GrandView Services, LLC

Helleren Gregory

208 Sequoia Ave.

Walnut Creek, CA 94595

925­932­6305

heller@grandview.biz

GrandView Services, LLC is filing a petition for exemption with the FAA regarding Title 14 of the Code of Federal

Regulations (CFR). We are seeking exemptions from the following items in the FAR/AIM rules and procedures:

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) &

(b) concerning commercial operation of the 3D Robotics Iris+ and additional UAS’s purchased for the business of

collecting data for civil and geotechnical engineering, environmental management, and infrastructure asset

management and maintenance. This is pursuant to section 333 of the FAA modernization and reform act of 2012

(Public law 122­95).

GrandView is seeking relief of the following in effort the use of UAS’s for commercial purposes. Operated initially by

private pilot and PIC Ms. Helleren Gregory for the purposes of high resolution digital modeling and surveying in the

applications of civil and geotechnical engineering, environmental management, and infrastructure asset management

and maintenance.

This request would benefit the practice of civil and geotechnical engineering, civil engineering construction, including

landslide identification and monitoring, real­time access to earthquake damaged areas, time lapse data collection for

management and maintenance of federal, state, and local infrastructure assets including levees, roads, and

waterways, and time lapse data collection for evaluation and management of environmental restoration. Geospatial

data collection for use in these applications enhances public safety and allows for better management of critical

infrastructure and environmental assets.

GrandView will currently use the services of PIC Helleren Gregory to ensure safety at job sites. Future UAV pilots will

go through the training and testing as deemed appropriate by the FAA, including both written and practical tests that

will apply. Ms. Gregory has taken the written knowledge test within the two year recent proposed time limit of the

FAA written test taken and passed in June, 2014.

GrandView is seeking exemption from the rules noted below. For clarity the specifics of our request are indicated in

italics.

61.113 Private pilot privileges and limitations: Pilot in command.

(a)​Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate

may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, for compensation or hire, act as pilot in command of an aircraft.

(b)​A private pilot may, for compensation or hire, act as pilot in command 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.

(c)​A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers,

provided the expenses involve only fuel, oil, airport expenditures, or rental fees.
61.113(a) Requirement for certificates, ratings, and authorized

Pilot certificate. ​No person may serve as required pilot flight crew member of a civil aircraft of the United States,

unless that person ­

1. Has a pilot certificate or special purpose pilot authorization issued under this part in that person’s physical

possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or

authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that

country may be used; and

2. Has a photo identification that is in that person’s physical possession or readily accessible in the aircraft

when exercising the privileges of that pilot certificate or authorization. The photo identification must be a :

i. Driver’s license issued by a State, the District of Columbia, or territory or territory or possession of the United

States:

ii. Government identification card issued by the Federal government, a State, the District of Columbia, or a

territory or possession of the United States;

iii. US Armed Forces’ identification card;

iv. Official passport;

v. Credential that authorizes unescorted access to a security identification display area at an airport regulated

under 49 CFR part 1542; or

vi. Other form of identification that the Administrator finds acceptable.

The request of this exemption is to use a private pilot license for profit, only on UAV vehicles. The exemption will not

include single engine planes. Rule 61.113 will still apply to SEL planes in this request.

(b) Required pilot certificate for operating a foreign­registered aircraft. ​No person may serve as a required pilot

flight crew member of a civil aircraft of foreign registry within the United States, unless that person’s pilot certificate —

1. Is in that person’s physical possession, or readily accessible in the aircraft when exercising the privileges of

that pilot certificate; and

2. Has been issued under this part, or has been issued or validated by the country in which the aircraft is

registered.

91.7 Civil aircraft airworthiness:

a. No person may operate a civil aircraft unless it is in an airworthy condition

b. The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for

safe flight. The pilot in command shall discontinue the flight when un­airworthy mechanical, electrical, or

structural conditions occur.

