June	18 th,	2015

U.S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Dear	Sir	or	Madam,

Please	find	below Good	Earth	Tools	request	for	exemption	from	the	listed	Federal Aviation	Regulations	to	allow commercial	operations	of	its	Unmanned	Aircraft Systems	for	safe	aerial	imaging	of	railway	bridges.

Thank	you	for	your	time	and	consideration,	and	please	let	me	know	if	you	have	any questions.
Sincerely,

Eric	Van	de	Riet Good	Earth	Tools Drone	InternPursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the

“Reform	Act”)	and	14	C.F.R.	Part	11,	Good	Earth	Tools,	the	operator	of	the	DJI Phantom	3	Professional	Unmanned	Aircraft	System	(“UAS”),	seeks	an	exemption from	the	Federal	Aviation	Regulations	(“FARs”)	listed	below.

The	requested	exemption	would	permit	Good	Earth	Tools	to	operate	their	Phantom 3,	which	weighs	less	than	4	pounds,	and	is	made	by	DJI,	for	informal	railroad	bridge inspections:

- take	video	and ph otographs of	railroad	bridges

- allow	more	precise	identification	of	potential	bridge	issues

As	detailed	in	this	document,	the	requested	exemption	would	permit	the	operation of	UAS	under	controlled	conditions	in	airspace	that	is:

- limited

- predetermined

- contr olled	as	to	access

Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transportation’s	(the	FAA	Administrator’ s)	responsibilities	to	“establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national airspace system.”
Good	Earth	Tools	specializes	in	modifying	construction	equipment	to	allow	them to aide	in	the	construction	and	maintenance	or	railroads.		The	Phantom	3	would	allow Good	Earth	Tools (“GET”) to	help	customers	better	identify	what	might	req uire maintenance	work	without	having	people	walking	on	the	bridge	or	working	from	a bucket	hanging	off	the	side	of	the	bridge.		The	use	of	a	UAS	would increase	safety	by keeping	people	off	of	the	bridge,	and	also	decrease	bridge	downti me.
Operations	under the	exemption	will	be	subject	to	strict	operating	requirements and	conditions	to	ensure	at	least	an	equivalent	level	of	safety	to	currently authorized	operations	using	manned	aircraft	and	under	conditions	as	may	be modified	by	the	FAA	as	required	by	Secti on	333.

GET respectfully submits	that	because	this	small,	unmanned	aerial	v ehicle	will	be used	in	lieu	of comparatively	hazardous	operations,	such	as	inspectors	in	buckets hanging	over	the	bridge,	the	FAA	can	have	confidence	that	the	operations	will achi eve	at	least	an	equivalent	or	greater	level	of	safety	than	previously	existed. Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transportation’s	responsibilities	under	Section	333(c)	of	the	Reform	Act	“to establish	requ irements	for	the	safe	operation	of	such	aircraft	systems	in	the	national airspace	system”.

The	name	and	address	of	the	applicant	is: Good	Earth	Tools Eric	Van	de	RietPH:	314

- 941

- 9464

Email: evanderi@purdue.edu A ddress:	43	Muirfield	Lane,	St.	Louis	MO	63141

The	regulations	from	which	the	exemption	is	requested	are	as	follows: 14	C.F.R.	Part	21; 14	C.F.R.	45.23(b); 14	C.F.R.	91.7(b); 14	C.F.R.	91.9(b)(2); 14	C.F.R.	91.109(a); 14	C.F.R.	91.119; 14	C.F.R.	91.1 51(a); 14	C.F.R.	91.203(a)	&	(b); 14	C.F.R.	91.405(a); 14	C.F.R.	91.407(a)(1); 14	C.F.R.	91.409(a)(2); 14	C.F.R.	91.417(a).

**I. Statutory	Authority	for	Exemptions** 

The	Federal	Aviation	Act	expressly	grants	the	FAA	authority	to	issue exemptions.	This	statutory	authority	includes	exempting	civil	aircraft,	as	the	term	is defined	und er	40101	of	the	Act,	including UASs,	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 ion	the	public	interest.	49	U.S.C. 44701(f)	See	also	49	USC	44711(a);	49	USC	44704;	14	CFR	91.203(a)(1).

