To From

US Department of Transportation Jennifer M. Clark, M.S.

Docket Management Facility Chief Executive Officer

1200 New Jersey Avenue, SE West Geotechnical Testing & Inspections (GTI)

Building Ground Floor Room W12-140 7855 East Evans Road, Suite “C”

Washington, DC 20590 Scottsdale, AZ 85260

(480) 659-6630

BASIS FOR PETITION

Petitioner, Geotechnical Testing & Inspections (GTI), pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R § 11.61) and the FAA Modernized and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems (UAS), hereby

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+, in the National

Airspace System (NAS), and for an exemption from the requirements of : 

! 14 C.F.R §§ 61.113(a) & (b) 

! 14 CFR 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 PETITIONER 

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

Jennifer M. Clark, M.S.

Chief Executive Officer (CEO)

7855 East Evans Road, Suite “C”

Scottsdale, Arizona 85260

Office: 480-659-6630

Fax:480-659-7280

email: Jennifer@gtiaz.com

PREFACE

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the

Act, that includes Unmaned Aircraft Systems (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 grant an exemption from a requirement of a regulation prescribed under

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

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC

§44704; 14 CFR §91.203 (a) (1).

Geotechnical Testing and Inspections (GTI) proposes to use one or more Unmanned Aerial Drones

(DJI PHANTOM 2 Vision +), for the following uses:

# Conduct Phase IEnvironmental Site Assessment Inspections of undeveloped properties. 

# Inspections of roadways which are to be widened or improved.

# Periodic inspections of infrastructure improvement projects.

# Bridge; Roadway and site development inspections

# Assist with damage assessments or situational status reports during construction

operations and/or emergency response operations

# Evaluations of undeveloped desert land.

# Inspection of earth fissures and ground subsidence areas.

# Inspection and documentation of construction operations.

This UAS has four rotors and four motors in a quadcopter configuration (X4). The unit is only

capable of vertical takeoff and landings. This UAS weighs under to 3 lbs which is substantially less

than the 55 lbs classification, including payload. It can fly, under normal conditions, at a speed of

no more than 30 knots and has the capability to hover, and move in the vertical and horizontal plane

simultaneously. This UAS is equipped with GPS and has an auto return function that returns the unit

to the predetermined safe landing area as well as allowing reading of magnetic interference that can

cause loss off GPS signal. The UAS is operated only in line of sight and will operate only within the

limits of public rights of way or easements or private property for which authorization has been

obtained. Such operations will be conducted to insure that the UAS will “not create a hazard to users

of the national airspace system or the public.” (Reform Act Section 333 (b)).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before

completion of the rule making required under Section 333 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UASs do not create a hazard to

users of the NAS or the public or pose a threat to national security in light of the following:

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

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

! Operation of the UAS within visual line of sight of the operator.
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 system, the Secretary shall establish requirements for the safe operation of such aircraft in

the national airspace system.” Id. §333©.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the

Act, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness

certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under

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

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC

§44704; 14 CFR §91.203 (a) (1).

RELIEF OVERVIEW 

Given the very small size of the UAS involved and the restricted environment within which theywill

operate, the applicant falls squarelywithin that zone of safety (an equivalent level of safety) in which

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

commence immediately. Also due to the size 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 Federal

Aviation Act, as amended; the strong equivalent level of safetysurrounding the proposed operations,

and the significant public benefit, including enhanced safety, reduction in environmental impacts,

including reduced emissions associated with allowing UASs for aerial inspections, surveying,

photography and videography, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

Geotechnical Testing & Inspections (GTI) proposes that the exemption requested herein apply to

civil aircraft that have the characteristics and that operate with the limitations listed herein. These

limitations provide for at least an equivalent or even higher level of safety to operations under the

current regulatory structure because the proposed operations represent a safety enhancement to the

already safe aerial inspections, surveying and photography and videography operations conducted

with conventional aircraft.

These limitations and conditions to which Geotechnical Testing & Inspections (GTI) agrees to be

bound when conducting commercial operations under an FAA issued exemption include:
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 4 

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a Pilot In Command (PIC).

3. Maximum total flight time for each operational flight will be 30 minutes or less. Flights

will be terminated at 25% battery power reserve should that occur prior to the 30 minute

limit.

4. Flights will be operated at an altitude of no more than 300 feet AGL or, not 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 of which will

be determined by the UAS Pilot In Command (PIC) based on the site specific activities

and speed of the UAS required for the operation, and coordinated with the jurisdictional

FAA FSDO and local government officials, as applicable.