Currently, there is no registration process for UAS vehicles. The PIC of UAS will perform the required checklist to

determine whether it is safe for flight. If registering a UAS in the future is a requirement, GrandView will comply.

If necessary, GrandView will apply for a special airworthiness certificate in the experimental category under Title 14

of the Code of Federal Regulations (14 CFR) § 21.191 for the purposes of research and development, crew training,

or market survey. We will also apply for type certification under § 21.17(b) (for a standard airworthiness certificate in

the special class category) or § 21.25 (for a special airworthiness certificate in the restricted category).

91.121 Altimeter settings.

a. Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the

case may be, by reference to an altimeter that is set, when operating —

1. Below 18,000 feet MSL, to —

i. The current reported altimeter setting of a station along the route and within 100 nautical miles of the

aircraft;
ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported

altimeter setting of an appropriate available station; or

iii. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate

altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92” Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation.

(c) To convert minimum altitude prescribe under 91.119 and 91.177 to the minimum flight level, the pilot shall take the

flight level equivalent of the minimum altitude in feet and add the appropriate number of feet according to the current

reported altimeter setting:

GrandView will comply with the height and weight requirements proposed by the FAA on February 15, 2015 or as

modified in the future.

91.151 (b) Fuel requirements for flight in VFR conditions

Battery operated flight time of ten minutes for 3DR Iris+ UAS. UAS will be flown in accordance with line of sight and

weather minimums designated for UAS’s as proposed by the FAA on February 15, 2015 or as modified in the future..

91.405(a), Maintenance required

GrandView seeks exemption from maintenance required of a single engine plane. We will comply with manufacturer

recommended maintenance and maintenance as required of a UAS by the FAA when that is mandated.

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding or alteration

a. No person may operate aircraft that has undergone maintenance, preventive maintenance, rebuilding, or

alteration unless —

1. It has been approved for return to service by a person authorized under 43.7 of this chapter

91.409(a)(1) & (a)(2) Inspections

a. Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the

preceding 12 calendar months, it has had—

1. An annual inspection in accordance with part 43 of this chapter and has been approved for return to service

by a person authorized by 43.7 of this chapter.

2. An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No

inspection performed under paragraph (b) of this section may be substituted for any inspection required by

this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as

an “annual” inspection in the required maintenance records.

91.417(a) & (b) ­ Maintenance records

GrandView requests exemption from UAS annuals and inspections by an FAA authorized mechanic. Maintenance

and airworthiness will be performed either by the UAS manufacturer or by the dealer of the UAS. General

maintenance will be performed by the UAS PIC to ensure all precautions and checklists have been performed prior to

UAS flight.

GrandView Services, LLC will comply with all aspects of currently proposed and future FAA rulings. We feel that the

use of UAS’s in the engineering fields noted will enhance data collection for existing sites and for monitoring of site

conditions following natural disasters. We will operate specifically in this field, making the services available to
private engineering and consulting firms and public agencies who would like to focus on the engineering aspects and

not file for their own exemptions or create another data collection division of their current business or agency.

We understand that the currently proposed FAA rules are as follows:

• A small UAS operator must always see and avoid manned aircraft. If there is a risk of collision, the UAS

operator must be the first to maneuver away.

• The operator must discontinue the flight when continuing would pose a hazard to other aircraft, people or

property.

• A small UAS operator must assess weather conditions, airspace restrictions and the location of people to

lessen risks if he or she loses control of the UAS.

• A small UAS may not fly over people, except those directly involved with the flight.

• Flights should be limited to 500 feet altitude and no faster than 100 mph.

• Operators must stay out of airport flight paths and restricted airspace areas, and obey any FAA Temporary

Flight Restrictions (TFRs).

Helleren Gregory is current with these proposed regulations in operations regarding limitations in Class A,B,C, & D

airspace along with weather minimums for safe flight. GrandView will have current charts along with access to

DUATS, an AOPA membership, and TFR notifications before UAV flight.