Section	333(b)	of	the	Reform	Act	assists	the	Se cretary	in	determining	whether UASs may	operate	in	the	National	Airspace	System	(NAS)	without	creating a	hazard	to	the user,	the	public,	or	a	threat	to	national	security.	In	making	this	determination,	the Secretary	must	consider:

- The UAS’s	size,	weight,	spe ed,	and	operational	capability

- Whether	the UAS	operates	within	the	visual	line	of	sight	of	the	operator

- Whether	the UAS	operated	outside	of	highly	populated	areas	and	away	from close	proximity	to	airports.

Reform	Act	333(a).	If	the	Secr etary	determines	that	a UAS	“may	operate	safely	in	the national	airspace	system,	the	Secretary	shall	establish	requir ements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	333(c). GET’s UASs	are multirotor vehicles,	weighing 4 o r	fewer	lbs.	including payload.		The	pilot	will operate	under	normal	conditio ns	at	a	speed	of	no	more	than 25 kno ts	and	have	the	capability	to	hover,	and	move	in	the	vertical	and	horizo ntal plane s simultaneously.	The UASs	will	operate	only	in	the	pilot’s	visual	line	of	sight	atall	times.	Such	o perations	will	e nsure	that	the UASs	will	“not	create	a	hazard	to

users	of the	national airspace	system	or	the	public.” Reform	Act	Section	333	(b ). Given	the	small	size	of	the UASs	involved	and	the	restricted	environment within	which	they	will	operate,	our	application	falls	squarely	within	the	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	small	size	of	the UASs	and	the	low	altitudes	and restricted areas	in	which	our UASs	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,	the	grant	of	the	requested	exemptions	is	in	the	public interest. Accordingly, GET respectfully	requests	that	the	FAA	grant	the	requested exemption	without	delay.

**II. PUBLIC	INTEREST** 
This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in passing	Section	333(a)	thr ough	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary of	Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may operate	safely	in	the	NAS	before	completion	of	the	rulemaking	required	under Section	332	of	the	Reform	Act.	By	granting	a n	exemption	the	FAA	will	fulfill Congress’	intent	of	allowing	UAS	to	operate	with	significant	safety	precautions	in low	risk	environments. The	use	of UASs	on	a bridge site	can	significantly	reduce	the	risk	to	wor kers of	falls	while	inspecting	the	bridge. UASs	can	inspect,	photograph,	and	collect	data on	hard	to	get	to	areas	that	otherwise	would	require	worker	inspection .		The	use	of a	drone	would	greatly	reduce	the	need	for	workers	to	be	placed	in	precarious	and high	locations,	greatly	reducing	the	risk of	injury. Additionally,	the	proposed	would	have	very	little	environmental	impact	as	it is	powered	by	lithium

- ion	batteries,	and	thus	does	not	burn	fossil	fuels.		This provides	a	more	than	equivalent	level	of	environmental	impact,	as	a	typical	truck and	b ucket	would	run	on	environmentally	harmful	fossil	fuels.

**III. EQUIVALENT	LEVEL	OF	SAFETY** 
GET	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	protocols	followed	on construction	sites	and	ima ging	and	surveying	operations	conducted	with	helicopters and	other	conventional	aircraft.GET will	be	bound	by	the	following	l imitations	when	conducting	its UAS

operations	under	an	FAA	issued	exemption: 1. The	UAS	will	be	less	than	5	pounds. 2. Flights	will	be operated	within	visual	line	of	sight. 3. Maximum	total	flight	time	will	be	20	minutes.		The	UAS	calculates	battery reserve	in	real	time,	and	will	return	to	its	original	takeoff	point	once	the battery	reaches	20%	remaining	should	this	limit	be	reached	before the	20 minute	flight	limit. 4. Flights	will	be	operated	at	an	altitude	of	less	than	200	AGL,	and	will	never exceed	400	AGL. The	operator	is	presented	the	current	AGL	through	the ground	based	camera	feed. 5. Crew	for	each	operation	will	consist	of	the	UAS	pilot who	will	keep	the	UAS within	his	or	her	visual	line	of	sight	at	all	times. 6. The	UAS	pilot	will	be	trained	in	flight,	operations,	and	safety	procedures. 7. The	UAS	will	only	operate	within	a	confined	area. 8. A	briefing	will	be	held before	each	flight	that	will	in form	all	persons	involved of	the	flight	plan	and	necessary	safety	procedures. 9. The	pilot	will	have	been	trained	in	operation	of	UASs	generally	and	received up	to	date	information	and	training	on	the	DJI	Phantom	3. 10. Written	and/or	oral	permission	from	the	r elevant	property	holders	will	be obtained. 11. All	required	permissions	and	permits	will	be	obtained	from	territorial,	state, county,	or	city	jurisdiction,	including	local	law	enforcement,	fire,	or	other appropriate	governmental	agencies. 12. If	the	UAS	loses	comm unications	or	loses	its	GPS	signal,	it	will	have	the capability	to	return	to	the	location	where	it	originally	took	off. 13. The	UAS	will	have	the	capability	to	safely	abort	a	flight	in	case	of	unpredicted obstacles	or	emergencies.

