To F rom

US Departm ent of

Transportation Jennif e r M. Clark, M.S. Docket Managem ent F acility Chief Executive Of

f icer 1200 New J ersey

Avenue, SE W est Geotechnical Testing & I nspections (GTI ) B u ilding Ground F loor Room W 12-140 7855 East Evans Road, Suite “C” W a shing ton, DC 20590 Scottsdale, AZ 85260 (480) 659-6630

BASIS F OR P ETITION

Petitioner, Geotechnical Testing & I nspections (GTI ), p ursuant to the provis i o n s o f the F ederal Aviation Reg ulations (14 C.F .R § 11.61) and the F AA Moderni z e d a n d Reform Act of 2012 (F MRA), Section 333, Special Rules for Certain Unmanned A i r craft Sy stems (UAS), hereby petitions the Administrator to commercially o perate the DJ I Phantom 2 Vision+, in t h e National Airspace Sy stem (NAS), and for an ex emption from the requirements of :

! 14 C.F .R §§ 61.113(a) & (b)

! 14 CF R 45.23(b)

! 91.7(a),

! 91.121,

! 91.151(b),

! 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91

NAME AND ADDRESS OF THE P ETITIONER

The name and address of the Petitioner and point of contact is:

J e nnifer M. Clark, M.S. Chief Ex e cutive Officer (CEO) 7855 East Evans Road, Suite “C” Scottsdale, Ariz ona 85260 Office: 480-659-6630 F ax :480-659-7280 email: J e n nifer@g tiaz .com

P REF ACE

The F ederal Aviation Act e x pressly g rants the F AA the authority to issue ex emptions. This statutory authority by its terms includes ex empting civil aircraft, as the term is defined under §40101 of the Act, that includes Unmaned Aircraft Sy stems (UAS), from the requirement that all civil aircraft must have a current airworthiness certificate.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 2

The Administrator may g ra n t a n e x e m ption from a requirement of a regulation prescribed under subsection (a) o r (b) of this section or any sections 44702 44716 of this title if the Administrator finds the ex emption in the p ublic interest. 49 U .S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CF R §91.203 (a) (1).

Geotechnical Testing and Inspections (GTI ) proposes to use one o r more Unmanned Aerial Drones (DJ I PHANTOM 2 Vision +), for the following uses:

# Conduct Phase I Environmental Site Assessment I nspections of undeveloped properties.

# I nspections of roadway s which are to be widened or improved.

# Periodic inspections of infrastructure improvement projects.

# B ridg e ; Roadway

and site development inspections

# A s s i s t w ith damag e a ssessments o r situational status reports during construction operations and/or emerg e ncy response operations

# Evaluations of undeveloped desert land.

# I nspection of earth fissures and g round subsidence areas.

# I nspection and documentation of construction operations.

This UAS has four rotors and four motors i n a quadcopter configuration ( X4). The unit is only capable of vertical takeoff a nd landing s. This UAS weig hs under to 3 lbs which is substantially less than the 55 lbs c lassification, including payload. I t can fly
, under normal c onditions, at a speed of

no more than 30 k

nots and has the capability to hover, a nd move in the vertical and horiz ontal plane simultaneously

. This U AS is equipped with GPS and has an auto r eturn function that returns the unit
to the predetermined safe landing area as well as allowing reading of mag netic interference that can

cause loss off GPS sig nal. The UAS is operated only in line of sig ht a nd w ill operate only within the limits of publi c rig hts of way or easements or private property for which authoriz ation has been obtained. Such operations will be conducted to insure that the U AS will “not create a haz ard to users of the national airspace system or the public.” (Reform Act Section 333 (b)).

This ex emption application is ex pressly submitted to fulfill Cong ress’ g o al in passing Section 333(a) throug h (c) of the Reform A ct. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft sy stems may operate safely in the national airspace sy stem (NAS) before completion of the rule making required under Section 333 of t h e R e f o rm Act. I n making this determination, the Secretary is required to determine which ty p e s of UASs do not create a haz ard to users of the NAS or the public or pose a threat to national security in lig ht of the following :

! The UAS’s siz e , weig ht, speed and operational capability ;
! Operation of the UAS in close prox imity to airports and populated areas; and

! Operation of the UAS within visual line of sig ht of the operator.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 3

Reform Act § 333 (a). Secretary determines that such vehicles “may operate safely in the national airspace sy stem, the Secretary shall establish requirements for the safe o peration o f such aircraft in the national airspace sy stem.” I d. §333©.

The F ederal Aviation Act e x pressly g rants the F AA the authority to issue ex emptions. This statutory authority by its terms includes ex empting civil aircraft, as the term is defined under §40101 of the Act, that includes UAS, from the requirement that all civil a ircraft must have a current airworthiness certificate.

