Page | 1

GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

Stephen Thomas and Svetlana Thomas

GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

703.862.8191

stephen.thomas@geodroneinc.net

May 16, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C.  20590

RE: Stephen Thomas and Svetlana Thomas, Owners, GeoDrone Robotics for Exemption Request

Pursuant to Section 333 of the FAA Reform Act

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R.

Part 11, Stephen Thomas and Svetlana Thomas, GeoDrone Robotics, LLC, owners and operators of Small

Unmanned Aircraft Systems (sUAS) that are equipped to perform aerial photography, videography and

terrain features, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to

allow commercial operation of an sUAS, so long as such operations are conducted within and under the

conditions outlined herein or as may be established by the FAA as required by Section 333.1

The proposed exemption, if granted, would allow GeoDrone Robotics, LLC, to conduct commercial

operation of sUAS meeting or exceeding all of the operational and safety requirements Congress has set

forth in Section 333.  Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in

the National Air Space (NAS).  Section 333(a) states that the FAA “shall determine if certain unmanned

aircraft systems may operate safely in the national airspace system before completion of the

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required

by section 334 of the Act.”    In Section 332(b)(1), Congress made it clear that Section 333 provides a

mechanism for “expedited operation authorization” if several factors are met.  The petitioner meets all

requirements to permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief from the Following Regulations:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 91.7 (a)
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.215

14 C.F.R. 91.405

14 C.F.R. 91.407

14 C.F.R. 91.409

14 C.F.R. 91.417

14 C.F.R. 91.109

Stephen and Svetlana Thomas, GeoDrone Robotics, LLC is petitioning for exemption to enable GeoDrone

Robotics, LLC to operate a DJI Inspire 1 quadcopter.  This quadcopter has an advanced flight controller

that constantly updated and recorded using a high‐strength, intelligent GLONASS + GPS system.  This dual

positioning system allows for greater safety and higher precision.  See attached Inspire 1 User Manual

v1.2 for more information.  In addition the Inspire 1 has an advanced Inertial Measurement Unit (IMU)

that has a 6‐axis gyroscope and accelerometer to monitor any change in the sUAS’s attitude and

movement.  These systems allow the Inspire 1 to operate safely and compensate and adjust immediately

to hold its precise position at all times.  In addition the DJI Inspire 1 can accommodate two operators a

Pilot In Command (PIC) and a payload operator.  This also enhances safety by allowing the PIC to operate

the sUAS and concentrate only on flying the sUAS while the payload operator controls the camera.  The

sUAS will be equipped with cameras, camera stabilizing gimbals and on‐screen displays (OSD) providing

the PIC with altitude, airspeed, battery life and direction.  The GLONASS + GPS system will be used to limit

the altitude above the ground and limit the distance it flies from the PIC.  The Inspire 1 has GPS guided

failsafe functions that command the autopilot to fly the sUAS back to the original launch site

autonomously.  This failsafe will be triggered if the system loses the minimum number of GLONASS + GPS

signals or if the signal from the transmitter is lost or if the PIC decides to abort the flight.

GeoDrone Robotics is owned operated by Stephen and Svetlana Thomas.  Stephen has been involved with

analysis of Air and Missile defense as a contractor supporting Secretary of the Air Force Actuations, the

Ballistic Missile Defense Organization, and the Joint Chiefs of Staff.  He has owned and operated remote

controlled (RC) aircraft for over 30 years and has flown fixed wing, traditional rotary wing, and multirotor

sUAS.  GeoDrone Robotics employs various RC pilots that also meet the minimum criteria of 100 hrs. of

flight time on the Inspire 1 and hold at least a Sport Pilot License.  Current applicants hold either a Private

Pilot License (PPL) or Airline Transport Pilot (ATP) license.  Some of our candidates are retired USAF and

received their training and flight experience through the U.S. military.

Our Commercial Activities Will Include:

 Aerial Surveying

 Event Photography/Videography

 Real Estate Photography/Videography

 Aerial Filming and Photography
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

 Construction Site Inspections and Monitoring

 Building Inspections

 Roof Inspections

 Transmission Line Inspections

 Transceiver Tower Inspections

 Water Tower Inspections

 Bridge Inspections

 sUAS Training and Safe Operations

FCC Information

The Inspire 1’s C1 transmitter used for controlling the sUAS complies with part 15 of the FCC rules.  Please

refer to the User Manual (downloadable at this link http://www.dji.com/product/inspire‐1/download)

page 62 FCC Compliance.

Operation is subject to the following two conditions:

(1) This device may not cause harmful interference,  

(2) This device must accept any interference received, including interference that may cause

undesired operation.