7. A briefing will be conducted in regards to the planned UAS operations prior to each

day’s operation. It will be mandatory that all personnel who will be performing duties

within the boundaries of the project be present for this briefing.

8. The UAS Pilot will be able to communicate by voice and/or two way radio

communication system with office management at all times.

9. The operations of the UAS will be limited to daylight operations only.

10 If the UAS loses communications or loses its GPS signal, the UAS will have the

capability to return to a pre-determined location within the Project Perimeter and land

safely.

11. The UAS will have the capability to abort flight in case of unpredicted obstacles or

emergencies

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the small size and

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the

Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness

certificate, upon consideration of the size, weight, speed, operational capability, and proximity to

airports and populated areas of the particular UAS. In all cases, an analysis of these criteria

demonstrates that the UAS operated without an airworthiness certificate, in the restricted

environment and under the conditions proposed will be at least as safe, or safer, than a conventional

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions

and conditions proposed. In consideration of the speed, weight, size, and limited operating area

associated with the unmanned aircraft and its operation, the Geotechnical Testing & Inspections

(GTI)’ operation of DJI Phantom 2 Vision+, UAS meets the conditions of FMRA Section 333 and

therefore, will not 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 

Accordingly, Geotechnical Testing & Inspections (GTI) requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate. Geotechnical Testing &

Inspections (GTI) submits that the requested relief is proper since an equivalent level of safety will

be ensured. Geotechnical Testing&Inspections (GTI) will use experienced personnel or technicians

as needed to perform maintenance, alterations, or preventive maintenance on the UASs using the

methods,techniques, and practices prescribed in the operating documents (i.e., MonthlyMaintenance

Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, Geotechnical Testing &

Inspections (GTI) will document and maintain all maintenance records for the DJI Phantom 2

Vision+ UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and

limitations: Pilot in command,, is requested by Geotechnical Testing & Inspections (GTI) to the

extent necessary to allow a Pilot in Command (PIC) meet or exceed the described requirements of

operations set by manufacturer, and who has demonstrated, that the PIC is able to safely operate the

DJI Phantom 2 Vision+ UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures. 

Geotechnical Testing & Inspections (GTI) seeks relief from Section 91.7(a), entitled

Civil aircraft airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Geotechnical

Testing & Inspections (GTI) submits that he will ensure that the DJI Phantom 2 Vision+ UAS is in

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

the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction

Manual), and that the aircraft are in a condition for safe flight.

Geotechnical Testing&Inspections (GTI) also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ will be provided

to the PIC via Global PositioningSystem(GPS) equipment and radio communications telemetrydata

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Geotechnical Testing & Inspections (GTI)’ operation of the DJI

Phantom 2 Vision+ UAS within visual line of sight, at or below 300 feet AGL, will ensure a level

of safety equivalent to Section 91.121.

Additionally, Geotechnical Testing & Inspections (GTI)seeks an exemption from the requirements

of Section 91.151(b), entitledFuelrequirementsforflightinVFRconditions.GTIsubmits that safety

will not be affected by operation of the DJI Phantom 2 Vision+ during daylight hours in visual

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 30 minutes to the first point of intended landing and, assuming

normal cruising speed, 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 GEOTECHNICAL TESTING &

INSPECTIONS SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE: 

1. Section 61.113(a) & b).

Relief from Section 6 1 . 1 1 3 (a) and (b) entitled Private pilot privileges and limitations; Pilot

in command, is requested to the extent necessary to allow a PIC meet all requirements as

described in the DJI Phantom 2 Vision+ owner’s manual to conduct the proposed UAS flight

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

business or employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Geotechnical Testing & Inspections (GTI) submits that an

equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI

Phantom 2 Vision+ UAS unless that PIC has demonstrated that the PIC is able to safely operate

either the DJI Phantom 2 Vision+ UAS in a manner consistent with the operations specifications

as described in this exemption, including evasive and emergency maneuvers, as well as

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Geotechnical Testing & Inspections (GTI) submits that all flights of the DJI Phantom

2 Vision+ 1 UAS, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Geotechnical Testing & Inspections (GTI)’ business; and 

(2) will not carry passengers or property for compensation or hire. 