The Administrator may g rant an ex e mption from a requirement of a regulation p r e s c r i b e d under subsection (a) or (b) of this section or any sections 44702 44716 of this title if the Administrator finds the ex emption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CF R §91.203 (a) (1).

RELIEF OVERVIEW

Given the very small siz e of the UAS involved and the restricted e nvironment within which they will operate, the applicant falls squarely within that z o ne of safety (an equivalent level of safety ) in which Cong r ess envisioned that the F AA must, by ex emption, a llow c ommercial operations of UASs to

commence immediately

. Also due to the siz e of the UASs and the restricted areas in which the relevant UAS will operate, approval of the application presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the F ederal Aviation A ct, as amended; the strong equivalent level of safety surrounding the p roposed operations, and the sig nificant p ublic benefit, includingenhanced safety
, reduction in environmental impacts, including reduced emissions associated with a llowing UASs for aerial inspections, survey ing
, phot o gr aphy and videog raphy
, the g rant of the r e quested e x emptions is in the public interest. According ly , the applicant respectfully requests that the F AA g rant the requested ex emption.

A IRCRAF T AND EQUIVALENT LEVEL OF SAF ETY

Geotechnical Testing & I nspections (GTI ) proposes that the ex emption re quested 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 hig her level of safety to operations under the
current regulatory structure because the proposed operations represent a safety e nhancement to the already safe aerial inspections, survey ing and photog raphy and videog raphy operations conducted with conventional aircraft.

These limitations and c onditions to which Geotechnical Testing & I nspections (G T I ) ag rees to be bound when conducting commercial operations under an F AA issued ex emption include:Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 4

1. The UAS will weig h less than 55 lbs. 2. F lig hts will be operated within line of sig ht of a Pilot I n Command (PI C). 3. Max imum total flig ht time for each operational flig ht will be 30 minutes or less. F lig hts will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. F lig hts w ill be operated at an altitude of no more than 300 f e et AGL or, n ot more than 200 feet above an elevated platform for which filming is planned. 5. Minimum crew for each operation will consist of qualified UAS. 6. The UAS will only operate within the defined project area, the boundaries o f w hich will be determined b y the UAS Pilot I n Command (PI C) based on the site specific activities and speed of the UAS required for the o peration, a nd c oordinated with the jurisdictional F AA F SDO and local g overnment officials, as applicable. 7. A briefing will be conducted in reg ards to t h e p l an n e d UA S o p e rations prior to each day ’s o peration. I t will be mandatory that all personnel who will b e performing duties within the boundaries of the project be present for this briefing

. 8. The UAS Pilot w i l l b e a b l e t o c o m m u n i c a t e b y v o i c e an d / or two way radio communication sy stem with office manag ement at all times. 9. The operations of the UAS will be limited to day lig ht operations only

. 10 I f the UAS l oses communications or loses its GPS sig nal, the UAS will have the capability to return to a p re-det ermined location within the Project Perimeter and land safely

. 11. The UAS will have the capability to abort flig h t in c ase of u n p r e d i c t ed obstacles or emerg encies

14 C.F .R. P art 21, Subpart H: Airw orthiness Certif icates 14 C.F .R. §91.203 (a) (1)

Subpart H, entitled A irworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness c ertificates as required by F AR §91.203 (a) (1). Given the small siz e and limited operating area associated with the aircraft to be utiliz e d by the Applicant, a n ex emption from Part 21 Subpart H meets the r equirements of an e quivalent level of safety under Part 11 and Section 333 of the Reform Act. The F ederal Aviation Act (49 U.S.C.§44701 (f)) a n d S e c t ion 333 of the Reform Act both authoriz e the F AA to e x empt aircraft f rom the requireme n t f

o r a n airworthiness certificate, upon consideration of the si z e, weig ht, speed, operational capability
, a nd prox imity to airports and populated a reas o f the particular U AS. I n all c a s e s , a n a naly sis of these criteria demonstrates that the UAS o p e r a t e d w ithout an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, o r safer, than a conventional aircraft (fix ed wing or r otorcraft) operating with an airworthiness certificate without the r e strictions

a n d conditions proposed. I n consideration of the speed, weig ht, siz e, and limited opera t i n g a r ea associated with the unmanned aircraft and its operation, the Geotechnical T e sti n g & I n s pections (GTI )’ operation of DJ I Phantom 2 Vision+, UAS meets the c onditions of F MRA Section 333 and therefore, will n ot require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 5

According ly
, Geotechnical Testing & I nspections ( GTI ) requests relief from Sect i o n s 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements f or maintenance that only apply to a ircraft with an airworthiness ce r t i ficate. Geotechnical Testing & I nspections (GTI ) submits that the requested relief is p roper since an equivalent level of safety will be ensured. Geotechnical Testing & I nspections ( G TI ) will use ex perienced personnel or technicians

as needed t o p er fo rm maintenance, alterations, o r preventive maintenance on the UASs using the

m e t h o d s , t e c h n i q u e s , a n d p r a c t i c e s p r e s c r i b ed in the operating documents (i.e., Monthly Maintenanc e L o g, a nd DJ I Phantom 2 Vision+ I nstruction Manual). F urthermore, Geotechnical Tes t i n g & I nspections ( GTI ) w i l l d o c ument and maintain all maintenance records for the DJ I Phantom 2 Vision+ UAS.