**IV. DESCRIPTION	OF	SPECIFIC	REGU**  **LATIONS**
**14	CFR	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	size	and	limited	operating	area	associated	with	the	aircraft to	be	utilized	b y GET,	an	exemption	from	Part	21	Subpart	H	meets	the	requirements of	an	equivalent	level	of	safety	under	Part	II	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	exe mpt	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.	Our	small	UAS	will be	operated	at	low	speed	in	a controlled	environment,	at	least	five	miles	from	an airport	and	more	than	three	miles	from	any	city	or	densely	populated	area.	An analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an airworthiness	certificate,	in	the	restricted	environ ment	and	under	the	conditions proposed	will	be	at	least	as	safe,	or	safer,	than	conventional	aircraft	(fixed	wing	orhelicopter)	operating	with	an	airworthiness	certificate	without	the	restrictions	and

conditions	proposed.

The UAS	to	be	op erated	hereunde r	is	less	than	4 lbs.	fully	loaded,	carries	neither	a pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and operates	exclusively	within	a	secured	area.	Like	other	civil	aircraft,	operations under	this	exemption	will	be	tightly controlled	and	monitored	by	the	operator,	and under	the	requirements	and	in	compliance	with	l ocal	public	safety	requirements.

Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible threat	to	national	security	posed	by	the	UAS, due	to	its	size,	speed	of	operation, location	of	operation,	lack	of	explosive	m aterials	or	flammable	liquid	fuels,	and	lack of	ability	to	carry	an	external	load	outside	of	a	camera.
**14	C.F.R.	45.23(b):	Marking	of	the	Aircraft** This	regulation	requires	certain	experimental,	provisionally	certified	aircraft,	or light

- sport	category	aircraft	to	be	marked	with	letters	between	2	inches	and	6 inches	high	“limited”,	“restricted”,	“light

- sport”,	“experimental”,	or	“provisional”,

near	ea ch	entrance	to	a	cabin,	cockpit,	or	pilot	station.	Even	though	the	UAS	will have	no	airworthiness	certificate,	an	exemption	may	be	needed	as	the	UAS	will	have no	entrance	to	the	cabin,	cockpit,	or	pilot	station	on	which	the	word	“Experimental” can	be	place d.	Given	the	size	of	the	sUAS,	two

- inch	lettering	will	be	impossible.	The word	“Experimental”	will	be	placed	on	the	fuselage	in	compliance	with	45.29(f).	The equivalent	level	of	safety	will	be	provided	by	having	the	sUAS	marked	on	its	fuselage as	required by	45.29(f)	where	the	pilot,	observers	and	others	working	with	the sUAS	will	see	the	identification	of	the	UAS	as	“Experimental”	The	FAA	has	issued	the following	exemptions	to	this	regulation.	Exemptions	Nos.	10700,	8738,	10167	and 10167A.
**14	CFR	61.113	( a)	&	(b):	Private	pilot	privileges	and	limitations:	Pilot	in**  **command**

Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non

- commercial	operations.	Because the	UAS	will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve the	equivalent	level	of	safety	of	current	operations	by	requiring	the	pilot	operating the	a ircraft	to	have	completed	at	least	40	hours	of	prior	UAS	flying	time	before undertaking	completion	of	a	bridge	inspection .	Unlike	a	conventional	aircraft	that carries the	pilot	and	pa ssengers,	the UAS	is	remotely	controlled	with	no	living	thing or	cargo	on	board.	The	area	of	operation	is	controlled	and	restricted,	and	all	flights are	planned	and	coordinated	in	advance.	The	risks	associated	with	commercial operations	contemplated	by	Part	61	when	drafted,	that	allowing	operations	of	the UAS	as	requested	with	a	pilot	who	has	met	the	minimum	requirements	exceeds	the present	level	of	safety	achieved	by	14	C.F.R.	61.113	(a)	&	(b).**14	C.F.R.	91.7	(a):	Civil	aircraft	airworthiness**

The	regu lation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in airworthy	condition.	As	there	is	no	airworthiness	certificate	issued	for	the	aircraft, should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for determining	airwo rthiness.	Given	the	size	of	the	aircraft	and	the	use	of	safety ch ecklists	prior	to	each	flight,	an	equivalent	level	of	safety	will	be	provided.