2. 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent

required to allow Geotechnical Testing & Inspections (GTI) to determine that the DJI Phantom

2 Vision+ UASs are in airworthy condition prior to every flight by ensuring that the UAS is in

compliance with the operating documents (i.e., the Geotechnical Testing & Inspections (GTI)

Operations Manual, MonthlyMaintenance Log, and DJIPhantom 2Vision+InstructionManual).

Geotechnical Testing & Inspections (GTI) seeks the requested relief because the DJI Phantom

2 Vision+ UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part

21, Subpart H. Therefore, Geotechnical Testing & Inspections (GTI) will ensure that the DJI

Phantom 2 Vision+ UAS are in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction

Manual) prior to every flight, and further, determine that the aircraft are in condition for safe

flight, 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 settings, may be required to allow flight

operations of the DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure sensor, GPS

equipment, and a radio communications telemetry data link to downlink altitude information

from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet

above ground level (AGL), GTI seeks the requested relief because the DJI Phantom 2 Vision+

UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought

to the extent necessary to comply with the applicable conditions and limitations stated below.

As more fully set forth herein, an equivalent level of safety will be maintained since the DJI

Phantom 2 Vision+ UA are equipped with a barometric pressure sensor and GPS equipment,

which automatically ensures that a ground level pressure setting will be established prior to each

flight, and provides the PIC 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 Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision+

UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules

(VFR), for a total duration of 25 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 5 minutes. GTI seeks the requested relief

because without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJI Phantom 2 Vision+ UA will severely constrain the practicality of any aerial video

or still photo flight operations that Geotechnical Testing & Inspections (GTI) proposes to

conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJIPhantom 2 Vision+ UAS,

the DJIPhantom 2 Vision+ operating documents, and Geotechnical Testing&Inspections (GTI)

proposed operating limitations, ensure that Geotechnical Testing&Inspections (GTI) will safely

operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power

to fly for a total duration of 25 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 4.5 minutes.
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 8 

14 CFR 45.23(b).

Marking of the Aircraft; Applicable codes of Federal Regulation require aircraft to be marked

according to certain specifications. UAV Field Services UASs are, by definition, unmanned.

They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or

phrases. Further, two inch lettering is difficult to place on such small aircraft. Regardless, UAV

Field Services will mark its UAS in the largest possible lettering by placing the "N "number on

its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others

working with the UAV will see the markings. The FAA has previously issued exemptions to this

regulation through Exemption 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), and 91.417(a) & (b) only apply

to aircraft with an airworthiness certificate, Geotechnical Testing & Inspections (GTI) requests

relief from these Sections because the DJI Phantom 2 Vision+ UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS meet the conditions

of FMRA Section 333 for operation without an airworthiness certificate. Accordingly

Geotechnical Testing & Inspections (GTI) will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the Geotechnical Testing & Inspections (GTI)

aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction

Manual). Furthermore, Geotechnical Testing & Inspections (GTI) will document and maintain

all maintenance records for the DJI Phantom 2 Vision+ UAS.

The Reasons for granting this request are entirely beneficial to the

 public and community as a whole.

Granting the present Petition will further the public interest by allowing Geotechnical Testing &

Inspections (GTI) to safely, efficiently, and economically perform aerial video and photographic

surveys and inspections of construction sites, rights of way, utility easements, and other sites. This

exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a)

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before

completion of the rule making required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UAS do not create a hazard to

users of the NAS or the public or pose a threat to national security in light of the following:

! The UAS’s small size, light weight, speed and operational capability;

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

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

UAS Petition for Exemption

June 10, 2015

Page 9 

Reform Act § 333 (a). Lastly, id. the Secretary determines that such vehicles “may operate safely in

the national airspace system, the Secretaryshall establish requirements for the safe operation of such

aircraft in the national airspace system.” Id. §333©.

Given the small size of the UAS involved and the restricted sterile environment within which they

will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in

which Congress envisioned that the FAAmust, byexemption, allow commercial operations of UASs

to commence immediately. Also due to the size 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 Federal Aviation Act,

as amended; the strong equivalent level of safety surrounding the proposed operations, and the

significant public benefit, including enhanced safety, reduction in environmental impacts, including

reduced emissions associated with allowing UASs for movie and television operations, the grant of

the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests

that the FAA grant the requested exemption without delay.

