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 Administrators,

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 equipped 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 collectively 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 similar to this request has been 

allowed under FAA Exemption No. 11453 dated May 4, 2015.

An exemption from 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 request, 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 this 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. SelectTech 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 Sheet”); 

3) Attachment 3 (“Top Level Drawing”); 

SelectTech GeoSpatial 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 SelectTech GeoSpatial. The EH4 

holds 2 government 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 with 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 speed capability 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 exceed this height, which are 

already considered an obstacle to other aircraft. Operations 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 operations 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 

carry out the Operation commercially using the EH-4. This application includes arguments and 
attachments that will explain how the operation will uphold or exceed current levels of safety, if there is 

a public interest in the operation, 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 the 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 Operation 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 and 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 at the time of the review. The Operation will follow the 

Manual 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 

condition. 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 maintenance 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 the 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 the 
aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. At a 

minimum, the Manual must include the following: 

a. Actuators/servos/motors

b. Transmission (multi rotor) 

c. Power plant (motors) 

d. Propellers 

e. Electronic speed controller 

f. Batteries 

g. Mechanical dynamic components (multi rotor) 

h. Remote command and control 

i. Ground control station 

j. Any other components as determined by either the Manufacturer 

12. The PIC will be certified according to FAA requirements. Because SelectTech GeoSpatial 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 that 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 

controlled space, away from any non-participants by a minimum of 500 feet.

14. Prior to the Operation, the PIC must 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-participant 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 successfully 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 developed 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. The 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 loses 

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 obstacles or emergencies, as 

addressed in the Manual. 

22. Each flight during the Operation will conclude after 30 minutes or at 25% battery power remainingwhichever 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 Operation 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 Manual. 

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 Commission (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 times 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 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.

35. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS 

may not operate 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 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. 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 SelectTech 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: Certification Procedures for Products and Parts This section outlines 

requirements for the issue of design and production approvals, airworthiness certificates, and 

other airworthiness approvals. As outlined in the List of Limitations and Conditions in this 

application, 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 Nnumber 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 aircraft 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 describe 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 inspected. 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 achieved 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 believes 

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 safety, 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 in 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 to 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 4,000 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 down 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 the 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 begin unless 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. Limiting flights to whichever of 20 minute duration or 25% battery life reserve 
comes first should suffice for a high 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 Attachments, 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, because 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 the 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 substations, 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 helicopter 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.

Other 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 over 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 

flights 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 strictly for inspection of the 

equipment. The weight, speed, operating capacity, 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 

SelectTech 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.