Applicant Name and Contact Information:

SelectTech GeoSpatial LLC Attn: Frank J. Beafore, Executive Director
1251 West Blee Road Springfield Beckley Airport (SGL) Springfield, Ohio 45502

937

- 398

- 0313 fbeafore@sgamf.com September 20, 2015

Exemption Request Pursuant to Section 333 of FAA Reform Act Part 11 of FAA Regulations 14 C.F.R. 21; 45.23(b); 61.113(a) & (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b)

Dear FAA A dministrators,

Pursuant to Section 333 of the Federal Aviation Administration Reform Act of 2012 and 14 Code of Federal Regulations Part 11 (“Regulations”), SelectTech GeoSpatial LLC, (“SelectTech GeoSpatial”) operator of SelectTech GeoSpatial’s EH

- 4 Unmanned Aerial System (“UAS ”) will perform operations involving the use of sensors equ ipped to the UAS to test with :

1) Utility infrastructure and equipment including substations, transmission towers, distribution towers, pipelines, flare stacks, and other industrial equipment; 2) wind turbine blades and other structural aspects of wind farms; 3) Solar power panels; 4) Vegetation and line clearance for tree trimming near the infrastructure stated above; 5) Antenna towers / cellphone towers for safety.

Herein referred to colle ctively as “the Operation”, applies for exemption from the following Regulations:

1) 14 C.F.R. 21; 2) 14 C.F.R. 45.23(b); 3) 14 C.F.R. 61.113(a) & (b); 4) 14 C.F.R. 91.119(c); 5) 14 C.F.R. 91.121; 6) 14 C.F.R. 91.151(a); 7) 14 C.F.R. 91.405(a); 8) 14 C.F.R. 91.407(a)(1) & (2);9) 14 C.F.R. 91.409(a)(1) & (2);

10) 14 C.F.R. 91.417(a) & (b).



### An exemption for the EH

- 4 and operations are very sim ilar to this request has been allowed under FAA Exemption No. 11453 dated May 4, 2015.

An exemption f rom the listed Regulations is requested to allow commercial activity of the Operation utilizing the UAS to be performed by SelectTech GeoSpatial. The Operation will only be conducted by SelectTech GeoSpatial with the use of the UAS as outlined in this requ est, with procedures documented in the attached proprietary documentation (“Attachments”) or what may be established by the FAA if an exemption were granted under Section 333 or Section 49 of the United States code § 44701(f).

The conditions listed in t his application, set forth by SelectTech GeoSpatial, are drafted following exemptions and guidelines drafted by the FAA to maintain the highest level of safety, either maintaining or exceeding current safety standards, practices, and regulations. SelectTec h GeoSpatial applies for an exemption to provide a safer method of the Operation compared to manned aircraft and manned ground inspections. The Operation will be conducted in a limited space with limited, approved access.
Section 333 of the FAA Reform Act of 2012 grants authority to the FAA to issue exemptions based on the safety of the Operation and the UAS with established requirements set out by both the application and exemption granted for the Operation. The Attachments to this request are considered proprietary. We ask that you request these documents separately from the public accessible website. Each attachment is numbered and will each hereinafter referred to as the following:

1) Attachment 1 (“The Manual”);

2 ) Attachment 2 (“Specification Shee t ”); 3) Attachment 3 (“Top Level Drawing ”);

SelectTech GeoSpat ial is a UAV design and build company who will perform each task within the Operation for these tests and services. The EH

- 4 UAS is manufactured by Selec tTech GeoSpatial. The EH4 holds 2 gove rnment Certificates of Authorization (COA) with Ohio DOT and one 333 waiver with US
Aerobotix. The EH

- 4 is a Vertical Take Off and Landing (“VTOL”) rotorcraft wit h four rotors and weighs
less than 6 lbs., including the payload. The airframe is constructed from G

- 10 fiberglass reinforced polyester resin, which can withstand rough landings and challenging environments. Additionally, the construction of the airframe and the components and hardware greatly reduce the conductivity of the
UAS. The s peed capabili ty of the UAS is 50 knots; however the Operation is intended to travel no more than 35 knots, both vertically and horizontally. The structures SelectTech GeoSpatial intend to include in the Operation stand below 400 feet AGL. However, some structures do ex ceed this height, which are already considered an obstacle to other aircraft. Operation s will include a Pilot

- in

- Command (“PIC”) and Visual Observer (“VO”), operating lower than 400 feet AGL (unless approval is granted on a case

- by

- case basis for special o perations involving taller structures), will stay well within Visual Line of Sight (“VLOS”), and cause no hazard to any users of the national airspace or the public. The Manual details the safety standards of SelectTech GeoSpatial, the safety redundancies of the UAS, and mitigate how SelectTech GeoSpatial will help in establishing requirements for safe operation in the national airspace system (“NAS”).

