FAA

Exemption Rulemaking

Section 333

Of The

FAA Reform Act and Part 11

Prepared by

Holly M. LaMantia

January 27, 2016

4195 Sherwood Blvd, Melbourne, FL 32935

Office: 321-960-4599

Cell: 321-960-4021

www.geoimagingtech.com
4195 Sherwood Blvd, Melbourne, FL 32935

O: 321-960-4599 C: 321-960-4021

www.geoimagingtech.com

Attention: United States Secretary of Transportation

Mr. Anthony R Foxx 

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 

(a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a) 

(2); 91.417 (a) & (b)

Dear Mr. Secretary,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 

14 CFR Part 11, Geo Imaging Technologies, LLC, a research developer and operator of Small 

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography for industrial, 

motion picture, agricultural and television industry for scripted closed set filming, hereby applies for 

an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 

of its sUASs (Fixed-wing & Multi-Rotor), so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

1

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) 

limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to 

the already safe operations in the industrial, film, and television production community presently 

using conventional and unmanned aircraft. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333 (c) of the Reform Act.

________________________________________________________________

1

The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-

Issue a Certificate of Waiver for Motion Picture and Television Filming.
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The name and address of the applicant is:

Geo Imaging Technologies LLC

Attn: Holly LaMantia

Phone: 321-960-4599 or 321-960-4021

Email: holly.lamantia@geoimagingtech.com 

Address: 4195 Sherwood Blvd, Melbourne, FL 32935

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)
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Page Three

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of 

the following:

 The UAS’s size, weight, speed, and operational capability:

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers.

Reform Act §333 (a). Lastly, if the Secretary determines that such vehicles “may operate 

safely in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. §333 (c) (emphasis added).

2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any 

sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 

49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

________________________________________________________________

2 Applicant interprets this provision to place of the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions 

herein for the safe operation of the UAS, if it should be determined that the conditions set forth 

herein do not fulfill the statutory requirements for approval.
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Geo Imaging Technologies LLC (GITech), Small Unmanned Aircraft Systems (sUASs) are 

rotorcraft and fixed-wing aircraft, weighing 55 or fewer lbs. including sensor payload. They 

operate their rotorcraft, under normal conditions at a speed of no more than 50 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. They 

operate their fixed-wing aircraft, under normal conditions at a speed of no more than 50 knots 

and primarily have the flight characteristics of traditional airplanes. They will manually operate 

only in VLOS and will operate only within the sterile area described in the Confidential: Flight 

Operations Manual (FOM) attached as Exhibit 1 (hereinafter “the Manual”).

3 Adherence to the 

Manual will insure that the sUAS will “not create a hazard to the national airspace system or 

the public.” 4 

Given the small size and weight of the sUAS involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UASs to commence immediately. Also due to the size of the 

UASs and the restricted areas in which the relevant sUAS will operate, approval of the 

application presents no national security issue. Given the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety, surrounding the proposed operations, and significant public benefit, 

including enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing UASs for movie and television operations, the grant of the requested 

exemptions is in the public interest. Accordingly, the applicant respectfully requests that the 

FAA grant the requested exemption without delay.

________________________________________________________________

3 The Flight Operation Manual is presented as an applicant Confidential document under 14 

CFR 11.35 (b) as the entire manual contains proprietary methods and information that the 

applicant has not and will not share with others. The manual reflects learned experiences, 

methods, operating conditions, and procedures that are not available to the public and are 

protected from release under the Freedom of Information Act 5 USC 552 et.seq.

4 Reform Act Section 333 (b)
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for

at least an equivalent or even higher level of safety to operations under the current regulator

structure because the proposed operations represent a safety enhancement to the already

safe movie and television filming operations conducted with conventional aircraft. These

limitations and condition to which GITech agrees to be bound when conducting

commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and 

aircrew (Spotter / Observer, Camera / Sensor Operator). 

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 

200 feet above an elevated platform from which airborne data collection is planned.

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and Spotter 

/ Observer. In most cases the third aircrew member will serve as the Camera / Sensor 

Operator. 

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate 

and third class medical. The Camera / Sensor Operator and Spotter (Observer) will 

hold at least a third class medical.

7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on 

set (i.e. the Aerial Coordinator), that person can also be designated as PIC.

8. The sUAS will only operate within a confined “Sterile Area” as defined in the Manual. 

Section D of the Manual requires the establishment of a “Security Perimeter” for the 

flight operations areas. 
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Page Six

9. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to 

each day’s production activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for this 

briefing. 

10. The Operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office (FSDO).

11. The Operator will obtain the consent of all persons involved in the filming and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, and 

this radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required by Appendix A.3 of the Manual. With the advanced 

permission of the relevant FSDO, operations at closer range can be approved. 

12. The Operator will submit a written Plan of Activities to the FSDO three (3) days before 

the proposed shoot as required by Section E of the Manual.

13. Pilot, Camera Operator, and Spotter (Observer) will have been trained in operation of 

sUAS generally and received up-to-date information on the particular sUAS to be

operated as required by Section J and Section 2. B of the Manual.

14. Spotter (Observer) and Pilot will at all times be able to communicate by voice and/or 

radio.