REASONS BENEFICIAL TO THE PUBLIC/COMMUNITY

1. The Public Will Benefit from Decreased Congestion of the NAS. 

The DJI Phantom 2 Vision+ UA are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an

exemption allowing the use of a DJI Phantom 2 Vision+ UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of

life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom

2 Vision+ UA do not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and photographymissions would result in fewer aircraft that

must be handled by air traffic control during the ground, takeoff, departure, arrival, and

landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vis

ion+ UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photographyflight operations. By

using battery power and electric motors, the DJI Phantom 2 Vision+ UAS produce no air
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 10 

pollution, and is the most viable environmentally conscious alternative to the cabin class, six

cylinder internal combustion engine aircraft that are typically utilized for aerial video and

photography, while burning approximately 20 30 gallons per hour of leaded aviation fuel.

The DJI Phantom 2 Vision+ UA, while reducing the carbon footprint of aerial acquisitions,

also eliminates noise pollution, as the UAs are propelled by battery powered electric motors,

rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ UAS to perform aerial observation, the substantial risk

to life and property in the air and on the ground, which is usually associated with traditional

manned aircraft flight operations, will be substantially reduced or completely eliminated.

Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom

2 Vision+ UA (weighing approximately 2 pounds 11 ounces, at their maximum gross

weights with length of 16 inches, widths of 16 inches, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air,

compared to the manned aircraft that typically conduct similar operations (weighing

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet,

and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography, surveys and Inspections, Operations with

the DJI Phantom 2 Vision + UAS Will Benefit the Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ UAS are also provides an

economical alternative to usingmanned aircraft to conduct similar aerial operations. As such,

operation of the DJI Phantom 2 Vision+ UAS will allow the Geotechnical Testing &

Inspections (GTI), to provide quality services to the residents, clients and the City and the

Region at minimum costs. Specifically, with the rising cost of aviation fuel and the

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation

fuels, agencies must adopt new and alternative technology in continue to provide required

services at reasonable costs. Operating the battery powered DJI Phantom 2 Vision+ UAS is

one such technology that not only allows agencies & companies greater operational

flexibility compared to manned aircraft, but provides such flexibility without the high

operational cost of a traditional manned aircraft.

Byoperating the DJIPhantom 2 Vision+ UAS, theGeotechnical Testing&Inspections (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 system wide modeling

of water, water, stormwater and roadwaysystems as well as provide accurate and current data

related to environmental issues such as ground cover, vegetation & wildlife habitats.
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 11 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, the Geotechnical Testing & Inspections (GTI)’ proposed operation of the DJI

Phantom 2 Vision+ UAS will not implicate anyprivacyissues. Specifically, the DJIPhantom

2 Vision+ UAS will be operated only in compliance with operating documents (i.e., the

Geotechnical Testing&Inspections (GTI) Aerial Operations Manual, MonthlyMaintenance

Log, and DJI Phantom 2 Vision+ Instruction Manual) which requires propertyowner

involvement as well as local law enforcement notification, and in accordance with the

Federal Aviation Regulations, including the maximum altitude limitations as per the

requirements of 14 C.F.R. § 91.119.

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY, OR HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF 

SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH 

GTI SEEKS EXEMPTION.

1. Reasons Why The DJI Phantom 2 Vision+ UA Meet The Conditions Of The FAA Moder

nization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, Geotechnical Testing & Inspections (GTI)’ operation

of the DJI Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333, and will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

In seeking this exemption, Geotechnical Testing & Inspections (GTI) submits that the DJI

Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS; (b) the pilot

certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its Safe 

Characteristics.

• The DJI Phantom 2 Vision UAS do not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and

operational capability.

i. Technical Specifications of The DJI Phantom 2 Vision+ UAS. 

• The technical specifications of the DJI Phantom 2 Vision+ UAS are set forth by the DJI

Phantom 2 Vision+ Specifications and Data Sheet attached.
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 12 

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And Navigation Modes Enabl

The UAS To Remain Within A Defined Operational Area. 

• The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully autonomous

flight modes. A complete description of the flight and navigational modes of the DJI

Phantom 2 Vision+ UAS are included in the User Manuals.

iii. The DJI Phantom 2 Vision+ UASs Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

• When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain stationary, in

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ UA does not

reacquire control link data from the GCS, the UAs will assume that the Control Link is lost

and the UAs 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 Failsafe Functions of the DJI Phantom 2 Vision+ UA are set

forth in the DJI Phantom 2 Vision+ User Manual, attached.

iv. The DJI Phantom 2 Vision+ GCS And Its Operation.