As granted to the FAA by Section 333 of the Reform Act, SelectTech GeoSpatial asks for an exemption to

c arry out the Oper ation commercially using the EH

- 4 . This appl ication includes arguments anda ttachm ents that will explain how the o peration will uphold or exceed current levels of safety, if there is

a public interest in th e o peration, and steps taken to ensure national security remains a priority. Reviewing Exemption 11062 granted by the FAA to the movie industry, SelectTech GeoSpatial will operate with similar limitations and conditions, which will be referred to later in th e application. This will ensure a high level of safety already approved by the FAA and hold SelectTech GeoSpatial accountable for how the operation is conducted. The List of Limitations and Conditions are already addressed throughout the Manual, and are as follows:

1. The UAS described in this application, including all payloads , must weigh less than 20 lbs.

2. The UAS will not exceed 35 knots during the Operation, and no more than 50 knots in transitional airspace.

3. The Operation will be conducted less than 400 feet AGL and reported to Air Traffic Control (“ATC”). If a structure exceeds this height restriction, the PIC must obtain approval from the FAA to perform the operation in a limited capacity.

4. The Operat ion will be conducted in VLOS for the PIC at all times, regardless of the VO orientation. The PIC and VO must only use natural eyesight, aided only by corrective lenses or glasses, to meet this requirement and hold an FAA medical certificate.

5. The VO a nd PIC will maintain verbal communication at all times.

6. The Manual attached to this application binds SelectTech GeoSpatial to the limitations outlined within, as approved by the FAA. If the FAA imposes other limitations or conditions, the Manual will be revised to include such revisions. A copy of the Manual and any other documentation requested by the FAA will remain available at all times. If for any reason a change was not amended in the Manual, the
new limitations and conditions will be followed a t the time of the review. The Operation will follow the

M anual at all times.

7. A report will be attached to the Manual logging all revisions and changes to the Manual.

8. If a revision would change the Operation and potentially require a new revision, it is the responsibility of SelectTech GeoSpatial to contact the FAA UAS Integration Office (AFS

- 80) with all questions regarding
the revisions.

9. The PIC must inspect the UAS and Ground Control Station (“GCS”) before each flight to ensure a safe
condi tion. If the PIC determines the condition to be unsafe, the aircraft will not perform the Operation and undergo the necessary maintenance required to perform a safe flight. A report of all maintenance performed will be included in the Manual.

10. If main tenance or alterations are made that affect the flight characteristics of the UAS, the PIC must perform a functional test flight. Procedures for these test flights are outlined in the Manual. These test flights must be logged into the flight records for th e UAS and added to the Manual.

11. SelectTech GeoSpatial will follow the Manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. The Manual also outlines theaircraft/component, maintenance, ove rhaul, replacement, inspection, and life limit requirements. At a

minimum, the Manual must include the following:

a. Actuators/servos /motors
b. Transmissi on (multi rotor)

c. Power plant (motors) d. Propellers e. Electronic speed controller
f. Batter ies g. Mecha nical dynamic components (multi rotor)
h. Remote command and control
i. Ground control station j. Any other components as determined by either the Manuf acturer

12. The PIC will be certified according to FAA requirements

. Because SelectTech GeoSpat ial is the designer and builder of the EH

- 4, we believe that the training and certification program outlined in the Manual is sufficient and could replace the Private Pilot Certificate requirement, upon the FAA’s approval.

13. Prior to field Operation, the PIC must have accumulated 50 flight cycles and /or 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience th at was obtained in compliance with applicable regulations will be used to satisfy this requirement. Training, proficiency, and experience

- building flights will be used with the UAS to accomplish these requirements. The training will be conducted in a

contr olled space, away from any non

- participants by a minimum of 500 feet.

14. Prior to the Operation, the PIC mu st have accumulated and logged a minimum of five hours as UAS pilot operating the make and model of the UAS in this application for the use of the Operation and three
take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and
take

- off and landing currency flights will be conducted to accomplish these requirements; during these trainings, any non

- participan t must remain at least 500 feet away from the training area.

15. The PIC and VO of the Operation must successfully complete a qualification process outlined in the Manual. SelectTech GeoSpatial has developed a test included in the Manual to be successful ly passed by all PIC and VO personnel before the Operation. A record of completion of this qualification process will be documented and made available to the Administrator upon request.

16. Prior to the Operation, a flight demonstration, administered by a SelectTech GeoSpatial

- approved and qualified pilot must be successfully completed and documented. The documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been develop ed by SelectTech GeoSpatial, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designed examiners, SelectTech GeoSpatial will conduct these tests in accordance with the Manual.17. The UAS will not be operated directly over any person, except authorized and consenting personnel

necessary to the Operation, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

18. T he Manual establishes safety parameters for participating persons who are authorized and consenting. These persons will be essential to the Operation.