**14	C.F.R.	91.9	(b)(2):	Civil	aircraft	flight	manual,	marking,	and	placard requirements** 
The	UAS,	given	its	siz e	and	configuration	has	no	ability	or	place	to	carry	such	a	flight manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	because there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivalent level	of	safety	will	be	m aintained	by	keeping	the	flight	manual	at	the	ground	control point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	it.	The	FAA	has issued	the	following	exemptions	to	this	regulation:	Exemption	Nos.	8607,	8737, 8738,	9299,	9299A,	9565,	9565B,	1 0167,	10167A,	10602,	32827,	and	10700.
**14	C.F.R.	91.103:	Preflight	Action**

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	a flight	to	ensure	the	safety	of	flight.	An	exemption	is	needed	from	this requirement, as	the	pilot	will	take	separate	preflight	actions,	including	checking	for	weather conditions,	checking	flight	battery	requirements,	checking	takeoff	and	landing distances,	and	all	other	actions	in	the	Preflight	Checklist	in	the	Manual.	These actions	will	provide	an	equi valent	level	of	safety.

**14	C.F.R.	91.109	Flight	Instruction**

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has fully	functio ning	dual	controls.	By	design, UAS	and	remotely	piloted	aircraft	do	not have	fully	functional	dual	controls.	Flight	control	is	accomplished	through	the	use	of a	control	box	that	communicates	with	the	aircraft	via	radio	communications.	The FAA	has	previously	approved	exemptions	for	aircraft	without	fully	functional	dual controls.	See	Exemption	Nos.	5778K	&	9862A.	The	equivalent	level	of	safety provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the aircra ft,	the	ability	to	control	the UAS	via	radio	signals	from	the	controller,	and	by the	size	and	speed	of	the	aircraft.

**14	C.F.R.	91.119:	Minimum	Safe	Altitudes**

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section 91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed, provided	the	person	operating	the	helicopter	complies	with	any	route	or	altitudesprescrib ed	for	helicopters	by	the	FAA.	This	exemption	is	for	a	multirotor	craft	that

flies	similarly	to	a	helicopter,	with	vertical	takeoff	and	vertical	landing,	which	will typ ically	operate	at	altitudes	of	4 00	AGL,	so	an	exemption	may	be	needed	to	allow such	oper ations.	The	UAS	will	never	operate	at	altitude	higher	than	400	AGL	and will	be	in	a	restricted	area	with	security	perimeter,	where	buildings	and	people	will not	be	exposed	to	operations	without	their	pre

- obtained	consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the permission	of	the	property	owner	or	local	officials.	Because	of	the	advance	notice	to the	property	owner	and	any	onsi te	personnel,	all	affected	individuals	will	be	aware of	the	planned	flight	operations.	Compared	to	flight	operations	with	aircraft	or rotorcraft	weighing	far	more	that	the	maximum	10	lbs.	proposed	herein	and carrying	flammable	fuel,	any	risk	associated	with	our	operations	of	the	sUAS	will ensure	separation	between	these	small	UAS	operations	and	the	operations	of conventional	aircraft	that	must	comply	with	Section	91.119.
**14	C.F.R.	91:121:	Altimeter	Settings**

This	regulation	requires	each	person	operating an	aircraft	to	maintain	cruising altitude	by	reference	to	an	altimeter	that	is	set	“..to	the	elevation	of	the	departure airport	or	an	appropriate	altimeter	setting	avail able	before	departure.”	As	the UAS may	not	have	a	barometric	altimeter,	but	instead	a	G PS	altitude	read	out,	an exemption	may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	by	the operator,	pursuant	to	the	Safety	Checklist,	confirming	the	altitude	of	the	launch	site shown	on	the	GPS	altitude	indication	before	flight.

**14	C.F.R.	91 .151	(a):	Fuel	requirements	for	flight	in	VFR	conditions** 
Section	91.151	(a)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR conditions.	Our	UAS	is	limited	to	operations	in	sterile	and	controlled	environments as	outlined	above	and	has	a	limited	r ange	and	flight	time	which	require	an exemption	from	14	CFR	91.151	(a).

