sectional

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC).

However, aeronautical charts may not reflect pertinent local

information. Ultimately, it is the Operator’s responsibility to

maintain the minimum safe altitudes required by § 91.119 (d)

(1).

26) 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 debris in the event of an

accident. The Aircraft Operator must ensure that

nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such

protection and are within 30 feet of the UA, flight

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures

where the land owner/controller has granted permission

and/or the Aircraft Operator has made a safety assessment

of the risk of operating closer to those objects and;
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c. Operations near the Aircraft Operator do not present an

undue hazard to the Operator per § 91.119(a).

27) All operations shall be conducted over private or controlledaccess property with permission from the land owner/controller

or authorized representative. Permission from land

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.

Specific Uses Public Benefits

NSA proposes use of its sUAV provided equivalent or augmented levels of safety for

each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting

the roofs, agriculture land, buildings and large structures site surveys, wild life

monitoring, mosquito and insect control are now conducted by either humans

wading through swamps, climbing on the roofs and structures that are steep, tall,

slippery, weakened or otherwise hazardous or by the use of conventional aircraft.

The current procedures can result in significant injuries to the people who must

climb on the roofs or require the use of aircraft that are orders of magnitude greater

in size than the sUAV. Either method, manual inspection or large conventional

aircraft, results in increased risk of injury due to personnel falling off roofs or

ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or

increased risk from low altitude flyovers with helicopters or fixed wing aircraft

inspecting buildings after damage from storms or other disasters, such as

earthquakes or fires. Such flights are, of course, significantly more expensive than

those undertaken with a sUAV.

The present system exposes those not only in the immediate area of inspection, but

those who are along the path of flight associated with the arrival and departure of

the conventional aircraft at the inspection site because the aircraft must be flown to

and from the site. By contrast, the sUAV is carried to the site and transits no other

property. Conventional aircraft carry flammable fuels that are not carried by the

UAS and emit pollutants associated with internal combustion engines. The sUAV’s

proposed herein are battery powered and have no emissions.
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Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the NSA’s sUAV is

remotely controlled with no passengers or property of others on board. Section

61.133(a) requires an individual with a commercial pilot’s license to be pilot in

command of an aircraft for compensation or hire.

NSA respectfully proposes that Operator requirements should take into account the

characteristics of the particular UAS. NSA’s sUAV has a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the

potential for operation outside of the operating conditions set forth in the

exemption application. The NSA’s sUAV has navigation and control system

comprised of a Ground Control Station (GCS) and auto-pilot system that can be preprogrammed to set operational boundaries. All flights are pre-programmed with

precision GPS guidance. In the case of unplanned events, the Operator may input

pre-programmed evasive maneuvers from the control unit, and the onboard

autopilot executes those maneuvers. Pre-programmed Operator interventions

include initiation of holding at present position; suspension of mission; fly back to

launch point; abort mission and land immediately; and emergency power cut off and

land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the NSA’s

sUAV’s may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and

10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will

hold position at its current location for 5 seconds and if the signal is not

restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft

down in flight in the event of a loss of control or un-commanded

deviation from the flight path.

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog

signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph

(while imaging) nor above 200 feet above the structure (imaging

altitude) or a maximum of 400 AGL.
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Given these safety features, NSA proposes that Operators of the NSA’s sUAV should

not be required to hold a commercial or private pilot certification.

Instead, Operators should be required to: have successfully completed, at a

minimum, FAA private pilot ground instruction and passed the FAA Private Pilot

written examination or FAA-recognized equivalents; have completed the

manufacturer’s or NSA’s training program for operation of the UAS.

NSA notes that the FAA has found that safety factors permitted operation of UASs by

Operators with these qualifications in the case of operations pursuant to public

COAs where the mandatory operating conditions specified above were present. See,

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems

(UAS) Operational Approval, at 20-21 (July 30, 2013). Likewise, NSA notes that the

NPRM does not require that the Operator hold a private pilot license issued by the

FAA.

Given these conditions and restrictions, an equivalent level of safety will be

provided by allowing operation of the NSA’s sUAV without a private pilot’s

certificate or a commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the NSA’s sUAV (given its size, speed,

operational capabilities, and lack of combustible fuel) are so diminished from the

level of risk associated with private pilot operations or commercial operations

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that

allowing operations of the UAS as set forth above meets or exceeds the present level

of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of

requiring a commercial pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. Should the exemption be granted allowing commercial

operation of the UAS without an airworthiness certificate, no standard will exist for

airworthiness of the UA. Given the size of the aircraft and the requirements that the

Operator has agreed to as it relates to airworthiness, as contained in the manual, an

equivalent level of safety will be achieved by insuring compliance with the manuals

prior to each flight. The FAA has granted exemptions to conduct similar operations

in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes
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Section 91.119 establishes safe altitudes for operation of civil aircraft. Section

91.119 (d) allows helicopters to be operated at less than the minimums prescribed,

provided the person operating the helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a

helicopter and the exemption requests authority to operate at altitudes up to 400

AGL, an exemption may be needed to allow such operations.

The equivalent level of safety will be achieved given the size, weight, and speed of

the UAS as well as the location where it is operated. No flight will be taken without

the permission of the property owner, facility owner, and/or local officials. Because

of the advance notice to the property owner and participants, all affected individuals

will be aware of the planned flight operations as set forth in the Manuals. Compared

to flight operations with aircraft or rotorcraft weighing far more than the maximum

55 lbs. and the lack of flammable fuel, any risk associated with these operations is

far less than those presently presented by conventional aircraft operating at or

below 500 AGL in the aerial photography industry. In addition, the low-altitude

operations of the sUAS will ensure separation between these small-UAS operations

and the operations of conventional aircraft that must comply with Section 91.119.