Relief from c ertain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command,, is r equested b y Geo t e c h n ical T e sting & Inspections (GTI ) to the

ex tent necessary to allow a Pilot in Command (PI C) meet or ex c eed the d escribed requirements of operations set by manufacturer, and who has demonstrated, that the PI C is able to safely operate the D J I P hantom 2 Vision+ UAS in a manner c onsistent with this ex emption, including evasiv e a n d
emerg ency maneuvers and maintaining a ppropriate d istances f

rom people, vessels, vehicles and
structures.

Geotechnical Testing & I nspections ( GTI ) seeks relief from Section 91.7(a), e n t itled Civil aircraft airworthiness
, because the DJ I Phantom 2 Vision+ U AS do not require an airworthiness c ertifica t e i n a ccordance with 14 C.F

. R. Part 21, Subpart H. As such, Geotechnical Testing & I nspections (GTI ) submits that he will ensure that the DJ I Phantom 2 V ision+ UAS is in

an airworthy condition, prior to every flig ht, by determining that the UASs are in compliance with the operating

documents (i.e., Monthly Maintenance L og , and DJ IPhantom 2 Vision+ I nstruction Manual), and that the aircraft are in a condition for safe flig ht.

Geotechnical Testing & I nspections ( GTI ) also seeks an ex emption from the requirements of Section 91.121, entitled Altimeter Setting s, as the DJ I Phantom 2 Vision+ will not have a ty pical barometric altimeter onboard. Howe v e r , a l t i t ude information of the DJ I Phantom 2 Vision+ will be provided
to the PI C via Global Positio n i n g S y s t e m ( G PS) e quipment and radio communications telemetry data link, which downlinks f

rom the UA to the GCS for a ctive monitoring of the f lig ht p ath. T his altitude information, combined with G eotech n i c al Testing & I nspections (GTI )’ o peration of the DJ I Phantom 2 Vision+ UAS within visual line of sig ht, at or below 300 feet AGL
, will ensure a level of safety equivalent to Section 91.121.

Additionally
, Geotechnical Testing & I nspections (GTI ) seeks an ex emption from the requirements of Sectio n 9 1

. 1 5 1 ( b )
, e nt i t l e d F u e l re q u i r e m e n t

s f o r f l i g h t i n V F R c o n d i t i o n s

. G T I s u

bmits that safety will n ot be affected by operation of the DJ I Phantom 2 V ision+ during daylig ht hours in visual meteorolog ical conditions ( VMC) under visual flig ht rules (VF R), with enoug h battery power to fly for a total duration o f approx imately 30 minutes to the first point of intended landing and, assuming normal cruisingspeed, to fly after that for at least 5 minutes.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 6

EXTENT AND REASONING WHY G EOTECHNICAL TESTING & INSP ECTIONS SEEK S RELIEF F ROM THE LISTED SECTIONS ABOVE:

1. Section 61.113(a) & b).

Relief from Section 6 1

. 1 1 3 (a) and (b) e ntitled Private p ilot privileges and limitations; Pilot in command, is requested to the ex tent necessary to allow a PI C meet a ll requirements as described in the DJ I Phanto m 2 Vision+ owner’s manual to conduct the proposed UAS flig ht operations for compensation or hire.

This reli ef is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may , for compensation or hire, a ct as PI C o f a n a i r c r a f t i n c onnection with any business o r employ

ment if: (1) The flig ht is only incidental to that business or employ ment; and (2) The aircraft does not carry passeng ers or property

for compensation or hire.

As set forth more fully below, Geotechnical Testing & I n spections (GTI ) submits that an equivalent level of safety will b e maintained because no PI C will b e a llowed to operate the DJ I Phantom 2 Vision+ UAS unless that PI C has demonstrated that the PI C is able to safely operate either the DJ I Phantom 2 V ision+ UAS in a manner c onsistent with the operations specifications

as descri b ed in this ex emption, including evasive a nd emerg ency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

F urther, Geotechnical Testing & I nspections (GTI ) submits that all flig hts of the DJ IPhantom 2 Vision+ 1 UAS, conducted by the PI C pursuant to the g rant of this Petition: (1) will be incidental to Geotechnical Testing & I nspections (GTI )’ business; and (2) will not carry passeng ers or property for compensation or hire.

