31 Manzanita

Littleton, CO 80127 USA

303-979-7773

 Page 1 of 5

January 27, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Section 333 (Docket does not exist) “Special Rules for Certain Unmanned Aircraft 

Systems” (under Interim Policy) – Application for Certificate of Waiver for GeoCounsel, 

Inc.

Note: This application for a certificate of waiver is intentionally kept very short (while hoping to 

make it interesting), since it is assumed that there are many such applications. In addition, no 

legal counsel was retained for this, given the size of the petitioning company. 

Introduction

GeoCounsel, Inc. seeks exemption from the requirements of 14 C.F.R §§ 91.151(a)(1), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned 

Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit GeoCounsel, Inc. to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial acquisitions and research over certain 

rural areas of the United States. GeoCounsel, Inc., is a duly registered Colorado Corporation, 

100% US owned. 

The petitioner, GeoCounsel, Inc., is a two-man company that has been dedicated to aerial 

mapping since 1993. It has performed consulting services in photogrammetry and geodesy for 

very large regional mapping projects, while leaving the flying to contractors. GeoCounsel’s 

owner and operator, Harold C. Schuch (the undersigned), is a Professional Engineer (Civil, 

active, Colorado, #22302) and a Certified Photogrammetrist (ASPRS, active, #R582). Apart 

from consulting, GeoCounsel provides corporate employee training in the above sciences, and 

performs research for various private sector groups. 

Privacy and confidentiality

As described below, the UAS will not be used in public places, but only in private sites. No 

public will be present. Prior to each mission, the following will be done: 

 Any person present will be informed when a flight will take place, where the camera will be 

pointing, and what the flight path and duration will be. 

 The mission is discussed with the client to determine if there are any objects present that 

should not be photographed, such as commercially sensitive detail. This detail will not be 

photographed. 

 The work always involves objects, and not people. 
31 Manzanita

Littleton, CO 80127 USA

303-979-7773

 Page 2 of 5

Over the last five years, Mr. Schuch has completed various small-scale photogrammetric 

projects utilizing hand-held or pole-mounted cameras (no UAS). Examples thereof are the 

following: 

Example 1: Survey of the volume of very large sand stock piles (note size of SUV)

Example 2: Archeological orthomap of Dinosaur Ridge, Morrison, Colorado
31 Manzanita

Littleton, CO 80127 USA

303-979-7773

 Page 3 of 5

Example 3: Large excavation mapping, in this case 800 feet by 1,100 feet

All this work represents a bona-fide application of photogrammetry to engineering work. In 

addition, GeoCounsel’s activities have included the processing of images taken by others, as 

the following example illustrates: 

Example 4: Roof Survey, Samford Hall, Auburn University (perspective view created in CAD)

All these projects would have benefited from additional perspectives that are provided by an 

UAS-mounted camera. 
31 Manzanita

Littleton, CO 80127 USA

303-979-7773

 Page 4 of 5

Conditions of operation

GeoCounsel wishes to pursue similar projects for mining operations that would, in part, utilize 

an UAS. Since this will include various sensors, various commercial mining interests already 

have expressed an interest in the results of this research, therefore already promising 

economic benefits. 

In each and every case the following will apply for all operations (maybe you will get some 

ideas from this): 

 A flying height of less than 250 feet from the surface in question. In no case will the flying 

height be greater than 400 feet from any ground point (including the upper rim of 

excavations)

 Keeping the UAS at a horizontal distance of less than 200 feet 100% of the time. 

 All operations at line of sight 100% of the time, with the ground-based operator in control at 

all times. 

 All operations during visual meteorological conditions that allow this 100% line of sight rule. 

 Only perform operations when wind is less than 5 miles per hour, as indicated on a wind 

speed monitor installed next to the operator. 

 All operations are done only during full daylight. 

 No operations above people, or within 500 feet from any non-operating people, sensitive 

areas (power stations, etc.), power lines, explosives, equipment, etc. (also obeying all 

OSHA regulations). 

 No operations at less than 50% of battery power, as indicated by a ground-based display. 

 Operating only lightweight craft weighing less than 30 lbs with all equipment. 

 Flying the craft in such a way that, at all times, only safe territory is crossed. 

 Everyone’s privacy is respected at all times.

 Flight operations will be posted on a sign next to the operator. 

 The UAS will have strong strobe lights. 

 No operations / flights will be done with UAS using gasoline or other combustible materials. 

 Maximum UAS speed will be 10 miles per hour. 

 No operations will be done at, in, or near airports, within a five mile radius from any airport’s 

geographic center, or within one mile from the boundaries of any Federal installations. 

 No radio communications with air traffic control will be undertaken, or otherwise interfered 

with. 

 All radio communications with the UAS will be WiFi or Bluetooth based, therefore being of a 

short distance. 

 Only launch an UAV after a safe landing space has been identified. 
31 Manzanita

Littleton, CO 80127 USA

303-979-7773

 Page 5 of 5

 No operations will be done for the benefit of a public, and none will be present. 

 Any and all UAS will be registered with the FAA prior to any use. 

 No UAS registered with FAA will be used for private operations or hobbies. 

 An irworthiness inspection will be done prior to any single flight and any repairs, which 

includes the UAS and any ground station equipment. 

Type of UAS

The specific UAS will be identified in the relevant COA application. However, in all cases, the 

UAS will be of the non-winged battery-operated copter type (quad, hex, or octo, having four, 

six or eight propellers). 

The name and address of the petitioner and point of contact are: 

Harold C. Schuch

GeoCounsel, Inc.

31 Manzanita

Littleton, CO 80127

303-979-7773

hschuch@geocounsel.com

Respectfully submitted by

GeoCounsel, Inc.

Harold Schuch, PE, CP, LSI

President