ACI_20150114_333a August 2015 2 TABLE OF CONTENTS

3. List of Abbreviation s 4. Applicant Information /UAV Pilot Information

SECTION I

– INTRODUCTION AND BACKGROUND INFORMATION

5. Introduction
5

. GeoStar sUAS General Description and Imagery Product Samples
8. AeroLogix GeoStar Operations under COA 2014

- CSA

- 35

9

. The AeroLogix 333 Exemption Application and the Summary Grant Process

SECTION II

– AMENDMENT REQUEST SPECIFICS

10

. Principal Issues Addressed in the Amendment Request
10

. Combined Effects of Conditions and Limitations 4, 26 and 27.

1 1

. Requested Amendments to 11370 Conditions and Limitations and Supporting Information

11.

- Condition and Limitation No. 4

- Discussion

- Proposed Amendment to Condition and Limitation 4
13.

- Condition and Limitation No. 26

- References to the Clayco 333 Exemption

- Discussion

- Proposed Amendment to Condition and Limitation 26

14.

- Condition and Limitation No. 27

- References to the Woolpert 333 Exemptions

- Discussion

- Proposed Amendment to Conditio n and Limitation 27

SECTION III

- SUMMARY STATEMENTS

17. Amendment Summary

17

. Public Benefit

17

. Summary for the Public RegisterACI_20150114_333a August 2015 3 List of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

C&Ls Conditions and Limitations

COA Certificate of Waiver or Authorization

CTAF Common Traffic Advisory Frequency

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FSDO Flight Standards District Office

GIS Geospatial Information System

MnDOA Minnesota Department of Aeronautics

NAS National Ai rspace System

PIC Pilot in Command

RC Radio Control

RTL Return to Launchpoint

sUAS Small Unmanned Aerial System

UA Unmanned Aircraft

UAV Unmanned Aerial Vehicle

UAS Unmanned Aerial System

VFR Visual Flight RulesACI_20150114_333a August 2015 4 Applicant Contact Information:

Timothy J. Briggs AeroLogix Consulting Inc.

101 1 st St SE New Prague, MN 56071 (952) 334

- 1801 timb@aerologixmn.com

UAV Pilot Information

Timothy Joseph Briggs
Private Pilot Certificate
Certificate Number: 3518562

A SEL, Tail Dragger, Complex, High Performance endorsements.
Medical: Class II, October 2014
ASEL Time: 880 hours

US Navy Sensor Operator Flight Time (1983

- 2005)

P

- 3 Orion, S

- 3 Viking
Total Time 4000+ hours

US Army Contract Sensor Operator Flight Time (2007

- 2015)
Shorts 360 Beech King Air 350
Total Time 3500+ Hours

Fixed Wing Radio Control Experience
30+ Years

GeoStar UAV Flight Time 21 flights, 5 .3 hours total time in typeACI_20150114_333a August 2015 5 

### SECTION I

– INTRODUCTION AND BACKGROUND INFORMATION

Introduction

AeroLogix Consulting Inc. (“AeroLogix ”) i s the designer, builder and exclusive operator of the GeoStar sUAS

aerial imaging system. AeroLogix has operated the first GeoStar sUAS airframe (N542VC) since September 2014 as a

public aircraft in partnership with Le Sueur County, Mi nnesota under FAA Public Use Certificate of Waiver or

Authorization (COA) 2014

- CSA

- 35. COA 2014 CSA

- 35 is included for your reference to this amendment application.

On April 17 th , 2015, AeroLogix was awarded FAA Exemption No. 11370 under Section 333 of t he FAA Modernization

and Reform Act of 2012 to operate additional GeoStar airframes. The Conditions and Limitations (C&Ls) expressed in

Exemption 11370 define a very narrow scope of operations and have effectively eliminated m ost practical applications of

the GeoStar sUAS in the private and public sector s , especially state and county level civil engineering and mapping

projects.

AeroLogix seeks amendment s to certain C&Ls expressed in Exemption 11370 to allow greater operational

flexibility while maintaining the same levels of safety that continue to be demonstrated in our COA 2014

- CSA

- 35

operations with Le Sueur County.