2. 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is r equested t o the ex tent required to allow Geotechnical Testing & I nspections (GTI ) to determine that the DJ I Phantom 2 Vision+ U ASs are in airworthy condition prior to every flig ht by ensuringthat the UAS is in compliance with the operating d o cuments (i.e., the Geotechni c a l T e s ting & I nspections (GTI ) O p e r a t i ons Manual, Monthly Maintenance L og , and DJ I Phantom 2 V i s i o n + I n s t r u c t i o n M a n u a l )

. Geotechnical Testing

& I nspections (GTI ) seeks the requested relief b ecause the DJ IPhantom 2 V ision+ UAS does not require an airworthiness certificate in accordance w ith 1 4 C.F .R. Part 21, Subpart H

. T h e r efore, Geotechnical Testing & I nspections (GTI ) will e nsure that the DJ I Phantom 2 Vision+ UAS are i n a i rworthy condition based upon its compliance with the operatingdocuments (i.e., Monthly Maintenance L o g , and DJ I Phantom 2 Vision+ I nstruction Manual) prior to every f

lig ht, and further, d e t e r m i n e that the aircraft are in condition for safe flig ht, as stated in the conditions and limitations below.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 7

3. 91.121

.

Relief from Section 91.121, entitled Altimeter setting s, may be required to allow flig ht operations of the D J I Phantom 2 V ision+ UAS, which utiliz e a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link t o d o wnlink altitude information from the UA to the PI C at the g round control station (GCS). S i n ce t h e F A A requires that any altitude information concerning UAS o perations be reported to air traffic control ( ATC) in feet above g round level (AGL ), GTI seeks the requested relief because the DJ IPhantom 2 Vision+ UA altimeter may be set o n the g round to zero feet AGL
, r a ther than the local barometric pressure or field altitude, before each flig ht.

Considering the limited altitude of the proposed operations, relief from 1 4 CF R 91.121 is soug ht
to the ex tent necessary to comply with the applic a b l e conditions and limitations stated below. As more fully set forth h erein, an equivalent level o f safety will be mai n t ained since the DJ I Phantom 2 Vision+ UA are equipped with a b arometric p ress u r e s e n s o r and G PS equipment, which automatically e n sures that a g round level pressure setting will be established prior to each flig ht, and provides the PI C with altitude information of the UA on the heads up display of the GCS.

4. 91.151(b).

Relief from Section 91.151(b) entitled F uel requirements for f lig ht in VFR c o n d itions, is requested to the ex tent required to allow flig hts of the battery p owered DJ I Phantom 2 Vision+ UA during daylig ht hours in v isual meteorolog ical conditions ( VMC), un der visual flig ht rules (VF R), for a total duration of 25 minutes to the first p o i n t of intended landing and, assuming normal cruising speed, to f l y a f t er that for at least 5 minutes. G TI seeks the requested relief because without an ex e mpt i o n f r o m Section 91.151(b), the flig h t time duration of the battery powered DJ I Phantom 2 Vision+ UA will severely constrain the practicality of any aerial video

or still ph o t o f

l i g ht operations that Geotechnical Testing & Inspections (GTI ) proposes to conduct pursuant to this Petition.

Sig nificantly
, as set forth b elow, the technical specifications o f the D J I Phantom 2 Vision+ UAS, the DJ I Phantom 2 Vision+ operating documents, and Geotechnical Testing & I nspections (GTI ) proposed operating limitations, ensure that Geotechnical Testing & Inspections (GTI ) will safely operate the battery p owered D J I Phantom 2 Vision+ U A during dayli gh t h o urs in visual meteorolog ical conditions (VMC), under visual flig ht rules ( VF R), with enoug h battery power to fly for a total duration of 25 minutes to the first p oint o f i n t e n d ed landing and, assuming normal cruisingspeed, to fly after that for at least 4.5 minutes.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 8

14 CF R 45.23(b)

. Marking of the Aircraft; Applicable codes of F ederal Reg u lation require aircraft to be marked according to certain specificat i o n s

. UA V F ield Services U ASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or p ilot station on which to mark certain words or phrases. F urther, two inch lettering is difficult to place on such small aircraft. Reg ardless, UAV F ield Services w ill mark its UAS in the larg est possible lettering by placing the " N " number on its fuselag e as r equire d b y 1 4 CF R 45.29 (f) so that the pilot, technician, spotter a nd others working with the UAV will see the marking s. The F A A has previously issued ex emptions to this
regulation throug h Ex emption No 10167 and 10700 .

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), a nd 91.417(a) & (b) o nly apply
to aircraft w ith an airworthiness certificate, Geotechnical Testing & I nspections (GTI ) requests relief from these Sections because the D J I Phantom 2 Vision+ UAS do n ot require airworthiness certificates. As set forth more fully below, the DJ I Phantom 2 Vision+ UAS meet the conditions of F MRA Section 3 33 for operation witho u t a n airworthiness certificate. A ccording ly Geotechnical Testing & I nspections (GTI ) will u se trained technicians to p e rform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Geotechnical T e sting & I nspections (GTI ) aerial Operations Manual, Monthly Maintenance L o g , and DJ IPhantom 2 Vision+ I nstruction Manual). F urthermore, Geotechnical Testing & Inspections (GTI ) will d ocument and maintain all maintenance records for the DJ IPhantom 2 Vision+ UAS.