19. The Operation will be conducted no closer than 500 feet away from non

- participating persons,
except those consenting to allow the Operation closer, in which case the Operation will be no less than 200 feet away from consenting non

- participating persons.

20. As addressed in the Manual as a part of the preflight inspection, in the event that the UAS los es communications or Global Positioning System (GPS) signal, the UAS will be programmed to return to the

pre

- determined location within the security perimeter and land or be recovered.

21. The UAS is equipped to abort flight in the event of unpredicted o bstacles or emergencies, as
addressed in the Manual.

22. Each flight du ring the Operation will conclude after 30 minutes or at 25% battery power remaining

whichever occurs first.

23. SelectTech GeoSpatial must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations. The COA will also require SelectTech GeoSpatial to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the Operati on unless otherwise required by FAA.

24. All aircraft used for the Operation 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.

25. SelectTech GeoSpatial must document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures are outlined in the Manu al.

26. Each UAS used in the Operation must comply with the Manufacturer’s Safety Bulletins.

27. SelectTech GeoSpatial includes technician qualification criteria in the Manual.

28. The preflight inspection procedures in the manual include inspecting and accounting for all discrepancies, logging all maintenance, and reviewing each mission prior to execution.

29. Before the Operation, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Com mission (FCC) or other appropriate government oversight agency requirements. Details of this adherence are in the Manual.

30. The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the PIC at the
Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.31. The UAS will remain clear and yield the right of way to all other manned operations and activities at

all ti mes for all reasons (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

32. The UAS will not operate during night, as defined in 14 C.F.R. § 1.1. All operations will be conducted
under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be
conducted.

33. The UAS will only be operated by the PIC from a stationary position and not in a moving device or
vehicle. 34. The UAS will not be operat ed 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.

35. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS
may not o perate within 5 nautical miles of the geographic center of a non

- towered airport 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.

36. Any incident, accident, or flight operation that transgresses the lateral or vertical bounda ries 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 NTS B Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided.

The following section will describe the extent of relief Sel ectTech GeoSpatial seeks in each section of 14 C.F.R. requested, as well as reasons why the exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to the existing rule:

1) 14 C.F.R. 21: Certificati on Procedures for Products and Parts This section outlines requirements for the issue of design and production approvals, airworthiness certificates, and other airworthiness approvals . A s outlined in the List of Limitations and Conditions in this applicati on, as well as all of the Attachments to this application, including the Manual, SelectTech GeoSpatial seeks to uphold the same level or exceeded level of safety as described in
Part 21 of 14 C.F.R.

2) 14 C.F.R. 45.23(b): Display of Marks SelectTech GeoSpatial is aware that if an airworthiness certificate is issued as part of the exemption that this particular rule would not be necessary to request an exemption. The UAS described in this exemption is of a small size, but as the List of
Limitations and Conditions #24 outlined in this application, we will satisfy the display of the N

number on the aircraft, as large as applicable. The UAS will be registered and have appropriate markings to determine the responsible party of the flight if a loss of the ai rcraft does occur. This condition offers accountability for the PIC and SelectTech GeoSpatial to ensure the utmost safety during the Operation.3) 14 C.F.R. 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command

- these

sections desc ribe the limits of private pilots for non

- commercial operations. The UAS is controlled remotely by the PIC during the Operation. The area of the Operation is a controlled space with granted permission by the client who owns the infrastructure being inspect ed. There

is maximum approach distances explained in the Manual, as well as signage and warnings for
those non

- participants who are not trained on safety near the infrastructure. Therefore, the risk of harming non

- participants is low, since their presence is often non

- existent in the space near the infrastructure. Due to the nature of the Operation, which does not involve the carrying of persons (pilots, passengers, or otherwise), SelectTech GeoSpatial believes the same or exceeded level of safety can be ac hieved if the PIC had either a private or commercial pilot license. As the FAA has stated in Exemption 11062, the required areas of knowledge for a commercial versus private pilot cover the same fundamental principles. SelectTech GeoSpatial strongly believ es that it is in the best interest of the FAA to provide a means of certification for UAS specifically. Within the provided Manual and other Attachments, SelectTech GeoSpatial has detailed a process for training personnel that will uphold a high level of s afety, especially near areas with little collision risk, air traffic, and population.