GeoStar sUAS General Description and Imagery Product Samples

The GeoStar UAV is a semi

- autonomous fixed

- wing aircraft with el ectric power and a payload capacity

exceeding 10 pounds. During a collection mission, it cruises at approximately 40 mph. As one of the largest commercial

sUAS aircraft (13 ft wingspan) currently approved by the FAA, it is capab le of high

- resolution mapp ing of areas up to

1000 acres per flight while remaining within Visual Line of Sight (VLOS) of the Pilot. The GeoStar easily remains

visible to the naked eye at ranges exceeding 1 mile. The GeoStar sUAS is capable of creating advanced, high resolution

geospatial (“GIS”) imagery and engineering grade survey products

. Mapping these larger areas and c reating precision

GIS and survey products is an advanced application for sUAS. The operational requirements are quite different from

many multi

- copter opera tions that simply shoot video or still images over relatively small area s

.ACI_20150114_333a August 2015 6 GeoStar UAV in Flight

Samples of GeoStar sUAS products are depicted below:

Sample AeroLogix/GeoStar GIS Orthophoto Mosaic

– State Highway 99/112 Interchange, Le Sueur County, MNACI_20150114_333a August 2015 7 AeroLogix/GeoStar 3

- D Terrain Model

– State Highway 99/112 Interchange, Le Sueur County, MN

Sample Digital Elevation Model

– Ditch 34, Le Sueur County, MNACI_20150114_333a August 2015 8 AeroLogix GeoStar Operations under COA 2014

- CSA

- 35

In its work with Le Sueur County, the AeroLogix GeoStar sUAS has been employed to map a variety of areas. Its

imagery products have supported agricultural ditch surveys, road construction planning, development planning as well as

land and property assessment . As an affordable alternative to conventional aerial survey, the GeoStar sUAS was quickly

recognized as a valuable tool for rural counties with limited budgets for aerial survey.

AeroLogix GeoStar sUAS operations under COA 2014

- CSA

- 35, approved in August 2014, require compliance

wit h 14 CFR 91.119(c) (Minimum Safe Altitudes) that prescribe aircraft maintain a minimum of 500 feet separation from

persons and objects on the ground when operating over “other than congested areas.” To sustain compliance, GeoStar

sUAS operations up to 600 feet AGL are authorized under COA 2014

- CSA

- 35. This allows for a vertical separation of

500 feet and thus overflight of non

- participating persons, vehicles , vessels and structures

. Operating in compliance with

§ 91.119(c) through vertical separation i n this manner has proven safe and maximizes the capabilities of the GeoStar

sUAS imaging system.

In keeping with the vast majority of conventional aircraft aerial survey operations, AeroLogix GeoStar operations

under COA 2014

- CSA

- 35 do not require individual land

- owner permission for overflight and imaging of land parcels.

Public sector operations often require overflight of multiple land parcels and public

- use roads, bridges and land areas and

waterways. To the greatest extent possible, residents are advised of the impending operations . The Le Sueur County

program has been well received by the public and in many cases , residents have allowed AeroLogix/Le Sueur County the

use of their land for GeoStar UAV launch and recovery.

All Le Sueur County operations have been conducted within 1

- 1.25 miles of the launch /recovery site. Launch

and recovery sites have included county gravel roads, farm roads and farm fields . Missions have been 30 minutes or less

in duration. AeroLogix issues NOTAM s i n the days prior to missions and advises MSP ATC facilities when operations

are due to commence. AeroLogix monitors the CTAF frequencies for nearby airports and broadcasts announcements

when operations commence and are completed. As of this writing, the AeroLogix team has conducted 21 Le Sueur

County sponsored GeoStar missions at various locations within the county. There have been no incidents , near

- misses o r

conflicts with other aircraft.

Additionally, the Minnesota State Department of Aeronautics is coordinating with AeroLogix and Le Sueur

County to promote pilot awareness of GeoStar operations in Le Sueur County through informational seminars and has

agreed to sponsor an informational webpage that describes the GeoStar operational characteristics and planned missions

dates and areas. AeroLogix is also coordinating similar advisories via MnDOA for GeoStar commercial operations under

its 333 Exemption.ACI_20150114_333a August 2015 9 The AeroLogix 333 Exemption Application and the Summary Grant Process

In its original 333 Exemption application, submitted in January 2015, AeroLogix sought to operate the identical

GeoStar sUAS system, with the same personnel, in similar operational and airspace conditions that were previously vetted

and approved by the FAA in COA 2014

- CSA

- 35. AeroLogix repeatedly made specific reference to its unique status as an

established public

- use sUAS operator with documented, FAA

- approved sUAS operations in the NAS in 2014. AeroLogix

also made reference to the many public

- sector entities that had seen the capabilities of the GeoStar sUAS and expressed

interest in it s use on their projects. AeroLogix proposed wide

- ranging operations for both private and public entities over
land parcels, roadways, agricultural ditches and waterways. To achieve these g oals, AeroLogix sought to operate with the

same altitude parameters that had been approved in COA 2014

- CSA

- 35

– altitudes of up to 600 feet AGL.