The C1 transmitter used for controlling the sUAS is wireless technology which has been tested and found

to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to

2.4835GHz frequency range.

Pilot In Command and Observer Qualifications and Duties

The PIC will maintain at least a Sport Pilot License and a current Class III medical certificate, plus at least

10 hrs. Of flight time on the DJI Inspire 1 and at least 2 hrs. Of flight time with 3 takeoffs and landings

within 30 days of sUAS operations.  The PIC will have at least 100 hrs. Total flight time and at least 20 hrs.

Flying RC aircraft of that 10 hrs. On the DJI Inspire 1.

The PIC is responsible for the safe and efficient operation of the aircraft.    Specific duties include all

preflight preparation, in flight operation, and post flight requirements.    Procedures including but not

limited to:

 Utilize the FAA B4UFLY App to verify legal and safe operation in the planned flight area.

 Perform Pre‐Flight Check List.

 Ensure Safe Flight Operations.

 Perform Risk Assessment and Mitigation Plan to Persons and Property.

 Assess Site Suitability.

The Observer must have the visual acuity to observe the sUAS and be able to communicate clearly with

the PIC utilizing hand signals, verbally, 2 way radios, or by cellular communications.

The Observer’s duties are:
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

 Creating a pre‐flight weather report utilizing a personal weather station to collect data on the

wind speed, ambient temperature, and barometric pressure.

 Notifying the PIC of any impending obstacles in the flight path of the sUAS.

 Notifying the PIC of any deviations in the planned flight path of the sUAS.

 Notifying the PIC if unauthorized persons enter the area of the planned flight.

General Operating Standards

 Before an operation of a sUAS within 5NM of an airport with a control tower, the control tower

will be called to gain permission to operate the sUAS.  The PIC will give the position, altitude, and

the times the sUAS will be operated.  The sUAS will not be operated at an altitude of over 150 ft.

AGL.  Weather minimums will be 3 miles visibility and a 1000 ft. ceiling.

 Before an operation of a sUAS within 5NM of a non‐tower controlled airport, airport operators

will be notified and the PIC will give the right of way to avoid flying in the proximity of full‐scale

aircraft.  At no time will the sUAS be operated within the final approach course and the takeoff

course of any runway.  The sUAS will not be operated at an altitude of over 200 ft. AGL.

 Weather minimums will be 3 miles visibility and a 1000 ft. ceiling.

 GeoDrone Robotics, LLC will only operate itssUAS in line of sight of a PIC and/or Observer and will

operate at sites that are a ‘sufficient distance’ from populated areas.  Such operations will insure

that the sUAS will not create a hazard to users of the NAS or the public.

 All of our operations will be under 200 ft. AGL if we are operating within 30 miles reach of a mode

c vail.

 Maximum flight time for each operational flight will be less than 30 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute

limit.

 The sUAS will utilize ‘GPS fences’ so that it will not be operated at an altitude of no more than 400

ft. AGL, and not more than 200 ft. above an elevated platform from which data collection is

planned.

 Minimum crew for each operation will consist of the PIC, and the Visual Observer.

 The sUAS operated by the petitioner weighs less than 55 lbs., including the payload.

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously

move vertically and horizontally.
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

 All operations must utilize a Visual Observer.  The Visual Observer and the PIC must be able to

communicate by voice, 2 way radio, cellular, or hand signals at all times during flight operations.

 Flight operations will be restricted to flights over water, public or private property with the

permission of the property owner(s).

 All required permits will be obtained from state and local government prior to operation.

 sUAS will not be operated over densely populated areas.

 sUAS will not be operating over any open‐air assembly of people.

 sUAS will not be operating over heavily trafficked roads.

 All new to service sUAS both custom and pre‐manufactured will have a minimum of 25 logged

flight hours and deemed safe by the PIC prior to commercial operations.

 Flight operations will also adhere to the specifications stated in the DJI Safety Guidelines.

(downloadable at this link http://www.dji.com/product/inspire‐1/download)

 The sUAS will be maintained in accordance with the maintenance specified in the User Manual

and the Maintenance Manual (downloadable at this link http://www.dji.com/product/inspire‐

1/download).

How This Request Is To the Betterment of Our Community

The sUAS operated by GeoDrone Robotics, LLC are powered by batteries, are small, quieter, lighter, and

more maneuverable than larger aircraft running on combustible fuel, thus leaving a very small

environmental impact.   Our sUAS operate at lower altitudes and have no people on board, thereby

reducing the risk levels associated with traditional aircraft and larger UAS.  These factors increase the

safety of operation and reduce the risk of death orserious bodily injury by our aircraft.  Also, with a limited

payload and short flight duration, there is little risk to national security.    Low altitude data collection

methods are more efficient than ground based observations or manned aircraft imagery for displaying

detailed characteristics of ground based objects.  Because of the above mentioned characteristics of our

sUAS, GeoDrone Robotics, LLC intends to sell their data at a significantly reduced cost allowing for more

clients to be able to afford this type of data.  The benefits of unmanned sUAS data collection methods and

continued development and improvement of small sensors and increased flight times will benefit future

clients greatly.