15. Written and/or oral permission from the relevant property holders will be obtained.

16. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.
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14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) 

(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement 

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as 

safe, or safer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the Operator, pursuant to safety 

requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements, 

which already apply to civil aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.
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14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted”, “light-sport,” “experimental,” or “provisional,” as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAV, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 

(f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as 

required by §45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAV 

will see the identification of the UAS as “Experimental.” The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations - Pilot in 

Command (PIC)

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level 

of safety of current operations by requiring the PIC operating the aircraft to have a private 

pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with 

no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the Manual. The level of safety provided by 

the requirements included in the Manual exceeds that provided by single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved 

by 14 CFR §61.113 (a) & (b).
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14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance 

and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an 

equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure 

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the 

aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth 

in Sections J and K of the Manual. The PIC will take all actions including reviewing weather, 

flight battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. 
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14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. SUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety 

provided by the fact that aircraft. 

14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a sUAS that is a fixed-wing or rotorcraft requests authority to 

operate at altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, except for the limited conditions stated in the Manual, the UAS will never operate at 

higher than 400 ft. AGL. It will however be operated in restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants 

in the filming activity, all affected individuals will be aware of the planned flight operations as 

set forth in Section K of the Manual. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, 

any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 ft. AGL in the movie industry. In addition, the 

low-altitude operations of the sUAS will ensure separation between these small UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119.
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14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed – (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time frame 

for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that 

Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted.
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Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate return the sUAS to its planned landing zone from anywhere in its limited operating 

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (b) of this section or a special flight authorization issued under §91.715 is displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard Pilot. 

As such, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the Pilot flying the sUAS will have immediate access to them, to the extent 

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. 

A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 

9789A, 9797, 9797A, 9816A, and 10700.
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14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in Part 43 

of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook as referenced in the Manual. 

(See Sections L and Q) An equivalent level of safety will be achieved because these small 

UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 ft. AGL. As provided in the Manual, the operator will 

ensure that the UAS is in working order prior to initiating flight, perform required maintenance, 

and keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. 

*********

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs 

or less) in industrial, motion picture and television operations.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior 

consent and knowledge. Image capture of people will rarely take place, but in the event they 

are, they will have consented prior to being filmed or otherwise have agreed to be in the area 

where data collection will take place. 
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Airborne Image Capture (Day & Night)

It is anticipated that the airborne image capture process will be accomplished in both day and 

night environments. Currently, conventional aircraft are flown in highly populated and/or urban 

areas, with turbine powered helicopters. The grant of this exemption request will provide 

improved safety in both day and night operations. To capture the highest quality of resolution 

the majority of airborne data collections will take place during the 10:00am – 4:00pm window. 

There may be night operations conducted where infrared sensors will be deployed. If such 

operations are required the ground facilities and the subject tower assemblies may require 

additional lighting so that visibility is as though it was conducted during daylight hours. 

Public Benefit

With regard to airborne filming, GITech adheres to all FAA regulations. Furthermore, GITech

airborne teams operate under the principals of: Safety First, Quality Assurance, Accountability, 

Reporting, and Training. When approved by the FAA it is GITech’s mandate to treat all sUAS 

operations the exact same as that of conventional aircraft. 

Approval of exemptions allowing commercial operations of sUASs in the film industry will 

enhance safety by reducing risk. Conventional film operations, using jet or piston powered 

aircraft, operate at extremely low altitudes just feet from the subject being filmed and in 

extreme proximity to people and structures; and present the risks associated with vehicles that 

weigh in the neighborhood of 4,000lbs., carrying large amounts of Jet A or other fuel. Such 

aircraft must fly to and from film location. In contrast, a sUAS weighing fewer than 55lbs and 

powered by batteries eliminates virtually all of the risk given the substantial reduced mass and 

lack of combustible fuel carried on board. The sUAS is typically transported to the location via 

a support vehicle and is never flown to set. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to 

the ground, and in a sterile environment and, as a result, are far safer than ground than 

conventional operations conducted with turbine helicopters operating in close proximity to the 

ground and people. 
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Page Fifteen

The primary market of interest for GITech utilizing sUASs is for the visual inspection of 

telecommunications towers, and land survey. In the cellular tower sector, it is estimated the 

use of sUAS aircraft will reduce hazardous tower climbs by as much as forty percent (40%). 

Aside from reducing the number of physical climbs, the utilization of sUAS will dramatically 

lower the use of cranes and lifts, which also pose dangerous conditions for build and repair 

personnel. In a number of instances, inspectors just need to get “eyes on” the tower top 

assemblies to look for specific deficiencies. With regard to power lines, when climbers are 

sent in, the power must be deferred. The use of sUAS may allow these industries to fill in the 

data gaps where traditional aircraft are currently restricted. In addition, GITech is conducting 

engineering research with local universities and national research labs addressing a number of 

sUAS concerns (i.e., RF shielding, flight control range). 

Summary

Geo Imaging Technologies LLC, a Florida based builder and operator of Small Unmanned 

Aerial Systems, is seeking an exemption pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012.

GITech is requesting exemption from the following regulations under 14 CFR: 

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)
4195 Sherwood Blvd, Melbourne, FL 32935

O: 321-960-4599 C: 321-960-4021

www.geoimagingtech.com

January 27, 2016

Page Fifteen

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s sUAS in the 

industrial, motion picture and television production industry pursuant to the Manual appended 

hereto. GITech is eagerly standing by to support the FAA and sUAS community in its quest to 

establish proper regulations and protocols for the safe introduction of unmanned aircraft into 

the national airspace. 

Sincerely,

Holly LaMantia

President

Geo Imaging Technologies LLC