4) 14 C.F.R. 91.119(c): Minimum Safe Altitudes: General; Over other than congested areas As noted in previous exemptions, since the airspace used for the Operation is i n a controlled environment surrounding the infrastructure of electrical equipment, SelectTech GeoSpatial will already operate in accordance with most of 91.119. The key exemption sought in 91.119(c) is in regard to the altitude of, “...closer than 500 feet t o any person, vessel, vehicle, or structure.” Since we must be near the structure of the equipment being inspected for the Operation, and closer to consenting non

- participants and participants, an exemption from this rule is desired. The Operation will be below 400 feet AGL, as stated in the List of Limitations and Conditions #3, unless permission is granted by the FAA for anything higher. Regarding the speed and size of the UAS for the Operation, and how similar rules were passed for aircraft exceeding 4,0 00 lbs, this exemption will not endanger any persons, structures, or other aircraft. The conditions offered in this application, along with the rules and exemptions already passed by the FAA will still account for safety as the most paramount consideration in seeking exemption from this particular rule.

5) 14 C.R.R. 91.121: Altimeter settings Exemption from this rule is only sought due to the wording used within the rule. The UAS is equipped with a digital telemetric data feed of the
barometric altitude d own to the Ground Control Station, instead of a traditional altimeter onboard the aircraft. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the PIC. Further description of the altimeter technology is described in the Manual. This will maintain the safety intended by 91.121 with respect to t he remote operation of the UAS.

6) 14 C.F.R. 91.151(a): Fuel requirements for flights in VFR conditions the first part of this rule states that a flight may not be gin unles s there is enough fuel to fly 20 minutes after approximate arrival to landing. The battery used for the EH

- 4 lasts approximately 30 minutes after fully energized and with little payload. Given the technical limitations of the flight length of the UAS, and the proposed safety measures explained in the List of Limitations and Conditions #22, a longer time frame for flight in daylight VFR conditions is safe. Other exemptions passed by the FAA were granted the same exemption due to the same limitations . Any risk being mitigated by this rule for other aircraft is alleviated by the nature of the aircraft for the Operation in this application. Lim iting flights to whichever of 20 minute duration or 25% battery life reservecomes first should suffice for a h i gh level of safety. Note that battery life is a function of payload

and flights will be adjusted accordingly

– always having 25% battery life available for return to
base.

7) 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1) & (2); 14 C.F.R. 91.409(a)(1) & (2) ; 14 C.F.R. 91.417(a) & (b): Maintenance and Inspections All of these regulations require aircraft operators and owners to inspect aircraft as required by subpart E and must, between inspections, unless otherwise stated in paragraph (c), have discrepancies repaired as prescribed in Part 43. Because Part 43 applies only to aircraft with an airworthiness certificate, these sections will not apply. However, as stated in the List of Limitations and Conditions of this application, as well as the
other Attachment s, supporting documents, and the Manual, maintenance will remain to be an important part of the Operation. The UAS is very nimble and can be repaired very quickly, even on the field during the Operation. If mechanical issues do pass preflight inspection, b ecause of the limited airspace and AGL of the Operation, a failure will not result in loss

- of

- life or put anyone in significant danger, as long as the Limitations and Conditions, the procedures outlined in the Manual, and any other conditions offered by th e FAA are strictly followed. A log of all maintenance will be kept in the manual and made available to the Administrator any time it is requested.

SelectTech GeoSpatial applies for this exemption with the intention of performing the Operation safely
and in the best interest of the public. Please review the Attachments provided as a part of this exemption. The ultimate goal of SelectTech GeoSpatial service is to provide a method of testing sensors
in used in the inspection for utility lines, towers, and su bstations, solar generating panels, wind generating farms, and any other infrastructure or equipment in use by the power industry.

Solar energy farms often require infrared inspections. This process is time consuming and potentially dangerous for a helic opter at low altitudes. The risk of flight failure can result in loss of power to thousands of consumers, and a high risk for injury for the pilot. A small UAS, outfitted with the same payload, can accomplish the task much more safely and efficiently.

Ot her Operations may include flare stacks and other larger industrial infrastructure. For these Operations, aircraft that currently perform the inspection already seek approval from the FAA prior to inspection. Additionally, because these flights are often o ver facilities that have personnel, SelectTech GeoSpatial will greatly reduce the risk of injury or death to personnel involved in these inspections.

The Operation is focused on a closed environment without any risk to personnel. Transitions between flig hts do not require the use of airspace, as the UAS is carried to the desired area before it is flown. Any data collected during the Operation will be handed to the client and used s trictly for inspection of the equipment. The weight, speed, operating capac ity, proximity to persons and structures, and the Limitations and Conditions expressed in this application, supplemented by the Manual and all other Attachments will be used to prove the safety of the NAS with respect to the Operation performed by
SelectTe ch GeoSpatial using the UAS. This is considered to be adequate information to fulfill the necessary requirements of obtaining an exemption for commercial use of UAS by SelectTech GeoSpatial granted to the FAA in Section 333 of the Reform Act of 2012.