The	battery	powering	the UAS	provides	approximately	25 minutes	of	powered flight.	To	meet	the	30	minute	reserve	requirement	in	14	CFR	91.151,	UAS	flights

wou ld	be	limited	to	approxim ately	negative	5 minutes	in	length.	Given	the limitations	on	the	UAS’s	proposed	flight	area	and	the	location	of	its	proposed operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in	daylight	or night	VFR	conditions	is	reasonable.

GET	bel ieves	that	an	exemption	from	14	CFR	91.151	(a)	falls	within	the	scope	of prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to operate	without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a tightly	controlled	area	where	only	people	and	property	owners	or	official representatives	who	have	signed	waivers	will	be	allowed,	with	less	than	30	minutesof	reserve	fuel,	does	not	engender	the	type	of	risks	that	Section	91.151	(a)	was

intended	to	alleviate	given	the	size	and	sp eed	of	the	small	UAS.	Addition ally,	limiting UAS	flights	to	negative	minutes would	greatly	reduce	the	utility	for	which	the exemption	will	be	granted.

An	equivalent	level	of	safety	can	be	ac hieved	by	limiting	flights	to	20 minutes,	or enough	battery	rese rve	to	ensure	that	the	UAS	lands	at	the	ground	station	with	at least	20%	of	battery	power	(as	determined	by	the	onboard	monitoring	system	and the	pilot),	whichever	happens	first.	This	restriction	would	be	more	than	adequate	to return	the	UAS	to	its	planned landing	zone	from	anywhere	in	its	limited	operating

area.
Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions 2689F,	5745,	10673,	and	10808.
**14	CFR	91.203	(a)	&	(b):	Carrying	civil	aircraft	certification	and	registration.**

The	regulation	provided	in	part:

(a)	Except	as	provided	in	91.715,	no	person	may	operate	a	civil	aircraft	unless	it	has within	it	the	following:	(1)	An	appropriate	and	current airworthiness	certificate.... (b)	No	person	may	operate	a	civil	aircraft	unless he	airworthiness	certificate required	by	paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued under	91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is legible	to passengers	or	crew.
The	UAS	fully	loaded	weighs	no	more	than	10	lbs	and	is	operated	without	an onboard	pilot.	Therefore	there	is	no	ability	or	place	to	carry	certification	and registration	documents	or	to	display	them	on	the	UAS.

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the ground	control	point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to them,	to	the	extent	they	are	applicable	to	the	UAS.	The	FAA	has	issued	numerous exemptions	to	this	regulation.	A	representative	sample	of	other	exceptions	includes Exemption Nos.	9565,	9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

**14	CFR	91.405	(a);	407	(a)(1);	409	(a)( 2);	417	(a)	&	(b):	Maintenance**  **I nspections** 
These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft inspected	as	prescribe d	in	subpart	E	of	this	part	and	shall	between	required inspections,	except	as	provided	in	paragraph	©	of	this	section,	have	discrepancies repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or maintain	the	aircraft	in	compliance	with	Part	43.Given	that	these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness

certificate,	these	sections	will	not	apply	to GET

. Maintenance	will	be	accomplished by	the	operator	pursuant	to	the	flight	manual	and	operating	handbook	as	r eferenced in	the	Manual.	An	equivalent	level	of	safety	will	be	achieved	because	these	small UASs	are	very	limited	in	size	and	will	carry	a	small	payload	and	operate	only	in restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise	the	UAS	ca n land	immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	As provided	in	the	Manual,	the	operator	will	ensure	that	the	UAS	is	in	working	order prior	to	initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any maintenance	perf

ormed.	Moreover,	the	operator	is	the	person	most	familiar	with the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to provide	the	equivalent	level	of	safety.

**Privacy** All	flights	will	occur	over	private	or	controlled	access	prop erty	with	the	property owner’s	prior	consent	and	knowledge.		Images	taken	will	of	individuals	who	have also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where aerial	photography	will	take	place.

Satisfaction	of	the	criteria	provi ded	in	Section	333	of	the	Reform	Act	of	2012

– size, weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and operation	within	visual	line	of	sight	and	national	security

– provide	more	than adequate	justification	for	the	grant	o f	the	requested	exemptions	allowing commercial	operation	of	applicant’s	UASs	in	railroad	bridge	inspection	industry.

Sincerely,

Eric	Van	de	Riet Good	Earth	Tools Drone	Intern