At the time of the AeroLogix submission, the FAA had not announced adoption of the Summary Grant process to

speed 333 application review and processing. The FAA announced the Summary Grant process in April , 2015 as

applicable when:

“...the agency can issue a summary grant when it finds it has already granted a previous exemption similar to the new

request

. ”

“Fo r unique requests, the agency will still publish the petition in the Federal Register for public comment and will conduct a detailed analysis.” http://www.faa.gov/news/updates/?newsId=82485

– 09 April 2015

AeroLogix anticipated consideration of all factors but most importantly, consideration as an established sUAS operator

already conducting FAA approved sUAS operations under a Public

- Use COA . However, the AeroLogix application was

not con sidered a “unique” case and was subsequently considered under the Summary Grant process

. There was no

process by which an applicant could request consideration as a unique case. AeroLogix did not see its application open

for co mment in the Federal Regist er and queried the FAA on this subject . The FAA responded that it was getting

processed through the proper channels. On April 17 th , 2015, AeroLogix was granted FAA Exemption No. 11370 under

Section 333.

Upon review of the C&Ls , AeroLogix determined t hat few projects could be conducted legally under the

expressed C&Ls . AeroLogix immediately sought clarification via the FAA UAS Integration Office and the Minneapolis

FSDO. AeroLogix was ultimately directed to submit an amendment request as its only method of potential resolution.ACI_20150114_333a August 2015 10 

### SECTION I I

– AMENDMENT REQUEST SPECIFICS

Principal Issues Addressed in the Amendment Request

The main issues of the amendment request involve where and how the GeoStar UAV is allowed to operate. The

following C& Ls from Approval 11370 are sought for amendment.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and
structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticip ating persons remain under such

p rotection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined
that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the pr operty owner/controller or authorized representative. Permission from property owner/controller or authorized representative
will be obtained for each flight to be conducted.

FAA: AeroLogix Exemption No. 111370

– 17 April 2015

Combined Effects of Conditions and Limitations 4
, 26 and 27.

Limiting operations to 400 feet AGL, while simultaneously requiring 500 feet of clearance from non

- participants

and objects on the ground creates a very limited and unrealistic scope of operations for fixed wing sU AS aerial survey

platforms

. T he in ability to vertically clear structures and/ or non

- participating persons on the ground while simultaneously

restricting operations to “private or controlled

- access properties” eliminate virtually all opportunities for publ ic

- sector

aerial survey projects

. Aerial survey supports many public civil engineering projects, planning, environmental and natural

resource management. Examples are:

- Road construction and maintenance

- Storm and sanitary sewer installation

- Utility installation

- Agricultural ditches and watershed management

- Disaster responseACI_20150114_333a August 2015 11 - Invasive species monitoring in lakes and forests

- Land tract and development planning

- Wetland survey and evaluation

- Crop research

- Riverbank erosion

- Mining areas doc umentation

Since the C&Ls combine to prohibit o verflight of adjac ent public r oads and properties w ithout prior permission

,

many private sector aerial survey opportunities are also severely restricted. Most aerial survey collections require

overflight of the adjace nt roads or properties as either data requirements or when the UAV maneuvers to establish new
photo collection track s

.ACI_20150114_333a August 2015 12 Requested Amendments to 11370 Conditions and Limitations and Supporting Information

Condition and Limitation No. 4

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

FAA: AeroLogix Exemption No. 111370

– 17 April 2015

Discussion

AeroLogix understands the FAA’s desire to keep sUAS below the altitudes generally prescribed for conventional

aircraft. However, the operations conducted by AeroLogix/ Le Sueur County have clearly demonstrated that a larger

sUAS can be safely operated in rural areas i n compliance with § 91.119 (c) at altitudes up to 600 feet

. Since September

2014, AeroLogix and Le Sueur County have safely conducted most aerial survey missions in the 550

