31 Manzanita Littleton, CO 80127 USA

303 - 979 - 7773

Page 1 of 5 January 27, 2015 U.S. Department of Transportation, Docket Operations We st Building Ground Floor, Room W1 2 - 140 1200 New Jersey Avenue, SE Wa shington, DC 20590 **Re: Section 333 (Docket does not exist) “Special Rules for Certain Unmanned A** **ircraft Sy** **stems” (under Interim Policy )**  **– Ap**  **plication for Certificate of Waiver for GeoCounsel,**  **Inc.** Note: This application for a certificate of waiver is intentionally kept very short (while h oping to make it interesting), since it is assume d 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 requiremen ts 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 GeoCounse l, 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. Th e 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 tra ining 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 missi on, 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 Ove r the last five years, Mr. Schuch has completed various small -scale photogrammetric projects utilizing hand - held or pole - mounted cameras (no UAS). Example s thereof are the following:

**Example 1: Survey of the volume of very large sand stock piles (not** **e size of SUV)**

**Example 2: A rcheological**  **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 h ave benefited from additional perspective s 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 wish es 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 U AS 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% li ne 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 we ighing 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 ope rator.  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 W iFi 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 b e registered with the FAA prior to any use.  No UAS registered with FAA will be used for private operations or hobbies.  A n irworthiness inspection will be done prior to any single flight and any repairs , which includes the UAS and any ground station equ ipment . **Ty pe of UA** **S** The specific UAS will be identified in the relevant COA application . However, in all cases, the UAS will be of the non -win ged battery-operated copter type (quad, hex, or octo, having four, six or eight propellers). The n ame 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 **Geo** Counsel, Inc. Harold Schuch, PE, CP, LSI President