• A complete description of the operation and specifications of the DJI Phantom 2 Vision+

GCS and flight control software is provided in the DJI Phantom 2 Vision+ User Manual.

b. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursuant To Specific Ope

rating Limitations. 

In seeking this exemption, Geotechnical Testing & Inspections (GTI) proposes to

commercially operate DJI Phantom 2 Vision+ UAS for the special purpose of conducting

aerial video and photography over certain areas of United States, pursuant to the following

specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft

described in the operating documents, rotorcraft UASs weighing less than 55 pounds

maximum gross weight: DJI Phantom 2 Vision+ Unmanned Aircraft Systems. Proposed

operations of any other aircraft will require a new petition or a petition to amend this

grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 20 knots. UA operator will

utilize 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 be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA issued airman-medical certificate or

drivers licence.

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

7. All operations must utilize a qualified PIC at all times. The PIC must be able to

communicate verbally at all times with supervisor or assistant. Electronic messaging or

texting is not permitted during flight operations. The PIC must be designated before the

flight and cannot transfer his or her designation for the duration of the flight. The PIC

must ensure that the assistanct can perform the functions prescribed in the operating

documents.

8. The assistant must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground-based obstacles/obstructions and is not

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating documents, the conditions and limitations contained

in the grant of exemption take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. It is the operator’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 documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines that any

update or revision would affect the basis upon which the FAA granted the exemption,

then the operator must petition for amendment to its grant of exemption. The FAA’s

UAS Integration Office (AFS 80) may be contacted if questions arise regarding updates

or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for

safe flight. Ifthe inspection reveals a condition that affects the safe operation of the UAS,

the aircraft is prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground Control
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 14 

Station must be included in the pre-flight inspection. All maintenance and alterations

must be properly documented in the aircraft records.

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

or flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight. The PIC who conducts the functional test flight must make an entry

in the aircraft records and stay at least 500 feet from other people.

12. The pre flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator 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 record keeping

requirements, in accordance 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 signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.

17. The PIC must meet or exceed all requirements as set forth by manufacturer in order to

justifiably operate the DJI Phantom 2 Vision+, or hold an equivalent pilot license

approved by the FAA.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive

and emergencymaneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures. PIC qualification flight hours must be ogged in a manner

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s

PICs are permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, proficiency, and

experience building flights, all persons not essential for flight operations are considered
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 15 

nonparticipants, and the PIC must operate the UA with appropriate distance from

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

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight

at night is required, a special request will be made at the FAA office closest to proposed

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

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

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

airport’s management is obtained, and the operation is conducted in accordance with a

NOTAM as required by the operator’s COA. The letter of agreement with the airport

management 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 horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, 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 PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the intended

landing point and land the UA with 25% battery power remaining or recommended by

the manufacturer.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting anyoperations under the grant of exemption.

This COA will also require the operator to request a Notice to Airman (NOTAM) not

more than 72 hours in advance, but not less than 48 hours prior to the operation. All

operations shall be conducted in accordance with airspace requirements in the ATO

issued COA including class of airspace, altitude level and potential transponder

requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

 Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be

as large as practicable.
Geotechnical Testing & Inspections (GTI)

UAS Petition for Exemption

June 10, 2015

Page 16 

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC)

or other appropriate government oversight agency requirements.

28. The UA must remain clear and yield the right of way to all manned aviation operations

and activities at all times.

29. The UAS may not be operated by the PIC from any moving device or vehicle.

30. All operations shall be conducted over publicly owned or controlled property. Any

operation over privately owned property would require permission from the land

owner/controller or authorized representative. Permission from land owner/controller or

authorized representative will be obtained for each flight to be conducted.

31. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA's UAS Integration Office (AFS 80) within 24 hours. Accidents must be reported

to the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov.

GEOTECHNICAL TESTING & INSPECTION (GTI) AFFIRMS THAT ALL

INFORMATION LISTED ABOVE TO BE TRUE AND BINDINGUPON FAA’S FINDINGS

OFEXEMPTION REGARDINGCOMMERCIALOPERATIONSOFLISTEDUAS,UNTIL

FURTHER NOTICE OF LAWS OR REGULATIONS DECIDED BY THE

GOVERNMENT/FAA. 

THANK YOU FOR YOUR CONSIDERATION.

Sincerely

Geotechnical Testing & Inspections (GTI)

Jennifer M. Clark, M.S.

CEO