- 600 feet AGL

altitude block and have experienced no issues or conflicts with low altitude aircraft. The nature of Aerial Survey dic tates

daytime, clear weather conditions for collections and thus maximizes the VLOS ability. To maintain VLOS, AeroLogix

operates the GeoStar within 1

- 1.2 5 sm of the launch point. This relatively small area and short duration flights effectively

limit the opportunity for conflicts with other aircraft. The PIC and Visual Observer are able to clearly see the GeoStar and

other aircraft in the vicinity. Conventional aircraft have traversed a Le Sueur County operational area on two occasions

but were not a fa ctor due to altitude and direction of flight. It has yet to happen, but a potential conflict with a

conventional aircraft is dealt with expeditiously by maneuvering the UAV or recalling it back to the launch point

. Commanding Return to Launch point (RTL) initiates an immediate descent to 350 feet. In extreme situations, the

GeoStar ’ s recovery parachute can be deployed to immediately terminate the flight and e ffect a rapid descent. With the

GeoStar sUAS, either the Pilot or Telemetry Operator can command these mit igations via separate command and control

links.

AeroLogix respectfully submits that authorization for AeroLogix to operate the GeoStar sUAS in compliance

with § 91.119(c), at altitudes of up to 600 feet AGL, is warranted and precedented through the ex isting FAA authorization

to AeroLogix /Le Sueur County under COA 2014

- CSA

- 35 and AeroLogix’s demonstrated conduct of operations in 2014

-

2015 at these altitudes i n the National Airspace System.

Proposed Amendment to Condition and Limitation 4:

4. Operation of the GeoStar Unmanned Aircraft System (UAS) is authorized in Class E and G airspace, at or below

600 feet Above Ground Level (AGL). O perations at or below 600 feet AGL within Class C or D airspace, require

prior approval and coordination wit h the controlling ATC facility

.ACI_20150114_333a August 2015 13 Condition and Limitation No. 26

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and
structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such

p rotection. If a situation arises where nonparticipating persons leave such prot ection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons;
and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating clos er to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined
that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipati ng persons under this exemption.

FAA: AeroLogix Exemption No. 111370

– 17 April 2015

Ref erences to the Clayco 333 Exemption

In its attempts to clarify and properly interpret C&L No. 26 with the FAA

, AeroLogix was directed to reference

an earlier 333 e xemption granted to Clayco Inc. (11109)

. It is apparent the Clayco exemption was instrumental in

establish ing a “template” of sUAS C&Ls for most aerial data 333 E xemptions via the Summary Grant process. Review of

most 333 a pprovals since April 2015 show a nearly identica l set of C&Ls established in the Clayco decision.

Discussion

The Clayco 333 Exemption contemplated the use of a small, multi

- copter drone over private, controlled access

construction sites. It established the limitations that non

- participants must remain under protective structures and that the

UAS operators ensure they remain there. These limitations would seem generally reasonable for the relatively small

private land areas and controlled access nature of construction sites. However, the risk mitigations appropriate for the

Clayco operations are completely unre alistic for a more wide ranging aerial survey platform serving larger area projects.

The GeoStar sUAS collects imagery across areas exceeding 1sq mile. Road segments of 2 miles in length have been

collected on a single flight in Le Sueur County with the GeoStar sUAS. These operations have demonstrated the

unfeasibility of managing all persons on the ground across the span of collection areas

, controlling their movements or
obtaining their permission for overflight in advance. Additionally, once launche d, the PIC and Visual Observer monitor

the UAV’s performance visually and scan for air traffic. Scanning the ground for random persons and attempting to

estimate their proximity to the UAV is not practicable

.

When allowed to operate in compliance with § 91.119(c) through 500 f oot vertical c learance s , C &L 26(a) would

no longer be necessary. The FAA has previously determined that 500 feet vertical clearance is adequate in non

- congestedACI_20150114_333a August 2015 14 areas for both the GeoStar sUAS (COA 2014

- CSA

- 35) and conventional aircraft weighing many thousands of pounds and

flying at much higher speeds ( § 91.119(c))

AeroLogix respectfully submits that authorization for AeroLogix to operate the GeoStar sUAS in compliance

with § 91.119(c), at altitudes of up to 600 feet AGL, is w arranted and precedented through the existing FAA authorization

to AeroLogix /Le Sueur County under COA 2014

- CSA

- 35 and AeroLogix’s demonstrated conduct of operations in 2014

- 2015 at these altitudes in the National Airspace System.