GeoDrone Robotics will make our sUAS available to first responders in our community who might require

assistance, including fire fighters, police, sheriff, etc., will remaining subject to all limitations cited in this

application.
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

Exemption Requests and Equivalent Level of Safety

Stephen and Svetlana Thomas, Owners of GeoDrone Robotics, LLC requests an exemption from the

following regulations as well as any additional regulations that may technically apply to the operation of

the sUAS.

14 C.F.R. Part 21, Airworthiness Certificates:

This part establishes the procedures for the issuance of an airworthiness certificate.    While the FAA

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an

experimental certificate be issued for our sUAS’s under either or both of the following provisions:  21.191

Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and Development.  Testing new aircraft design concepts, new aircraft equipment, new

air craft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing Compliance with Regulations.    Conducting flight test and other operations to show

compliance with the airworthiness regulations including flights to show compliance for issuance

of type and supplemental type certificates, flights to substantiate major design changes, and

flightsto show compliance with the function and reliability requirements of the regulations.  Since

the experimental certificate can be used for commercial purposes such as market surveys, sales

demonstrations, and customer crew training, we would expect that an experimental certificate

would permit our commercial purpose as well.  The aircraft will not carry persons or property, will

not carry fuel, and will only fly under strict operational requirements.  The sUAS’s light weight,

being constructed primarily of carbon fiber and plastic contribute to the low risk of injury or

property damage.    We propose that the sUAS will be at least as safe, if not safer, than a

conventionally certified aircraft performing the same commercial operations.  If an experimental

air worthiness certificate is not appropriate for this application, then we request an exemption of

14 C.F.R. Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing

the equivalent level of safety outlined in the previous paragraph.

14 C.F.R. 45.23 Display of Marks; General and 45.49 Size of Marks:

These regulations provide that each aircraft must display “N” and the aircraft’s registration number in

letters at least 3” high.  Additionally, the aircraft must display the word “EXPERIMENTAL” in letters at least

2” high near the entrance to the cabin, cockpit, or pilot station.  The sUAS does not have an entrance in

which the word “EXPERIMENTAL” can be placed, and may not have a registration number assigned to it

by the FAA.  We propose to achieve an equivalent level of safety by including the word “EXPERIMENTAL”

in the placard on the top of the aircraft, where the PIC, Visual Observer, and others in the vicinity of the

aircraft while it is preparing for launch will be able to see the designation.  Additionally, a permanent

placard that will provide the aircraft’s registration information will be placed at the location of the ground

station.  Finally, we will display at the ground station a high contrast flag or banner that containsthe words

“Unmanned Aircraft Ground Station” in letters 3” high or greater.  Since the aircraft will operate within

3⁄4NM of the ground station, the bannershould be visible to anyone that observes the aircraft and chooses

to investigate its point of origin.  Additional temporary signs will be erected in the flight area that willstate

“Caution, Unmanned Aerial Vehicle in Use, Please Stay Back 500 ft. From The Operating Area.”
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

14 C.F.R. 91.7 Prohibits the Operation of an Aircraft Without an Airworthiness Certificate:

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable.

91.119 Minimum Safe Altitudes:

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500

ft. to any person, vessel, vehicle, orstructure.  Since the typical mission of the sUAS would be photography

or survey of persons, vessels, vehicles or structures, it would be necessary to operate closer than 500 ft.

to the items listed.  Operations will only be flown over property or persons where a careful pre‐planned

flight path has been plotted.  In the event of a malfunction or emergency landing, a DJI DropSafe Ballistic

Parachute System may be used or mission abort with return to home function will occur.  In either event,

the hazard to persons or property on the surface will be very limited.  Therefore we maintain that due to

the small size of the sUAS and the embedded safety equipment and procedures used, the hazard to

persons, vehicles and structures are minimal compared to manned aircraft, which should be considered

in granting the exemption.

CFR 91.121 Altimeter Settings:

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting

available within 100 NM of the aircraft.  The sUAS will always fly below 400 ft. AGL and will not need to

maintain cruising altitudes in order to prevent conflict with other aircraft.    An Above Ground Level

altimeter measurement above the takeoff point is transmitted via radio from the sUAS’s on‐board

computer to the display screen held by the PIC, providing a constantly updated AGL readout.  The DJI’s

flight controller can be configured to geo‐fence the sUAS to remain under 400 ft. maximum altitude.