The Reasons f

or granting this request are entirely benef icial to the public and com m unity as a w hole.

Granting the present Petition w i l l further the public interest by allowing Geotechnical Testing & I nspectio n s (GTI ) to safely
, efficiently
, and economically perform aerial video and photog raphic
survey s a nd inspections of construction sites, r ig hts of way , utility easements, and o ther sites. This

ex e mption application is e x pressly submitted to fulfi l l C o ng ress’ g oal in passing Section 333(a) throug h (c) of the Reform A ct. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft sy stems may operate safely in the national a irspace sy stem (NAS) before completion of the rule making r e q u i r ed under Section 3 3 2 of the Reform Act. I n making this determination, the Secretary is required to determine which ty pes of UAS do not create a haz ard to users of the NAS or the public or pose a threat to national security in lig ht of the following :

! The UAS’s small siz e, lig ht weig ht, speed and operational capability ;
! Operation of the UAS in close prox imity to airports and populated areas; and

! Operation of the UAS within visual line of sig ht of the operator.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 9

Reform A ct § 333 (a). L astly
, id. the Secretary determines that such vehicles “may operate safely in the national airspace sy stem, the Secretary shall establish requirements f or the safe operation of such aircraft in the national airspace sy stem.” I d. §333©.

Given the small siz e of the UAS involved a nd the restricted sterile environment within which they will operate, the applicant falls squarely within that z one of safety (an equivalent level of safety ) in which Cong ress envisioned that the F A A m u s t , b y ex e mption, allow commercial operations of UASs
to commence immediately

. Also d u e t o t he siz e of the UASs and the r estricted areas in which the relevant U AS will operate, approval of the application p resents no national security issue. Given the clear direction in Section 3 33 of the Reform Act, the authority contained in the F ederal Aviation Act,

as amended; the strong e quivalent lev e l o f s a f e ty surrounding the proposed operations, and the sig nificant public benefit, including enhanced safety
, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie a nd television operations, the g rant of the requested ex emptions is in the public interest. According ly , the applicant respectfully requests that the F AA g rant the requested ex emption without delay

.

REASONS BENEF ICIAL TO THE P UBLIC/COMMUNITY

1. The P ublic Will Benef it f rom Decreased Congestion of the NAS.

The DJ I Phantom 2 V ision+ U A a r e b a t t e r y powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utiliz ed to o btain aerial imag ery

. B y reducing the amount of manned a i rcraft n eeded to perform aerial acquisitions, an

ex e mption allowing the use of a DJ I Phantom 2 Vision+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air p ollution, a s well as increase the safety of life and property

in the air and on the ground.

F urthermore, by reducing the number of manned aircraft operating in the NAS, cong estion around airports caused by arriving and departing aircraft will be r educed. T h e DJ I Phantom 2 V ision+ UA do not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photog raphy missions would result in fewer aircraft that
must be handled by air traffic control during the g round, takeoff
, d e p ar t u r e , a

rrival, and landing phases of flig ht operations.

2. The P ublic Will Benef it F rom The Sa f

e t y A n d E f

f i c i e n c y O f

The DJI P hantom 2 Vis ion+ UAS.

Conducting aerial a cq u i s i t ions with the D J I Phantom 2 Vision+ UAS, instead of manned aircraft, will g reatly benefit the public by drast i c al l y reducing the levels of air and noise pollution g e nerated during traditional aerial video and still photog raphy flig ht o p erations. B y usin g b a t t e ry power and electric motors, the D J I Phantom 2 V ision+ UAS produce no airGeotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 10

pollution, and is the most viable environmentally conscious a lternative to the cabin class, six
cylinder internal c o mbustion eng ine aircraft that a r e t y p i c ally utiliz ed for aerial video and photog r aphy
, while b urning approx imately 2 0 30 g allons per hour of leaded aviation fuel. The DJ I Phantom 2 Vision+ UA, while reducing the carbon f ootprint of aerial acquisitions, also eliminates n oise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion eng ine.

B y using the DJ I Phantom 2 V ision+ U AS to perform aerial observation, the substantial risk
to life and property in the air and on the g round, which is u sually associated with traditional manned aircraft flig ht operations, will be substantially reduced or completel y eliminated. Aside f rom the lack o f flig ht crew members located onboard the aircraft, the DJ I Phantom 2 Vision+ UA ( weig hing approx imately 2 pounds 11 ounces, at their max imum g ross weig hts with leng th of 16 inches, widths o f 16 inches, and w ith no fuel on board), has less phy sical potential f

o r c o l l at eral damag e to life and property o n the g round, and in the air,

c o m p a red to the manned aircraft that ty pically conduct similar operations (weig hin g approx imately 6,000 pounds with a wing span of approx imately 42 feet, a leng th of 34 feet, and a fuel capacity

of 180 g allons).