Proposed Amendment to C ondition and Limitation 26:

26. Except during takeoff and landing evolutions, all GeoStar sUAS flight operations shall be conducted with at least

500 feet vertical or horizontal clearance from all nonparticipating persons, vessels, vehicles, and structures

unless:

a. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer

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

and d etermined that it does not present an undue hazard.ACI_20150114_333a August 2015 15 Condition and Limitation No. 27

27. All operations shall be conducted over private or controlled

- access property with permission from the property

owner /controller or authorized representative. Permission from property owner/controller or authorized representative
will be obtained for each flight to be conducted.

FAA: AeroLogix Exemption No. 111370

– 17 April 2015

Interpretation and References to Woolpert 333 Exemptions

AeroLogix initially interpreted C&L No. 27 to mean:

1. Overflight of any private land parcel would require that land owner’s permission.

2. The UAV could not “spill out” from a private land parcel collection and overfly a public road, public land area or other land owner’s property without the permission of the land owner or government controlling authority.

3 . Overfli ght of public roads, waterways and land areas would require approval from the controlling government agency and would not be allowed unless a procedure was in place to control the access to such areas. Closing down a road, closing ac cess to a State Park or forest area etc...

4 . A local, state or federal government entity could not commission an aerial survey flight over multiple, private
land parcels without the permission of each land parcel owner.

In its attempts to clarify and properly interpret the expressed C&L No. 27 with the FAA, AeroLogix was directed

to reference an earl ier 333 exemption granted to Woolpert Inc. (11111 ) . Woolpert sought to operate a fixed

- wing sUAS

conducting more wide

- rang ing aerial survey operations over rural areas of Ohio. The initial Woolpert 11111 exemption

did not specifically limit their operations to “ private or controlled

- access property

. ” Woolpert was directed to obtain

authorization from a “Land Owner/Controlle r or Authorized Representative.” This would seem to imply that

authorization from a governmental entity for flights over public areas would be authorized. A subsequent amendment to

Woolpert (11111A), imposed the same “ private or controlled

- access propert y” limitation established in Clayco. In its

analysis of Woolp e rt’s proposed standoffs from highways, the FAA expressed its concern about potential overflight of

roads in violation of § 91. 119 (c):

“The FAA has reviewed these restrictions ( Woolpert’s proposed standoffs ) and finds that they are not sufficient to comply with § 91.119(c) which prohibits operations closer than 500 feet to any person, vessel, vehicle, or structure. Without a means to control or limit access to the operating areas, which cou ld include roads occupied by persons and vehicles, operations must comply with § 91.119(c).”

FAA : Woolpert Inc. Decision, Exemption 11111, 10 December 2014

In its analysis, the FAA was clear in its concerns about potential overflight of roads or areas occupied by non

- participating

vehicles and persons. Woolpert was limited to 400 feet AGL and thus unable to comply with § 91.119(c) by vertical

clearances. Woolpert was granted another exemption (11114) to conduct aerial survey missions over a National P ark onACI_20150114_333a August 2015 16 Ship Island, MS. In 11114, there was no expressed limitation of operations to “ private or controlled

- access property .”

AeroLogix could find no further information in either of the Woolpert decisions that specifically discuss private vs. public

lan d.

Discussion

As was the case in C&L No 26 and the Woolpert decision, i t is clear that the overriding concern by the FAA is the

overflight of non

- participating persons and vehicles at altitudes less than those prescribed in § 91.119(c). L imiting all

operations to “private or controlled

- access property ” limits the opportunity for non

- participants to enter an area of

operation where a sUAS is operating below the vertical minimums prescribed in § 91.119(c)

. However, as previously

stated, this limitation also severely restricts the opportunity for most sUAS aerial surveys in both the public and private

sector s. The vast majority of aerial surveys enc ompass both public and private areas. Proper aerial surveys of most land

parcels require the overflight o f public roads that either traverse or border the land parcel. I n many cases, public road s,
ditches and waterways are the desired survey subject. P ortions of the adjacent private lan d parcels need to be included for

proper data processing and the extraction of pertinent elevation data.

I n § 91.119(c), t he FAA has determined that 500 feet vertical clearance is adequate in non

- congested areas for a

conventional aircraft weighing many thousands of pounds and flying at much higher speeds than a sUAS

. In approving

COA 2014

- CSA

- 35, the FAA determined that the GeoStar sUAS, operated exclusively by AeroLogix, could be safely

operated in compliance with § 91.119(c) at altitudes of up to 600 feet on government sponsored operations over both

public and private land areas

.