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions:

The regulation provides that no person may begin a flight in an airplane under day‐VFR conditions unless

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes.  

The purpose of this is to provide an emergency reserve of fuel as a safety buffer for delays to landing.  

Since the aircraft will never fly more than 3⁄4 NM from the point of intending landing, a full battery charge

at launch will ensure that we meet the reserve energy requirement stated above.

14 C.F.R. 91.203(a) & (b) Civil Aircraft: Certifications Required:

The regulation provides that an airworthiness certificate, with the registration number assigned to the

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew." At a maximum gross weight of 55 pounds, the sUAS is too small to carry

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain

an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed

appropriate for this aircraft by the FAA will be with the crew at the ground control station and available

for inspection upon request. In order to identify the aircraft, we propose that the information found on

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing

the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 C.F.R. 45.23.
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

14 C.F.R. Subpart E (91.401 – 91.417) – Maintenance, Preventive Maintenance, Alterations:

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that

the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and

inspection.  It is our intention that our maintenance personnel along with the PIC perform maintenance

and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC

will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct

detailed inspections after every five hours of flight. All maintenance will be performed by GeoDrone

Robotics, LLC maintenance personnel with coordination from the PIC in accordance with the DJI manual.

If required maintenance is beyond the ability of the GeoDrone Robotics, LLC maintenance personnel or

the PIC, the maintenance will be performed by the manufacturer or their designated repair facility. The

GeoDrone Robotics, LLC maintenance personnel in coordination with the PIC will document work

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the

aircraft, our maintenance personnel and the PIC can ensure an equivalent level of safety.

14 C.F.R. 91.109 Flight Instruction; Simulated Instrument Flight and Certain Flight Tests:

The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction

unless that aircraft has fully functioning dual controls."  Training will be conducted by GeoDrone Robotics,

LLC.  We have the ability to provide dual controls utilizing two C1 transmitters with a wired link between

the transmitters. One transmitter is designated the master transmitter and the other transmitter is

designated as a slave.  Please refer to the attached DJI Inspire 1 User Manual.  The PIC instructor, utilizing

the master transmitter, will be at all times be able assume control of the sUAS.

14 C.F.R. 91.215 ATC Transponder and Altitude Reporting Equipment and Use:

This regulation states all aircraft operating within 30NM of class A, B and C airspace must be equipped

with automatic pressure altitude reporting equipment having a Mode C capability that automatically

replies to Mode C interrogations. Due to the small size and lifting capabilities of our UASs we cannot carry

a traditional transponder. All of our operations will be under 250 ft. if we are operating within the 30NM

reach of a mode c vail.

   
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GeoDrone Robotics, LLC

4301 Stretton Farm Ct.

Woodbridge, VA 22192

geodroneint@outlook.com

703.580.8666

Conclusion

By granting Stephen Thomas and Svetlana Thomas, Owners, GeoDrone Robotics, LLC the requested

exemptions, the FAA will help ensure the development of safe and successful commercial UAS operations

and will advance the public knowledge and perception for such operations of sUAS.  GeoDrone Robotics,

LLC personnel have a long history with Remote Controlled Aircraft and have worked closely with the U.S.

Military in areas of Counter UAS operations as well as Joint Air and Missile Defense.  We are committed

to promoting the sUAS research efforts of policymakers by sharing data from our commercial sUAS

operations and serving as a resource for future sUAS research opportunities.

GeoDrone Robotics, LLC’s sUAS will used , under authorization by the US DOT‐FAA, are small, light‐weight

(under 55 lbs.) devices that will be operated only in daylight within the line of sight of the PIC and Visual

Observer, they will operate under 400 ft. AGL and outside 5 miles from any airport or location with

aviation activities, unless the air traffic control (ATC) authorities have been properly notified and that the

ATC authorities have authorized each flight within the specified radius of their facilities.

GeoDrone Robotics, LLC seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA), which will permit the safe operation of our sUAS

commercially, without an Airworthiness Certificate.  By granting this Petition, the FAA Administrator will

be fulfilling the Congressional mandate of the FMRA of 2012, while also advancing the interests of the

public, by allowing GeoDrone Robotics, LLC to safely, efficiently, and economically operate our sUAS

commercially within the NAS.  In accordance with the FAA Regulations and the FMRA of 2012, Section

333, GeoDrone Robotics, LLC respectfully requests that the Administrator grant this petition for an

exemption from the requirements of 14 C.F.R Sections.

Sincerely,

Stephen Thomas, Svetlana Thomas

GeoDrone Robotics, LLC