3. P erf orm ing Aerial Video and P hotography, surveys and Inspections, Operations w ith the DJI P hantom 2 Vision + UAS Will Benef it the Econom y.

I n a ddition to being safe and efficient, the DJ I Phantom 2 Vision+ UAS are also p rovides an economical alternative to using manned aircraft to conduct si m i l a r a e r i a l operations. As such,

o p e r a t i o n of the D J I Phantom 2 Vision+ UAS will allow the Geotechnical Testing & I nspections (GTI )
, to provide quality services to the residents, cli e n t s and the City and the Reg ion at minimum costs. Specifically
, with the rising cost of aviation fue l and the Environmental Protection Ag ency (“EPA”) regulatory actions phasing out le a d ed aviation fuels, ag en c ies must adopt new and alternative technolog y in c ontinue to provide required services at reasonable c osts. Operating the battery powered DJ I Phantom 2 V ision+ UAS is

o n e s u c h technolog y that n ot only allows ag encies & companies g reater operation a l flex ibility c ompared to manned aircraft, but provi d es such flex ibility w ithout the hig h operational cost of a traditional manned aircraft.

B y operating the DJ I Phantom 2 Vision+ U A S
, t h e G e o technical Testing & I nspections (GTI )

can maintain and hopefully improve our ability to operate and maintain critical infrastructure and at the same time collect important data for further development of sy stem wide modeling of water, w ater, stormwater and r oadway sy stems as well as provide a ccurate and current data related to environmental issues such as g round cover, veg etation & wildlife habitats.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 11

4. There Are No P rivacy Issues.

Similar to th e manned aerial acquisition flig ht operations that have been conducted f or decades, the G eotechnical Testing & I nspections (GTI )’ proposed operation of the DJ I Phantom 2 Vision+ UAS will n ot implicate a ny privacy issues. Specifically
, the DJ I Phantom 2 Vision+ U AS will be operated only i n compliance with operating documents (i.e., the Geotechnical Testing & I nspections (GTI ) Aerial Operations Manual, Monthly Maintenance L og , and DJ I Phantom 2 Vision+ I nstruction Manual) which requires pr o p ertyowner involvement as well as local law enforcement noti f i c ation, and in accordance with the F ederal Aviation Regulations, including the max imum altitude limitations a s per the requirements of 14 C.F .R. § 91.119.

THE REASONS WHY G RANTING THE EXEMP TION W O U L D N OT ADVERSELY AF F ECT SAF ETY , O R H O W T H E E X E M PT I O N W OULD P ROVIDE A LEVEL OF SAF ETY AT L E A S T E Q U A L T O T H A T P R O V I D E D BY THE RULE F ROM WHICH G TI SEEK S EXEMP TION.

1. Reasons W h y

The DJ IP h a n t o m 2 V i s i o n + U A M e e t T h e Conditions Of The F AA Moder niz ation and Reform Act of 2012 (F MRA) Section 333.

I n consideration of the siz e, weig ht, s p e ed, and limited operating a rea associated with the unmanned aircraft and its o peration, Geotechnical Testing & I nspect ions (GTI )’ operation of the DJ I Phantom 2 Vision+ UAS meet the conditions of F MRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

I n seekingthis ex emption, Geotechnical Testing & I nspections (GTI ) submits that the DJ I Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to F MRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Phantom 2 Vision+ U A S; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specif

ications Of

The DJI P hantom 2 Vision+ UAS Dem onstrate Its Saf e Characteristics.

• The DJ I Phantom 2 Vision UAS do n o t c reate a haz ard to users of the NAS or the public, or otherwise p ose a threat to national security considering its siz e, weig ht, speed, and operational capability

.
i. Technical Specif

ications of

The DJI P hantom 2 Vision+ UAS.

• The technical specifications of the DJ I P h a n tom 2 Vision+ UAS are set forth by the DJ I Phantom 2 Vision+ Specifications and Data Sheet attached.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 12

ii. The DJI P hantom 2 V i s i o n + U A S A u t o n o mo u s Fl i g h t A n d N a v i g ation Modes Enabl The UAS To Rem ain Within A Def ined Operational Area.

• T he D J I Phantom 2 Vision+ UAS may be operated in both manual and fully auton o m o u s f l ig ht modes. A complete description of the flig ht a nd navig ational modes of the DJ I Phantom 2 Vision+ UAS are included in the User Manuals.

iii. The DJI P hantom 2 V ision+ UASs Are Designed F o r Autom a tic Return To Hom e P oint Or Hover In The Event Of Loss Of The Control Link Or Navigation.