AeroLogix respectfully submits that authorization for AeroLogix to operate the GeoStar sUAS in compliance

with § 91.119(c), at altitudes of up to 600 feet AGL, over public and private areas is warranted and precedented through

the existing FAA authorization to AeroLogix /Le Sueur County under COA 2014

- CSA

- 35 and AeroLogix’s demonstrated

conduct of operations in 2014

- 2015 at thes e altitudes in the National Airspace System.

Proposed Amendment to Condition and Limitation 27:

27. All GeoStar sUAS op erations shall comply with § 91. 119(c) by maintaining at least 500 feet vertical or horizontal clearance from any non

-

participating person, vehicle, vessel or structure. Any operations that cannot comply with § 91.119(c) through vertical clearances shall:

(a) B e restricted to private or controlled

- access property with permission from the proper ty owner/controller or authorized representative. And;

(b) Permission from the property owner/controller or authorized representative will be obtained for each flight to
be conducted.ACI_20150114_333a August 2015 17 

### SECTION I II

– SUMMARY STATEMENTS

Amendment Summary

AeroLogix is in a unique position as one of the few commercial sUAS builders/operators to exclusively operate a

proprietary system under a public

- use COA before the existence of most 333 Exemptions. The issue at the core of this

amendment request is whether or not the FAA will permit AeroLogix to operate the GeoStar sUAS in compliance with

§ 91.119(c) through 500 foot vertical clearances of persons and objects on the ground. In approving COA 2014

- CSA

- 35,

the FAA made the determination in August 2014 that AeroLogix could indeed operate the GeoStar sUAS in its

partnership operations with Le Sueur County over rural areas at altitudes of up to 600 feet AGL. These operations hav e
clearly demonstrated that AeroLogix possesses the operational competence to safely operate the GeoStar sUAS at these

altitudes in the NAS. With this amendment request, as in its original 333 Exemption application, AeroLogix seeks to

operate the identica l GeoStar sUAS system, with the same personnel, under the same operational and airspace conditions

that were previously vetted and approved by the FAA in COA 2014

- CSA

- 35.

Public Benefit

AeroLogix submits that approval of this amendment request is in the public interest and would be of great benefit

to many public agencies. Few public operations can be conducted under the original set of C&Ls expressed in Exemption

No. 11370. Approval of this amendment request will facilitate cost

- effective and unobtrusi ve aerial surveys to many

public agencies and institutions.

Summary for The Federal Register

Specific Rules Sought For Exemption

AeroLogix Consulting Inc., a Minnesota based builder and operator of advanced Small Unmanned Aerial Systems

(sUAS), is seeking an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.

AeroLogix is requesting exemption from th e following regulations under 14 CFR:

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Certifications Required 14 CFR § 45.23 Display of marks; general. 14 CFR § 45.25 Location of marks on fixed

- wing aircraft.
14 CF R § 45.29 Size of marks. 14 CFR § 61.113 Private Pilot Privileges and Limitations: Pilot In Command 14 CFR § 61.133 Commercial Pilot Privileges and Limitations. 14 CFR § 91.7 (a) Civil Aircraft Airworthiness 14 CFR § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft 14 CFR § 91.121 Altimeter SettingsACI_20150114_333a August 2015 18 14 CFR § 91.151 (a)(1) Fuel Requirements for Flight in VFR Conditions. 14 CFR § 91.207 (a)(1) Emergency Locator Transmitters (ELTs). 14 CFR § 91.307 (a) Parachutes and P arachuting 14 CFR § 91.405 (a) Maintenance Required 14 CFR § 91.407 (a)(1) Operation After Maintenance, Preventative, Rebuilding or Alteration 14 CFR § 91.409 (a) (1)(2) Inspections 14 CFR § 91.417 (a)(b) Maintenance Records

AeroLogix intends to commercially operate the GeoStar sUAS in rural areas for public and private customers. The

GeoStar sUAS performs aerial survey to produce imagery and terrain modeling products useful in applications ranging

from civil engineering, land and water resource management, environmental research, disaster response, agriculture and

many others useful applications. The FAA has previously approved AeroLogix and the GeoStar sUAS for public

operations under FAA Certificate of Waiver or Authorization (COA) 2014

- CSA

- 35 . This new exemption under Section

333 of the FAA Modernization and Reform Act of 2012 will permit AeroLogix to serve both public and private entities

with safe and affordable aerial survey services . The FAA and general public can have confidence that th e operations will

achieve an equivalent or greater level of safety as that demonstrated by conventional aerial survey providers.