The FAA has granted exemptions to conduct similar operations in Exemptions

11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure

airport or an appropriate altimeter setting available before departure.” As the NSA’

sUAV, in manual or emergency mode, will not have a barometric altimeter display,

but instead a GPS altitude display, an exemption will be needed. The Operator,

pursuant to the procedures set forth in the Manuals as indicated before flight, will

achieve an equivalent level of safety. The FAA has granted exemptions to conduct

similar operations in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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 30 minutes;

or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights

would be limited to approximately 10 minutes in length. Given the limitations on the
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UAS’ proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation

to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a

tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes

of reserve fuel, does not engender the type of risks that Section 91.151(a) was

intended to alleviate given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting

flights to 30 minutes or 25% of remaining battery power whichever happens first.

This restriction would be more than adequate to return the sUAS to its planned

landing zone from anywhere in its limited operating area. Similar exemptions have

been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808

and Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

These regulations require that an aircraft Operator or owner “shall have that

aircraft inspected as prescribed in subpart E of this part and shall between required

inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter...,” and others shall inspect or

maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the Petitioner. Maintenance will be

accomplished by the Operator or manufacturer pursuant to the flight manual and

operating handbook as referenced in the Manuals attached as confidential Exhibits

an equivalent level of safety will be achieved because these small UASs are very

limited in size and will carry a small payload and operate only in defined areas for

limited periods of time. If mechanical issues arise, the UAS can land immediately and

will be operating from no higher than 400 feet AGL. As provided in the Aircraft

Flight Operations Manual the Operator will ensure that the UAS is in working order

prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the Operator and manufacturer are most

familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety. The FAA has granted exemptions

for similar operations in Exemptions 11062 through 11067, 11080 and 11110.

*********
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Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in

the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge

inspections, flare stack inspection, utility-power generation system inspections and

patrolling, aerial inspection and photography of residential and commercial utility

infrastructure including but not limited to electrical power lines, wind turbines and

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and

videography, precision agriculture with on board sensors, wildlife and forestry

monitoring and mosquito and insect control, aerial surveying, construction site

inspection and monitoring, public entity support operations, aerial video and live

video feed to assist with search and rescue operations under the authority and

support of local authority officials, aerial video and photography for public and

private use including television, public events, and cinematography live feed and

live news-gathering, training to persons individually or belonging to both private

and public organizations to increase awareness and improve safety for current and

future UAS operations within the NAS, special events: including high schools,

colleges, professional sports, open air events and fairs, research, risk management

and assessment, motion picture production, surface mining, closed set filming,

disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Inspection will be of inanimate objects in

areas where the owners will have consented to the inspections or otherwise have

agreed to allow the UAS and the Operator to be in the area where operations will

take place.		

The size of the UAS, its speed and restricted area of operation do not raise national

security issues.

Summary

Approval of exemptions allowing commercial operations of sUAV’s for petitioner to

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare
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stack inspection, utility-power generation system inspections and patrolling, aerial

inspection and photography of residential and commercial utility infrastructure

including but not limited to electrical power lines, wind turbines and cell towers,

pipeline inspection and patrolling, filmmaking, cinematography, and videography,

precision agriculture with on board sensors, wildlife and forestry monitoring and

mosquito and insect control, aerial surveying, construction site inspection and

monitoring, public entity support operations, aerial video and live video feed to

assist with search and rescue operations under the authority and support of local

authority officials, aerial video and photography for public and private use including

television, public events, and cinematography live feed and live news-gathering,

training to persons individually or belonging to both private and public

organizations to increase awareness and improve safety for current and future UAS

operations within the NAS, special events: including high schools. colleges,

professional sports, open air events and fairs, research, risk management and

assessment, motion picture production, surface mining, closed set filming, disaster

and catastrophe events, will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing

people in swamps, on roofs or tall, hazardous or weakened structures, exposes them

to higher risks than those created by use of a sUAV’S. Conventional aircraft that

operate at extremely low altitudes just feet from the subject being inspected and in

extreme proximity to people and structures present the risks associated with

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other

fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project

location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries

eliminates virtually all of that risk given the reduced mass and lack of combustible

fuel carried on board. The sUAV is carried to the target area and not flown. The

sUAV will carry no passengers or crew and, therefore, will not expose them to the

risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the

grant of the exemptions requested herein. These lightweight aircraft operate at slow

speeds, close to the ground, and in areas that are under the control of the customer

for the operations and, as a result, are far safer than conventional operations

conducted with turbine helicopters operating in close proximity to the ground and

people or the use of individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size,

weight, speed, operating capabilities, proximity to airports and populated areas and

operation within visual line of sight and national security – provide more than

adequate justification for the grant of the requested exemptions allowing

commercial operation of Petitioner’s UAS for the Purposes outlined herein and are

consistent with exemptions already granted, including Exemptions number 11171

through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as

11857.
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Sincerely,

Adam Geiss

North Star Aerial

5605 Highwood Dr.

Edina, MN 55436

and

Stephen Gowdy

Chief Pilot,

Gowdy Brothers Aerospace, LLC

Consulting Agent for North Star Aerial
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APPENDIX A - EXEMPTION PATTERN

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain

proprietary confidential business information that is not released to the public and is

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section

333 (b).

Submitted under separate cover.
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APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA

PREVIOUS APPROVED EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION

NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED

EXEMPTION NUMBERS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.
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APPENDIX G – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS

MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they

contain proprietary confidential business information that is not released to the

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5

Reform Act Section 333 (b).

Submitted under separate cover.