• W h en the Control L ink is lost, the DJ I Phantom 2 Vision+ UA w i l l remain stationary
, in flig ht, for 3 seconds o r m o r e

. I f
, a fter 3 seconds, the DJ I Phantom 2 Vision+ UA does not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the U As will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the F ailsafe F unctions of the D J I Phantom 2 Vision+ UA are set forth in the DJ IPhantom 2 Vision+ User Manual, attached.

iv. The DJI P hantom 2 Vision+ G CS And Its Operation.

• A complete description of the operation and specifications of the DJ I Phan t o m 2 Vision+ GCS and flig ht control software is provided in the DJ IPhantom 2 Vision+ User Manual.

b. F lights Of

DJI P hantom 2 Vision+ UAS Will Be Conducted P ursuant To Specif ic Ope rating Lim itations.

I n seeking this ex emption, Geotechnica l T esting & I nspections (GTI ) proposes to

c o mmercially operate D J I Phantom 2 Vision+ UAS for the special purpose of con d u c t i n g aerial video and p hotog raphy over certain a reas of United States, pursuant to the following specific operating

limitations:

1. Operations authoriz ed b y this g rant of ex emption will be limited to the following aircraft described in the operating document s , r o t o rcraft U ASs weig hing less than 55 pounds

max imum g ross weig ht: DJ I Phantom 2 Vision+ Unmanned Aircraft Sy stems. Proposed operations of any o th e r a i r craft will require a n ew petition or a petition to amend this
g rant.

2. UAS operations under this ex empti o n w i l l be limited to conducting operations for the purpose of aerial video and photog raphy

.

3. The UA may not be flown at an indicated airspeed ex ceeding 20 knots. U A operator will utiliz e the set airspeeds recommended by the UAS manufacturer.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 13

4. The UA must b e operated at an altitude of no more than 4 00 fe e t a bove g round level (AGL ), as indicated by the p r ocedures specified in the operating documents unless a special request is made and approved by ATC. A ll altitudes reported to ATC must be in feet AGL

.

5. The UAs must be o pe ra t e d w i t h i n v isual line of sig ht (VL OS) of the PI C at all times. This requires the PI C to b e able to use human vi s ion unaided by any device other than

c o rrective lenses, as specified on the PI C’s F AA issued a irman-medical certificat e o r drivers licence.

6. The use of first person view camera to satisfy the visual line of site is not permitted.

7. All operations must utiliz e a qualified P I C a t all times. The PI C must be able to communicate verbally at all times with supervisor or a ssistant. Electronic messag ing or tex ting is not permitted during flig ht operations. The PI C must be desig n ated before the flig ht and cannot transfer his or h er desig n ation for the duration of the flig ht

. The PI C
must e nsure that the assistanct can perform the f unctions prescribed in the operating documents.

8. The assistant must not perform any other d u ties bey ond assisting the PI C with seeing and avoiding other a ir traffic a n d other g r ound-based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating d ocum e n t s a n d the g rant of ex emption must b e a ccessible during UAS operations and made av ailable to the Administrator u pon request. I f a d iscrepancy ex ists between the c ondi t i o n s a n d limitations contained in the g rant of ex emption and the procedures outlined in the operating d ocuments, the c onditions and limitations contained in the g r ant of ex emption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its o perating do cuments. The operator may update or revise its operating documents. I t is the o perator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised do c u m e n t s if it petitions f or

ex tension or amendment to the g rant of ex emption. I f the operator determines that any update or revision would affect the basis upon w hich the F AA g rante d t h e e x e mption, then the oper a t o r must petition for amendment to its g r ant of e x emption. The F AA’s UAS Integ ration Office ( AF S 80) may be contacted if questions arise r eg arding updates or revisions to the operating documents.

10. Prior to each flig h t the PI C m u s t inspect the UAS to ensure that it is in a c ondition f or safe flig h t. I f the inspection reveals a condition that affects the safe operation of the UAS, the a ircraft is prohibited from operating until the necessary mai n t e n ance has been performed a

nd the UAS is found to b e in a condition for safe flig ht. The Ground ControlGeotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 14

S t a tion must b e included in the pre-flig ht inspection. All maintenance and alte r a t i o n s

must be properly

documented in the aircraft records.

11. Any UAS that has underg one maintenance or alterations that affect the UAS operation

or flig ht characteristics, e.g

. replacement of a flig ht critical component, must underg o a functional test flig ht. The PI C who conducts the f unctional test flig ht must make an entry in the aircraft records and stay at least 500 feet from other people.

12. The pre flig ht inspection m ust account for all p otential discrepancies, e .g

. inoperable components, items
, o r equipment, n ot already covered in the relevant sections of the operating documents.

13. T h e o perator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and r e c o r d keeping requirements, in a c co r d a n ce with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the sig nature of the authoriz ed person returning the UAS to service.

15. Each U ASs operated unde r this ex emption must comply with all manufacturer Safety B ulletins.

16. The authoriz ed person must make an entry in the a ircraft record of the corrective action taken ag ainst discrepancies discovered between inspections.

17. The PI C must meet o r ex ceed all requirements as set forth by manufacturer in order to justifiably o perate the DJ I Phantom 2 Visio n + , o r h o l d an e quivalent pilot license approved by

the F AA.

18. The operator may not permit an y P I C to o p erate unless the PI C meets the operator’s qualification c riteria and demonstrates the ability to safely operate the U AS in a manner consistent with how the U AS will be operated under the ex emption, including evasive and emerg ency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification fli g ht hours must be og g ed in a manner consistent with 14 C.F

. R. § 61.51(b). F lig h ts for the purposes of training the operator’s PI Cs are permitted under the terms of the ex emption. H o wever, training operations may only be c o nducted during dedicated training sessions. During training
, proficiency
, and

ex perience building flig hts, all persons not e ssential f or f lig ht operations are consideredGeotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 15

nonparticipants, and the P I C m u s t operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F .R. § 91.119.

19. UAS o perations may not be conducted during nig ht, a s defined in 1 4 C.F

. R. § 1.1. All operations must be conducted under visual meteorolog ical conditions (VMC). I f flig ht
at nig ht is required, a special request will be made at the F AA o ffice c losest to proposed area of operations. F lig hts under special visual flig ht rules (SVF R) are not authoriz ed.

20. The UA may not operate within 5 nautical miles of an airport reference point a s denoted

on a current F A A p u b l i s h e d aeronautical c hart unless a letter of ag reement with that airport’s manag ement is obtained, and the operation is conducted in accordance with a NOTAM as r e q

uired by the operator’s COA. T h e lett e r o f a gr eement with the airport
manag e ment must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horiz ontally from a cloud or when visibility is less than 3 statute miles from the PI C.

22. I f the UA loses communications o r loses its GPS sig nal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PI C m u st a

bort the flig ht in the event o f unpredicted obstacles or emerg encies in accordance with the operating documents.

24. The PI C is prohibited from beg inning a flig h t unl e s s (c o nsidering wind and forecast weather conditions) there is enoug h power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining o r

recommended by the manufacturer.

25. The operator must o btain an Air Traffic Org aniz ation (ATO) issued C e r t i ficate of W aiver

or Authoriz ation ( COA) pri o r to conducting any operations under the g rant of e x emption. This COA will also r equire the operator to request a Notice t o A i r m an (NOTAM) not

more than 7 2 hours in advance, but not less than 48 hour s p rior to the o peration. All operations shall be conducted in accordance with airs pace requirements in the ATO issued C OA including class of a irspace, altitude level and potential transponder requirements.

26. All ai r c raft operated in accordance with the ex emption must be identified by serial number, r eg istered in accordance with 14 C.F .R. p art 47, and have identifica t i on (N Number) marking s in accordance with 14 C.F .R. part 45, Subpart C. Marking s must be as larg e as practicable.Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption June 10, 2015 Page 16

27. B e f o r e c o nducting operations, the radio f requency spectrum used for operation and control of the U A must comply with the F ederal Communications Commission (F CC) or other appropriate g overnment oversight ag ency requirements.

28. The UA must remain clear and y ield the rig ht of w ay to all manned aviation operations and activities at all times.

29. The UAS may

not be operated by

the PI C from any

moving device or vehicle.

30. All operati o n s s h a l l be conducted over p ublicly owned or controlled property

. Any operation over privately owned property would require permissio n f rom the land owner/controller or authoriz ed representative. Permission from land owner/controller or authoriz ed representative will be obtained for each flig ht to be conducted.

31. Any incident, accident, or flig ht operation that transg resses the lateral or vertical boundaries of the operational a rea as defined by the applicable COA must be reported to the F AA' s UAS I n teg ration Office (AF S 8 0) w ithin 24 hours. Accidents must be reported
to the National Transportation Safety B oard (NTSB ) per instructions contained on the NTSB W eb site: www.ntsb.g o v

.

GE O T E C H NICAL TESTING & INSP ECTION ( GT I ) A FFI R M S T H A T A L L INF ORMATION LISTED ABOVE TO BE TRUE AND BINDING UP ON F AA’S F INDING S O F EXEMP TION REG ARDING COMMERCI A L O P E R A T I O N S O F L I S T E D U A S , U N T I L FU R T H E R N O T I C E O F L A W S O R R E G U L A T I O N S D E C I D E D B Y T H E G OVERNMENT/F A A.

THANK YOU F OR YOUR CONSIDERATION.

Sincerely Geotechnical Testing

& I nspections (GTI )

J ennifer M. Clark, M.S. CEO